Document

On behalf of Knife River Corporation (“Knife River”, the “Company”, “we”, “us” or “our”), the Company submits this letter in response to the comments from the Staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “Commission”) that were set forth in the Staff’s letter dated May 8, 2025 (the “Comment Letter”) related to the Company’s Annual Report on Form 10-K for the fiscal year ended December 31, 2024, filed with the Commission on February 21, 2025.

For the Staff’s convenience, the text of the Staff’s comments is set forth below in bold and corresponds to the numbered comment contained in the Comment Letter, followed by the Company’s response.

Response: We acknowledge the Staff’s comment and respectfully advise the Staff that in accordance with ASC 280-10-50-22, a public entity shall disclose the amounts noted in 50-22c. and d. if the specified amounts are included in the measure of segment profit or loss reviewed by the chief operating decision maker or are otherwise regularly provided

to the chief operating decision maker, even if not included in that measure of segment profit or loss. The measure of segment profit or loss reviewed by our chief operating decision maker is earnings before interest, taxes, depreciation, depletion and amortization, which does not include the effects of interest revenue, interest expense or income tax expense or benefit. Further, our chief operating decision maker is not provided financial information for our segments that includes interest revenue, interest expense or income tax expense or benefit.

2.Please tell us why segment revenues disclosed on page 100 do not reconcile with the corresponding segment revenues disclosed on pages 46-51 for all periods presented. For example, $493,066 of revenue for external customers for Pacific in 2024 corresponds with $493.1 on page 46 but the revenue amounts for Northwest, Mountain, Central and Energy Services do not reconcile.

Response: We acknowledge the Staff’s comment and respectfully advise the Staff that the difference noted between the segment revenues on page 100 and those disclosed on pages 46-51 are related to intersegment revenues for sales between segments. The intersegment sales amounts included in the Business Segment Data footnote disclosure in the notes to the financial statements includes both intersegment revenues and intra segment revenues (sales between companies within the segment), whereas the internal sales disclosed in the Management’s Discussion and Analysis of Financial Condition and Results of Operations only includes the sales between companies within the segment.

The following reconciles the amounts reported in the Management’s Discussion and Analysis of Financial Condition and Results of Operations to the Business Segment Data footnote disclosure in the notes to the financial statements for 2024.


	Pacific		Northwest		Mountain		Central		Energy Services
	(In millions)
Aggregates	$	112.3	$	184.8	$	101.8	$	157.2	$	—
Ready-mix concrete	145.8		167.8		117.1		224.8		—
Asphalt	30.7		104.6		120.9		185.3		—
Liquid Asphalt	—		—		—		—		238.9
Other	149.3		18.1		—		31.7		50.6
Contracting Services	141.9		324.8		459.0		432.5		—
Internal Sales1	(86.9)		(107.7)		(135.7)		(213.4)		(13.8)
Total	493.1		692.4		663.1		818.1		275.7
Intersegment revenues1	—		(2.5)		(0.2)		(0.2)		(41.0)
Revenues from external customers	$	493.1	$	689.9	$	662.9	$	817.9	$	234.7

1.The total of internal sales and intersegment revenues ties to the amount disclosed in the Business Segment Data disclosure for intersegment revenues in the filed Form 10-K for the year ended December 31, 2024.

In future filings, we will revise our disclosures in the Business Segment Data footnote disclosure in the notes to the financial statements to present total segment revenue net of sales between companies within the segment and also remove the sales between companies within the segment from the intersegment revenue line. The total segment revenues will then reconcile to the revenues disclosed in the Management’s Discussion and Analysis of Financial Condition and Results of Operations and only intersegment sales will be included in intersegment revenues line in the Business Segment Data footnote disclosure in the notes to the financial statements. See the following for the 2024 Business Segment Data footnote revised for these changes.


For the year ended December 31, 2024	Pacific		Northwest		Mountain		Central		Energy Services		Total
	(In thousands)
Revenues from external customers	$	493,066	$	689,893	$	662,892	$	817,872	$	234,652	$	2,898,375
Intersegment revenues	47		2,542		173		194		41,040		43,996
Total segment revenue	493,113		692,435		663,065		818,066		275,692		2,942,371

Other revenues											1,149
Less: Elimination of intersegment revenue											44,515
Total consolidated revenue											$	2,899,005

In connection with our response to the Staff’s comments, we acknowledge that the Company and its management are responsible for the accuracy and adequacy of its disclosures, notwithstanding any review, comments action or absence of action by the Staff.