Ann: Results of SPP and Shortfall, page-216

I think you're probably right in so far as the EPA raising lots of concerns that VRX have needed, or are still yet, to address. However I don't believe the EPA will require any one thing in particular that will hinder VRX from mining their tenement. Rather, and this might be a case of us saying the same thing just a little differently, it is conceivable that the EPA requires some processes or adjustment to proposed processes that render the mining of the tenement uneconomical.

There is some evidence to suggest this..
1. VRX getting caught in years of back and forth with the EPA
2. Public Responses not published by VRX
3. 3+ years since a BFS was produced, surely the outcome has changed given there has been communication that elements of the original BFS are no longer valid (e.g Road vs Rail)

To use an analogy I think VRX are walking forward into a dark abyss and it's the EPA that are controlling the flashlight. Each step forward at this point is at the whim and direction of the EPA. In this circumstance it would be foolish for VRX to make ANY commitment on process, price, BFS, literally everything about the VRX business is subject to change until the company receives in principal approval to dig in the sand pit.

What else can a company with finite resources do if they are in this position? They can't back out of the abyss, after all they are in it because they believe it's worth the effort. They also can't back out now since they have come so far. In any case they have to keep going forward and do so without vision towards the resources they need to see it through. They can't pivot and diversify because that consumes resources needed to see out the abysmal journey.

The way I see it is even if the stipulations make it uneconomical now, given the supply issues forecast in the silica sand market, eventually this becomes economical regardless of the circus tricks needed to appease the EPA.