BLM Fee Increase for new claim filing and yearly maintenance fees
New fee structure adopted 7/1/2019 pertains to all BLM administered land claims
As it is our duty to inform you of changes in Federal, State and Local policy, rules, regulations and decision. On July 1st the BLM published the rate increase for all new and existing claims effective that date moving forward.
I have paraphrased the ruling publication to cover the more vital and pertinent sections of the final rule.
The Bureau of Land Management (BLM) is issuing this final rule to make statutorily required adjustments to its location and maintenance fees for unpatented mining claims, mill sites, and tunnel sites. These adjustments reflect changes in the Consumer Price Index (CPI), which is published by the Bureau of Labor Statistics.
The final rule is effective July 1, 2019.
The calculated change is 7.80 percent from December 31, 2013, through December 31, 2018. A calculated value for the fees was obtained by inflating the location and maintenance fees established in the 2014 rulemaking by 7.80 percent.
The new location fee is $40, and the new maintenance fee is $165 per lode mining claim or site and $165 for each 20 acres or portion thereof for placer mining claims.
The new location fee is based on rounding the calculated value to the nearest $1. The maintenance fee is based on rounding the calculated value to the nearest $5.
Mining claimants must pay the new maintenance fee to maintain existing mining claims and sites beginning with the 2020 maintenance year. The maintenance fee is due on or before September 1, 2019. Under 43 CFR 3834.23(d), mining claimants who have already submitted maintenance fees for the 2020 assessment year, and those who timely pay the 2020 assessment year maintenance fee based on the fee in effect immediately before the adjustment was made, will be given an opportunity to pay the additional amount without penalty upon notice from the BLM.
I find the following information extremely interesting and I suggest that you take the time to read the entire document which is located here: https://www.federalregister.gov/documents/2019/07/01/2019-13963/required-fees-for-mining-claims-or-sites.
At the end of Fiscal Year (FY) 2018, there were approximately 27,800 claimants holding approximately 413,000 mining claims and sites. This works out to be an average of 15 claims or sites per claimant. we estimate a total maintenance fee increase of about $5.34 million per year.
This represents an average maintenance fee increase of about $192 per claimant. The actual impact on an individual claimant will depend on a number of factors, including the number of claims or sites that are actually held. However, the average number of claims and sites actually held by individuals and companies that would be considered small entities by SBA would likely be significantly less than the 15 claims or sites per claimant figure. This average claims-per-claimant figure is skewed by the large number of claims and sites held by a few large mining companies.
For example, the three companies holding the most mining claims or sites at the end of FY 2018 each held over 10,000 claims or sites. All three of those companies were large multi-national corporations.
I will not express any personal opinion on Big Mining (If we have ever had a discussion about Big Mining and how it effects small scale mining you already know my position) yet the numbers released by the BLM in their Final Rule on the fee increase shows a great deal of impact Big Mining has on the small scale miner in regards to the BLM overall rate increases in the last few years.
When I received this Final Rule from the BLM on Monday July 1st I was definitely taken aback to some degree. I was in the middle of completing the BLM filing schedule for the 300 plus claims we administer and know firsthand after recalculating the now due 2019/2020 fees, the impact that this will have financially on the Small Scale Mining community for years to come.
I again ask that you take the time to read the entire document from the link above. After reading the document in its entirety and if you are a claim holder or considering filing as claim in the upcoming year, that could be burdened by this or future fee increases, I invite you to email me to begin a discussion on retaining your claim and opening it up to GPAA members.
With the right GPAA program for your sharing of your claim you are entitled to GPAA/LDMA Member Benefits plus there is a distinct probability of receiving a yearly fee to cover filing and recordation cost in all but a few cases.
We must stand strong, stay strong and work together to better our opportunities in recovering gold.