October 5, 2005

KATIE SWEENEY General Counsel

December 18, 2015

The Honorable Neil Kornze Director U.S. Bureau of Land Management 1849 C Street NW Washington, DC 20240

Re: Notice of Proposed Withdrawal; Sagebrush Focal Areas; Idaho, Montana, Nevada, Oregon, Utah, and Wyoming and Notice of Intent To Prepare an Environmental Impact Statement, 80 Fed. Reg. 57635 (September 24, 2015); Docket ID 2015-24212

Dear Director Kornze:

The National Mining Association (NMA) submits the following comments on the Bureau of Land Management’s (BLM) proposed withdrawal application for the withdrawal of 10 million acres of public and National Forest System (NFS) lands identified as “Sagebrush Focal Areas” in Idaho, Montana, Nevada, Oregon, Utah, and Wyoming, from location and entry under the United States mining laws as well as scoping comments to be analyzed in the associated draft environmental impact statement (EIS). NMA is a national trade association that includes the producers of most of the nation’s coal, metals, industrial and agricultural minerals; the manufacturers of mining and mineral processing machinery, equipment and supplies; and the engineering and consulting firms, financial institutions and other firms serving the mining industry. NMA’s members conduct mineral exploration and development in each region targeted for mineral withdrawal and would thereby be directly affected by the proposed withdrawal.

Additionally, NMA has participated in every stage of the land use planning process for conservation of Greater Sage Grouse (sage grouse) and its habitat, including filing comments on the BLM and U.S. Forest Service (FS) draft land use plan amendments and environmental impacts statements published January 29, 2014, and protests of the BLM/FS Nevada and Northeastern California, Utah, and Idaho and Southwestern

National Mining Association 101 Constitution Avenue, NW | Suite 500 East | Washington, DC 20001 | (202) 463-2600

Director Kornze December 23, 2015 Page Two

Montana Proposed Land Use Plan Amendments and Final Environmental Impact Statements which recommended the mineral withdrawals that are the subject of the current rulemaking and these comments.

I. Introduction

The restrictions included in the BLM and FS land use plan amendments, as well as the withdrawal recommendation, were instrumental in the U.S. Fish and Wildlife Services’ (FWS) Sept. 2015 conclusion that that listing of the sage grouse as endangered under the Endangered Species Act (ESA) was not warranted. The decision also rested on the unprecedented number of federal, state, local and private conservation efforts, including those voluntarily taken by the mining industry. Not only have mining companies entered into sage grouse conservation agreements1 and conducted award-winning habitat restoration2, their active management of mine sites has routinely resulted in improved habitat.

NMA opposes the proposed withdrawal of these lands from new mining claims. The withdrawal would be the largest ever in the history of the Federal Land Policy and Management Act (FLPMA). New mining operations are already either restricted or banned on more than half of all federally owned public lands. Given the vast amount of federal lands already closed to mining operations, caution should be exercised when determining whether additional lands should be withdrawn.

II. The Mineral Withdrawal is not Necessary to Conserve Sage Grouse or their Habitat

a. Wildfire and Invasive Species are Primary Threats

As a threshold matter, BLM has failed to demonstrate that the withdrawal of 10 million acres from location and entry under the general mining laws is necessary or even recognizably beneficial to achieve the stated objective of conserving the sage grouse and its habitat. It is undisputed that wildfire and invasive species are the primary threats to sage grouse throughout its range. BLM summarized the impacts of these threats in its Record of Decision (ROD) approving the Resource Management Plan Amendments, stating; “The primary threats [to sage grouse] are the widespread present and potential impacts of wildfire, the loss of native habitat to invasive species, and conifer

1 See e.g., DOI March 26, 2015 Press Release: Interior Department, Barrick Gold of North America & The Nature Conservancy Announce Partnership to Protect Sagebrush Habitat (available at https://www.doi.gov/news/pressreleases/interior-department-barrick-gold-of-north-america-and-the-nature- conservancy-announce-partnership-to-protect-sagebrush-habitat.) 2 See e.g., BLM Nov. 9 Press Release: BLM Announces Reclamation and Sustainable Mineral Development Award Winners (available at http://www.blm.gov/wo/st/en/info/newsroom/2015/november/nr_11_09_2015.html)

National Mining Association 101 Constitution Avenue, NW | Suite 500 East | Washington, DC 20001 | (202) 463-2600

Director Kornze December 23, 2015 Page Three encroachment.”3 The cycle of devastating wildfires and the damage they cause to slow recovering sage-brush, coupled with the invasion of faster growing cheatgrass is well known and is without dispute the paramount driver to sage grouse habitat degradation.4

Similarly, the FWS’ 2013 Greater Sage Grouse Conservation Objectives Team Report (COT Report) identifies fire as “one of the primary factors linked to loss of sagebrush- steppe habitat and corresponding population declines of greater sage-grouse.”5 The cycle of fire and pervasion of invasive species is well documented as the primary threat to sage grouse habitat. According to the COT Report:

The increase in mean fire frequency in sagebrush ecosystems has been facilitated by the incursion of nonnative annual grasses, primarily Bromus tectorum (cheatgrass) and Taeniatherum asperum (medusahead) (Billings 1994; Miller and Eddleman 2001). The positive feedback loop between exotic annual grasses and fires can preclude the opportunity for sagebrush to become re-established. Exotic annual grasses and other invasive plants also alter habitat suitability for sage-grouse by reducing or eliminating native forbs and grasses essential for food and cover.6

Notably, the COT Report was originally intended to assist the states in their efforts to conserve the sage grouse but was subsequently waylaid by an Oct. 2014 internal memo from FWS Director Dan Ashe to the BLM and FS urging the agencies to manage lands under their jurisdiction in accordance with sage grouse “strongholds” within previously identified Priority Habitat Management Areas.7

As a result, despite the acknowledgement of fire and invasive species as driving factors in species population and habitat degradation, the BLM and FS fail to prioritize these primary threats in their land planning process and instead focus on dramatic restrictions to activities, including the recommendations to withdrawal 10 million acres from mining. BLM’s own reports describe mining’s impacts as being “localized.”8 But even that term

3 Record of Decision and Approved Resource Management Plan Amendments for the Great Basin Region, Including the Greater Sage-Grouse Sub-Regions of Idaho, Southeastern Montana, Nevada, and Northeastern California, Oregon, Oregon, and Utah. September, 2015, at Sec. 1.3. 4 Long-Term Effects of Wildfire on Greater Sage-Grouse— Integrating Population and Ecosystem Concepts for Management in the Great Basin, United States Geological Survey, 2015, Page 32 5 See, U.S. Fish and Wildlife Service, Greater Sage-Grouse, Conservation Objectives Team (COT): Final Report, February, 2013, pg. 10 6 Id. 7 U.S. Fish and Wildlife, Memorandum to Bureau of Land Management and U.S. Forest Service Re: Greater Sage‐Grouse: Additional Recommendations to Refine Land Use Allocations in Highly Important Landscapes, October 27, 2014. 8 Record of Decision and Approved Resource Management Plan Amendments for the Great Basin Region, Including the Greater Sage-Grouse Sub-Regions of Idaho, Southeastern Montana, Nevada, and Northeastern California, Oregon, Oregon, and Utah. September, 2015, at Sec. 1.3.

National Mining Association 101 Constitution Avenue, NW | Suite 500 East | Washington, DC 20001 | (202) 463-2600

Director Kornze December 23, 2015 Page Four

is a misnomer as it fails to accurately reflect the truly minuscule impacts posed by mining operations in sage grouse habitat.

b. Mining is not a Major Threat to Sage Grouse or their Habitat

BLM’s proposed mineral withdrawal is significantly disproportionate to the amount of land used for mineral development and the impacts associated with that mineral exploration and development. The disparity between the scope of the mineral withdrawal and the footprint of mining activities is particularly clear when taking into account the projected long term, unclaimed surface disturbances such as open pit mines that are stabilized at closure but remain as features on the landscape which are minor in the context of habitat area. Data compiled by the United States Geological Survey (USGS) clearly show that the habitat loss due to mining (locatable, leasable and salable) range-wide are minor, totaling about 3.6 percent, and can be mitigated with appropriate project-specific conservation measures including off-site mitigation for unavoidable impacts.9 It is important to note that the locatable mineral activities subject to the withdrawal are only a subset of that 3.6 percent. Significantly, BLM’s own report, the Central Basin Range Rapid Ecological Assessment (CBR REA) indicates that just seven percent of the entire ecoregion (which includes areas outside the planning area) is impacted by all types of development and is only expected to increase by 0.5-percent over the next 10 years.10

As an example, BLM’s LR-2000 database shows that only about 191,374 acres of BLM- administered lands in the entire state of Nevada are included in Notices of Intent and Plans of Operations for locatable mineral activities. Because the LR-2000 database covers the entire state, which includes areas in southern Nevada that do not contain suitable sage grouse habitat, it is clear that only a fraction of the 191,374 acres is located within the planning area and co-located in sage grouse habitat. Furthermore, in developing its plans the BLM relies on mine plan acreages to calculate potential impacts, however, actual surface disturbance footprint within the boundaries of Notices and Plans will be a subset of the total acres reported in the LR2000 database. As a result, the actual footprint of mineral activities is minuscule and cannot be assessed by looking at claim acreages.

Despite the BLM’s characterization of mining impacts as being localized in nature, the agency’s proposed mineral withdrawals are generalized across the West. BLM’s proposed management of mineral development must be commensurate with the actual footprint on the land that mineral development has and is likely to have in the future. The withdrawal of 10 million acres is completely inappropriate in light of the limited extent of mineral activities co-located in sage grouse habitat within the planning area.

9 USGS Report at 71 10 Nevada and Northeastern California Greater Sage-Grouse Proposed Land Use Plan Amendments and Final Environmental Impact Statement (PLUPA/FEIS) at 78 Fed. Reg. 65701 (Friday, November 1, 2013) Section 3.2.4 at 3-37; see also CBR REA at 12

National Mining Association 101 Constitution Avenue, NW | Suite 500 East | Washington, DC 20001 | (202) 463-2600

Director Kornze December 23, 2015 Page Five

BLM must explain the overly restrictive response upon the regulated community in light of the relatively small footprint associated with developed lands in the ecoregion.

c. Alternative Measures Could have Better Achieved Conservation Goals

In addition to greater focus on the primary threats to sage grouse and sage grouse habitat—wildfire and invasive species, there are various other tools available that could better achieve the agencies’ stated conservation goals, without withdrawing 10 million acres across the west in violation of FLMPA and at great economic and national security loss to the nation. These tools include existing mitigation requirements and practices already in place. Not only are wholesale mineral withdrawals not necessary to conserve the sage grouse and its habitat, productive uses can co-exist with, and benefit, sage grouse when coupled with appropriate conservation measures. The best way to provide for protection of the sage grouse, while simultaneously allowing continued economic development, is for BLM to develop conservation measures in cooperation with the regulated community that include a strong but pragmatic mitigation program.

Well-designed reclamation of public lands impacted by mining can ultimately lead to higher value habitat than if the same lands were left unmanaged. This principle is particularly applicable to sage grouse habitat. For example, it is uncontested that noxious invasive species like cheatgrass have significantly degraded vast areas of former sage grouse habitat. The invasion of cheatgrass and other invasive species is magnified by wildfires after which faster growing invasive species inhibit sage-brush regrowth.11

Conversely, pinyon-juniper succession can lead to conversion of prime sage grouse habitat into comparatively low-value woodlands. During mine reclamation, operators routinely restores such low-value habitats into prime potential sage grouse habitat. Thus, when coupled with appropriate reclamation requirements, mining activity on public lands can play an important role in restoring sage grouse and other species to long-term viability. When lands are withdrawn, mining companies that provide these valuable contributions are removed from the conservation effort and reclamation benefits are lost. In addition, the costs of conservation in the absence of mining operators are increasingly borne by federal land management agencies with limited resources to do so.

Protection of intact sagebrush communities and ecological sites may require various phases with little to no sagebrush, allowing sagebrush to reestablish in an appropriate time period. This type of management or vegetation treatment sustains the long-term maintenance of intact sagebrush communities. Protecting intact sagebrush communities

11 See, U.S. Fish and Wildlife Service, Greater Sage-Grouse, Conservation Objectives Team (COT): Final Report, February, 2013, pg. 17.

National Mining Association 101 Constitution Avenue, NW | Suite 500 East | Washington, DC 20001 | (202) 463-2600

Director Kornze December 23, 2015 Page Six

from all disturbances can increase the risk of catastrophic fires in shrub-dominated communities and increase the risk of conversion to non-native invasive species, with the subsequent loss of sage grouse habitat. Prohibiting the conservation efforts of operators though mineral withdrawals reduces the ability to conduct these active management approaches, further jeopardizing sage grouse habitat.

NMA recommends that DOI work with mining operators to conserve sage grouse and habitat as opposed to pursuing a mineral withdrawal that is counterproductive for sagebrush communities.

III. Importance of Federal Minerals

In determining the appropriateness of the proposed withdrawal, BLM must take into consideration the importance of federal minerals. The federal government manages 632 million acres of public land in the United States. Access to federal lands for mineral exploration and development is critical to maintain a strong domestic mining industry as these lands historically have, and will continue to, provide a large share of the metals and hardrock minerals produced in this country. In fact, federal lands account for as much as 86 percent of the land area in certain Western states. These same states account for 75 percent of our nation’s metals production.

Domestic mining is an important economic driver. The value added by major industries that consume the $78 billion of minerals produced in the U.S. is an estimated $2.5 trillion (2014), or 14 percent of our GDP. Mining’s direct and indirect economic contribution includes nearly 2 million jobs with wage and benefits well above the state average for the industrial sector. In addition, domestic mining generates $46 billion in tax payments to federal, state and local governments. And, if we can unlock our mineral resources, mining could contribute even more to our economic security. This is especially true as the demand for minerals continues to grow.

And the demand is expected to grow exponentially as global population growth, rapid industrialization and urbanization in the developing world and a rising global middle class are all driving demand for metals minerals and raw materials. A 2012 KPMG report that looked at sustainability megaforces that will impact “each and every business” over the next 20 years predicted by 2030 that 83 billion tons of minerals, metals and biomass will be extracted from the earth, 55 percent more than in 2010. The study authors conclude: “the message is clear; over the next 20 years, demand for material resources will soar while supplies will become increasingly difficult to obtain.”12 Manufacturers have heeded this message and a recent NMA-commissioned survey of high level manufacturing executives found that more than 90 percent of manufacturers

12 Expect the Unexpected: Building business value in a changing world – KPMG, 2012 (available at https://www.kpmg.com/dutchcaribbean/en/Documents/KPMG%20Expect_the_Unexpected_ExctveSmmry_FINAL _WebAccessible.pdf).

National Mining Association 101 Constitution Avenue, NW | Suite 500 East | Washington, DC 20001 | (202) 463-2600

Director Kornze December 23, 2015 Page Seven

are concerned about access to minerals.13 These same executives believe that domestic mineral supplies will strengthen U.S. national security and decrease our growing dependence on foreign minerals and metals. Our nation’s import dependence for key mineral commodities has doubled over the past two decades. Today we are import dependent for 19 key mineral resources and more than 50 percent import dependent for an additional 24 mineral commodities.

The U.S. position as the world’s premier manufacturing nation could suffer if the U.S. mining industry is not allowed to perform to its full potential and supply more of the minerals needed to sustain growing manufacturing demand. Currently, less than half of the mineral needs of U.S. manufacturing are met from domestically mined resources. As the Rand Corporation has warned, this mismatch hinders international competiveness of U.S. manufacturing and creates pressures to move manufacturing away from the U.S. and into other countries where they can more easily access the minerals they need.14

IV. Consideration of Mineral Potential

FLPMA section 204 governs the secretary’s withdrawal authority. Of the many prerequisites to a withdrawal, BLM is required to submit a report to Congress “prepared by a qualified mining engineer, engineering geologist, or geologist which shall include but not be limited to information on: general geology, known mineral deposits, past and present mineral production, mining claims, mineral leases, evaluation of future mineral potential, present and potential market demands.” 43 USC 1714(c)(12) (See also, BLM withdrawal regulations at 43 CFR 2310.3-2(b)(3)(iii)).

Clearly BLM has the obligation to complete this mineral potential report. As a matter of good public policy, the federal government should make informed decisions about the impact of mineral withdrawals. And the issue of mineral potential is one of such importance that it should not be prejudged. Simultaneously with the non-listing decision regarding the sage grouse, Interior began to take steps to initiate the withdrawal. To defend its position on the withdrawal, various Interior officials indicated that “the withdrawn areas do not appear to be highly prospective for miners.”15 Such statements seem highly disingenuous in light of mineral information developed by BLM’s sister agency, the United States Geological Survey (USGS), and states impacted by the withdrawal.

13 Survey summary is available on the Minerals Make Life website at http://mineralsmakelife.org/assets/images/content/resources/NMA_Berland_Handout_FINAL.pdf. 14 Silberglitt, Bartis, Chow, et. al., Critical Materials: Present Danger to U.S. Manufacturing. Santa Monica, CA: RAND Corporation, 2013. (Available at http://www.rand.org/pubs/research_reports/RR133). 15 Greenwire, “Interior proposes banning new mining on 10M sage grouse acres,” Sept. 23, 2015 (available at http://www.eenews.net/greenwire/stories/1060025186/search?keyword=highly+prospective – subscription required).

National Mining Association 101 Constitution Avenue, NW | Suite 500 East | Washington, DC 20001 | (202) 463-2600

Director Kornze December 23, 2015 Page Eight

Few countries are blessed with the abundance of strategic minerals and metals as is the U.S. According to the USGS, when it comes to copper, silver and zinc and other key minerals “what is left to be discovered in the U.S. is almost as much as what has been discovered.” In 1986, the USGS completed an “Assessment of Undiscovered Deposits of Gold, Silver, Copper, Lead, and Zinc in the United States.” While only focused on these five minerals, the assessment is an extensive look at geological formations across the U.S. to determine the probability of commercially developable mineral deposits. The maps included in the 1986 assessment reveal that the USGS looked at the mineral potential of much of the federal lands that are included within the 10 million acre withdrawal and concluded at least some of these areas are likely to have commercially developable deposits of the five studied minerals. (See Appendix A of these comments for excerpts of the USGS assessment that are relevant to areas scheduled to be withdrawn.) One can only speculate how much greater the overlap between the USGS assessment maps and the withdrawn area maps would be if the USGS assessment included other critical minerals such as molybdenum, nickel, platinum, palladium, rare earths, and uranium.

Further, data compiled by various impacted states also belies claims that much of the proposed withdrawal area is not highly prospective. For example, maps prepared by the Nevada Bureau of Mines and Geology for the Nevada Division of Minerals show that there is significant overlap of the proposed withdrawal area and active mines and lands with high mineral potential. In fact, one map indicates that currently there are nearly 4000 mining claims within the proposed withdrawal area in Nevada. (These maps are contained in Appendix B of these comments.)

Information such as that in the USGS assessment and held by state agencies provide important clues about where to look for minerals. Given the elusive nature of mineral deposits, however, discoveries cannot occur without widespread exploration. The procedures of basic exploration such as geological mapping, geochemical and geophysical testing and drilling, must take place at many times at the cost of hundreds of millions of exploration dollars before a discovery is made.

Such extensive exploration activities are required because concentrations of useful minerals rich enough to form ore deposits are rare phenomena. Commercially extractable concentrations form only where special physical and chemical conditions have favored their accumulation. Exploration geologists frequently cite the metric that at best approximately 1 out of 10,000 deposits has the chance to be transformed into an operating mine. The difficulty in finding commercial mineral deposits underlies the mining industry concerns about large scale mineral withdrawals, as crucial future resources may be put off limits. Finding new resources and delineating their economic potential is critical to keeping the commodity pipeline flowing.

National Mining Association 101 Constitution Avenue, NW | Suite 500 East | Washington, DC 20001 | (202) 463-2600

Director Kornze December 23, 2015 Page Nine

a. Geology is not the sole determiner of mineral potential

While geologic information is critical to finding previously undiscovered resources of minable quality, mineral deposit, geology alone does not dictate whether a deposit can be economically mined. BLM needs to acknowledge that fact as it prepares its mineral potential report. Changes in price, demand, and technology can also factor into whether a deposit can be mined economically. For example, a mining company may have located a deposit that is too low grade to be mined at today’s prices but even a small increase in price could change that dynamic. A 1973 DOI Report accurately depicts the need to take a broad look at mineral potential:

It might seem ridiculous to consider resources that cost two or three times more than those produced now as having any future value at all. But keep in mind, as one of the many examples, that the cutoff grade for copper has been reduced progressively not just by a factor of two or three but by a factor of 10 since the turn of the century and by a factor of about 250 over the history of mining.16

The following charts from USGS17 help visualize this point. Together, they show the historical decline in world and US produced copper grades, from levels of 16 percent in 1750 to approximately 1 percent in 1950 to somewhere around 0.5 percent in 2000.

16 United States Mineral Resources, Geological Survey Professional Paper 820, Dept. of the Interior, 1973, p. 12. 17USGS, Technological Advancement – A Factor In Increasing Resource Use, Open File Report 2001-197, version 1.03, (available at http://pubs.usgs.gov/of/2001/of01-197/2001-197.pdf).

National Mining Association 101 Constitution Avenue, NW | Suite 500 East | Washington, DC 20001 | (202) 463-2600

Director Kornze December 23, 2015 Page Ten

Just as with other commodities, minerals and metals prices are determined by a variety of factors such as demand, supply disruptions, geopolitical situations etc. But an important point to note about minerals and metals is not only their integral nature to modern life but the dynamic nature of their use. Demand for minerals is increasing as new frontier technologies require a wider range of minerals and materials. For example, a modern computer chip contains more than half of the elements in the periodic table and even though they may be present in very small amounts, each is essential to function and performance.

The 1973 document also contains an excellent example of how technology can change views regarding which deposits can be economically mined. The example involves the development of technology that allows the extraction of disseminated gold deposits. At the time the document was written, only a few deposits of disseminated gold had been discovered so little was known about the amount of gold this type of deposit may contain. However, even in 1973 there was great excitement about being able to mine disseminated gold deposits:

Both the Carlin and the Cortez deposits contain more than 1 million ounces of gold. . . These deposits have produced only a tiny fraction of U.S. or world gold; from 1936 to 1969, they yielded slightly more than 2

National Mining Association 101 Constitution Avenue, NW | Suite 500 East | Washington, DC 20001 | (202) 463-2600

Director Kornze December 23, 2015 Page Eleven

million ounces, less than 3 percent of U.S. production during that period. However, they have become an increasingly important contributor to United States output, and in 1969 the Carlin and Cortez mines alone accounted for about 22 percent of U.S. production. The future importance of this type of deposit is difficult to assess on a worldwide basis, but for the United States it is likely to be great. … The discovery of two major deposits, Carlin and Cortez, in the 1960's encourages belief in the existence of other unrecognized deposits.18

Today, both Carlin and Cortez have gone from single mines to multiple, wide-spread, deposits as a product of exploration away from the original occurrences. These areas now produce the majority of the gold in the U.S.

V. Legal Infirmities

a. Proposed Withdrawal of Greater than 5,000 Acres Without Congressional Approval Exceeds Legal Authority under FLPMA

The proposed withdrawal of approximately 10 million acres from location and entry under the general mining laws without Congressional approval far exceeds the Secretary’s authority to withdraw lands under FLPMA. Specifically, FLPMA provides that:

“On and after October, 21, 1976, a withdrawal aggregating five thousand aces or more may be made (or such a withdrawal or any other withdrawal involving in the aggregate five thousand acres or more which terminates after such date of approval may be extended) only for a period of not more than twenty years by the Secretary on his own motion or upon request by a department or agency head. The Secretary shall notify both Houses of Congress of such a withdrawal no later than its effective date and the withdrawal shall terminate and become ineffective at the end of ninety days…beginning on the day notice of such withdrawal has been submitted to the Senate and the House of Representatives, if the Congress has adopted a concurrent resolution stating that such House does not approve the Withdrawal.”19

Despite the clear intent of Congress to provide the Secretary authority to withdraw more than five thousand acres only if Congress has the discretion to reject such a withdrawal, provisions of this nature were deemed unconstitutional in the U.S. Supreme Court case INS v. Chadha, 462 U.S. 919, 1982. Specifically, the Court held that statutory provisions authorizing executive actions while retaining Congressional discretion over actions deemed executive in nature were deemed “legislative vetoes” and in violation of the

18 Id. at 271. 19 42 U.S.C. § 1714(c)(1)

National Mining Association 101 Constitution Avenue, NW | Suite 500 East | Washington, DC 20001 | (202) 463-2600

Director Kornze December 23, 2015 Page Twelve

Constitution’s Bicameralism Clause and the Presentment Clause.20 The holding also provided that provisions in violation of these separation of powers principles could be severed and the balance of the statue retained, only if “what remains after severance is fully operative as a law.”21 To determine if a severed provision is fully operative as a law, the appropriate inquiry is “whether the statute will function in a manner consistent with the intent of Congress,” considering both the “importance of the legislative veto in the original legislative bargain” and” the nature of the delegated authority” at issue.22

Section 204(c)(1) is not operative as a law in a manner consistent with the intent of Congress if only the portion including the legislative veto is severed. In enacting FLPMA, Congress tied the legislative veto to the grant of authority for withdrawals greater than five thousand acres. It is uncontroverted that had Congress known it was not able to reject large-scale withdrawals by concurrent resolution, it would not have enacted the Section as written and would not have granted the authority to withdraw more than five thousand acres.23 This is clear not only in the text of Section 204(c)(1) of FLMPA but also in the well-established cannons of statutory construction. The authority to withdraw more than five thousand acres and the authority of Congress to disapprove such withdrawals through concurrent resolution were so inextricably integrated that Congress chose to include both elements not only within the same subsection, but immediately adjacent to one another within the same provision making the first element only possible upon condition of the second.24

Separating the Section 204(c)(1) from the rest of the statute is also consistent with FLPMA’s own severability clause which expressly supports striking the entirety of the integrated Section 204(c)(1) provision. FLPMA’s severability clause states; “If any provision of this Act…is held invalid, the remainder of the Act…shall not be affected.25 This clause, like the holding in INS v. Chadha applies the severability principle to provisions, not portions of provisions. Because the legislative veto portion of Section 204(c)(1) is invalid, the remainder of the same “provision”—Section 204(c)(1) is also invalid. In the case of FLMPA, severing Section 204(c)(1) is the smallest and most exact severance possible, as it applies only to one paragraph within the statute. Furthermore, severing the legislative veto from Section 204(c)(1) and proceeding with the proposed mineral withdrawal under the notion that the withdrawal authority in the same subsection remains intact renders obsolete Sections 204 (d) and (e) of FLPMA which establish procedures for withdrawals of less than five thousand acres and for emergency withdrawals for up to three years, respectively.26 There would be no need

20 INS v. Chadha, 462 U.S. 919, 949, 951 (1982). 21 Id. at 934. 22 Alaska Airlines, Inc. v. Brock, 480 U.S. 678, 685 (1987). 23 Id. 24 See, Am. Fed’n of Gov’t Employees v. Pierce, 697 F.2d 303, 308 (D.C. Cir, 1982), finding that “both parts of the single sentence Congress adopted”—including the legislative veto—“are invalid”). 25 FLPMA § 707, 90 Stat. 2794 (1976). 26 42 U.S.C. § 1714(d)(e)

National Mining Association 101 Constitution Avenue, NW | Suite 500 East | Washington, DC 20001 | (202) 463-2600

Director Kornze December 23, 2015 Page Thirteen for such provisions and the separate procedures and requirements they establish if the Secretary were authorized to withdraw any amount of land at her discretion. She is not. To sever only the legislative veto portion of the statute and retain the authority to withdraw greater than five thousand acres would allow a type of statutory re-writing inconsistent with both the law, congressional intent, and common sense.

Given the unconstitutionality of the legislative veto in Section 204(c)(1), leading scholars support the severance of the complete provision, and not a portion of it:

“It will be difficult to argue that the basic congressional intent underlying FLPMA can be carried out simply by excising the legislative vetoes, because Congress preeminently intended to reassert control over federal land use and classification. Invalidation of the vetoes only would return unfettered and unsupervised discretion to the executive brand, the very result that FLPMA was enacted to prevent.”27

“Removal of all of section 204(c) [authority] from the statute—seems closest to the scheme Congress itself would have chosen had it known that the legislative veto was invalid. The Secretary of the Interior’s authority to make withdrawals under FLPMA would be limited to tracts less than five thousand acres…Only the larger, more significant withdrawals would have to emanate from the legislature.”28

The proposed withdrawal of 10 million acres presumes that severance of the legislative veto within Section 204(c)(1) leaves intact the unfettered authority of the Secretary to withdraw as much land as the Secretary chooses, without any check by Congress. This interpretation, in addition to running counter to both FLMPA and Supreme Court precedent, also ignores the fundamental roles of the different branches of the federal government in managing public lands. The Property Clause of the Constitution vests Congress with primary authority manage public lands— “The Congress shall have power to dispose of and make all needful rules and regulations respecting the territory or other Property belonging to the United States....”29 Under the Constitution’s Property Clause, the “power over the public land…entrusted to Congress is without limitations”30 and any prior acquiescence to executive exercise of mineral withdrawal authority by Congress does not provide authority for subsequent executive mineral withdrawals31 as was made abundantly clear through the enactment of FLPMA. Despite the clear default position of Congress as the primary branch tasked with managing public lands, severing only the legislative veto and retaining the unlimited withdrawal authority turns the

27 George Coggins & Robert Glicksman, Public Natural Resources Law § 4:3 (2d ed. 2011). 28 Robert Glicksman, Severability and the Realignment of the Balance of Power over the Public Lands: The Federal Land Policy and Land Management Act, 36 Hastings L. J. 82-83 (1984). 29 United States Constitution, Article IV, Section 3, Clause 2. 30 Kleppe v. New Mexico, 426 U.S. 529, 539-40 (1976). 31 United States v. Woodley, 726 F.2d 1328, 1337-38 (9th Cir. 1983)

National Mining Association 101 Constitution Avenue, NW | Suite 500 East | Washington, DC 20001 | (202) 463-2600

Director Kornze December 23, 2015 Page Fourteen

Property Clause on its head with respect to all locatable minerals, allowing the executive branch to withdraw lands, effectively in perpetuity, without limitation.

Proposing to withdraw 10 million acres from location and entry under the general mining laws without any congressional oversight flies in the face of FLPMA, the Constitution, and decades of cases interpreting the public lands laws of this country. If accepted, this proposed withdrawal will be the largest in American history, and if executed without Congressional approval, will be of the exact type FLPMA, other public lands laws, and the Constitution intended to curtail— The wholesale withdrawal of mineral resources by administrative fiat, not because such lands are of particular historic or scientific value and designated in the smallest possible area as is the case under the Antiquities Act, or because the lands warrant emergency protection under Section 204(e) of FLPMA, but because the land management agencies speculate that it could have some positive effect on conserving sage grouse habitat, despite lack of adequate evidence to substantiate this. This proposed action is as irrational as it is illegal, and the lands in question must not be withdrawn.

b. Proposed Withdrawal Ignores the FLPMA Multiple Use Mandate for Federal Lands

As mentioned above, FLPMA governs the withdrawal of public lands but Congress’ intent in addressing withdrawals was to reign in withdrawals by the executive branch rather than to increase such use. While the goals of FLPMA are many, including protecting the environmental and other key values of the public land, the underpinning of the statute is that management of the public land should be on the basis of multiple use and sustained yield unless otherwise specified by law. A component of such multiple use includes the requirement that public land be managed in a manner that “recognizes the Nation’s need for domestic sources of minerals.”

The definition of multiple use in FLPMA was essentially borrowed from the Multiple-Use Sustained-Yield Act of 1960 (MYUSA) and is intended to have the same meaning. See Senate Report No. 95-583 (“this [multiple use] definition is very similar to that . . . which presently appears at section 4 of the Multiple-Use Sustained-Yield Act of 1960 . . . .” and House Report No. 94-1163 (“the definition of multiple use preserves essentially its same meaning as used in the Forest Service Multiple Use Act of 1960 [as MUSYA is also known].)”

Therefore, by analogy, the legislative history of MUSYA regarding multiple use principles applies with equal weight to FLPMA. In explaining MUSYA’s multiple-use directive, the House Report discusses the "relative values" analysis as follows:

One of the basic concepts of multiple use is that all of these resources in general are entitled to equal consideration, but in particular or localized areas relative values of the various resources will be recognized.... no

National Mining Association 101 Constitution Avenue, NW | Suite 500 East | Washington, DC 20001 | (202) 463-2600

Director Kornze December 23, 2015 Page Fifteen

resource would be given a statutory priority over the others. The bill would neither upgrade nor downgrade any resource.32

NMA agrees strongly with BLM’s assessment of FLPMA on its 30 year anniversary: “FLPMA provides us with the tools we need to cooperatively and creatively manage the public lands, and in the process, dispel the notion that a variety of uses and resources cannot co-exist.” Similarly, BLM’s 2006 Energy and Minerals Policy appropriately embraces FLPMA’s multiple use mission. That policy states the “BLM land use planning and multiple-use management decisions will recognize that, with few exceptions, mineral exploration and development can occur concurrently or sequentially with other resource uses. The least restrictive stipulations that effectively accomplish the resource objectives or uses will be used.” In pursuing the proposed withdrawal, BLM ignores the multiple use mission as the withdrawal is unnecessary to conserve sage grouse and its habitat.

c. Industry and the Public Was Deprived of the Opportunity to Comment on Sagebrush Focal Areas

NMA members were denied an opportunity to comments on the “Sagebrush Focal Areas” (SFAs) on which the proposed withdrawal is predicated, and therefore BLM may not withdraw the lands at issue in the absence of a supplemental environmental impact statement (SEIS) analyzing the SFAs and allowing NMA and the public sufficient time in which to comment on the SEIS.

For the first time in the proposed land use plan amendments and final environmental impact statements (FEIS) for the PLUPAs a new sage grouse habitat management construct to the LUPs makes an appearance. This novel regime, the SFAs, is grounded in a pronouncement in the Oct. 2014 Ashe Memo, entitled “Greater Sage-grouse: Additional Recommendations to Refine Land Use Allocations in Highly Important Landscapes” (“Ashe Memo”). Another element of the PLUPA/FEIS is the application of lek buffer distances identified in another document previously not available or included in the DEIS. A USGS report entitled Conservation Buffer Distance Estimates for Greater Sage-grouse — a Review, USGS Open File Report 2014 1239 (Manier, et al. 2014) (“Lek Buffer Study”), forms the basis for newly applied sage grouse lek buffer distances for activity on the public lands at issue.

A SEIS is required under NEPA: 1) if the agency makes substantial changes in the proposed action that are relevant to environmental concerns, 40 C.F.R.§ 1502.9(c)(1)(i); or 2) if there are significant new circumstances or information relevant to environmental concerns and bearing on the proposed action or its impacts, 40 C.F.R. § 1502.9(c)(1)(ii).

32 See H.R. Rep. No. 1551, 86th Cong., 2d Sess. (1960), reprinted in 1960 U.S.C.C.A.N. 2377, 2379. See 43 U.S.C. §§ 1701(a)(3) and National Wildlife Federation v. Buford, 835 F.2d 305, 308-09 (9th Cir. 1987) (finding that classifications must be reviewed consistent with the principles of multiple use and sustained yield).

National Mining Association 101 Constitution Avenue, NW | Suite 500 East | Washington, DC 20001 | (202) 463-2600

Director Kornze December 23, 2015 Page Sixteen

The new SFA habitat category dramatically reshaped the Proposed Federal Action (“Proposed Action”) due to its management as: 1) recommended for withdrawal from the Mining Law of 1872, “subject to valid existing rights”; 2) no surface occupancy (“NSO”), without waiver, exception, or modification, for fluid mineral leasing; and 3) prioritized for management and conservation actions in these areas, including, but not limited to, review of livestock grazing permits/leases. The debut of SFAs in the PLUPA/FEIS on which the proposed withdrawal is predicated constitutes a “substantial change” in the proposed action, 40 C.F.R. § 1502.9(c)(1)(i), and an SEIS is required prior to adoption or the PLUPAs or the proposed mineral withdrawal. Additionally, the Lek Buffer Study, coupled with the Ashe Memo, collectively constitute “significant” post-DEIS information bearing on the proposed action or its impacts, and thus an SEIS is required on that basis under 40 C.F.R. § 1502.9(c)(1)(ii).

When two new, key and significant pieces of information come late and are not subject to fair comment, this is fatal to the mandatory “meaningfulness” of this NEPA process. See 40 C.F.R. § 1506.6(b) (Federal government shall “[p]rovide public notice of NEPA- related hearings, public meetings, and the availability of environmental documents so as to inform those persons and agencies who may be interested or affected” by proposed actions of the United States.”). See also, Council on Environmental Quality, A Citizen’s Guide to the NEPA at 26 (“Agencies are required to make efforts to provide meaningful public involvement in their NEPA processes.).

Courts have required a SEIS when the proposed action differs “dramatically” from the alternatives described in the DEIS because, de facto, meaningful public comment on the proposed action was precluded. See California v. Block.33 Here, none of the DEIS alternatives analyzed the key elements that ultimately made their way into the Proposed Action, particularly the SFAs, lek-buffer distances, and the disturbance cap (discussed below). Thus, the Proposed Action in the PLUPA/FEIS could not have been fairly anticipated from reviewing the DEIS alternatives. Because the Agencies have “seriously dilut[ed] the relevance of public comment” on the DEIS, an SEIS is warranted.34 See also New Mexico ex rel. Richardson v. Bureau of Land Management, 565 F.3d 683, 707 (10th Cir. 2009) (new alternative proposing new locations of activities required an SEIS because it affected “environmental concerns in a different manner than previous analyses,” even though the general nature of the alternatives impact resembled those already analyzed).

This fatal error is compounded through the heavy reliance on the Ashe Memo and the Lek Buffer Study – both significant and material post-DEIS information – that formed key cornerstones to the Proposed Action. See PLUPA/FEIS at 2-3 (describing the need for SFAs, “In light of the landscape level approach to sage grouse conservation provided through this planning effort and as defined by the characteristics set forth

33 690 F.2d 753 (9th Cir. 1982). 34 Id. at 358.

National Mining Association 101 Constitution Avenue, NW | Suite 500 East | Washington, DC 20001 | (202) 463-2600

Director Kornze December 23, 2015 Page Seventeen

above, as well as additional considerations, including potential for impacts from climate change, fire and invasives, these areas have been identified as SFAs.”) and justifying buffers through “the USGS report [which] states that ‘various protection measures have been developed and implemented… [which have] the ability (alone or in concert with others) to protect important habitats, sustain populations, and support multiple-use demands for public lands.’”35 Accordingly, the Agencies’ justification that the PLUPA is a lawful “suite of management decisions that present a minor variation of the Preferred Alternative identified in the Draft LUPA/EIS,”36 fails both practically and as a matter of law.

d. SFAs Are not Valid and are a Proxy for ACEC Lands Under FLPMA, which Population Numbers do Not Support

The SFAs established by the 2014 Ashe Memo which predicate the proposed mineral withdrawal are not a valid land management or legal mechanism and cannot be used to support any land management action, including the proposed mineral withdrawal. Interior’s newly created term “SFA” is an attempt to create a FLPMA Areas of Critical Environmental Concern (ACEC) without going through the required process. The description contrived by the FWS in the Ashe Memo and adopted in the proposed withdrawal cannot serve as a proxy for ACECs. As such, SFAs are not a recognized land management mechanism under which BLM may recommend a withdrawal of lands from the general mining laws, and the only recognized land management tool available for the management of “fish or wildlife resources” under the public lands management process is FLPMA’s ACEC designation process. Specifically, Section 103(a) of FLPMA defines ACECs as:

“(a) The term “areas of critical environmental concern” means areas within the public lands where special management attention is required (when such areas are developed or used or where no development is required) to protect and prevent irreparable damage to important historic, cultural, or scenic values, fish and wildlife resources or other natural systems or processes, or to protect life and safety from natural hazards.”37

According to the BLM, the withdrawal is being proposed “to protect the Greater Sage- Grouse and its habitat from the adverse effects of locatable mineral exploration and mining, subject to valid existing rights.”38 The SFAs on which the proposed withdrawal is based are described in the Ashe Memo as, “a subset of priority habitat most vital to the

35 Idaho and Southwestern Montana, Greater Sage Grouse Proposed Land Use Plan Amendment and Final Environmental Impact Statement, at Appendix DD. 36 Idaho and Southwestern Montana, Final Environmental Impact Statement, at 2-6/ 37 43 U.S.C. § 1702(a) 38 80 Fed. Reg. 57635, September 24, 2015.

National Mining Association 101 Constitution Avenue, NW | Suite 500 East | Washington, DC 20001 | (202) 463-2600

Director Kornze December 23, 2015 Page Eighteen

species persistence, within which we recommend the strongest levels of protection.”39 These descriptions match that of an ACEC, in particular, “to protect and prevent irreparable damage to…fish and wildlife resources.” In order to designate lands as ACECs, BLM must follow its existing regulations which provide:

“Areas having potential for Areas of Critical Environmental Concern (ACEC) designation and protection management shall be identified and considered throughout the resource management planning process (see §§ 1610.4-1 through 1610.4-9). (a) The inventory data shall be analyzed to determine whether there are areas containing resources, values, systems or processes or hazards eligible for further consideration for designation as an ACEC. In order to be a potential ACEC, both of the following criteria shall be met: (1) Relevance. There shall be present a significant historic, cultural, or scenic value; a fish or wildlife resource or other natural system or process; or natural hazard. (2) Importance. The above described value, resource, system, process, or hazard shall have substantial significance and values. This generally requires qualities of more than local significance and special worth, consequence, meaning, distinctiveness, or cause for concern. A natural hazard can be important if it is a significant threat to human life or property. (b) The State Director, upon approval of a draft resource management plan, plan revision, or plan amendment involving ACECs, shall publish a notice in the Federal Register listing each ACEC proposed and specifying the resource use limitations, if any, which would occur if it were formally designated. The notice shall provide a 60-day period for public comment on the proposed ACEC designation. The approval of a resource management plan, plan revision, or plan amendment constitutes formal designation of any ACEC involved. The approved plan shall include the general management practices and uses, including mitigating measures, identified to protect designated ACEC.”

BLM has followed none of these procedures for purposes of adopting and designating the SFAs. The FWS may not establish a nonexistent designation—SFAs, which match the description of an existing statutory designation, nor may the BLM engraft the contrived designation upon their land use planning process under FLPMA where a regulatory process already exits.

39 U.S. Fish and Wildlife Service Memorandum, Greater Sage-Grouse: Additional Recommendations to Refine Land Use Allocations in Highly Important Landscapes, October 27, 2014.

National Mining Association 101 Constitution Avenue, NW | Suite 500 East | Washington, DC 20001 | (202) 463-2600

Director Kornze December 23, 2015 Page Nineteen

When taking into account the established requirements for designating ACECs under FLPMA, it is clear that that the SFAs fail to meet this standard and may not be designated. According to an August 2015 report developed by the Western Association of Fish and Wildlife Agencies (WAFWA), “the number of male birds documented this year has rebounded significantly from a recent low in 2013. Scientists make population estimates based on the number of male birds counted on traditional mating areas, or leks. The number of males counted on leks has increased 63% since 2013.”40 The WAFWA Report also found that “there is no evidence that the number of active leks has declined recently (2,822 active leks in 2006 and 3,154 in 2015).”41

As previously noted, the definition of “ACEC” under FLMPA allows for designation of lands to “prevent irreparable damage to…fish and wildlife resources.” Neither BLM nor FWS has presented adequate information to show that absent the mineral withdrawal of 10 million acres, the sage grouse is at risk of irreparable damage due to mining activity. To the contrary, the impacts of mining have been found to be highly localized, minimal in impact, and beneficial with respect to conservation efforts, while sage grouse populations are on the rise. The 10 million acres proposed for withdrawal do not approach the threshold set by FLMPA and its regulations for designation as ACECs. BLM has followed neither the appropriate process nor has it presented adequate information to substantiate designation had it done so. As a result, the proposed mineral withdrawal must not be accepted.

VI. Practical Implications of the Withdrawal

On a final note, NMA believes BLM needs to consider whether the withdrawal is even implementable given various BLM constraints. With the largest ever withdrawal in the history of FLMPA come BLM obligations of herculean proportions, not the least of which will be to conduct validity determinations of mining claims to ascertain which claims have valid existing rights and therefore are not subject to the withdrawal.

It is our understanding that there are fewer than 20 certified mineral examiners at BLM and even fewer at the Forest Service and that nearly all are of retirement age. Mineral examinations for claim validity determinations are time intensive. In fact, it does not appear that these two agencies have even finished the claim validity determinations required pursuant to the 1994 congressional moratorium on the patenting of mineral claims. If the agencies cannot complete those 392 determinations in 20 years, it is impossible to believe they can tackle the 1000s of determinations that will be required by a 10 million acre withdrawal in any reasonably length of time. And the number will be in the 1000s, since, as stated above, the Nevada Division of Minerals has identified nearly 4000 claims in the proposed withdrawal area in Nevada. Even if BLM provided

40 Western Association of Fish and Wildlife Agencies, Press Release, WAFWA Report Documents Greater Sage- Grouse Population Rebound, Aug. 17, 2015. 41 Western Association of Fish and Wildlife Agencies, Greater Sage-Grouse Population Trends: Analysis of Lek Databases 1965-2015, August 2015, at 11.

National Mining Association 101 Constitution Avenue, NW | Suite 500 East | Washington, DC 20001 | (202) 463-2600

Director Kornze December 23, 2015 Page Twenty additional resources to conduct determinations, it would take time to train and certify new examiners. In the meantime, even those companies that ultimately are successful in proving up their claims will be stuck in limbo – not being able to work their claims – but having to pay claims maintenance fees, and for the claim validity exam itself.

VII. Conclusion

NMA appreciates the opportunity to submit these comments. NMA believes the proposed withdrawal of 10 million acres of likely mineral rich federal lands is unwise from and unnecessary to protect the sage grouse and its habitat. We request BLM review the impacts of the proposed withdrawal through the lens of its multiple use mission under FLPMA. The agency can take other less restrictive measures to protect sage grouse habitat. If you have any questions regarding these comments please contact me at (202)463-2627 or [email protected].

Sincerely,

Katie Sweeney

National Mining Association 101 Constitution Avenue, NW | Suite 500 East | Washington, DC 20001 | (202) 463-2600

Appendix A USGS National Mineral Resource Assessment CVMS: Massive sulfide deposits, Cyprus type

NA04

PC09

PC10

GB19

Cumulative Distribution Histogram Table Model Mineral Deposits Rationale CVMS •••• • GB19 • • NA04 •••• • PC09 •••••• PC10

AD AD: Adirondack Mountains PC NR NA CP: Colorado Plateau LS CR: Central and Southern Rocky Mountains GB EC: East-central United States EC CR GB: Great Basin CP LS: Lake Superior SB GP SA NA: Northern Appalachian Mountains

NR: Northern Rocky Mountains map projection = Albers Equal Area

PC: Pacific Coast 50 0 50 100 200 300 400 miles SA: Southern Appalachian Mountains 50 0 50 100 200 300 400 kilometers SB: Southern Basin and Range National Mineral Resource Assessment, 1995

The tract ID is GB19 The Mark3 Index is 11: Massive sulfide, Cyprus

There is a 90% or greater chance of 1 or more deposits. There is a 50% or greater chance of 2 or more deposits. There is a 10% or greater chance of 5 or more deposits. There is a 5% or greater chance of 7 or more deposits. There is a 1% or greater chance of 8 or more deposits.

Estimated amounts of contained metal and mineralized rock (metric tons)

quantile Cu Au Zn Ag Pb rock 0.95 0 0 0 0 0 0 0.90 1,300 0 0 0 0 93,000 0.50 110,000 0 2,900 1 0 7,100,000 0.10 680,000 31 186,000 490 400 35,000,000 0.05 940,000 57 380,000 770 5,300 45,000,000 mean 250,000 12 63,000 140 1,400 13,000,000

Probability of mean 0.33 0.21 0.20 0.25 0.06 0.37 Probability of zero 0.07 0.49 0.43 0.49 0.85 0.07

gb19 14/9/95 National Mineral Resource Assessment, 1995

The tract ID is GB19

Cumulative Distributions of Contained Metal and Mineralized Rock

1.00

Filled circles 0.90 display mean amounts 0.80

0.70

0.60

0.50

Probability 0.40 rock Cu 0.30 Ag 0.20 Au Zn

0.10 Pb 0.00 1 10 0.1 100 0.0 0.0 0.1 1.0 0.01 10.0 1,000 0.001 100.0 10,000 1 billion 1 trillion 100,000 1 million 1,000.0 10 billion 10 million 10,000.0 100 billion 100 million 100,000.0 1,000,000.0 10,000,000.0 100,000,000.0 1,000,000,000.0 10,000,000,000.0 100,000,000,000.0 1,000,000,000,000.0 Histograms of Contained Metal and Mineralized Rock (metric tons)

0.180

0.160 0.140

0.120

0.100

0.080

0.060 0.040 Proportion of Simulations 0.020

0.000 10 18 32 56 1.0 1.8 3.2 5.6 100 178 316 562 0.10 0.18 0.32 0.56 0.010 0.018 0.032 0.056 1,000 1,780 3,160 5,620 0.0018 0.0032 0.0056 10,000 17,800 31,600 56,200 100,000 178,000 316,000 562,000 1,000,000 1,780,000 3,160,000 5,620,000 10,000,000 17,800,000 31,600,000 56,200,000 100,000,000 178,000,000 316,000,000 562,000,000 1,000,000,000 1,780,000,000 3,160,000,000 5,620,000,000 10,000,000,000 17,800,000,000 31,600,000,000 56,200,000,000 100,000,000,000 178,000,000,000 See table for probability of zero tons

Cu Au Zn Ag Pb rock

gb19 14/9/95 USGS National Mineral Resource Assessment NR17 BVMS: Massive sulfide deposits, Besshi type

NA05 1 NA07 NA06 1 NA08 PC11 NA09 NA10

CR23 GB20

Cumulative Distribution Histogram Table Model Mineral Deposits Rationale BVMS 1 2 CR23 SA02 SA01 •••• • GB20 1 •••••• NA05 2 ••• NA06 SA03 •••• • NA07 •••• • NA08 •••••• NA09 •••• • NA10 •••• • NR17 •••• • PC11 AD: Adirondack Mountains AD •••• • SA01 PC NR NA CP: Colorado Plateau LS CR: Central and Southern Rocky Mountains •••••• SA02 GB EC: East-central United States • • EC GB: Great Basin SA03 CR CP LS: Lake Superior •••••• SB GP NA: Northern Appalachian Mountains SA NR: Northern Rocky Mountains PC: Pacific Coast map projection = Albers Equal Area SA: Southern Appalachian Mountains 50 0 50 100 200 300 400 miles

SB: Southern Basin and Range 50 0 50 100 200 300 400 kilometers knowndep • 12:17 PM • 6/5/96 National Assessment, 1995 SDL/DPC Conterminous United States Known Deposits

Map Alternative deposit Layer Tract Deposit District County State Lat Long Deposit Type No. types Distal disseminated Ag- Trenton - Valmy Battle Mountain Humboldt NV 40.645 -117.178 DSDG GB18 06 Au Distal Disseminated Ag- Reona Battle Mountain Lander NV 40.540 -117.140 Skarn Au DSDG GB18 07 Au Distal disseminated Ag- Hilltop Hilltop Lander NV 40.420 -116.810 DSDG GB18 08 Au Distal disseminated Ag- Cove - McCoy McCoy Lander NV 40.340 -117.210 Skarn Au DSDG GB18 09 Au Distal disseminated Ag- Tenabo Bullion Lander NV 40.310 -116.640 DSDG GB18 10 Au Distal disseminated Ag- White Pine White Pine White Pine NV 39.980 -115.480 DSDG GB18 11 Au Distal disseminated Ag- Windfall Eureka Eureka NV 39.450 -115.980 DSDG GB18 12 Au Distal disseminated Ag- Star Pointer Robinson White Pine NV 39.250 -114.980 DSDG GB18 13 Au Distal disseminated Ag- Mt. Hamilton White Pine White Pine NV 39.250 -115.570 DSDG GB18 14 Au Distal disseminated Ag- Treasure Hill White Pine White Pine NV 39.220 -115.480 DSDG GB18 15 Au Distal disseminated Ag- Taylor Taylor White Pine NV 39.080 -114.680 DSDG GB18 16 Au Distal disseminated Ag- Candelaria Candelaria Mineral NV 38.150 -118.080 DSDG GB18 17 Au BVMS GB20 01 Rio Tinto Mountain City Elko NV 41.810 -115.980 Massive sulfide, Besshi Epithermal vein, Zaca Monitor-Mogul Alpine CA 38.666 -119.704 QZAD GB22 01 Comstock Epithermal vein, Patterson Mono CA 38.412 -119.232 QZAD GB22 02 Comstock Epithermal vein, Bodie Mono CA 38.223 -118.982 QZAD GB22 03 Comstock Epithermal vein, Long Valley Mono CA 37.700 -118.867 Hot-spring Au-Ag QZAD GB22 04 Comstock Epithermal vein, Jarbidge Elko NV 41.840 -115.410 QZAD GB23 01 Comstock Epithermal vein, National Humboldt NV 41.840 -117.590 QZAD GB23 02 Comstock Epithermal vein, Tuscarora Elko NV 41.320 -116.220 QZAD GB23 03 Comstock Epithermal vein, Gold Circle Elko NV 41.250 -116.790 QZAD GB23 04 Comstock Page 4 National Mineral Resource Assessment, 1995

The tract ID is GB20 The Mark3 Index is 30: Massive sulfide, Besshi

There is a 90% or greater chance of 0 or more deposits. There is a 50% or greater chance of 1 or more deposits. There is a 10% or greater chance of 2 or more deposits. There is a 5% or greater chance of 2 or more deposits. There is a 1% or greater chance of 3 or more deposits.

Estimated amounts of contained metal and mineralized rock (metric tons)

quantile Cu Au Zn Ag rock 0.95 0 0 0 0 0 0.90 0 0 0 0 0 0.50 1,200 0 0 0 92,000 0.10 110,000 2 30,800 56 6,000,000 0.05 280,000 6 87,000 160 21,000,000 mean 46,000 1 17,000 42 2,700,000

Probability of mean 0.16 0.12 0.12 0.11 0.19 Probability of zero 0.31 0.72 0.86 0.72 0.31

gb20 14/9/95 National Mineral Resource Assessment, 1995

The tract ID is GB20

Cumulative Distributions of Contained Metal and Mineralized Rock

1.00

Filled circles 0.90 display mean amounts 0.80

0.70

0.60

0.50

Probability 0.40

0.30

0.20 rock Cu Au Zn 0.10 Ag

0.00 1 10 0.1 100 0.0 0.0 0.1 1.0 0.01 10.0 1,000 0.001 100.0 10,000 1 billion 1 trillion 100,000 1 million 1,000.0 10 billion 10 million 10,000.0 100 billion 100 million 100,000.0 1,000,000.0 10,000,000.0 100,000,000.0 1,000,000,000.0 10,000,000,000.0 100,000,000,000.0 1,000,000,000,000.0 Histograms of Contained Metal and Mineralized Rock (metric tons)

0.100 0.090 0.080 0.070 0.060 0.050 0.040 0.030 0.020 Proportion of Simulations 0.010 0.000 10 18 32 56 1.0 1.8 3.2 5.6 100 178 316 562 0.10 0.18 0.32 0.56 0.010 0.018 0.032 0.056 1,000 1,780 3,160 5,620 0.0018 0.0032 0.0056 10,000 17,800 31,600 56,200 100,000 178,000 316,000 562,000 1,000,000 1,780,000 3,160,000 5,620,000 10,000,000 17,800,000 31,600,000 56,200,000 100,000,000 178,000,000 316,000,000 562,000,000 1,000,000,000 1,780,000,000 3,160,000,000 5,620,000,000 10,000,000,000 17,800,000,000 31,600,000,000 56,200,000,000 100,000,000,000 178,000,000,000 See table for probability of zero tons

Cu Au Zn Ag rock

gb20 14/9/95 USGS National Mineral Resource Assessment 1 NA12 NR18 KVMS: Massive sulfide deposits, kuroko type 1 PC12 LS03 NA11 2

NA15 1 1 1 2 NR19 LS02 2 Cumulative Distribution Histogram Table Model Mineral Deposits Rationale KVMS LS04 NA14 1 3 5 2 4 NA13 PC13 7 CR24 PC14 6 •••••• CR25 1 NA16 PC15 •••••• GB21 1-3 LS05 •••• • LS02 GB21 • • PC16 LS03 NR20 •••• • LS04 1 •••••• LS05 PC17 2 • • NA11 CR24 SA04 •••••• 3 NA12 1 •••• • 2 NA13 1 3 •••••• 2 •••••• NA14 • • NA15 •••• • NA16 1 1 NR18 2 3 4 SA07 •••• • 5-6 NR19 7 SA06 •••• • NR20 1 SB25 CR25 •••• • PC12 PC18 SA08 SA05 SA09 •••••• PC13 •••••• PC14 SB26 •••••• PC15 •••••• PC16 •••• • PC17 AD AD: Adirondack Mountains PC NR NA CP: Colorado Plateau •••••• PC18 LS CR: Central and Southern Rocky Mountains •••• • GB EC: East-central United States SA04 EC CR GB: Great Basin •••••• SA05 CP LS: Lake Superior SB GP • • SA NA: Northern Appalachian Mountains SA06 NR: Northern Rocky Mountains map projection = Albers Equal Area 50 0 50 100 200 300 400 miles • • PC: Pacific Coast SA07 SA: Southern Appalachian Mountains 50 0 50 100 200 300 400 kilometers •••••• SA08 SB: Southern Basin and Range •••• • •••• • SA09 •••••• SB25 •••• • SB26 National Mineral Resource Assessment, 1995

The tract ID is GB21 The Mark3 Index is 44: Massive sulfide, Sierran kuroko

There is a 90% or greater chance of 1 or more deposits. There is a 50% or greater chance of 3 or more deposits. There is a 10% or greater chance of 6 or more deposits. There is a 5% or greater chance of 7 or more deposits. There is a 1% or greater chance of 8 or more deposits.

Estimated amounts of contained metal and mineralized rock (metric tons)

quantile Cu Au Zn Ag Pb rock 0.95 0 0 0 0 0 0 0.90 770 0 0 0 0 95,000 0.50 25,000 2 28,000 55 2,500 1,500,000 0.10 92,000 15 255,000 820 60,000 5,600,000 0.05 120,000 20 380,000 1,400 100,000 6,900,000 mean 38,000 5 85,000 270 19,000 2,300,000

Probability of mean 0.38 0.32 0.27 0.25 0.23 0.37 Probability of zero 0.07 0.12 0.14 0.11 0.31 0.07

gb21 14/9/95 National Mineral Resource Assessment, 1995

The tract ID is GB21

Cumulative Distributions of Contained Metal and Mineralized Rock

1.00

Filled circles 0.90 display mean amounts 0.80

0.70

0.60

0.50

Probability 0.40 Cu rock 0.30 Au Ag Zn Pb 0.20

0.10

0.200 0.180 0.160 0.140 0.120 0.100 0.080 0.060 0.040 Proportion of Simulations 0.020 0.000 10 18 32 56 1.0 1.8 3.2 5.6 100 178 316 562 0.10 0.18 0.32 0.56 0.010 0.018 0.032 0.056 1,000 1,780 3,160 5,620 0.0018 0.0032 0.0056 10,000 17,800 31,600 56,200 100,000 178,000 316,000 562,000 1,000,000 1,780,000 3,160,000 5,620,000 10,000,000 17,800,000 31,600,000 56,200,000 100,000,000 178,000,000 316,000,000 562,000,000 1,000,000,000 1,780,000,000 3,160,000,000 5,620,000,000 10,000,000,000 17,800,000,000 31,600,000,000 56,200,000,000 100,000,000,000 178,000,000,000 See table for probability of zero tons

Cu Au Zn Ag Pb rock

gb21 14/9/95 USGS National Mineral Resource Assessment

2 1 3-6 QZAD: Epithermal vein deposits, quartz-adularia type PC19 1-2 NR21

1 PC21 2 PC22 PC23 NR22 NR24 PC20 PC24 NR25 1 PC25 NR23 PC26 2 3 1 5 4 6 7

8 11

9 Cumulative Distribution Histogram Table Model Mineral Deposits Rationale 10 QZAD 14 12 1 15 13 CR26 2 GB23 19 18 16 3 17 GB24 •••••• CR27 4 20 CR26 22 21 1 •••••• CR28 23 2 GB22 24 3 1 •••••• GB22 2 3 •••••• GB23 4 •••••• GB24 SB28 1 1 •••••• NR21 SB27 3 2 4 •••••• NR22 5 SB29 •••••• 7 CR27 NR23 10 8 6 •••••• NR24 9 1 2 •••••• 11 1 3 NR25 •••• • PC19 12 13 •••••• PC20 SB30 •••••• PC21 CR28 •••••• PC22 AD: Adirondack Mountains AD •••••• PC NR NA CP: Colorado Plateau PC23 LS CR: Central and Southern Rocky Mountains •••••• PC24 GB EC: East-central United States EC GB: Great Basin •••••• CR PC25 CP LS: Lake Superior •••••• SB GP NA: Northern Appalachian Mountains PC26 SA NR: Northern Rocky Mountains map projection = Albers Equal Area •••••• PC: Pacific Coast 50 0 50 100 200 300 400 miles SB27 SA: Southern Appalachian Mountains 50 0 50 100 200 300 400 kilometers •••••• SB28 SB: Southern Basin and Range •••••• •••••• SB29 •••••• SB30 knowndep • 12:17 PM • 6/5/96 National Assessment, 1995 SDL/DPC Conterminous United States Known Deposits

Map Alternative deposit Layer Tract Deposit District County State Lat Long Deposit Type No. types Epithermal vein, Rosebud Rosebud Pershing NV 40.800 -118.650 QZAD GB23 05 Comstock Epithermal vein, Seven Troughs Pershing NV 40.450 -118.790 QZAD GB23 06 Comstock Epithermal vein, Trinity Pershing NV 40.410 -118.590 QZAD GB23 07 Comstock Epithermal vein, Gooseberry Ramsey Storey NV 39.480 -119.460 QZAD GB23 08 Comstock Epithermal vein, Talapoosa Talapoosa Lyon NV 39.450 -119.270 QZAD GB23 09 Comstock Epithermal vein, Wonder Churchill NV 39.450 -118.050 QZAD GB23 10 Comstock Epithermal vein, Comstock Lode Storey NV 39.320 -119.590 QZAD GB23 11 Comstock Epithermal vein, Fairview Churchill NV 39.180 -118.130 QZAD GB23 12 Comstock Epithermal vein, quartz- Bruner Nye NV 39.080 -117.800 Epithermal vein, Sado QZAD GB23 13 adularia Epithermal vein, Rawhide - Regent Mineral NV 39.030 -118.420 QZAD GB23 14 Comstock Epithermal vein, Bovard - Rand Mineral NV 38.790 -118.400 QZAD GB23 15 Comstock Epithermal vein, Manhattan Nye NV 38.530 -117.060 QZAD GB23 16 Comstock Epithermal vein, Longstreet Nye NV 38.380 -116.710 QZAD GB23 17 Comstock Epithermal vein, Silver Star Mineral NV 38.340 -118.200 QZAD GB23 18 Comstock Epithermal vein, Aurora Mineral NV 38.290 -118.890 QZAD GB23 19 Comstock Epithermal vein, Tonopah Nye NV 38.070 -117.230 QZAD GB23 20 Comstock Epithermal vein, Divide Esmeralda NV 37.990 -117.240 QZAD GB23 21 Comstock Sixteen To One - Epithermal vein, Silver Peak Esmeralda NV 37.720 -117.780 QZAD GB23 22 Nivloc Comstock Epithermal vein, Delamar Lincoln NV 37.460 -114.770 QZAD GB23 23 Comstock Epithermal vein, Bullfrog Bullfrog Nye NV 36.900 -116.880 QZAD GB23 24 Comstock

Page 5 National Mineral Resource Assessment, 1995

The tract ID is GB23 The Mark3 Index is 16: Epithermal vein, Comstock

There is a 90% or greater chance of 14 or more deposits. There is a 50% or greater chance of 18 or more deposits. There is a 10% or greater chance of 24 or more deposits. There is a 5% or greater chance of 26 or more deposits. There is a 1% or greater chance of 29 or more deposits.

Estimated amounts of contained metal and mineralized rock (metric tons)

quantile Au Ag rock 0.95 77 2,300 11,000,000 0.90 130 4,400 19,000,000 0.50 340 18,000 60,000,000 0.10 840 73,000 152,000,000 0.05 1,100 110,000 190,000,000 mean 440 31,000 76,000,000

Probability of mean 0.37 0.31 0.41 Probability of zero 0.01 0.01 0.01

gb23 14/9/95 National Mineral Resource Assessment, 1995

The tract ID is GB23

Cumulative Distributions of Contained Metal and Mineralized Rock

1.00

Filled circles 0.90 display mean amounts 0.80

0.70

0.60

0.50

rock Probability 0.40 Au 0.30 Ag

0.20

0.10

0.300

0.250

0.200

0.150

0.100

Proportion of Simulations 0.050

Au Ag rock

gb23 14/9/95 USGS National Mineral Resource Assessment QZAL: Epithermal vein deposits, quartz-alunite type

NR26

GB26

1 GB27 2 CR29 GB25 SA10 1

1 SB33

Cumulative Distribution Histogram Table Model Mineral Deposits Rationale QZAL 2 SA12 CR29 SB32 SB34 1 CR30 •••••• CR30 •••••• GB25 SA11 •••••• GB26 •••••• GB27 •••••• NR26 SB35 •••••• SA10 •••••• SA11 AD: Adirondack Mountains PC AD •••••• NR NA CP: Colorado Plateau SA12 LS CR: Central and Southern Rocky Mountains •••••• GB EC: East-central United States SB32 EC CR GB: Great Basin •••••• SB33 CP LS: Lake Superior SB GP •••••• SA NA: Northern Appalachian Mountains SB34 NR: Northern Rocky Mountains map projection = Albers Equal Area •••••• PC: Pacific Coast 50 0 50 100 200 300 400 miles SB35 SA: Southern Appalachian Mountains 50 0 50 100 200 300 400 kilometers •••••• SB: Southern Basin and Range knowndep • 12:17 PM • 6/5/96 National Assessment, 1995 SDL/DPC Conterminous United States Known Deposits

Map Alternative deposit Layer Tract Deposit District County State Lat Long Deposit Type No. types Epithermal vein, quartz- Marysvale Piute UT 38.430 -112.330 QZAD GB24 01 adularia Epithermal vein, quartz- Escalante Washington UT 37.650 -113.810 QZAD GB24 02 adularia Epithermal vein, quartz- Goldstrike Washington UT 37.400 -113.930 QZAD GB24 03 adularia Epithermal vein, quartz- Freedom Flat Lucky Boy Mineral NV 38.380 -118.770 QZAL GB26 01 alunite Epithermal vein, quartz- Goldfield Esmeralda NV 37.710 -117.210 QZAL GB26 02 alunite HTSG GB28 01 Buckskin National National Humboldt NV 41.790 -117.540 Hot spring Au-Ag HTSG GB28 02 Sleeper Awakening Humboldt NV 41.330 -118.050 Hot spring AuAg HTSG GB28 03 Western Hog Ranch Leadville Washoe NV 41.160 -119.450 Hot spring Au-Ag HTSG GB28 04 Ivanhoe Ivanhoe Elko NV 41.110 -116.560 Hot spring Au-Ag HTSG GB28 05 Crofoot - Lewis Sulphur Humboldt NV 40.860 -118.690 Hot spring Au-Ag HTSG GB28 06 Mule Canyon Beowave Lander NV 40.600 -116.683 Hot spring Au-Ag HTSG GB28 07 Florida Canyon Imlay Pershing NV 40.580 -118.240 Hot spring Au-Ag HTSG GB28 08 Wind Mountain San Emidio Washoe NV 40.430 -119.390 Hot spring Au-Ag HTSG GB28 09 Buckhorn Buckhorn Eureka NV 40.180 -116.490 Hot spring Au-Ag HTSG GB28 10 Dixie Comstock Dixie Valley Churchill NV 39.870 -118.020 Hot spring Au-Ag HTSG GB28 11 Paradise Peak Fairplay Nye NV 38.750 -117.970 Hot spring Au-Ag HTSG GB28 12 Ketchup Flat Fairplay Nye NV 38.733 -117.958 Hot spring Au-Ag HTSG GB28 13 Round Mountain Round Mountain Nye NV 38.700 -117.080 Hot spring Au-Ag HTSG GB28 14 Santa Fe Gold Santa Fe Mineral NV 38.550 -118.170 Hot spring Au-Ag HTSG GB28 15 Atlanta Atlanta Lincoln NV 38.470 -114.320 Hot spring AuAg HTSG GB28 16 Borealis Lucky Boy Mineral NV 38.380 -118.760 Hot spring Au-Ag HTSG GB28 17 Tonopah Hasbrouck Divide Esmeralda NV 37.990 -117.270 Hot spring Au-Ag SEDG GB30 01 Big Springs Birch Creek Elko NV 41.550 -115.980 Sediment-hosted Au SEDG GB30 02 Winters Creek Burns Basin Elko NV 41.450 -115.950 Sediment-hosted Au SEDG GB30 03 Wright Window Burns Basin Elko NV 41.400 -116.069 Sediment-hosted Au Burns Basin-Jerritt Burns Basin Elko NV 41.340 -116.010 Sediment-hosted Au SEDG GB30 04 Canyon Twin Creeks (Chimney SEDG GB30 05 Creek and Rabbit Potosi Humboldt NV 41.280 -117.170 Sediment-hosted Au Creek)

Page 6 National Mineral Resource Assessment, 1995

The tract ID is GB26 The Mark3 Index is 38: Epithermal vein, quartz-alunite

There is a 90% or greater chance of 2 or more deposits. There is a 50% or greater chance of 5 or more deposits. There is a 10% or greater chance of 9 or more deposits. There is a 5% or greater chance of 12 or more deposits. There is a 1% or greater chance of 15 or more deposits.

Estimated amounts of contained metal and mineralized rock (metric tons)

quantile Cu Au Ag rock 0.95 10 7 14 1,400,000 0.90 110 28 69 4,400,000 0.50 60,000 160 820 22,000,000 0.10 460,000 440 2,520 50,000,000 0.05 690,000 550 3,200 60,000,000 mean 160,000 200 1,100 25,000,000

Probability of mean 0.30 0.39 0.40 0.43 Probability of zero 0.04 0.04 0.04 0.04

gb26 14/9/95 National Mineral Resource Assessment, 1995

The tract ID is GB26

Cumulative Distributions of Contained Metal and Mineralized Rock

1.00

Filled circles 0.90 display mean amounts 0.80

0.70

0.60

0.50 rock Probability 0.40 Au Ag

0.30 Cu

0.20

0.10

0.300

0.250

0.200

0.150

0.100

Proportion of Simulations 0.050

Cu Au Ag rock

gb26 14/9/95 USGS National Mineral Resource Assessment

NR27 HTSG: Hot-spring Au-Ag deposits 1

2 PC29 NR28 PC31 1 NR30 PC28 1 2 1 PC30 NR31 1 1 2 3 Cumulative Distribution Histogram Table Model Mineral Deposits Rationale HTSG PC32 PC33 1 NR29 CR31 2 3 5 2 ••••• • 4 CR32 8 7 6 •••• • GB28 1 10 9 3 2 GB28 •••••• GB29

11-12 •••• • NR27 16 14 13 15 GB29 ••• • • NR28 PC34 17 •••••• NR29 •••• • NR30 CR31 •••••• SA13 NR31 1 ••••• • PC28 2 SB36 SB38 1 2 •••••• PC29 SA161 •••• • PC30 SB39 SA17 3 •••••• 4 PC31 PC35 1 2 CR32 ••• ••• 3 PC32 SA14 •••••• PC33 SB37 SA15 ••• • • PC34 •••••• PC35 •••• • SA13 ••• • • SA14 AD AD: Adirondack Mountains PC • • NR NA CP: Colorado Plateau SA15 LS CR: Central and Southern Rocky Mountains •••••• GB EC: East-central United States SA16 EC CR GB: Great Basin •••• • SA17 CP LS: Lake Superior SB GP ••• ••• SA NA: Northern Appalachian Mountains SB36 NR: Northern Rocky Mountains map projection = Albers Equal Area •••••• PC: Pacific Coast SB37 50 0 50 100 200 300 400 miles SA: Southern Appalachian Mountains •••••• 50 0 50 100 200 300 400 kilometers SB38 SB: Southern Basin and Range •••• • • • SB39 knowndep • 12:17 PM • 6/5/96 National Assessment, 1995 SDL/DPC Conterminous United States Known Deposits

Page 6 National Mineral Resource Assessment, 1995

The tract ID is GB28 The Mark3 Index is 45: Hot spring Au-Ag

There is a 90% or greater chance of 13 or more deposits. There is a 50% or greater chance of 18 or more deposits. There is a 10% or greater chance of 21 or more deposits. There is a 5% or greater chance of 25 or more deposits. There is a 1% or greater chance of 29 or more deposits.

Estimated amounts of contained metal and mineralized rock (metric tons)

quantile Au Ag rock 0.95 220 610 150,000,000 0.90 340 1,100 240,000,000 0.50 740 2,800 540,000,000 0.10 1,300 6,100 980,000,000 0.05 1,600 7,400 1,100,000,000 mean 800 3,300 580,000,000

Probability of mean 0.44 0.40 0.45 Probability of zero 0.01 0.01 0.01

gb28 14/9/95 National Mineral Resource Assessment, 1995

The tract ID is GB28

Cumulative Distributions of Contained Metal and Mineralized Rock

1.00

Filled circles 0.90 display mean amounts 0.80

0.70

0.60

0.50 Au rock

Probability 0.40 Ag

0.30

0.20

0.10

0.450

0.400 0.350

0.300

0.250

0.200

0.150 0.100 Proportion of Simulations 0.050

Au Ag rock

gb28 14/9/95 USGS National Mineral Resource Assessment

NR32 SEDG: Sediment-hosted Au deposits

NA17 GB30 5-7 1-4 1 11 8-10 12-24 36 30 25-27 31-36 44 37 28-29 41 2-3 38 43 39-40 52 45 42 46-4749 48 4 51 50 54 53 GB31

SB40

Cumulative Distribution Histogram Table Model Mineral Deposits Rationale SEDG •••••• GB30 •••••• GB31 •••••• NA17 •••••• NR32 •••••• SB40

AD AD: Adirondack Mountains PC NR NA CP: Colorado Plateau LS CR: Central and Southern Rocky Mountains GB EC: East-central United States EC CR GB: Great Basin CP LS: Lake Superior GP SB NA: Northern Appalachian Mountains SA map projection = Albers Equal Area NR: Northern Rocky Mountains 50 0 50 100 200 300 400 miles PC: Pacific Coast 50 0 50 100 200 300 400 kilometers SA: Southern Appalachian Mountains SB: Southern Basin and Range knowndep • 12:17 PM • 6/5/96 National Assessment, 1995 SDL/DPC Conterminous United States Known Deposits

Page 6 knowndep • 12:17 PM • 6/5/96 National Assessment, 1995 SDL/DPC Conterminous United States Known Deposits

Map Alternative deposit Layer Tract Deposit District County State Lat Long Deposit Type No. types SEDG GB30 06 Getchell Potosi Humboldt NV 41.210 -117.260 Sediment-hosted Au SEDG GB30 07 Pinson Potosi Humboldt NV 41.130 -117.270 Sediment-hosted Au SEDG GB30 08 Dee Bootstrap Elko NV 41.030 -116.430 Sediment-hosted Au SEDG GB30 09 Bootstrap/Capstone Bootstrap Elko NV 41.020 -116.420 Sediment-hosted Au SEDG GB30 10 Meikle Bootstrap Elko NV 41.010 -116.360 Sediment-hosted Au SEDG GB30 11 Preble Potosi Humboldt NV 41.000 -117.390 Sediment-hosted Au SEDG GB30 12 Goldstrike-Post Bluestar-Goldstrike Eureka NV 40.977 -116.358 Sediment-hosted Au SEDG GB30 13 North Star Bluestar-Goldstrike Eureka NV 40.962 -116.362 Sediment-hosted Au SEDG GB30 14 Deepstar Bluestar-Goldstrike Eureka NV 40.962 -116.353 Sediment-hosted Au SEDG GB30 15 Bobcat Bluestar-Goldstrike Eureka NV 40.960 -116.353 Sediment-hosted Au SEDG GB30 16 Genesis - Blue Star Bluestar-Goldstrike Eureka NV 40.952 -116.352 Sediment-hosted Au SEDG GB30 17 Lantern Lynn Eureka NV 40.923 -116.333 Sediment-hosted Au Universal Gas (Bullion Lynn Eureka NV 40.920 -116.330 Sediment-hosted Au SEDG GB30 18 Monarch) SEDG GB30 19 Carlin Lynn Eureka NV 40.912 -116.320 Sediment-hosted Au SEDG GB30 20 Pete Lynn Eureka NV 40.910 -116.313 Sediment-hosted Au SEDG GB30 21 Tusc Maggie Creek Eureka NV 40.833 -116.233 Sediment-hosted Au SEDG GB30 22 Mac Maggie Creek Eureka NV 40.828 -116.232 Sediment-hosted Au SEDG GB30 23 Gold Quarry Maggie Creek Eureka NV 40.825 -116.225 Sediment-hosted Au SEDG GB30 24 Maggie Creek Maggie Creek Eureka NV 40.825 -116.225 Sediment-hosted Au SEDG GB30 25 Emigrant Rain Elko NV 40.620 -115.970 Sediment-hosted Au SEDG GB30 26 Rain - SMZ Rain Elko NV 40.610 -116.010 Sediment-hosted Au SEDG GB30 27 Gnome Rain Elko NV 40.600 -116.110 Sediment-hosted Au Piñon Range - Cord Elko NV 40.458 -115.844 Sediment-hosted Au SEDG GB30 28 Ranch SEDG GB30 29 Dark Star Elko NV 40.458 -115.844 Sediment-hosted Au SEDG GB30 30 Horse Canyon Cortez Lander NV 40.410 -116.920 Sediment-hosted Au SEDG GB30 31 Robertson Lander NV 40.310 -116.694 Sediment-hosted Au SEDG GB30 32 Elder Creek Lander NV 40.308 -116.850 Sediment-hosted Au SEDG GB30 33 Cortez Cortez Bullion Lander NV 40.260 -116.740 Sediment-hosted Au SEDG GB30 34 Pipeline Lander NV 40.255 -116.740 Sediment-hosted Au SEDG GB30 35 South Pipeline Lander NV 40.248 -116.740 Sediment-hosted Au SEDG GB30 36 Relief Canyon Antelope Springs Pershing NV 40.210 -118.170 Sediment-hosted Au Page 7 knowndep • 12:17 PM • 6/5/96 National Assessment, 1995 SDL/DPC Conterminous United States Known Deposits

Map Alternative deposit Layer Tract Deposit District County State Lat Long Deposit Type No. types SEDG GB30 37 Cortez Cortez Eureka NV 40.150 -116.580 Sediment-hosted Au Saddle (Toiyabe Lander NV 40.030 -116.710 Sediment-hosted Au SEDG GB30 38 project) SEDG GB30 39 Bald Mountain Bald Mountain White Pine NV 39.960 -115.590 Sedimenthosted Au SEDG GB30 40 Little Bald Mountain Bald Mountain White Pine NV 39.920 -115.550 Sediment-hosted Au SEDG GB30 41 Tonkin Springs Tonkin Springs Eureka NV 39.900 -116.430 Sediment-hosted Au SEDG GB30 42 Golden Butte Cherry Creek White Pine NV 39.830 -115.050 Sediment-hosted Au SEDG GB30 43 Gold Pick Antelope Eureka NV 39.800 -116.330 Sediment-hosted Au SEDG GB30 44 Fondaway Canyon Churchill NV 39.800 -118.200 Sediment-hosted Au SEDG GB30 45 Alligator Ridge Alligator Ridge White Pine NV 39.760 -115.520 Sediment-hosted Au SEDG GB30 46 Gold Canyon Roberts Eureka NV 39.760 -116.170 Sediment-hosted Au SEDG GB30 47 Gold Bar Roberts Eureka NV 39.750 -116.200 Sediment-hosted Au SEDG GB30 48 Yankee Alligator Ridge White Pine NV 39.690 -115.530 Sediment-hosted Au Easy Junior - White Pine NV 39.450 -115.880 Sediment-hosted Au SEDG GB30 49 Nighthawk Ridge SEDG GB30 50 Pan White Pine NV 39.411 -115.676 Sediment-hosted Au SEDG GB30 51 Ratto Canyon Eureka Eureka NV 39.400 -115.990 Sediment-hosted Au SEDG GB30 52 Austin Gold Venture Lander NV 39.380 -117.090 Sediment-hosted Au SEDG GB30 53 Green Springs White Pine White Pine NV 39.140 -115.550 Sediment-hosted Au SEDG GB30 54 Northumberland Northumberland Nye NV 38.960 -116.860 Sediment-hosted Au SEDG GB30 55 Mother Lode Bare Mountain Nye NV 36.910 -116.650 Sediment-hosted Au SEDG GB31 01 Black Pine (Tallman) Black Pine Cassia ID 42.078 -113.042 Sediment-hosted Au SEDG GB31 02 Barney's Canyon Barney's Canyon Salt Lake UT 40.610 -112.160 Sediment-hosted Au SEDG GB31 03 Melco Melco Salt Lake UT 40.600 -112.170 Sediment-hosted Au SEDG GB31 04 Mercur Mercur Tooele UT 40.320 -112.240 Sediment-hosted Au Silver Reef Sediment-hosted Cu, Washington UT 37.250 -113.370 SCU3 GB32 01 (Harrisonburg) redbed Sediment-hosted Cu, Mangum Greer OK 34.830 -99.530 SCU1 GP04 01 reduced facies Sediment-hosted Cu, Creta Jackson OK 34.500 -99.500 SCU1 GP04 02 reduced facies Lafayette, Grant, Upper Mississippi IL, WI, Southeast Missouri Pb- Green, Jo Daviess, 42.450 -90.420 Mississippi Valley MVTD GP05 01 Valley IA Zn Dubuque

Page 8 National Mineral Resource Assessment, 1995

The tract ID is GB30 The Mark3 Index is 17: Sediment-hosted Au

There is a 90% or greater chance of 15 or more deposits. There is a 50% or greater chance of 21 or more deposits. There is a 10% or greater chance of 27 or more deposits. There is a 5% or greater chance of 30 or more deposits. There is a 1% or greater chance of 33 or more deposits.

Estimated amounts of contained metal and mineralized rock (metric tons)

quantile Au Ag rock 0.95 220 0 98,000,000 0.90 340 0 150,000,000 0.50 1,000 7 540,000,000 0.10 2,700 26 1,200,000,000 0.05 3,400 33 1,400,000,000 mean 1,300 11 610,000,000

Probability of mean 0.38 0.40 0.43 Probability of zero 0.01 0.22 0.01

gb30 14/9/95 National Mineral Resource Assessment, 1995

The tract ID is GB30

Cumulative Distributions of Contained Metal and Mineralized Rock

1.00

Filled circles 0.90 display mean amounts 0.80

0.70

0.60

0.50 rock

Probability 0.40 Ag Au

0.30

0.20

0.10

0.350

0.300

0.250

0.200

0.150

0.100

Proportion of Simulations 0.050

Au Ag rock

gb30 14/9/95 USGS National Mineral Resource Assessment

NR32 SEDG: Sediment-hosted Au deposits

NA17 GB30 5-7 1-4 1 11 8-10 12-24 36 30 25-27 31-36 44 37 28-29 41 2-3 38 43 39-40 52 45 42 46-4749 48 4 51 50 54 53 GB31

SB40

Cumulative Distribution Histogram Table Model Mineral Deposits Rationale SEDG •••••• GB30 •••••• GB31 •••••• NA17 •••••• NR32 •••••• SB40

Page 8 National Mineral Resource Assessment, 1995

The tract ID is GB31 The Mark3 Index is 17: Sediment-hosted Au

There is a 90% or greater chance of 1 or more deposits. There is a 50% or greater chance of 2 or more deposits. There is a 10% or greater chance of 6 or more deposits. There is a 5% or greater chance of 9 or more deposits. There is a 1% or greater chance of 16 or more deposits.

Estimated amounts of contained metal and mineralized rock (metric tons)

quantile Au Ag rock 0.95 0 0 0 0.90 3 0 1,300,000 0.50 59 0 26,000,000 0.10 570 6 375,000,000 0.05 1,000 13 500,000,000 mean 210 2 99,000,000

Probability of mean 0.22 0.20 0.21 Probability of zero 0.07 0.79 0.07

gb31 14/9/95 National Mineral Resource Assessment, 1995

The tract ID is GB31

Cumulative Distributions of Contained Metal and Mineralized Rock

1.00

Filled circles 0.90 display mean amounts 0.80

0.70

0.60

0.50

Probability 0.40

0.30

0.20 Ag Au rock

0.10

0.160

0.140

0.120

0.100

0.080

0.060

0.040

Proportion of Simulations 0.020

Au Ag rock

gb31 14/9/95 NR08 1 1 2 USGS National Mineral Resource Assessment 4 3 5 6-7 PCU2: Porphyry Cu deposits II

1 NR10 PC04 1 NA03 2 PC06 2

PC05 NR09 PC07 GB09 NR11

1 GB11 1

GB12

CR09

Cumulative Distribution Histogram Table Model Mineral Deposits Rationale PCU2 CR09 SB08 •••••• CR10 •••••• GB09 CR10 •••••• GB11 •••••• GB12 •••••• NA03 SB16 •••••• NR08 •••••• NR09 •••••• NR10 •••••• NR11 AD AD: Adirondack Mountains •••••• PC NR NA CP: Colorado Plateau PC04 LS CR: Central and Southern Rocky Mountains •••••• PC05 GB EC: East-central United States EC •••••• CR GB: Great Basin PC06 CP LS: Lake Superior SB GP •••••• PC07 SA NA: Northern Appalachian Mountains NR: Northern Rocky Mountains map projection = Albers Equal Area •••••• SB08 PC: Pacific Coast 50 0 50 100 200 300 400 miles SA: Southern Appalachian Mountains 50 0 50 100 200 300 400 kilometers •••••• SB16 SB: Southern Basin and Range •••••• knowndep • 12:17 PM • 6/5/96 National Assessment, 1995 SDL/DPC Conterminous United States Known Deposits

Map Alternative deposit Layer Tract Deposit District County State Lat Long Deposit Type No. types NONE NONE 31 Baxter Springs Manhattan Nye NV 38.440 -117.120 Unclassified NONE NONE 32 Apex Washington UT 37.067 -113.802 Kipushi Cu-Pb-Zn NONE NONE 33 Daisy Gold Nye NV 36.890 -116.680 Unclassified NONE NONE 34 Sterling Fluorine Nye NV 36.830 -116.640 Unclassified NONE NONE 35 Colosseum Clark San Bernardino CA 35.622 -115.569 Breccia pipe, Au NONE NONE 36 Morning Star Ivanpah San Bernardino CA 35.360 -115.490 Unclassified Flat fault Au NONE NONE 37 Zenda Loraine Kern CA 35.291 -118.465 Unclassified NONE NONE 38 San Lazarus Old Placers Santa Fe NM 35.239 -106.176 Unclassified NONE NONE 39 America San Bernardino CA 34.400 -115.580 Unclassified Vein, polyetallic NONE NONE 40 Waters Sunset Yavapai AZ 34.358 -113.215 Unclassified NONE NONE 41 Clementine unk AZ 33.813 -112.313 Unclassified NONE NONE 42 Big Horn Alamo Spring La Paz AZ 33.430 -113.860 Unclassified NONE NONE 43 Oro Cruz Tumco Imperial CA 32.867 -114.800 Unclassified NONE NONE 44 American Girl Cargo Muchacho Imperial CA 32.790 -114.765 Unclassified Flat fault Au NONE NONE 45 Van Horn-Allamoore Culberson TX 31.170 -104.900 Unclassified Vein, polymetallic Buckhorn Mountain Meyers Creek Okanogan WA 48.956 -118.983 Skarn Au SKNG NR05 01 (Crown Jewel) SKNG NR07 01 Diamond Hill Indian Creek (Hassel) Broadwater MT 46.313 -111.675 Skarn Au SKNG NR07 02 Elkhorn Elkhorn Jefferson MT 46.278 -111.941 Skarn Au SKNG NR07 03 Cable Georgetown (Cable) Deer Lodge MT 46.200 -113.216 Skarn Au SKNG NR07 04 Butte Highlands Highland Silver Bow MT 45.797 -112.516 Skarn Au SKNG NR07 05 Bannack district Bannack Beaverhead MT 45.155 -112.985 Skarn Au SKNG NR07 06 New World New World Park MT 45.060 -109.960 Skarn Au PCU2 NR08 01 Kelsey unnamed Okanogan WA 48.995 -119.478 Porphyry Cu PCU2 NR10 01 Heddleston Heddleston Lewis and Clark MT 47.026 -112.360 Porphyry Cu-Mo PCU2 NR10 02 Continental Berkeley Butte Silver Bow MT 46.020 -112.526 Porphyry Cu-Mo PMR1 NR12 01 Clayton Silver Bayhorse Custer ID 44.283 -114.410 Polymetallic replacement PMR1 NR13 01 Garnet (First Chance) Granite MT 46.827 -113.343 Polymetallic replacement Vein, polymetallic PMR1 NR13 02 Castle Mountain Meagher MT 46.470 -110.680 Polymetallic replacement PMR1 NR13 03 Hope Philipsburg Granite MT 46.344 -113.274 Polymetallic replacement Scratch Awl - True Philipsburg Granite MT 46.332 -113.266 Polymetallic replacement Vein, polymetallic PMR1 NR13 04 Fissure PMR1 NR13 05 Trout Philipsburg Granite MT 46.329 -113.267 Polymetallic replacement Vein, polymetallic Page 12 National Mineral Resource Assessment, 1995

The tract ID is NR10 The Mark3 Index is 81: Porphyry Cu (North America)

There is a 90% or greater chance of 0 or more deposits. There is a 50% or greater chance of 1 or more deposits. There is a 10% or greater chance of 3 or more deposits. There is a 5% or greater chance of 6 or more deposits. There is a 1% or greater chance of 7 or more deposits.

Estimated amounts of contained metal and mineralized rock (metric tons)

quantile Cu Mo Au Ag rock 0.95 0 0 0 0 0 0.90 0 0 0 0 0 0.50 610,000 1,900 0 0 130,000,000 0.10 11,000,000 180,000 88 2,900 2,000,000,000 0.05 19,000,000 340,000 170 5,300 3,300,000,000 mean 3,700,000 73,000 35 980 660,000,000

Probability of mean 0.24 0.20 0.19 0.21 0.26 Probability of zero 0.31 0.48 0.57 0.55 0.31

nr10 12/9/95 National Mineral Resource Assessment, 1995

The tract ID is NR10

Cumulative Distributions of Contained Metal and Mineralized Rock

1.00

Filled circles 0.90 display mean amounts 0.80

0.70

0.60

0.50

Probability 0.40

0.30 Cu rock 0.20 Au Ag Mo

0.10

0.120

0.100

0.080

0.060

0.040

Proportion of Simulations 0.020

Cu Mo Au Ag rock

nr10 12/9/95 USGS National Mineral Resource Assessment PMR1: Polymetallic replacement deposits I

2-5 6 2 8 7 NR13 NR12 9 1

GB15

1 4 5

GB16 1 2 2 6 3 GB14 1 2 CR15

3 1 1

SB19 Cumulative Distribution Histogram Table Model Mineral Deposits Rationale PMR1 CR18 CR15 SB18 •••••• CR18

1 •••••• CR19 SB20 1 •••••• GB14 2 1 •••••• 4 3 5 GB15 2 •••••• GB16 4 3 5 •••••• NR12 SB21 •••••• CR19 •••••• NR13 AD: Adirondack Mountains SB18 PC AD 1 NR NA CP: Colorado Plateau •••••• SB19 LS CR: Central and Southern Rocky Mountains GB EC: East-central United States •••••• SB20 EC CR GB: Great Basin CP •••••• LS: Lake Superior SB21 GP SB NA: Northern Appalachian Mountains SA map projection = Albers Equal Area •••••• NR: Northern Rocky Mountains 50 0 50 100 200 300 400 miles PC: Pacific Coast 50 0 50 100 200 300 400 kilometers SA: Southern Appalachian Mountains SB: Southern Basin and Range knowndep • 12:17 PM • 6/5/96 National Assessment, 1995 SDL/DPC Conterminous United States Known Deposits

Map Alternative deposit Layer Tract Deposit District County State Lat Long Deposit Type No. types PMR1 NR13 06 Elkhorn (Holter) Elkhorn Jefferson MT 46.282 -111.953 Polymetallic replacement PMR1 NR13 07 Silver Star - Iron Rod Madison MT 45.696 -112.314 Polymetallic replacement PMR1 NR13 08 Hecla (Bryant) Beaverhead MT 45.605 -112.913 Polymetallic replacement PMR1 NR13 09 Argenta (Montana) Beaverhead MT 45.335 -112.904 Polymetallic replacement Vein, polymetallic Little Rocky Zortman - Landusky Phillips MT 47.929 -108.586 Alkaline Au-Te ALKG NR15 01 Mountains Canyon Resources Kendall Fergus MT 47.294 -109.459 Alkaline Au-Te ALKG NR15 02 (Kendall) Warm Springs Spotted Horse Fergus MT 47.176 -109.210 Alkaline Au-Te ALKG NR15 03 (Maiden) Warm Springs Maginnis Fergus MT 47.176 -109.219 Alkaline Au-Te ALKG NR15 04 (Maiden) Warm Springs (Gilt Gilt Edge Fergus MT 47.144 -109.226 Alkaline Au-Te ALKG NR15 05 Edge) ALKG NR15 06 Golden Sunlight Whitehall Jefferson MT 45.906 -112.014 Alkaline Au-Te ALKG NR16 01 Richmond Hill Carbonate Lawrence SD 44.383 -103.856 Alkaline Au-Te ALKG NR16 02 Johnson Gulch Ragged Top Lawrence SD 44.350 -103.900 Alkaline Au-Te ALKG NR16 03 Wharf Bald Mountain Lawrence SD 44.344 -103.842 Alkaline Au-Te ALKG NR16 04 Golden Reward Bald Mountain Lawrence SD 44.331 -103.806 Alkaline AuTe ALKG NR16 05 Gilt Edge Gilt Edge Lawrence SD 44.328 -103.764 Alkaline Au-Te Epithermal vein, Orient Orient Stevens WA 48.884 -118.159 Hot spring Au-Ag QZAD NR21 01 Comstock Epithermal vein, Kettle River Republic Ferry WA 48.879 -118.626 Hot spring Au-Ag QZAD NR21 02 Comstock Epithermal vein, Golden Eagle Republic Ferry WA 48.680 -118.759 Hot spring Au-Ag QZAD NR21 03 Comstock Knob Hill-Golden Epithermal vein, Republic Ferry WA 48.673 -118.758 Hot spring Au-Ag QZAD NR21 04 Promise Comstock Epithermal vein, Last Chance Republic Ferry WA 48.668 -118.755 Hot spring Au-Ag QZAD NR21 05 Comstock Epithermal vein, Republic Republic Ferry WA 48.638 -118.745 Hot spring Au-Ag QZAD NR21 06 Comstock Epithermal vein, quartz- Seven-Up Pete Seven-Up Pete Lewis and Clark MT 46.972 -112.530 QZAD NR24 01 adularia Basin Creek (Paupers Epithermal vein, quartz- Rimini (Vaughn) Lewis and Clark MT 46.420 -112.290 Hot-Spring Au-Ag QZAD NR24 02 Dream) adularia HTSG NR28 01 Thunder Mountain Thunder Mountain Valley ID 44.958 -115.142 Hot spring Au-Ag

Page 13 National Mineral Resource Assessment, 1995

The tract ID is NR13 The Mark3 Index is 47: Polymetallic replacement

There is a 90% or greater chance of 1 or more deposits. There is a 50% or greater chance of 4 or more deposits. There is a 10% or greater chance of 6 or more deposits. There is a 5% or greater chance of 8 or more deposits. There is a 1% or greater chance of 12 or more deposits.

Estimated amounts of contained metal and mineralized rock (metric tons)

quantile Cu Au Zn Ag Pb rock 0.95 0 0 0 0 0 0 0.90 0 0 9,200 43 27,000 550,000 0.50 19,000 4 740,000 2,200 660,000 15,000,000 0.10 140,000 42 3,500,000 13,000 3,400,000 62,000,000 0.05 230,000 73 5,200,000 20,000 5,100,000 82,000,000 mean 56,000 17 1,400,000 5,000 1,300,000 24,000,000

Probability of mean 0.26 0.22 0.32 0.30 0.30 0.34 Probability of zero 0.12 0.12 0.07 0.08 0.07 0.07

nr13 12/9/95 National Mineral Resource Assessment, 1995

The tract ID is NR13

Cumulative Distributions of Contained Metal and Mineralized Rock

1.00

Filled circles 0.90 display mean amounts 0.80

0.70

0.60

0.50

Probability 0.40 rock 0.30 Ag PbZn Cu 0.20 Au

0.10

0.180

0.160 0.140

0.120

0.100

0.080

0.060 0.040 Proportion of Simulations 0.020

Cu Au Zn Ag Pb rock

nr13 12/9/95 USGS National Mineral Resource Assessment NR14 ALKG: Alkaline Au-Te Deposits NR15 1 2

3-5

NR16 1-5

2 1 3 CR20 4

1 CR21

Cumulative Distribution Histogram Table Model Mineral Deposits Rationale ALKG 5 CR20 •••••• 1 CR21 •••••• CR22 2-4 •••••• NR14 •••• • NR15 CR22 5 •••••• NR16 6 ••••••

AD: Adirondack Mountains AD PC NR NA CP: Colorado Plateau LS CR: Central and Southern Rocky Mountains GB EC: East-central United States EC GB: Great Basin CR CP LS: Lake Superior SB GP NA: Northern Appalachian Mountains SA NR: Northern Rocky Mountains map projection = Albers Equal Area

PC: Pacific Coast 50 0 50 100 200 300 400 miles SA: Southern Appalachian Mountains 50 0 50 100 200 300 400 kilometers SB: Southern Basin and Range National Mineral Resource Assessment, 1995

The tract ID is NR15 The Mark3 Index is 80: Alkaline Au-Te

There is a 90% or greater chance of 1 or more deposits. There is a 50% or greater chance of 6 or more deposits. There is a 10% or greater chance of 11 or more deposits. There is a 5% or greater chance of 12 or more deposits. There is a 1% or greater chance of 20 or more deposits.

Estimated amounts of contained metal and mineralized rock (metric tons)

quantile Au Ag rock 0.95 0 0 0 0.90 5 0 590,000 0.50 310 180 74,000,000 0.10 1,800 830 263,000,000 0.05 2,600 1,200 320,000,000 mean 680 340 110,000,000

Probability of mean 0.31 0.32 0.40 Probability of zero 0.06 0.10 0.06

nr15 12/9/95 National Mineral Resource Assessment, 1995

The tract ID is NR15

Cumulative Distributions of Contained Metal and Mineralized Rock

1.00

Filled circles 0.90 display mean amounts 0.80

0.70

0.60

0.50

Probability 0.40 rock

0.30 AgAu

0.20

0.10

Au Ag rock

nr15 12/9/95 USGS National Mineral Resource Assessment

NR27 HTSG: Hot-spring Au-Ag deposits 1

Page 13 knowndep • 12:17 PM • 6/5/96 National Assessment, 1995 SDL/DPC Conterminous United States Known Deposits

Map Alternative deposit Layer Tract Deposit District County State Lat Long Deposit Type No. types Sunbeam-Grouse Epithermal vein, Yankee Fork Custer ID 44.439 -114.736 Hot spring Au-Ag HTSG NR28 02 Creek Comstock Epithermal vein, Champagne Lava Creek Butte ID 43.594 -113.571 Hot spring Au-Ag HTSG NR28 03 Comstock Hog Heaven Flathead MT 47.923 -114.582 Hot spring Au-Ag (Pb) HTSG NR30 01 (Flathead) Epithermal vein, quartz- McDonald Meadows Seven-Up Pete Lewis and Clark MT 47.000 -112.525 Hot spring Au-Ag HTSG NR30 02 adularia Cabinet Mountains Sediment-hosted Cu, Troy (Spar Lake) Lincoln MT 48.230 -115.860 SCU1 NR37 01 area Revett Rock Lake Cabinet Mountains Sediment-hosted Cu, Sanders MT 48.080 -115.640 SCU1 NR37 02 (Montanore) area Revett Cabinet Mountains Sediment-hosted Cu, Rock Creek Sanders MT 48.070 -115.660 SCU1 NR37 03 area Revett Sediment-hosted Cu, Snowstorm Coeur d'Alene Shoshone ID 47.467 -115.733 SCU1 NR37 04 Revett Sedimentary exhalative Sheep Creek Meagher MT 46.750 -110.680 Massive sulfide, Besshi SEDX NR39 01 Zn-Pb (Cu-Co rich) Sedimentary exhalative Polymetallic replacement Triumph Warm Springs Blaine ID 43.665 -114.284 SEDX NR40 01 Zn-Pb and veins MVTD NR43 01 Yellowhead Metaline Pend Oreille WA 48.883 -117.371 Mississippi Valley Irish Sedex Pb-Zn MVTD NR43 02 Pend Oreille Metaline Pend Oreille WA 48.882 -117.360 Mississippi Valley Irish Sedex Pb-Zn MVTD NR43 03 Van Stone Bossburg Stevens WA 48.761 -117.757 Mississippi Valley Irish Sedex Pb-Zn South Pass-Atlantic Low-sulfide Au-quartz Fremont WY 42.500 -108.700 HMAS NR47 01 City and Lewiston vein, Archean HMAS NR48 01 Mineral Hill Sheepeater (Jardine) Park MT 45.080 -110.620 Homestake stratiform Au HMAS NR49 01 Homestake Homestake Lawrence SD 44.360 -103.770 Homestake stratiform Au Homestake stratiform Cloverleaf Roubaix Lawrence SD 44.283 -103.650 HMAS NR49 02 Au? PCU2 PC04 01 Mazama Mazama Okanogan WA 48.615 -120.382 Porphyry Cu PCU2 PC04 02 Gold Mountain Snohomish WA 48.216 -121.334 Porphyry Cu PCU2 PC04 03 Glacier Peak Sampson Snohomish WA 48.198 -120.979 Porphyry Cu Porphyry Cu, breccia Sunrise Sultan Basin Snohomish WA 48.009 -121.504 PCU2 PC04 04 pipe Porphyry Cu, breccia North Fork Snoqualmie King WA 47.669 -121.636 PCU2 PC04 05 pipe Clipper - Three Middle Fork King WA 47.518 -121.344 Porphyry Cu PCU2 PC04 06 Brothers Snoqualmie

Page 14 National Mineral Resource Assessment, 1995

The tract ID is NR28 The Mark3 Index is 45: Hot spring Au-Ag

There is a 90% or greater chance of 0 or more deposits. There is a 50% or greater chance of 2 or more deposits. There is a 10% or greater chance of 5 or more deposits. There is a 5% or greater chance of 7 or more deposits. There is a 1% or greater chance of 8 or more deposits.

Estimated amounts of contained metal and mineralized rock (metric tons)

quantile Au Ag rock 0.95 0 0 0 0.90 0 0 0 0.50 56 150 38,000,000 0.10 320 1,300 250,000,000 0.05 450 2,000 340,000,000 mean 120 480 82,000,000

Probability of mean 0.32 0.31 0.31 Probability of zero 0.21 0.34 0.21

nr28 12/9/95 National Mineral Resource Assessment, 1995

The tract ID is NR28

Cumulative Distributions of Contained Metal and Mineralized Rock

1.00

Filled circles 0.90 display mean amounts 0.80

0.70

0.60

0.50

Probability 0.40

0.30 Au Ag rock

0.20

0.10

0.160

0.140

0.120

0.100

0.080

0.060

0.040

Proportion of Simulations 0.020

Au Ag rock

nr28 12/9/95 USGS National Mineral Resource Assessment 1 SCU1: Sediment-hosted Cu deposits I 2-3 4 NR37

NA19

SA18

LS06

CR33

CP02 Cumulative Distribution Histogram Table Model Mineral Deposits Rationale SCU1 CP02 •••••• CR33 1 2 •••••• GP03 •••••• GP04 GP04 •••••• LS06 GP03 •••••• NA19 •••••• NR37 •••••• SA18 AD: Adirondack Mountains AD •••••• PC NR NA CP: Colorado Plateau LS CR: Central and Southern Rocky Mountains GB EC: East-central United States EC CR GB: Great Basin CP LS: Lake Superior SB GP NA: Northern Appalachian Mountains SA map projection = Albers Equal Area NR: Northern Rocky Mountains 50 0 50 100 200 300 400 miles PC: Pacific Coast 0 50 100 200 300 400 kilometers SA: Southern Appalachian Mountains 50 SB: Southern Basin and Range knowndep • 12:17 PM • 6/5/96 National Assessment, 1995 SDL/DPC Conterminous United States Known Deposits

Page 14 National Mineral Resource Assessment, 1995

The tract ID is NR37 The Mark3 Index is 64: Sediment-hosted Cu, Revett

There is a 90% or greater chance of 9 or more deposits. There is a 50% or greater chance of 10 or more deposits. There is a 10% or greater chance of 15 or more deposits. There is a 5% or greater chance of 20 or more deposits. There is a 1% or greater chance of 30 or more deposits.

Estimated amounts of contained metal and mineralized rock (metric tons)

quantile Cu Ag rock 0.95 1,500,000 1,600 150,000,000 0.90 2,600,000 4,100 260,000,000 0.50 7,900,000 29,000 830,000,000 0.10 19,000,000 84,000 1,760,000,000 0.05 26,000,000 110,000 2,100,000,000 mean 9,900,000 38,000 940,000,000

Probability of mean 0.37 0.40 0.43 Probability of zero 0.01 0.02 0.01

nr37 13/9/95 National Mineral Resource Assessment, 1995

The tract ID is NR37

Cumulative Distributions of Contained Metal and Mineralized Rock

1.00

Filled circles 0.90 display mean amounts 0.80

0.70

0.60

0.50 rock

Probability 0.40 Ag Cu 0.30

0.20

0.10

0.350

0.300

0.250

0.200

0.150

0.100

Proportion of Simulations 0.050

Cu Ag rock

nr37 13/9/95 USGS National Mineral Resource Assessment NR38 SEDX: Sedimentary exhalative deposits

NR39 1 AD05 AD03

AD02 1 NA20 2 AD04 3 NA21 1 NR41 NR40

NR42

EC02 GB33 CR35

Cumulative Distribution Histogram Table Model Mineral Deposits Rationale SEDX AD02 •••••• AD03 •••••• AD04 •••••• AD05 •••••• CR35 •••••• EC02 •••••• GB33 •••••• NA20

AD AD: Adirondack Mountains •••••• NA21 PC NR NA CP: Colorado Plateau •••••• LS CR: Central and Southern Rocky Mountains NR38 GB EC: East-central United States •••••• EC NR39 CR GB: Great Basin CP LS: Lake Superior •••••• NR40 SB GP SA NA: Northern Appalachian Mountains map projection = Albers Equal Area •••••• NR: Northern Rocky Mountains NR41 50 0 50 100 200 300 400 miles PC: Pacific Coast 0 50 100 200 300 400 kilometers •••••• 50 NR42 SA: Southern Appalachian Mountains SB: Southern Basin and Range •••••• knowndep • 12:17 PM • 6/5/96 National Assessment, 1995 SDL/DPC Conterminous United States Known Deposits

Page 14 National Mineral Resource Assessment, 1995

The tract ID is NR39 The Mark3 Index is 13: Sedimentary exhalative Zn-Pb

There is a 90% or greater chance of 0 or more deposits. There is a 50% or greater chance of 2 or more deposits. There is a 10% or greater chance of 4 or more deposits. There is a 5% or greater chance of 6 or more deposits. There is a 1% or greater chance of 8 or more deposits.

Estimated amounts of contained metal and mineralized rock (metric tons)

quantile Zn Ag Pb rock 0.95 0 0 0 0 0.90 0 0 0 0 0.50 3,000,000 1,300 1,500,000 50,000,000 0.10 21,000,000 19,000 12,900,000 290,000,000 0.05 30,000,000 29,000 18,000,000 380,000,000 mean 7,500,000 6,400 4,400,000 100,000,000

Probability of mean 0.32 0.28 0.31 0.35 Probability of zero 0.20 0.23 0.20 0.20

nr39 13/9/95 National Mineral Resource Assessment, 1995

The tract ID is NR39

Cumulative Distributions of Contained Metal and Mineralized Rock

1.00

Filled circles 0.90 display mean amounts 0.80

0.70

0.60

0.50

Probability 0.40 rock 0.30 PbZn Ag

0.20

0.10

0.160

0.140

0.120

0.100

0.080

0.060

0.040

Proportion of Simulations 0.020

Zn Ag Pb rock

nr39 13/9/95 USGS National Mineral Resource Assessment

2 1 3-6 QZAD: Epithermal vein deposits, quartz-adularia type PC19 1-2 NR21

1 PC21 2 PC22 PC23 NR22 NR24 PC20 PC24 NR25 1 PC25 NR23 PC26 2 3 1 5 4 6 7

8 11

The tract ID is PC20 The Mark3 Index is 16: Epithermal vein, Comstock

There is a 90% or greater chance of 0 or more deposits. There is a 50% or greater chance of 1 or more deposits. There is a 10% or greater chance of 3 or more deposits. There is a 5% or greater chance of 5 or more deposits. There is a 1% or greater chance of 5 or more deposits.

Estimated amounts of contained metal and mineralized rock (metric tons)

quantile Au Ag rock 0.95 0 0 0 0.90 0 0 0 0.50 5 78 720,000 0.10 89 4,200 13,400,000 0.05 160 9,500 29,000,000 mean 36 2,500 6,000,000

Probability of mean 0.21 0.14 0.20 Probability of zero 0.32 0.32 0.32

pc20 13/9/95 National Mineral Resource Assessment, 1995

The tract ID is PC20

Cumulative Distributions of Contained Metal and Mineralized Rock

1.00

Filled circles 0.90 display mean amounts 0.80

0.70

0.60

0.50

Probability 0.40

0.30

0.20 Au rock Ag 0.10

Au Ag rock

pc20 13/9/95 USGS National Mineral Resource Assessment

2 1 3-6 QZAD: Epithermal vein deposits, quartz-adularia type PC19 1-2 NR21

1 PC21 2 PC22 PC23 NR22 NR24 PC20 PC24 NR25 1 PC25 NR23 PC26 2 3 1 5 4 6 7

8 11

The tract ID is PC21 The Mark3 Index is 16: Epithermal vein, Comstock

There is a 90% or greater chance of 2 or more deposits. There is a 50% or greater chance of 4 or more deposits. There is a 10% or greater chance of 7 or more deposits. There is a 5% or greater chance of 11 or more deposits. There is a 1% or greater chance of 16 or more deposits.

Estimated amounts of contained metal and mineralized rock (metric tons)

quantile Au Ag rock 0.95 1 2 79,000 0.90 6 73 750,000 0.50 53 1,900 8,400,000 0.10 270 20,000 66,100,000 0.05 430 38,000 92,000,000 mean 110 8,100 20,000,000

Probability of mean 0.28 0.21 0.25 Probability of zero 0.04 0.04 0.04

PC21 12/8/95 National Mineral Resource Assessment, 1995

The tract ID is PC21

Cumulative Distributions of Contained Metal and Mineralized Rock

1.00

Filled circles 0.90 display mean amounts 0.80

0.70

0.60

0.50

0.40 Probability

0.30 Au rock 0.20 Ag

0.10

0.00 1 0.0 0.0 0.1 1.0 10 0.1 10.0 100 0.01 100.0 1,000 0.001 1,000.0 10,000 1 billion 1 trillion 10,000.0 100,000 1 million 100,000.0 10 billion 10 million 100 billion 1,000,000.0 100 million 10,000,000.0 100,000,000.0 1,000,000,000.0 10,000,000,000.0 100,000,000,000.0 1,000,000,000,000.0

Histograms of Contained Metal and Mineralized Rock (metric tons)

0.180 0.160 0.140 0.120

0.100 0.080 0.060 0.040 0.020 Proportion of Simulations 0.000 10 56 1.8 316 0.32 0.010 0.056 1,780 0.0018 10,000 56,200 316,000 1,780,000 10,000,000 56,200,000 316,000,000 1,780,000,000 10,000,000,000 56,200,000,000 See table for probability of zero tons

Au Ag rock

PC21 12/8/95 USGS National Mineral Resource Assessment

NR27 HTSG: Hot-spring Au-Ag deposits 1

Map Alternative deposit Layer Tract Deposit District County State Lat Long Deposit Type No. types Middle Fork Condor-Hemlock King WA 47.497 -121.360 Porphyry Cu PCU2 PC04 07 Snoqualmie PCU2 PC05 01 Margaret St. Helens Skamania WA 46.356 -122.081 Porphyry Cu Porphyry Cu-Au, breccia Bornite Marion OR 44.850 -122.310 PCU2 PC05 02 pipe PCU1 PC08 01 Lights Creek Lights Creek Plumas CA 40.300 -120.750 Porphyry Cu CVMS PC10 01 Turner-Albright Waldo Josephine OR 42.007 -123.757 Massive sulfide, Cyprus KVMS PC12 01 Holden Railroad Creek Chelan WA 48.197 -120.780 Massive sulfide, kuroko Submassive sulfide; KVMS PC13 01 Red Ledge Seven Devils Adams ID 45.226 -116.664 Massive sulfide, kuroko stockwork; dissemination Massive sulfide KVMS PC13 02 Iron Dyke Seven Devils Baker OR 45.026 -116.849 Massive sulfide, kuroko fragments in laharic breccia KVMS PC14 01 Gray Eagle Happy Camp Siskiyou CA 41.863 -123.371 Massive sulfide, kuroko KVMS PC15 01 Mammoth West Shasta Shasta CA 40.763 -122.454 Massive sulfide, kuroko KVMS PC15 02 Balaklala West Shasta Shasta CA 40.725 -122.498 Massive sulfide, kuroko KVMS PC15 03 Iron Mountain West Shasta Shasta CA 40.673 -122.524 Massive sulfide, kuroko KVMS PC17 01 Western World Yuba CA 39.175 -121.292 Massive sulfide, kuroko KVMS PC17 02 Penn Campo Seco Calaveras CA 38.294 -120.824 Massive sulfide, kuroko Blue Moon-Amer. Hornitos Mariposa CA 37.542 -120.217 Massive sulfide, kuroko KVMS PC17 03 Eagle Epithermal vein, Cannon Wenatchee Chelan WA 47.396 -120.325 QZAD PC19 01 Comstock Epithermal vein, Lovitt Wenatchee Chelan WA 47.382 -120.315 QZAD PC19 02 Comstock Epithermal vein, War Eagle Project French Carson Owyhee ID 43.007 -116.711 Vein, polymetallic, Au-Ag QZAD PC24 01 Comstock HTSG PC28 01 Quartz Mountain Lake OR 42.300 -120.800 Hot spring Au-Ag Epithermal vein, Hayden Hill Lassen CA 41.080 -120.576 Hot spring Au-Ag HTSG PC28 02 Comstock HTSG PC30 01 Grassy Mountain Malheur OR 43.669 -117.360 Hot spring Au-Ag HTSG PC31 01 Idaho Almaden Weiser Washington ID 44.240 -116.714 Hot spring Ag Hot spring Au-Ag Epithermal vein, Stone Cabin Florida Mountain Owyhee ID 43.025 -116.756 Hot spring Au-Ag HTSG PC32 01 Comstock Epithermal vein, DeLamar De Lamar Owyhee ID 43.020 -116.831 Hot spring Au-Ag HTSG PC32 02 Comstock

Page 15 National Mineral Resource Assessment, 1995

The tract ID is PC28 The Mark3 Index is 45: Hot spring Au-Ag

There is a 90% or greater chance of 0 or more deposits. There is a 50% or greater chance of 1 or more deposits. There is a 10% or greater chance of 3 or more deposits. There is a 5% or greater chance of 5 or more deposits. There is a 1% or greater chance of 7 or more deposits.

Estimated amounts of contained metal and mineralized rock (metric tons)

quantile Au Ag rock 0.95 0 0 0 0.90 0 0 0 0.50 21 16 15,000,000 0.10 190 790 135,000,000 0.05 310 1,200 260,000,000 mean 68 280 48,000,000

Probability of mean 0.29 0.26 0.27 Probability of zero 0.31 0.47 0.31

pc28 13/9/95 National Mineral Resource Assessment, 1995

The tract ID is PC28

Cumulative Distributions of Contained Metal and Mineralized Rock

1.00

Filled circles 0.90 display mean amounts 0.80

0.70

0.60

0.50

Probability 0.40

0.30 Au Ag rock 0.20

0.10

0.140

0.120

0.100

0.080

0.060

0.040

Proportion of Simulations 0.020

Au Ag rock

pc28 13/9/95 USGS National Mineral Resource Assessment

NR27 HTSG: Hot-spring Au-Ag deposits 1

The tract ID is PC29 The Mark3 Index is 45: Hot spring Au-Ag

There is a 90% or greater chance of 2 or more deposits. There is a 50% or greater chance of 6 or more deposits. There is a 10% or greater chance of 10 or more deposits. There is a 5% or greater chance of 16 or more deposits. There is a 1% or greater chance of 30 or more deposits.

Estimated amounts of contained metal and mineralized rock (metric tons)

quantile Au Ag rock 0.95 9 0 4,900,000 0.90 35 32 25,000,000 0.50 220 810 160,000,000 0.10 710 3,200 518,000,000 0.05 970 4,400 690,000,000 mean 320 1,300 230,000,000

Probability of mean 0.36 0.34 0.37 Probability of zero 0.04 0.08 0.04

.PC29 12/8/95 National Mineral Resource Assessment, 1995

The tract ID is PC29

Cumulative Distributions of Contained Metal and Mineralized Rock

1.00

Filled circles 0.90 display mean amounts 0.80

0.70

0.60

0.50

0.40 Probability Au rock Ag 0.30

0.20

0.10

Histograms of Contained Metal and Mineralized Rock (metric tons)

0.250

0.200

0.150

0.100

0.050 Proportion of Simulations 0.000 10 56 1.8 316 0.32 0.010 0.056 1,780 0.0018 10,000 56,200 316,000 1,780,000 10,000,000 56,200,000 316,000,000 1,780,000,000 10,000,000,000 56,200,000,000 See table for probability of zero tons

Au Ag rock

.PC29 12/8/95 USGS National Mineral Resource Assessment PMR1: Polymetallic replacement deposits I

2-5 6 2 8 7 NR13 NR12 9 1

GB15

1 4 5

GB16 1 2 2 6 3 GB14 1 2 CR15

3 1 1

SB19 Cumulative Distribution Histogram Table Model Mineral Deposits Rationale PMR1 CR18 CR15 SB18 •••••• CR18

Map Alternative deposit Layer Tract Deposit District County State Lat Long Deposit Type No. types Porphyry Cu, skarn- Ely Robinson White Pine NV 39.260 -115.000 PCU1 GB08 01 related PCU1 GB08 02 Sullivan - Cuervo Fairplay Nye NV 38.780 -117.950 Porphyry Cu Porphyry Cu, skarn- Copper Canyon Battle Mountain Lander NV 40.540 -117.120 PCU2 GB09 01 related PCU3 GB10 01 Macarthur Yerington Lyon NV 39.050 -119.240 Porphyry Cu PCU3 GB10 02 Bear Prospect Yerington Lyon NV 39.030 -119.180 Porphyry Cu PCU3 GB10 03 Yerington Yerington Lyon NV 38.980 -119.200 Porphyry Cu PCU3 GB10 04 Ann Mason Yerington Lyon NV 38.960 -119.270 Porphyry Cu Polymetallic Bingham Canyon Bingham Canyon Salt Lake UT 40.540 -112.140 Porphyry Cu PCU2 GB11 01 replacement; skarn Cu PMR1 GB14 01 Cerro Gordo Inyo CA 36.540 -117.791 Polymetallic replacement PMR1 GB14 02 Darwin Inyo CA 36.280 -117.600 Polymetallic replacement PMR1 GB14 03 Argus Inyo CA 35.925 -117.516 Polymetallic replacement PMR1 GB15 01 Eureka Eureka NV 39.500 -115.980 Polymetallic replacement PMR1 GB15 02 Bristol - Jackrabbit Lincoln NV 38.100 -114.600 Polymetallic replacement PMR1 GB15 03 Pioche Lincoln NV 37.920 -114.460 Polymetallic replacement Distal disseminated Ag- Tecoma Box Elder UT 41.267 -114.000 Polymetallic replacement PMR1 GB16 01 Au Little and Big Salt Lake UT 40.620 -111.670 Polymetallic replacement PMR1 GB16 02 Cottonwood PMR1 GB16 03 Park City Summit UT 40.620 -111.510 Polymetallic replacement PMR1 GB16 04 Tintic Utah-Juab UT 39.910 -112.100 Polymetallic replacement Distal disseminated Ag- Detroit Detroit Juab UT 39.550 -112.990 Polymetallic replacement PMR1 GB16 05 Au San Francisco and PMR1 GB16 06 adjacent districts Beaver UT 38.480 -113.300 Polymetallic replacement (Milford area) Distal disseminated Ag- Lone Tree Battle Mountain Humboldt NV 40.830 -117.210 DSDG GB18 01 Au Distal disseminated Ag- Stonehouse Battle Mountain Humboldt NV 40.830 -117.210 DSDG GB18 02 Au Distal disseminated Ag- Eight South Battle Mountain Humboldt NV 40.742 -117.160 DSDG GB18 03 Au Distal disseminated Ag- Marigold Battle Mountain Humboldt NV 40.730 -117.180 DSDG GB18 04 Au Distal disseminated Ag- East Hill - UNR - Top Battle Mountain Humboldt NV 40.729 -117.175 DSDG GB18 05 Au Page 3 National Mineral Resource Assessment, 1995

The tract ID is GB15 The Mark3 Index is 92: Polymetallic Replacement + skarn Zn-Pb

There is a 90% or greater chance of 9 or more deposits. There is a 50% or greater chance of 14 or more deposits. There is a 10% or greater chance of 18 or more deposits. There is a 5% or greater chance of 20 or more deposits. There is a 1% or greater chance of 22 or more deposits.

Estimated amounts of contained metal and mineralized rock (metric tons)

quantile Cu Au Zn Ag Pb rock 0.95 11,000 1 670,000 1,100 480,000 13,000,000 0.90 26,000 3 1,200,000 2,200 900,000 24,000,000 0.50 150,000 26 3,700,000 9,000 2,800,000 68,000,000 0.10 530,000 150 8,400,000 25,000 6,900,000 140,000,000 0.05 760,000 230 11,000,000 32,000 8,700,000 160,000,000 mean 230,000 59 4,400,000 12,000 3,500,000 75,000,000

Probability of mean 0.33 0.27 0.40 0.37 0.38 0.44 Probability of zero 0.02 0.02 0.01 0.01 0.01 0.01

gb15 14/9/95 National Mineral Resource Assessment, 1995

The tract ID is GB15

Cumulative Distributions of Contained Metal and Mineralized Rock

1.00

Filled circles 0.90 display mean amounts 0.80

0.70

0.60

0.50 rock

Probability 0.40 Zn Ag Pb Cu 0.30 Au 0.20

0.10

0.400

0.350

0.300

0.250

0.200

0.150

0.100

Proportion of Simulations 0.050

Cu Au Zn Ag Pb rock

gb15 14/9/95 Appendix B

35,000 32,879

30,000 26,745 26,123 25,000

20,000

15,000

10,000

5,000 3,762

0 Claims in Claims in PHMA Claims in GHMA Claims in OHMA Mineral Withdrawl Area