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Testimony: 

Before the Subcommittee on Energy and Mineral Resources, Committee on 
Natural Resources, House of Representatives: 

United States Government Accountability Office: 
GAO: 

For Release on Delivery: 
Expected at 10:00 a.m. EST:
Thursday February 26, 2009: 

Hardrock Mining: 

Information on Types of State Royalties, Number of Abandoned Mines, and 
Financial Assurances on BLM Land: 

Statement of Robin M. Nazzaro, Director: 
Natural Resources and Environment: 

GAO-09-429T: 

GAO Highlights: 

Highlights of GAO-09-429T, a testimony before the Subcommittee on 
Energy and Mineral Resources, Committee on Natural Resources, House of 
Representatives. 

Why GAO Did This Study: 

The General Mining Act of 1872 helped open the West by allowing 
individuals to obtain exclusive rights to mine billions of dollars 
worth of gold, silver, and other hardrock (locatable) minerals from 
federal lands without having to pay a federal royalty. However, western 
states charge royalties so that they share in the proceeds from various 
hardrock minerals extracted from their lands. For years, some mining 
operators did not reclaim land used in their mining operations, 
creating environmental and physical safety hazards. To curb further 
growth in the number of abandoned hardrock mines on federal lands, in 
1981, the Department of the Interior’s Bureau of Land Management (BLM) 
began requiring mining operators to reclaim BLM land disturbed by these 
operations, and in 2001 began requiring operators to provide financial 
assurances to cover reclamation costs before they began exploration or 
mining operations. 

This testimony focuses on the (1) royalties states charge, (2) number 
of abandoned hardrock mine sites and hazards, and (3) value and 
coverage of financial assurances operators use to guarantee reclamation 
costs. It is based on two GAO reports: Hardrock Mining: Information on 
Abandoned Mines and Value and Coverage of Financial Assurances on BLM 
Land, [hyperlink, http://www.gao.gov/products/GAO-08-574T] (Mar. 12, 
2008) and Hardrock Mining: Information on State Royalties and Trends in 
Imports and Exports, [hyperlink, 
http://www.gao.gov/products/GAO-08-849R] (July 21, 2008). 

What GAO Found: 

Twelve western states, including Alaska, that GAO reviewed assess 
royalties on hardrock mining operations on state lands. In addition, 
each of these states, except Oregon, assesses taxes that function like 
a royalty, which GAO refers to as functional royalties, on the hardrock 
mining operations on private, state, and federal lands. The royalties 
the states assess often differ depending on land ownership and the 
mineral being extracted. For example, for private mining operations 
conducted on federal, state, or private land, Arizona assesses a 
functional royalty of 1.25 percent of net revenue on gold mining 
operations, and an additional royalty of at least 2 percent of gross 
value for gold mining operations on state lands. The actual amount 
assessed for a particular mine may depend not only on the type of 
royalty, its rate, and exclusions, but also on other factors, such as 
the mine’s location relative to markets. 

Over the past 10 years, estimates of the number of abandoned hardrock 
mine sites in the 12 western states reviewed, as well as South Dakota, 
have varied widely, in part because there is no generally accepted 
definition for a hardrock mine site. Using a consistent definition that 
GAO provided, these states reported the number of abandoned sites in 
their states. On the basis of these data, GAO estimated that there are 
at least 161,000 abandoned hardrock mine sites in these states, and 
these sites have at least 332,000 features that may pose physical 
safety hazards and at least 33,000 sites that have degraded the 
environment. 

According to BLM data, as of November 2007, hardrock mining operators 
had provided financial assurances worth approximately $982 million to 
guarantee reclamation costs for 1,463 hardrock mining operations on BLM 
land and 52 of these operations had financial assurances valued at 
about $28 million less than needed to fully cover estimated reclamation 
costs. However, GAO determined that the assurances for these 52 
operations should be more accurately reported as about $61 million less 
than needed for full coverage. The $33 million difference between GAO’s 
and BLM’s estimated shortfalls occurs because BLM calculated its 
shortfall by comparing the total value of financial assurances in place 
with the total estimated reclamation costs. This approach effectively 
offsets the shortfalls in some operations with the higher than needed 
financial assurances of others. However, the financial assurances that 
are greater than the amount required for an operation cannot be 
transferred to an operation with inadequate financial assurances. In 
contrast, GAO totaled the difference between the financial assurances 
in place for an operation and the financial assurances needed for that 
operation to determine the actual shortfall for each of the 52 
operations for which BLM had determined that financial assurances were 
inadequate. BLM has taken steps to correct the reporting problem GAO 
identified. 

To view the full product, including the scope and methodology, click on 
[hyperlink, http://www.gao.gov/products/GAO-09-429T]. For more 
information, contact Robin M. Nazzaro at (202) 512-3841 or 
nazzaror@gao.gov. 

[End of section] 

Mr. Chairman and Members of the Committee: 

I am pleased to be here today to discuss our 2008 work on several 
hardrock mining issues that are central to the debate on reforming the 
General Mining Act of 1872: royalties, abandoned mines, and financial 
assurances.[Footnote 1] 

As you know, since the passage of the General Mining Act of 1872, mine 
operators have extracted billions of dollars worth of silver, gold, 
copper, and other hardrock (locatable) minerals from federal lands 
without having to pay a royalty.[Footnote 2] Most of these lands are 
managed by the Department of the Interior's Bureau of Land Management 
(BLM) and the U.S. Department of Agriculture's Forest Service. 
Assessing a royalty on hardrock minerals would ensure that the public 
is compensated for hardrock minerals extracted from federal lands, as 
more recently enacted laws require for oil, gas, and other minerals. 

The vast majority of the federal lands where hardrock mining operations 
occur are in 12 western states, including Alaska (hereafter referred to 
as the 12 western states).[Footnote 3] These western states have 
statutes governing hardrock mining operations on lands in their state. 
However, unlike the federal government, these states charge royalties 
that allow them to share in the proceeds from hardrock minerals 
extracted from state-owned lands. In addition, most of these states 
charge taxes, such as severance taxes, mine license taxes, or resource 
excise taxes, on hardrock mining operations that occur on private, 
state, and federal lands. For the purposes of this report, we use the 
term "functional royalty" to refer to taxes that function like a 
royalty in that they permit the state to share in the value of the 
mine's production. Although states may use similar names for functional 
royalties they assess, there can be wide variations in their forms and 
rates. 

In addition to not requiring hardrock mining operators to pay 
royalties, prior to 1981, BLM did not require them to reclaim the 
federal land they used. Consequently, hardrock mining operators have 
left thousands of acres of federal land disturbed through mineral 
exploration, mining, and mineral processing. Some of these disturbed 
abandoned mine lands pose serious environmental and physical safety 
hazards. These hazards include environmental hazards such as toxic or 
acidic water that contaminates soil and groundwater or physical safety 
hazards such as open or concealed shafts, unstable or decayed mine 
structures, or explosives. Cleanup costs for these abandoned mines vary 
by type and size of the operation.[Footnote 4] 

To curb further growth in the number of abandoned hardrock mines, BLM 
issued regulations, effective in 1981, that required all mining 
operators to reclaim BLM land disturbed by hardrock mining. In 2001, 
BLM began requiring all mining operators to provide financial 
assurances before beginning exploration or mining operations on BLM 
land. These financial assurances must cover all of the estimated 
reclamation costs for a given hardrock operation. Having adequate 
financial assurances to pay reclamation costs for BLM land disturbed by 
hardrock operations is critical to ensuring that the land is reclaimed 
if the mining operators fail to do so. In June 2005, we reported that 
some current hardrock operations on BLM land do not have financial 
assurances, and some have no or outdated reclamation plans and/or cost 
estimates on which the financial assurances should be based.[Footnote 
5] 

My testimony today focuses on the (1) royalties states currently charge 
on hardrock mining operations, (2) the number of abandoned hardrock 
mine sites and number of associated hazards, and (3) value and coverage 
of the financial assurances operators use to guarantee reclamation 
costs on lands managed by BLM. 

To address these objectives, we interviewed staff at BLM and the Forest 
Service; examined agency documents and data; and reviewed relevant 
legislation and regulations. To identify the types of royalties, 
including functional royalties that the 12 western states assess on 
hardrock mining operations, we reviewed state statutes and regulations 
pertaining to royalties on hardrock mining operations. To aid in 
understanding general patterns in state royalties, we consulted 
academic and industry sources and then we categorized each royalty 
according to how it is assessed. To assess the number of abandoned 
hardrock mine sites, we asked the 12 western states and South Dakota-- 
which have significant numbers of abandoned hardrock mining operations-
-to determine the number of these mine sites in their states. We asked 
the states to use a consistent definition, which we provided, in 
estimating the number of abandoned mine sites and associated features 
that pose a significant hazard to public health and safety and the 
number of sites that cause environmental degradation.[Footnote 6] We 
specified that states should only include hardrock (also known as 
locatable), non-coal sites in this estimate. From these data, we 
estimated the number of features that pose physical safety hazards and 
the number of sites with environmental hazards in the 12 western 
states. We also summarized six selected studies by federal agencies and 
organizations to document differences in estimates, definitions, and 
methodologies. To assess the value and coverage of financial assurances 
in place to guarantee reclamation, we reviewed BLM's Bond Review 
Report. This report provides information on financial assurances for 11 
western states.[Footnote 7] This Bond Review Report is generated from 
BLM's automated information system--LR 2000. Although the LR2000 data 
are of undetermined reliability, our limited assessment of these data 
indicates that they are appropriate as used and presented in this 
testimony, and we do not base any conclusions or recommendations on 
them. This testimony is based on prior GAO reports whose work was 
conducted in accordance with generally accepted government auditing 
standards.[Footnote 8] Those standards require that we plan and perform 
the audit to obtain sufficient, appropriate evidence to provide a 
reasonable basis for our findings and conclusions based on our audit 
objectives. We believe that the evidence obtained provides a reasonable 
basis for our findings and conclusions based on our audit objectives. 

The 12 Western States Assess Multiple Types of Royalties, Including 
Functional Royalties, on Mining Operations: 

Twelve western states assess royalties on the hardrock mining 
operations on state lands. In addition, each of these states, except 
Oregon, assesses taxes that function like a royalty, which we refer to 
as functional royalties, on the hardrock mining operations on private, 
state, and federal lands. To aid in the understanding of royalties, 
including functional royalties, the royalties are grouped as follows: 

* Unit-based is typically assessed as a dollar rate per quantity or 
weight of mineral produced or extracted, and does not allow for 
deductions of mining costs. 

* Gross revenue is typically assessed as a percentage of the value of 
the mineral extracted and does not allow for deductions of mining 
costs. 

* Net smelter returns is assessed as a percentage of the value of the 
mineral, but with deductions allowed for costs associated with 
transporting and processing the mineral (typically referred to as mill, 
smelter, or treatment costs); however, costs associated with extraction 
of the mineral are not deductible. 

* Net proceeds is assessed as a percentage of the net proceeds (or net 
profit) of the sale of the mineral with deductions for a broad set of 
mining costs. The particular deductions allowed vary widely from state 
to state, but may include extraction costs, processing costs, 
transportation costs, and administrative costs, such as for capital, 
marketing, and insurance.[Footnote 9] 

Royalties, including functional royalties, often differ depending on 
land ownership and the mineral being extracted, as the following 
illustrates: 

* For private mining operations conducted on federal, state, or private 
lands, Arizona assesses a net proceeds functional royalty of 1.25 
percent on gold mining operations, and an additional gross revenue 
royalty of at least 2 percent for gold mining operations on state 
lands. 

* Nine of the 12 states assess different types of royalties for 
different types of minerals. For example, Wyoming employs three 
different functional royalties for all lands: (1) net smelter returns 
for uranium, (2) a different net smelter returns for trona--a mineral 
used in the production of glass, and (3) gross revenue for all other 
minerals. 

Furthermore, the royalties the states assess often differ in the 
allowable exclusions, deductions, and limitations.[Footnote 10] For 
example, in Colorado, a functional royalty on metallic mining excludes 
gross incomes below $19 million,[Footnote 11] whereas in Montana a 
functional royalty on metallic mining is applied on all mining 
operations after the first $250,000 of revenue.[Footnote 12] 

Finally, the actual amount assessed for a particular mine may depend 
not only on the type of royalty, its rate, and exclusions, but also on 
such factors as the mineral's processing requirements, mineral markets, 
mine efficiency, and mine location relative to markets, among other 
factors. 

Table 1 shows the types of royalties, including functional royalties, 
that the 12 western states assess on all lands, including federal, 
state, and private lands, as well as the royalties assessed only on 
state lands. 

Table 1: Types of Royalties, Including Functional Royalties, Assessed 
on Hardrock Mining Operations in Western States, by State: 

State: Alaska: State lands; 
Unit-based: [Empty]; 
Gross revenue: [Empty]; 
Net smelter returns: [Empty]; 
Net proceeds: [Check]. 

State: Alaska: All lands; 
Unit-based: [Empty]; 
Gross revenue: [Empty]; 
Net smelter returns: [Empty]; 
Net proceeds: [Check]. 

State: Arizona: State lands; 
Unit-based: [Empty]; 
Gross revenue: [Check]; 
Net smelter returns: [Empty]; 
Net proceeds: [Empty]. 

State: Arizona: All lands; 
Unit-based: [Empty]; 
Gross revenue: [Check]; 
Net smelter returns: [Empty]; 
Net proceeds: [Check]. 

State: California: State lands; 
Unit-based: [Empty]; 
Gross revenue: [Check]; 
Net smelter returns: [Empty]; 
Net proceeds: [Check]. 

State: California: All lands; 
Unit-based: [Check]; 
Gross revenue: [Empty]; 
Net smelter returns: [Empty]; 
Net proceeds: [Empty]. 

State: Colorado: State lands; 
Unit-based: [Empty]; 
Gross revenue: [Check]; 
Net smelter returns: [Empty]; 
Net proceeds: [Check]. 

State: Colorado: All lands; 
Unit-based: [Check]; 
Gross revenue: [Check]; 
Net smelter returns: [Empty]; 
Net proceeds: [Empty]. 

State: Idaho: State lands; 
Unit-based: [Empty]; 
Gross revenue: [Check]; 
Net smelter returns: [Check]; 
Net proceeds: [Empty]. 

State: Idaho: All lands; 
Unit-based: [Empty]; 
Gross revenue: [Empty]; 
Net smelter returns: [Empty]; 
Net proceeds: [Check]. 

State: Montana: State lands; 
Unit-based: [Empty]; 
Gross revenue: [Check]; 
Net smelter returns: [Check]; 
Net proceeds: [Empty]. 

State: Montana: All lands; 
Unit-based: [Check]; 
Gross revenue: [Empty]; 
Net smelter returns: [Check]; 
Net proceeds: [Empty]. 

State: Nevada[A]: State lands; 
Unit-based: [Empty]; 
Gross revenue: [Empty]; 
Net smelter returns: [Empty]; 
Net proceeds: [Empty]. 

State: Nevada[A]: All lands; 
Unit-based: [Empty]; 
Gross revenue: [Empty]; 
Net smelter returns: [Empty]; 
Net proceeds: [Check]. 

State: New Mexico: State lands; 
Unit-based: [Empty]; 
Gross revenue: [Check]; 
Net smelter returns: [Check]; 
Net proceeds: [Empty]. 

State: New Mexico: All lands; 
Unit-based: [Empty]; 
Gross revenue: [Check]; 
Net smelter returns: [Check]; 
Net proceeds: [Check]. 

State: Oregon: State lands; 
Unit-based: [Check]; 
Gross revenue: [Check]; 
Net smelter returns: [Empty]; 
Net proceeds: [Empty]. 

State: Oregon: All lands; 
Unit-based: [Empty]; 
Gross revenue: [Empty]; 
Net smelter returns: [Empty]; 
Net proceeds: [Empty]. 

State: Utah: State lands; 
Unit-based: [Empty]; 
Gross revenue: [Check]; 
Net smelter returns: [Empty]; 
Net proceeds: [Empty]. 

State: Utah: All lands; 
Unit-based: [Empty]; 
Gross revenue: [Empty]; 
Net smelter returns: [Empty]; 
Net proceeds: [Check]. 

State: Washington: State lands; 
Unit-based: [Empty]; 
Gross revenue: [Check]; 
Net smelter returns: [Empty]; 
Net proceeds: [Empty]. 

State: Washington: All lands; 
Unit-based: [Empty]; 
Gross revenue: [Check]; 
Net smelter returns: [Empty]; 
Net proceeds: [Empty]. 

State: Wyoming: State lands; 
Unit-based: [Check]; 
Gross revenue: [Check]; 
Net smelter returns: [Empty];
Net proceeds: [Empty]. 

State: Wyoming: All lands; 
Unit-based: [Empty]; 
Gross revenue: [Check]; 
Net smelter returns: [Check]; 
Net proceeds: [Empty]. 

Total: State lands; 
Unit-based: 2; 
Gross revenue: 10; 
Net smelter returns: 3; 
Net proceeds: 3. 

Total: All Lands; 
Unit-based: 3; 
Gross revenue: 5; 
Net smelter returns: 3; 
Net proceeds: 6. 

Source: GAO analysis of state statutes and regulations. 

Note: Sales and use taxes are excluded. Royalties often apply only to 
specific minerals. 

[A] Nevada also has royalty on hardrock mining operations on state 
lands, however it is unlike these four categories of royalties. 

[End of table] 

Prior State Estimates of the Number of Abandoned Hardrock Mine Sites 
Vary Widely, but Our Data Show at Least 161,000 Sites, with Many Posing 
Hazards: 

It has been difficult to determine the number of abandoned hardrock 
mine sites in the 12 western states, and South Dakota, in part because 
there is no generally accepted definition for a hardrock mine site. The 
six studies we reviewed relied on the different definitions that the 
states used, and estimates varied widely from study to study.[Footnote 
13] 

Furthermore, BLM and the Forest Service have had difficulty determining 
the number of abandoned hardrock mines on their lands. In September 
2007, the agencies reported an estimated 100,000 abandoned mine sites, 
[Footnote 14] but we found problems with this estimate. For example, 
the Forest Service had reported that it had approximately 39,000 
abandoned hardrock mine sites on its lands. However, this estimate 
includes a substantial number of non-hardrock mines, such as coal 
mines, and sites that are not on Forest Service land. At our request, 
the Forest Service provided a revised estimate of the number of 
abandoned hardrock mine sites on its lands, excluding coal or other non-
hardrock sites. According to this estimate, the Forest Service may have 
about 29,000 abandoned hardrock mine sites on its lands. That said, we 
still have concerns about the accuracy of the Forest Service's recent 
estimate because it identified a large number of sites with 
"undetermined" ownership, and therefore these sites may not all be on 
Forest Service lands. 

BLM has also acknowledged that its estimate of abandoned hardrock mine 
sites on its lands may not be accurate because it includes sites on its 
lands that are of unknown or mixed ownership (state, private, and 
federal) and a few coal sites. In addition, BLM officials said that the 
agency's field offices used a variety of methods to identify sites in 
the early 1980s, and the extent and quality of these efforts varied 
greatly. For example, they estimated that only about 20 percent of BLM 
land has been surveyed in Arizona. Furthermore, BLM officials said that 
the agency focuses more on identifying sites closer to human habitation 
and recreational areas than on identifying more remote sites, such as 
in the desert. Table 2 shows the Forest Service's and BLM's most recent 
available estimates of abandoned mine sites on their lands. 

Table 2: BLM's and the Forest Service's Most Currently Available 
Estimated Number of Abandoned Mines on Their Lands, by State: 

State: Alaska; 
Estimated number of abandoned mine sites on BLM land[A]: 6,000; 
Estimated number of abandoned mine sites on Forest Service land[B]: 
830; 
Total: 6,830. 

State: Arizona; 
Estimated number of abandoned mine sites on BLM land[A]: 22,000; 
Estimated number of abandoned mine sites on Forest Service land[B]: 
2,183; 
Total: 24,183. 

State: California; 
Estimated number of abandoned mine sites on BLM land[A]: 11,500; 
Estimated number of abandoned mine sites on Forest Service land[B]: 
6,248; 
Total: 17,748. 

State: Colorado; 
Estimated number of abandoned mine sites on BLM land[A]: 2,500; 
Estimated number of abandoned mine sites on Forest Service land[B]: 
2,605; 
Total: 5,105. 

State: Idaho; 
Estimated number of abandoned mine sites on BLM land[A]: 400; 
Estimated number of abandoned mine sites on Forest Service land[B]: 
4,635; 
Total: 5,035. 

State: Montana; 
Estimated number of abandoned mine sites on BLM land[A]: 1,016; 
Estimated number of abandoned mine sites on Forest Service land[B]: 
3,899; 
Total: 4,915. 

State: Nevada; 
Estimated number of abandoned mine sites on BLM land[A]: 9,000; 
Estimated number of abandoned mine sites on Forest Service land[B]: 
1,613; 
Total: 10,613. 

State: New Mexico; 
Estimated number of abandoned mine sites on BLM land[A]: 3,000; 
Estimated number of abandoned mine sites on Forest Service land[B]: 
989; 
Total: 3,989. 

State: Oregon; 
Estimated number of abandoned mine sites on BLM land[A]: 3,400; 
Estimated number of abandoned mine sites on Forest Service land[B]: 
2,427; 
Total: 5,827. 

State: South Dakota; 
Estimated number of abandoned mine sites on BLM land[A]: Not reported; 
Estimated number of abandoned mine sites on Forest Service land[B]: 
503; 
Total: 503. 

State: Utah; 
Estimated number of abandoned mine sites on BLM land[A]: 10,000; 
Estimated number of abandoned mine sites on Forest Service land[B]: 
697; 
Total: 10,697. 

State: Washington; 
Estimated number of abandoned mine sites on BLM land[A]: Not reported; 
Estimated number of abandoned mine sites on Forest Service land[B]: 
1,956; 
Total: 1,956. 

State: Wyoming; 
Estimated number of abandoned mine sites on BLM land[A]: 2,000; 
Estimated number of abandoned mine sites on Forest Service land[B]: 
336; 
Total: 2,336. 

State: Total; 
Estimated number of abandoned mine sites on BLM land[A]: 70,816; 
Estimated number of abandoned mine sites on Forest Service land[B]: 
28,921; 
Total: 99,737. 

Source: GAO analysis of BLM and Forest Service data. 

[A] These data are from BLM's Abandoned Mine Land Inventory and 
Remediation Report, BLM/NV/GI-97/004, November 1996. 

[B] These data are from the U.S. Geological Survey's analysis of data 
in the Mineral Resources Data System (of which the Mineral Availability 
System/Mineral Industry Locator System is now a part), revised by the 
Forest Service as of November 2007. 

[End of table] 

To estimate abandoned hardrock mine sites in the 12 western states and 
South Dakota, we developed a standard definition for these mine sites. 
In developing this definition, we consulted with mining experts at the 
National Association of Abandoned Mine Land Programs; the Interstate 
Mining Compact Commission; and the Colorado Department of Natural 
Resources, Division of Reclamation, Mining and Safety, Office of Active 
and Inactive Mines. We defined an abandoned hardrock mine site as a 
site that includes all associated facilities, structures, improvements, 
and disturbances at a distinct location associated with activities to 
support a past operation, including prospecting, exploration, 
uncovering, drilling, discovery, mine development, excavation, 
extraction, or processing of mineral deposits locatable under the 
general mining laws. We also asked the states to estimate the number of 
features at these sites that pose physical safety hazards and the 
number of sites with environmental degradation. 

Using this definition, states reported to us the number of abandoned 
sites in their states, and we calculated that there are at least 
161,000 abandoned hardrock mine sites in their states. At these sites, 
on the basis of state data, we estimated that at least 332,000 features 
may pose physical safety hazards, such as open shafts or unstable or 
decayed mine structures. Furthermore, we estimated that at least 33,000 
sites have degraded the environment, by, for example, contaminating 
surface and ground water or leaving arsenic-contaminated tailings 
piles.[Footnote 15] Table 3 shows our estimate of the number of 
abandoned hardrock mine sites in the 12 western states and South 
Dakota, the number of features that pose significant public health and 
safety hazards, and the number of sites with environmental degradation. 

Table 3: GAO's Estimate of the Number of Abandoned Hardrock Mine Sites, 
Features That Pose Significant Public and Safety Hazards, and Sites 
With Environmental Degradation, in 12 Western States and South Dakota, 
as of October 1, 2007: 

State: Alaska; 
Estimated number of abandoned hardrock (non-coal, locatable) mine 
sites: 469; 
Estimated number of features that pose a significant hazard to public 
health and safety: 235; 
Estimated number of sites with environmental degradation: 99. 

State: Arizona; 
Estimated number of abandoned hardrock (non-coal, locatable) mine 
sites: 50,000; 
Estimated number of features that pose a significant hazard to public 
health and safety: 59,400; 
Estimated number of sites with environmental degradation: 9,900. 

State: California; 
Estimated number of abandoned hardrock (non-coal, locatable) mine 
sites: 47,084; 
Estimated number of features that pose a significant hazard to public 
health and safety: 164,795; 
Estimated number of sites with environmental degradation: 5,200. 

State: Colorado; 
Estimated number of abandoned hardrock (non-coal, locatable) mine 
sites: 7,300; 
Estimated number of features that pose a significant hazard to public 
health and safety: 17,000; 
Estimated number of sites with environmental degradation: 150. 

State: Idaho; 
Estimated number of abandoned hardrock (non-coal, locatable) mine 
sites: 7,100; 
Estimated number of features that pose a significant hazard to public 
health and safety: Not reported; 
Estimated number of sites with environmental degradation: Not reported. 

State: Montana; 
Estimated number of abandoned hardrock (non-coal, locatable) mine 
sites: 6,000; 
Estimated number of features that pose a significant hazard to public 
health and safety: 6,000-22,000; 
Estimated number of sites with environmental degradation: 331. 

State: Nevada; 
Estimated number of abandoned hardrock (non-coal, locatable) mine 
sites: 16,000; 
Estimated number of features that pose a significant hazard to public 
health and safety: 51,000; 
Estimated number of sites with environmental degradation: 150. 

State: New Mexico; 
Estimated number of abandoned hardrock (non-coal, locatable) mine 
sites: 800; 
Estimated number of features that pose a significant hazard to public 
health and safety: 15,000; 
Estimated number of sites with environmental degradation: 200-300. 

State: Oregon; 
Estimated number of abandoned hardrock (non-coal, locatable) mine 
sites: 3,823; 
Estimated number of features that pose a significant hazard to public 
health and safety: Not reported; 
Estimated number of sites with environmental degradation: 140. 

State: South Dakota; 
Estimated number of abandoned hardrock (non-coal, locatable) mine 
sites: 950; 
Estimated number of features that pose a significant hazard to public 
health and safety: Not reported; 
Estimated number of sites with environmental degradation: Not reported. 

State: Utah; 
Estimated number of abandoned hardrock (non-coal, locatable) mine 
sites: 17,000; 
Estimated number of features that pose a significant hazard to public 
health and safety: 17,000; 
Estimated number of sites with environmental degradation: 17,000. 

State: Washington; 
Estimated number of abandoned hardrock (non-coal, locatable) mine 
sites: 3,629; 
Estimated number of features that pose a significant hazard to public 
health and safety: 1,608; 
Estimated number of sites with environmental degradation: 50. 

State: Wyoming; 
Estimated number of abandoned hardrock (non-coal, locatable) mine 
sites: 956; 
Estimated number of features that pose a significant hazard to public 
health and safety: 519; 
Estimated number of sites with environmental degradation: 437. 

State: Total; 
Estimated number of abandoned hardrock (non-coal, locatable) mine 
sites: 161,111; 
Estimated number of features that pose a significant hazard to public 
health and safety: 332,557-348,557; 
Estimated number of sites with environmental degradation: 33,657- 
33,757. 

Source: GAO analysis of state-reported data. 

Notes: While states used our definition to provide data on the 
estimated number of mine sites and features, these data have two key 
limitations: (1) the methods and sources used to identify and confirm 
abandoned sites and hazardous features vary substantially by state and 
(2) states have markedly different data systems and requirements for 
recording data on abandoned mines. For complete information on these 
limitations, see [hyperlink, http://www.gao.gov/products/GAO-08-574T]. 

[End of table] 

BLM Estimates That Operators Have Provided About $982 Million in 
Financial Assurances--About $61 Million Less Than Needed to Cover 
Estimated Reclamation Costs: 

As of November 2007, hardrock mining operators had provided financial 
assurances valued at approximately $982 million to guarantee the 
reclamation cost for 1,463 hardrock mining operations on BLM land in 11 
western states, according to BLM's Bond Review Report.[Footnote 16] The 
report also indicates that 52 of the 1,463 hardrock mining operations 
had inadequate financial assurances--about $28 million less than needed 
to fully cover estimated reclamation costs. We determined, however, 
that the financial assurances for these 52 operations should be more 
accurately reported as about $61 million less than needed to fully 
cover estimated reclamation costs. Table 4 shows total operations by 
state, the number of operations with inadequate financial assurances, 
the financial assurances required, BLM's calculation of the shortfall 
in assurances, and our estimate of the shortfall, as of November 2007. 

Table 4: Total Hardrock Mining Operations, Operations with Inadequate 
Financial Assurances, Financial Assurances Required, and Difference 
Between Requirements and Actual Value, by State, as of November 2007: 

State: Arizona; 
Total operations: 107; 
Operations with inadequate financial assurances: 2; 
Financial assurances required: $7,689,394; 
BLM's difference between current and required value of financial 
assurances: ($49,583); 
GAO's difference between current and required value of financial 
assurances: ($101,870). 

State: California; 
Total operations: 95; 
Operations with inadequate financial assurances: 4; 
Financial assurances required: $24,530,439; 
BLM's difference between current and required value of financial 
assurances: $1,593,013; 
GAO's difference between current and required value of financial 
assurances: ($439,669). 

State: Colorado; 
Total operations: 250; 
Operations with inadequate financial assurances: 4; 
Financial assurances required: $1,605,574; 
BLM's difference between current and required value of financial 
assurances: ($170,291); 
GAO's difference between current and required value of financial 
assurances: ($167,730). 

State: Idaho; 
Total operations: 46; 
Operations with inadequate financial assurances: 1; 
Financial assurances required: $1,556,705; 
BLM's difference between current and required value of financial 
assurances: ($13,000); 
GAO's difference between current and required value of financial 
assurances: ($13,000). 

State: Montana; 
Total operations: 41; 
Operations with inadequate financial assurances: 0; 
Financial assurances required: $67,478,064; 
BLM's difference between current and required value of financial 
assurances: $1,200; 
GAO's difference between current and required value of financial 
assurances: 0. 

State: New Mexico; 
Total operations: 28; 
Operations with inadequate financial assurances: 0; 
Financial assurances required: $1,066,735; 
BLM's difference between current and required value of financial 
assurances: 0; 
GAO's difference between current and required value of financial 
assurances: 0. 

State: Nevada; 
Total operations: 579; 
Operations with inadequate financial assurances: 28; 
Financial assurances required: $844,953,161; 
BLM's difference between current and required value of financial 
assurances: ($33,667,684); 
GAO's difference between current and required value of financial 
assurances: ($47,739,814). 

State: Oregon; 
Total operations: 60; 
Operations with inadequate financial assurances: 4; 
Financial assurances required: $366,773; 
BLM's difference between current and required value of financial 
assurances: $47,327; 
GAO's difference between current and required value of financial 
assurances: ($1,227). 

State: Utah; 
Total operations: 150; 
Operations with inadequate financial assurances: 5; 
Financial assurances required: $12,247,645; 
BLM's difference between current and required value of financial 
assurances: ($2,682,539); 
GAO's difference between current and required value of financial 
assurances: ($2,769,802). 

State: Washington; 
Total operations: 4; 
Operations with inadequate financial assurances: 0;
Financial assurances required: $49,975; 
BLM's difference between current and required value of financial 
assurances: 0; 
GAO's difference between current and required value of financial 
assurances: 0. 

State: Wyoming; 
Total operations: 103; 
Operations with inadequate financial assurances: 4; 
Financial assurances required: $47,934,110; 
BLM's difference between current and required value of financial 
assurances: $7,103,396; 
GAO's difference between current and required value of financial 
assurances: ($9,518,877). 

State: Total; 
Total operations: 1,463; 
Operations with inadequate financial assurances: 52; 
Financial assurances required: $1,009,478,575; 
BLM's difference between current and required value of financial 
assurances: ($27,838,161); 
GAO's difference between current and required value of financial 
assurances: ($60,751,989). 

Source: GAO analysis of BLM's Bond Review Report. 

[End of table] 

The $33 million difference between our estimated shortfall of nearly 
$61 million and BLM's estimated shortfall of nearly $28 million occurs 
because BLM calculated its shortfall by comparing the total value of 
financial assurances in place with the total estimated reclamation 
costs. This calculation approach has the effect of offsetting the 
shortfalls in some operations with the greater than required financial 
assurances of other operations. However, the financial assurances that 
are greater than the amount required for an operation cannot be 
transferred to an operation with inadequate financial assurances. In 
contrast, we totaled the difference between the financial assurance in 
place for an operation and the financial assurances needed for that 
operation to determine the actual shortfall for each of the 52 
operations for which BLM had determined that financial assurances were 
inadequate. 

BLM's approach to determining the adequacy of financial assurances is 
not useful because it does not clearly lay out the extent to which 
financial assurances are inadequate. For example, in California, BLM 
reported that, statewide, the financial assurances in place were $1.5 
million greater than required as of November 2007, suggesting 
reclamation costs are being more than fully covered. However, according 
to our analysis of only those California operations with inadequate 
financial assurances, the financial assurances in place were nearly 
$440,000 less than needed to fully cover reclamations costs. BLM 
officials agreed that it would be valuable for the Bond Review Report 
to report the dollar value of the difference between financial 
assurances in place and required for those operations where financial 
assurances are inadequate and have taken steps to modify LR2000. 

BLM officials said that financial assurances may appear inadequate in 
the Bond Review Report when: 

* expansions or other changes in the operation have occurred, thus 
requiring an increase in the amount of the financial assurance; 

* BLM's estimate of reclamation costs has increased and there is a 
delay between when BLM enters the new estimate into LR2000 and when the 
operator provides the additional bond amount; and: 

* BLM has delayed updating its case records in LR2000. 

Conversely, hardrock mining operators may have financial assurances 
greater than required for a number of reasons; for example, they may 
increase their financial assurances because they anticipate expanding 
their hardrock operations. 

In addition, according to the Bond Review Report, there are about 2.4 
times as many notice-level operations--generally, operations that cause 
surface disturbance on 5 acres or less--as there are plan-level 
operations on BLM land--generally operations that disturb more than 5 
acres (1,033 notice-level operations and 430 plan-level operations). 
However, about 99 percent of the value of financial assurances is for 
plan-level operations, while 1 percent of the value is for notice-level 
operations. While financial assurances were inadequate for both notice- 
and plan-level operations, a greater percentage of plan-level 
operations had inadequate financial assurances than did notice-level 
operations--6.7 percent and 2.2 percent, respectively. Finally, over 
one-third of the number of all hardrock operations and about 84 percent 
of the value of all financial assurances are for hardrock mining 
operations located in Nevada. 

Mr. Chairman, this concludes my prepared statement. I would be happy to 
respond to any questions that you or Members of the Committee may have. 

Contact and Staff Acknowledgments: 

Contact points for our Offices of Congressional Relations and Public 
Affairs may be found on the last page of this testimony. For further 
information about this testimony, please contact Robin M. Nazzaro, 
Director, Natural Resources and Environment (202) 512-3841 or 
Nazzaror@gao.gov. Key contributors to this testimony were Andrea 
Wamstad Brown (Assistant Director); Elizabeth Beardsley; Casey L. 
Brown; Kristen Sullivan Massey; Rebecca Shea; and Carol Herrnstadt 
Shulman. 

[End of section] 

Footnotes: 

[1] GAO, Hardrock Mining: Information on State Royalties and Trends in 
Mineral Import and Exports, [hyperlink, 
http://www.gao.gov/products/GAO-08-849R] (Washington, D.C.: July 21, 
2008); and GAO, Hardrock Mining: Information on Abandoned Mines and 
Value and Coverage of Financial Assurances on BLM Land, [hyperlink, 
http://www.gao.gov/products/GAO-08-574T] (Washington, D.C.: Mar. 12, 
2008). 

[2] Under U.S. mining laws, minerals are classified as locatable, 
leasable, or saleable. Locatable minerals include those minerals that 
are not leasable or saleable, for example, copper, lead, zinc, 
magnesium, gold, silver, and uranium. Only locatable minerals continue 
to be "claimed" under the Mining Act. For the purposes of this report, 
we use the term "hardrock minerals" as a synonym for "locatable 
minerals." Leasable minerals include, for example, oil, gas, and coal. 
The Mineral Leasing Act of 1920, 41 Stat. 437 (codified at 30 U.S.C. § 
181) created a leasing system for coal, gas, oil and other fuels, and 
chemical minerals. Saleable minerals include, for example, common sand, 
stone, and gravel. In 1955, the Multiple Use Mining Act of 1955, 69 
Stat. 367 (codified at 30 U.S.C. § 601) removed common varieties of 
sand, stone, and gravel from development under the Mining Act. 

[3] The other 11 western states are Arizona, California, Colorado, 
Idaho, Montana, Nevada, New Mexico, Oregon, Utah, Washington, and 
Wyoming. 

[4] For purposes of this testimony, cleanup refers to the mitigation of 
environmental impacts at mine sites, such as contaminated water, and 
the reclamation of land disturbed by hardrock operations. 

[5] GAO, Hardrock Mining: BLM Needs to Better Manage Financial 
Assurances to Guarantee Coverage of Reclamation Costs, [hyperlink, 
http://www.gao.gov/products/GAO-05-377] (Washington, D.C.: June 20, 
2005). 

[6] We defined an abandoned hardrock mine site as all associated 
facilities, structures, improvements, and disturbances at a distinct 
location associated with activities to support a past operation under 
the general mining laws. 

[7] Data for Alaska are not maintained in LR2000 and not reported in 
the Bond Review Report. 

[8] [hyperlink, http://www.gao.gov/products/GAO-08-849R] and 
[hyperlink, http://www.gao.gov/products/GAO-08-574T]. 

[9] For a full discussion of the definition and formula for each type 
of royalty, see [hyperlink, http://www.gao.gov/products/GAO-08-849R]. 

[10] For a complete listing of exclusions, deductions, and limitations, 
see [hyperlink, http://www.gao.gov/products/GAO-08-849R], enclosure II, 
table 3. 

[11] Gross income is the value of ore immediately after its removal 
from the mine and does not include any value added subsequent to mining 
by any treatment processes. 

[12] Gross value of product, less first $250,000; Gross value is the 
receipts received from the sale of concentrates or metals extracted 
from mines or recovered from the smelting, milling, reduction, or 
treatment of such ores. Receipts received is defined as the payment 
received, less allowable deductions. 

[13] For a full discussion of these six studies, see [hyperlink, 
http://www.gao.gov/products/GAO-08-574T], appendix III. 

[14] BLM and Forest Service, Abandoned Mine Lands: A Decade of Progress 
Reclaiming Hardrock Mines (September 2007). 

[15] Tailings are a combination of fluid and rock materials that are 
left behind after the minerals are extracted. Tailings are often 
disposed of in a nearby pile. 

[16] Data for Alaska are not maintained in LR2000 and not reported in 
the Bond Review Report. 

[End of section] 

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