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By William Mayrsohn

INTRODUCTION The net smelter return (NSR) calculations made on various smelter-refiner alternatives, is usually done by taking the gross metal value less metal deductions, smelter-refiner charges and transportation-insurance costs. An important further step in the calculations is the financial charges imputed by refining time, transportation delays, to the time gold is returned (if tolled) or paid for if bought by the refiner. Metal that is priced in advance of payment also requires a forward premium that the mine may or may not be getting. This is a hidden cost that is often omitted from the calculations. Segmentation of each of the above costs are vital to see where improvements can be made through negotiations, better choice of metal pricing or transportation alternatives. BASIC NSR CALCULATIONS SMELTER-REFINER CHARGES Payable Metals - Treatment Refining Charges: Since these can vary from one smelter to another, the effect of a $25 per ounce price increase/decrease should be calculated and kept in mind. This effect is compared to differences in refining/treatment charge and a total smelter/refiner cost on a cost per ounce of dore, gold, or a dry ton of concentrate. Transportation - Insurance: Research has to be done on transportation alternatives perhaps with some assistance from the smelters, railroads or trucking companies. For dore, the U.S. postal service is viable and inexpensive. For railroads, deal with the regional office ie., B&N El Paso, if production warrants regular bulk shipments. Spot rates tend to be higher. A small mine producing concentrates usually goes to the nearest smelter due to extremely high transportation costs. Here is where a refiner can help. Insurance-Quotes for rates on dore/ concentrates are easily obtainable, but the mine has to shop for the best rates. Your insurance broker is the best source of this information. Differences between Mine and Smelter/Refiners Metal losses can be caused by the following: - Concentrate dry weight differences caused by moisture determination or faulty scales (often at the mine). - Sample bias by poor preparation practices on either side ie., grinding of the sample removing gold; or a poorly mixed concentrate. Dore bullion has no such difficulties.

Jan 1, 1987

By D. Drymonitis, G. Gialoglou

"Placer gold mineralizations have been observed in the north-eastern parts of Greece. Some of them have been at first evaluated to be of special interest so, exploration campaigns have been designed and carried out. Among the other exploration techniques applied on the sites of interest, drilling was the one to give the detailed information and data for the evaluation of the deposits. Having collected the data from trenching and two consecutive drilling campaigns, they were processed geostatistically to estimate the ore reserves and therefore the economic interest of the deposits. The latter was done by using exploitability indices, which would give a rough idea whether the deposits were economically feasible. A small number of such deposits have been spotted in the area and have been explored and evaluated as above. The present paper deals with the most important of them, giving all the process followed and the results derived from the exploration carried out."

Jan 1, 2005

By James H. Boettcher, W. Durand Eppler

INTRODUCTION In the second quarter of 1979, Rapid Mining Co., Inc. ("Rapid") inquired whether Crocker National Bank ("CNB") would provide $4 million in term loan financing to help ("Dry Creek") acquire the outstanding shares of the Dry Creek Coal Company ("Dry Creek") in West Virginia. Prior to approaching CNB, Rapid had sought financing with the assistance of a financial advisor from a number of commercial banks without success. A summary of the initial terms requested by Rapid is shown in Table 1 compared with the actual terms on which the transaction closed. It is not difficult to note that the two sets of terms differ significantly. This is often the case when financing requests based on the expectations and vision of a mine developer are juxtaposed with more pragmatic requirements of a commercial bank. The "art" and fund of structuring financing plans for mining ventures (highly leveraged acquisitions or grass roots) comes in working with mine developers to arrive at a final financial structure that meets their objectives and constraints as well as those of the bank or other financial institutions providing much of the financing. Beginning with the terms requested by Rapid and ending with the terms that closed the transaction, this article briefly describes the process we went through with Rapid Mining. The Seller and Buyer The Dry Creek Coal Company was established in 1961, after its owner acquired the coal leases from Republic Steel. Republic has mined the primary coal seam from 1948-1961. Dry Creek was owned as a subchapter S corporation (i.e., for federal income tax purposes, income is taxed at the shareholder level) and had been run on a low key basis. Since the company had virtually no debt and limited cash needs, the owner produced primarily when rail cars were available and income was required. Output was therefore erratic as is shown in the top of Table II, but the result was a profitable little company with an attractive free cash position. Because the owner wished to retire and enjoy his wealth in a more readily spendable form, he had put the mine, with stated recoverable reserves of approximately 13 million tons, up for sale. In contrast, Rapid Coal's investors consisted of a number of investors of disparate financial situations. They had agreed upon a primary objective of income maximization and planned an annual production rate of 120,000 TPA which they and the current owner believed realizable. The Formulation of a Financing Structure Figure 1 presents a simplified overview of the sequence of steps taken in the financing process which lasted approximately three months from start to finish. Since banks see many requests for funding and considerble time is required to follow up on each, an important step was determining, after a brief review of the materials provided to us, whether the basic "eonomic entity" was viable. In this case, the size and quality of the reserves, the inherent operating cost characteristics, the sales arrangements, the management/labor situation and Rapid's principles all appeared to be sound enough to warrant investing the time necessary to do a thorough analysis of the project. Once this decision was made, the evaluation and analytic process shown in Figure 2 was initiated. The first and most fundamental concern of any banker is whether the loan will be paid back as scheduled from the cash flow generated by the project. The amount of debt relative to the owner's equity is of course crucial in such a determination. Before the debt/equity issue was addressed, however, a number of more qualitative factors had to be studied and if

Jan 1, 1985

By Xu C

This paper describes the structure and operation of an interacth.. computer program for mineral industry financial analysis and production planning. It includes comprehensive risk analysis with correlated variables and optimal production scheduling using Lane's balancing cut-off grades and the general dynamic programming approach.

Jan 1, 1995

By Lynton B. Manssen

Introduction Net Present Value (NPV) techniques are becoming widely used in industry as a standard analytical tool in making capital budgeting decisions. However, NPV techniques are often misused in "common practice." A comparison was made between the use of NPV techniques in common practice and an Adjusted Net Present Value (ANPV) approach to capital budgeting in the financial analysis of a mining project. The comparison was made by applying both methods to a hypothetical copper project. The intent of the analysis is to provide an example for practitioners to follow when financially analyzing mining (or other) projects. To maintain the thrust of the analysis, the project has been evaluated as a stand alone, total project. No consideration has been made of the division of cash flows accruing to various owners over the life of the project. This omission will not affect the comparative nature of the analysis. This discussion assumes that the reader is familiar with present value as a concept and as a tool in capital budgeting. Finance theory has embraced NPV analysis as the correct way to evaluate capital budgeting alternatives. Many articles have been written expounding the virtues of NPV over other capital budgeting methods, such as Internal Rate of Return (IRR), Payback, Accounting Rate of Return, and others. It is not the purpose of this article to review all of the literature in this area; suffice it to say that in academic circles NPV concepts are accepted as the norm. A survey by Schall, Sundem, and Geijsbeck (1978) indicates that major US companies are finally following in academia's footsteps. Fifty-six percent of the companies responding to the survey use NPV techniques in their capital budgeting process. Further, some 86% of the companies surveyed use discounted cash flow methods (NPV or IRR) for capital budgeting decisions. This compares with a survey by Klammer (1972) that showed 57% of companies using both techniques, a considerable increase in seven years. With the increasing use of NPV techniques in industry, there are certain uses in common practice that can give misleading results. Five common errors in NPV analysis of large projects are: • No distinction is made between real and nominal cashflows. • The discount rate(s) used in the NPV analysis is not formally adjusted for risk. • There is no distinction of possible differences in the riskiness of different project cash flows; i.e., revenue vs. depreciation. • There is no recognition of the cash benefits to the project from interest tax shields (interest payments on the project's debt that are tax deductible). • There is no clear recognition of subsidies to the project from concessionary debt financing. No Distinction Between Real and Nominal Cash Flows Often, expected cash flows for a project are stated as a mixture of real (in constant dollars) and nominal (in current dollars) cash flows. For example, expected revenue cash flows may be stated in real terms and depreciation may be stated in nominal terms. If cash flows are added together to give an after tax cash flow, and this single cash stream is discounted, care must be taken to ensure that cash flows are consistently stated. All cash flows should either be stated in nominal terms or in real terms. In addition, the discount rate used must be stated in the same terms as the cash flows being discounted. Real cash flows must be discounted using real discount rates and nominal cash flows using nominal discount rates. Discount Rate Not Adjusted Numerous methods for obtaining discount rates are used in common practice. Schall and others

Jan 6, 1983

By Hugh Douglas

This paper discusses the financial health of the U.S. mining industry and its ability to meet the future raw material requirements of this country in the context of resource independence. The title of this paper begs several questions, and three will be raised here. The answers to them will form the basis for discussion. The three questions are: What does one mean by resource independence. How is the U.S. mining industry defined. How is financial health measured.

Jan 1, 1977

In constructing a financial model of a project significant effort is expended on capital and operating cost estimation, commodity price forecasts, and choice of discount rates while uncertainty in the primary input, the reserve, is often completely overlooked. The aim of this paper is to highlight the impact of uncertainty in the resource/reserve estimation process on the assessment of the financial performance of a project. Four qualitative processes have an impact on resource/reserve uncertainty. These stages are: 1.Ore definition 2.Geological interpretation 3.Resource estimation 4.Ore reserve estimation and mine planning. Each stage contains a number of tasks that may be considered as key performance activities (KPAs). Optimizing the manner in which these KPAs are completed can remove a great deal of uncertainty and error from the resource/reserve process. Examination of these KPAs within a company can also provide an insight to the quality of the information underlying the project. This will allow the company to identify any shortcomings in the data and to assess the resulting risks (Gilfillan, 1998). A hypothetical financial model based on a gold operation has been used to estimate the potential effect of resource/reserve uncertainty on revenue. Monte Carlo simulation has been employed to simulate a number of hypothetical scenarios: 1.a base case scenario which assumes no major errors or biases, but contains realistic margins for uncertainty that would exist in any project where work is being completed to the limit of best endeavours 2.a poor sampling scenario which assumes poor sampling practice and lack of understanding of sample preparation 3.a poor resource estimation scenario which assumes poor modelling and inappropriate choice of interpolation technique, and 4. a ?typical? scenario which represents a project where the majority of KPAs are not performed as best as they could be. The results show that realistic uncertainty ranges can generate changes in the estimate of potential revenue of plus or minus 30%.Therefore, it is important to allow for errors in these processes in any financial analysis or feasibility study. It is recommended that, when building a financial model, are view of relevant resource/reserve KPAs be carried out and appropriate ranges for uncertainty be applied to provide a range of potential outcomes. These outcomes can then be factored into the detailed cash flow analysis in order to ensure that technical uncertainty is built into financial decisions.

Jan 1, 1999

The purpose of this paper is to outline the current status of financing in the Australian Gold Mining industry and to discuss a number of developments that have occurred during 1983/84.Recognising the importance of equity financing various equity issues, including project valuation, will be discussed against the backdrop of an industry experiencing both rapid growth and a changing structure.Nothwithstanding the current tax exempt status of the industry there is a trend towards more debt financing. A number of financing issues will be covered and it will be shown howvalue can be created through astute financing planning.

Jan 1, 1984

By Peter J. Maxworthy

INTRODUCTION There is no hard and fast rule on whether functions within a company, diversified or otherwise, should be strongly centralized or decentralized. In all diverse organizations, there are certain basic functions which remain common (or central) to each element of the business, viz: Personnel Management Cash Management Taxation Management Legal Planning Accounting Standards It would follow that each of these common factors requires some supervision at a central level to ensure that overall group objectives are met. It is true that other functions including: Industrial Relations Marketing and Distribution Production Research and Development Purchasing Management Accounting may also be common to each element of the organization. However, there is far less commonality in the degree to which these functions are central to the efficient performance and financial well-being of the business. Role of Operating Units The resources of operating centers may be viewed as a bank of funds, the nature of which can be changed from time to time, but the employment of which must provide for ongoing increases in the net worth of the total enterprise expressed in terms of market values. Operating units are required to continually review products, methods, and opportunities and to monitor avenues for incremental investment--all with a view to attaining the necessary additive net present value of future cash flows of the enterprise. Operating units should be permitted sufficient autonomy to enable the best use to be made of the skills and experience of the people it employs in order to produce a return appropriate to the value of assets employed. Role of Head Office The head office will typically comprise a specialist group--the leaner the better if one strongly adopts the decentralist approach--often acting as Service Centers but also performing a control function in the corporate sense. The head office function is a cost center. It may be instrumental in developing strategies for increasing revenues or reducing costs on a group scale, but it does not generate revenue. Every dollar spent on this function is an extra dollar to be generated by the operating centers in order to achieve an increase in corporate wealth. TREASURY MANAGEMENT Treasury management is concerned with the provision of finance, cash-flow management, and risk analysis. Each decision taken within the enterprise has a cash implication. It follows that a well-integrated central Treasury function can, in all likelihood, produce economic benefits. The degree to which the function should be centralized depends largely upon the unique nature of the operating units it is servicing. Levels of ownership, the calibre of unit operating managers, and the nature and geographic distribution of the business are all factors determining the degree to which the Treasury function is centralized. In the case of Peko-Wallsend, the Treasury Department is small, comprising four people. While divisional cash-flow management is largely decentralized, Treasury is responsible for the daily management of funds surplus to the immediate needs of operating units. Treasury also operates as central banker and provides funds to

Jan 1, 1985

By E. Kendall Cork

The traditional financial objective for a single mine company has been to operate as frugally as possible and to pay out most of the earnings as dividends. If the business is cyclical (as it is for most metals) the dividends might fluctuate quite widely. When the mine is exhausted the company disappears. This is still quite a viable strategy for a single mine company. It is not however a viable strategy for the world as a whole. The mining industry is built by mine development companies who can mobilize the people and capital to bring new mines into production. Their skills must include marketing, engineering, finance and other politics. It is very rare for a property to be brought in without the support of a major company that can provide all these services. The exceptions will usually have some other form of big brother support, for example the U.S. government uranium contracts at guaranteed generous prices. The mine development company will seek as a minimum to perpetuate itself by developing new mines in order to replace those which are running out. The more common and more ambitious objective is to grow -- that is to add to its ore reserves and current production by developing more new mines. The financial objectives for that company are very different. Obviously if all the earnings were paid out in dividends there would be nothing left to work with. The first financial policy then is to spend an appropriate amount on exploration for new properties. The next is to retain enough of the earnings to provide the capital for new projects at least sufficient for the equity. There is no magic formula as to what proportion of earnings should properly be distributed as dividends by a growth-oriented mine development company. As a rough rule of thumb distributing half or more will probably leave too little to work on and 30% or so is probably a good balance. However the circumstances differ widely from company to company. It may be useful to set an objective for the rate of growth of a company's earnings. Some have picked rates such as 15% per annum compounded. Others have set a target in real terms which might appear as 10 or 11% plus inflation. Obviously the arithmetic of compound interest is very attractive; however in practice there is much variation. Indeed current returns from existing operations swing widely with the business cycle and there is no assurance that economic new properties will be found according to someone's arbitrary time schedule. For example, Western Mining Corporation Limited in Australia explored for 30 years with little to show for it, but then found the great Australian nickel deposits and more recently the huge Roxby Downs copper. That long dry spell could not have fitted anyone's arbitrary calendar of growth and yet they would not have found such orebodies without that long period of effort. Should they have abandoned the search? Once a new property has been found or acquired there has to be a threshold rate of return on the new capital to be invested against which to evaluate the property's economics. Conventionally this seems to be 15% after tax, a number common in other heavy industries as well. In some cases it is expressed as a lower number plus allowance for inflation. Discounted cash flow analysis is a very useful tool but it does not make the decision. In the end a "go" decision depends on judgment of many factors some of which are numbers used in the DCF calculation whose credibility must be examined. It is curious how frequently investment proposals come in with the rates of return very close to 15%. The project advocates know that a number much less than 15% will not fly and that a number much more is not necessary. With much higher nominal and real interest rates of recent years, even though before tax, logic suggests that the hurdle rate should also rise. The power of compound interest is so great that 20% is very hard to achieve in any cash flow projection but 18% may be a sensible yard - stick. Once again it is remarkable how many project proposals come in with an 18% return. On the record the mining industry as a whole has not been overly restrictive in choosing its hurdle rates of return. This is shown by the abundance of metals in recent years and the failure of metal prices to keep up with inflation. All of the foregoing is standard text book stuff.

Jan 1, 1985

By Cole NH

Substantial savings in terms of project time, cost, and financial viability can result through the expert involvement of independent financial advisors in the early stages of any mining project's preparation. This role is not confined to project financing, financial modelling, valuations and corporate finance advice, but may in the early stages be much more strategic in nature, covering a wide group of subject areas. A number of separate examples and case studies are outlined, which show the manner in which financial advisors can be effectively used. The benefits arising from involving an additional professional team with the project group must be offset against the separate and additional cost factors involved.

Jan 1, 1986

By Jr. Winters

The United States continues to be the largest producer and consumer of copper in the world. Table 1 on the following page shows several production statistics for 1974, the most recent year which the non-communist world copper industry might consider a good year, and for 1976 and 1977. In 1974 an estimated 24 percent of the non-communist world's newly mined copper was mined in the United States, and. 87 to 89 percent of that was from the western porphyry coppers. In 1976 U. S. new mine production was down to 22 percent of the non-communist world's newly mined copper, and the percentage of U. S. new mine production supplied by the porphyry coppers had risen to 89 to 91 percent. In 1977 the statistics remained the same as in 1976. U. S. porphyry copper production represented about 65 percent of U. S. refined copper consumption in 1974, rose to 75 percent in 1976, and dropped back to 61 percent in 1977 as imports of foreign copper into the United States began to swell.

Jan 1, 1978

By H. J. Winters

Position of the Porphyries in US Copper Supply The United States continues to be the largest producer and consumer of copper in the world. [Table 1] shows several production statistics for 1974, the most recent year that the non-communist world copper industry might consider a good year, and for 1976 and 1977. In 1974 an estimated 24% of the non-communist world's newly mined copper was mined in the US, and 87.89% of that was from the western porphyry coppers. In 1976 US new mine production was down to 22% of the non-communist world's newly mined copper, and the percentage of US new mine production supplied by the porphyry coppers had risen to 89-91%. In 1977 the statistics remained the same as in 1976. US porphyry copper production represented about 65% of US refined copper consumption in 1974, rose to 75% in 1976, and dropped back to 61% in 1977 as imports of foreign copper into the US began to swell. The financial situation of the porphyry copper mining industry continues to be very unhealthy. To see why; we can take a quick look at costs and prices.

Jan 1, 1982

By David M. Koogler

If you are contemplating starting a small coal mining operation there is a good possi¬bility that you can not afford it. If you, have already started, you may be on the road to bankruptcy. If you are a small but well established operator you may be trading dollars, or even dissipating your capital, equipment and other assets. A bleak outlook? Yes! Meant to be discouraging? No! Just a reminder that, with todays costs of doing business, high interest rates, rapidly increasing costs and decreasing sales prices, a small businessman/miner had best watch closely or he will be mired in something worse than a soft bottom - namely a cash and credit shortage, and in too many instances In recent times, bankruptcy. We will not dwell on what happens once you are that far gone, though I could cite a good example. But, let us look at what should be done to avoid such a catastrophe.

Jan 1, 1981

The visible portion of accounting-record keeping and preparation of financial statements-suggests a lack of sophistication and imagination. In reality, accounting is based on a large body of theory. Accountants philosophize, theorize, judge, create, and deliberate as a significant part of their professional practice. The subjective aspects that are so critical to current accounting practice, such as searching for truth and fact, judging what is fair presentation, and considering the behavior induced by presentations, are often overshadowed by the appearance of exactitude, precision, and objectivity that accompanies the use of numbers to express the financial results of the enterprise. * Fundamental accounting principles are hypothesized in the same manner as mathematical principles. These principles are justified by acceptability and intuition. Accounting theory is built upon these hypotheses, resulting in a coherent set of standards and rules. Although it does not specifically address every situation that may be encountered, this conceptual frame- work enables the manager or analyst to resolve specific situations. This framework also aids in the understanding and confidence in financial statements and ensures comparability between statements from different companies. This framework is referred to as "generally accepted accounting principles," or GAAP.

Jan 1, 1999

By Blom W. M

Shareholders, creditors, government agencies and auditors all have a different perspective of financial reports which is determined by the uses to which they put the information disclosed in the report.Shareholders today are better informed than previously and are more aware of the market in which they are investing. This is the result of the increasing role of institutional investors and the increasing reliance being placed on analysts to interpret financial information.

Jan 1, 1990

By Warren M

Many Australian tunnelling and mining companies regularly investigate different methods or equipment in an attempt to keep ahead of their competition. Sometimes the result is a new approach or process which wins a tender or provides an advanced solution to a problem.The Australian Government has a policy of encouraging forward thinking among Australian companies and provides a range of incentives. One of these incentives is currently available retrospectively to 1985 - 86, and the registration process is relatively simple with only one form to be completed. Companies who investigate methods of raising productivity could be reimbursed for the costs of the investigation.

Jan 1, 1993

By Barnett DW

Financial risk analysis provides the tools to examine the uncertainty of capital decisions in new mining ventures. This paper explores the methodology by which financial risks can be studied and quantified. The most commonly used risk evaluation methods, such as sensitivity analysis and discount rate adjustment, are presented as an introduction to a more comprehensive discussion of stochastic methods of discounted cash flow analysis using Monte Carlo sampling. The discussion is illustrated with examples of a stochastic discounted cash flow. The advantages of Monte Carlo sampling in risk analysis are discussed together with its problems, particularly those originating from the correlation amongst the variables that determine the economic output of a mining venture, and the difficulties created by insufficient data, imperfect knowledge and complexity. The paper also surveys the most commonly used software used in risk analysis.

Jan 1, 1994

[ASSETS CAPITAL ASSETS: Equity in United Engineering Society's Land and Buildings $486,792.79 Library 40,000.00 $526,792.79 INVESTMENTS: Jas. Douglas Fund-Schedule #2 $ 99,966.40 Life Membership Fund-Schedule #3 9,415.63 R. W. Hunt Medal Fund-Schedule #4 7,489.09 116,871.12 INVENTORIES: Paper Account 305.10] [ ]

Jan 1, 1925

By Douglas A. Karvonen

INTRODUCTION Although the economy in the Province of Saskatchewan has historically been agriculturally oriented, a major source of wealth has been realized through natural resources such as petroleum and natural gas, coal and uranium and since the 1960's - potash. Potash or potassium chloride, in the form in which it is presently produced in Saskatchewan, is used primarily as fertilizer, a source of potassium, one of three essential elements required for healthy plant growth, with about 5% of production sold to the chemical industry for use in such products as soap and liquid detergent, glass and ceramics, textiles and some pharmaceuticals. Saskatchewan is estimated to have approximately 40% of known world potash reserves and its ten active mines account for some 25% of annual world production. POTASH CORPORATION OF SASKATCHEWAN In an effort to guarantee a fair and lasting economic benefit to the Province of Saskatchewan, the Potash Corporation of Saskatchewan (PCS) was created on February 4, 1975 through an Order-in-Council under the Crown Corporation's Act and later on April 1, 1976, the Potash Corporation Act provided for its continuation. PCS was given the mandate to acquire ownership of a significant portion of the potash mining capacity in Saskatchewan and to establish an organization capable of operating the facilities, marketing the product, and conducting all of the other activities necessary for a successful corporation competing in the world potash industry. The corporation is the largest potash producing and selling organization in the Western World - or third largest in the world. (See also Figure 1). PCS through its wholly-owned subsidiary, PCS Mining, has acquired a whole or partial interest in five geographically distinct producing properties or divisions, representing today more than 40% of Saskatchewan's potash producing capacity. The acquisition of each division was followed by a program designed to exploit and maximize the particular opportunities at each minesite for increased production. To that end, PCS Mining has taken an active lead in expanding to meet future demand and has implemented expansion programs at all properties except for its Esterhazy Division where it has a long-term processing agreement with International Minerals & Chemical Corporation (Canada) Limited. Through its wholly-owned subsidiaries, PCS Mining, PCS Sales and PCS Transport, this provincial crown corporation has the ability to operate as a producer and marketer of Saskatchewan's potash. In certain instances PCS, the parent company, assists in the financing of various projects undertaken by the subsidiaries and in other cases the subsidiary involved arranges its own financing. POTASH RESERVES As a background to the specific issue of financing, it is helpful to describe briefly the nature of the deposit which supports the industry - our collateral, if you like. The potash beds underlying Saskatchewan are sedimentary rock deposits formed by the gradual evaporation of an inland sea during the Middle Devonian period roughly 400 million years ago. Now known as the Prairie Evaporite, this formation stretches from North Dakota and Northeast Montana through Southern Saskatchewan into North-Central Alberta. These beds lie at mining depths ranging from 950 - 1000m (3,000 ft) below the surface, where conventional mining methods can be used, and to 1,650m (5,000 ft), where solution mining must be

Jan 1, 1985