EXHIBIT 99


                              CONFIRMING STATEMENT

      This Statement confirms that the undersigned, Terry M. Palmer, has
authorized and designated each of Mark A. Lettes, Keith R. Hulley, Jeffrey G.
Clevenger, and Daniel J. Stewart, signing singly, to execute and file on the
undersigned's behalf all Forms 3, 4 and 5 (including any amendments thereto)
that the undersigned may be required to file with the U.S. Securities and
Exchange Commission as a result of the undersigned's ownership of or
transactions in securities of Apex Silver Mines Limited. The authority of each
of Mark A. Lettes, Keith R. Hulley, Jeffrey G. Clevenger, and Daniel J. Stewart
under this Statement shall continue until the undersigned is no longer required
to file Forms 3, 4 and 5 with regard to the undersigned's ownership of or
transactions in securities of Apex Silver Mines Limited, unless earlier revoked
in writing. The undersigned acknowledges that Mark A. Lettes, Keith R. Hulley,
Jeffrey G. Clevenger, and Daniel J. Stewart, are not assuming any of the
undersigned's responsibilities to comply with Section 16 of the Securities
Exchange Act of 1934.

Date:       September 30, 2004


                                          /s/ TERRY M. PALMER
                                          --------------------------------------
                                          Terry M. Palmer