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United States securities and exchange commission logo
September 2, 2022
David L. Lamp
President and Chief Executive Officer
CVR Energy, Inc.
2277 Plaza Drive, Suite 500
Sugar Land, TX 77479
Re: CVR Energy, Inc.
Form 10-K for
Fiscal Year Ended December 31, 2021
Response dated
August 11, 2022
File No. 001-33492
Dear Mr. Lamp:
We have reviewed your August 11, 2022 response to our comment
letter and have the
following comments. In some of our comments, we may ask you to provide
us with information
so we may better understand your disclosure.
Please respond to these comments 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 our
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your response to these comments, we may have
additional
comments. Unless we note otherwise, our references to prior comments are
to comments in our
July 11, 2022 letter.
Response dated August 11, 2022
Management's Discussion and Analysis of Financial Condition and Results
of Operations, page
38
1. Your response to prior
comment 3 states that you had no material capital expenditures
related to your nitrous
oxide abatement and carbon dioxide sequestration
projects/activities.
Please provide us with quantitative information for these
projects/activities for
each of the periods for which financial statements are presented in
your Form 10-K and for
any subsequent periods.
2. We note from your
response to prior comment 4 that the indirect consequences of climate-
related regulation or
business trends would be reflected in the prices you receive for your
products. However, it
is not clear how you evaluated the factors noted in our prior
comment to determine
their effect on demand for the products you sell. Please describe
David L. Lamp
CVR Energy, Inc.
September 2, 2022
Page 2
how the indirect consequences of regulations or business trends
related to climate change
were considered in your analysis and tell us how you concluded that
they were not
material. Your response should specifically addresses each item from
our prior comment.
3. We note your response to our prior comment 5 and reissue it in part.
Please provide us
with quantitative information for each of the periods identified in
our prior comment
regarding weather-related damages to your property or operations and
the cost of
insurance.
4. In response to prior comment 5, you state that the physical effects of
climate change have
not had a material physical effect on your operations. Please provide
us with additional
detail explaining how you considered providing disclosure regarding:
the potential for the physical effects of climate change to affect
your operations and
results; and
possible indirect financial and operational impacts to you from
disruptions to the
operations of your customers from severe weather, including, but
not limited to,
decreased agricultural production capacity.
5. Your response to prior comment 6 states that you have not incurred any
material
compliance costs related to climate change other than those associated
with the
Renewable Fuel Standard and costs associated with your compliance with
environmental
laws. Beyond those related to compliance with the Renewable Fuel
Standard, please
quantify for us compliance costs incurred related to climate change
for the periods noted
in our prior comment.
Please contact Anuja A. Majmudar, Attorney-Adviser, at (202) 551-3844 or
Ethan
Horowitz, Accounting Branch Chief, at (202) 551-3311 with any questions.
FirstName LastNameDavid L. Lamp Sincerely,
Comapany NameCVR Energy, Inc.
Division of
Corporation Finance
September 2, 2022 Page 2 Office of Energy
& Transportation
FirstName LastName