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The issuer engaged external engineering consultants (“company's specialists”) to review and evaluate the mineral reserves and resources estimates prepared by management which were then used in the development of a life-of-mine (LOM) plan for each site. The company's specialists evaluated the estimated mineral reserves and resources using various methods which included the use of financial and non-financial information data and assumptions that were provided by or obtained from the issuer other specialists and/or external sources. The firm's approach for substantively testing the valuation of long-lived assets was to test the issuer's process. With respect to the evaluation of the LOM plans and reserves estimates by the company's specialists which were then used in the issuer's depreciation expense calculations the following deficiencies were identified: · The firm did not perform any procedures to evaluate the reasonableness of significant assumptions used by the company's specialists. (AS 2501.16; AS 1105.A8b)

The issuer engaged external engineering consultants (“company's specialists”) to review and evaluate the mineral reserves and resources estimates prepared by management which were then used in the development of a life-of-mine (LOM) plan for each site. The company's specialists evaluated the estimated mineral reserves and resources using various methods which included the use of financial and non-financial information data and assumptions that were provided by or obtained from the issuer other specialists and/or external sources. The firm's approach for substantively testing the valuation of long-lived assets was to test the issuer's process. With respect to the evaluation of the LOM plans and reserves estimates by the company's specialists which were then used in the issuer's depreciation expense calculations the following deficiencies were identified: · The firm did not perform any procedures to evaluate whether the methods used by the company's specialists were appropriate under the circumstances. (AS 1105.A8c)

The issuer had determined during the first and second quarters that one of its properties was not impaired based on the results of analyses that it had performed in those quarters to determine whether the carrying value of the property was recoverable. The firm did not identify and test any controls over these analyses. (AS 2201.39)

The issuer capitalized certain employee and contractor labor costs to long-lived assets. The following deficiencies were identified: · The firm used employee and contractor hours derived from the issuer's time recording system in its substantive testing of these capitalized labor costs. The firm did not test or (as discussed above) test or sufficiently test controls over the accuracy of the employee or contractor hours. (AS 1105.10)

The issuer identified indicators of potential impairment related to certain CGUs performed an impairment analysis over those CGUs and recorded an impairment charge. The firm selected for testing a control that included the issuer's review of the assumptions used in the impairment analysis. The firm did not evaluate the specific review procedures that the control owners performed to assess the reasonableness of these assumptions. (AS 2201.42 and .44)

The issuer had multiple cash generating units ('CGUs'). For one CGU the issuer concluded that there were no indicators of potential impairment. For another CGU the issuer identified indicators of potential impairment performed an impairment analysis and recorded an impairment charge. The firm selected for testing controls over the issuer's evaluation of long-lived assets for possible impairment that included the issuer's reviews of (1) potential indicators of impairment and (2) assumptions underlying the forecasted operating costs capital expenditures and discount rates used in the impairment analysis. The firm did not evaluate the specific review procedures that the control owners performed (1) with respect to potential indicators of impairment related to the first CGU and (2) to assess the reasonableness of the forecasted operating costs capital expenditures and discount rates used in the impairment analysis for the second CGU. (AS 2201.42 and .44)

The firm did not evaluate management's determination that there were no indicators of potential impairment for the first CGU beyond inquiring of management and reading the issuer's impairment indicator memorandum and a reserves report prepared by an external specialist. (AS 2301.08)

The firm's approach for substantively testing the impairment analysis for the second CGU was to review and test management's process. The firm did not sufficiently test the impairment analysis for this CGU because the firm did not perform procedures to evaluate the reasonableness of the discount rates and the forecasted operating costs and capital expenditures beyond the first year that the issuer used in the impairment analysis. (AS 2501.09 10 and .11)

The issuer capitalized certain employee and contractor labor costs to long-lived assets. The following deficiencies were identified: · The firm did not identify and test any controls over the accuracy of the employee labor hours associated with the employee labor costs capitalized to long-lived assets. (AS 2201.39)

The issuer capitalized certain employee and contractor labor costs to long-lived assets. The following deficiencies were identified: · The firm selected for testing a control that consisted of the review and approval of contractor labor hours. The firm did not evaluate the specific review procedures that the control owners performed to address the accuracy of the contractor labor hours associated with the contractor labor costs capitalized to long-lived assets. (AS 2201.42 and .44)

The issuer's policy was to group its property plant and equipment as a single asset group when evaluating its long-lived assets for possible impairment because the cash flows were interdependent. The following deficiencies were identified: · The firm selected for testing a control over the impairment of property plant and equipment which included the determination of its asset grouping. The firm did not evaluate the specific review procedures that the control owner performed to assess whether the issuer's use of a single asset group was in conformity with FASB ASC Topic 360 Property Plant and Equipment. (AS 2201.42 and .44)

The issuer's policy was to group its property plant and equipment as a single asset group when evaluating its long-lived assets for possible impairment because the cash flows were interdependent. The following deficiencies were identified: · The firm did not perform substantive procedures beyond reading an issuer-prepared memorandum to evaluate whether the issuer's use of a single asset group was in conformity with FASB ASC Topic 360. (AS 2301.08)

The firm selected for testing a control that consisted of management's review of certain assumptions used to determine depreciation expense on long-lived assets. The firm did not evaluate the review procedures that the control owners performed including the procedures to identify items for follow up and the procedures to determine whether those items were appropriately resolved. (AS 2201.42 and .44)

For a third asset the firm's approach to evaluate the recoverability of this asset was to test the issuer's process. The issuer engaged two external specialists to develop an estimate that the issuer considered along with other assumptions and information in determining the recoverability of the asset. The firm used the work of the company's specialists as audit evidence. The following deficiency was identified: · The firm did not perform sufficient procedures to evaluate the relevance and reliability of the work performed by the company's specialists and whether the specialists' findings support or contradict the recoverability of the asset because it did not (1) identify that the report compiled by the company's specialists was a year old and (2) evaluate whether the specialists' findings continued to be relevant and reliable. (AS 1105.A9 and .A10)

The firm did not perform procedures to evaluate whether certain transactions were appropriately capitalized in accordance with the applicable accounting standard. (AS 2301.08 and .11)

For one asset the issuer performed an assessment of this asset for possible impairment and concluded that it was recoverable. The firm did not identify that the issuer did not consider certain indicators of possible impairment in its assessment of this asset. (AS 2301.08 and .11; AS 2810.03)

For a second asset the issuer estimated the recoverable amount of the asset and determined that it exceeded the asset's carrying value. The firm did not perform any procedures to test the issuer's estimated recoverability of this asset. (AS 2501.07)

For a third asset the firm's approach to evaluate the recoverability of this asset was to test the issuer's process. The issuer engaged two external specialists to develop an estimate that the issuer considered along with other assumptions and information in determining the recoverability of the asset. The firm used the work of the company's specialists as audit evidence. The following deficiency was identified: · The firm did not perform procedures to evaluate (1) the knowledge skill and ability of one company specialist and (2) the relationship of the issuer to this specialist. (AS 1105.A3 and .A4)

For a third asset the firm's approach to evaluate the recoverability of this asset was to test the issuer's process. The issuer engaged two external specialists to develop an estimate that the issuer considered along with other assumptions and information in determining the recoverability of the asset. The firm used the work of the company's specialists as audit evidence. The following deficiency was identified: · The firm did not perform any procedures to evaluate the reasonableness of certain significant assumptions developed by the company's specialists or the issuer that were used by the specialists to develop the estimate. (AS 1105.A8b; AS 2501.16)

For a third asset the firm's approach to evaluate the recoverability of this asset was to test the issuer's process. The issuer engaged two external specialists to develop an estimate that the issuer considered along with other assumptions and information in determining the recoverability of the asset. The firm used the work of the company's specialists as audit evidence. The following deficiency was identified: · The firm did not perform any procedures to evaluate the relevance and reliability of external information the issuer used to determine the recoverability of the asset. (AS 1105.04 and .06)

For a third asset the firm's approach to evaluate the recoverability of this asset was to test the issuer's process. The issuer engaged two external specialists to develop an estimate that the issuer considered along with other assumptions and information in determining the recoverability of the asset. The firm used the work of the company's specialists as audit evidence. The following deficiency was identified: · The firm did not perform procedures to test the accuracy and completeness of company-produced data and evaluate the relevance and reliability of certain other data from sources external to the issuer that the company's specialists used to develop the estimate considered by the issuer in determining the recoverability of the asset. (AS 1105.A8a)

For a third asset the firm's approach to evaluate the recoverability of this asset was to test the issuer's process. The issuer engaged two external specialists to develop an estimate that the issuer considered along with other assumptions and information in determining the recoverability of the asset. The firm used the work of the company's specialists as audit evidence. The following deficiency was identified: · The firm did not perform procedures to evaluate whether the methods used by the company's specialists were appropriate under the circumstances. (AS 1105.A8c)

The issuer exchanged land with an external party during the year. The issuer estimated the fair value of the acquired land based on the nominal value within the agreement and the purchase price of other land during the year (collectively the 'inputs'). The firm selected for testing a control that included a review of accounting and other considerations for this transaction. The firm did not evaluate the specific review procedures that the control owners performed to evaluate the relevance of inputs used to estimate the fair value of the acquired land. (AS 2201.42 and .44)

The firm did not perform substantive procedures to evaluate the relevance of the inputs used to estimate the fair value of the acquired land beyond determining that the acquired land was adjacent to land previously acquired by the issuer during the year. (AS 2502.26 .28 and .31)

The firm did not perform any substantive procedures to test additions to long-lived assets. (AS 2301.08)

The firm did not perform sufficient procedures to test the estimated useful lives assigned to the issuer's property and equipment because it limited its procedures to comparing the useful lives to information from an external source. Further the firm did not evaluate the relevance and reliability of the information. (AS 1105.04 and .06; AS 2501.07)

The firm did not perform procedures to evaluate the issuer's conclusion that there were no indicators of potential impairment even though the firm was aware that such conditions existed. (AS 2301.08; AS 2810.03)

The issuer performed an impairment analysis for its long-lived asset groups using estimates of future undiscounted cash flows to evaluate whether the carrying value of each asset group was recoverable. These estimates were based on a weighted average of historical cash flows for each asset group. The firm's approach for substantively testing this analysis was to review and test management's process and for certain asset groups to develop an independent expectation of the estimate. The following deficiencies were identified: • The firm did not evaluate whether certain assumptions the issuer used in this analysis were in conformity with FASB ASC Topic 360 Property Plant and Equipment. (AS 2810.30)

The issuer performed an impairment analysis for its long-lived asset groups using estimates of future undiscounted cash flows to evaluate whether the carrying value of each asset group was recoverable. These estimates were based on a weighted average of historical cash flows for each asset group. The firm's approach for substantively testing this analysis was to review and test management's process and for certain asset groups to develop an independent expectation of the estimate. The following deficiencies were identified: • The firm did not evaluate the reasonableness of the weighting that the issuer assigned to the historical cash flows including consideration of the significant adverse events that affected the issuer's business during the year beyond concluding that it was reasonable to weigh the more recent results more heavily. (AS 2501.09 .10 and .11;3 AS 2810.03) [This citation refers to AS 2501 Auditing Accounting Estimates which was in effect for this audit. This standard was replaced by AS 2501 Auditing Accounting Estimates Including Fair Value Measurements which became effective for audits of financial statements for fiscal years ending on or after December 15 2020.]

The issuer performed an impairment analysis for its long-lived asset groups using estimates of future undiscounted cash flows to evaluate whether the carrying value of each asset group was recoverable. These estimates were based on a weighted average of historical cash flows for each asset group. The firm's approach for substantively testing this analysis was to review and test management's process and for certain asset groups to develop an independent expectation of the estimate. The following deficiencies were identified: • The firm used certain information from external sources to develop its independent expectations but did not perform any procedures to evaluate the relevance and reliability of this information. (AS 1105.04 and .06)

The firm selected for testing a control over management's review of long-lived assets for potential impairment. The firm did not evaluate the review procedures that the control owner performed including the criteria that the control owner used to identify items for follow up and whether those items were appropriately resolved. (AS 2201.42 and .44)

The firm did not evaluate the effect of certain impairment indicators on whether the carrying value of long-lived assets was recoverable. (AS 2301.08; AS 2810.03)

The firm selected for testing certain review controls over long-lived assets. The firm did not evaluate the review procedures that the control owners performed including the procedures to identify items for follow up and the procedures to determine whether those items were appropriately resolved. (AS 2201.42 and .44)

The firm selected for testing a review control over purchases and disposals of long-lived assets. The firm did not test the aspect of this control related to the control owner's review of the summary of activity or transaction details supporting the control. (AS 2201.42 and .44)

The issuer developed undiscounted cash flows to evaluate certain long-lived assets for potential impairment. The following deficiency was identified: · The firm did not perform procedures to evaluate the reasonableness of significant assumptions related to daily revenue rates beyond comparing the rates used by the issuer to rates obtained from the external source that the issuer used to develop the assumptions. (AS 2501.16)

The issuer developed undiscounted cash flows to evaluate certain long-lived assets for potential impairment. The following deficiency was identified: · The firm did not perform procedures to evaluate the relevance and reliability of the rates obtained from the external source. (AS 1105.04 and .06)

The issuer developed undiscounted cash flows to evaluate certain long-lived assets for potential impairment. The following deficiency was identified: · The firm did not perform sufficient procedures to evaluate the reasonableness of significant assumptions related to certain expense rates because it limited its procedures to comparing the rates to the actual operating expenses during the year and the issuer's budget without evaluating whether the issuer had a reasonable basis for the assumptions in the budget. (AS 2501.16)

The firm did not perform any procedures to test the additions made to long-lived assets during the year. (AS 2301.08)

The issuer capitalized certain labor costs associated with the development of an asset. The firm used labor hours in its substantive testing of this asset but did not perform any procedures to test or test any controls over the accuracy and completeness of these labor hours. (AS 1105.10)

The issuer performed an assessment of its long-lived assets for possible impairment at year end using various significant assumptions it developed based on its planned course of action. The firm's approach for substantively testing the issuer's impairment assessment was to test the issuer's process. The following deficiencies were identified: · The firm did not identify and evaluate that the issuer did not comply with FASB ASC Topic 350 Intangibles – Goodwill and Other and FASB ASC Topic 360 Property Plant and Equipment because the issuer performed its impairment assessment of goodwill prior to performing its assessment of long-lived assets for possible impairment. (AS 2810.30) In connection with our review the issuer reevaluated its assessment of long-lived assets for possible impairment and concluded that misstatements existed that had not been previously identified. The issuer subsequently corrected these misstatements in a restatement of its financial statements and the firm revised and reissued its report on the financial statements.

The issuer capitalized certain labor costs and external costs associated with the development of this asset. Capitalized labor costs were estimated using a significant assumption. The following deficiencies were identified: · The firm did not perform any procedures to evaluate the reasonableness of this significant assumption. (AS 2501.16)

The issuer capitalized certain labor costs and external costs associated with the development of this asset. Capitalized labor costs were estimated using a significant assumption. The following deficiencies were identified: · The firm used certain issuer-produced reports in its substantive testing of this asset but did not perform any procedures to test or test controls over the accuracy and completeness of these reports. (AS 1105.10)

The issuer capitalized certain labor costs and external costs associated with the development of this asset. Capitalized labor costs were estimated using a significant assumption. The following deficiencies were identified: · The firm did not evaluate whether the issuer's capitalization of external costs was in conformity with FASB ASC Topic 350. (AS 2301.08 and .11)

The firm did not evaluate whether the method used by the issuer to estimate amortization expense for capitalized external costs was in conformity with certain requirements of FASB ASC Topic 350. (AS 2501.10)

The issuer performed an assessment of this long-lived asset for possible impairment and concluded that it was recoverable. The firm did not identify that the issuer did not consider certain indicators of possible impairment in its assessment of this asset. (AS 2301.08 and .11; AS 2810.03)

During the year the issuer identified events indicating that the carrying value of its long-lived assets may not be recoverable. The issuer performed an impairment analysis using forecasted cash flows that it developed using various assumptions. The following deficiencies were identified: · The firm did not perform any procedures to evaluate the reasonableness of certain significant assumptions. (AS 2501.16)

During the year the issuer identified events indicating that the carrying value of its long-lived assets may not be recoverable. The issuer performed an impairment analysis using forecasted cash flows that it developed using various assumptions. The following deficiencies were identified: · The firm did not perform procedures to evaluate the reasonableness of another significant assumption beyond reviewing the effect that certain external events would have on the assumption. (AS 2501.16)

During the year the issuer identified events indicating that the carrying value of its long-lived assets may not be recoverable. The issuer performed an impairment analysis using forecasted cash flows that it developed using various assumptions. The following deficiencies were identified: · The firm did not perform sufficient procedures to evaluate whether the method used by the issuer to develop its impairment analysis was in conformity with the requirements of FASB ASC Topic 360 because it did not evaluate whether certain assets were (1) assets under development at the time of the impairment analysis and as a result the issuer should have included the carrying value of these assets in its impairment analysis or (2) capital expenditures that would increase the service potential of the long-lived asset group and as a result the issuer should have excluded the cash flows associated with these assets in its impairment analysis. (AS 2501.10)

The issuer performed an assessment of its long-lived assets for possible impairment at year end using various significant assumptions it developed based on its planned course of action. The firm's approach for substantively testing the issuer's impairment assessment was to test the issuer's process. The following deficiencies were identified: · The firm did not sufficiently evaluate the reasonableness of certain significant assumptions including taking into account factors affecting the issuer's intent and ability to carry out these assumptions because its procedures were limited to inquiring of management and evaluating the assumptions for consistency with recent experience. (AS 2501.16 and .17) In connection with our review the issuer reevaluated its assessment of long-lived assets for possible impairment and concluded that misstatements existed that had not been previously identified. The issuer subsequently corrected these misstatements in a restatement of its financial statements and the firm revised and reissued its report on the financial statements.

The issuer performed an assessment of its long-lived assets for possible impairment at year end using various significant assumptions it developed based on its planned course of action. The firm's approach for substantively testing the issuer's impairment assessment was to test the issuer's process. The following deficiencies were identified: · The firm did not sufficiently evaluate the reasonableness of certain other significant assumptions because its procedures were limited to evaluating the assumptions for consistency with certain industry information. Further the firm did not perform procedures to evaluate the relevance and reliability of this industry information. (AS 1105.04 and .06; AS 2501.16) In connection with our review the issuer reevaluated its assessment of long-lived assets for possible impairment and concluded that misstatements existed that had not been previously identified. The issuer subsequently corrected these misstatements in a restatement of its financial statements and the firm revised and reissued its report on the financial statements.