A Visit To The Texas Rare Earth Resources Round Top Project

by Gareth Hatch on May 19, 2014 · 12 comments

in Rare Earths, Site Visits, USA

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Earlier this month I had the opportunity to visit Round Top, the rare-earth-element (REE) project being developed by Texas Rare Earth Resources Corp. (OTCQX:TRER). While in the Lone Star State I also paid a visit to the University of Texas at El Paso (UTEP), where much of the processing and analysis work on the project has been undertaken.

The project is located in Hudspeth County in the far west of Texas, USA, approximately 85 miles southeast of the city of El Paso. The nearest town is Sierra Blanca, 8 miles to the southeast of the deposit, with a population of around 560 people and where Texas Rare Earth Resources (TRER) has an office. The border with Mexico is nearby, some 10 miles to the south.

Round Top is one of five peaks that make up the Sierra Blanca range, the others being Triple Hill, Sierra Blanca Peak, Little Blanca and Little Round Top. According to TRER’s most recent Preliminary Economic Assessment (PEA) report (published in December 2013), these peaks are rhyolite laccoliths – intrusions of magma that have welled up between layers of Cretaceous sedimentary rock to formed domed structures. The topmost layer of sedimentary rock has eroded over time, resulting in the present exposed rhyolite formations.

The deposit is just 3 miles north of I-10, the interstate highway that starts in Santa Monica, California in the west and which finishes in Jacksonville, Florida in the east, passing through El Paso, San Antonio and Houston in Texas along the way. Round Top is therefore highly accessible by road. Sierra Blanca sits at the intersection of two branches of the Union Pacific railroad. There is an active rail spur that terminates less than three miles from the base of Round Top Mountain, serving a local company, RCL Rock, which mines an average of 6,000 t / day of similar rhyolite for railroad ballast.

My hosts for the visit were Dan Gorski, CEO and director of TRER, and Tony Marchese, chairman of the company’s board of directors.

Round Top is more than a mile across at its base, with a peak approximately 300 m (1,000 feet) above the desert plateau, which is itself approximately 1,300 – 1,400 m (4,270 – 4,600 feet) above sea level.

As part of the recent PEA report, TRER published an updated NI 43-101 compliant mineral-resource estimate for Round Top. The deposit contains an estimated 231.0 Mt of rare-earth mineral resources at the Measured level, with an average grade of 0.06 wt% total rare-earth oxide (TREO), 298.0 Mt of resources at the Indicated level, with an average grade of 0.06% TREO, and an estimated 377.0 Mt of resources at the Inferred level, with an average grade of 0.06% TREO. Each of these estimates used a cut-off grade of 0.0428% yttrium (Y).

You can see photos taken during my visit, below – just click on the thumbnails to see the full images.



In total there are an estimated 573 kt of TREOs in the Round Top deposit, with an average heavy REO (HREO) distribution of 72% of the TREOs present. In addition to the presence of REEs, the project is of interest for by-products of beryllium (Be), lithium (Li), niobium (Nb), tantalum (Ta) and uranium (U).

The first (and an admittedly blunt) question that I asked Mr. Gorski concerned the grade of the deposit. Given the low concentration of REEs at Round Top, compared to other deposits, how could future production hope to be economic – despite the proximity to infrastructure and a large pool of labor? Mr. Gorski explained that despite that relatively low grade, the distribution of the main REE-bearing mineral variety yttrofluorite was highly uniform across the deposit. Furthermore, tests at UTEP had conclusively determined that the rhyolite host rock was highly amenable to leaching, despite the fine-grained nature of the rock.

Mr. Gorski explained that once mined, the material at Round Top would be crushed into pellets, approximately 6-13 mm (0.25-0.5 inches) in diameter, before being placed onto leach pads. The pellets would then be treated with an 8 vol% dilute solution of sulfuric acid in water, which after having time to percolate through the pellet heaps, would leach the REEs and other metals of interest into solution. A series of tests at UTEP on the process achieved recoveries of over 90% of the yttrium (Y), dysprosium (Dy) and other HREEs present via this leaching process. These tests were confirmed in independent contract laboratories.

This amenability to leaching would eliminate the need for a flotation processing step, considered by a previous incarnation of the TRER management team in the initial PEA for Round Top, which was published in June 2012. Mr. Marchese commented that the updated PEA saw a dramatic drop in the estimated initial capital expenditures (capex) for the project from $2.1B to $292M, and sustaining capital from $860M to $553M. The PEA determined a pre-tax Net Present Value of $1.4B at a 10% discount, and an IRR of 67%. I note 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.

Unit operating expenditures would be similar ($14.59 / t mined rock in the initial PEA compared to $15.16 / t mined rock in the updated PEA), despite a reduction in throughput from 80,000 t / day to 20,000 t / day of mined rock. TRER plans to produce approximately 3,200 t / year of separated REOs, with an anticipated initial mine life of 20 years. The proposed pit would focus on the northwest portion of Round Top, with rock sent to the leach pads located north of the deposit, via conveyor. This constitutes approximately 18% of the overall mineral resource, giving the project a potentially long life beyond the initial plan.

90-95% of the rock consists of the minerals quartz and feldspar, which do not react to the leaching solution. The remaining 5-10% of the rock consists of fluorites fluorides such as yttrofluorite and cryolite. Urananite, thorite and coffinite are also present, which contain thorium (Th) and uranium (U). In the rock as a whole Th levels are approximately 179 ppm and U levels are approximately 45 ppm. The rock also contains Li-rich mica, and there is evidence of Be too, though it has yet to be determined just where in the mineral assemblage this element is located. Other accessory minerals include columbite (containing Nb and Ta) and zircon (containing zirconium and hafnium).

The iron (Fe)-bearing mineral magnetite is also present in the rhyolite rock, with some of this mineral having been altered over time to form hematite, giving some of the rhyolite a pink-red color. Hydrothermal or groundwater alteration gives other sections of the rhyolite a tan to brown color.



Once leached, the pregnant solution would be subject to a multi-stage process to remove undesirable elements such as Fe and aluminum, before being subject to solvent extraction (SX) as a means of separating and purifying the concentrate, resulting in individual REOs. According to the PEA, overall recoveries of the REEs after heap leaching, separation and purification include 80% for Y and 76% for Dy. There is little detail in the PEA about the SX processes proposed for the operation, and TRER did not get into much detail on the process, though I was told that the costs of the associated SX facility (approximately $93M) are included in the overall capex estimate.

The first documented exploration in the vicinity of Round Top took place in the 1970s, when fluorite fluoride deposits and Be mineralization where identified near to Sierra Blanca Peak. In the 1980s Cabot Corporation and Cyprus Metals initiated exploration for Be at Round Top, Sierra Blanca Peak and Little Round Top. At this point the Texas Bureau of Economic Geology conducted its own extensive exploration of the Round Top area and vicinity. Associated studies in 1987, 1988 and 1990 identified REE mineralization for the first time, at Round Top.

In 2007, the predecessor to TRER, Standard Silver Corporation, acquired prospecting permits from the GLO and discovered large numbers of documented drill samples in an exploratory decline into Round Top, created by Cyprus Metals during their previous work. These samples were re-logged and analyzed as part of the most recent PEA for Round Top. Subsequent drill programs by TRER commenced in 2010. The core samples are currently stored in a large warehouse building in the vicinity of Round Top; we did not visit the building or examine core samples during the visit.

The Round Top deposit is located on land owned by the state of Texas. In 2011, TRER entered into renewable 19-year leases with the state General Land Office (GLO) totaling some 380 ha (950 acres) of land including Round Top and the vicinity. The associated mineral leases come with a statutory 6.25% royalty to the GLO, on the gross profits of all minerals that are commercially produced at the site. In addition, TRER owns the surface lease to approximately 22,300 ha (55,000 acres) of land around Round Top, and also holds more than a dozen prospecting permits on land elsewhere in Hudspeth County, covering approximately 2,900 ha (7,100 acres).

Close to the base of Round Top, on land accessible to TRER are abundant quantities of Del Rio clays, and Finlay limestone. Mr. Gorski explained that the former will be highly suitable for the production of the heap leach pads at Round Top; the latter will be suitable for neutralizing the acids used, once the leaching process has been completed. Their proximity will save significant costs in terms of the purchase and transportation of such materials, to the future project site.

TRER works closely with Nicholas Pingitore at the Department of Geological Sciences at UTEP, located 90 minutes northwest of Round Top. Dr. Pingitore is a professor in the department, focusing on analytical geochemistry and is Director of the Electron Microprobe Laboratory at UTEP. Dr. Pingitore is also a director of TRER. We paid a visit to his laboratory at UTEP, where he and his researchers have been working on various aspects of the Round Top deposit, and its amenability to processing.



Dr. Pingitore does a nice demonstration of just how permeable the rhyolite rock is, and thus amenable to leaching. Taking samples of the rhyolite that have been sectioned into different thicknesses, he adds a couple of drops of blue ink to the top surface. Within minutes, the ink appears on the other side of the section, with little expansion of the original diameter of the drops applied on the initial side. In other words, the ink penetrates “straight down” with gravity, to the other side, relatively quickly.

Dr. Pingitore noted that the minerals of interest in the rhyolite are very soluble, and that there is enough porosity (typically 3-5%) to allow aqueous solutions to soak through the rock with ease – but not so much porosity that it would do so too quickly, without dissolving the minerals of interest. The work now focuses on obtaining an optimum pellet size for the heap leaching process. I asked him what the rate-determining step or steps would be for the leaching process. He indicated that the key was how fast fresh acid diffuses through the thin films of leach solution that permeate and soak the rock particles, and thus dissolve more and more of the microscopic yttrofluorite grains. Likewise, diffusion of the liberated REEs in the opposite direction, out of the rock particles via those liquid films, also limits the rate at which the overall heap leaching proceeds.

Given the rather unusual composition of the rhyolite rock at Round Top, Dr. Pingitore conducted experiments at the Stanford Synchrotron Radiation Lightsource, part of the Stanford Linear Accelerator in California, to determine which mineral or minerals host the Y and other HREEs. By probing the atomic structure surrounding the Y in bulk samples of the rhyolite, with powerful synchrotron-generated x-rays, Dr. Pingitore said that it became evident that essentially all of the Y, and by proxy the HREEs, is hosted in yttrofluorite, substituting for some of the normal calcium atoms. Dr. Pingitore and Mr. Gorski were co-authors of a paper that detailed this characterization work, in addition to the leaching experiments on the Round Top rhyolite, published in the Chinese Society of Rare Earth’s Journal of Rare Earths in January 2014.

The laboratory at UTEP houses the usual high-end analytical equipment, including an inductively coupled mass spectrometer (ICP-MS) capable of detecting metals in solution to 1 part per trillion or better. It also houses an X-ray fluorescence (XRF) analyzer, for testing solid samples. The latter is particularly useful for quantitative leach testing; XRF analysis is conducted on powders ground and pressed into pucks, from rhyolite pellets that were crushed to various sizes and then subject to different leaching regimens. The XRF profile for each sample is compared to the untreated base case; the XRF curves for each sample can be superimposed on the base case and where REEs and other metals have been removed via leaching, this shows as reduced (or eliminated) XRF peaks for the specific element in question. These peaks are proportional to the quantity of individual elements present. This method is a simple but reliable method of quickly determining the effectiveness of the various leaching parameters used (see the images below for more detail).

Under a joint UTEP-TRER research contract, TRER provides funds for supplies, equipment usage, support personnel and the like for the laboratory investigations. Dr. Pingitore does not receive a salary or other direct or indirect financial benefit in this arrangement, and TRER confirms significant findings at one or more contract laboratories.

In addition to the geochemistry of the rhyolite rock, Dr. Pingitore has also looked at the compositional data from all of the samples taken during previous drilling campaigns at Round Top, and plotted them against depth (see the images below for more detail). By using the primary data points, rather than statistics derived from them, one can quickly see that there is little geographic variation of concentration of the individual REEs in the deposit – i.e. little variation from one drill hole to another. There is also no trend with depth, either; these plots indicate that there is consistent grade of REEs from the top to the bottom of the Round Top deposit, making it unusually uniform in distribution.



At over 4,570 square miles in area, Hudspeth County is larger than the states of Delaware and Rhode Island combined, yet has a total population of only 3,500 people per the last census. During my visit I chatted with Laura Lynch, Executive VP for External Affairs at TRER and a director of the company, about the potential impact of the Round Top project on the local community.

Ms. Lynch pointed out that the county is the poorest and sparsest populated in Texas, with a median income in the country of approximately $13-15k / year. Compare this to the median salary of approximately $50k / year that TRER anticipates will be paid to employees of the future Round Top operation. Ms. Lynch commented that these jobs (up to 150 in total) are just one reason why TRER has received very significant local support to date. Mr. Gorski further commented that wherever possible they plan to hire local people for the project, such as the folks at RCL Rock, or people currently living in the town of Sierra Blanca.

As a local land owner and as someone raised on a ranch herself, Ms. Lynch said that children in these rural areas learn a wide range of mechanical and other practical skills as they grow up, which could be put to good use at the Round Top operation. Other local landowners have commented that they welcome the development of Round Top as a means of potentially attracting their children and grandchildren to return back to the area, having had to leave for other places to find work. Having their family back in the area increases the chances of the ranches staying in the respective families in the future. This is of course a natural desire for the current land owners, who wish to leave a legacy to future generations of their families, with these properties being managed and operated tomorrow, in the same traditional ways as they are today.

Ms. Lynch commented that the 6.25% royalty on GLO mineral leases is used to fund the public school system in Texas. The anticipated $500M in royalties that this represents from Round Top, over the initial 20-year life of the mine, effectively gives the state of Texas a vested interest in the success of the Round Top project. The ongoing collaborative work at UTEP may grow and become even more significant as the project progresses, too. There is strong support for TRER’s endeavors elsewhere in El Paso outside of UTEP too. During my time in El Paso we had the opportunity to meet Robert Wingo, a local El Paso businessman, entrepreneur and UTEP alumnus who recently joined TRER’s Advisory Board to help the company work more closely with the El Paso business community.

Mr. Marchese noted that as a result of the Round Top deposit being on state (not Federal) land, the route to permit approvals for the project has the potential to be more straightforward, than if the company had to deal with Federal Bureau of Land Management or US Forestry Service land.

As the name of the company implies, TRER is very much a Texas company, focused on developing a Texas resource to the benefit of its shareholders, as well as the local and regional community. A key step for the company was teaming up with UTEP as this has helped them to advance the leaching work significantly. The company continues to work with third parties such as RDI, Gustavson Associates and Lyntek in Denver on the specific design of the scaled-up leach processes, as well as to optimize the extraction and purification process for the pregnant leach solution, once produced. Obviously the most critical question for the company is whether or not they can do that heap-leach process in a cost-effective and environmentally sustainable manner. All indications are that they are on the right path to figuring that out.

During a conversation with Mr. Marchese, he commented that one of TRER’s biggest challenges is getting people past the idea that just because a REE project based on rhyolite has not been commercialized before, does not mean that it can’t be done in the future. I have to agree with him on this point. At the end of the day each project has its own unique characteristics, and will ultimately live or die on its own merits or shortcomings. The HREE industry in southern China has clearly demonstrated that low grade is not necessarily an impediment to economic production, if the processes used to extract the REEs are simple and cost effective. If you can produce a range of products for less than the market is willing to pay for them, you have yourself a business. It will be for TRER to demonstrate that it do just that, and I for one will be most interested to see how they do.

My thanks go to Mr. Marchese and Mr. Gorski and their colleagues at Texas Rare Earth Resources Corp., for facilitating the visits to Round Top Mountain and to the University of Texas at El Paso.

Disclosure: at the time of writing, Gareth Hatch is neither a shareholder of, nor a consultant to, Texas Rare Earth Resources Corp. (TRER). TMR’s Jack Lifton is a director of TRER. Neither Gareth nor Jack received compensation from TRER or from anyone else, in return for the writing of this article.

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1 John Tumazos May 19, 2014 at 4:44 pm

Gareth,
Thank you for your commentary on a legitimate rare earth company based in the USA. Your writeup was conservative, and did not state that 25% of the US $293 mm cap ex budget was contingency and 10% of the $14/tonne op ex budget also is contingency. Further, you did not state that the 69% pretax IRR (you wrote 67% but it is 69%) excludes 82% of the resource tonnages and excludes Lithium, Beryllium, Uranium and another other non-REE revenues that may increase the pretax IRR closer to 80%-100%.
Hopefully legitimate companies like TRER rebuild the credibility of REE sectors. You dwelt on TREO grades, which is in my opinion a worthless statistic that fails to differentiate between the “three easies” Ce, La and Nd and the truly scarce heavy REE that sell for many times higher prices.
Faithfully,
John Tumazos

2 Wolfgang Hampel May 19, 2014 at 4:51 pm

Gareth,
Many thanks for this report on TRER’s REE deposit, their project certainly is very much different from all the others “out there”. One correction, one question and one comment:
– you mention yttrofluorite and cryolite as “fluorites”, mineralogically/chemically speaking they are halides or fluorides, not fluorites; the latter is just the mineral fluorite CaF2;
– the process of leaching the yttrofluorite with diluted sulfuric acid, wouldn’t that produce enormous amounts of hydrofluoric acid, one of the nastiest acids in general?
– You say “The HREE industry in southern China has clearly demonstrated that low grade is not necessarily an impediment to economic production, if the processes used to extract the REEs are simple and cost effective.” I assume you are talking about the REE bearing ion adsorption clays of Southern China. It is undoubtedly true that the Chinese produce HREE from very low grade clays at very low costs. However, the only reason they may do so is simply because they don’t clean up the mess they’ve caused. The Chinese themselves (!) reckon that the costs of renaturation would be higher than the total value of extracted rare earths. Some further reading on the effects and costs of ionic clay mining in China is given here: http://www.sciencedirect.com/science/article/pii/S2211464513000316 , I’d be happy to send you the article if you wish.
Ionic clay occurrences are actually quite easy to be found but their economic viability is an entirely different story.
Kind regards,
Wolfgang

3 zac May 19, 2014 at 5:51 pm

What about water? It sounds like they’ll need quite a bit of it.

4 Richard W. Morris May 19, 2014 at 7:29 pm

The article mentioned that core samples were stored near Round Top Mountain. Coring represents less than 10% of the drilling. The rest (+90%) of the drilling was by reverse circulation. Coring was not effective because of water loss during drilling.

5 Gareth Hatch May 20, 2014 at 4:40 pm

@John Tumazos: per the latest edition of the PEA report (April 28, 2014), the pre-tax 10% NPV is $1.43 billion compared to $1.47 billion in the original report, the IRR is 67% compared to 69%, and there is a pre-tax cash flow of $4.22 billion compared to $4.35 billion in the original report. I did note that the planned mine production constitutes approximately 18% of the overall mineral resource. Since the byproducts were not considered in the PEA, they were (rightly) not considered, monetarily, above. As for which are the important REEs – I’ll leave that debate for another time :-)

6 Gareth Hatch May 20, 2014 at 4:48 pm

@Wolfgang Hampel: thanks for the correction on fluorides vs fluorites – I will make the correction above.

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.

7 Gareth Hatch May 20, 2014 at 5:02 pm

@zac: checking my notes, I see that the company’s water-development plan would utilize five existing wells in the area. TRER estimates that they will need around 500 gallons / minute of water for dust suppression and other non-process needs; one of the wells in the vicinity of Round Top was apparently reported to be able to produce 900 gallons / minute, with another approximately 450 gallon / minute. As I understand it, water should not be a problem. Part of the optimization work for the heap leaving will be to engineer the process to be effective at lower flow rates.

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.

8 Gareth Hatch May 20, 2014 at 8:03 pm

@Richard W. Morris: thanks for the comments, and clarification. In addition to the core samples, I can confirm (after checking with the folks at TRER) that all samples taken from Round Top, including reverse circulation samples, are stored in that warehouse also.

9 Chris Taylor May 20, 2014 at 10:35 pm

Mr Hatch,
Thanks for this article. It is nice to see the doors open wide on this project. I don’t know if you have been out in west Texas when the winds blow. It can get down right nasty. The UTEP geology dept has graphs on their wall showing dust plumes reaching south east Canada before they fall to earth.
Does TRER have a dust control plan?? Or are they like the oil companies all over west TEXAS and southeast New Mexico that don’t give a damn.
Also where is the leach water go after it’s useful life. I guess TCEQ and the EPA will be asking these questions. Did You?
Chris

10 Gareth Hatch May 21, 2014 at 8:49 am

@Chris Taylor: TRER indicates that crushing the rock will not generate much dust because of the physical nature of the material. In addition, per standard procedure the crushing units will be misted with water to minimize dust generation. Roads will be sprinkled with water, too, and of course the heaps themselves will be wet, which further minimizes any dust. There will be no tailings pond, which can apparently be a source of dust problems in other operations.

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.

11 Veritas Bob May 26, 2014 at 7:29 pm

The not very independent Mr. Tumazos states ‘You dwelt on TREO grades, which is in my opinion a worthless statistic that fails to differentiate between the “three easies” Ce, La and Nd and the truly scarce heavy REE that sell for many times higher prices. ‘ Well, Y sells for much less than Nd, so that leaves the project with Dy to do the heavy hitting.

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.

12 Gareth Hatch May 27, 2014 at 9:54 pm

@Veritas Bob: Who is claiming that the project economics are “a sure thing”?

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.

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