Excelsior Mining Corp (EXMGF)

[singhinvestor16]

I just saw the news. In my opinion, the appeal will be denied.

The appeal raises three issues:

1. Request for the functional equivalent of a NEPA study. This will be denied because the EPA obviously grants permits only if the EPA feels that a NEPA study or the functional equivalent is not necessary. I don't believe the EPA is going to say great idea, why didn't we think of that. More importantly, NEPA is not part of the permitting process and this is not a valid appeal issue.(/b]

2. The impacts to wildlife and habitat. This will be denied because this was evaluated as part of the permit process. Comprehensive biodiversity studies were done by the State of Arizona, the EPA, and the US Fish and Wildlife Service. There are no endangered or threatened species on the property and the habitat is not conducive to any. She specifically mentions the bats – these bats feed on the Senora cactus – Excelsior's property does not have any.

3. Appeal to an aquifier exemption. This will also be denied. The mining method used by Excelsior will not contaminate. In fact the beauty is once they are gone, you won't know they were there shortly thereafter

I predict that the EPA will respond within 30 days and the appeals board will deny the appeal within 30 days. This will amount to a 60 day delay which is not a big deal for such an accomplishment, it's a very tiny negative.