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independent expert report indian iron ore

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    Cluf f Resources Paci f ic NL
    ABN 72 002 261 565
    Registered Office:
    1/30 Leighton Place,
    Hornsby NSW 2077,
    Australia
    ASX Code: CFR
    Postal Address:
    Locked Bag 3355,
    Hornsby NSW 2077,
    Australia
    Tele-Communications:
    Tel: (612) 9482 4655
    Fax: (612) 9482 4987
    email: [email protected]
    Internet: www.cluff.com.au
    29 July, 2008
    The Manager (Companies),
    Australian Stock Exchange,
    Sydney
    Dear Sir,
    INDEPENDENT EXPERT REPORT, INDIAN IRON ORE
    I attach the Independent Expert Report prepared by N.H.Cole and Associates Pty
    Ltd, Project Investment and Mineral Industry Advisors, on six Applications for Mining
    Leases in Karnataka State, India. These AMLs have been offered to Cluff as a result
    of the Memorandum of Understanding between Cluff Resources Pacific NL and Sai
    Engineering, of Bangalore signed on 2 May, 2008.
    The mining lease applications are within a district with a large amount of current and
    historical mining, and particularly those very close to two of the AMLs offered, the
    evidence of past and current illegal mining activity by artisanal mining workers within
    at least three of the areas offered, suggesting the presence of commercial grades of
    iron ore on the leases. The region produces the large majority of iron ore from the
    state, and is the location of at least 140 current or former high grade, low impurity
    haematite iron ore open pit mines.
    Sampling Haematite Scree Deposit on 2511AML07
    The Report encourages the Company to further investigate committing to iron ore
    mining in Karnataka State by highlighting the haematitic nature of the deposits, high
    grade of iron ore mined regionally, and low levels of silica, alumina, phosphorous and
    sulphur within the ores. Reported mine gate price of this iron ore is high. The smaller
    size of the mines and low requirement for ore processing suggests that mine
    establishment costs would be much lower than for many other commodities. This,
    together with likely low stripping ratios, and the use of contract haulage is likely to
    result in low production costs. Hence mining operations on these leases have
    potential to produce profits suitable for an emerging miner such as Cluff.
    Haematite outcrop, 2511AML07
    The minimal amount of exploration and geological mapping carried out to date needs
    to be remedied. Hence the projects are at the point where they require exploratory
    drilling to define a resource, rather than at mine planning stage.
    Discussions with our Joint Venture Partner are continuing in order to remedy the
    Company’s concerns about uncertainties in time required for grant of the Mining
    Leases. It is now examining the possibility of purchasing additional granted Mining
    Leases, with the aim of obtaining near term production while grant of the applications
    for mining leases described in the Report is obtained.
    Haematite on 2511AML 07
    Beds of Banded Ironstone, 2318AML07
    Iron Ore Transport in Typical Thirteen Tonne Truck, 2318AML07
    Scree Ore Mining Area, 2318AML07
    Ridge of Banded Ironstone, 374AML08
    Illegal Artisanal Miners Settlement, 374AML08
    Transport of Iron Ore to Screening Plant
    Screening Plant and Stockpiles, Mullock Dump from Large Open Cut in
    Background (in Valley, LHS)
    Illegal Artisanal Mining Pit in Scree Deposit, with Banded Iron Formation Ridge
    in Background, 802AML05
    For further information contact:
    Scott Enderby on Phone (02) 9482 4655
    Fax: (02) 9482 4987
    Email: [email protected] or
    Peter Kennewell on Phone: (02) 9482 4655
    Yours faithfully,
    Peter Kennewell,
    Managing Director
    NN HH CC
    PROJECT INVESTMENT AND MINERAL INDUSTRY ADVISORS
    Telephone 041 22 66 089 ACN 000 266 606 Level 4 15-17 Young Street
    Private (02) 9327 3320 [email protected] Sydney NSW 2000 Australia
    23 July 2008
    The Directors
    Cluff Resources Pacific NL
    Unit 1, 30 Leighton Place
    Hornsby NSW 2077
    Attention: Mr Peter Kennewell, Managing Director
    Dear Sirs
    TECHNICAL ASSESSMENT REPORT, KARNATAKA, INDIA, IRON ORE PROJECTS
    This independent technical assessment report (“the Report”) provides an assessment of five
    predevelopment iron ore projects in the southern Indian state of Karnataka, which Cluff
    Resources Pacific NL (“Cluff”) is currently considering for joint venture participation. The
    Report is prepared in keeping with the countersigned letter of engagement agreed with Cluff.
    The agreed scope of work for the Report excludes any consideration of due diligence aspects
    relating to legal, financial, accounting, taxation, and corporate matters, except to the extent that such
    matters are pertinent to the present assessment of projects for the Report. Cluff has arranged for the
    preparation of the specialist’s tenement report referred to in Section 8 of the Report.
    Site visits have been undertaken during the preparation of the Report by the undersigned to the
    three of the five iron ore project areas. A meeting was also held with the Director of Mines and
    Geology of the state of Karnataka.
    The five iron ore project areas are all at the local, ie Karnataka state, AML (Application for
    Mining Lease) stage. A minimal level of exploration expenditure has been undertaken, with no
    geological mapping prepared for any of the sites. There is extensive statistical data from prior
    iron ore mining at nearby locations, and also plain evidence of past and current unauthorised
    mining in some of the areas by artisanal mining workers.
    The proposal being considered by Cluff involves its 71 per cent owned subsidiary Elephant
    Gold Pty Limited becoming a 60 per cent shareholder in a planned incorporated joint venture
    company Karnataka Iron Ore Pte Ltd. The other 40 per cent pro-rata contributing shareholder is
    to be a local Bangalore company Sai Constructions.
    The focus of much of the Report is on the iron ore project located in the Bellary/Hospet region
    of Karnataka. That region produces the large majority of iron ore from the state and is the
    location for at least 140 current or former high grade, low impurity haematite iron ore open pit
    mines.
    Coollee aanndd AAssssoocciiaatteess PPttyy LLttdd
    Technical Assessment of Karnataka, India Iron Ore Projects 23 July 2008
    N H Cole and Associates Pty Ltd Page 2
    From inquiry of local experienced persons, it is the opinion of N H Cole and Associates Pty Ltd
    that the statistical data we have been able to review can nearly always be regarded as entirely
    reliable, even though much of the statistical data is slow to emerge from government sources.
    1. EXECUTIVE SUMMARY
    1.1 The five project areas are located in areas of active high grade haematite open pit mines.
    None has yet involved any significant exploration or assessment expenditures. Two are
    assessed as currently worthy of closer investigation.
    1.2 The Bellary project area in particular is located in an area of high grade low impurity mines,
    with production grades of at least 64 per cent iron and very low silica, alumina, phosphorus
    and sulphur levels.
    1.3 Ownership of the iron ore operating mines is widely diverse. The Bellary district has
    involved at least 143 mainly very small open pit mining areas, averaging 220 hectares in size.
    1.4 The Bellary project appears to offer the potential for a minimum of 200,000 tonnes of float
    ore, otherwise known as scree, at a grade of 65 per cent iron and higher tonnages of reef ore
    of uncertain grade.
    1.5 Infrastructure facilities are poor. The transport of ore to export ports is mainly in maximum
    13 tonne payload trucks, via roads partly in very poor condition.
    1.6 Verbal advice has been received that the mine gate price currently paid for 63 per cent iron
    ore fines is the equivalent of approximately A$77 per tonne.
    1.7 The float ore appears to indicate a potential pre-tax operating cash surplus of at least A$12
    million over an initial two year period from commencement of operations.
    1.8 All five areas are at the AML (registered Application for Mining Lease) stage.
    1.9 The processing of mining lease applications in Karnataka is extremely slow. For the latest
    available annual reporting period, 40 leases were granted from a total of 1216 applications.
    1.10 For the possibility of proving and developing the target Bellary district open pit iron ore
    project, the main risks assessed are the absence of any JORC Code mineral resources, the
    likely permitting delay, the contingency of future environmental constraints and medium term
    iron ore price risk, if a protracted period is involved in permitting.
    Technical Assessment of Karnataka, India Iron Ore Projects 23 July 2008
    N H Cole and Associates Pty Ltd Page 3
    2. ASSESSMENT METHODOLOGY
    For the preparation of independent expert technical assessment and valuation reports on mineral
    project interests, the appropriate professional standards are as set down in the provisions of the 2005
    Valmin Code1 of The Australasian Institute of Mining and Metallurgy ("The AusIMM"). Under the
    definitions of that code, three of the five areas are classified as Advanced Exploration Areas, with
    the other two possibly being classified as Exploration Areas.
    From the discussion later in the Report, it is possible to undertake a technical assessment for the
    five iron ore project areas, but it is considered premature to assign any fair market value
    assessment to the areas, partly because only a nominal amount of exploration expenditure work
    has been undertaken on any of the five areas. With work over the next several months, a fair
    market valuation assessment may be reasonably anticipated.
    The five iron ore project areas have been assessed with regard to the assessed prospectivity of the
    areas, taking into account the geological setting of the projects, and their geological and regional
    proximity to existing or past iron ore production areas.
    Except where otherwise noted, all references to mineral resources and ore reserves herein are in
    accordance with the Australasian Code for Reporting of Identified Mineral Resources and Ore
    Reserves, 2004 Edition (“the JORC Code”), as defined in and required under Appendix 5A of the
    ASX Listing Rules, effective 17 December 2004. References in many of the information sources
    listed in the Appendix to “reserves” reflects a much more liberal use of that term in India than
    applies under the JORC Code.
    References herein to dollars are to Australian dollars, expressed in July 2008 terms, except where
    otherwise indicated. The exchange rate adopted for the conversion of local currency is A$1.00 =
    41 INR.
    3. OVERVIEW OF THE INDIAN IRON ORE INDUSTRY
    India has a very large iron ore resource base, with an inventory in excess of 25 billion tonnes,
    with the haematite to magnetite ratio of about 58 per cent to 42 per cent. India has long been a
    major producer of high grade iron ore, with growth in recent years mainly to supply exports to
    China.
    There are two main iron ore production regions:
    • The Central and Eastern States of Orissa, Chattisgarh and Jharkhand, producing about 55
    per cent to 60 per cent of total production.
    • The South-Western States of Karnataka and Goa, producing the balance.
    1 "Valmin Code" is the Code and Guidelines for Technical Assessment and/or Valuation of Mineral and Petroleum
    Assets and Mineral and Petroleum Securities for Independent Expert Reports, 2005 Edition, which is binding on
    members of The AusIMM, and applies to all relevant reports issued from 29 April 2005.
    Technical Assessment of Karnataka, India Iron Ore Projects 23 July 2008
    N H Cole and Associates Pty Ltd Page 4
    The biggest growth in production has come from the state of Orissa, where production increased
    from 16.6 million tonnes to 49.9 million tonnes over the four years to 2006.
    There is very minor production of concentrates in India, from one mine source that mined and
    concentrated magnetite ore, but which closed in late 2005. There is no evidence of any form of
    concentration of lower grades of haematite ore feed by jigging or heavy media separation as is
    practiced extensively in the Pilbara region of Western Australia.
    The key iron ore industry data are shown in Table 1.
    Table 1
    INDIAN IRON ORE INDUSTRY STATISTICS
    Production Domestic
    Consumption
    Exports Balance
    2000-01 million tonnes
    2001-02 million tonnes
    2002-03 million tonnes
    2003-04 million tonnes
    2004-05 million tonnes
    2005-06 million tonnes
    80.8
    86.2
    99.1
    122.8
    145.9
    154.4
    36.0
    37.7
    40.9
    45.0
    48.2
    52.2
    37.3
    41.6
    48.2
    62.6
    78.1
    89.3
    7.5
    6.9
    10.1
    15.3
    19.7
    12.9
    For the latest statistical year, 38 per cent of production was from public sector organisations. 23
    per cent of production was from mines captive to steel works in India in 7 different locations.
    The low and declining proportion of lump iron ore can be seen in the data in Table 2.
    Table 2
    INDIAN IRON ORE EXPORT STATISTICS
    Iron Ore Fines Lump Iron Ore Total
    2003-04 million tonnes
    2004-05 million tonnes
    2005-06 million tonnes
    49.1 (78.5%)
    64.6 (82.7%)
    75.0 (84.0%)
    13.5 (21.5%)
    13.5 (17.3%)
    14.3 (16.0%)
    62.6
    78.1
    89.3
    Although Indian iron ore is well recognised as relatively high in grade and with low levels of
    silica, alumina and phosphorus, the recent trend has been consistently towards slightly lower
    grades, as shown in Table 3.
    Technical Assessment of Karnataka, India Iron Ore Projects 23 July 2008
    N H Cole and Associates Pty Ltd Page 5
    Table 3
    INDIAN IRON ORE EXPORT GRADES
    >64% Fe 63-64% Fe Lower Grade Total
    2002-03 million tonnes
    2003-04 million tonnes
    2004-05 million tonnes
    2005-06 million tonnes
    24.1
    21.9
    20.2
    18.1
    5.4
    15.6
    34.2
    39.3
    18.5
    25.1
    23.8
    31.9
    48.0
    62.6
    78.1
    89.3
    Figure 1 shows the location in India of the five project areas being assessed for joint venture
    participation by Cluff, referred to the five separate AML location groups listed later in Table 6.
    Figure 1
    LOCATION OF TARGET IRON ORE PROJECTS
    3.1 Iron Ore Production in Karnataka
    The high grade haematite and lower grade magnetite resources of Karnataka are very extensive,
    but with much of the magnetite being located in the Western Ghats area, which is described as
    ecologically sensitive. As at 2000, the recoverable haematite resources of 62 per cent to 65 per
    cent iron grade were estimated at 966 million tonnes. Earlier data (Indian Bureau of Mines, Year
    Technical Assessment of Karnataka, India Iron Ore Projects 23 July 2008
    N H Cole and Associates Pty Ltd Page 6
    Book, 1993) indicates the then estimates were that 714 million tonnes, or 77 per cent, out of a
    then total of 929 million tonnes of iron ore estimated for the state of Karnataka were from the
    Bellary district.
    High grade haematite has been mined in Karnataka since 1952.
    Table 4 shows the production data recorded for the latest two statistical years in Karnataka.
    Table 4
    IRON ORE PRODUCTION IN KARNATAKA
    Year to March 2006 Year to March 2007
    Lump iron ore
    Iron ore fines
    Total production
    14.0 million tonnes
    22.9 million tonnes
    36.9 million tonnes
    14.4 million tonnes
    21.8 million tonnes
    36.2 million tonnes
    For the latest available year, iron ore was produced from 6 of the total of 18 districts in
    Karnataka, with 88 per cent of production from the Bellary district in the central eastern part of
    the state, some 250 kilometres north of the state capital city of Bangalore.
    There are three types of exploration and mining tenements available in India, identified as mining
    leases, prospecting licences and reconnaissance permits. Data for Karnataka for the year to
    March 2006 show the following:
    • 35 mining leases were granted or executed, of which 9 were in the district of Bellary, for
    iron ore, manganese and red oxide, with an average size of 52.7 hectares; one much larger
    lease of 4605 hectares was executed in the district of Chickmagalur for iron ore. Of the
    total of 35, 19 were renewals.
    • 2 prospecting licences were granted, of average size 3.3 hectares, from 220 applications.
    • 3 reconnaissance permits were granted, of average size 1278 square kilometres from 14
    applications.
    The total of 40 tenements granted is from a total shown of 1216 applications. From a government
    report, “….. existing administrative procedures for the grant of mining leases are extremely
    tedious and tardy ………. It has been placed on record that an application has to pass through 77
    desks that require 485 to 765 days to cover.”
    As at late 2006, there were 147 mining leases in force in Karnataka with an average area of 321
    hectares. 101 or 69 per cent of these are in the Bellary district with an average area of 220
    hectares.
    The iron ore industry in Karnataka is very poorly served in terms of infrastructure, with most
    transport of ore being done in old trucks with 13 tonne payload limits on roads that are fairly
    described as in poor to very poor condition, with some sections having been heavily damaged.
    Technical Assessment of Karnataka, India Iron Ore Projects 23 July 2008
    N H Cole and Associates Pty Ltd Page 7
    The main iron ore export ports now in use are Belekere, New Mangalore and Karwar, on the
    western coast of India. There was nothing in any way suggested during the time of the recent
    field visit that there were plans for any improvement in roads or transport services.
    In the Bellary/Hospet/Sandur iron ore mining belt, recent work has shown that dust from mining
    and trucking movements has led to environmental exceedances for suspended particulate matter
    and for respirable suspended particulate matters. Spillages of iron ore fines from the transport
    trucks are quite common.
    4. GEOLOGY AND MINERALISATION
    The haematite iron ores of Karnataka occur mainly in the Sandur schist belt in two prominent
    bands, the western Sandur belt and the eastern Copper Mountain belt. All are associated with
    prominent hills and mountains, the origins of which are from the hard-standing erosion-resistant
    vertical to sub-vertical banded iron formations (“BIF”). The BIFs are characterised by alternating
    bands of iron oxides and silica, formed by volcano-sedimentary processes. Iron oxides and silica
    from submarine volcanic sources have been precipitated in Early Precambrian depositional basins
    in alternating layers, due to specific seasonal and chemical variations. Some of the Precambrians
    of Karnataka have been metamorphosed with the resulting fine grained magnetites with 45 per
    cent to 55 per cent iron, similar to the well known fine grained very hard taconite iron ores of the
    Minnesota Lake Superior region of the United States.
    The weathering, alteration and enrichment of Precambrian BIFs under surface conditions, either
    through the replacement of silica by iron or by the leaching of silica, during Tertiary and
    Quaternary periods have produced commercially valuable haematite rich supergene iron ores in
    the Sandur and Chitradurga schist belts. Such processes over a long period of time have given
    rise to massive orebodies occupying the crest of mountains, hills and elevated plateaus.
    The ores are friable and powdery with 62 per cent to 68 per cent iron content.
    From the recent field inspection, it is obvious that large quantities of high grade haematite ores
    occur as float ore, otherwise known as scree or colluvium, which are erosional products deposited
    on the faces of the hillsides or mountains which have been formed from the erosion resistant
    BIFs. The most obvious evidence of this is to be seen in the quite extensive surface workings of
    the unlicenced artisinal miners.
    4.1 Geological Setting for the Bellary/Hospet/Sandur Mines
    The haematite iron ores of the Bellary/Hospet/Sandur area occur in an associated group of
    mountain ranges, taking in an historical group of at least 140 separate haematite open pit mines,
    all but two with relatively small production, located at elevations from 540 metres to 980 metres.
    The Bellary iron ore mines are located in three sub-parallel groups of mountain ranges, mainly
    with a north-west to south-west orientation, as shown in Figure 2.
    Technical Assessment of Karnataka, India Iron Ore Projects 23 July 2008
    N H Cole and Associates Pty Ltd Page 8
    Figure 2
    HOSPET/BELLARY REGION IRON ORE MINES SETTING
    Technical Assessment of Karnataka, India Iron Ore Projects 23 July 2008
    N H Cole and Associates Pty Ltd Page 9
    The main line of historical and current operations strikes south-east from a distance about 4
    kilometres south-east of the town of Hospet for a further distance of about 40 kilometres, taking
    in the N E B, Thimmappanagodi and Donimalai mountain ranges.
    Offset to the south-west by about 4 to 6 kilometres are the Ramandurga, Devadari and
    Kumaraswamy ranges, over a distance of about 30 kilometres.
    To the north-east by about 15 to 20 kilometres, some 10 kilometres south-west of the town of
    Bellary is the further line of the Belagal Range, over about 20 kilometres.
    4.2 Data from Mines near the Bellary Iron Ore Target Area
    The Bellary iron ore project area described later in the Report is located at 76º41' E, 15º2' N, in a
    tenement application area of about 900 acres or 360 hectares over a north-west to south-east
    distance of about 2400 metres, by 1500 metres across. The elevation is from about 600 metres
    ASL to about 1030 metres ASL. Though little exploration work has been undertaken to date on
    this area, preliminary conclusions as to its prospectivity can be drawn from data in Table 5, for
    four other quite nearby open pit operations, which are assessed as being nearby in terms of the
    geological setting for the iron ore mineralisation.
    Table 5
    BELLARY REGION IRON ORE MINE DATA
    Project Name Appenhalli Ubbalagandi A Ubbalagandi B Ubbalagandi C
    Location, easting
    Location, northing
    Area, hectares
    Elevation
    Local mineralisation
    Iron ore grade
    76º40' E
    15º0' N
    520
    960 m ASL
    Refer Note 1
    66.95% Fe
    76º39' E
    15º3' N
    80
    920 m ASL
    Refer Note 2
    65.66% Fe
    76º39' E
    15º3' N
    80
    950 m ASL
    Refer Note 3
    67.32% Fe
    76º39' E
    15º3' N
    93
    690 m ASL
    Refer Note 4
    65.50% Fe
    Notes: 1. Three parallel iron ore reefs 300, 400 and 410 metres long, 15 to 24 metres wide;
    float ore concentration on both slopes to estimated 200,000 tonnes; 4 million tonnes
    of reef worked to 60 metres depth.
    2. One iron ore reef, steel grey, laminated and friable of about 1 million tonnes to 60
    metres depth, with float ore on the eastern slope; 30% of mined ore in powdery form.
    3. Two iron ore reefs 600 and 200 metres long and 9 to 12 metres wide, described as
    hard, compact and friable; estimated 1.5 million tonnes of reef ore to 60 metres
    depth, and 500,000 tonnes of float ore on the eastern slope.
    4. Float ore only, estimated at about 260,000 tonnes.
    Technical Assessment of Karnataka, India Iron Ore Projects 23 July 2008
    N H Cole and Associates Pty Ltd Page 10
    The impurity levels in the iron ore reported for these four mining areas are reported as under:
    • Silica in the range of 1.38 per cent to 1.70 per cent
    • Alumina in the range of 1.28 per cent to 2.24 per cent
    • Phosphorus in the range of 0.025 per cent to 0.039 per cent
    • Sulphur in the range of trace to 0.009 per cent
    Such impurity levels are very low by comparison for example with iron ore products exported
    from the Pilbara region of Western Australia, and reflect products that would be in high demand
    in the international seaborne iron ore trade, for Chinese and other markets.
    Such impurity levels have been reviewed in the context of assay results recorded for 97 iron ore
    leases out of the total sample of 143 Bellary District mines reported in 1985. No assay results
    were recorded for the other 46 iron ore leases. Those results show the following assay results:
    • Minimum iron content of 64.0%, except for two much lower grade outliers
    • Maximum silica content of 3.68%, except for one much higher grade outlier
    • Maximum alumina content of 4.1 per cent
    • Maximum phosphorus content of 0.058%2, except for six higher grade outliers over 0.1
    per cent
    • Highest sulphur content of 0.013 per cent, except for two higher grade outliers.
    The Bellary District mines are of the highest iron ore grades known to N H Cole and Associates
    Pty Ltd. However, in iron ore project development terms, the district is handicapped
    • by the very small size of the diversely owned mining leases, identified in the 1985 report
    as mostly 30 to 200 hectares in size, with only 4 larger than 400 hectares (and more
    recently in late 2006 with an average 220 hectare size, as shown in Section 3 above), but
    more particularly
    • by the severe lack of adequate infrastructure access.
    There are no policy moves known from government or the private sector towards amelioration of
    either of these handicaps, in any moves towards a more efficient iron ore industry in the district.
    2 This phosphorus level compares with the historical maximum levels of 0.08 per cent phosphorus for
    premium grade haematite exports from the Pilbara region of Western Australia.
    Technical Assessment of Karnataka, India Iron Ore Projects 23 July 2008
    N H Cole and Associates Pty Ltd Page 11
    5. THE FIVE IRON ORE PROJECT OPPORTUNITIES
    Summary details about the five project areas being considered by Cluff for participation are
    shown earlier in Figure 1 and also in Table 6 on the following page. Certain fields indicate where
    the data are not available or not yet known (“n a”)
    The table indicates preliminary assays from samples gathered during the recent field visits. More
    detailed assays for deleterious elements in these samples have not yet been received.
    Location No. 1 2A (NE front face) 2B (SW back face) 3 4 5
    Project Name Elladakere Rajapur Doddapura Holalkere n a
    Approximate location 47 km SSE of Chitradurga 16 km ESE of Sandur 15 km SE of Holalkere 32 kms SW of Chitradurga 20 kms W of Hiriyur
    Site visits pm 20 June 2008 noon 21 June 2008 pm 21 June 2008 not seen not seen
    Application for Mining Lease 2511AML07 2318AML07 374AML08 802AML05 503AML05 44AML02
    AML date 3 September 2007 16 August 2007 10 March 2008 16 June 2005 15 April 2005 27 March 2002
    Applicant T K Chandrappa T K Chandrappa T K Chandrappa Sri Shiridi Sai Baba Sri Shiridi Sai Baba Indus Mines &
    Mines & Minerals Mines & Minerals Minerals
    District Chitradurga Bellary Chitradurga Chitradurga Chitradurga
    Taluk (headquarters) Hiriyur/Hosdurga Sandur Chitradurga Holalkere Hosdurga
    Villages Elladakere, Ittegehalli Rajapur Ubbalagundi Ramapura Chudenahalli Lakihalli
    Nerlakere, Kasapanahalli Doddapura Thenegehalli
    Lakshmidevarahalli Hirekandavadi
    Easting, northing 76º31' E, 13º46' N 76º41' E, 15º2' N 76º16' E, 13º55' N 76º11' E, 14º10' N 76º26' E, 13º55' N
    Approximate area (hectares) 240 160 200 120 320 55
    Approximate elevation 1100 m ASL 600 - 1030 m ASL 920 m ASL 790 m ASL 700 m ASL
    Other iron ore mines nearby No Yes No Yes No
    Current/recent artisanal mining yes, minor yes, quite major yes, minor n a n a
    Environmental sensitivity High Low Low n a n a
    Samples taken 20/21 June 2008 yes – 2 yes - 3 yes - 2 no no
    Preliminary assays
    59.4%Fe outcrop, beneath
    scree 31.2% Fe, BIF outcrop, west side
    55.9% Fe, -30+15mm
    colluvium
    48.7% Fe, unsorted
    colluviums 52.5% Fe, BIF outcrop, east side
    41.0% Fe, +30mm
    colluvium
    66.8% Fe, colluvium, brecciated rock
    Forestry status Mari Kanive State Forest Donimalai State Forest n a n a Lakihalli State Forest
    forested area, not forested not forested n a n a
    AML description Kamari trees no vegetation no vegetation "Busy vegetation" n a
    Strike NE/SW Strike about 500' NS Float ore Strike NE to SW Reef and float ore n a
    near vertical dip dipping E 80º dipping to E strike NE/SW, dip E 70º n a
    Technical Assessment of Karnataka, India Iron Ore Projects 23 July 2008
    N H Cole and Associates Pty Ltd Page 12
    Table 6
    SUMMARY DETAILS, FIVE TARGET IRON ORE PROJECT AREAS
    Technical Assessment of Karnataka, India Iron Ore Projects 23 July 2008
    N H Cole and Associates Pty Ltd Page 13
    Summary comments about the five target iron ore project areas are indicated below.
    Location 1 2511AML07
    This area is located in what is assessed as an environmentally sensitive area, along a mountain
    ridge, to the immediate north and south of which, along the ridge line, are located dozens of large
    recently installed wind-power turbines. It is quite unlikely mining development would be possible
    without some degree of interference with this power generation activity. It is also in a designated
    forestry area with valuable trees that are prone to theft, so the access roads and tracks have been
    blocked by the digging of several trenches that are impassable even for four wheel drive vehicles.
    Samples taken from one of the obvious earlier artisanal mining areas included an elevated iron
    ore assay. In the opinion of N H Cole and Associates Pty Ltd, any expenditure on this area would
    be of a high risk nature, with little indication available that mining development could ever be
    permitted.
    Locations 2A 2318AML07 and 2B 374AML08 (contiguous)
    This area is assessed by N H Cole and Associates Pty Ltd very encouraging. It is considered in
    greater detail in Section 6 below.
    Location 3 802AML05
    This area appears encouraging, with mining development potential. However, little information is
    known about any nearby iron ore properties. Eventual mining development may be able to be
    permitted, and in the opinion of N H Cole and Associates Pty Ltd, participation in preliminary
    investigative exploration work is justified, up to the stage of assessing if the potential for float ore
    warrants more serious exploration work, including costeaning, drilling and preliminary
    metallurgical assessment by way of crushing and screening trials, for the determination of assays
    for different size fractions. Like the earlier two locations, there is evidence of considerable
    artisanal mining activity in this area.
    Location 4 503AML05
    This area is described as being adjacent to the existing Chitradurga John mine, but little
    information has been made available. It is not known if the area lies in the same geological
    setting or whether it is along strike from the adjacent area of mining activity. The extent of
    artisanal mining activity, if any, is not known. In the absence of information, no observations can
    be made about the potential merits of this area.
    Location 5 44AML02
    The same comments apply as for the prior Location 4 area.
    6. THE BELLARY PROJECT AREA OPPORTUNITY
    The contiguous areas in Locations 2A and 2B are assessed as quite encouraging. The two
    contiguous AML areas are as shown in Figure 4.
    Technical Assessment of Karnataka, India Iron Ore Projects 23 July 2008
    N H Cole and Associates Pty Ltd Page 14
    Figure 3
    LEASE APPLICATION AREAS, BELLARY PROJECT
    6.1 The Bellary Project Tonnage and Grade Potential
    From the discussion in Section 4.2 above, it is possible to draw the inference of good potential in
    this area, insofar as field inspection shows
    Technical Assessment of Karnataka, India Iron Ore Projects 23 July 2008
    N H Cole and Associates Pty Ltd Page 15
    • the obvious near vertical mountain-top outcropping of three BIF reef structures, with fine
    grained slab structures sampled during the field inspection
    • the presence of extensive quantities of float or scree material, a single grab sample of
    which yielded an assay of 66.8 per cent iron, and
    • dozens of people involved in artisanal mining of float ore, both on the north-east front
    scree face of the mountain and much further away in the flat river valley area below the
    mountain slope.
    A broad analysis from the information in Section 4.2 above suggests the potential for
    • 200,000 to 500,000 tonnes of float mineralisation, that is quite likely to be high grade by
    usual iron ore standards, and
    • up to 2 million tonnes of reef material to a maximum depth of about 60 metres, of more
    uncertain grade, with more expensive development and mining costs, and a longer lead
    time to production.
    It should be noted that the potential tonnages above are well short of being classified as mineral
    resources in keeping with JORC Code standards.
    From the recorded information about nearby mined iron ore grades shown in Table 5 in Section
    4.2, the grade to be anticipated from the float material is at least 65 per cent iron, with low levels
    of silica, alumina, phosphorus and sulphur impurities.
    6.2 Bellary Project Revenue Considerations
    Providing exploration work confirms the existence of at least 200,000 tonnes of high grade float
    material, and providing a mining lease can be obtained without the significant delays referred to in
    Section 3.1 above, there appears scope for a small but economically viable operation to be
    planned.
    During the time of the recent site visit, the undersigned was advised verbally that, unlike the
    export market, the preferred product for local sales was -10 mm iron ore fines, rather than lump.
    The mine gate price for such material was currently said to be 3150 INR per tonne, at 63 per cent
    iron content. This is the equivalent of A$76.83 per tonne of iron ore fines sold. A request has
    been made for written confirmation of such prices, including prices for lump ore, and price trends
    over the past three or four years, but this information has not yet been received.
    At a grade of 65 per cent iron, there is an iron ore royalty payable to the state of Karnataka at the
    rate of 15.5 INR per tonne.
    From a consideration of supply/demand factors and especially in relation to keeping the growing
    Chinese import demand satisfied, large new tonnages of iron ore will need to be sourced from
    sources other than the low-cost high-productivity areas of Brazil and the Pilbara region of
    Western Australia. Prices will need to reflect the marginal costs of the new higher cost producers
    Technical Assessment of Karnataka, India Iron Ore Projects 23 July 2008
    N H Cole and Associates Pty Ltd Page 16
    soon to be entering the market, such as magnetite concentrate imports from the MidWest region of
    Western Australia. In the opinion of N H Cole and Associates, this will keep iron ore prices at
    high and possible even higher levels for the next two to three years. However, the reality of a
    mid-term reversal of price trends is well recognised by market commentators.
    As of the date hereof, and assuming no adverse tax or other structural changes to the iron ore
    industry in India, then for a two to three year view, a mine gate price assumption of at least A$70
    per tonne appears reasonable, with a longer term base price of perhaps A$50 per tonne to be
    assumed.
    If an initial 200,000 tonne float ore project could be demonstrated to JORC Code standards and
    brought to production after 12 months, ie by July/August 2009, the gross revenue prospects for all
    involved are at an aggregate level of A$14 million.
    6.3 Bellary Project Cost Considerations
    Establishing a starter project at the target Bellary area will require exploration and feasibility
    study expenditure costs, and not inconsiderable overhead, acquisition, corporate, legal and other
    holding costs, for whatever time it may take to demonstrate a JORC Code mineral resource and
    ore reserve, achieve a mining lease and prepare to commission a project, initially involving a
    potential threshold target of 200,000 tonnes of high grade float ore, to be mined if possible over a
    two year period. These initial high risk capital costs would perhaps be at a minimum of
    A$500,000 but could prove to be as high as A$2 million.
    For a threshold-level starter float iron ore project however, direct operating costs should be quite
    low. Based on the recent field visit evidence, once a form of JORC Code compliant ore reserve is
    established and a mine plan agreed and permitted, the operation should involve nothing more than
    the following:
    • Surface mining of free-dig ore, with no drill and blast of overburden or ore required, by
    bulldozer or similar plant.
    • Loading and trucking of waste overburden or interburden, if any, to waste dumps outside
    the area of the known float ore mineral resources, to a maximum distance of perhaps
    1000 metres.
    • Loading and trucking of ore to an in-pit ROM (run-of-mine) stockpile area, at a distance
    of up to perhaps 500 metres from the mining face.
    • Screening of ROM tonnages in a double-deck or triple-deck screening plant, possibly
    involving the existing nearby contract operator.
    • Storage of one or two finished sized products at a final products stockpile area, for later
    loading into trucks provided by the purchasers of the finished product(s).
    • Overhead costs, including project management, environmental monitoring, assaying and
    tenement management costs.
    Technical Assessment of Karnataka, India Iron Ore Projects 23 July 2008
    N H Cole and Associates Pty Ltd Page 17
    Local operating costs include wages and salaries, plus maintenance supplies and consumables, of
    which the main cost would be diesel or other fuel costs for mobile plant. Given local wages rates
    and employment conditions, at an initial scale of say 100,000 tonnes per annum for a two year
    project, direct operating costs should not exceed A$10 per tonne of product, and could be
    significantly lower if minimal waste to ore overburden ratios are involved.
    Significantly higher capital and operating costs would be involved if further exploration work
    leads to the conclusion that a larger project involving the exploitation of any reef ore is warranted.
    6.4 Bellary Project Future Cash Flow Potential
    If a starter project can be established for 200,000 tonnes of high grade float ore, with revenue
    assumed at A$70 per tonne and costs at A$10 per tonne, the potential is for an on-site surplus of
    some A$12 million over a two year operating period. The expectation would be for greater cash
    flow if more float ore is defined or if further work demonstrates the economic viability of any reef
    ore that may be available to be demonstrated.
    Any such potential cash flows are estimated before taxation, royalties, corporate and all other
    overhead costs.
    6.5 Bellary Project Technical Assessment
    Subject to the risk assessment considered in the following Section 6.6, the technical assessment
    for the Bellary project is summarised in the following terms:
    • Though without any specific indications as to JORC Code mineral resources and/or ore
    reserves, the target Bellary project appears to have strong indications for a potentially
    viable project in a region which has a very extensive history of high grade haematite open
    pit mine operations.
    • A nominal amount of exploration expenditure has been spent on the project to date. The
    history of any earlier work by third parties, if any, is not known. If the prospectivity of the
    two contiguous AML areas is as good as it seems to be, the issue that arises for inquiry is
    why has no other party already taken a serious interest in the area, prior to the current
    AML application dates of 16 August 2007 and 10 March 2008.
    • Based on averages for other AML areas in Karnataka, it is possible the grant of a mining
    lease could involve a considerable time delay, in the extreme to a protracted time when
    iron ore prices have reduced considerably below current levels.
    6.6 Bellary Project Risk Assessment
    The assessment of project risk factors is covered under paragraph 103 of the 2005 Valmin Code.
    Technical Assessment of Karnataka, India Iron Ore Projects 23 July 2008
    N H Cole and Associates Pty Ltd Page 18
    A technical assessment of the Bellary district target iron ore project has to be qualified with regard to
    Risk Factors, with such factors needing to be considered in the context of the future contingent
    impact on business viability based on three factors:
    • The assessed frequency or likelihood of a future occurrence of an adverse risk event.
    • The business impact or consequence of such an adverse risk event occurring.
    • The scope that may or may not be available to the project owners to mitigate or remediate
    the potential consequential business impact of any such adverse business events.
    By way of example, a medium term limitation in overall permitted trucking tonnages in the
    district, arising possibly due to inadequate infrastructure or environmental considerations, would
    be likely to have a significant to severe business impact, especially for an undefined project not
    yet at the feasibility study stage. At the other extreme, recurrent crushing and screening plant
    shutdowns due to power failure or other reasons might be not infrequent, but the potential
    business impact may be minor, with mitigation of the impact by short term increases in
    production, and by the management of ROM (run-of-mine) stockpiles, crushed ore stockpiles, and
    intermediate and finished product stockpiles.
    Quantified risk ratings can be derived for a range of factors by reference to the diagram below.
    3 4 5
    2 3 4
    CONSEQUENCE
    1 2 3
    LIKELIHOOD
    In the following Table 7, risk ratings assessed for several different potentially adverse risk factors
    are shown, having regard for the assessed likelihood and consequence as shown in the figure
    above. The risk ratings must be read in the context that the Bellary district target iron ore project
    is at an entirely preliminary stage of project definition, with a large amount of further study and
    other investigative work required to determine if a JORC Code mineral resource can be estimated
    and if there is a technically and economically viable project.
    Technical Assessment of Karnataka, India Iron Ore Projects 23 July 2008
    N H Cole and Associates Pty Ltd Page 19
    Table 7
    BELLARY IRON ORE PROJECT RISK ASSESSMENT
    Potentially Adverse Risk
    Factor Assessed
    Likelihood Consequence Risk
    Rating
    Comment
    Exploration
    Resource estimation
    Reserve estimation
    Iron ore tonnages
    Mine planning
    Geotechnical
    Feasibility study preparation
    Operating costs
    Capital costs
    Production scheduling
    Mid-term prices deterioration
    Iron ore grades
    Deleterious elements
    Plant design, eqpt selection
    Environmental limitations
    Permitting and delays
    Logistics and infrastructure
    Weather
    Seismic activity
    Utilities
    Project management
    Labour & skills availability
    low
    low
    low
    medium
    low
    low
    low
    low
    low
    low
    high
    low
    low
    low
    medium
    high
    medium
    low
    low
    low
    low
    medium
    moderate
    moderate
    moderate
    moderate
    slight
    slight
    moderate
    moderate
    moderate
    slight
    severe
    slight
    slight
    slight
    moderate
    severe
    moderate
    slight
    slight
    slight
    moderate
    moderate
    2
    2
    2
    3
    1
    1
    2
    2
    2
    1
    5
    1
    1
    1
    3
    5
    3
    1
    1
    1
    2
    3
    No JORC resources
    Simple geometry
    None yet, but simple
    Speculative
    Simple mine design
    Good conditions
    None yet complete
    No information
    No information
    Straightforward
    Significant risk
    Good grades indicated
    Regional information
    Contingent constraints
    Severe delays normal
    Poor conditions
    Minimal
    Site generated power
    Local expertise
    As yet untested
    Save for the permitting and medium term commodity price risks, which are high, the total lack of
    any JORC Code mineral resource tonnage, and the contingency of future environmentally based
    tonnage constraints, the Bellary project at the present stage of demonstration is assessed generally
    at a moderate level of risk, with the mitigation of most risk factors possible as the project
    progresses through initial exploration expenditures and subsequent feasibility study stages.
    Technical Assessment of Karnataka, India Iron Ore Projects 23 July 2008
    N H Cole and Associates Pty Ltd Page 20
    7. TECHNICAL ASSESSMENT CONCLUSIONS
    7.1 Prior Assessments and Valuations
    As required under paragraph 40 of the 2005 Valmin Code, N H Cole and Associates Pty Ltd and
    the undersigned hereby report that they are not aware of any prior technical assessments or
    valuations that have previously been prepared for the iron ore project interests reviewed in the
    foregoing sections of this report.
    7.2 Technical Assessment Conclusions
    Having regard to the foregoing risk assessment in Section 6.6 of the Report and also for the lack of
    JORC Code resources or reserves, it is the current opinion of N H Cole and Associates Pty Ltd
    • that there are merits worthy of pursuit in the projects described in the Report as Locations 2A,
    2B and 3, and
    • that staged, conditional exploration expenditure participation by Cluff in those two projects is
    warranted.
    It is the further opinion of N H Cole and Associates Pty Ltd that it is not reasonably possible to
    ascribe a fair market value to the projects at the present time, although the prospects for this in after
    several months’ detailed investigative exploration work are quite encouraging.
    8. VERIFICATION OF TENEMENTS AND TITLES
    To meet the verification of tenements and titles requirements of paragraphs 67 to 73 of the 2005
    Valmin Code, Babu Pattar Solicitiors of Bangalore have been retained to provide the necessary
    independent report. That report has not yet been received, but on an interim basis N H Cole and
    Associates Pty Limited has relied on the following written representations from the registered
    applicants for the five AML project areas described in the report, as summarised in Table 6:
    Technical Assessment of Karnataka, India Iron Ore Projects 23 July 2008
    N H Cole and Associates Pty Ltd Page 21
    9. STATEMENT OF CAPABILITY
    The undersigned is a Fellow and past Councillor of The AusIMM, and a past Fellow of the Securities
    Institute of Australia with experience of more than 20 years in the technical assessment financial
    analysis, valuation, and investment appraisal of resources projects. Specifically, more than 100
    separate projects have been assessed or valued, the majority of which have related directly to the
    determination of a consideration which could fairly or reasonably be paid by interested purchasers for
    mining or mineral projects or project interests. The undersigned previously has been responsible for
    the provision of independent expert reports in the assessment of takeover bids or other proposals
    involving resources companies, as required under corporate regulatory guidelines and ASX Listing
    Rule requirements for independent expert valuation and assessment opinions. The undersigned is
    responsible for and is a contributor to all sections of this report.
    The other contributor to the technical assessment of the Advanced Exploration Areas and
    Exploration Areas reviewed in Sections 4, 5, 6.1, 6.5 and 7.2, in keeping with the requirements of
    paragraph 22 of the 2005 Valmin Code, is geologist Mr Peter Kennewell, Managing Director of
    Cluff.3.
    10. PRIOR INVOLVEMENT AND INDEPENDENCE
    N H Cole and Associates Pty Ltd and the undersigned are independent of and have had no prior
    client relationship or any other form of involvement with Cluff. N H Cole and Associates Pty Ltd
    will receive a time-based professional fee plus reimbursement for out of pocket costs for the
    preparation of the Report, payment for which is not contingent on the outcome of Cluff’s potential
    involvement with the iron ore projects reviewed in the Report. There is no pecuniary or other
    interest which could reasonably be regarded as being capable of affecting the independence of N
    H Cole and Associates Pty Ltd or the undersigned.
    N H Cole and Associates Pty Ltd and the undersigned, and members of his immediate family have
    no interest or entitlement in the securities of Cluff, or in the any of the project areas the subject of
    the Report.
    11. LIMITATIONS AND DECLARATION
    This assessment has been based largely on a detailed examination of information about the iron ore
    project interests, largely on the basis of reports and other information made available by or through
    officers of Cluff, and from the site visit recently undertaken. The statements and opinions contained
    herein are given in good faith and represent our own independent assessment of the information
    provided. Much of the information reviewed has been presented in a professional manner but it is not
    possible to provide the usual declaration that all such information is believed to be true, complete as to
    3 Mr Kennewell has consented in writing to the form and context in which the technical assessment comments
    in the sections noted have been used in deriving the technical assessment conclusions included in Section
    7.2.
    Technical Assessment of Karnataka, India Iron Ore Projects 23 July 2008
    N H Cole and Associates Pty Ltd Page 22
    aterial details and not misleading.
    purpose of this report in no way constitutes a technical
    udit of any of the project interests reviewed.
    m the circulation or use of this report other than from
    roven wilful misconduct or negligence.
    report. No substantive changes to this report
    ave been made as a result of the review by Cluff.
    ustralasian Institute of
    ining and Metallurgy, and is subject to the Codes of Ethics of that body.
    H Cole and Associates Pty Ltd
    Principal and Managing Director
    m
    The assistance provided by Cluff and its officers in facilitating the preparation of this report is
    acknowledged. The work undertaken for the
    a
    N H Cole and Associates Pty Ltd has been indemnified by Cluff in respect of any consequential
    damages, costs and expenses arising fro
    p
    An advanced draft copy of this report was submitted to Cluff for comment as to any errors of fact
    or misunderstandings or misinterpretations, or substantive disagreements as to the assumptions
    made explicitly or implicitly in this report, but expressly not in relation to the valuation
    methodology or valuation conclusions drawn in the
    h
    The undersigned hereby declares that he is a Corporate Member of The A
    M
    Yours faithfully
    N
    N H Cole
    N H Cole
    B E (Hons), FAusIMM, MCIM
    Technical Assessment of Karnataka, India Iron Ore Projects 23 July 2008
    N H Cole and Associates Pty Ltd Page 23
    Appendix
    PRINCIPAL INFORMATION SOURCES
    For the purposes of preparation of this report, N H Cole and Associates Pty Ltd has relied on the
    principal information sources listed below.
    1. Geological Maps of Karnataka, 1:500,000, undated
    2. Various 1:250,000 scale and 1:50,000 scale topographical plans, 1976 to 2002
    3. Sudhaker, K S, Government of Karnataka, Department of Mines and Geology, Iron Ore
    Leases of Bellary District, 1985
    4. Radhakrsihna, B P, ed, Precambrian Banded Iron Formation of India, 1986
    5. Radhakrsihna, B P, Geological Society of India, Mineral Resources of Karnataka, 1996
    6. Government of India, Ministry of Mines, Indian Bureau of Mines, Mines and Minerals
    (Development and Regulation) Act, 1957, as Amended up to 20th December 1999, January
    2000
    7. Pattabhiramaiah, N R, Government of Karnataka, Department of Mines and Geology,
    Districtwise Geology and Mineral Resources of Karnataka, Geological Studies No 345,
    2001
    8. Government of India, Ministry of Mines, Indian Bureau of Mines, Mineral Concession
    Rules, as Amended up to 5th May 2005, August 2005
    9. Venugopal, T N, Government of Karnataka, Department of Mines and Geology, Mineral
    Resources of Karnataka and Challenges for its Extraction, Geological Studies No 387,
    February 2006
    10. Baderiya, G, et al, Government of Karnataka, Department of Mines and Geology, The
    Status of Iron Ore Mining in Karnataka, Geological Studies No 391, November 2006
    11. Baderiya, G, Government of Karnataka, Department of Mines and Geology, Administration
    Report of the Department of Mines and Geology for the Year 2005-2006, 2007
    12. Government of India, Ministry of Mines, Indian Bureau of Mines, Bulletin of Mineral
    Information, Vol 24, No 2, October 2006 – March 2007
    13. Government of India, Ministry of Mines, Indian Bureau of Mines, Monthly Statistics of
    Mineral Production, Vol 39, No 3, March 2007
    14. Federation of Indian Mineral Industries, Indian Iron Ore, 2007
 
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