The closest I would assimilate this to would be the financial services sector. Their legislation is written completely differently from this. It's exempt and not non-commercial activity, which is a new concept. With that, there is a zero-rating provision. Notably, for financial institutions that have some activities with non-residents, that's considered to be zero-rated and not exempt, which means it gives them the opportunity to claim their input tax credits.
I would also add that there is specific legislation for refining in the mining industry of precious metals that equally gives the refiner the ability to claim back the input tax credits, recognizing that this is the most expensive part of the process. After that, it's simply passing along that precious metal.
On Dan's point, just quickly, I would add that the legislation is not only unfair because it limits input tax credits, as we mentioned; it's also unfair to certain provinces because it limits the input tax credits you're paying depending on what province you're in. For instance, in you're in Quebec or if you're in the Atlantic provinces, the 15% rate will discourage mining in those provinces versus provinces with a lower tax rate.