United States securities and exchange commission logo
November 9, 2023
Mike Wiedemer
Vice President and Chief Financial Officer
United States Lime & Minerals, Inc.
5429 LBJ Freeway, Suite 230
Dallas, Texas 75240
Re: United States Lime
& Minerals, Inc.
Form 10-K for the
Fiscal Year Ended December 31, 2022
File No. 000-04197
Dear Mike Wiedemer:
We have reviewed your
filing and have the following comment(s).
Please respond to this letter within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe a
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to this letter, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2022 Filed February 23,
2023
Item 1. Business, page 2
1. Please revise to
include the following disclosure with your mineral property summary
disclosure:
aggregate (total)
annual production for the properties during each of the three most
recently completed
fiscal years as required by Item 1303(b)(2)(i) of Regulation S-
K, and
resources
disclosed exclusive of mineral reserves as required by Item 1303(b)(3)(ii)
of Regulation S-K.
2. Please revise to
include the following disclosure for each material property:
the location
accurate to within one mile using an easily recognizable coordinate
system, and a
map(s) with appropriate engineering detail for each material property
as required by Item
1304(b)(1)(i) of Regulation S-K,
the total cost or
book value of the material property as required by Item
1304(b)(2)(iii) of
Regulation S-K, and
Mike Wiedemer
United States Lime & Minerals, Inc.
November 9, 2023
Page 2
resources reported exclusive of reserves as required by Item
1304(d)(2) of Regulation
S-K.
Exhibit Index
Exhibit 96.1 to 96.4, page 54
3. We note that your mineral resources are presented inclusive of mineral
reserves. In a
technical report summary mineral resources may be presented inclusive
on mineral
reserves, however they should also be presented exclusive of mineral
reserves as required
by Item 601(b)(96)(iii)(B)(11)(ii) of Regulation S-K. Please revise
accordingly.
4. We note that the point of reference established for your mineral
resources and mineral
reserves in each technical report summary is shot limestone delivered
to the primary
crusher. Additionally we note that the processing and recovery section
of each technical
report summary has not been included, however language has been
included in each
technical report summary stating that the process plant and
description does not apply to
the report as the mines deliver shot limestone to the primary crusher.
The technical report summaries should assess the property from the
point of mineral
extraction up to the first point of material external sale, including
processing,
transportation, and warehousing, as suggested in the materiality
analysis in Item
1301(c)(3) of Regulation S-K, and included in Table 1 to paragraph (d)
of Item 1302.
Based upon the disclosures in your annual filing it does not appear
that shot limestone is a
product that is sold externally, therefore your technical report
summaries should include a
description of your processing facilities.
We also note that the price selected by your qualified person is a
price associated with
crushed limestone, which does not correlate to the point of reference
selected for mineral
resources and mineral reserves. For example the price associated with
crushed limestone
is a saleable product price, and your reserves and resources are
reported as shot limestone
delivered to the primary crusher, prior to processing, and do not
include process recovery
factors or processing costs in your cash flow analysis.
Please consult with your qualified person and obtain revised technical
report summaries
that include your processing operations, along with necessary revisions
to your recovery
factors
FirstName and costs. Wiedemer
LastNameMike
Comapany
5. NameUnited
Please disclose theStates Limelevel
accuracy & Minerals, Inc. and operating cost
estimates, as required
of the capital
by Item
November 601(b)(96)(iii)(B)(18)(i)
9, 2023 Page 2 of Regulation S-K.
FirstName LastName
Mike Wiedemer
FirstName LastNameMike Wiedemer
United States Lime & Minerals, Inc.
Comapany 9,
November NameUnited
2023 States Lime & Minerals, Inc.
November
Page 3 9, 2023 Page 3
FirstName LastName
We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.
Please contact John Coleman at 202-551-3610 or Craig Arakawa at
202-551-3650 if you
have questions regarding comments.
Sincerely,
Division of
Corporation Finance
Office of Energy &
Transportation