Subject: File No. S7-10-16
From: Michael Moats, Ph.D.
Affiliation: Associate Professor of Metallurgical Engineering, Missouri ST

August 31, 2016

I believe that the Instruction 1 to paragraph (b)(96)(iv)(B)(16) and Instruction 2 to paragraph (b)(96)(iv)(B)(16) need further clarification (see excerpts later in comment).

The term "successfully extract" is technically vague. Is there a particular scale at which the extraction was successful? Does successful indicate economically profitable or technically demonstrated?

It would seem these words should be replaced with "commercially" or "in production". Further clarification is warranted to clarify if demonstration plants or pilot plant operations can be used to warrant a process method as "successful".

"Instruction 1 to paragraph (b)(96)(iv)(B)(16): If the processing method, plant design or other parameters have never been used to successfully extract the valuable product from such mineralization, the qualified person must so state and provide a justification for why he or she believes the approach will be successful in this instance."

"Instruction 2 to paragraph (b)(96)(iv)(B)(16): If the processing method, plant design or other parameters have never been used to successfully extract the valuable product from such mineralization and is still under development, then no mineral resources or reserves can be disclosed on the basis of that method."