Project Information

Project Title

Bear Lodge Rare Earth Project

Sector

Mining

Project Location

Location Type: Both



• Latitude *: 44° 30′ 00"
  Longitude *: 104° 27′ 00″

Project Sponsor Contact Information

• Company Name/Agency: Rare Element Resources, Inc. (RER)
  Project Sponsor: Rare Element Resources, Inc. (RER)
  Street Address 1 : PO Box 80
  City: Firestone
  State: Colorado
  Zip Code: 80520
  POC Name: Ken Mushinski
  POC Title: Chief Executive Officer
  POC Phone: (720) 278-2460
  POC Email Address: KMushinski@RareElementResources.com

Alternative Point Of Contact (Optional)

Yes 

• Company Name/Agency: Rare Element Resources, Inc. (RER)
  Project Sponsor: Rare Element Resources, Inc. (RER)
  Street Address 1: PO Box 80
  Street Address 2: NA
  City: Firestone
  State: Colorado
  Zip Code: 80520
  POC Name: Kelli Kast
  POC Title: VP/GC/CAO
  POC Phone: (303) 278-2460
  POC Email Address: KKast@RareElementResources.com

Project Purpose

The Bear Lodge Rare Earth Project is a vertically integrated project designed to secure America’s rare earth element (REE) supply chain and address a critical national security vulnerability. The project encompasses mining a USGS-recognized REE resource at the Bear Lodge deposit on National Forest System lands that will become feed material for a state-of-the-art commercial processing facility that will produce high-purity separated neodymium-praseodymium (Nd/Pr) oxide using RER’s patented, environmentally superior technology. The processing facility will be located on private land, approximately 40 miles from the mine area. Neodymium and praseodymium are both on the USGS Critical Minerals List. This project’s primary objective is to develop and operate a standalone domestic REE mine that will be a source of feed material to RER’s planned processing and separation facility, supplying strategic materials to downstream partners for alloy and permanent magnet manufacturing essential to defense and high-tech industries, independent of foreign sources or processing.

Project Description

Overview & Location:
The Bear Lodge Project utilizes the planned Bull Hill Mine, located near the town of Sundance in northeastern Wyoming which is comprised of several disseminated REE deposits and characterized by a favorable distribution of critical magnet REEs, specifically neodymium-praseodymium (Nd/Pr), and other essential REEs. The Project includes the Bull Hill Mine (pit, ore hauling, waste rock storage, ore stockpile, ore crushing and loading, pit dewatering, and site management), grid supplied power, and access/transportation in to and out of federal lands.

RER controls 100% of the mineral rights at the Bear Lodge property, consisting of 499 unpatented mining claims located on National Forest System land, and an adjacent 640 acres owned by RER. The Bear Lodge Property is located within parts of Sections 5, 6, 7, 8, 9, 14, 15, 16, 17, 18, 19, 21, 22, 23, 26, 27, 28, 29, 30, 31, 32, 33, 34 and 35 in Township 52 North and Range 63 West, Sixth Principal Meridian, Crook County, Wyoming.

The Bear Lodge Project area is in central Crook County, Wyoming, in the northwestern portion of the Black Hills uplift, situated in the central Bear Lodge mountains. The Bear Lodge Project is flanked to the west by the Powder River Basin, known for its extensive coal mining, and is adjoined by the plains to the southeast.

The project lies about 7 air miles or 12 road miles northwest of Sundance (Wyoming), approximately 22 air miles west of the South Dakota-Wyoming border, 55 air miles east of Gillette, Wyoming, and 230 air miles north of Cheyenne, the Wyoming state capital.

In parallel with the Bear Lodge Project, RER, in conjunction with its technology partner General Atomics (whose affiliate is RER’s majority shareholder), are advancing the goal of providing American-sourced REE through the development of innovative, proprietary REE processing and separation technologies capable of handling feed material from the Bear Lodge Project and possibly from other sources. The hydrometallurgical processing plant (Hydromet Plant) will be located on privately held land in Weston County, Wyoming, near the town of Upton which will serve as the site for the plant and associated support facilities.

NEPA:
The U.S. Forest Service’s (USFS) use of an Environmental Assessment (EA) is an appropriate and legally defensible NEPA pathway for the Bear Lodge Project.

The current Bear Lodge Project represents a materially smaller undertaking than the action evaluated in Draft Environmental Impact Statement published in 2016. The revised Mine Plan of Operations reflects a substantially reduced project footprint, a shorter operating timeframe (reduced by more than half), and the elimination of previously proposed exploration activities. Importantly, the Mine Plan of Operations incorporates comprehensive applicant committed and agency identified environmental protection measures developed during the previous NEPA process. These measures are expressly intended to avoid or reduce environmental effects below the level of significance. These changes significantly narrow the scope and intensity of potential environmental effects relative to those previously analyzed.

Current federal policy emphasizes timely and efficient review of critical mineral projects, and the USDA Forest Service’s revised NEPA implementing procedures (7 CFR Part 1b) explicitly allow for mitigated FONSIs where enforceable mitigation reduces impacts below the threshold of significance. Recent Forest Service decisions for mining projects demonstrate consistent application of EA/FONSI determinations based on incorporated environmental protection measures.

Taken together, the reduced scope of the Bear Lodge Project, the elimination of higher impact components, the incorporation of binding mitigation measures, and the current NEPA regulatory environment all support the conclusion that a finding of no significant impact is likely and supportable, and thus an EA level of NEPA and finding of no significant impact is appropriate.

Geospatial Summary & Planned Facilities:
In response to prior agency and public feedback, the proposed project has been substantially redesigned to minimize surface disturbance. The project will result in disturbance of about 260 acres on National Forest System lands, inclusive of the Bull Hill Mine pit of approximately 132 acres.

Environmental, Cultural, and Historic Resources:
Many environmental, cultural, and historical resources were previously analyzed in the Bear Lodge Project Draft Environmental Impact Statement (EIS), published in 2016. The Draft EIS evaluated air quality, cultural and historic resources, soils, surface water and groundwater, vegetation, wetlands, fish and wildlife, and timber. As the project progresses toward new federal permitting actions, baseline surveys for these resource areas are being updated to ensure that accurate, current information is available to support upcoming NEPA analyses.

A key project‑related feature on National Forest System land involves the creation of an open pit and, possibly, the development of a pit lake. Prior to and during mining, groundwater will be actively removed from the pit to maintain dry working conditions, which may temporarily lower groundwater levels and may reduce water availability to nearby springs and seeps. After mining ends and dewatering ceases, groundwater levels are expected to rebound to at or near‑pre‑mining conditions, ultimately forming a pit lake.

Technical and Financial Ability

Technical Ability:
RER’s management team has extensive expertise in mining, mineral processing, and project execution.

Ken Mushinski, President and CEO, has 30+ years of leadership in resource industry operations, including production and decommissioning, bolstered by his strategic role in General Atomics’ uranium operations.

Cameo Flood, RER’s contracted NEPA Permitting Coordinator, has over 30 years of experience in NEPA permitting for resource projects, including 10 years as a federal NEPA coordinator and an additional 24 years as a consulting project manager/leader for mines and mine closure, transmission lines, pipelines, timber management, fire management, and weed control; working with federal and state agencies in multiple states, including more than 25 environmental impact statements.

Kelli Kast, Vice President, General Counsel, and Chief Administrative Officer, contributes 30 years of legal expertise in the extractive industries, including rare earth and precious metals, with 13 years of tenure at RER. Her experience enhances the Company’s ability to navigate complex regulatory and permitting landscapes.

WSP, as NEPA Contractor for RER, adds proven expertise in environmental permitting and NEPA compliance, strengthening the team’s ability to deliver a defensible EIS and navigate complex regulatory processes efficiently.

This collective expertise and proven success on other mining projects positions RER to manage the complex technical demands of a vertically integrated rare earth project, from mining to high-purity Nd/Pr oxide production.

RER’s technical capability is further enhanced by its patented, proprietary, environmentally superior REE processing and separation technologies, developed in collaboration with General Atomics, whose affiliate is the majority shareholder of RER. These innovations are tailored to the Bear Lodge deposit’s mineral profile, which contains a high distribution of the magnet REEs Nd/Pr. The relationship with General Atomics, a leader in advanced technologies, not only strengthens RER’s processing capabilities but also provides access to operational know-how, ensuring the Bear Lodge Project can meet stringent technical and environmental standards for a domestic REE supply chain.

The RER team has previously advanced NEPA permitting on the Project, with a Draft Environmental Impact Statement (EIS) prepared in early 2016 which was put on hold by RER due to market conditions at the time. A Plan of Operations (POO) was prepared in 2014, and an NRC license application was submitted in May 2015. Environmental baseline data covers hydrology, water quality, vegetation, wildlife, fish, historical resources, and climate. These data were updated in 2018, 2023, and 2025. Reports before 2025 and the 2025 wildlife report were submitted to both the US Forest Service and Wyoming Department of Environmental Quality (WDEQ), Land Quality Division (WDEQ-LQD). The 2025 wildlife report was submitted to the Forest Service, and remaining 2025 reports will be submitted when complete.

Financial Ability:
RER, publicly traded on the Over-the-Counter Quotations (OTCQB) market under the ticker REEMF (market cap $393M as of 2/19/2026), has showcased a robust financial strategy to support its Bear Lodge Rare Earth Project.

• A March 2024 shareholder rights offering, which was oversubscribed, raised approximately US$35.8 million, highlighting strong investor confidence. These funds were designated for advancing the Project, including the operation of a demonstration plant which has been constructed at $70+ million in total cost) and general corporate needs. The Company has recently completed another rights offering, raising approximately US$30 million.

• RER has secured government support for its technology development, notably as a cost-share recipient of $24.2 million matching funds awarded in 2021 by the U.S. Department of Energy (DOE) toward a technology demonstration plant. Additionally, RER received a $4.4 million matching fund award toward the demonstration plant from the Wyoming Energy Authority. These non-dilutive funds support the engineering, construction, and operation of RER’s rare earth separation and processing demonstration plant, aligning the project with national priorities for critical minerals.

Additionally, RER received a Letter of Interest from the Export-Import Bank (EXIM) bank for potential loan funding for the advancement of the Bear Lodge Project up to an amount of $553 million. RER’s success raising capital, strategic relationship with General Atomics, and government support collectively indicate a solid financial foundation.

Summary of Financing, Reviews and Authorizations

Federal Financing:
RER has previously secured and is pursuing further Federal financial support to advance its technology development, reflecting its importance to U.S. critical mineral supply chains. The prior support by the Federal and state of Wyoming governments highlights the government’s commitment to supporting domestic REE production for applications in defense, energy, transportation, and technology.

No further federal financing is required to complete the Project, although further support by federal and state agencies may provide opportunity for investment.

Environmental Reviews:
As the Bull Hill mine of the Bear Lodge Project is located on USFS in Wyoming, it must undergo comprehensive environmental reviews to comply with federal and state regulations. The USFS has already been determined to be the lead agency. Key aspects include:

• Federal Regulations:
o National Environmental Policy Act (NEPA): NEPA requires an assessment of potential environmental impacts due to the mine site location on federal land and a federal decision by the US Army Corps of Engineers under the Clean Water Act.

o US Nuclear Regulatory Commission (NRC) License: RER’s demonstration plant in Upton, Wyoming is already licensed by the NRC for the possession of NORM (naturally occurring radioactive material), notably Thorium and Uranium, both of which are present in trace amounts in the Bear Lodge deposit. The commercial Hydromet Plant is to be located on private land and therefore have no impact on National Forest or other federal lands and will require a source material possession license from the NRC (or the State of Wyoming, with primacy of the licensing program) due to this same NORM content.

•State Environmental Regulations: Wyoming state environmental permitting in accordance with the State’s regulations on land quality (mining), water quality (discharges), air emissions, and waste management will be required. RER will coordinate with the WDEQ for necessary approvals. RER will also be required to comply with the Wyoming Industrial Siting Regulations. Finally, Wyoming, as an Agreement State, is expected to have primacy commencing in 2026 over the U.S. Nuclear Regulatory Commission (NRC) to regulate the concentration of NORM as it pertains to REE mining, aiming to streamline permitting and licensing processes for REE mining and processing within the state.

Authorizations:
The Bear Lodge Project (both the mine and Hydromet Plant) requires Federal and state authorizations to proceed legally and operationally. Key authorizations may include:

• U.S. Forest Service (USFS) Permits: Since the project will operate on National Forest System land, RER must complete appropriate NEPA processes and secure approval of its Mine Plan of Operations from the USFS. The USFS approval ensures compliance with Federal mining laws and includes reclamation plans and financial assurance to guarantee reclamation after mining activities conclude.

• U.S. Fish and Wildlife Service (USFWS): Section 7 of the Endangered Species Act (ESA) (16 U.S.C. §§ 1531-1544) requires all federal agencies to ensure their actions, funding, or authorization do not jeopardize threatened or endangered species or harm their critical habitats through consultation with USFWS for terrestrial species. It also mandates conservation programs for listed species, prohibits "taking" (harming/killing) them, and regulates commerce in listed species.

• The U.S. Army Corps of Engineers will be required to conduct a Jurisdictional Determination of the streams that may be affected by the Project and evaluate whether a Section 404 permit is required.

• State Permits: A state of Wyoming permit to mine, air quality permit, water quality permit, and an industrial siting permit are required to advance the project to operational status.

• Advisory Council on Historic Preservation (ACHP): Section 106 of the National Historic Preservation Act (NHPA) (54 U.S.C. §§300101 et seq.) requires federal agencies to assess the impact of their projects on historic properties and other relevant cultural resources, and involve ACHP (when required), relevant tribes, and the public in the review process. It also requires that federal agencies consider any feasible ways to avoid, minimize, or mitigate any adverse effects on those properties before project approval or funding, through consultation with any relevant State and Tribal Historic Preservation Officers (SHPOs and THPOs).

• Clean Air Act: The Clean Air Act requires mining projects to obtain and comply with federal and state air quality permits, implement emission controls, and take reasonable precautions to prevent fugitive dust and other air pollutants generated by mining operations. These requirements typically include securing construction and operating air permits, adhering to applicable standards, and implementing best management practices to control particulate emissions from drilling, blasting, haul roads, material handling, and ore processing activities.

• Source Material License: A license from Wyoming’s WDEQ to possess source material pursuant to its primacy transfer from the US Nuclear Regulatory Commission will be required for the commercial processing facility to be located on private land outside of the National Forest.

Project Assessment

The Bear Lodge Rare Earth Project (mining and ore removal) meets the definition of a "covered project" as outlined in 42 U.S.C. §4370m(6)(A) of the Fixing America’s Surface Transportation Act (FAST Act) due to its clear alignment with the statutory criteria.

1. Federal nexus: The project involves federal involvement through its location on National Forest land and the requirement for Federal permits, such as an approved Mine Plan of Operations.

2. NEPA applicability: The location on federal land, need for approval of the Mine Plan of Operations and other federal approvals needed.

3. Cost Threshold: The Project’s estimated cost is greater than $200 million. EXIM has given RER a non-binding LOI for $553 million for construction. Total development capital is expected to be more than $700 million, to be confirmed in the final Definitive Engineering Study.

Collectively, these factors (the Federal nexus, NEPA applicability, and substantial cost) confirm that the Bear Lodge Project meets the requirements of 42 U.S.C. §4370m(6)(A), qualifying it as a "covered project" under the FAST Act.