Vanuatu prepares for deep sea mining

Deep_sea_vent_chemistry_diagram_deepsea_mining

MAREX | The Maritime Executive

The Republic of Vanuatu has commenced a national consultation program on a draft Deep Sea Minerals Policy.

Past studies in Vanuatu’s waters have revealed the presence of massive seafloor sulfide deposits within its exclusive economic zone, which could contain significant quantities of copper, gold, zinc, silver and other commercially viable minerals. The presence of such minerals could present a potential economic opportunity for Vanuatu if deep sea mining activity is properly conducted and balanced with appropriate environmental, legal and financial management.

The draft Policy sets out Vanuatu’s vision and strategic goals in relation to its deep sea minerals, and will form the basis for future drafting of laws in line with the policy. The draft policy has been prepared by the Ministry of Lands with advice from the Deep Sea Minerals (DSM) Project: a partnership between the Secretariat of the Pacific Community (SPC) and the European Union (EU). The DSM Project works to assist 15 Pacific Island countries to improve governance and management of their deep-sea mineral resources, including through the development of national policies and laws.

The DSM Project places great emphasis on the importance of a consultative approach, and encourages all governments to involve concerned citizens in decisions that may affect natural resources and the environment. The DSM Project is providing technical and financial support to the government of Vanuatu to conduct this important consultation exercise and will continue to work with Vanuatu’s multi-stakeholder National Offshore Minerals Committee, which includes the Vanuatu Association of Non-Governmental Organisations (VANGO), as they progress this work.

While PNG made news for being the first country in the world to issue a licence for deep-sea mining, more and more Pacific Islands countries are getting approaches from companies interested in exploration and exploitation of deep-sea minerals. The questions that arise are—what are the risks? What are the benefits? What do Pacific Islanders need to know to make the right decisions here?

Many islanders have learnt, the hard way, the consequences of not knowing what they were getting into with mining and unsustainable development—phosphate mining on Nauru perhaps being the most dramatic example of a mining boom…and then a bust. Is deep-sea mining different? Time is critical, says Dr Jimmie Rodgers, Director-General, Secretariat of the Pacific Community (SPC): “Is it urgent? Is it important now? Yes! Because multinationals are not going to wait to give Pacific Islands countries time to look at all the studies, environmental analysis, before they come in—they push in.”

Over 300 exploration licences have been granted in Pacific Islands countries like Solomon Islands, Vanuatu and Tonga. In the Pacific, most of the mineral deposits considered profitable to mine are known as Seafloor Massive Sulfides (SMS). Some countries have manganese nodules and cobalt-rich crusts on the seafloor, mining of which are likely to have greater environmental impacts than SMS. For instance, nodules, small lumpy concretions that form over millions of years as metals from the seawater and seafloor sediments precipitate around a core, which may be a shark tooth or rock fragment. Nodules cover a significant area of the sea floor and contain minerals such as manganese, copper, nickel and cobalt.

Minerals are also found around hydrothermal vents—places where very hot fluid (around 400 degrees Celsius) that carries minerals comes into contact with cold sea water (around two degrees Celsius), resulting in the precipitation and deposition of minerals on the seafloor. The “chimneys” that form around the vents are the direct result of the accumulation of minerals on the seafloor over time. Companies are now chasing these natural phenomena in the Pacific Islands region and other parts of the world ocean.

Deep-sea minerals have a use in everything from mobile phones to metal alloys, renewable energy technologies and batteries. Papua New Guinea’s Nautilus minerals venture was halted in 2012 after disagreement over government’s equity and benefits. Meanwhile, projects now go ahead in Sudan, Saudi Arabia, New Zealand and other countries. The companies and scientists are quick to point out the consequences of sea mining versus land mining are different—land mining can produce more than 99 percent waste and less than one percent ore. Waste materials when exposed for an extended period of time produce acid by the reaction of sulfide minerals with fresh water and oxygen, as well as liberated heavy metals that can pollute the environment.

In SMS mining, sulfide in waste materials cannot react with the alkaline seawater hence acid cannot form in the ocean. SMS due to the small size of the mineral rich deposits do not produce as much waste as land mining, or leakage of minerals into the environment. On the other hand, as deep-sea mining is new, some are skeptical of claims it will have minimal impact on the environment.

As part of the work of SOPAC (the Applied Geoscience & Technology Division of SPC) which provides technical support and advice to Pacific Islands countries, the division has been assisting countries to improve technical capacity, community involvement and government management of deep sea mineral resources. One of the elements of the Pacific Deep-Sea Minerals Project, started in 2011 with funding from the European Union, is that it recommends national policies and laws before any mining takes place.

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Filed under Environmental impact, Financial returns, Human rights, Pacific region, Papua New Guinea, Vanuatu

St Barbara looks to dump responsibility for its failures onto Solomon Islands government

St Barbara calls on Solomons to help ensure Gold Ridge mine remains safe

Cole Latimer | Australian Mining

St Barbara has called on the Solomon Islands Government aid to ensure its tailings dam does not burst in the upcoming wet season.

It comes on the back of St Barbara’s talks to hand the embattled Gold Ridge mine back to the nation’s government.

A series of weather issues, cyclones, and flooding, compounded by ongoing security concerns saw the miner decide to withdraw all staff from the site, and eventually enter into “negotiations with the government to hand over the investment back to the Solomon Islands Government”.

Now St Barbara is butting heads with the Government over the improvement of Gold Ridge’s tailings dam dewatering conditions prior to the west season, or face the potential of an environmental incident, according to Radio New Zealand.

In its quarterly report St Barbara said “management of the tailings dam is now a critical issue with the approach  of the high rainfall season”.

St Barbara added that “Gold Ridge has made many attempts over a prolonged period of time to agree a tailings dam remedial action plan with the Solomon Islands Government; GRML has not been able for some time now to pump water from the taillings dam in compliance with the current dewatering licence conditions due to the destruction of the necessary equipment and the continuing concerns about the security situation”.

“We can’t doing anything of the nature we are looking at without the approval of the Government, in terms of environmental approvals. And those environmental approvals have to involve the local communities – clearly that is the case. Now we are not in a position to just do what we like there,” St Barbara chief executive Bob Vassie stated.

The miner added that “Gold Ridge has offered technical assistance to the Solomon Islands Government during the currency of the force majeure and to pay for short-term tailings dam facility works, but no progress has been made towards establishing and then implementing an agreed solution”.

The Government hit back, stating that the tailings dam issue is only St Barbara’s problem to solve.

Negotiations are stalled and a decision is yet to be reached ahead of the Solomons Island wet season.

Miner says Solomons Govt must help

Radio New Zealand

Solomon Islands gold miner, Melbourne based St Barbara, says the Solomons Government is critical to ensuring a tailings dam does not burst.

Its shut down Gold Ridge mine needs an improved tailings storage facility before the wet season or the downstream environmental effects could be catastrophic.

The Government, which wants to buy the mine, claims it is a problem for the company to solve.

But chief executive, Bob Vassie, says security remains unsatisfactory and vandalism of their equipment is continuing.

He says roading access also needs government input and it has to sort out environmental approvals.

“We can’t doing anything of the nature we are looking at without the approval of the Government, in terms of environmental approvals. And those environmental approvals have to involve the local communities – clearly that is the case. Now we are not in a position to just do what we like there.”

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Porgera mining township Authority going broke

Mining township going broke: Another indicator of the success of our government’s development model based around large-scale resource extraction by foreign companies. When will they understand this model is a failure!

Violent clashes at Porgera earlier this year. Photo: Post Courier

Violent evictions at Porgera earlier this year. Photo: Post Courier

Post Courier

A SMALL local urban management company from the mining township of Paiam in the Porgera Gold Mine area is on the verge of shutting down its operations.

Porgera Development Authority (PDA) general manger John Miukin in a letter to Barrick’s Resident Mines manager raising the plight of the mining township said Paiam Town Management Company (PMC) faces shutdown of its operations due to government’s failure in honouring an agreement to release K2 million annually to maintain the company’s operation.

Mr Miukin told the Post- Courier this week that PMC’s source of funds include mine operator (Barrick) PNG, National Government, Enga Provincial Government (EPG), and PDA as stipulated by a memorandum of understanding (MOU) signed between these parties to stop the mine’s fly-in -fly-out (FIFO) arrangement.

He said an accumulated outstanding of K24 million is owed to PMC by the government over the last 12 years.

PMC was established under the MOU in order to maintain the operations of all public utilities and facilities of the township such as sewerage, schools, hospitals, electricity, water etc…

However, since the suspension FIFO arrangement, all funding support to PMC from all the parties to the agreement has since ceased resulting in financial woes.

Mr Miukin stressed; ” since all funds to PMC have ceased; PDA maintained and subsidised PMC’s operations for 12 years and wouldn’t continue as PDA is not the responsible financier for PMC.

Meanwhile Manager- Project Coordination from Mineral Resources Authority John Ipidari when pressed on the situation admitted that the FIFO agreement is currently under suspension, however, proposal has been by the MOA parties to review the FIFO agreement in three to four months after the MOA has been reviewed.

Parties to the MOA are: National Government, Enga Provincial Government and landowners.

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Drive to Mine the Deep Sea Raises Concerns Over Impacts

Armed with new high-tech equipment, mining companies are targeting vast areas of the deep ocean for mineral extraction. But with few regulations in place, critics fear such development could threaten seabed ecosystems that scientists say are only now being fully understood.

Mike Ives | Environment 360

hydrothermal vent

Hydrothermal vents create rich mineral deposits that companies are eager to exploit. Nautilus Minerals

For years, the idea of prospecting for potentially rich deposits of minerals on the ocean floor was little more than a pipe dream. Extractive equipment was not sophisticated or cost-effective enough for harsh environments thousands of feet beneath the ocean’s surface, and mining companies were busy exploring mineral deposits on land. But the emergence of advanced technologies specifically designed to plumb the remote seabed— along with declining mineral quality at many existing terrestrial mines — is nudging the industry closer to a new and, for some environmentalists and ocean scientists, worrying frontier.

More than two-dozen permits have been issued for mineral prospecting in international waters. And in April, after years of false starts, a Canadian mining company signed an agreement with the government of Papua New Guinea to mine for copper and gold in its territorial waters. That company, Nautilus Minerals, plans to begin testing its equipment next year in European waters, according to the International Seabed Authority (ISA), a regulatory agency established in 1994 under the auspices of the United Nations. A Nautilus spokesman, John Elias, said the plan is to award a construction contract in November for a specialized mining vessel. “All other equipment has been manufactured and is in final assembly,” he wrote in an email.

Chief among critics’ concerns is that seabed mining will begin without comprehensive regulatory oversight and environmental review. They say dredging or drilling the seafloor could potentially obliterate deep-sea ecosystems and kick up immense sediment plumes, which could temporarily choke off the oxygen supply over large areas. And powerful international companies, they add, could take advantage of the lax or non-existent review and enforcement capabilities in many small island nations of the Pacific Ocean — precisely where seabed mineral deposits are thought to be highly concentrated.

“Communities are concerned that our governments don’t know enough about the ecology or the implications” of seabed mining, said Maureen Penjueli, coordinator of the Pacific Network on Globalization, a Fiji-based non-profit that has tracked seabed prospecting in the region since 2009. “We haven’t seen much benefit from land-based mining, let alone fisheries or tourism — and here we are entering a new frontier.”

drawing showing seabed mining operationBut industry proponents say no extractive industry is free of environmental impacts, and that only a fraction of the seabed covered by exploration permits would actually be mined. Companies and governments, they say, are carefully studying both deep-sea ecosystems and emerging mining technologies in order to prevent or mitigate ecological damage.

“We are committed to using ecologically sound, deep-seabed mineral recovery methods,” said Jennifer Warren, the regulatory director at UK Seabed Resources, a subsidiary of the U.S. defense giant Lockheed Martin’s British arm. “Toward that end, we are working closely with research institutions and scientists to understand any potential environmental impact of commercial recovery efforts.”

Gaining that kind of understanding is a work in progress. As late as the 1950s, the deep sea was still viewed as a dark and barren place with little or no biodiversity worthy of protection. But in the 1960s, new sampling technologies prompted the discovery of new deep-sea species, and by the late 1970s, scientists had discovered bacteria that could thrive amid hydrothermal vents in deep, volcanically active regions. Those bacteria are turning out to be food for a number of “beautiful and strange” invertebrates, according to Cindy Van Dover, a marine biologist at Duke University. By the early 1990’s, scientists were speculating that the deep sea played host to as many as 10 million species of small invertebrates.

It is amid this awakening to deep-sea biodiversity that interest in seabed mineral mining is heating up. While investing in seabed-mining operations remains comparatively expensive, “the equation is turning,” according to Michael W. Lodge, legal counsel with the ISA. “People are starting to think that upfront investment is worth it for the long term payoff.” The ISA has issued seven new seabed exploration permits this year, Lodge noted, bringing its global total to 26, stretching across an area of international waters roughly the size of Mexico.

Nautilus Minerals’ planned operation in the territorial waters off Papua New Guinea, however, is widely expected to be the world’s first commercial-scale deep-seabed mine. Several neighboring countries have begun to issue export permits — and in some cases, are drafting seabed-specific mining legislation. New Zealand has also been weighing applications for two seabed mines in its waters, which would target iron sands and phosphate, respectively.

In an email message, James Hein, a geologist with the U.S. Geological Survey and the president of the International Marine Minerals Society, a non-profit organization linking industry, government, and academic institutions, suggested that the global rush to mine so-called “rare earth” elements – which are used to manufacture cellular phones, wind turbines, solar panels, electric cars and other applications – is a key driver in moving the industry forward.

Other sought-after resources include sulfide minerals — a source of precious metals like silver, gold and copper — that accumulate around gaps in the seafloor where chemical-rich fluids leak into the ocean at temperatures nearing 1,000 degrees Fahrenheit. The Nautilus Minerals project in Papua New Guinea plans to mine a sulfide deposit by cutting the seabed with a remote-control machine that is 26 feet tall, 42 feet wide, and 55 feet long. According to the company, the ore will be extracted with an “associated suction mouth” and pumped to the surface — a distance of about a mile.

Manganese nodules — palm-sized chunks of rock containing copper, nickel and cobalt — are also prized, and in shallower areas, mining companies plumb for rocks containing phosphates, a key ingredient in agricultural fertilizers. “The process itself is essentially a large vacuum cleaner on the end of a hose,” said Chris Castle of Chatham Rock Phosphate, the company behind the phosphate-mining application pending in New Zealand.

Here and elsewhere, however, environmental battle lines are now being drawn. In June, a New Zealand court, citing environmental concerns, riled the mining industry by rejecting a proposed plan for an iron sands mine about 15 miles off the coast of the country’s North Island. The company behind the proposed mine, Trans-Tasman Resources, says it has spent over seven years and more than $50 million studying the potential impacts. An appeals hearing is scheduled for next March.

Meanwhile, the New Zealand advocacy group Kiwis Against Seabed Mining has argued that the mines would pose risks to iconic mammals — including blue whales and Maui’s dolphins — that outweigh any potential economic benefits.

Castle, Chatham Rock Phosphate’s project director, said the environmental impacts on the seabed would be far less than those that fishing trawlers regularly inflict. But Les Watling, a biology professor at the University of Hawaii at Manoa, argued that sediment plumes from the phosphate mine could stress or kill an entire species of local coral, Goniocorella dumosa, leading to wider impacts because the coral’s branches are a habitat for smaller organisms. And Liz Slooten, a zoologist at New Zealand’s Otago University, said the sounds from seabed mining in that area could damage or destroy the hearing of blue whales, causing them to flee and perhaps even beach themselves.

Ultimately, the exact impacts of deep-sea mining in New Zealand or beyond won’t be entirely clear until the mines actually open, said Phil Weaver, a geologist and the coordinator of a three-year project called Managing Impacts of Deep Sea Resource Exploitation, which launched in 2013 with a $11.4 million grant from the European Commission. “We need to put in place some criteria and protocols which will at least try to control those impacts based on available information.”

In March, the ISA began soliciting public comments for its first-ever Mineral Exploitation Code. A voluntary environmental code drafted by the International Marine Minerals Society in 2001 will inform the new ISA document, according to Hein, the society’s president. David Billett of Britain’s National Oceanography Centre, who sits on the ISA’s legal and technical commission, said environmental matters are “regularly raised” at the committee’s meetings, and that the ISA has strict guidelines for the sort of ecological data that prospective miners must collect along seabeds.

Still, individual countries are free to choose their own regulatory approaches to seabed mining, and permits in the South Pacific have already been issued in waters that cover an area the size of Iran, according to the Deep Sea Mining Campaign, an international coalition of non-profit groups. A 2010 study in the journal Marine Policy said the “absence of a clearly defined regulatory regime” in international waters was encouraging seabed prospectors to pursue projects in territorial waters, where legal risks were smaller. It named Tonga and its neighbor Papua New Guinea as two countries that would struggle to balance economic development against the need to protect marine ecosystems.

Environmental groups are watching carefully as the Nautilus Minerals project gathers speed in Papua New Guinea. The company says its mine will not contaminate coral or fisheries, and Jonathan Copley, a prominent marine ecologist at Britain’s University of Southampton, has said that the project’s design appears to be environmentally sensitive. Yet Nautilus and other international firms have other mining applications scattered across the South Pacific, and Van Dover of Duke University said scientists’ biggest concern is the cumulative impacts of multiple mines opening in the same area.

“A single mining event — at the scale of a single hydrothermal vent field — would be no worse than the most extreme natural disturbance,” Van Dover said in an email message. “But multiple mining events in a region in a short period of time — i.e. within a decade — would be unwise without good environmental knowledge of the ability of the system to recover.”

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Lion One receives Environmental Approvals for construction and development at Tuvatu Gold Project in Fiji

Lion One Metals | Marketwired 

Lion One Metals Limited announces that the Company has received approval from the Fiji Government’s Department of Environment for its Construction Environment Management Plan and Operation Environmental Management Plan (the EMP’s) for its 100% owned Tuvatu Gold project, located near Nadi on the island of Viti Levu in Fiji.

The Construction and Operation EMP’s have been approved for the potential future development of processing plant, construction of roads, underground and open cut mine construction, mine site infrastructure, tailings, pipeline, and water management facilities, and follows extensive consultations with the Mineral Resources Department, Rural Local Authority, Town and Country Planning, Lands Department, Forestry Department, and i-Taukei Land Trust Board, following the approval of the Company’s Environmental Impact Assessment (see announcement dated Feb.11, 2014). The Company is currently conducting a number of additional studies, including two independent processing plant studies, a mine plan and development study, and geotechnical studies for the potential tailings dam facility and the processing plant site for Tuvatu, all of which are expected to conclude by December 2014.

About Tuvatu

Tuvatu is a high grade, vein-hosted gold deposit located on the island of Viti Levu in Fiji. Tuvatu is situated on the Viti Levu lineament, 35 km along trend from Vatukoula, Fiji’s largest gold deposit and oldest gold operating mine, with over 7 million ounces of production over 75 years (per VGM website 2014). Both deposits are low-sulphidation epithermal gold deposits related to alkalic volcanic intrusive complexes. In late 2013, the Company received Department of Environment approval for the Tuvatu Environmental Impact Assessment and in 2014 signed a 21-year Surface Lease (see news release dated  May 22, 2014), and upgraded Tuvatu’s indicated resource to 1,101,000 tonnes at a grade of 8.46 grams per tonne gold (g/t Au) and inferred resource to 1,506,000 tonnes at a grade of 9.70 g/t Au, at a cut-off grade 3.0 g/t Au (see news release dated June 4, 2014).

About Lion One Metals

Lion One Metals is a mineral exploration and development company based in North Vancouver, BC, focused on the advancement of its high grade Tuvatu Gold Project in Fiji.

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Solomons’ miner told tailings threat its responsibility

Radio New Zealand

The sun setting at Gold Ridge mine, Solomon Islands.

The sun setting at Gold Ridge mine, Solomon Islands. Photo: Koroi Hawkins

Solomon Islands says the onus is on Australian mine operator, St Barbara, to sort out any threat should the Gold Ridge tailings dam bursts.

Gold Ridge has been inactive since flooding on Guadalcanal in April.

The company has been reported to be warning of the threat posed by the tailings storage facility if a spillway is not created before the wet season due from next month.

There have been negotiations on a possible sale of the mine but the special secretary to the prime minister, Philip Tagini, says two factors are delaying St Barbara sending staff in for the spillway work.

He says the company wants a commitment from the Solomons government to share some of the mine’s liabilities if a sale goes ahead.

“We are willing to have the conversation about the future of the mine but we want to get the environmental issues sorted before that conversation actually is formulated to something that can be agreed upon.”

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Global Zinc shortage accelerates; Thunderstruck Resources to explore Zinc Project in Fiji

A ‘mining friendly’ government and heavy Chinese investment make Fiji an attractive destination for global speculators… 

Market Watch

The world’s largest zinc mines are shutting down, propelling the spot price of zinc to a three-year high of $2,400 per metric ton.

Global zinc consumption is growing 7% a year, catalysed by an automobile industry that requires zinc to protect steel components from rust and corrosion. Supply constraints could propel the metal even higher over the coming years.

This perfect storm of growing demand and shrinking supply is likely to benefit Thunderstruck Resources (AWE), which has a 100% interest in a portfolio of zinc, copper, gold and silver prospects located in the mining-friendly Republic of Fiji.

Fiji has recently transitioned to democracy, and China is continuing to invest heavily in infrastructure, cultural and mining projects in the country.

“Our technical team looked at hundreds of mineral properties around the globe,” says Bryce Bradley, Thunderstruck’s president and CEO, in an exclusive interview. “We had a very specific set of criteria. We rejected projects that were over-priced or incurred an unacceptable level of geological or political risk.”

Thunderstruck ended up with a portfolio of projects in Fiji that were drilled by Anglo America in the 1970’s. Thunderstruck has access to all of the drill data.

“We’re looking forward to a comprehensive drill program that will include confirming the high grade Anglo holes as well as conducting expansion drilling,” stated Bradley. “We’ll be following Anglo’s exploration success to determine the size of the deposits, and whether they have potential to be a mine.”

VMS deposits provide shareholders with exposure to an array of precious and base metal prospects with high grade intercepts of zinc, copper, gold and silver.

“The Fiji assets first landed on our plate about a year ago,” stated Bradley, “the properties were spectacular but the terms were too onerous. Finally, in July 2014 we reached an agreement, for less than 10% of the initial share issuance. It is a great deal for our shareholders.”

Thunderstruck will pay $600,000 and 1.5 million shares over three years for 100% of the assets.

Brien Lundin is a co-founder and director of Thunderstruck Resources. He runs the New Orleans Investment Conference which has featured influential speakers such as Ayn Rand, Margaret Thatcher and Alan Greenspan. Lundin also writes the influential Gold Newsletter. With 30 years’ experience as an analyst and metal investor, he has seen everything and done everything.

“Mr. Lundin is highly respected in the world of junior mining,” stated Bradley, “He is a co-founder and active board member who has been instrumental in choosing these particular assets, as he sees great potential in them.”

“We looked at a lot of projects before discovering this package of properties,” stated Lundin. “The Fiji assets are an interesting mix of ground-floor exploration and historic drilling. Thunderstruck has under license or application nearly 4% of the main island of Fiji. The beauty of VMS systems is that multiple metals can be found in the same deposit. So they can function as single-deposit diversification investments.”

Thunderstruck has two main VMS prospects within 25 km of each other, Wainaleka and Nakoro. They could accommodate a mill in between them, and ore could potentially be shipped to smelters in China or Japan via the deep-water Port of Suva, Fiji’s capital city.

Anglo completed two diamond drill programs on both VMS projects in the 1970s, but metal prices at that time didn’t warrant further exploration. However, the core drilling returned significant VMS drill intercepts, including 12 meters of 12.7% zinc and 56 grams/tonne silver. The targets remain open in all directions.

Thunderstruck Resources has only 12.4 million shares outstanding, tightly held by loyal shareholders. Subject to financing, Bradley anticipates spending approximately $1 million in the next year to drill both VMS properties and combining all known data into a 3-D model providing a clear delineation of the current asset.

Bradley anticipates selling the zinc either to the Japanese or the Chinese, who have invested heavily in Fiji’s mines and infrastructure such as roads and hospitals. The Chinese recently purchased Fiji’s oldest and largest gold mine, Emperor, and has an interest in several others.

Thunderstruck is also preparing their highly prospective gold property at Liwa Creek for drilling, but will limit their exploration activity until the gold markets recover.

“It is very likely that we will partner with a Chinese entity somewhere down the road,” confirmed Bradley, ” China is buying a lot of zinc, and we are in a perfect position geologically, politically and geographically to feed that demand.”

Zinc stored in the London Metal Exchange’s warehouses is down 22% since the start of 2014, equivalent to only about 20 days of global production. If this trend continues, international investors will look to zinc explorers in mature mining districts, with good proximity to China.

“In the next 12 to 24 months we hope to have a resource,” stated Bradley, “which would have a significant impact on the valuation of Thunderstruck.”

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