Compared to the other price decks that have been used in the past couple of years, these are indeed conservative numbers. In absolute terms? You raise a valid question with respect to the future pricing for exported materials, given that the tariffs on Chinese material will come off. However, China is already talking about adding a new resource tax across the board (domestic and FOB materials), which would bring prices (all else being equal) to somewhere between current FOB and internal China prices. That’s just for starters.

As for the 52% reduction, I can assure you, having looked through the most recent PEA / PFS / FS report for every project on the TMR Index within the last couple of weeks, that this is a significantly more robust threshold that many if not most of the HREE projects under development. Some (which I won’t name here) would have negative NPV with just a 20% decline in the price decks that they have used, which are multiples of current pricing… meaning many of those “other non-China Y and Dy mines” to which you allude, will not be opening any time soon.

As for your last statement concerning Dr. Pingitore, my original comments stand on their own merits. To my knowledge there is nothing untoward going on here, despite your curious attempt to imply otherwise.

As for the project economics, for the sake of argument, let’s give the benefit of the doubt on capital and operating costs and oxide recovery rates. The article notes that “these numbers use a conservative REO price deck that is based on current spot prices for these materials, instead of the rather optimistic prices that most REE project-development companies have used in the past couple of years.” The “conservative” REO price deck appears to be based on FOB prices from Fall 2013. FOB prices have come down significantly since then, but more seriously, how conservative is it to use FOB prices given the WTO rare earth ruling, with the very real possibility that FOB prices could go down to China domestic prices by the time this project starts producing? China domestic prices for Yttrium Oxide and Dysprosium Oxide are about 65% and 30% respectively below the prices used in the IRR calculation. As stated in the PEA, a 52% reduction in the price deck prices is enough to neutralize the IRR. And what if any other non-China Y and Dy mines open, what then with Y and Dy prices? So maybe the project economics are not quite such a sure thing. Even if the price deck is not as optimistic as those used for competitor projects, that does not mean that it is conservative in any absolute sense.

As for the statement “Dr. Pingitore does not receive a salary or other direct or indirect financial benefit in this arrangement”, the article also notes “Dr. Pingitore is also a director of TRER.”, so it would seem he does have a financial benefit in the overall relationship he has with TRER.

As for water management – once the elements of interest have been removed from the solution, and the Al, Fe and other elements have been precipitated, the remaining water will be run through a reverse-osmosis unit and then returned to the leach circuit. So this will pretty much be be a closed-loop system – there will be no discharge. About 10% of the water, carrying mostly Na, K and other minor elements will be bled off into evaporation ponds. The company indicates that there may be by-produce potential for these elements, but that has yet to be determined.

Per the recent PEA for Round Top, the project will be evaluated by appropriate regulatory bodies, including the Texas Commission on Environmental Quality (TCEQ) and the EPA and others. Table 1-4 on page 10 of the PEA technical details the various permits required, and the agencies that would issue them.

I should also mention that Mr. Gorski told me that there are no clays in the rhyolite rock and when crushed, it produced few fines, meaning that there will be good permeability in the heap. He also mentioned that the rhyolite will drain down to 6.5% moisture which is very low for a heap operation.

Mr. Gorski further mentioned that there is also a very small ‘slump factor’ and the acid will not be reacting with any of the ‘framework’ minerals, unlike, for example gold and copper heaps. The main drawback in gold heaps is that they are generally altered rock with poor permeability and subject to channeling; they normally have to be agglomerated to maintain permeability. Copper heaps are very large and usually are waste rock, and are usually not designed for high efficiency.

Concerning the hydrofluoric acid question – my understanding is that the fluorine contained in the fluoride minerals will form a complex with the aluminum that is present (in excess) during the leaching process, so the formation of hydrofluoric acid is not going to be an issue.

As for the problems in southern China – the key issue there the in-situ nature of the leaching, surely, not the leaching itself. The plan for Round Top involves moving mined ore a short distance down the mountain via conveyor, to self-contained leach pads, where all residues will be collected and presumably handled appropriately.

I would be interested in seeing a copy of the paper that you mentioned, thanks.