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Testimony: 

Before the Committee on Energy and Natural Resources, U.S. Senate: 

United States Government Accountability Office: 
GAO: 

For Release on Delivery: 
Expected at 2:15 p.m. EDT:
Wednesday, March 12, 2008: 

Hardrock Mining: 

Information on Abandoned Mines and Value and Coverage of Financial 
Assurances on BLM Land: 

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

GAO-08-574T: 

GAO Highlights: 

Highlights of GAO-08-574T, testimony before the Committee on Energy and 
Natural Resources, U.S. Senate. 

Why GAO Did This Study: 

The Mining Act of 1872 helped foster the development of the West by 
giving individuals exclusive rights to mine gold, silver, copper, and 
other hardrock minerals on federal lands. However, miners often 
abandoned mines, leaving behind structures, safety hazards, and 
contaminated land and water. Four federal agencies—the Department of 
the Interior’s Bureau of Land Management (BLM) and Office of Surface 
Mining Reclamation and Enforcement (OSM), the Forest Service, and the 
Environmental Protection Agency (EPA)—fund the cleanup of some of these 
sites. 

To curb further growth in the number of abandoned hardrock mines on 
federal lands, in 1981 BLM began requiring mining operators to reclaim 
lands when their operations ceased. In 2001, BLM began requiring all 
operators to provide financial assurances to guarantee funding for 
reclamation costs if the operator did not complete the task as 
required. 

This testimony provides information on the (1) federal funds spent to 
clean up abandoned hardrock mine sites since 1998, (2) number of 
abandoned hardrock mine sites and hazards, and (3) value and coverage 
of financial assurances operators use to guarantee reclamation costs on 
BLM land. To address these issues, GAO, among other steps, asked 12 
western states and Alaska to provide information on the number of 
abandoned mine sites and associated features in their states using a 
consistent definition 

What GAO Found: 

Between fiscal years 1998 and 2007, BLM, the Forest Service, EPA, and 
OSM spent at least $2.6 billion (in 2008 constant dollars) to reclaim 
abandoned hardrock mines. BLM and the Forest Service have reclaimed 
abandoned hardrock mine sites on the lands they manage; EPA funds the 
cleanup of these sites, primarily on nonfederal lands through its 
Superfund program; and OSM provides some grants to states and Indian 
tribes to clean up these sites on their lands. Of the four agencies, 
EPA has spent the most—about $2.2 billion (in 2008 constant dollars) 
for mine cleanups. BLM and the Forest Service spent about $259 million 
(in 2008 constant dollars), and OSM awarded grants totaling about $198 
million (in 2008 constant dollars) to support the cleanup of abandoned 
hardrock mines. 

Over the last 10 years, estimates of the number of abandoned hardrock 
mining sites in the 12 western states and Alaska have varied widely, in 
part because there is no generally accepted definition for a hardrock 
mine site. Using a consistent definition that GAO provided, 12 western 
states and Alaska provided estimates of abandoned hardrock mine sites. 
On the basis of these data, GAO estimated a total of at least 161,000 
such sites in these states with 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’s information on financial assurances as reported in 
its November 2007 Bond Review Report, mine operators had provided 
financial assurances valued at approximately $982 million to guarantee 
reclamation costs for 1,463 hardrock operations on BLM land. The report 
also estimates that 52 mining operations have financial assurances that 
amount to about $28 million less than needed to fully cover estimated 
reclamation costs. However, GAO found that the financial assurances for 
these 52 operations are in fact about $61 million less than needed to 
fully cover estimated reclamation costs. The $33 million difference 
between GAO’s estimated shortfall and BLM’s 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 financial assurances of other operations. 
However, financial assurances that are greater than the amount required 
for an operation cannot be transferred to another operation that has 
inadequate financial assurances. 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 BLM has taken 
steps to correct this. 

GAO discussed the information in this testimony with officials from the 
four federal agencies, and they provided GAO with technical comments, 
which were incorporated as appropriate. 

To view the full product, including the scope and methodology, click on 
[hyperlink, http://www.GAO-08-574T]. 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 several aspects of hardrock 
mining, including abandoned hardrock mining sites and financial 
assurances. We developed this information during the course of our 
ongoing review, which is being conducted at the request of this 
Committee, Senator Reid, and the Chairman of the House Committee on 
Natural Resources. 

As you know, the General Mining Act of 1872 encouraged the development 
of the West by allowing individuals to stake claims and obtain 
exclusive rights to the gold, silver, copper, and other valuable 
hardrock mineral deposits on land belonging to the United States. Since 
then, thousands of operators have extracted billions of dollars worth 
of hardrock minerals from land managed by the Department of the 
Interior's Bureau of Land Management (BLM) and the U.S. Department of 
Agriculture's Forest Service--the two principal agencies responsible 
for federal lands open for hardrock mining. However, some operators did 
not reclaim thousands of acres of federal land disturbed for 
exploration, mining, and mineral processing when their operations 
ceased. Some of these disturbed 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 1] For 
example, the cost of plugging holes is usually minimal, but reclamation 
costs for large mining operations can be in the tens of millions of 
dollars. 

Four federal agencies--BLM, the Forest Service, the Environmental 
Protection Agency (EPA), and the Department of the Interior's Office of 
Surface Mining Reclamation and Enforcement (OSM)--fund the cleanup and 
reclamation of some of these abandoned hardrock mine sites. BLM's and 
the Forest Service's Abandoned Mine Lands programs focus on the safety 
of their land by addressing physical and environmental hazards. EPA's 
funding of abandoned hardrock mine sites, under its Superfund Program, 
focuses on the cleanup and long-term health effects of air, ground, or 
water pollution by abandoned hardrock mine sites, and is generally for 
mines on nonfederal lands. Finally, OSM, under amendments to the 
Surface Mining Control and Reclamation Act (SMCRA) of 1977,[Footnote 2] 
can provide grants to fund the cleanup and reclamation of certain 
hardrock mining sites after a state certifies that it has cleaned up 
its abandoned coal mine sites and the Secretary of the Interior 
approves the certification or at the request of a state or an Indian 
tribe. 

Federal agencies, states, mining, and environmental organizations, and 
others have attempted to determine the total number of abandoned 
hardrock mines and the safety and environment hazards these mines pose. 
These estimates vary widely, and many of these abandoned hardrock mines 
present safety, health, and environmental hazards. 

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.[Footnote 3] 
In 2001, BLM regulations began requiring all mining operators to 
provide financial assurances before beginning exploration or mining 
operations on BLM land.[Footnote 4] These financial assurances must 
cover all of the estimated reclamation costs for a given hardrock 
operation.[Footnote 5] 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 6] In that report we: 

* concluded that BLM did not have an effective process and critical 
management information needed for ensuring that adequate financial 
assurances are actually in place, as required by federal regulations 
and BLM guidance; and: 

* made recommendations to strengthen BLM's management of financial 
assurances for hardrock operations on its lands. 

In response to those recommendations, BLM modified its computer system-
-LR2000--to generate the Bond Review Fiscal Report (the Bond Review 
Report). BLM uses this report to determine if adequate financial 
assurances are in place for mining operations on its lands. BLM also 
requires its state directors to annually review the Bond Review Report 
to determine if all reclamation cost estimates are adequate, take 
action to address inadequacies, and certify that the financial 
assurances are adequate. 

In contrast to BLM, the Forest Service--the other federal agency 
principally responsible for hardrock mining operations on federal land-
-does not have readily available information on the financial 
assurances in place for hardrock operations on its lands. Although the 
Forest Service's regulations do not require financial assurances for 
all operations, the Forest Service's policy is to require them. 

In this context, my testimony today, as requested, discusses the (1) 
federal funds spent to clean up abandoned hardrock mine sites since 
1998, (2) number of abandoned hardrock mine sites and the number of 
associated hazards, and (3) value and coverage of the financial 
assurances operators use to guarantee reclamation costs on BLM land. 

To address these objectives, we interviewed staff at BLM, the Forest 
Service, EPA, and OSM; examined agency documents and data; and reviewed 
relevant legislation and regulations. In addition, for the first 
objective, we obtained federal expenditure data from these four 
agencies for cleaning up and reclaiming abandoned hardrock mine sites 
from fiscal years 1998 through 2007. We adjusted the expenditure data 
to 2008 constant dollars. For the second objective, we asked 12 western 
states and Alaska--which have significant numbers of abandoned hardrock 
mining operations--to determine the number of these mine sites in their 
states.[Footnote 7] 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. 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 of minerals 
locatable under the general mining laws. 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 abandoned 
hardrock mine sites, the number of features that pose physical safety 
hazards, and the number of sites with environmental hazards in the 12 
western states and Alaska. We also summarized selected prior survey 
efforts by federal agencies and organizations to document differences 
in estimates, definitions, and methodologies. For the third objective, 
we reviewed BLM's Bond Review Report to determine the value and 
coverage of financial assurances in place to guarantee coverage of 
reclamation costs. This report provides information on financial 
assurances for 11 western states.[Footnote 8] 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. 

We conducted this performance audit from November 2007 through March 
2008, in accordance with generally accepted government auditing 
standards. 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. See 
appendix I for more detailed information on our scope and methodology. 

In summary: 

* The four federal agencies we examined--BLM, the Forest Service, EPA, 
and OSM--spent at least $2.6 billion (in 2008 constant dollars) between 
fiscal years 1998 and 2007 to clean up abandoned hardrock mines. BLM 
and the Forest Service spent a total of about $259 million (in 2008 
constant dollars) to fund the cleanup of abandoned sites on the lands 
they manage. EPA spent the most of the four agencies--about $2.2 
billion (in 2008 constant dollars) to fund the cleanup of abandoned 
mine sites, primarily on nonfederal land through its Superfund program, 
and OSM provided grants to states and Indian tribes totaling about $198 
million (in 2008 constant dollars) to support cleanups of abandoned 
hardrock mines. 

* According to several studies we reviewed that were conducted over the 
last 10 years, estimates of the number of abandoned hardrock mine sites 
in the 12 western states and Alaska vary widely, in part because there 
is no generally accepted definition for a hardrock mine site and the 
studies rely on the different definitions the states used. Furthermore, 
BLM's and the Forest Service's estimate of 100,000 abandoned hardrock 
mines on their lands is problematic because they included non-hardrock 
mines and mines that may not be on their lands. Using a consistent 
definition that we provided, the 12 western states and Alaska estimated 
the number of hardrock mine sites in their states and from this 
information we estimated a total of at least 161,000 abandoned hardrock 
mine sites in these states on state, private, or federal lands. These 
sites have at least 332,000 features that may pose physical safety 
hazards, such as open shafts or unstable or decayed mine structures. 
The states also estimated that at least 33,000 sites have degraded the 
environment by, for example, contaminating surface water and 
groundwater. 

* As of November 2007, mine operators had provided financial assurances 
valued at approximately $982 million to guarantee reclamation costs for 
1,463 hardrock operations on BLM land in 11 western states, according 
to BLM's Bond Review Report. The report also estimates that 52 mining 
operations have inadequate financial assurances amounting to about $28 
million less than needed to fully cover estimated reclamation costs. 
However, we determined that the financial assurances for the 52 
operations are actually about $61 million less than needed to fully 
cover estimated reclamation costs. The $33 million difference between 
our estimated shortfall and BLM's 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 
financial assurances of other operations. However, financial assurances 
that are greater than the amount required for an operation cannot be 
transferred to another operation that has inadequate financial 
assurances. 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 BLM has taken steps to modify 
LR2000. 

We discussed the information in this testimony with officials from the 
four federal agencies, and they provided us with technical comments, 
which we incorporated as appropriate. 

Background: 

Historically, the mining of hardrock minerals, such as gold, lead, 
copper, silver, and uranium, was an economic incentive for exploring 
and settling the American West. However, when the ore was depleted, 
miners often left behind a legacy of abandoned mines, structures, 
safety hazards, and contaminated land and water. Even in more recent 
times, after cleanup became mandatory, many parties responsible for 
hardrock mining sites have been liquidated through bankruptcy or 
otherwise dissolved.[Footnote 9] Under these circumstances, some 
hardrock mining companies have left it to the taxpayer to clean up the 
mining site. BLM, the Forest Service, EPA, and OSM play a role in 
cleaning up these abandoned mining sites and ensuring that currently 
operating sites are reclaimed after operations have ceased. 

BLM and the Forest Service are responsible for managing more than 450 
million acres of public lands in their care, including land disturbed 
and abandoned by past hardrock mining activities. BLM manages about 258 
million acres in 12 western states, including Alaska. The Forest 
Service manages about 193 million acres across the nation. In 1997, BLM 
and the Forest Service each launched a national Abandoned Mine Lands 
Program to remedy the physical and environmental hazards at thousands 
of abandoned hardrock mines on the federal lands they manage. According 
to a September 2007 report by these two agencies, they had inventoried 
thousands of abandoned sites and, at many of them, had taken actions to 
clean up hazardous substances and mitigate safety hazards.[Footnote 10] 

BLM and the Forest Service are also responsible for managing and 
overseeing current hardrock operations on their lands, including the 
mining operators' reclamation of the land disturbed by hardrock mining. 
Although reclamation can vary by location, it generally involves such 
activities as regrading and reshaping the disturbed land to conform 
with adjacent land forms and to minimize erosion; removing or 
stabilizing buildings and other structures to reduce safety risks; 
removing mining roads to prevent damage from future traffic; and 
establishing self-sustaining vegetation. One of the agencies' key 
responsibilities is to ensure that adequate financial assurances, based 
on sound reclamation plans and cost estimates, are in place to 
guarantee reclamation costs.[Footnote 11] If a mining operator fails to 
complete required reclamation, BLM or the Forest Service can take steps 
to obtain funds from the financial assurance provider to complete the 
reclamation. 

BLM requires financial assurances for both notice-level hardrock mining 
operations--those disturbing 5 acres of land or less--and plan-level 
hardrock mining operations--those disturbing over 5 acres of land and 
those in certain designated areas, such as the national wild and scenic 
rivers system. For hardrock operations on Forest Service lands, agency 
regulations require reclamation of sites after operations cease, but do 
not require financial assurances for the reclamation. However, 
according to a Forest Service official, if the proposed hardrock 
operation is likely to cause a significant disturbance, the Forest 
Service requires financial assurances. 

Both agencies allow several types of financial assurances to guarantee 
estimated reclamation costs for hardrock operations on their lands. 
According to regulations and agency officials, BLM and the Forest 
Service allow cash, letters of credit, certificates of deposit or 
savings accounts, and negotiable U.S. securities and bonds in a trust 
account. BLM also allows surety bonds, state bond pools, trust funds, 
and property. 

Neither agency centrally tracks all the types of financial assurances 
in place for hardrock operations on its lands. BLM's LR2000 tracks most 
of the types, and BLM is updating the database to include more types of 
financial assurances, but data are incomplete for the types of 
assurances currently in the system. The Forest Service does not have 
readily available information on the types of financial assurances in 
use, but it is developing a database to collect this and other 
information on hardrock operations by late summer 2008, according to 
Forest Service officials. 

EPA administers the Superfund program, which was established under the 
Comprehensive Environmental Response, Compensation, and Liability Act 
of 1980 to address the threats that contaminated waste sites, including 
those on nonfederal lands, pose to human health and the 
environment.[Footnote 12] The act also requires that the parties 
statutorily responsible for pollution bear the cost of cleaning up 
contaminated sites, including abandoned hardrock mining operations. 
Some contaminated hardrock mine sites have been listed on Superfund's 
National Priorities List--a list of seriously contaminated sites. 
Typically, these sites are expensive to clean up and the cleanup can 
take many years. According to EPA's Office of Inspector General in 
2004, 63 hardrock mining sites were on the National Priorities List and 
another 93 sites had the potential to be added to the list.[Footnote 
13] Regarding financial assurances, EPA has statutory authority under 
the Superfund program to require businesses handling hazardous 
substances on nonfederal lands to provide financial 
assurances,[Footnote 14] and according to agency officials, is 
currently exploring options for implementing this authority. 

OSM's Abandoned Mine Land Program primarily focuses on cleaning up 
abandoned coal mine sites. However, OSM, under amendments to the 
Surface Mining Control and Reclamation Act (SMCRA) of 1977, can provide 
grants to fund the cleanup and reclamation of certain hardrock mining 
sites either (1) after a state certifies that it has cleaned up its 
abandoned coal mine sites and the Secretary of the Interior approves 
the certification, or (2) at the request of a state or Indian tribe to 
address problems that could endanger life and property, constitute a 
hazard to the public and safety, or degrade the environment, and the 
Secretary of the Interior grants the request. OSM has provided more 
than $3 billion to clean up dangerous abandoned mine sites. Its 
Abandoned Mine Land Program has eliminated safety and environmental 
hazards on 314,108 acres since 1977, including all high-priority coal 
problems and non-coal problems in 27 states and on the lands of three 
Indian tribes.[Footnote 15] 

Federal Agencies Have Spent At Least $2.6 Billion to Clean Up Abandoned 
Hardrock Mine Sites Since 1998: 

Between fiscal years 1998 and 2007, the four federal agencies we 
examined--BLM, the Forest Service, EPA, and OSM--spent at least $2.6 
billion to reclaim abandoned hardrock mines on federal, state, private, 
and Indian lands. EPA has spent the most--$2.2 billion.[Footnote 16] 
Although the amount each agency spent annually varied considerably, the 
median amount spent for the public lands by BLM and the Forest Service 
was about $5 million and about $21 million, respectively. EPA spent 
substantially more--a median of about $221 million annually--to clean 
up mines that are generally on nonfederal lands. Finally, OSM provided 
grants with an annual median value of about $18 million to states and 
Indian tribes through its SMCRA program for hardrock mine cleanups. 
Table 1 summarizes information on expenditures and hardrock mine 
cleanup activities at BLM, the Forest Service, EPA, and OSM. See 
appendix II for more detailed information on agency expenditures by 
fiscal year. 

Table 1: Summary of Expenditures for Cleaning Up Abandoned Hardrock 
Mines at BLM, the Forest Service, EPA, and OSM, Fiscal Years 1998 
through 2007; Dollars in thousands (2008 constant dollars): 

Total expenditures between fiscal years 1998 and 2007: 
BLM[A]: $50,462; 
Forest Service: $208,709; 
EPA[B]: $2,155,916; 
OSM: $198,099. 

Median expenditures, fiscal years 1998 through 2007: 
BLM[A]: $5,141; 
Forest Service: $21,476; 
EPA[B]: $221,029; 
OSM: $17,626. 

Percent of total: 
BLM[A]: 1.9; 
Forest Service: 7.8; 
EPA[B]: 82.6; 
OSM: 7.6. 

Source: GAO analysis of BLM, Forest Service, EPA, and OSM data. 

[A] These data include funding for large cleanup projects from the Soil 
Water and Air and the Hazard Management and Resource Restoration 
subactivities from BLM appropriations. These data do not include 
funding for smaller projects under those two subactivities, funding 
from Central Hazardous Materials Fund or the Natural Resource Damage 
Assessment and Restoration subactivities from the Department of the 
Interior's appropriations, or funding under the Southern Nevada Public 
Land Management Act. 

[B] According to EPA officials, about 90 percent of these expenditures 
are EPA's; the other 10 percent are funds from responsible parties and 
states. 

[End of table] 

According to available data, as of September 30, 2007, BLM had spent 
the largest share of its funds in Montana--about $18 million; EPA had 
spent the largest share of its funds in Idaho--about $352 million; and 
Wyoming was the largest recipient of OSM grants for cleaning up 
hardrock mine sites--receiving about $99 million. Wyoming was eligible 
for OSM grants after OSM's acceptance of the state's certification that 
it had completed its cleanup of coal mine sites. The Forest Service was 
unable to provide this information by state. See appendix II for BLM, 
EPA, and OSM total funding by state. 

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: 

Previous state estimates of the number of abandoned hardrock mine sites 
vary widely in the six studies that we reviewed because, in part, there 
is no generally accepted definition for a hardrock mine site and the 
studies rely on the states' different definitions of hardrock mine 
sites. In addition, we found problems with BLM's and the Forest 
Service's estimate of 100,000 abandoned hardrock mines on their lands 
because the agencies included non-hardrock mines and mines that may not 
be on their lands. Using our consistent definition, 12 western states 
and Alaska estimated a total of at least 161,000 abandoned hardrock 
mine sites in their states on state, private, or federal lands. 

Six Studies Identified a Range of Estimated Abandoned Hardrock Mining 
Sites: 

We identified six studies conducted in the past 10 years that estimated 
the number of abandoned hardrock mine sites in the 12 western states 
and Alaska.[Footnote 17] The estimates in each of these studies were 
developed by asking states to provide data on the number of abandoned 
hardrock mine sites in their states, generally without regard to 
whether the mine was on federal, state, Indian, or private lands. The 
estimates for a particular state do, in some cases, vary widely from 
study to study. For example, for Nevada, the Western Governors' 
Association/National Mining Association estimated that the state had 
50,000 abandoned hardrock mine sites in 1998, while in 2004 EPA 
estimated that the state had between 200,000 to 500,000 abandoned 
sites. The estimates also reflect the different definitions that states 
used for abandoned hardrock mining sites for a given study. For 
example, we found that, within the same study, some states define an 
abandoned mine site as a mine opening or feature, while others define a 
site as all associated mine openings, features, or structures at a 
distinct location. As a result, an abandoned hardrock operation with 
two mine openings, a pit, and a tailings pile could be listed as one 
site or four sites, depending on the definitions and methodologies 
used. See appendix III for more information on estimates from these 
studies. 

In addition, some regional or state estimates included coal and other 
non-hardrock mineral sites because it was (1) not important to 
distinguish between the type of minerals mined or (2) difficult to 
determine what mineral had been mined. In 2004, EPA commented on this 
problem, noting, "it is important to keep in mind that a universally 
applied definition of an [abandoned mine land] does not exist at 
present...therefore, the various agencies and state- 
developed...inventories presented may possess inconsistencies and are 
not intended for exact quantitative comparisons." 

BLM and Forest Service Estimates of Abandoned Hardrock Mines Include 
Non-Hardrock Mines and Mines That May Not Be on Their Lands. 

BLM and the Forest Service have also had difficulty determining the 
number of abandoned hardrock mines on their lands and have no 
definitive estimates. In September 2007, the agencies reported that 
there were an estimated 100,000 abandoned hardrock mine sites,[Footnote 
18] 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, we found that 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, 
in November 2007, 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 includes a large number of 
sites on lands 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 
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 report on Abandoned Mine Land Inventory 
and Remediation, 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 MAS/MILS is now a part). 

[End of table] 

Using a Consistent Definition, GAO Estimated at Least 161,000 Abandoned 
Sites: 

To estimate abandoned hardrock mining sites in the 12 western states 
and Alaska, 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. See appendix I for the 
complete definition we used when asking states for their estimates. 

Using this definition, states reported to us the number of abandoned 
sites in their states, and we estimated 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; and at least 33,000 sites have degraded the 
environment, by, for example, contaminating surface water and 
groundwater or leaving arsenic-contaminated tailings piles. Table 3 
shows our estimate of the number of abandoned hardrock mine sites in 
the 12 western states and Alaska, 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 Alaska, 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. 

[End of table] 

While states used our definition to provide data on the estimated 
number of mine sites and features, these data have two key limitations. 
First, the methods and sources used to identify and confirm abandoned 
sites and hazardous features vary substantially by state. For example, 
some states, such as Colorado and Wyoming, indicated they had done 
extensive and rigorous fieldwork to identify sites and were reasonably 
confident that their estimates were accurate. Other states, however, 
relied less on rigorous fieldwork, and more on unverified, readily 
available records or data sources, such as published or unpublished 
geological reports, mining claim maps, and the Mineral Availability 
System/Mineral Industry Locator System (MAS/MILS),[Footnote 19] which 
states indicated were typically incomplete. Several of those states 
that relied primarily on literature used the literature only as a 
starting point, and then estimated the number of features on the basis 
of experience. For example, while one state estimated that there were 
about three times the number of public safety hazards as identified by 
the literature, another state estimated that there were four times as 
many, and a third state estimated that there were up to six times as 
many. 

Second, because states have markedly different data systems and 
requirements for recording data on abandoned mines, some states were 
less readily able to provide the data directly from their systems 
without manipulation or estimation. For example, New Mexico estimated 
the number of abandoned mine sites from the data it maintains on 
hazardous features, and Nevada estimated the number of abandoned 
hardrock mine sites from the data it maintains on the number of mining 
districts in the state. 

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 costs for 1,463 hardrock mining operations on BLM lands in 
11 western states, according to BLM's Bond Review Report. 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 hardrock mining 
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. 

Note: Data for Alaska are not maintained in LR2000 and not reported in 
the 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 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 
reports that, statewide, the financial assurances in place are $1.5 
million greater than required, 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 are 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--operations that cause surface 
disturbance on 5 acres or less--as there are plan-level operations on 
BLM land--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. See 
appendix IV for further details on the number of plan-and notice-level 
operations in each state. 

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); Casey L. Brown; Kristen Sullivan 
Massey; Rebecca Shea; and Carol Herrnstadt Shulman. 

[End of section] 

Appendix I: Objectives, Scope, and Methodology: 

To determine the (1) federal funds spent to clean up abandoned hardrock 
mine sites since 1998, (2) number of abandoned hardrock mine sites and 
the number of associated hazards, and (3) value and coverage of the 
financial assurances operators use to guarantee reclamation costs on 
the Department of the Interior's Bureau of Land Management (BLM) land, 
we interviewed officials at the BLM, the U.S. Department of 
Agriculture's Forest Service, the Environmental Protection Agency 
(EPA), and the Department of the Interior's Office of Surface Mining 
Reclamation and Enforcement (OSM); examined agency documents and data; 
and reviewed relevant legislation and regulations. 

Specifically, to answer our first objective, we interviewed officials 
involved with the abandoned mine cleanup programs at BLM, the Forest 
Service, EPA, and OSM to request expenditure data, to understand how 
they tracked and monitored expenditures to clean up abandoned hardrock 
mines, and to request and ensure that we would receive the data we 
needed. We reviewed agency documents, budget justification reports and 
reports detailing agencies' cleanup efforts and programs. We obtained 
data on total expenditures for cleaning up and reclaiming abandoned 
hardrock mine sites that were compiled from BLM's Financial Accounting 
and Reporting System, EPA's Superfund eFacts Database, OSM's Abandoned 
Mine Land Inventory System, and Forest Service officials. BLM officials 
told us that in addition to the expenditure data they provided, the 
agency receives funding allocations from other sources, such as the 
Department of the Interior's Central Hazardous Materials fund. Since 
BLM does not track the expenditures from these other sources, we were 
unable to provide this information. 

Because the four agencies' abandoned hardrock mine programs started in 
different years, start years for expenditure data vary. Specifically, 
BLM's data were for fiscal years 1997 through 2007; Forest Service's 
data, for fiscal years 1996 through 2007; EPA's data, for fiscal years 
1988 through 2007; and OSM's data, for fiscal years 1993 to 2007. We 
performed a limited reliability assessment of the expenditure data and 
determined that we would limit our year-by-year presentation of 
expenditure data to the past 10 years (1998 through 2007) because of 
(1) variability in the program start year across the agencies, (2) 
inconsistencies across the agencies in their methods for tracking and 
reporting the data, and (3) some data recording errors in early years 
at some agencies. We presented these data in 2008 constant dollars. 

Because of limited time in preparing this testimony, we were unable to 
fully assess the reliability of the agencies' expenditure data and the 
data are therefore of undetermined reliability. However, we concluded 
that the data are appropriate as used and presented to meet our 
objectives because we (1) attribute the data to what agencies report as 
their expenditures, (2) present rounded data to minimize the perception 
of precision, and (3) do not base any conclusions or recommendations on 
the data. 

To answer our second objective, we summarized selected prior survey 
efforts by federal agencies and organizations to document differences 
in estimates, definitions, and methodologies.[Footnote 20] We also 
consulted experts in mining and abandoned mine land programs at the 
National Association of Abandoned Mine Land Programs; the Interstate 
Mining Compact Commission; and the Colorado State Department of Natural 
Resources, Division of Reclamation, Mining and Safety, Office of Active 
and Inactive Mines to develop a standard definition for estimating the 
number of abandoned hardrock mine sites, features, and sites with 
environmental degradation. Other efforts to assess the magnitude of the 
abandoned mine situation have acknowledged limitations in their efforts 
to develop a nationwide estimate because of inconsistencies in states' 
definitions and methods for estimating abandoned sites. Consequently, 
through iterative consultation with state and other mining experts, the 
definition we ultimately chose was clear and incorporated enough 
flexibility for all major hardrock mining states--the 12 western states 
and Alaska--to reasonably comply with our request, despite differences 
in how the states might define and maintain abandoned mine 
data.[Footnote 21] We then provided states with an edit-controlled data 
collection instrument that requested data specifically tailored to our 
definitions and methods. Our definition of abandoned hardrock mine 
sites: 

* 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; 

* can range from an isolated prospect shaft and its associated waste 
rock pile and adjacent prospect pits, to a complex site with multiple 
entries, shafts, open pits, mill buildings, waste rock piles, a 
tailings pond, and associated environmental problems; and: 

* includes only hardrock (also known as locatable), non-coal sites. 

Features that pose a significant hazard to public health and safety 
include: 

* features, such as mine openings, structures, and highwalls; and: 

* impoundments that pose a threat to public health and safety and 
require actions to secure, remedy or reclaim. 

Sites with environmental degradation include features that lead to 
environmental degradation, and, consequently, require remediation of 
air, water, or ground pollution. 

Rather than reporting, as requested, the number of features leading to 
environmental degradation, most states reported only the number of 
sites with environmental degradation, if they reported data for this 
request at all. Because most states do not maintain environmental 
degradation data by feature, states could only speculate about this 
figure, or compute it by estimating an average number of features per 
site and multiplying that by the overall number of sites with 
environmental degradation. Because of these limitations with feature- 
level data, we report only the number of sites with data on 
environmental degradation in order to ensure more reliable and 
consistent reporting across the states. 

As a secondary confirmation that states provided data consistent with 
the definition, our data collection instrument included a section for 
states to provide a brief description of how the various data points 
were calculated, and whether the data provided were actual or estimated 
values. Based on comments in these fields, and basic logic checks on 
the data, we followed up as needed through telephone interviews to 
clarify and confirm problematic responses. Our definitional and editing 
processes provided us with reasonable assurance that the data were as 
clean and consistent as possible, and using these final edited data, we 
calculated the estimated number of abandoned mine sites, the number of 
features that pose physical safety and environmental hazards, and the 
number of abandoned mine sites with environmental degradation in the 12 
western states and Alaska. 

To answer our third objective--to determine the value and coverage of 
financial assurances in place to guarantee coverage of reclamation 
costs--we requested the BLM Bond Review Report from BLM's Legacy Rehost 
System 2000 (LR2000) database. Because we had previously reported 
reliability problems with data on financial assurances in 
LR2000,[Footnote 22] we conducted a limited reliability assessment of 
the bond report data. This limited assessment included (1) basic logic 
checks on the data we received, (2) interviews with BLM minerals 
management officials knowledgeable of the changes made to LR2000 to 
address GAO's 2005 recommendations, and (3) a review of BLM's June 14, 
2006, Instruction Memorandum 2006-172 for processing and entering Bond 
Review Report data in LR2000. Although the data are of undetermined 
reliability, our limited assessment indicates that management controls 
were improved for the generation of bond review reports from LR2000. We 
concluded that the data are appropriate as used and presented, and we 
did not base any conclusions or recommendations on these data. 

[End of section] 

Appendix II: Information on Federal Agency Expenditures to Clean Up 
Abandoned Hardrock Mines: 

This appendix provides information on federal expenditures used to 
clean up abandoned hardrock mines by fiscal year (table 5) and by state 
(table 6). 

Table 5: BLM, Forest Service, EPA, and OSM Federal Expenditures to 
Clean Up Abandoned Hardrock Mine Sites, Fiscal Years 1998 to 2007; 
Dollars in thousands (2008 constant dollars): 

Fiscal year: 1998; 
BLM[A]: $1,263; 
Forest Service: $16,623; 
EPA[B]: $176,620; 
OSM: $1,634; 
Total: $194,175. 

Fiscal year: 1999; 
BLM[A]: 5,210; 
Forest Service: 22,003; 
EPA[B]: 225,941; 
OSM: 9,795; 
Total: 257,570. 

Fiscal year: 2000; 
BLM[A]: 5,071; 
Forest Service: 23,150; 
EPA[B]: 228,460; 
OSM: 30,492; 
Total: 286,026. 

Fiscal year: 2001; 
BLM[A]: 5,916; 
Forest Service: 22,617; 
EPA[B]: 245,662; 
OSM: 43,130; 
Total: 317,858. 

Fiscal year: 2002; 
BLM[A]: 5,600; 
Forest Service: 22,192; 
EPA[B]: 191,903; 
OSM: 18,620; 
Total: 238,740. 

Fiscal year: 2003; 
BLM[A]: 4,957; 
Forest Service: 21,752; 
EPA[B]: 209,753; 
OSM: 24,502; 
Total: 261,405. 

Fiscal year: 2004; 
BLM[A]: 8,696; 
Forest Service: 21,200; 
EPA[B]: 225,680; 
OSM: 16,631; 
Total: 272,760. 

Fiscal year: 2005; 
BLM[A]: 6,350; 
Forest Service: 20,542; 
EPA[B]: 222,508; 
OSM: 11,236; 
Total: 261,294. 

Fiscal year: 2006; 
BLM[A]: 4,587; 
Forest Service: 19,779; 
EPA[B]: 219,549; 
OSM: 15,450; 
Total: 260,128. 

Fiscal year: 2007; 
BLM[A]: 2,811; 
Forest Service: 18,852; 
EPA[B]: 209,839; 
OSM: 26,608; 
Total: 259,037. 

Fiscal year: Total; 
BLM[A]: $50,462; 
Forest Service: $208,709; 
EPA[B]: $2,155,916; 
OSM: $198,099; 
Total: $2,613,186. 

Percent of total; 
BLM[A]: 2 percent; 
Forest Service: 8 percent; 
EPA[B]: 83 percent; 
OSM: 8 percent; 
Total: [Empty]. 

Median; 
BLM[A]: $5,141; 
Forest Service: $21,476; 
EPA[B]: $221,029; 
OSM: $17,626; 
Total: $260,711. 

Sources: BLM, the Forest Service, EPA, OSM. 

Notes: Program inception totals are $50,462 since 1998 for BLM; 
$231,538 since fiscal year 1996 for Forest Service; $3,261,197 since 
1988 for EPA; and $406,236 since 1977 for OSM. 

[A] These data include funding for large cleanup projects from the Soil 
Water and Air and the Hazard Management and Resource Restoration 
subactivities from BLM appropriations. These data do not include 
funding for smaller projects under those two subactivities, funding 
from Central Hazardous Materials Fund or the Natural Resource Damage 
Assessment and Restoration subactivities from the Department of the 
Interior's appropriations, or funding under the Southern Nevada Public 
Land Management Act. 

[B] According to EPA officials, about 90 percent of these expenditures 
are EPA's; the other 10 percent are funds from responsible parties and 
states. 

[End of table] 

Table 6: BLM, EPA, and OSM Expenditures to Cleanup Abandoned Hardrock 
Mines, by State, Fiscal Years 1988 to 2007; Dollars in thousands (2008 
constant dollars): 

State: Montana; 
BLM[A]: $18,158; 
EPA[B]: $325,693; 
OSM: $27,499; 
Total: $371,350;
Rank: 1; 
Percent of total: 15.44. 

State: Idaho; 
BLM[A]: 6,310; 
EPA[B]: 351,848; 
OSM: [Empty]; 
Total: $358,158; 
Rank: 2; 
Percent of total: 14.90. 

State: Colorado; 
BLM[A]: 6,762; 
EPA[B]: 277,622; 
OSM: 19,362; 
Total: $303,746; 
Rank: 3; 
Percent of total: 12.63. 

State: New Jersey; 
BLM[A]: [Empty]; 
EPA[B]: 271,473; 
OSM: [Empty]; 
Total: $271,473; 
Rank: 4; 
Percent of total: 11.29. 

State: Utah; 
BLM[A]: 4,970; 
EPA[B]: 132,135; 
OSM: 5,029; 
Total: $142,133; 
Rank: 5; 
Percent of total: 5.91. 

State: California; 
BLM[A]: 3,748; 
EPA[B]: 126,384; 
OSM: [Empty]; 
Total: $130,131; 
Rank: 6; 
Percent of total: 5.41. 

State: Oklahoma; 
BLM[A]: [Empty]; 
EPA[B]: 119,017; 
OSM: [Empty]; 
Total: $119,017; 
Rank: 7; 
Percent of total: 4.95. 

State: Missouri; 
BLM[A]: [Empty]; 
EPA[B]: 101,648; 
OSM: 489; 
Total: $102,138; 
Rank: 8; 
Percent of total: 4.25. 

State: Wyoming; 
BLM[A]: 1,054; 
EPA[B]: [Empty]; 
OSM: 99,893; 
Total: $100,947; 
Rank: 9; 
Percent of total: 4.20. 

State: Nebraska; 
BLM[A]: [Empty]; 
EPA[B]: 74,331; 
OSM: [Empty]; 
Total: $74,331; 
Rank: 10; 
Percent of total: 3.09. 

State: South Dakota; 
BLM[A]: [Empty]; 
EPA[B]: 64,246; 
OSM: [Empty]; 
Total: $64,246; 
Rank: 11; 
Percent of total: 2.67. 

State: New York; 
BLM[A]: [Empty]; 
EPA[B]: 52,567; 
OSM: [Empty]; 
Total: $52,567; 
Rank: 12; 
Percent of total: 2.19. 

State: Texas; 
BLM[A]: [Empty]; 
EPA[B]: 30,518; 
OSM: 18,342; 
Total: $48,860; 
Rank: 13; 
Percent of total: 2.03. 

State: Pennsylvania; 
BLM[A]: [Empty]; 
EPA[B]: 41,079; 
OSM: [Empty]; 
Total: $41,079; 
Rank: 14; 
Percent of total: 1.71. 

State: Washington; 
BLM[A]: [Empty]; 
EPA[B]: 32,223; 
OSM: [Empty]; 
Total: $32,223; 
Rank: 15; 
Percent of total: 1.34. 

State: Vermont; 
BLM[A]: [Empty]; 
EPA[B]: 27,473; 
OSM: [Empty]; 
Total: $27,473; 
Rank: 16; 
Percent of total: 1.14. 

State: South Carolina; 
BLM[A]: [Empty]; 
EPA[B]: 22,913; 
OSM: [Empty]; 
Total: $22,913; 
Rank: 17; 
Percent of total: 0.95. 

State: Indian Tribes; 
BLM[A]: [Empty]; 
EPA[B]: [Empty]; 
OSM: 22,226; 
Total: $22,226; 
Rank: 18; 
Percent of total: 0.92. 

State: Kansas; 
BLM[A]: [Empty]; 
EPA[B]: 19,704; 
OSM: 536; 
Total: $20,240; 
Rank: 19; 
Percent of total: 0.84. 

State: New Mexico; 
BLM[A]: [Empty]; 
EPA[B]: 15,845; 
OSM: 3,349; 
Total: $19,194; 
Rank: 20; 
Percent of total: 0.80. 

State: Nevada; 
BLM[A]: 2,289; 
EPA[B]: 13,229; 
OSM: [Empty]; 
Total: $15,517; 
Rank: 21; 
Percent of total: 0.65. 

State: Tennessee; 
BLM[A]: [Empty]; 
EPA[B]: 15,493; 
OSM: [Empty]; 
Total: $15,493; 
Rank: 22; 
Percent of total: 0.64. 

State: Michigan; 
BLM[A]: [Empty]; 
EPA[B]: 14,995; 
OSM: [Empty]; 
Total: $14,995; 
Rank: 23; 
Percent of total: 0.62. 

State: Minnesota; 
BLM[A]: [Empty]; 
EPA[B]: 8,804; 
OSM: [Empty]; 
Total: $8,804; 
Rank: 24; 
Percent of total: 0.37. 

State: Illinois; 
BLM[A]: [Empty]; 
EPA[B]: 7,201; 
OSM: 724; 
Total: $7,925; 
Rank: 25; 
Percent of total: 0.33. 

State: Oregon; 
BLM[A]: 4,205; 
EPA[B]: 2,611; 
OSM: [Empty]; 
Total: $6,816; 
Rank: 26; 
Percent of total: 0.28. 

State: Alaska; 
BLM[A]: 2,786; 
EPA[B]: [Empty]; 
OSM: 602; 
Total: $3,388; 
Rank: 27; 
Percent of total: 0.14. 

State: Maine; 
BLM[A]: [Empty]; 
EPA[B]: 1,761; 
OSM: [Empty]; 
Total: $1,761; 
Rank: 28; 
Percent of total: 0.07. 

State: Florida; 
BLM[A]: [Empty]; 
EPA[B]: 1,611; 
OSM: [Empty]; 
Total: $1,611; 
Rank: 29; 
Percent of total: 0.07. 

State: North Carolina; 
BLM[A]: [Empty]; 
EPA[B]: 1,523; 
OSM: [Empty]; 
Total: $1,523; 
Rank: 30; 
Percent of total: 0.06. 

State: Arizona; 
BLM[A]: 180; 
EPA[B]: 748; 
OSM: [Empty]; 
Total: $927; 
Rank: 31; 
Percent of total: 0.04. 

State: Kentucky; 
BLM[A]: [Empty]; 
EPA[B]: 452; 
OSM: [Empty]; 
Total: $452; 
Rank: 32; 
Percent of total: 0.02. 

State: Ohio; 
BLM[A]: [Empty]; 
EPA[B]: 248; 
OSM: 49; 
Total: $297; 
Rank: 33; 
Percent of total: 0.01. 

State: Indiana; 
BLM[A]: [Empty]; 
EPA[B]: 230; 
OSM: [Empty]; 
Total: $230; 
Rank: 34; 
Percent of total: 0.01. 

State: Virginia; 
BLM[A]: [Empty]; 
EPA[B]: 154; 
OSM: [Empty]; 
Total: $154; 
Rank: 35; 
Percent of total: 0.01. 

State: West Virginia; 
BLM[A]: [Empty]; 
EPA[B]: 139; 
OSM: [Empty]; 
Total: $139; 
Rank: 36; 
Percent of total: 0.01. 

State: Total: 
BLM[A]: $50,462; 
EPA[B]: $2,155,916; 
OSM: $198,099; 
Total: $2,404,477; 
Rank: [Empty]; 
Percent of total: 100.00. 

Sources: BLM, EPA, OSM. 

Note: The Forest Service was unable to provide this information by 
state. 

[A] These data include funding for large cleanup projects from the Soil 
Water and Air and the Hazard Management and Resource Restoration 
subactivities from BLM appropriations. These data do not include 
funding for smaller projects under those two subactivities, funding 
from Central Hazardous Materials Fund or the Natural Resource Damage 
Assessment and Restoration subactivities from the Department of the 
Interior's appropriations, or funding under the Southern Nevada Public 
Land Management Act. 

[B] According to EPA officials, about 90 percent of these expenditures 
are EPA's; the other 10 percent are funds from responsible parties and 
states. 

[End of table] 

[End of section] 

Appendix III: Estimated Number of Abandoned Mine Sites, According to 
Selected Studies, 1998 to 2007: 

State: Alaska; 
Western Governors' Association/National Mining Association (1998)[A]: 
432; 
Interstate Mining Compact Commission (2001)[B]: No data provided; 
Interstate Mining Compact Commission (2007)[C]: 350; 
Mineral Policy Center (2003)[D]: 432; 
Earthworks (formerly Mineral Policy Center) (2007)[E]: No data 
provided; 
EPA (2004)[F]: 432; 
Range of estimated abandoned mines previously reported: 350-432. 

State: Arizona; 
Western Governors' Association/National Mining Association (1998)[A]: 
100,000; 
Interstate Mining Compact Commission (2001)[B]: 100,000; 
Interstate Mining Compact Commission (2007)[C]: 80,000; 
Mineral Policy Center (2003)[D]: 100,000 "openings"; 
Earthworks (formerly Mineral Policy Center) (2007)[E]: 100,000; 
EPA (2004)[F]: 8,000-10,000; 
Range of estimated abandoned mines previously reported: 8,000-100,000. 

State: California; 
Western Governors' Association/National Mining Association (1998)[A]: 
20,000; 
Interstate Mining Compact Commission (2001)[B]: 15,000; 
Interstate Mining Compact Commission (2007)[C]: 47,000; 
Mineral Policy Center (2003)[D]: 39,000; 
Earthworks (formerly Mineral Policy Center) (2007)[E]: 39,000; 
EPA (2004)[F]: 40,000-47,000; 
Range of estimated abandoned mines previously reported: 15,000-47,000. 

State: Colorado; 
Western Governors' Association/National Mining Association (1998)[A]: 
22,000; 
Interstate Mining Compact Commission (2001)[B]: 18,000 mine openings; 
Interstate Mining Compact Commission (2007)[C]: No data provided; 
Mineral Policy Center (2003)[D]: 23,000 including coal; 
Earthworks (formerly Mineral Policy Center) (2007)[E]: 23,000 including 
coal; 
EPA (2004)[F]: 8,000-23,000; 
Range of estimated abandoned mines previously reported: 8,000-23,000. 

State: Idaho; 
Western Governors' Association/National Mining Association (1998)[A]: 
9,000; 
Interstate Mining Compact Commission (2001)[B]: No data provided; 
Interstate Mining Compact Commission (2007)[C]: No data provided; 
Mineral Policy Center (2003)[D]: 8,000-9,000; 
Earthworks (formerly Mineral Policy Center) (2007)[E]: 8,000-9,000; 
EPA (2004)[F]: 8,000-16,000; 
Range of estimated abandoned mines previously reported: 8,000-16,000. 

State: Montana; 
Western Governors' Association/National Mining Association (1998)[A]: 
6,000; 
Interstate Mining Compact Commission (2001)[B]: No data provided; 
Interstate Mining Compact Commission (2007)[C]: 2,740; 
Mineral Policy Center (2003)[D]: 6,000; 
Earthworks (formerly Mineral Policy Center) (2007)[E]: 6,000; 
EPA (2004)[F]: 6,000-19,000; 
Range of estimated abandoned mines previously reported: 2,740-19,000. 

State: Nevada; 
Western Governors' Association/National Mining Association (1998)[A]: 
50,000; 
Interstate Mining Compact Commission (2001)[B]: 50,000 could pose a 
physical threat to people; 
Interstate Mining Compact Commission (2007)[C]: 100 mine sites, 200,000 
mine openings; 
Mineral Policy Center (2003)[D]: 200,000-500,000 mine features; 
Earthworks (formerly Mineral Policy Center) (2007)[E]: No data 
provided; 
EPA (2004)[F]: 200,000-500,000; 
Range of estimated abandoned mines previously reported: 100-500,000. 

State: New Mexico; 
Western Governors' Association/National Mining Association (1998)[A]: 
20,000; 
Interstate Mining Compact Commission (2001)[B]: 25,000 mine openings; 
Interstate Mining Compact Commission (2007)[C]: No data provided; 
Mineral Policy Center (2003)[D]: 10,000-20,000; 
Earthworks (formerly Mineral Policy Center) (2007)[E]: 10,000-20,000; 
EPA (2004)[F]: 10,000-20,000; 
Range of estimated abandoned mines previously reported: 10,000-25,000. 

State: Oregon; 
Western Governors' Association/National Mining Association (1998)[A]: 
No data provided; 
Interstate Mining Compact Commission (2001)[B]: No data provided; 
Interstate Mining Compact Commission (2007)[C]: No data provided; 
Mineral Policy Center (2003)[D]: 126 plus ongoing inventory in specific 
watersheds; 
Earthworks (formerly Mineral Policy Center) (2007)[E]: 126 on the 
ground inventory; 
EPA (2004)[F]: 94-120; 
Range of estimated abandoned mines previously reported: 94-126. 

State: South Dakota; 
Western Governors' Association/National Mining Association (1998)[A]: 
900 in Black Hills; 
Interstate Mining Compact Commission (2001)[B]: No data provided; 
Interstate Mining Compact Commission (2007)[C]: 900 in Black Hills; 
Mineral Policy Center (2003)[D]: 900 in Black Hills area; 
Earthworks (formerly Mineral Policy Center) (2007)[E]: 900; 
EPA (2004)[F]: 900; 
Range of estimated abandoned mines previously reported: 900. 

State: Utah; 
Western Governors' Association/National Mining Association (1998)[A]: 
20,000; 
Interstate Mining Compact Commission (2001)[B]: No data provided; 
Interstate Mining Compact Commission (2007)[C]: 17,000-20,000; 
Mineral Policy Center (2003)[D]: 20,000 mine openings, including coal; 
Earthworks (formerly Mineral Policy Center) (2007)[E]: 20,000; 
EPA (2004)[F]: 20,000 mine openings; 
Range of estimated abandoned mines previously reported: 17,000-20,000. 

State: Washington; 
Western Governors' Association/National Mining Association (1998)[A]: 
No data provided; 
Interstate Mining Compact Commission (2001)[B]: 800 mine sites that 
that produced minerals worth more than $2,000; 
Interstate Mining Compact Commission (2007)[C]: 3,800; 
Mineral Policy Center (2003)[D]: 3,800; 
Earthworks (formerly Mineral Policy Center) (2007)[E]: 3,800; 
EPA (2004)[F]: 3,800; 
Range of estimated abandoned mines previously reported: 800-3,800. 

State: Wyoming; 
Western Governors' Association/National Mining Association (1998)[A]: 
2,649; 
Interstate Mining Compact Commission (2001)[B]: No data provided; 
Interstate Mining Compact Commission (2007)[C]: 1,696; 
Mineral Policy Center (2003)[D]: 640; 
Earthworks (formerly Mineral Policy Center) (2007)[E]: No data 
provided; 
EPA (2004)[F]: 3,371; 
Range of estimated abandoned mines previously reported: 640-3,371. 

Source: GAO's analysis of nationwide estimates. 

Note: Although studies asked for the number of sites, states did not 
always report the number of hardrock mine sites; instead some states 
reported other data, such as the number of mine openings, number of 
sites including coal, and number of mine features. 

[A] Western Governors' Association and National Mining Association, 
Cleaning Up Abandoned Mines: A Western Partnership, 1998. 

[B] Interstate Mining Compact Commission, State NonCoal AML Inventory, 
2001. 

[C] Preliminary data were collected in 2007, and will be presented in 
Interstate Mining Compact Commission, NonCoal Minerals Survey and 
Report (expected issuance Spring 2008). 

[D] Mineral Policy Center, Cleaning Up Western Watersheds, 2003. 

[E] Earthworks fact sheets on hardrock mining from Earthworks Web site 
last visited on March 4, 2008 [hyperlink 
http://www.earthworksaction.org/resources.cfm]. 

[F] EPA, Reference Notebook, September 2004. EPA has been working to 
update this information and expects to issue a new report in Summer 
2008. 

[End of table] 

[End of section] 

Appendix IV: Information on BLM Financial Assurances and Their Adequacy 
to Cover Estimated Reclamation Costs: 

This appendix provides information from BLM's November 2007 Bond Review 
Report, which includes information on the number of financial 
assurances in place for hardrock operations on BLM lands in 11 western 
states (table 7); the value of these financial assurances by state 
(table 8); the number of inadequate financial assurances for notice-and 
plan-level operations, by state (table 9); and BLM's and our analyses 
of the differences between financial assurance requirements and actual 
value of financial assurances in place for notice-and plan-level 
operations by state (table 10). 

Table 7: Number of Financial Assurances in Place for Hardrock 
Operations on BLM Land in 11 Western States: 

State: Arizona; 
Total number of notices: 72; 
Total number of plans of operation: 35; 
Total number of notices and plans of operation: 107. 

State: California; 
Total number of notices: 46; 
Total number of plans of operation: 49; 
Total number of notices and plans of operation: 95. 

State: Colorado; 
Total number of notices: 228; 
Total number of plans of operation: 22; 
Total number of notices and plans of operation: 250. 

State: Idaho; 
Total number of notices: 19; 
Total number of plans of operation: 27; 
Total number of notices and plans of operation: 46. 

State: Montana; 
Total number of notices: 27; 
Total number of plans of operation: 14; 
Total number of notices and plans of operation: 41. 

State: New Mexico; 
Total number of notices: 20; 
Total number of plans of operation: 8; 
Total number of notices and plans of operation: 28. 

State: Nevada; 
Total number of notices: 409; 
Total number of plans of operation: 170; 
Total number of notices and plans of operation: 579. 

State: Oregon; 
Total number of notices: 57; 
Total number of plans of operation: 3; 
Total number of notices and plans of operation: 60. 

State: Utah; 
Total number of notices: 103; 
Total number of plans of operation: 47; 
Total number of notices and plans of operation: 150. 

State: Washington; 
Total number of notices: 3; 
Total number of plans of operation: 1; 
Total number of notices and plans of operation: 4. 

State: Wyoming; 
Total number of notices: 49; 
Total number of plans of operation: 54; 
Total number of notices and plans of operation: 103. 

State: Total; 
Total number of notices: 1,033; 
Total number of plans of operation: 430; 
Total number of notices and plans of operation: 1,463. 

Source: BLM's Bond Review Report, November 2007. 

Note: Data for Alaska are not maintained in LR2000 and are not reported 
in BLM's Bond Review Report. 

[End of table] 

Table 8: Value of Financial Assurances Guaranteeing Reclamation of 
Hardrock Operations on BLM Land, by State: 

State: Arizona; 
Value of assurances required for notices: $538,847.00; 
Value of assurances in place for notices: $554,578.20; 
Value of assurances required for plans of operation: $7,150,547.46; 
Value of assurances in place for plans of operation: $7,085,233.46. 

State: California; 
Value of assurances required for notices: $177,749.00; 
Value of assurances in place for notices: $212,849.00; 
Value of assurances required for plans of operation: $24,352,689.65; 
Value of assurances in place for plans of operation: $25,910,602.86. 

State: Colorado; 
Value of assurances required for notices: $235,859.39; 
Value of assurances in place for notices: $225,673.39; 
Value of assurances required for plans of operation: $1,369,715.00; 
Value of assurances in place for plans of operation: $1,209,610.00. 

State: Idaho; 
Value of assurances required for notices: $44,871.00; 
Value of assurances in place for notices: $44,871.00; 
Value of assurances required for plans of operation: $1,511,834.19; 
Value of assurances in place for plans of operation: $1,498,834.19. 

State: Montana; 
Value of assurances required for notices: $966,268.96; 
Value of assurances in place for notices: $966,268.96; 
Value of assurances required for plans of operation: $66,511,795.32; 
Value of assurances in place for plans of operation: $66,512,995.32. 

State: New Mexico; 
Value of assurances required for notices: $87,940.54; 
Value of assurances in place for notices: $87,940.54; 
Value of assurances required for plans of operation: $978,794.00; 
Value of assurances in place for plans of operation: $978,794.00. 

State: Nevada; 
Value of assurances required for notices: $4,764,983.00; 
Value of assurances in place for notices: $4,779,329.00; 
Value of assurances required for plans of operation: $840,188,178.00; 
Value of assurances in place for plans of operation: $806,506,148.00. 

State: Oregon; 
Value of assurances required for notices: $168,777.00; 
Value of assurances in place for notices: $166,104.00; 
Value of assurances required for plans of operation: $197,995.85; 
Value of assurances in place for plans of operation: $247,995.85. 

State: Utah; 
Value of assurances required for notices: $1,411,244.00; 
Value of assurances in place for notices: $1,497,253.00; 
Value of assurances required for plans of operation: $10,836,401.00; 
Value of assurances in place for plans of operation: $8,067,853.00. 

State: Washington; 
Value of assurances required for notices: $750.00; 
Value of assurances in place for notices: $750.00; 
Value of assurances required for plans of operation: $49,224.85; 
Value of assurances in place for plans of operation: $49,224.85. 

State: Wyoming; 
Value of assurances required for notices: $935,922.00; 
Value of assurances in place for notices: $957,122.00; 
Value of assurances required for plans of operation: $46,998,188.00; 
Value of assurances in place for plans of operation: $54,080,384.00. 

State: Total; 
Value of assurances required for notices: $9,333,211.89; 
Value of assurances in place for notices: $9,492,739.09; 
Value of assurances required for plans of operation: $1,000,145,363.32; 
Value of assurances in place for plans of operation: $972,147,675.53. 

Source: BLM's Bond Review Report, November 2007. 

Note: Data for Alaska are not maintained in LR2000 and are not reported 
in BLM's Bond Review Report. 

[End of table] 

Table 9: Number of BLM's Notice-and Plan-Level Operations with 
Inadequate Financial Assurances on BLM Land, by State: 

State: Arizona; 
Number of notices with inadequate financial assurances: 1; 
Number of plans with inadequate financial assurances: 1; 
Total number of notices and plans with inadequate financial assurances: 
2. 

State: California; 
Number of notices with inadequate financial assurances: 1; 
Number of plans with inadequate financial assurances: 3; 
Total number of notices and plans with inadequate financial assurances: 
4. 

State: Colorado; 
Number of notices with inadequate financial assurances: 2; 
Number of plans with inadequate financial assurances: 2; 
Total number of notices and plans with inadequate financial assurances: 
4. 

State: Idaho; 
Number of notices with inadequate financial assurances: 0; 
Number of plans with inadequate financial assurances: 1; 
Total number of notices and plans with inadequate financial assurances: 
1. 

State: Montana; 
Number of notices with inadequate financial assurances: 0; 
Number of plans with inadequate financial assurances: 0; 
Total number of notices and plans with inadequate financial assurances: 
0. 

State: New Mexico; 
Number of notices with inadequate financial assurances: 0; 
Number of plans with inadequate financial assurances: 0; 
Total number of notices and plans with inadequate financial assurances: 
0. 

State: Nevada; 
Number of notices with inadequate financial assurances: 14; 
Number of plans with inadequate financial assurances: 14; 
Total number of notices and plans with inadequate financial assurances: 
28. 

State: Oregon; 
Number of notices with inadequate financial assurances: 4; 
Number of plans with inadequate financial assurances: 0; 
Total number of notices and plans with inadequate financial assurances: 
4. 

State: Utah; 
Number of notices with inadequate financial assurances: 1; 
Number of plans with inadequate financial assurances: 4; 
Total number of notices and plans with inadequate financial assurances: 
5. 

State: Washington; 
Number of notices with inadequate financial assurances: 0; 
Number of plans with inadequate financial assurances: 0; 
Total number of notices and plans with inadequate financial assurances: 
0. 

State: Wyoming; 
Number of notices with inadequate financial assurances: 0; 
Number of plans with inadequate financial assurances: 4; 
Total number of notices and plans with inadequate financial assurances: 
4. 

State: Total; 
Number of notices with inadequate financial assurances: 23; 
Number of plans with inadequate financial assurances: 29; 
Total number of notices and plans with inadequate financial assurances: 
52. 

Source: BLM's Bond Review Report, November 2007. 

Note: Data for Alaska are not maintained in LR2000 and is not reported 
in BLM's Bond Review Report. 

[End of table] 

Table 10: BLM and GAO Difference Between Financial Assurance 
Requirements and Actual Value in Place for Notice and Plan Operations, 
by State, as of November 2007: 

State: Arizona; 
BLM's difference for notice operations: $15,731.20; 
GAO analysis of difference for notice operations: ($1,629.80); 
BLM's difference for plan operations: ($65,314.00); 
GAO analysis of difference for plan operations: ($100,240.00). 

State: California; 
BLM's difference for notice operations: 35,100.00; 
GAO analysis of difference for notice operations: (200.00); 
BLM's difference for plan operations: 1,557,913.21; 
GAO analysis of difference for plan operations: (439,468.88). 

State: Colorado; 
BLM's difference for notice operations: (10,186.00); 
GAO analysis of difference for notice operations: (7,518.00); 
BLM's difference for plan operations: (160,105.00); 
GAO analysis of difference for plan operations: ($160,212.00). 

State: Idaho; 
BLM's difference for notice operations: 0.00; 
GAO analysis of difference for notice operations: 0.00; 
BLM's difference for plan operations: ($13,000.00); 
GAO analysis of difference for plan operations: ($13,000.00). 

State: Montana; 
BLM's difference for notice operations: 0.00; 
GAO analysis of difference for notice operations: 0.00; 
BLM's difference for plan operations: $1,200.00; 
GAO analysis of difference for plan operations: 0.00. 

State: New Mexico; 
BLM's difference for notice operations: 0.00; 
GAO analysis of difference for notice operations: 0.00; 
BLM's difference for plan operations: 0.00; 
GAO analysis of difference for plan operations: 0.00. 

State: Nevada; 
BLM's difference for notice operations: $14,346.00; 
GAO analysis of difference for notice operations: ($109,092.00); 
BLM's difference for plan operations: ($33,682,030.00); 
GAO analysis of difference for plan operations: ($47,630,722.00). 

State: Oregon; 
BLM's difference for notice operations: ($2,673.00); 
GAO analysis of difference for notice operations: ($1,227.00); 
BLM's difference for plan operations: 50,000.00; 
GAO analysis of difference for plan operations: 0.00. 

State: Utah; 
BLM's difference for notice operations: $86,009.00; 
GAO analysis of difference for notice operations: ($1,254.00); 
BLM's difference for plan operations: ($2,768,548.00); 
GAO analysis of difference for plan operations: ($2,768,548.00). 

State: Washington; 
BLM's difference for notice operations: 0.00; 
GAO analysis of difference for notice operations: 0.00; 
BLM's difference for plan operations: 0.00; 
GAO analysis of difference for plan operations: 0.00. 

State: Wyoming; 
BLM's difference for notice operations: $21,200.00; 
GAO analysis of difference for notice operations: 0.00; 
BLM's difference for plan operations: $7,082,196.00; 
GAO analysis of difference for plan operations: ($9,518,877.00). 

State: Total; 
BLM's difference for notice operations: $159,527.20; 
GAO analysis of difference for notice operations: ($120,920.80); 
BLM's difference for plan operations: ($27,997,687.79); 
GAO analysis of difference for plan operations: ($60,631,067.88). 

Source: BLM's Bond Review Report, November 2007. 

Note: Data for Alaska are not maintained in LR2000 and is not reported 
in BLM's Bond Review Report. 

[End of table] 

[End of section] 

Footnotes: 

[1] 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. 

[2] Pub. L. No. 95-87, as amended by Pub L. No. 101-5-8, Title VI, § 
6010(2), Nov. 5, 1990. 

[3] An operator is a person who conducts operations in connection with 
exploration, mining, and processing hardrock minerals on federal lands. 

[4] 43 C.F.R. §3809. 

[5] BLM manages about 258 million acres, most of which are located in 
12 western states, and Alaska. For simplicity in this testimony, we 
refer to BLM-managed land as BLM land. 

[6] GAO, Hardrock Mining: BLM Needs to Better Manage Financial 
Assurances to Guarantee Coverage of Reclamation Costs, GAO-05-377 
(Washington, D.C.: June 20, 2005). 

[7] These states were Arizona, California, Colorado, Idaho, Montana, 
Nevada, New Mexico, Oregon, South Dakota, Utah, Washington, and 
Wyoming. 

[8] These states were Arizona, California, Colorado, Idaho, Montana, 
New Mexico, Nevada, Oregon, Utah, Washington, and Wyoming. 

[9] GAO, Environmental Liabilities: Hardrock Mining Cleanup 
Obligations, GAO-06-884T (Washington, D.C.: June 14, 2006); GAO-05-377. 

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

[11] 43 C.F.R. 3809 and 36 C.F.R. §228, Subpart A. 

[12] 42 USC §§ 9601-9675. 

[13] EPA, Office of Inspector General, Nationwide Identification of 
Hardrock Mining Sites, 2004-P-00005 (Washington, D.C: Mar. 31, 2004). 

[14] GAO-06-884T. 

[15] U.S. Department of the Interior, Office of Surface Mining 
Reclamation and Enforcement, 2006 Report to the President and Congress 
(Washington, D.C.: Oct. 1, 2006). 

[16] Unless otherwise stated all dollars in this section are in 2008 
constant dollars. 

[17] The six studies are (1) Western Governors' Association and 
National Mining Association, Cleaning up Abandoned Mines: A Western 
Partnership, 1998; (2) Interstate Mining Compact Commission, State 
NonCoal AML Inventory, 2001; (3) Interstate Mining Compact Commission; 
NonCoal Minerals Survey and Report (expected issuance Spring 2008); (4) 
Mineral Policy Center, Cleaning Up Western Watersheds, 2003; (5) 
Earthworks fact sheets on hardrock mining from Earthworks Web site last 
visited on March 4, 2008 [hyperlink, 
http://www.earthworksaction.org/resources.cfm]; and (6) EPA, Reference 
Notebook, September 2004. 

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

[19] The MAS/MILS database was established to provide comprehensive 
information for known mining operations, mineral deposits/occurrences, 
and processing plants. The original data were collected on a state-by- 
state basis from the mid-1970s to 1982. The nonconfidential portions of 
the MAS/MILS database were compiled by the U.S. Department of the 
Interior, Bureau of Mines, but the accuracy of the database varies by 
location and mineral. 

[20] These studies were: (1) Western Governors' Association and 
National Mining Association, Cleaning up Abandoned Mines: A Western 
Partnership, 1998; (2) Interstate Mining Compact Commission, State 
NonCoal AML Inventory, 2001; (3) Interstate Mining Compact Commission; 
Noncoal Minerals Survey and Report, 2007; (4) Mineral Policy Center, 
Cleaning Up Western Watersheds, 2003; (5) Earthworks fact sheets on 
hardrock mining from Earthworks Web site last visited on March 4, 2008 
[hyperlink, http://www.earthworksaction.org/resources.cfm]; and (6) 
EPA, Reference Notebook, September 2004. 

[21] These states were Alaska, Arizona, California, Colorado, Idaho, 
Montana, Nevada, New Mexico, Oregon, South Dakota, Utah, Washington, 
and Wyoming. 

[22] GAO-05-377. 

[End of section] 

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