BAMR has reclaimed approximately 1,905 acres of forfeited surface mining permit sites at a cost of $13,592,193. The total of forfeited areas remaining to be reclaimed is currently 2,060 acres. BAMR has developed cost estimates based on engineering designs for the reclamation of 421 acres of the remaining total. The cost estimate for this category is $6,984,045. The Bureau of Mining and Reclamation has estimated that it will cost an additional $14,195,902 to reclaim the remaining 1,639 acres needing reclamation. This estimate is based on average costs of $5,500 per reclamation acre for surface coal mine sites and $11,000 per reclamation acre for coal refuse reprocessing sites. Coal preparation plant estimates are developed from site-specific evaluations. The costs for structure removal are based on original bond calculations for structure removal and approximately $13,000 per acre for land reclamation. The results are summarized in Table 12.

The estimated total cost of all forfeited primacy surface mine reclamation completed and to be completed by the alternative bonding system is $34,772,140.

Revenue from several sources is available to cover these costs. Since 1982, $13,394,675 in revenue has been collected from forfeited bonds on primacy surface mining sites. Excess funds from a site-specific bond remaining after reclamation has been completed are available to supplement obligations on other sites. This analysis assumes that such transfers will be made. However, because of reported acid mine drainage (AMD) discharges, a total of $879,538 in such site-specific bonds is restricted even though the land reclamation on these sites has been completed. The reclamation fee on primacy operations generated total supplementary income of $13,806,464. Further, the department has committed $700,000 of the interest income earned in the bonding program account for work on these forfeited primacy surface mine sites during the current fiscal year. Finally, the total of uncollected forfeited bonds is $4,614,518. After making an allowance for a portion of bonds that the department historically has not been able to collect, it is assumed that $3,909,763 will be ultimately collected.

The calculated current deficit of approximately $3.9 million represents the difference between the cost of reclaiming forfeited sites and the designated assets from the alternative bonding program fund that have been applied to reclaim the forfeited sites. However, the deficit does not fully reflect the historical ability of the fund to maintain balance between primacy forfeiture reclamation costs and the income to deal with them. Other resources available to the fund have, by historical department policy, been applied to higher-priority, non-primacy land reclamation. The result of applying these additional resources to the reclamation of primacy forfeiture sites would be a significantly reduced deficit. (Details of the resources available to the fund are presented in the section titled Repositories for Bond Program Funds on page *).

BAMR has reclaimed approximately 1,686 acres of forfeited primacy surface coal permit sites at a cost of $10,509,368. There are currently 1,332 surface coal acres that need to be reclaimed. BAMR engineering estimates project a cost of $845,100 to reclaim 79 acres of this obligation. The Bureau of Mining and Reclamation has estimated that an additional $6,888,750 is needed to reclaim the remaining 1,253 surface coal acres. This estimate is based on an average reclamation cost of $5,500 per acre, as determined from analysis of the 81 forfeited primacy surface coal sites that BAMR has reclaimed since 1988. The $5,500 amount represents the typical average cost adjusted for inflation.

The estimated total cost of all forfeited primacy surface coal reclamation completed and to be completed by the alternative bonding system is $18,243,218. Since 1986, the department has collected $11,490,556 in bonds from forfeited surface coal permits. Of this total, $879,538 is associated with 15 sites on which the land reclamation has been completed but for which BAMR records reflect a post-reclamation AMD discharge. (The current status of the reported AMD discharges on these sites is under evaluation). Since 1982, the department has also collected approximately $12,840,011 in reclamation fees from surface coal permits. Uncollected forfeited surface coal bonds are currently valued at $1,639,605. Historically, the department has been able to collect approximately 92% of all forfeited bonds from primacy surface coal forfeitures. (See the discussion on Collection of Forfeited Bonds and the summary of collection rates in Table 2 on page *). Assuming that 92% of all uncollected forfeited bonds are collected and applied, along with the collected bonds and available reclamation fees, the total land reclamation cost of all forfeited primacy surface coal permits has a current surplus of $6,716,248. The surplus does not consider the costs associated with preventing water pollution on these sites. Those costs are the subject of a separate evaluation.

BAMR has reclaimed approximately 169 acres of forfeited primacy coal refuse reprocessing sites at a cost of $1,846,971. There are currently 364 coal refuse reprocessing acres remaining to be reclaimed. BAMR engineering estimates project a cost of $4,595,800 to reclaim an additional 243 acres. The Bureau of Mining and Reclamation has estimated that it will cost an additional $1,329,350 to reclaim the remaining 121 coal refuse reprocessing acres. This estimate is based on an average reclamation cost of $11,000 per acre, determined from analysis of the nine forfeited primacy coal refuse reprocessing sites that BAMR has reclaimed since 1990. The $11,000 amount represents the average cost per acre adjusted for inflation over time.

The estimated total cost of all forfeited primacy coal refuse reprocessing site reclamation completed and to be completed by the alternative bonding system is approximately $7,772,121. Since 1987, the department has collected $806,944 in bonds from forfeited coal refuse reprocessing permits, and since 1982 has also collected approximately $966,453 in reclamation fees from coal refuse reprocessing permits. Uncollected forfeited coal refuse reprocessing bonds are currently valued at $125,855. Historically, the department has been able to collect approximately 97% of all forfeited bonds from primacy coal refuse reprocessing permit forfeitures (see Table 2 on page *). Assuming that 97% of all uncollected forfeited bonds are collected and applied, along with the collected bonds and available reclamation fees, the total reclamation cost of all forfeited primacy coal refuse reprocessing permits has a current deficit of $5,876,644.

BAMR has reclaimed approximately 50 acres of forfeited primacy coal preparation plant sites at a cost of $1,229,085. There are currently 364 coal preparation plant acres that need to be reclaimed. BAMR engineering estimates project a cost of $1,549,915 to reclaim an additional 99 acres. The Bureau of Mining and Reclamation has determined that it will cost an additional $5,977,802 to reclaim the remaining 265 coal preparation plant acres. This estimate is based on site specific evaluations of the original bond calculations for removal of coal facility structures and an average land reclamation cost of approximately $13,000 per acre.

The estimated total cost of reclamation at all forfeited coal preparation plant sites that has been completed by the alternative bonding system plus the reclamation remaining to be completed is approximately $8,756,802. Since 1990, the department has collected $1,097,175 in bonds from forfeited coal preparation plant permits. There are no reclamation fees collected from coal preparation plant permits.

Uncollected bonds associated with forfeited primacy coal preparation plants currently are valued at $2,849,059. These uncollected funds are associated with only four coal preparation plant permits. The historical rate of collection of forfeited bonds from coal preparation plant forfeitures is 37%. However, this historical collection rate is a reflection of several anomalies and is not considered representative. One anomaly is that the historical collections are associated with small dollar amount forfeitures, while the uncollected forfeitures represent much higher dollar amounts. Second, the uncollected forfeitures are still under normal processing and are ultimately expected to be resolved through collection or other surety obligation. A surety company will routinely challenge a forfeiture action and, as an alternative to paying the bond, is very likely to enter into a reclamation agreement if the amount of the bond exceeds its expected reclamation cost. All four coal preparation plant forfeitures have been appealed. The department expects that all four of these forfeitures will ultimately be resolved either by full collection of the bonds or surety reclamation of the sites. Thus, the final collection rate should be close to 100%. However, final resolution may not be reached for a year or several years. Consequently, for the purpose of this analysis, the department has assumed a conservative collection rate of 80% (see Table 2 on page *). Applying the anticipated proceeds along with the collected bonds, the total reclamation cost for all forfeited primacy coal preparation plant permits has a current deficit of $5,380,380.

A summary of the individual balances for each of the three surface coal mining activities in the alternative bonding system is presented in Table 20. As discussed at the beginning of this section, there is an estimated deficit of $3,840,776.

BAMR has not reclaimed any forfeited primacy coal refuse disposal sites. There are currently 194 coal refuse disposal acres that need to be reclaimed. BAMR engineering estimates project a cost of $3,506,770 to reclaim 113 acres. The Bureau of Mining and Reclamation has estimated that it will cost an additional $1,612,000 to reclaim the remaining 81 coal refuse disposal acres. This estimate is based on an average reclamation cost of $20,000 per acre, as recommended by BAMR as an average reclamation cost for refuse disposal sites not requiring special treatment or costly design considerations.

The estimated reclamation cost of all forfeited primacy coal refuse disposal sites to be reclaimed by the alternative bonding system is approximately $5,118,770. Since 1990, the department has collected $434,995 in forfeited bonds from coal refuse disposal permits. There are no reclamation fees collected from coal refuse disposal permits.

The total of uncollected forfeited coal refuse disposal bonds is currently $164,384. Historically, the department has collected approximately 91% of all forfeited bonds from primacy coal refuse disposal permit forfeitures. Assuming that 91% of all uncollected forfeited bonds are collected and applied, along with the collected bonds, the total cost to reclaim all forfeited primacy coal refuse disposal sites has a current deficit of $4,534,186.

The BAMR has reclaimed approximately 43 acres of forfeited primacy underground mining sites at a cost of $774,958. There are currently 95 acres that still need to be reclaimed. Based on engineering estimates, BAMR projects that it will cost $2,583,800 to reclaim these 95 acres. The total cost of all reclamation completed and to be completed is approximately $3,358,758.

The bonding rates for underground mines are based on the full cost to perform reclamation on a forfeited site. Consequently, there are no reclamation fees associated with underground mining permits. The department has collected $760,148 from forfeited bonds, and $134,010 in forfeited bonds remains to be collected. The department has been able to collect 100% of all previously forfeited primacy underground mining bonds. Assuming that all uncollected forfeited bonds are collected, the total cost to reclaim all forfeited primacy underground mining sites will have a current deficit of $2,464,600.