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Environmental Protection Agency (“EPA”) to evaluate our heat recovery coke oven technolog y as a basis for establishing Maximum Achievable Control Technology (“MACT”) standards for new cokemaking facilities.
−Removed: In addition, each of the four cokemaking facilities that we have built since 1990 has either met or exceeded the applicable Best Available Control Technology (“BACT”), or Lowest Achievable Emission Rate (“LAER”) standards, as applicable, set forth by the EPA for cokemaking facilities at that time.
+Added: In addition, each of the four cokemaking facilities that we have built since 1990 has either met or exceeded the applicable Best Available Control Technology (“BACT”), or Lowest Achievable Emission Rate (“LAER”) standards, as applicable, set forth by the EPA for cokemaking facilities.
We have constructed the only greenfield cokemaking facilities in the U.S.
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Granite City Granite City, Illinois 2009 Steam for power generation 120 650 U.S.
−Removed: Steel December 2024 Capacity
+Added: Steel June 2025
Indiana Harbor East Chicago, Indiana 1998 Heat for power generation 268 1,220 Cliffs Steel September
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( “ Algoma Steel ” ).
+Added: (4) Non-contracted blast coke produced utilizing capacity in excess of that reserved for the long-term, take-or-pay agreement is sold into the export and North American spot coke markets.
+Added: (5) In October 2024, the Granite City long-term, take-or-pay agreement with U.S.
+Added: Steel was extended through June 30, 2025, with an option for U.S.
+Added: Steel to extend for an additional six months.
+Added: Under the terms of the extension, Granite City will operate at a turn-down capacity, supplying 295 thousand tons of coke to U.S.
+Added: Steel during the initial six-month term.
+Added: See further discussion in “ Management's Discussion and Analysis Financial Condition and Results of Operations.
(6) Under the long-term, take-or-pay agreement with Cliffs Steel, Jewell and Haverhill I supply a combined 400 thousand tons annually through 2025.
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As a result, our ability to produce the contracted coke volume is a key determinant of our profitability.
−Removed: Our domestic capacity is largely consumed by these long-term agreements, which do not have exposure to the fluctuations in domestic spot prices for blast furnace coke.
+Added: Our domestic capacity is largely consumed by these long-term agreements, which do not have exposure to the fluctuations in domestic and global spot prices for blast furnace coke.
Our long-term, take-or-pay coke sales agreements contain pass-through provisions for costs we incur in the cokemaking process, including coal and coal procurement costs, subject to meeting contractual coal-to-coke yields, operating and maintenance expenses, costs related to the transportation of coke to our customers, taxes (other than income taxes) and costs associated with changes in regulation.
−Removed: When targeted coal-to-coke yields are achieved, the price of coal is not a significant determining factor in the profitability of these facilities, although it does affect our revenue and cost of sales for these facilities in approximately equal amounts.
+Added: When targeted coal-to-coke yields are achieved, the price of coal is not a significant determining factor in the profitability of our long-term, take-or-pay coke sales agreements, although it does affect our revenue and cost of sales for these facilities in approximately equal amounts.
However, to the extent that the actual coal-to-coke yields are less than the contractual standard, we are responsible for the cost of the excess coal used in the cokemaking process.
−Removed: Conversely, to the
−Removed: extent our actual coal-to-coke yields are higher than the contractual standard, we realize gains.
+Added: Conversely, to the extent our actual coal-to-coke yields are higher than the contractual standard, we realize gains.
As coal prices increase, the benefits associated with favorable coal-to-coke yields also increase.
36 unchanged sentences
We believe we are well-positioned to compete with other coke producers.
−Removed: In recent years, our Domestic Coke segment has accounted for approximately 37 percent of the U.S.
+Added: In recent years, our Domestic Coke segment has accounted for approximate ly 38 percent of the U.S.
blast furnace coke market capacity.
3 unchanged sentences
Our technology also allows us to produce heat that can be converted into steam or electrical power.
−Removed: We monitor the development of competing technologies carefully.
−Removed: In recent years, steelmakers have begun to explore alternatives to blast furnace technology that require less or alternatives to coke, such as electric arc furnaces.
+Added: We monitor the development of competing technologies carefully, such as steelmakers' growing use of electronic arc furnaces as an alternative to blast furnace technology, which requires less or alternatives to coke.
We also monitor ferrous technologies, such as direct reduced iron production, as these could indirectly impact our blast furnace customers.
−Removed: During 2023, economic uncertainty, driven by inflation and commodity pricing volatility, resulted in declines in the price of global export coke, reducing the sales price of our non-contracted blast coke.
−Removed: All non-contracted blast coke is produced utilizing capacity in excess of that reserved for long-term, take-or-pay Domestic Coke sales agreements, which largely consume our capacity and are not impacted by the fluctuation of coke prices.
+Added: During 2024, our domestic coke plants continued to operate at full capacity.
+Added: Our long-term, take-or-pay Domestic Coke sales agreements, which largely consume our capacity, are not impacted by the fluctuations of global coke prices.
+Added: Non-contracted blast coke, which is produced utilizing capacity in excess of that reserved for long-term, take-or-pay Domestic Coke sales agreements, is sold in the global market and can be impacted by fluctuations of global coke prices.
Our principal competitors of CMT are located on the U.S.
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with direct rail access on the Canadian National Railway.
−Removed: In 2023, CMT accounted for approximately 42 percent of U.S.
+Added: In 2024, CMT accounted for ap proximately 38 per cent of U.S.
thermal coal exports from the U.S.
−Removed: Gulf Coast and approximately 16 percent of total U.S.
+Added: Gulf Coast and approxim ately 16 pe rcent of total U.S.
thermal coal exports.
2 unchanged sentences
Additionally, CMT has a strategic alliance with a company that performs barge unloading services for the terminal, which provides CMT with the ability to transload and mix a significantly broader variety of materials.
−Removed: Certain CMT customers are impacted by seaborne export market dynamics.
−Removed: Fluctuations in the benchmark price for coal delivery into northwest Europe, as referenced in the Argus/McCloskey's Coal Price Index Report ( “ API2 index price ” ), as well as Newcastle index coal prices, as referenced in the Argus/McCloskey's Coal Price Index ( “ API6 index price ” ), which reflect low-ash coal prices shipped from Australia, contribute to our customers' decisions to place tons into the export market and thus impact transloading volumes through CMT.
−Removed: During 2023, decreases in European energy needs, primarily due to mild weather conditions, ample European coal inventory and the stabilization of global thermal coal supply, resulted in lower demand for coal delivery into northwest Europe and negatively impacted export coal volumes from CMT.
+Added: Our coal handling customers at CMT are impacted by seaborne export market dynamics.
+Added: Fluctuations in global energy needs and the benchmark pricing for coal delivery into Europe, as referenced in the Argus/McCloskey's Coal Price Index Report ("API2 index price"), as well as coal exports out of the U.S.
+Added: Gulf Coast, as referenced in the Platt's FOB New Orleans 3 percent Sulfur Coal Index, contribute to our customers' decisions to place tons into the export market and thus impacted transloading volumes through CMT during 2024.
+Added: Fluctuations in benchmark pricing can be impacted by weather conditions, natural gas prices, geopolitical issues, U.S.
+Added: thermal coal supply and global thermal coal demand.
Our KRT terminals serve two primary domestic markets, metallurgical coal trade and thermal coal trade.
1 unchanged sentence
Our KRT competitors are generally located within 100 miles of our operations.
−Removed: KRT has fully automated and computer-controlled mixing capabilities that mix coal to within two percent
−Removed: accuracy of customer specifications.
+Added: KRT has fully automated and computer-controlled mixing capabilities that mix coal to within two percent accuracy of customer specifications.
KRT also has the ability to provide pad storage and has access to both CSX and Norfolk Southern rail lines as well as the Ohio River system.
−Removed: Lake Terminal provides coal handling and/or mixing services to our Indiana Harbor cokemaking facility and therefore, does not have any competitors.
+Added: Demand for our services at KRT increased during 2024, driven by the
+Added: desire for certain coal suppliers to diversify transloading tons across the U.S.
+Added: This increased demand also resulted in an additional coal handling agreement and an associated capital expenditure project to be completed at KRT in 2025.
+Added: Lake Terminal provides coal handling and mixing services to our Indiana Harbor cokemaking facility and therefore, does not have any competitors.
Our revenues in our Domestic Coke segment are largely tied to long-term, take-or-pay agreements and as such, are not seasonal.
However, our cokemaking profitability is tied to coal-to-coke yields, which improve in drier weather.
−Removed: Accordingly, the coal-to-coke yield component of our profitability tends to be more favorable in the third quarter.
Extreme weather may also challenge our operating costs and production in the winter months for our Domestic Coke segment.
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Over the years, this program has produced numerous patents related to our heat recovery coking design and operation, including patents for pollution control systems, oven pushing and charging mechanisms, oven flue gas control mechanisms, high quality foundry coke, higher activity foundry coke, hydrated activated carbon for removing mercury from a flue-gas desulfurization system, corrosion resistant spray dry absorber, low particulate matter quench tower design and various others.
−Removed: Additionally, we have continued
−Removed: to successfully utilize our existing coke ovens to produce foundry coke in addition to our primary product of blast furnace coke.
+Added: Additionally, we have continued to successfully utilize our existing coke ovens to produce foundry coke in addition to our primary product of blast furnace
As of December 31, 2024, we had 83 patents issued and 38 pending in the U.S., as well as 222 issued and 75 pending in foreign jurisdictions.
2 unchanged sentences
Human Capital Management
−Removed: Our human capital strategy is focused on workforce composition, talent recruitment and retention, diversity, workforce stability, training and total compensation.
−Removed: At SunCoke we aim to foster an inclusive work environment where our employees are respected, trusted and feel empowered to provide value as individuals and as a collaborative team.
−Removed: We feel our employees offer a fresh perspective on SunCoke operations and so we welcome their ideas on process improvement and value each employee’s contribution across the business.
+Added: We live by the ethos:
+Added: Our top priority has always been the safety and health of our employees, contractors and visitors.
+Added: Safety is so important to SunCoke that we include safety in our core values and also incorporate safety as a metric in our short-term incentive program.
+Added: Our ambition is to have zero incidents and injuries in the workplace.
+Added: To reach our goal, we follow our Safety Vision, which is comprised of five core components including:
+Added: • Visible safety leadership – Site and corporate leadership have made a commitment to safety as the paramount value within the Company and our site leadership practices visible safety leadership on a daily basis.
+Added: • Communication and training – All team members and contractors take responsibility for their own safety and the safety of those around them, and we train for proper safety knowledge.
+Added: • Safe work practices – All team members and contractors take the time necessary to properly identify and mitigate hazards and safely do each job.
+Added: • Incident investigation – We have a structured process for investigating incidents and perform root cause failure analyses.
+Added: Our target for Total Rec ordable Incident Rate (“TRIR”) at SunCoke for 2024 was 0.80 company-wide, which includes both employees and contractors.
+Added: Our safety performance in 2024 was a 0.50 TRIR.
+Added: Our excellent safety record is best understood in comparison to industry-wide safety performance.
+Added: According to the Bureau of Labor Statistics, the TRIR of Other Petroleum and Coal Products (Coke) Manufacturing was 2.9 in 2023 and the TRIR for the Iron and Steel Mills sector was 2.1 in 2023, based on the most recent data available.
+Added: Our year-over-year safety performance is consistently significantly lower than average industry-wide rates, demonstrating our strong commitment to safety.
+Added: Year Total TRIR
+Added: Human Capital Strategy
+Added: Our human capital strategy is centered on talent retention, succession planning, workforce stability, training and total compensation.
+Added: At SunCoke, we strive to create a welcoming work environment where our employees are valued, trusted, and motivated to contribute meaningfully both as individuals and as a part of the team.
Company leadership and the Compensation Committee of our Board of Directors are actively involved in overseeing the Company’s human capital management programs.
−Removed: The leadership of our Human Resources department, in partnership with local Human Resources and General Managers sponsor the development and oversight of all human capital programs in the organization including:
−Removed: (i) workforce composition, recruitment and retention, (ii) culture, (iii) workforce stability, (iv) employee development and training, (v) benefits, (vi) talent management and total compensation.
−Removed: Additionally, Human Resources works in collaboration with our Legal department, including our Chief Compliance Officer, as necessary for human capital matters, ethics and compliance.
−Removed: Workforce Culture
+Added: The leadership of our Human Resources department sponsors the development and oversight of all human capital programs in the organization including:
+Added: workforce composition, talent acquisition and retention, culture, workforce stability, employee development and training, benefits, talent management and total compensation.
+Added: Additionally, our Legal department, including the Chief Compliance Officer, oversees matters related to ethics and compliance.
+Added: Culture and Core Values
Our culture at SunCoke is driven by our core values.
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• Excellence:
−Removed: expect the best from yourself, remove obstacles, inspire and support others, embrace diversity and celebrate success.
+Added: expect the best from yourself, remove obstacles, inspire and support others and celebrate success.
• Innovation:
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provide safe, reliable and environmentally sound operations for our people and their families, our customers and the communities where we do business.
−Removed: Workforce Composition and Recruitment
+Added: Workforce Composition
As of December 31, 2024, we have 868 employees in the U.S.
−Removed: Approximately 40 percent of our domestic employees, principally at our cokemaking operations, are represented by the United Steelworkers union under various local collective bargaining agreements.
−Removed: Additionally, approximately 3 percent of our domestic employees are represented by the International Union of Operating Engineers.
−Removed: As of December 31, 2023, we have 280 employees at the cokemaking facility in Vitória, Brazil, all of whom are represented by a union under a labor agreement .
−Removed: On recruiting, we partner with reputable recruitment firms to fill key positions.
−Removed: To expand our recruitment pools, we have partnered with a third-party vendor specializing in broader outreach, which presents SunCoke’s open roles to organizations from traditionally underrepresented backgrounds across the nation.
−Removed: This partnership will support our focus on attracting qualified candidates from such backgrounds to apply for positions at SunCoke.
−Removed: In 2023, we required frontline leaders and SunCoke management to attend a diversity and inclusion training.
−Removed: The training was conducted by an outside firm to further develop the ability to create an environment where everyone feels valued and has the opportunity to succeed.
−Removed: While we believe that these efforts are important to the Company’s long-term performance and value, we recognize the importance of pursuing such efforts in legally compliant ways.
−Removed: We are committed to not making employment (including hiring, promotion, and compensation) or other contracting decisions on the basis of any legally protected characteristic.
−Removed: Workforce Stability & Leadership Experience
−Removed: Our commitment to employee retention thr ough our talent management, benefits, performance management and total compensation programs is shown through our low regrettable turnover rate of approximately 1 percent in 2023.
−Removed: stability of our workforce is anchored by our experienced corporate leadership team along with our General Managers that lead the day-to-day operations at our facilities.
−Removed: Our leaders each have an average of nearly 20 years of leadership experience and an average tenure (or length of service) of over 14 years with SunCoke.
−Removed: Employee Development & Training
−Removed: SunCoke provides a robust training program that is meant to meet applicable regulatory requirements.
+Added: Approximately 40 percent of our domestic employees, at our cokemaking operations, are represented by the United Steelworkers union under various local collective bargaining agreements.
+Added: Additionally, approximately 3 percent of our domestic employees are represented by the International Union of Operating Engineers at our Lake Terminal facility.
+Added: As of December 31, 2024, we have 300 employees at the cokemaking facility in Vitória, Brazil, all of whom are represented by Sindimetal-ES - Union of Metallurgists under a labor agreement.
+Added: Talent Retention, Development & Training
+Added: We strive to continually attract, develop, engage, and retain a high-performing team that executes our strategy of long-term profitable growth.
+Added: We are committed to employee development and helping individuals reach their full potential, by making ongoing investments in our team.
+Added: We have a continual focus on strengthening technical, professional and leadership capabilities at every level using contemporary learning strategies to foster high performance.
+Added: Development occurs in the form of specialized leadership training through third-party vendors, cross training, stretch assignments, and on the job training.
+Added: In 2024, frontline supervisors and first-time managers received training to strengthen their leadership skills, including training on conflict resolution, high-quality decision making, communication, coaching others, and safety and workplace performance.
+Added: Strategic talent reviews occur at a minimum, twice a year, across the company through succession planning discussions and annual performance calibration.
+Added: SunCoke also provides a robust training program that is meant to meet applicable regulatory requirements.
In addition to the annual interactive video-based SunCoke Code of Business Conduct and Ethics training we provide to all employees, we also provide specialized trainings on an as-needed basis for current topics throughout the year.
−Removed: Over the past several years, special training topics have included Active Shooter Preparedness, Harassment, Worker’s Compensation, Diversity and Inclusion (Inclusive Leadership, Unconscious Bias at the Workplace), Conducting Effective Investigations, Retirement Planning, and Substance Abuse Awareness.
+Added: Over the past several years, special training topics have included Active Shooter Preparedness, Harassment, Worker’s Compensation, Unconscious Bias at the Workplace, Conducting Effective Investigations, Retirement Planning, and Substance Abuse Awareness.
SunCoke’s Personal Information & Privacy Policy outlines specific procedures for employees to handle sensitive information in a secure and responsible manner.
1 unchanged sentence
SunCoke utilizes a variety of information security training methods, including training segments on data security best practices and periodic security awareness communications that remind employees to stay vigilant with respect to data security.
−Removed: We believe in developing our employees both within their daily roles and to be ready for their next assignment at SunCoke.
−Removed: Development occurs in the form of leadership training, cross training, stretch assignments, and on the job training.
−Removed: In 2023, SunCoke signed a contract to partner with a global leadership consulting firm.
−Removed: Frontline supervisors and first-time managers will receive training that we believe is important for their leadership skills development, including training on conflict resolution, high-quality decision making, communication, coaching, and improving safety and workplace performance.
+Added: Succession Planning
We pride ourselves on being a lean workforce that focuses on developing and promoting talent internally.
−Removed: Our open roles are almost always filled internally, and our key positions (General Manager, Maintenance Manager and Operations Manager) are only filled internally.
+Added: Our open roles are almost half filled internally.
We engage in succession planning to help identify development and training opportunities for high performing talent, preparing potential successors for our most critical roles through assessment of the incumbents and equipping these employees with individualized development plans and job assignments to help them grow.
−Removed: We offer comprehensive benefits to our employees and their families, including health care coverage, retirement benefits, life and disability insurance, competitive vacation and leave policies.
−Removed: We also offer supplemental benefits programs designed to enhance the daily life and well-being of our employees, including:
−Removed: supplemental life insurance for all eligible family members, supplemental short-term disability, a legal services plan, an identity theft and device protection program, financial retirement planning education and coaching, paid-time off (including time for community service), tuition reimbursement, health management for chronic conditions, a 24/7 employee assistance program, and telemedicine.
−Removed: Talent Management and Total Compensation
−Removed: Our full-year performance management process begins with setting annual goals for the Company, which guide the development of functional, local and individual employee goals.
−Removed: Employees and their managers are accountable for the goals and must review their performance against the goals on an ongoing basis.
−Removed: It is our policy to provide employee base wages that are competitive and consistent with employees' positions, skill levels, experience, and geographic location.
−Removed: We use an annual review process to evaluate employees' performance and assist in their development.
−Removed: We believe that individual performance and the results of the Company are directly linked, which is why a significant portion of employee compensation is performance-based.
+Added: We have customized leadership development plans for the immediate successors of key positions across the Company.
+Added: Compensation and Benefits
+Added: Providing competitive benefits and compensation underpins our commitment to our engaged and productive employees.
+Added: Our pay-for-performance philosophy aligns employee’s individual contributions, behaviors and business results with individual rewards.
Our short-term incentives include both financial metrics as well as performance-based environmental and safety metrics.
The level of pay at risk increases progressively with positions of greater responsibility, with long-term cash and equity incentives with multi-year vesting periods granted at the Director, Vice President and Senior Vice President levels.
−Removed: Further, below the Director level, top performers may be granted long-term cash and equity incentives with multi-year vesting for retention.
+Added: Further, below the Director level, top performers may be granted long-term incentive (restricted stock units) with multi-year vesting for retention.
This helps the Company to retain those identified as having the top skills and abilities that are critical to our business.
−Removed: We live by the ethos:
−Removed: Our top priority has always been the safety and health of our employees, contractors and visitors.
−Removed: Safety is so important to SunCoke that we include safety in our core values and also incorporate safety as a metric in our short-term incentive program.
−Removed: We have an ambition of zero incidents and injuries in the workplace.
−Removed: To reach our goal, we follow our Safety Vision, which is comprised of five core components including:
−Removed: • Visible safety leadership - Site and corporate leadership have made a commitment to safety as the paramount value within the Company and our site leadership practices visible safety leadership on a daily basis.
−Removed: • Communication and training - All team members and contractors take responsibility for their own safety and the safety of those around them, and we train for proper safety knowledge.
−Removed: • Safe work practices - All team members and contractors take the time necessary to properly identify and mitigate hazards and safely do each job.
−Removed: • Incident investigation – We have a structured process for investigating incidents and perform root cause analysis of significant incidents.
−Removed: • Continuous improvement – We are always focused on preventing safety incidents and Thinking Safe, Acting Safe and Being Safe.
−Removed: Our target for Total Recordable Incident Rate ("TRIR") at SunCoke for 2023 w as 0.80 company-wide, which includes both employees and contractors.
−Removed: Our safety performance in 2023 was 0.99 TRIR.
−Removed: Our excellent safety record is best understood in comparison to industry-wide safety performance.
−Removed: According to the Bureau of Labor Statistics, the TRIR of Other Petroleum and Coal Products (Coke) Manufacturing was 3.1 in 2022 and the TRIR for the Iron and Steel Mills sector was 2.2 in 2022, based on the most recent data available.
−Removed: Our year-over-year safety performance is consistently significantly lower than average industry-wide rates, demonstrating our strong commitment to safety.
−Removed: Year Total TRIR
+Added: We offer comprehensive benefits to our employees and their families, including health care coverage, retirement benefits, life and disability insurance, vacation and leave policies.
+Added: We also offer supplemental benefits programs designed to enhance the daily life and well-being of our employees, including:
+Added: supplemental life insurance for all eligible family members, supplemental short-term disability, a legal services plan, an identity theft and device protection program, financial retirement planning education and coaching, paid-time off (including time for community service), tuition reimbursement, health management for chronic conditions, a 24/7 employee assistance program, telemedicine, critical illness, accident and hospital indemnity insurance.
+Added: Talent Management
+Added: We use an annual review process to evaluate employees' performance and assist in their development.
+Added: Our full-year performance management process begins with setting annual goals for the Company, which guide the development of functional, local and individual employee goals.
+Added: Employees and their managers are accountable for the goals and must review their performance against the goals on an ongoing basis.
+Added: Workforce Stability & Leadership Experience
+Added: Our regrettable turnover rate is approximately 1 percent in 2024.
+Added: This low rate is a testament to our commitment to employee retention.
+Added: The stability of our workforce is also anchored by our experienced corporate leadership team along with our General Managers that lead the day-to-day operations at our facilities.
+Added: Our leaders each have an average of nearly 20 years of leadership experience and an average tenure (or length of service) of 14 years with SunCoke.
Ethics & Compliance
9 unchanged sentences
Guidance & Reporting Without Fear of Retaliation
−Removed: All employees, officers and directors must report suspected policy violations of our Code of Business Conduct and Ethics to the Compliance Team, which is led by our Chief Compliance Officer and includes representatives from our Human Resources and Legal departments.
+Added: All employees, officers and directors must report suspected policy violations of our Code of Business Conduct and Ethics to the Compliance Team, which is led by our Chief Compliance Officer and oversees investigations conducted by representatives from our Human Resources and Legal departments.
They can do so through a variety of channels, including, but not limited to, directly reporting to a supervisor, providing email or verbal reports directly to the Compliance Team and using our confidential, third-party 24/7 reporting hotline or website.
15 unchanged sentences
Our cokemaking facilities employ MACT standards designed to limit emissions of certain hazardous air pollutants.
−Removed: Specific MACT standards apply to oven door leaks, charging, oven pressure, pushing and quenching.
−Removed: Certain MACT standards for cokemaking facilities were developed using test data from SunCoke's Jewell cokemaking facility located in Vansant, Virginia.
+Added: Specific MACT standards apply to oven door leaks, charging, oven pressure, pushing, quenching, and emissions from our main stacks and bypass vent stacks.
+Added: Certain MACT standards for cokemaking facilities were developed using test data from SunCoke's facilities.
Additionally, under applicable federal air quality regulations, permitting requirements may differ among facilities, depending upon whether the cokemaking facility will be located in an “attainment” area—i.e., one that meets the national ambient air quality standards (“NAAQS”) for certain pollutants, or in a “non-attainment” or "unclassifiable" area.
14 unchanged sentences
In April 2015, the area where the Middletown facility is located was designated unclassifiable/attainment for PM 2.5.
−Removed: These designations mean that no action is required for the facilities with respect to PM 2.5 emissions at this time.
−Removed: However, on February 7, 2024, the EPA adopted a rule that would lower the annual PM2.5 NAAQS and maintain the daily PM 2.5 standard, the daily PM 10 standard, and the secondary NAAQS for PM 10 and PM 2.5.
−Removed: It is possible that the areas where our facilities are located may be redesignated in the future as non-attainment areas as a result of this rule.
−Removed: If redesignated, there is a potential risk that any re-designations may have an impact on our operations and costs for facilities located in areas that the EPA determines to be non-attainment with the NAAQS.
+Added: These designations mean that no action is required for the facilities with respect to the 2012 PM 2.5 NAAQS at this time.
+Added: However, on February 7, 2024, the EPA adopted a rule that lowers the annual PM 2.5 NAAQS and maintains the daily PM 2.5 standard, the daily PM 10 standard, and the secondary NAAQS for PM 10 and PM 2.5.
+Added: In March 2024, a coalition of states initiated litigation against EPA regarding the legality of the new PM 2.5 standard in the U.S.
+Added: Court of Appeals for the District of Columbia Circuit, which is ongoing at this time.
+Added: In November 2024, the state of Ohio, which is where our Middletown facility is located, has been preliminarily designated as nonattainment under the new PM 2.5.
+Added: It is possible that the areas where our other facilities are located may also be redesignated in the future as non-attainment areas as a result of this rule.
+Added: If redesignated, there is a potential risk that any re-designations may have an impact on our operations and costs for facilities located in areas that the EPA determines to be non-attainment with the NAAQS if the rule is upheld in court and otherwise remains in effect.
• In 2015, the EPA revised the existing NAAQS for ground level ozone to make the standard more stringent.
3 unchanged sentences
As a result of the same litigation, the status of the area where the Granite City facility is located was remanded to the EPA, which finalized the area as nonattainment in January 2021.
−Removed: On June 9, 2022, the U.S.
−Removed: the EPA redesignated the area where the Middletown facility is located as an attainment area for the 2015 ozone NAAQS.
−Removed: Nonattainment designations under the new standard and any future more stringent standard for ozone have two potential impacts:
+Added: On June 9, 2022, the EPA redesignated the area where the Middletown facility is located as an attainment area for the 2015 ozone NAAQS.
+Added: Nonattainment designations under the 2015 standard and any future more stringent standard for ozone have two potential impacts:
(1) demonstrating compliance with the standard using dispersion modeling for permitting new facilities or significant new projects may be more difficult;
and (2) facilities operating in areas that are classified as moderate non-attainment areas may be required to install Reasonably Available Control Technology (“RACT”) or demonstrate that they already meet RACT standards.
−Removed: While we are not able to determine the extent to which the 2015 ozone standard will impact our business at this time, it presents a potential risk of having an impact on our operations and costs.
+Added: While we are not able to determine the extent to which any new ozone standards will impact our business at this time, it presents a potential risk of having an impact on our operations and costs.
• The EPA adopted a rule in 2010 requiring a new facility that is a major source of greenhouse gases (“GHGs”) to install equipment or employ BACT procedures.
24 unchanged sentences
The amounts recorded are dependent upon a number of variables, including the estimated future retirement costs, inflation rates, and the assumed credit-adjusted interest rates.
−Removed: Our future operating results would be adversely affected if these accruals were determined to be insufficient.
+Added: Our future operati ng results would be adversely affected if these accruals were determined to be insufficient.
These obligations are unfunded.
4 unchanged sentences
These changes in the terms of such bonds have been accompanied, at times, by a decrease in the number of companies willing to issue surety bonds.
−Removed: As of December 31, 2023, we have posted $8.3 million in surety bonds or other forms of financial security for future reclamation.
+Added: As of December 31, 2024, we have post ed $8.4 million in surety bonds or other forms of financial security for future reclamation.
Regulation of Operations
13 unchanged sentences
We are subject to two categories of MACT standards.
−Removed: The first category applies to pushing and quenching.
+Added: The first category applies to pushing, quenching, and emissions from the main stacks and bypass vent stacks.
The second category applies to emissions from charging and coke oven doors.
−Removed: The EPA is required to make a risk-based determination for pushing and quenching emissions and determine whether additional emissions reductions are necessary.
−Removed: In 2016 and 2022, the EPA issued a request for information and testing to our cokemaking facilities and other companies as part of its residual risk and technology review of the MACT standard for pushing and quenching, and a technology review of the MACT standard for coke ovens and charging emissions.
−Removed: Testing was conducted by our cokemaking facilities in 2017, 2022, and 2023.
−Removed: On August 16, 2023, the EPA proposed a rule that would impose various new emissions limits and other requirements under both categories of MACT standards regulating our cokemaking facilities.
−Removed: We submitted comments for the EPA’s consideration in response to this proposed rule.
−Removed: While we are not able to determine the extent to which any new standards would impact our business at this time, if the rule is finalized as proposed and withstands legal challenges, compliance with some of these proposed requirements may require the installation of additional pollution control systems and presents a potential risk of having an impact on operations and costs at some of our facilities.
−Removed: The EPA is required to finalize any changes to these MACT standards by May 23, 2024 pursuant to a court-ordered deadline.
−Removed: ◦ The Regional Haze program requires that states submit State Implementation Plans that demonstrate reasonable progress towards achieving natural visibility conditions in Class I areas.
+Added: The EPA is required to periodically make a risk-based determination for certain emissions sources and determine whether additional emissions reductions would be necessary.
+Added: On July 5, 2024, the EPA published a final rule that imposes various new emissions limits and other requirements under both categories of MACT standards regulating our cokemaking facilities.
+Added: We had previously submitted comments for the EPA’s consideration in response to its proposed rule.
+Added: Although EPA addressed certain comments we made in August 2023, we and other industry participants filed petitions for reconsideration with EPA, as well as litigation in the U.S.
+Added: Court of Appeals for the District of Columbia Circuit, in response to certain other aspects of this rule.
+Added: If the rule remains intact and withstands legal challenges, compliance with some of these proposed requirements may require the installation of additional pollution control systems and presents a potential risk of having an impact on operations and costs at our facilities.
+Added: ◦ The Regional Haze program requires that states submit State Implementation Plans (“SIPs”) that demonstrate reasonable progress towards achieving natural visibility conditions in Class I areas.
+Added: The program has been challenged by various parties.
On November 5, 2020, the Virginia Department of Environmental Quality (“VDEQ”) requested that the Jewell facility conduct an analysis of potential controls for SO2 under the Regional Haze program.
−Removed: The VDEQ is currently reviewing Jewell’s determination that the installation of new controls is not feasible and any new requirements should be limited to operating pollution controls already present at the facility.
−Removed: Jewell submitted a permit application to the VDEQ related to this determination, which is under review by the VDEQ at this time.
−Removed: While we are not able to determine the extent to which a different determination by the VDEQ or the EPA would impact our business at this time and were it to withstand legal challenges, it presents a potential risk of having an impact on our operations and costs at the Jewell facility.
+Added: Jewell determined that the installation of new controls is not feasible and any new requirements should be limited to operating pollution controls already present at the facility.
+Added: While we are not able to determine at this time the extent to which a determination by the VDEQ or the EPA requiring more significant measures would impact our business, were it to withstand legal challenges, it presents a potential risk of having an impact on our operations and costs at the Jewell facility.
◦ On April 6, 2022, the EPA proposed a Federal Implementation Plan Addressing Regional Ozone Transport for the 2015 Ozone NAAQS, which proposed requirements applicable to certain coke plant operations.
11 unchanged sentences
The Clean Water Act of 1972 (“CWA”) may affect our operations by requiring water quality standards generally and through the National Pollutant Discharge Elimination System (“NPDES”) program.
−Removed: Regular monitoring, reporting requirements and performance standards are requirements of NPDES
−Removed: permits that govern the discharge of pollutants into water.
+Added: Regular monitoring, reporting requirements and performance standards are requirements of NPDES permits that govern the discharge of pollutants into water.
Discharges must either meet state water quality standards or be authorized through available regulatory processes such as alternate standards or variances.
−Removed: Additionally, through the CWA Section 401 certification program, states have approval authority over water discharge permits or licenses that might result in a discharge to their waters.
+Added: Additionally, through the CWA Section 401 certification program, states have approval authority over water
+Added: discharge permits or licenses that might result in a discharge to their waters.
Similarly, for permitting or any future water intake and/or discharge projects, our facilities could be subject to the Army Corps of Engineers Section 404 permitting process.
11 unchanged sentences
We also must comply with reporting requirements under the Emergency Planning and Community Right-to-Know Act and the Toxic Substances Control Act.
−Removed: ◦ Pursuant to a court-mandated deadline, the EPA published a final rule in December 2020 that does not impose financial assurance requirements for managing hazardous substances on the coal products manufacturing sector under Section 108(b) of the Comprehensive Environmental Response, Compensation and Liability Act of 1980 (“CERCLA 108(b)”).
−Removed: The EPA’s final rule determined that the risks associated with these facilities’ operations are addressed by existing federal and state programs and regulations and modern industry practices.
• Climate Change Legislation and Regulations.
2 unchanged sentences
In 2014, the Supreme Court issued a decision holding that although the EPA may not treat GHGs as a pollutant for the purpose of determining whether a source must obtain a PSD or Title V permit, the EPA may continue to require GHG limitations in permits for sources classified as major based on their emission of other pollutants.
−Removed: Currently there is little information as to what may constitute BACT for GHG in most industries.
−Removed: Under this rule, certain modifications to our facilities could subject us to the additional permitting and other obligations related to emissions of GHGs under the New Source Review/Prevention of Significant Deterioration ("NSR/PSD") and Title V programs of the CAA based on whether the facility triggered NSR/PSD because of emissions of another pollutant such as SO2, NOx, PM, ozone or lead.
−Removed: ◦ The EPA has engaged in various rulemakings in recent years to attempt to regulate GHG emissions from existing and new coal fired power plants.
−Removed: If the EPA were to ever promulgate a similar rule that applies to our facilities, it may present a potential risk of having an impact on our operations and cost structure.
−Removed: ◦ The SEC has said it intends to finalize new climate rules that, among other matters, may require disclosure of certain climate change-related information.
−Removed: We expect that our operations will be subject to this disclosure rule.
−Removed: However, we cannot predict what such rules may require, the timing of such rules and how significantly they will affect the Company.
+Added: Currently there is little information as to what may constitute BACT for GHG for the cokemaking industry.
+Added: Potential future modifications to our facilities could subject us to the additional permitting and other obligations related to emissions of GHGs under the New Source Review/Prevention of Significant Deterioration ("NSR/PSD") and Title V programs of the CAA based on whether the facility triggered NSR/PSD because of emissions of another pollutant such as SO2, NOx, PM, ozone or lead.
+Added: ◦ The EPA has engaged in various rulemakings in recent years to regulate GHG emissions from existing and new coal fired power plants.
+Added: If the EPA were to ever promulgate a similar rule that applies to our facilities, it may present a risk of having an impact on our operations and cost structure.
+Added: ◦ The SEC published a final rule on March 6, 2024 requiring disclosure of certain climate change-related information.
+Added: The rule is currently stayed and being challenged in federal court.
+Added: If the rule survives, we expect that our operations would be subject to this final rule.
• Occupational Safety and Health ACT (OSH Act).
9 unchanged sentences
The Patient Protection and Affordable Care Act (“PPACA”), which was implemented in 2010, amended previous legislation and provides for the automatic extension of awarded lifetime benefits to surviving spouses and changes the legal criteria used to assess and award claims.
−Removed: SunCoke is not an active coal mine operator and does not perform or oversee coal mining.
+Added: SunCoke is not an active coal mine operator and does not
+Added: perform or oversee coal mining.
However, SunCoke has retained certain black lung liabilities associated with legacy coal operations.
−Removed: Our obligation related to black lung benefits at December 31, 2023 was $58.2 million and was estimated based on various assumptions, including actuarial estimates, discount rates, number of active claims, changes in health care costs and the impact of PPACA.
+Added: On August 13, 2024, the U.S.
+Added: Department of Labor’s Division of Coal Mine Workers Compensation agreed to permanently assume responsibility for payment of the Company's black lung benefits for claims based on employment that ended prior to February 1, 2013, excluding limited exceptions, in exchange for a lump sum payment of $36.0 million.
+Added: This agreement resulted in a total reduction of $45.5 million of the Company's black lung liability.
+Added: See Note 12 to our consolidated financial statements for further detail.
+Added: Our remaining obligation related to black lung benefits at December 31, 2024 was $13.7 million and was estimated based on various assumptions, including actuarial estimates, discount rates, number of active claims, changes in health care costs and the impact of PPACA.
Available Information
8 unchanged sentences
Our executive officers and their ages as of February 21, 2025, were as follows:
−Removed: Rippey 66 Chief Executive Officer
−Removed: Gates 47 President
+Added: Gates 48 President and Chief Executive Officer
Marinko 63 Senior Vice President and Chief Financial Officer
2 unchanged sentences
Shantanu Agrawal 38 Vice President, Finance and Treasurer
−Removed: Quanci 62 Vice President, Chief Technology Officer
+Added: Quanci 63 Vice President, Engineering and Technology and Chief Technology Officer
Nigl 58 Vice President, Coke Operations
−Removed: Since January 1, 2023 Mr.
−Removed: Rippey has been Chief Executive Officer of SunCoke Energy, Inc., focusing on strategic objectives and growth initiatives for the company.
−Removed: Prior to that, he was Chief Executive Officer and President since December 1, 2017.
−Removed: He has been a director of SunCoke’s Board of Directors since December 2017.
−Removed: At that time, he also was appointed as Chairman, Chief Executive Officer and President of SunCoke Energy Partners GP LLC, the general partner of SunCoke Energy Partners, L.P., our former sponsored master limited partnership.
−Removed: Prior to joining SunCoke, Mr.
−Removed: Rippey served as Senior Advisor to Nippon Steel & Sumitomo Metal Corporation (a leading global steelmaker) since 2015.
−Removed: From 2014 to 2015, he was Chairman of the Board of ArcelorMittal USA (a major domestic steel manufacturer), and from August 2006 through October 2014, he was ArcelorMittal USA’s President and Chief Executive Officer.
−Removed: Prior to that, he successfully rose through progressively responsible financial, commercial and administrative leadership roles at ArcelorMittal USA and its predecessor companies:
−Removed: (i) from 2005 to 2006, he was Executive Vice President, Sales and Marketing at Mittal Steel USA;
−Removed: (ii) from 2000 to 2005, he was Executive Vice President and Chief Financial Officer at Ispat Inland Inc.;
−Removed: and (iii) from 1998 to 2000, he served as Vice President, Finance and Chief Financial Officer of Ispat Inland Inc.
−Removed: He began his career with Inland Steel Company (a predecessor to ArcelorMittal USA) in 1984.
−Removed: Rippey currently serves on the Board of Directors of Olympic Steel, Inc.
−Removed: ZEUS] (a leading U.S.
−Removed: metals service center), where he is a member of the Nominating Committee and serves as Chair of the Audit and Compliance
−Removed: In addition to ArcelorMittal USA, Mr.
−Removed: Rippey’s previous board service also includes the National Association of Manufacturers and the American Iron & Steel Institute, where he was a past Chairman of the Board.
−Removed: Gates was elected President of SunCoke Energy, Inc., and was appointed as a director on SunCoke’s Board of Directors, effective January 1, 2023.
−Removed: Prior to that, she was Senior Vice President, Chief Legal Officer and Chief Human Resource Officer since November 2019.
−Removed: Gates served as Senior Vice President, General Counsel and Chief Compliance Officer from October 2015 to November 2019.
−Removed: From July 2014 to October 2015, she was Vice President and Assistant General Counsel, where she focused on litigation, regulatory and commercial matters.
+Added: Gates became Chief Executive Officer of SunCoke Energy, Inc.
+Added: in May 2024, after being appointed as President and a director on SunCoke’s Board of Directors, in January 2023.
+Added: From November 2019 until her promotion to President in January 2023, Ms.
+Added: Gates served as SunCoke’s Senior Vice President, Chief Legal Officer and Chief Human Resources Officer.
+Added: Gates joined SunCoke in February 2013 as Senior Health, Environment and Safety Counsel, and has held leadership positions of increasing responsibility since then, including serving as General Counsel and Chief Compliance Officer from October 2015 to November 2019.
+Added: She was promoted to Vice President in July 2014, and to Senior Vice President in October 2015.
In addition, from October 2015 through June 2019, Ms.
−Removed: Gates served as a director of SunCoke Energy Partners GP LLC, the general partner of SunCoke Energy Partners, L.P, our former master limited partnership subsidiary.
−Removed: Gates joined SunCoke in February 2013 as Senior Health, Environment and Safety Counsel.
+Added: Gates was elected as a director of SunCoke Energy Partners GP LLC, the general partner of SunCoke Energy Partners, L.P., our former publicly traded master limited partnership subsidiary.
Prior to joining SunCoke, Ms.
−Removed: Gates practiced law for two decades.
−Removed: As a Partner at Beveridge & Diamond, P.C., she served on the firm’s Management Committee and co-chaired the civil litigation section of the firm’s Litigation Practice Group.
+Added: Gates was a Partner at Beveridge & Diamond, P.C., where she served on the firm’s Management Committee and co-chaired the firm’s civil litigation practice group.
Marinko was appointed as SunCoke Energy, Inc.’s Senior Vice President and Chief Financial Officer in March 2022.
27 unchanged sentences
He has increasingly taken on more responsibilities and oversight over that period.
−Removed: Agrawal is an accomplished finance executive with a rich mix of finance, operations and strategic planning.
In his current roles, Mr.
16 unchanged sentences
Since joining SunCoke in February 2011 as Maintenance Manager at the Company’s Haverhill, Ohio cokemaking facility, Mr.
−Removed: Nigl has progressed into leadership and oversight roles for the Company’s domestic cokemaking
+Added: Nigl has progressed into leadership and oversight roles for the Company’s domestic cokemaking operations.
Prior to joining SunCoke, Mr.
1 unchanged sentence
Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.