Digging in the Mine Permitting Process at ANM
Hello fellow Verde shareholders,
I have spent some time exploring the online registry and database provided by ANM the National Mining Agency in Brazil. This was in order to gain a better understanding of the critical licencing process our Company must follow to secure the necessary permits to proceed with mineral extraction. I thought you might be interested in what I have learned to date.
As I recently posted, Verde has 32 tenements which remain active in its exploration and development of the Cerrado Verde project (down from an original 96 in 2010). These have been narrowed to the following 12, which we assume represent the ones with the highest concentration of the potassium we are seeking. These are:
833.306/2008
830.383/2008 (*)
833.263/2008
833.323/2008 (*)
833.276/2008
833.295/2008
833.270/2008
833.272/2008
833.268/2008
833.324/2008
833.326/2008
833.280/2008
On January 11, 2021 a Mining Application was submitted by FVS Mineracao to the ANM seeking a concession for the annual extraction and processing of 25 million tonnes of Rocha Potassica mineral on a combined basis from the 12 tenements listed above. The ANM acknowledged the application and agreed to process it as a single combined submission, so linking all 12 tenements on its database.
On February 12, 2021 a response was issued by the ANM which reads (in part):
Considering that the Application of Mining (fls. 297/623e fls. 629/790 PIAE updated physical process) was filed, timely, on 07/06/2013 and 16/07/2018 (Approval of the RFP published in the DOU of 05/09/2013 – fl. 295 of the physical process), form I - Analysis of Study of Areas (document SEI No. 0671070),Form II - Procedural Regularity (800 to 802) and Form III - PaE Analysis (fls. 803 to 807) was elaborated. It should be noted that the process already has a draft issued through the document SEI No. 0674684 and with notification contained in Letter No. 210/2020/DFMNM - MG/GER - MG document SEI No.1094814. Only the analysis of the Environmental License presented by the holder on 01/11/2021 remains through the document SEI No.2110928
Based on this response, it appears the only issue holding up the approval of the 25 million tonne per year concession is the receipt of the necessary Environmental licences. The response then notes that the Environmental Licences submitted by FVS on January 11, 2021 only addressed the 2.5 million tonne per year production from tenements 833.323/2008 and 830.383/2008 as noted above by (*) but had nothing for the remaining 10 tenements making up the combined application.
It then gives a 60 day notice period which expires on April 12, 2021 for FVS to submit the necessary Environmental Licences for the other 10 tenements. Based on the numbers in the 2020 MD&A, I don’t think these licences are currently in hand, so cannot be submitted by the April 12, 2021 deadline set by the ANM.
Which is of course all somewhat moot as the target for production in 2021 is only 350,000 tonnes for which the Company is already fully permitted.
Anyway, another question to add to the list for April 7, 2021 Q&A with Mr. Veloso.
Stay tuned,
S