America prices a prospector’s eleventh mining claim at $2,050 and the tenth at $15.

Start with the page the BLM mails to claimants, because it is published, dated and short. The 2027 Mining Season packet, posted in March 2026, states that “the Maintenance Fee for lode claims, mill sites or tunnel sites are $200 per claim or site,” that placer claims pay “$200 for each 20 acres of the claim or a portion thereof,” and that “annual filings will be due on September 1, 2026, for the 2027 assessment year” — followed by the words NO EXTENSIONS. Locating a new claim costs more in year one: the packet’s own table gives “a $49 location fee and an initial Maintenance Fee for the 2027 assessment year at the rate of $200 … along with a $25 processing fee,” and prints the sum: Total of — $274.

Now the line almost nobody quotes. The BLM’s mining claim filing requirements sheet says the upcoming year’s maintenance fee is due with the new claim fees “unless a waiver of maintenance fee is filed with the new claim Certificate of Location.” The waiver certification itself carries no processing fee. So the same new claim, located by a qualifying person, costs $25 + $49 = $74 — and then $15 a year for the annual filing that keeps it alive. The condition is not money. It is a headcount: the waiver is available only where “you and all related parties hold no more than a total of 10 mining claims or sites nationwide,” where related parties are “the spouse and dependent children of the claimant” and “a person who controls, is controlled by, or is under common control with the claimant,” and where you “continue to own or control 10 or less claims during the entire assessment year.”

Run that into arithmetic and a cliff appears. Ten claims held under the waiver cost $150 a year in cash to the government. Eleven claims cannot be held under the waiver at all — exceed the limit and “your waiver is immediately canceled and you must pay the maintenance fees for the claims on the waiver” — so eleven claims cost 11 × $200 = $2,200. The marginal cost of the eleventh claim is $2,050. Patriot Gold Corp’s own annual report puts twelve of its unpatented claims at “about 248 acres,” so a lode claim runs about 20.67 acres: ten claims under the waiver is $0.73 an acre a year, eleven claims at the fee is $9.68, and the ratio is 13.3× in favour of the smaller holder.

Where did the $200 come from? A final rule, FR Doc 2024–14301, effective 1 July 2024, implementing 30 U.S.C. 28j(c), which requires an adjustment “every 5 years after August 10, 1993, or more frequently if the Secretary determines an adjustment to be reasonable.” The BLM took the change in CPI-U from 31 December 2018 to 31 December 2023 — 22.1% — and applied it to the 2019 figures of $40 and $165, rounding the location fee to the nearest dollar and the maintenance fee to the nearest $5. The arithmetic checks: 165 × 1.221 = 201.465, rounded to $200; 40 × 1.221 = 48.84, rounded to $49. The 1993 originals were $25 and $100. The fee a fee-payer owes has therefore doubled since Congress invented it, while the filing fee a waiver-holder owes has not been touched by that mechanism at all, because it lives on a different schedule.

That other schedule is where the pattern repeats. The BLM’s annual cost-recovery notice at 91 FR 1195, FR Doc 2026–00386, effective 12 January 2026, prices the paperwork: notice of location $25, recording an annual FLPMA filing $15, transfer of a mining claim or site $15, amendment of location $15, deferment of assessment work $145, adverse claim $145, protest $90. And then, at the bottom, the giveaway: mineral patent adjudication, $2,005 for ten or fewer claims and $4,010 for more than ten. The ten-claim line is not a quirk of the waiver. It is written twice into the same fee structure, in two unrelated places, as the boundary between a person and an operation.

Here is the reading almost nobody holds. The argument about federal hard-rock minerals is an argument about giveaways to corporations, and it is conducted entirely in the language of what the public does not collect. Read the two fee schedules as a price list instead, and they say something narrower and stranger: the cheapest possible holder of federal mineral rights in the United States is one natural person with ten claims, and every structure that looks more serious — a partnership, an LLC with a portfolio, anything under common control — pays 13.3× as much per acre for identical ground. The binding input in this market is not capital. It is identity count. And Congress saw the obvious dodge coming: the waiver form carries its own criminal warning, “a fine of up to $250,000, a prison term not to exceed five years, or both,” and the related-party test reaches anyone “under common control,” which is exactly what a ring of nominee holders is.

Now the other side of the trade, which is where the money and the honesty both live. Patriot Gold Corp (PGOL) is a three-person shell — Trevor Newton as President, CEO, CFO, Secretary, Treasurer and director, Robert Coale as chairman, Zachary Black as director — that holds 130 unpatented claims and does no mining. Its income is a 3% net smelter returns royalty over roughly 400 unpatented claims and five patented parcels at the Moss Mine in Arizona, operated by Golden Vertex Corp. Its 10-K for 2025 reports royalty revenue of $361,523 in 2024 and $0 in 2025, with a net loss of $1,879,452. Its 10-Q for the quarter ended 30 June 2026 reports royalty revenue of $1,777,840 for the quarter against $0 a year earlier, net income of $1,284,517, and cash of $573,666. The same page discloses the reason for the gap: litigation, a settlement reached after quarter-end in which “the royalty remains intact going forward,” and separate litigation against the operator’s previous owners, who “filed for bankruptcy protection.”

Read those three numbers in order — $361,523, then $0, then $1,777,840 in a single quarter — and you have the shape of this asset class stated by an auditor rather than by a brochure. The company’s other property, Vernal, came to it through a “Property Option Agreement dated July 25, 2003” with MinQuest, Inc., which kept a 3% royalty on the way out. That is the whole business model in one sentence of a filing: somebody locates ground cheaply, options it to somebody with money, and keeps a percentage. The fee schedule says the cheapest person in the world to be at the start of that chain is an individual holding ten claims. It says nothing whatever about whether the second step ever happens.