June 20, 2016
I fully support the concept of requiring a, "qualified person" to author the technical report providing the necessary methodology and detail for mineral resource and reserve estimates. It is essential that these technical reports be made public in a similar manner to the NI43-101 reports in Canada which are available on www.sedar.com.
I am concerned about the manner by which a person is designated "qualified". Unfortunately, using the qualifications of the State Boards of Professional Engineering is inadequate and should not be approved. For two reasons, the Professional Engineering exams include little or no meaningful questions on mineral resource and reserve estimation, so a person can become a Professional Engineer knowing nothing about the subject. The state boards rarely if ever have any board member who knows anything about the topic of mineral resource and reserve estimation, therefore, they are in no position nor are capable of deciding on any unethical or incompetent practice by a person who became "qualified' through their Professional Engineer process.