SEC Comment Letter for UR-ENERGY INC (URG) (CIK 0001375205) (URG) — Jun 2, 2015
UR-ENERGY INC (URG) (CIK 0001375205)
Date: June 2, 2015 · CIK: 0001375205 · Accession: 0000000000-15-029314
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File numbers found in text: 001-33905
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June 2 , 2015
Via E -Mail
Mr. Roger Smith
Chief Financial Officer
Ur-Energy , Inc.
10758 W Centennial Road, Suite 200
Littleton, Colorado 80127
Re: Ur-Energy , Inc.
Form 10-K for the Fiscal Year ended December 31, 2014
Filed March 2 , 2015
File No. 001-33905
Dear Mr. Smith :
We have reviewed your filing an d have the following comment s. In some of our
comment s, we may ask you to provide us with information so we may better understand your
disclosure.
Please respond to these comments within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond. If you do not believe our
comments apply to your facts and circumstances, please tel l us why in your response.
After reviewing your response to these comments, we may have additional comments.
Form 10 -K for the fiscal year ended December 31, 2014
Our Mineral Properties
Operating Properties page 11
1. In future filings please provide a brief description of your ISL operation including an
overview of your processing operation(s). In your response provide a draft of you r
proposed future disclosure.
2. Please tell us the capacity and utilization of your processing facility and disclose this in
future filings pursuant to the Instructions to Item 102 of Regulation S -K.
3. Please tell us your actual leaching and processing recovery factor(s) and include this
information in future filings.
Roger Smith
Ur-Energy , Inc.
June 2 , 2015
Page 2
Critical Accounting Policies and Estimates, page 60
4. We note the total capitalized costs of $32.97 million that are classified as Lost Creek
enclosures (page 85), and that the estimate life for plant enclosures is 20 years for
depreciation purposes (page 79). Please advise us of the following:
Describe to us the nature of the significant components that are included in the
enclosures line item of your capital assets.
Given that you have not established proven and probable reserves at Lost Creek,
please explain to us why you believ e capitalization of these costs was appropriate and
cite the authoritative literature that you relied upon to support your accounting
treatment. Also explain to us your basis for the 20 year estimate life for the
enclosures.
Finally confirm to us that yo u will expand your disclosure in future filings to clearly
describe your accounting policy for capital assets, including your basis for
capitalization in instances where proven and probable reserves have not been
established. Please provide your proposed future disclosure in your response.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exc hange Act rules require. Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
In responding to our comments, pleas e provide a written statement from the company
acknowledging that:
the company is responsible for the adequacy and accuracy of the disclosure in the filing;
staff comments or changes to disclosure in response to staff comments do not foreclose
the Commis sion from taking any action with respect to the filing; and
the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.
Roger Smith
Ur-Energy , Inc.
June 2 , 2015
Page 3
You may contact Joanna Lam at (202) 551 -3476 or John Archfield at (202) 551 -3315 if
you have questions regarding comments on the financial statements and related matters. Please
contact John Coleman at (202)551 -3610 if you have questions regarding the eng ineering
comments.
Sincerely,
/s/Craig Arakawa for
Tia L. Jenkins
Senior Assistant Chief Accountant
Office of Beverages, Apparel, and
Mining