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Projections for Annual Primacy Forfeitures
Projected annual forfeitures of permits, estimates of the number of forfeited acres needing reclamation, the cost of reclamation and anticipated reclamation income to offset these costs have been determined for each of the activities covered by the bonding program. In order to develop realistic projections, an evaluation period of approximately four years was used (from December 1999 until the end of 2003). Results were then converted to annual values. Some projections are based on historical experience. Details that are relevant to the analyses in this section are presented in Table 28. This table includes a compilation of selected information presented in tables on pages 10, 13, 14, and 15. The methods used to develop projections vary by category of permit: details for each are discussed in the individual sections.
Table 28
Summary of Percentage of Forfeited Primacy Permit Acres Needing Reclamation
|
Activity |
Acres Forfeited |
Acres Requiring Reclamation |
% of Forfeited Acres Requiring Reclamation |
|
Surface Coal |
59,379 |
6,382 |
11 |
|
Coal Refuse Reprocessing |
2,837 |
625 |
22 |
|
Coal Preparation Plant |
981 |
609 |
62 |
|
Coal Refuse Disposal |
1,361 |
449 |
33 |
|
Bituminous Underground |
1,286 |
438 |
34 |
The assumptions and results related to activities covered by the alternative bonding system are summarized in Table 29.
Table 29
Summary of Annual Projected Forfeitures and Estimated Reclamation Costs and Possible Income
|
Surface Coal |
Coal Refuse Reprocessing |
Coal Preparation Plant |
Surface Mining Total |
|
|
Acres Projected to Forfeit |
4,384 |
479 |
102 |
4,965 |
|
Acres DEP Required to Reclaim |
237 |
90 |
41 |
368 |
|
Estimated Reclamation Cost per Acre |
$5,500 |
$11,000 |
$20,500 |
|
|
Estimated Reclamation Cost |
$1,295,741 |
$987,176 |
$846,801 |
$3,129,718 |
|
Bonds to be Collected |
$943,086 |
$152,339 |
$279,998 |
$1,375,423 |
|
Reclamation Fees to be Collected |
$465,000 |
$35,000 |
0 |
$500,000 |
|
Land Reclamation Cost (Deficit) or Surplus |
$112,345 |
($799,837) |
($566,803) |
($1,254,295) |
In the future, there will be completions and forfeitures of some of the permits that are now considered active. Likewise, there will be new permits issued during the same period. For the discussions that follow, the acreage changes due to rates of completion and forfeiture are considered equivalent to those due to new permitting. Rates of future and historical permit completion, as well as future rates of forfeiture, will be analyzed and updated annually to confirm or revise future projections and the necessary supplemental income needed to ensure complete reclamation of future forfeitures.
There are currently 702 primacy surface coal mining permits that are theoretical candidates for forfeiture in the future. This inventory includes permit sites that are actively mining, sites that have not started yet, and sites that are in a state of approved cessation. The total area associated with these permits is 168,926 acres.
Historically, approximately 10% of all primacy surface coal permit acres have been forfeited since 1982. (See Table 4 on page *). Applying this percentage to the 168,926 acres yields a potential 17,537 acres that possibly could be forfeited from now through the year 2003. On an annual basis, the potential forfeiture is 4,384 acres.
Since 1982, approximately 11% of forfeited primacy surface coal permit acres have required reclamation (see Table 28). Assuming a similar trend for the future, approximately 471 surface coal acres forfeited will require reclamation annually. Repermitting and reclamation undertaken by others have accounted for 50% of the land reclamation needed, leaving approximately 50% of forfeited primacy surface coal permit sites to be reclaimed with resources from the alternative bonding system. Consequently, the future need for reclamation is likely to be approximately 237 surface coal acres annually.
The historical record of average bond proceeds per acre needing reclamation for all surface coal permits has been approximately $4,351. Since primacy, the department has collected approximately 92% of forfeited bonds for all forfeited surface coal permits. Using these factors, the projected annual revenue from forfeited bonds for the 237 acres needing reclamation is $943,086. This amount would be applied toward the anticipated reclamation costs.
The department should expect also to collect $465,000 in reclamation fees annually, at a rate of $100 per newly permitted surface coal acre. Combined with the estimated bond amount that should eventually be collected from surface coal permits projected to be forfeited, an annual total of $1,408,086 would be available to apply toward anticipated future surface coal reclamation costs.
The estimated annual reclamation obligation is determined by applying the $5,500 average cost per acre needed to reclaim forfeited surface coal permit sites to the projected annual 237 acres that may need to be reclaimed with resources from the alternative bonding system. Thus, the projected total reclamation cost for new surface coal permit forfeitures will be approximately $1,295,741 annually.
With the anticipated reclamation fees and forfeited bonds to be collected for surface coal permit forfeitures, there will be an annual reclamation income surplus of $112,345. This estimate excludes costs associated with the prevention of water pollution.
Coal Refuse Reprocessing Permits
There are currently 142 primacy coal refuse reprocessing permits that have the potential for forfeiture in the future. This inventory includes permit sites that are active, have not started or are in a state of approved cessation. The total area associated with the potentially affected permitted coal refuse reprocessing acres is 24,613 acres.
Historically, approximately 8% of all primacy coal refuse reprocessing permit acres have been forfeited since 1982. Applying this percentage to the 24,613 acres yields a potential 1,917 acres that possibly could be forfeited. On an annual basis, the potential forfeiture is 479 acres.
Historically, about 22% of forfeited primacy coal refuse reprocessing permit acres have had to be reclaimed. (See Table 28). Assuming a similar trend for the future, approximately 106 acres of coal refuse reprocessing permits will require reclamation annually. The alternative bonding system has been obligated to reclaim approximately 85% of all forfeited primacy coal refuse reprocessing permit sites. Consequently, approximately 90 acres of coal refuse reprocessing acres could require reclamation annually.
The historical record of average bond proceeds per acre needing reclamation for all coal refuse reprocessing permits has been approximately $1,750. Since primacy, the department has collected approximately 92% of forfeited bonds for all forfeited coal refuse reprocessing permits. Using these factors, the projected annual revenue from forfeited bonds for the 90 acres needing reclamation is $152,339. This amount would be applied toward anticipated reclamation costs for coal refuse reprocessing forfeitures.
The department should expect also to collect $35,000 in reclamation fees annually, at a rate of $100 per newly permitted acre. Combined with the estimated bond amount that should eventually be collected from coal refuse reprocessing permits projected to be forfeited, a total of $187,339 annually would be available to apply toward anticipated future coal refuse reprocessing reclamation costs.
The estimated annual reclamation cost for coal refuse reprocessing forfeitures is determined by applying the $11,000 average cost per acre needed to reclaim forfeited sites to the projected annual 90 acres that may need to be reclaimed. Thus, the projected total annual reclamation cost for new coal refuse reprocessing permit forfeitures will be approximately $987,176.
With the anticipated reclamation fees and forfeited bonds to be collected for coal refuse reprocessing forfeitures, there will be an annual reclamation income deficit of $799,837. This estimate excludes costs associated with the prevention of water pollution.
Coal Preparation Plant Permits
There are currently 72 primacy coal preparation plant permits that have the potential for forfeiture in the future. This inventory includes permit sites that are active, have not yet started or are in a state of approved cessation. The total area associated with these potentially affected permitted coal preparation plant permits is 1,868 acres.
Historically, approximately 21.9% of all primacy coal preparation plant permit acres have been forfeited since 1982. Applying this percentage to the 1,868 acres yields a potential 410 acres that possibly could be forfeited. On an annual basis, the potential forfeiture is 102 acres.
Historically, about 62% of forfeited primacy coal preparation plant permit acres have had to be reclaimed (See Table 28). Assuming a similar trend for the future, approximately 64 acres of coal preparation plant acres will require reclamation annually. Approximately 65% of all forfeited primacy coal preparation plant permit sites have been left to be reclaimed with resources from the alternative bonding system. Consequently, approximately 41 coal preparation plant acres could be expected to need reclamation annually.
The historical record of average bond proceeds per acre for all coal preparation plant permits has been approximately $8,473. The department expects to collect all outstanding funds from the forfeiture of coal preparation plant permits in the future. However, for the reasons discussed in the previous section (see page *), this analysis is based on a more conservative collection rate of 80%. Using these factors, the projected annual revenue from forfeited bonds for the 41 acres needing reclamation annually is $279,998. This amount would be applied toward the anticipated obligation reclamation costs. The department does not collect reclamation fees from coal preparation plant permits.
The estimated annual reclamation obligation for coal preparation plant forfeitures is determined by applying an average total cost per acre of $20,500, determined from averaging anticipated costs to reclaim 10 currently forfeited sites, to the projected annual 41 acres that may need to be reclaimed. Thus, the projected total annual reclamation cost for new coal preparation plant permit forfeitures will be approximately $846,801.
With the anticipated forfeited bonds to be collected for coal preparation plant forfeitures, there will be an annual reclamation income deficit of $566,803. This estimate excludes costs associated with the prevention of water pollution.
Full-Cost Bonding System - Coal Refuse Disposal Permits
There are currently 52 primacy coal refuse disposal permits that have the potential for forfeiture in the future. This inventory includes permit sites that are active, have not started yet or are in a state of approved cessation. The total area associated with these potentially affected permitted coal refuse disposal permits is 8,000 acres.
Historically, approximately 10.5% of all primacy coal refuse disposal permit acres have been forfeited since 1982. Applying this percentage to the 8,000 acres yields a potential 840 acres that possibly could be forfeited. On an annual basis, the potential forfeiture is 210 acres.
Historically, about 33% of forfeited primacy coal refuse disposal permit acres have had to be reclaimed. (See Table 28). Assuming a similar trend for the future, approximately 69 acres of coal refuse disposal permits will require reclamation annually. In the past, other parties have reclaimed approximately 47% of forfeited primacy coal refuse disposal permit sites, leaving 53% to be reclaimed by the bonding program. Consequently, it is anticipated that approximately 36 coal refuse disposal acres would need to be reclaimed annually with resources from the bonding program.
The historical record of average bond proceeds per acre needing reclamation for all coal refuse disposal permits has been approximately $2,913. Since primacy, the department has collected approximately 91% of forfeited bonds for all forfeited coal refuse disposal permits. Using these factors, the projected annual revenue from forfeited bonds for the 36 acres needing reclamation annually is $96,682. This amount would be applied toward the department's anticipated reclamation costs. The department does not collect reclamation fees from coal refuse disposal permits.
The estimated annual reclamation cost for coal refuse disposal forfeitures is determined by applying the estimated $20,000 average cost per acre needed to reclaim forfeited sites to the projected annual 36 acres that may need to be reclaimed. Thus, the projected total annual reclamation cost for new coal refuse reprocessing permit forfeitures will be approximately $729,386.
With the anticipated forfeited bonds to be collected for coal refuse disposal forfeitures, there will be an annual reclamation income deficit of $632,704. This estimate excludes costs associated with the prevention of water pollution.
Full-Cost Bonding System - Underground Mining Permits
Because of the pronounced differences in the size of surface areas associated with anthracite and bituminous underground mines and the different reclamation costs involved, the projected costs for reclamation of these two types of underground mines are discussed separately. In order to develop realistic projections, an evaluation period of approximately four years was used (until the end of 2003). Results were then converted to annual values.
Anthracite Underground Mining Permits
There are currently 57 active anthracite underground permits. The historical forfeiture rate for anthracite underground permits is 6.3%. (This rate is based on the number of permits, not acreage). The bonding program has been left to reclaim 88% of all anthracite permit forfeitures. This means that in the future four of the 57 active permits may need to be reclaimed. BAMR cost estimates to reclaim five of the already forfeited anthracite underground mine sites range from $20,000 to $27,500 per site. The average BAMR estimated cost to reclaim an anthracite underground mine site is $21,800. The total estimated cost to reclaim the four anticipated forfeitures of active permits is therefore $87,200.
The current total bond amount for all active anthracite underground mine permits is $446,155, with the average bond amount per active site being $7,827. Thus, the projected bond proceeds from forfeitures of four permit sites is $31,309. Historically, the department has collected 100% of all forfeited primacy anthracite underground mine bonds. Assuming this collection rate for the future results in proceeds of $31,309 for the four forfeitures. The difference between this amount and the estimated cost to reclaim four anthracite underground permit sites is a deficit of $55,891. On an annual basis through the year 2003, the deficit would be $13,973. These details are summarized in Table 30.
With the anticipated collection of forfeited bonds for anthracite underground mine forfeitures, there will be an annual reclamation deficit of $13,973. This estimate excludes costs associated with the prevention of water pollution.
Table 30
Summary of Forfeitures and Reclamation Costs for Anthracite Underground Mine Permits
|
"Active" Anthracite Underground Mine Permits |
57 |
|
Percentage of Permits Forfeited |
6.3% |
|
Percentage of Forfeited Permits with bond program reclamation |
87.5% |
|
Number of Permits to Forfeit with bond program reclamation |
4 |
|
Anticipated Reclamation Cost 2000-2003 Forfeitures |
$87,200 |
|
Estimated Bonds on Forfeited Permits for Bond Program Reclamation |
$31,309 |
|
Percentage of Forfeited Bonds Collected by DEP |
100% |
|
Estimated Bonds to be Collected from Forfeitures |
$31,309 |
|
Estimated Deficit for Reclamation of Forfeited Permits |
($55,891) |
|
Annual Reclamation Deficit |
($13,973) |
Bituminous Underground Mining Permits
There are currently 81 active bituminous underground permits. The permitted and affected surface areas of bituminous underground mines are much more variable than for anthracite mines. For this reason, rates of forfeiture and associated reclamation costs are described by permit acreage, not the number of permits or cost per site. The historical forfeiture rate for bituminous underground permit acreage is 2.6%. Applying this percentage to the 28,056 acres of the active bituminous underground mine permits indicates that approximately 729 acres could be forfeited.
Historically, approximately 34% of all forfeited bituminous underground mine surface acres have had to be reclaimed. (See Table 28). This suggests that about 248 acres could require reclamation. The bonding program has been left to reclaim 36% of all forfeited bituminous underground mine acreage. This means that the bonding program could be expected to reclaim 90 acres from future forfeited bituminous underground mines.
BAMR cost estimates to reclaim already forfeited bituminous underground mine sites range from $11,363 to $77,922 per acre. The average BAMR estimated cost to reclaim a bituminous underground mine site is $34,342 per acre. The total estimated cost to reclaim the 90 acres due to anticipated forfeitures that may need to be reclaimed is $3,074,691.
The current total bond amount for all active bituminous underground mine permits is $60,490,198. The average bond amount per active site is $746,793. Historically, the average value of bonds available on forfeited bituminous underground sites that the bonding program has been left to reclaim is $6,484. Using this average, the department would have $583,560 in bonds available for use on the 90 acres projected to need reclamation. The department has been able to collect approximately 100% of all previously forfeited primacy bituminous underground mine bonds. Applying this historical collection rate to the total bond amount indicates that approximately $583,560 should be collected. The difference between this amount and the estimated cost to reclaim 90 acres of forfeited bituminous underground mine sites is a deficit of $2,491,131. On an annual basis, the deficit would be $622,783. These details are summarized in Table 31.
With the anticipated collection of forfeited bonds for bituminous underground mine forfeitures, there will be an annual reclamation deficit of $622,783. This estimate excludes costs associated with the prevention of water pollution.
Table 31
Summary of Forfeitures and Reclamation Costs for Bituminous Underground Mine Permits
|
"Active" Bituminous Underground Mine Acres |
28,056 |
|
Percentage of Permit Acres Forfeited |
2.6% |
|
Percentage of Forfeited Acres Requiring Reclamation |
34.0% |
|
Percentage of Forfeited Acres with Bond Program Reclamation |
36.1% |
|
Number of Forfeited Acres with Bond Program Reclamation |
90.0 |
|
Anticipated Reclamation Cost 2000-2003 Forfeits |
$3,074,691 |
|
Estimated Bonds on Forfeited Permits for Bond Program Reclamation |
$583,560 |
|
Percentage of Forfeited Bonds Collected by DEP |
100% |
|
Estimated Bonds to be Collected from Forfeitures |
$583,560 |
|
Estimated Deficit for Reclamation of Forfeited Permits |
($2,491,131) |
|
Annual Reclamation Deficit |
($622,783) |
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