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	Comments on: Is There A Gold Standard For Estimating Rare-Earth Mineral Resources And Reserves?	</title>
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	<link>https://www.techmetalsresearch.net/is-there-a-gold-standard-for-estimating-rare-earth-mineral-resources-and-reserves/</link>
	<description>Commentary &#38; analysis on rare earths and other technology metals</description>
	<lastBuildDate>Wed, 25 Apr 2012 21:39:38 +0000</lastBuildDate>
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		<title>
		By: Bob Roe		</title>
		<link>https://www.techmetalsresearch.net/is-there-a-gold-standard-for-estimating-rare-earth-mineral-resources-and-reserves/#comment-3059</link>

		<dc:creator><![CDATA[Bob Roe]]></dc:creator>
		<pubDate>Wed, 25 Apr 2012 21:39:38 +0000</pubDate>
		<guid isPermaLink="false">https://www.techmetalsresearch.net/?p=5295#comment-3059</guid>

					<description><![CDATA[Gareth, thanks for highlighting the issue of mineral resources vs mineral reserves. Responses by Don Ranta and others are quite correct.  Most mining professionals (including, I suspect, the individuals at SRK who produced the recent MCP reserves calculations) would disagree that US SEC’s “Guide 7” is the world’s most rigorous standard.  Guide 7 is, in fact, quite ambiguous compared to Canada’s NI 43-101, Australia’s JORC, RSA’s SAMREC and equivalent guidelines, which amongst other differences require endorsement of the reserves/resources estimates by a “competent person(s),” i.e. qualified mining professionals. 

Mountain Pass has likely been drilled out and evaluated to the extent that most of its inventory of “resources” has either been qualified as economic reserves or classified as uneconomic.  Thus, SEC’s non-recognition of resource classifications benefits MCP in comparison to its competitors whose less-advanced projects have not been investigated sufficiently to make the reserves/resources distinction.  An over-simplified explanation of that difference is that “resources” must be adequately drilled (trenched, etc), analyzed for mineral content, geologically and statistically modeled to essentially a positive feasibility status, then integrated into the life-of-mine plan in order to be classified as “reserves.”  However, for mining professionals and investors alike, a project’s resources are also vitally important, since those are the basis for the operation’s future ore reserves, subject to technical and economic parameters. 

Most mining firms, even those based in the US with projects located only in the US, have already adopted NI 43-101 or equivalent standards in their reporting of resources and reserves, including only “reserves” in their required reports to SEC (e.g. 10-K’s) but including both in their other public technical documents.  US professional organizations like SME and MMSA have recognized the inconsistencies in SEC’s guidelines relative to those of other industrialized nations and are actively lobbying SEC to catch up to their international peers.]]></description>
			<content:encoded><![CDATA[<p>Gareth, thanks for highlighting the issue of mineral resources vs mineral reserves. Responses by Don Ranta and others are quite correct.  Most mining professionals (including, I suspect, the individuals at SRK who produced the recent MCP reserves calculations) would disagree that US SEC’s “Guide 7” is the world’s most rigorous standard.  Guide 7 is, in fact, quite ambiguous compared to Canada’s NI 43-101, Australia’s JORC, RSA’s SAMREC and equivalent guidelines, which amongst other differences require endorsement of the reserves/resources estimates by a “competent person(s),” i.e. qualified mining professionals. </p>
<p>Mountain Pass has likely been drilled out and evaluated to the extent that most of its inventory of “resources” has either been qualified as economic reserves or classified as uneconomic.  Thus, SEC’s non-recognition of resource classifications benefits MCP in comparison to its competitors whose less-advanced projects have not been investigated sufficiently to make the reserves/resources distinction.  An over-simplified explanation of that difference is that “resources” must be adequately drilled (trenched, etc), analyzed for mineral content, geologically and statistically modeled to essentially a positive feasibility status, then integrated into the life-of-mine plan in order to be classified as “reserves.”  However, for mining professionals and investors alike, a project’s resources are also vitally important, since those are the basis for the operation’s future ore reserves, subject to technical and economic parameters. </p>
<p>Most mining firms, even those based in the US with projects located only in the US, have already adopted NI 43-101 or equivalent standards in their reporting of resources and reserves, including only “reserves” in their required reports to SEC (e.g. 10-K’s) but including both in their other public technical documents.  US professional organizations like SME and MMSA have recognized the inconsistencies in SEC’s guidelines relative to those of other industrialized nations and are actively lobbying SEC to catch up to their international peers.</p>
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		<title>
		By: Owen Barlow		</title>
		<link>https://www.techmetalsresearch.net/is-there-a-gold-standard-for-estimating-rare-earth-mineral-resources-and-reserves/#comment-3046</link>

		<dc:creator><![CDATA[Owen Barlow]]></dc:creator>
		<pubDate>Sat, 14 Apr 2012 23:14:44 +0000</pubDate>
		<guid isPermaLink="false">https://www.techmetalsresearch.net/?p=5295#comment-3046</guid>

					<description><![CDATA[Jack, what do you think about the short attack on GW?]]></description>
			<content:encoded><![CDATA[<p>Jack, what do you think about the short attack on GW?</p>
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		<title>
		By: Owen Barlow		</title>
		<link>https://www.techmetalsresearch.net/is-there-a-gold-standard-for-estimating-rare-earth-mineral-resources-and-reserves/#comment-3045</link>

		<dc:creator><![CDATA[Owen Barlow]]></dc:creator>
		<pubDate>Sat, 14 Apr 2012 23:13:37 +0000</pubDate>
		<guid isPermaLink="false">https://www.techmetalsresearch.net/?p=5295#comment-3045</guid>

					<description><![CDATA[Jack, what do you think about the short attack on GW?  Owen]]></description>
			<content:encoded><![CDATA[<p>Jack, what do you think about the short attack on GW?  Owen</p>
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		<title>
		By: Owen Barlow		</title>
		<link>https://www.techmetalsresearch.net/is-there-a-gold-standard-for-estimating-rare-earth-mineral-resources-and-reserves/#comment-3044</link>

		<dc:creator><![CDATA[Owen Barlow]]></dc:creator>
		<pubDate>Sat, 14 Apr 2012 23:11:29 +0000</pubDate>
		<guid isPermaLink="false">https://www.techmetalsresearch.net/?p=5295#comment-3044</guid>

					<description><![CDATA[Jack, what do you think about the short attack in GW?]]></description>
			<content:encoded><![CDATA[<p>Jack, what do you think about the short attack in GW?</p>
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		<title>
		By: Veritas Bob		</title>
		<link>https://www.techmetalsresearch.net/is-there-a-gold-standard-for-estimating-rare-earth-mineral-resources-and-reserves/#comment-3025</link>

		<dc:creator><![CDATA[Veritas Bob]]></dc:creator>
		<pubDate>Tue, 10 Apr 2012 22:01:47 +0000</pubDate>
		<guid isPermaLink="false">https://www.techmetalsresearch.net/?p=5295#comment-3025</guid>

					<description><![CDATA[As to Don Ranta&#039;s question in comment 8 about Molyorp&#039;s use of 5% cutoff:  Does this keep down the size of the reserves and thus taxes?]]></description>
			<content:encoded><![CDATA[<p>As to Don Ranta&#8217;s question in comment 8 about Molyorp&#8217;s use of 5% cutoff:  Does this keep down the size of the reserves and thus taxes?</p>
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		<title>
		By: SouthernX		</title>
		<link>https://www.techmetalsresearch.net/is-there-a-gold-standard-for-estimating-rare-earth-mineral-resources-and-reserves/#comment-3023</link>

		<dc:creator><![CDATA[SouthernX]]></dc:creator>
		<pubDate>Tue, 10 Apr 2012 18:35:02 +0000</pubDate>
		<guid isPermaLink="false">https://www.techmetalsresearch.net/?p=5295#comment-3023</guid>

					<description><![CDATA[Great article!

Clear, concise and cogent contrasting of the codes. I sense that in the next few quarters a tipping point will become apparent separating the wheat from the chaff. Continuing the agrarian metaphor, as the frustratingly still low hanging fruits ripen, can you provide your insights on interpreting PEA&#039;s, BFS&#039;s and scoping studies with an eye to: &quot;there&#039;s never been a negative PEA&quot;?

Thank you.]]></description>
			<content:encoded><![CDATA[<p>Great article!</p>
<p>Clear, concise and cogent contrasting of the codes. I sense that in the next few quarters a tipping point will become apparent separating the wheat from the chaff. Continuing the agrarian metaphor, as the frustratingly still low hanging fruits ripen, can you provide your insights on interpreting PEA&#8217;s, BFS&#8217;s and scoping studies with an eye to: &#8220;there&#8217;s never been a negative PEA&#8221;?</p>
<p>Thank you.</p>
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		<title>
		By: Don Ranta		</title>
		<link>https://www.techmetalsresearch.net/is-there-a-gold-standard-for-estimating-rare-earth-mineral-resources-and-reserves/#comment-3022</link>

		<dc:creator><![CDATA[Don Ranta]]></dc:creator>
		<pubDate>Tue, 10 Apr 2012 14:54:58 +0000</pubDate>
		<guid isPermaLink="false">https://www.techmetalsresearch.net/?p=5295#comment-3022</guid>

					<description><![CDATA[Gareth, in my judgment Molycorp is wrong in their emphasis that they use the highest standard. SEC Guide 7 (attached) is essentially the same standard but without allowing the designation of “inferred” resources, so it is a more restrictive standard, not a higher standard. The Guide 7 definitions of Proven (Measured) Reserves and Probable (Indicated) Reserves are essentially the standard industry definitions and the same as JORC or CIM (NI 43-101).  Guide 7 does defer to state law or foreign law and, through general industry practice, has allowed the use of the term “mineralized material” (the SEC does not like the term &quot;resources&quot;), which is often generally the same as “inferred resources”, or, in more advanced projects, can include measured, indicated and inferred resources. Guide 7 is silent on any guidance as to how to define and classify the mineralized material.   NI 43-101 rules guided by the CIM guidelines and definitions are the same as SME guidelines, which only allow proven and probable reserves to be derived from measured and indicated resources (a portion of the mineralized material).  SEC Guide 7 is too limited in scope and the JORC or NI 43-101/CIM rules are definitely more valuable for investors. SME has attempted to influence the SEC to adopt its Guidelines for Estimating Mineral Resources and Reserves, which are essentially the same as JORC and CIM, but maybe because the US mining industry is such a small portion of the US GDP, there has not been any motivation for the SEC to do so. 

Molycorp uses a cutoff grade of 5% TREO, and used a 4% cutoff previously. The cutoff grade is usually the economic cutoff, so it is puzzling that they either cannot or do not report reserves at a lower cutoff grade. Are their recoveries so low or costs so high that the lower grade material below 5% is not economic, or have they not completed adequate metallurgical testing on the lower grade material? These would be logical questions based on SRK&#039;s reserves report.]]></description>
			<content:encoded><![CDATA[<p>Gareth, in my judgment Molycorp is wrong in their emphasis that they use the highest standard. SEC Guide 7 (attached) is essentially the same standard but without allowing the designation of “inferred” resources, so it is a more restrictive standard, not a higher standard. The Guide 7 definitions of Proven (Measured) Reserves and Probable (Indicated) Reserves are essentially the standard industry definitions and the same as JORC or CIM (NI 43-101).  Guide 7 does defer to state law or foreign law and, through general industry practice, has allowed the use of the term “mineralized material” (the SEC does not like the term &#8220;resources&#8221;), which is often generally the same as “inferred resources”, or, in more advanced projects, can include measured, indicated and inferred resources. Guide 7 is silent on any guidance as to how to define and classify the mineralized material.   NI 43-101 rules guided by the CIM guidelines and definitions are the same as SME guidelines, which only allow proven and probable reserves to be derived from measured and indicated resources (a portion of the mineralized material).  SEC Guide 7 is too limited in scope and the JORC or NI 43-101/CIM rules are definitely more valuable for investors. SME has attempted to influence the SEC to adopt its Guidelines for Estimating Mineral Resources and Reserves, which are essentially the same as JORC and CIM, but maybe because the US mining industry is such a small portion of the US GDP, there has not been any motivation for the SEC to do so. </p>
<p>Molycorp uses a cutoff grade of 5% TREO, and used a 4% cutoff previously. The cutoff grade is usually the economic cutoff, so it is puzzling that they either cannot or do not report reserves at a lower cutoff grade. Are their recoveries so low or costs so high that the lower grade material below 5% is not economic, or have they not completed adequate metallurgical testing on the lower grade material? These would be logical questions based on SRK&#8217;s reserves report.</p>
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		<title>
		By: Don Burton		</title>
		<link>https://www.techmetalsresearch.net/is-there-a-gold-standard-for-estimating-rare-earth-mineral-resources-and-reserves/#comment-3020</link>

		<dc:creator><![CDATA[Don Burton]]></dc:creator>
		<pubDate>Tue, 10 Apr 2012 13:39:21 +0000</pubDate>
		<guid isPermaLink="false">https://www.techmetalsresearch.net/?p=5295#comment-3020</guid>

					<description><![CDATA[For me the press release muddled the differentiation between &quot;resources&quot; and &quot;reserves&quot;. I am not familiar with SEC standards but it sounds the same in that inferred resources cannot be converted to any kind of reserve in both systems 43-101 does not allow inferred resource to be converted to reserves. You would have to drill inferred into at least indicated resource to be used in a reserve calculation. 

One cannot compare resources to reserves. Presumably Molycorp has the  rigorous economic studies (feasibility study level) completed to allow the conversion of the additional tonnage into reserves. It would be interesting to understand if their resource base has increased or if they have achieved more reserves by converting existing &quot;inferred&quot; resource into a higher classification (indicated or measured) by more detailed drilling.

I too ponder why they could not be operating at a lower cutoff. It is not misleading to report resources at varying cutoffs and as metal prices change companies can legitimately re-assess reserves if the economics allow it.

Perhaps the greatest difference between reporting in the US versus Canada is the level of disclosure required... not that Molycorp is doing anything wrong in this regard but quite frankly if the securities commissions don&#039;t require you to report more fully then why would you? Focus on production rather than filing reports on Sedar! I do believe the Canadian disclosure requirements serve investors far better in this regard.]]></description>
			<content:encoded><![CDATA[<p>For me the press release muddled the differentiation between &#8220;resources&#8221; and &#8220;reserves&#8221;. I am not familiar with SEC standards but it sounds the same in that inferred resources cannot be converted to any kind of reserve in both systems 43-101 does not allow inferred resource to be converted to reserves. You would have to drill inferred into at least indicated resource to be used in a reserve calculation. </p>
<p>One cannot compare resources to reserves. Presumably Molycorp has the  rigorous economic studies (feasibility study level) completed to allow the conversion of the additional tonnage into reserves. It would be interesting to understand if their resource base has increased or if they have achieved more reserves by converting existing &#8220;inferred&#8221; resource into a higher classification (indicated or measured) by more detailed drilling.</p>
<p>I too ponder why they could not be operating at a lower cutoff. It is not misleading to report resources at varying cutoffs and as metal prices change companies can legitimately re-assess reserves if the economics allow it.</p>
<p>Perhaps the greatest difference between reporting in the US versus Canada is the level of disclosure required&#8230; not that Molycorp is doing anything wrong in this regard but quite frankly if the securities commissions don&#8217;t require you to report more fully then why would you? Focus on production rather than filing reports on Sedar! I do believe the Canadian disclosure requirements serve investors far better in this regard.</p>
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		<title>
		By: blackjack		</title>
		<link>https://www.techmetalsresearch.net/is-there-a-gold-standard-for-estimating-rare-earth-mineral-resources-and-reserves/#comment-3019</link>

		<dc:creator><![CDATA[blackjack]]></dc:creator>
		<pubDate>Tue, 10 Apr 2012 04:30:46 +0000</pubDate>
		<guid isPermaLink="false">https://www.techmetalsresearch.net/?p=5295#comment-3019</guid>

					<description><![CDATA[What is it with the USA?

They always want it their way.

Their standards.

Then force companies to adopt their ways and their systems.

Frankly, from Moly I would not listen. They always seem to be looking for the edge. Why not just get on with it and produce REE&#039;s and stop all the chest beating. LIKE China does!]]></description>
			<content:encoded><![CDATA[<p>What is it with the USA?</p>
<p>They always want it their way.</p>
<p>Their standards.</p>
<p>Then force companies to adopt their ways and their systems.</p>
<p>Frankly, from Moly I would not listen. They always seem to be looking for the edge. Why not just get on with it and produce REE&#8217;s and stop all the chest beating. LIKE China does!</p>
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		<title>
		By: Gareth Hatch		</title>
		<link>https://www.techmetalsresearch.net/is-there-a-gold-standard-for-estimating-rare-earth-mineral-resources-and-reserves/#comment-3018</link>

		<dc:creator><![CDATA[Gareth Hatch]]></dc:creator>
		<pubDate>Tue, 10 Apr 2012 03:56:53 +0000</pubDate>
		<guid isPermaLink="false">https://www.techmetalsresearch.net/?p=5295#comment-3018</guid>

					<description><![CDATA[@G H: on your questions:

1) Increases in mineral-reserve estimates are of direct value, by the very nature of what a mineral reserve actually represents, compared to, say, a similar increase in a mineral-resource estimate, which only has indirect value. A mineral resource gives no indication of the economic viability of the deposit - only a mineral-reserve estimate can do that.

I think the only thing that surprises me about the reserve update from Molycorp is that they (or their consultants SRK) have maintained the same, relatively high cut-off grade as in the past. Given current technology, and the present value of rare earths, I might have expected them to lower the cut-off grade, which would probably have given them even higher reserves.

Mark Smith, Molycorp&#039;s President &#038; CEO, does however make a powerful point in the press release when he said that &quot;&lt;em&gt;[i]t is noteworthy that the cutoff grade of 5% used by SRK far exceeds the head-grades of most other known rare earth projects around the world, which underscores the unique richness of our ore body&lt;/em&gt;&quot;. Mountain Pass is indeed a rich ore body.

One other comment on this: it is my understanding that companies may be taxed on their reserves, since they may be considered as real, tangible assets, so companies won&#039;t want to get too carried away with upgrading resources to reserves.

2) You&#039;re right of course, that it is to be expected for an NYSE-traded company to be measuring reserves to SEC standards. But if the intent was to &quot;&lt;em&gt;provide a simple comparison&lt;/em&gt;&quot;, then clearly such a comparison fails, for the reasons stated above.

If the news release had simply referred to the fact that the vast majority of other leading projects have mineral-resource estimates only, and don&#039;t have estimates of mineral reserves, then we wouldn&#039;t be having this conversation.  Such statements would be factually correct, and would demonstrate, as I commented earlier, just how well-established Mountain Pass is in comparison to other non-Chinese rare-earth projects.]]></description>
			<content:encoded><![CDATA[<p>@G H: on your questions:</p>
<p>1) Increases in mineral-reserve estimates are of direct value, by the very nature of what a mineral reserve actually represents, compared to, say, a similar increase in a mineral-resource estimate, which only has indirect value. A mineral resource gives no indication of the economic viability of the deposit &#8211; only a mineral-reserve estimate can do that.</p>
<p>I think the only thing that surprises me about the reserve update from Molycorp is that they (or their consultants SRK) have maintained the same, relatively high cut-off grade as in the past. Given current technology, and the present value of rare earths, I might have expected them to lower the cut-off grade, which would probably have given them even higher reserves.</p>
<p>Mark Smith, Molycorp&#8217;s President &amp; CEO, does however make a powerful point in the press release when he said that &#8220;<em>[i]t is noteworthy that the cutoff grade of 5% used by SRK far exceeds the head-grades of most other known rare earth projects around the world, which underscores the unique richness of our ore body</em>&#8220;. Mountain Pass is indeed a rich ore body.</p>
<p>One other comment on this: it is my understanding that companies may be taxed on their reserves, since they may be considered as real, tangible assets, so companies won&#8217;t want to get too carried away with upgrading resources to reserves.</p>
<p>2) You&#8217;re right of course, that it is to be expected for an NYSE-traded company to be measuring reserves to SEC standards. But if the intent was to &#8220;<em>provide a simple comparison</em>&#8220;, then clearly such a comparison fails, for the reasons stated above.</p>
<p>If the news release had simply referred to the fact that the vast majority of other leading projects have mineral-resource estimates only, and don&#8217;t have estimates of mineral reserves, then we wouldn&#8217;t be having this conversation.  Such statements would be factually correct, and would demonstrate, as I commented earlier, just how well-established Mountain Pass is in comparison to other non-Chinese rare-earth projects.</p>
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