Comstock Inc. (LODE)
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Apr 24, 2026, 4:00 PM EDT - Market closed
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Fireside Chat

Nov 18, 2025

Peter Gastreich
Managing Director of Energy Transition and Sustainable Investing, Water Tower Research

Sustainable metals company with additional investments in renewable fuels, mineral properties, and real estate. Its high-volume solar panel recycling technology diverts end-of-life solar panels from landfills and recycles 100% of the commodities that go into them, like silver, aluminum, and other valuable and sometimes scarce resources. Before we get started, I would like to point out that the company's safe harbor statements can be found on its investor relations website. This fireside chat may not be reproduced or written transcript distributed without the express written consent of Water Tower Research. Also, this conversation is being recorded so you can access it again in the future and share it with others. Finally, we will try to get to questions that have been submitted by investors, and if not, we'll make sure those are delivered to Corrado and his team after our chat today.

With those housekeeping notes out of the way, let's get started. Corrado, welcome, and thanks so much for joining us today.

Corrado De Gasperis
Executive Chairman and CEO, Comstock Inc.

Thanks for having me. It's an absolute pleasure.

Peter Gastreich
Managing Director of Energy Transition and Sustainable Investing, Water Tower Research

Okay, great. Let's jump right in. Let's start with your systems-based strategy. From a high level, what is the broad overarching goal and business strategy for achieving this goal, and how do the main business segments, metals, mining, real estate, and fuels, contribute?

Corrado De Gasperis
Executive Chairman and CEO, Comstock Inc.

Yeah, great question. The fundamental goal of the company is to accelerate the commercialization of technologies and the products that come from those technologies that make a major critical impact in the markets. We do think systemically. In a way, that means what market has a problem? What market can we address? What's blocking companies or supply chains from actually achieving that? When we say systemic strategy, we say, what's the system, and then what's the bottleneck or the constraint of that system? We think of it in the context of scenarios where those aren't being addressed. We essentially say, if there's a problem in the market that's not being addressed, if we understand what's blocking and we can unblock that with our technology developments, with our solutions, then we like to go after those markets.

They're impactful environmentally, they're impactful financially, and they're making a difference. We say accelerate the commercialization of those technologies, those solutions in those circumstances.

Peter Gastreich
Managing Director of Energy Transition and Sustainable Investing, Water Tower Research

Okay, great. Thanks, Corrado. In terms of this system-based strategy that you've outlined, in what ways does the company's management structure and expertise support the execution? How does it address the challenges of operating in what are diverse, but as you know, certainly very much related sectors for your company?

Corrado De Gasperis
Executive Chairman and CEO, Comstock Inc.

Yeah, it's a great question. First of all, it really comes down to the people that work within our system, that management structure. It's not siloed. It's not functional in the narrow band sense of it. What we basically do is we organize our people, our competencies, our teams around the goal. Sounds obvious, okay? It's just remarkable how uncommon it is to organize yourself that way. I think part of that, there's such an established paradigm on corporate hierarchies. Everybody has a precise functional role. They just don't interface very well when you're structured that way. We define the goal. We define the steps required to achieve the goal. Most people would call that a strategy. Then we organize the teams and the projects. We have chemists and scientists and mathematicians. They're extraordinary. We have engineers.

We have commercialists, people who monetize, who make markets, who make offers into markets. We have financial competency. We have human competency. What you'll see in our management structure is teams organized around what competencies are needed to achieve a specific major step towards the goal. This has gotten some popularity recently, but we've always thought this way. What is the biggest conflict that's facing a project today? What is the biggest conflict facing a market today? What is the biggest conflict facing the company today?

We prioritize, in fact, the culture of this management structure is to surface the conflicts that are most blocking, the most important obstacle, if you want to think of it that way, bottleneck, constraint that we're facing, create a culture in organization that surfaces that and encourages the surfacing of that, welcomes the surfacing of that, and then the teams organize professionally, project-based around attending and attacking those things. That can be done at the enterprise level. Why are all these solar panels going into landfills? That's the problem statement. Tsunamis of them that are going to toxify our water systems and our environments. Why? How do we tackle that problem? Why can't biofuels gain any traction and self-sustain themselves in the market? The feedstock, the carbon in the feedstocks, there is not a technology that efficiently unlocks enough of it to make a difference.

I did not answer it fully in your first question, but what are the synergies across the markets? Clearly, they are all natural resources. Clearly, they are all in the commodity cycle and some would say supercycle. Clearly, they are all sophisticated industrial supply chains. We also like to leverage existing infrastructures and not try to create brand new, entirely new infrastructures. Those are common denominators. I think the most common thing is just how we think and how we approach a problem. I think it is the most common thing pervasive within our management structure, but it is very uncommon, which creates a problem for us in hiring people outside the company because in a way, we have to educate, some would say indoctrinate, but we have to certainly assimilate them into our culture.

Peter Gastreich
Managing Director of Energy Transition and Sustainable Investing, Water Tower Research

Okay, understand. I'd like to turn to your business operations in a moment, but before we get to that, could you please share your recent financial milestones? You've been very busy executing on this front with successful capital raises and notably the elimination of all debt. What has been happening there and how is that positioning you for executing your growth strategy?

Corrado De Gasperis
Executive Chairman and CEO, Comstock Inc.

Yeah, no, absolutely. Love to answer that question. Maybe let me take a half a step back. Five years ago, four years ago, we took technologies that would clearly unblock the constraint of the problem, but were immature. It's not fun, Peter, like going to the capital markets and what's your technology readiness level? Three. What's your technology level? Five, where six is when you've proven a TEA, Technical and Economic Assessment. Seven is when you're scaling it. It was hard. We had incurred some debt and we had some convertible notes.

Last year, when we were hitting six and seven, and in the case of seven with metal recycling revenue in a huge market, in fuels where we hit six and Marathon Petroleum proved our product and was very excited and said, "We'd like to partner with you." When those things happened, to answer your question now, we were able to bring in Marathon Petroleum to invest directly into the fuels business and raised another $20 million in cash on top of that to fund the fuels business and really graduated up into almost its own mature stand-on-your-two-leg company. Soon thereafter, we raised over $34 million to fund the metal scale-up, rapid scale-up to go to industry scale and enough capital to pay off all of our debt and our obligations, fully fund the scale-up of the first facility and have enough runway to get all the way to profitability.

We're in a new state of reality as a company where both businesses are funded, but more importantly, to your point, eliminate all of the debt and more than just the debt. Eliminate debt, eliminate obligations, and eliminate even future obligations. Very, very strong from a financial position perspective.

Peter Gastreich
Managing Director of Energy Transition and Sustainable Investing, Water Tower Research

Okay, yeah. It's a great foundation laid down there in terms of the financial side. Corrado, it's that time we're going to kind of get into the weeds here a little bit. Let's take investors through your operations, starting with the solar panel recycling. The first thing there would be, let's discuss what makes Comstock's approach and technology with the solar panel recycling so differentiated. It'd be great if you could tie in a little bit about how this positions the company within the broader critical metals and mining industry.

Corrado De Gasperis
Executive Chairman and CEO, Comstock Inc.

Absolutely. The problem is this tsunami of solar panels, 1.4 billion panels already deployed in the United States with an amazing growth profile in front of it, but 1.4 billion already there. Our technology has four major differentiators. One, we're the only company, and we're certified as such by the industry, that has a zero-landfill solution. The first thing we do is we eliminate all contaminants in a way that the reprocessing of these metals generates zero waste. By generating zero waste, you're eligible for certain permits, especially here in Nevada, which is very strict with environmental permitting regimes that would be very difficult for someone to replicate. Secondly, we do it super efficiently. The totally variable cost of electricity and natural gas that we use is less than 7% of our revenue and stably so. That is a remarkable cost profile.

Third, we can process a panel very fast. We load the machine every seven seconds. By loading a panel every seven seconds, we can do 3.3 million panels a year. Speed, number three, translates to scalability, number four. In the market, because the dilemma, because of the problem in the market is so many panels coming out, if you do not have the capacity to take them, store them, and process them, you miss the market, they go to landfills. We have positioned ourselves. Let me just say, that first point that I made about being able to eliminate the contaminants is based on decades of experience of our President, PhD chemist who spent all of his career, over 40 years, building industrial facilities and operating them all over the world, almost always with hazardous materials.

Perfecting the ability at the molecular level, at the atomic level, to depolymerize, to break down those polymers and then oxidize them out so that there's no harmful emission and there's an elimination, then you can resell these materials clean. If those laminants and plastics and glues aren't eliminated, guess what? They stick to the metal. Guess what also sticks to the metal? Lead, cadmium. You're now a hazardous waste generator instead of a clean metal reprocessor. When you look at what's happening geopolitically, the U.S. put itself at a disadvantage, always chasing cost, always exporting all of our production to China. Obviously, that's understood now. People understand that now and there's a reversion back. How do we build domestic supply chains for these critical materials? We're the largest purchaser. We're the largest market in the U.S.

Why wouldn't we want to be reusing these materials and keeping those critical minerals and domestic supply chains here where they're needed desperately? We play a big role in that. The last thing that we are still to do is develop a refining solution. We're already producing clean glass, clean aluminum, and these tailings are clean, meaning you can refine them without those contaminants. However, we'd like to refine them ourselves because the U.S. has a gap in refining, unfortunately. We need to reestablish the entire closed loop here at home.

Peter Gastreich
Managing Director of Energy Transition and Sustainable Investing, Water Tower Research

You have this tsunami of solar panels. I like that. That's very well put. That will stick. How should we think about converting this tsunami of solar panels into the operational elements here of the panel recycling? For example, how should investors think about revenue streams like tipping fees or commodity sales? You mentioned a little bit about the cost structure. You touched on the natural gas cost structure being quite competitive.

Corrado De Gasperis
Executive Chairman and CEO, Comstock Inc.

Yeah. Two points on that. First, let me say that just use silver as an example just for a minute. There's about 0.5-0.6 troy ounces of silver in every panel on average, give or take a little. If we're producing 3.3 million panels, if we're processing 3.3 million panels a year, you start to push like 1.6, 1.7, 1.8 million ounces of silver. If you have two facilities, that's 3.5, 3.6, almost 4 million ounces of silver. I think the largest silver mine in Nevada today does 4.1 million ounces. There's a real shot at us to become a leading silver producer in the number one jurisdiction in the country, the Silver State of Nevada. If we have five, six, seven facilities across the United States, we would be the largest silver producer in the country.

When you talk about magnitude, we'd just be getting warmed up at that point that you're talking about a meaningful situation. Now let's translate that into cost and revenue. The variable costs are low, as I mentioned. If you converted it, it would be about $35 a ton, assuming we're operating to the scale that I was talking about. Variable cost stays the same, of course, as $35 a ton. The fixed cost at full scale would contribute all in. That's not everything. We get paid upfront about $500 a ton to take that environmental liability off of the utility company's hands. They have a problem. They have to dispose of it. It's universal/hazardous waste. They have to pay to do it. We're competitive with that. They don't have to pay more for us.

We get $500 a ton just upfront, just to take that off of their hands. Today, we're getting about $200-$250 a ton to resell 100% of those materials, excluding the contaminants that were eliminated, which tend to be about 7% of the weight. On an equivalent value per ton, we're getting $500 a ton to take it. We're getting $250 a ton to reship and sell clean aluminum, clean glass, silver-rich tailings. One production line in one facility is $12 million. Based on the numbers that we just discussed, you'll generate $50 million-$60 million in cash flow, assuming it's running full. Really, the throughput model, if you will, throughput, in our definition of throughput, is the speed at which the system generates cash.

If you're doing a panel every seven seconds, they're paying you upfront to take that panel, and then you're selling it all again, that's high throughput. We love it. I mean, I don't know of a better economic model. Fast, low variable cost, low CapEx.

Peter Gastreich
Managing Director of Energy Transition and Sustainable Investing, Water Tower Research

How about taking this model and scaling it up? Sort of what are the plans for growing this platform?

Corrado De Gasperis
Executive Chairman and CEO, Comstock Inc.

Yeah. If you look at the U.S. deployment of the 1.4 billion panels, remarkably, we would estimate 50% of the end of life in the target zone of end of life is in California. When you add Southern Nevada, Northern Nevada, Arizona, the southwest region, you're at about 60%, in our opinion, our estimate, pretty good estimate of the end-of-life panels for the whole country. By having a facility in Northern Nevada and Southern Nevada, you can cover more than half of the U.S. domestic market. You look across the country, Texas, Florida, North Carolina, New England, Michigan, Minnesota, those are the hubs of where the solar panels are. They vary in age. The younger ones are less priority markets. The older ones are high priority markets. We just want to deploy up to seven facilities in those markets.

We will also deploy some storage to optimize logistics a bit. The best thing to do to optimize logistics is be as close to the hubs of those panel deployments as you can, full stop. The next thing you'll do is maybe have some regional storage where it makes some sense to aggregate. Otherwise, you're spending more on logistics. The third thing is, where would you put a refinery once we've developed that solution? You won't be refining at every facility. You might need one or maybe two because only about 12% of the material represents these silver-rich fines. Most of the material is glass when you're talking about weight, then aluminum, and then third is these silver-rich fines, which are the most valuable, but the least heavy.

You would probably have some notion of spoken hub when it comes to refining, but here in the U.S. Excuse me. Just to make a very critical point, we've been approached by Australians. We've been approached by Indians. We've been approached by Europeans. We've even been approached by some Middle Eastern representatives who have said, not all of them have said this, but at least two have said this. We recycle e-waste. We do not have a solution for solar panels. We've looked around and seen what solutions are currently out there. We don't see any solution that can scale.

I think ultimately, we want to make sure that we maintain control over the technology deployment, but there will probably be some notion of either joint ventures or international expansions because, very critically, every number that I said to you, 1.4 billion panels in the U.S., it's 8x-10x bigger if you look at the global footprint. 8x-10x . That means there's 8 billion-10 billion panels deployed today in the world.

Peter Gastreich
Managing Director of Energy Transition and Sustainable Investing, Water Tower Research

You mentioned earlier about silver as an output. I guess it would be an understatement to say that prices have been on the uptrend recently. It would appear that you could not have asked for a better timing for this project, all considered as far as the silver market is concerned. Let's talk about the silver market. What do you view as the key drivers there for increasing that demand for silver? How are these recycling operations poised to benefit from those trends?

Corrado De Gasperis
Executive Chairman and CEO, Comstock Inc.

Great question. Silver was confounding to me a decade ago and even half a decade ago. Why? Because you saw demand growing with electrification. There were some offsetting things. It was declining in use in some fields. It was increasing use in others. It was hard to get a handle around it. Here's the bottom line. The electrification explosion, and people point to EVs, of course. People point to these batteries and even these new generation batteries, which are requiring more and more silver. People point to photovoltaics. They're expanding like there's no tomorrow. Silver is the best, most efficient conductor that people are all over using. What's happened recently, though, in the last four years is that the demand for silver, hitting a record in 2025 now, the demand for silver has clearly turned robust.

We're using anywhere from 120 million to just recently 200 million more ounces of silver per year than the mines are producing. I can tell you, if you think you're going to put a new silver mine into production in less than 10 years, you're out of your mind. The supply cannot catch up from hard rock mining, from conventional mining, and the demand is exploding. To my earlier point, yes, EVs, yes, computers, yes, solar panels, but what about these data centers? What about the GPUs? What about the massive conductivity of the electrical grids and now off-grid deployments? What about robots? I think the demand curve is just, I mean, people are rationally estimating 20%, 30%, 40% growth over the next decade. I don't think they're understating it. It's going to be stronger.

You said the silver price go from the high teens to the high 20s to the high 30s. Did it hit $54 last night? I think it did. We're bullish on those metals. We always have been, and we were somewhat confounded by why is it so depressed? I think that's broken out now, and it's macro. The supply and demand portion of this discussion has taken the lead versus the investment portion versus the monetary discussions.

Peter Gastreich
Managing Director of Energy Transition and Sustainable Investing, Water Tower Research

You have exposure to the silver market there through your panel recycling, but we can also move into your precious metals mining interests. Let's talk about that. What is the current status and the strategic importance when it comes to your silver and gold mining district holdings?

Corrado De Gasperis
Executive Chairman and CEO, Comstock Inc.

Yeah. I think that the platform, we consolidated this 12 sq mi mineral district, which is one of the most famous silver mines in the country, if not the world, gold and silver, of course. We mined it from 2012 to 2016. Our first pour was 1,733 gold, I think like 35 silver, somewhere around there. Our last pour was 1,033 gold. That was 2016. We stopped the mining. With foresight and because the maintenance of the platform was very efficient, spend maybe today it'd be like $1.3 million a year to maintain the infrastructure, all the properties, the permits, and have a small, highly technical team, Chief Geologist, Chief Engineer, Junior Geologist, Safety Supervisor. That's all in place.

To me, what's strategic about it is for a very, very low cost of maintenance, we have a huge call on gold and we have a huge option on gold and silver. Our Dayton resource at $3,500 gold and $35 silver would throw off net about $500,000,000 over a six-year mine life. We think it's ultimately bigger than that. For us, with all the monetary devaluation, the debasements, all these things going on, it provides a huge platform and hedge for us from an asset base. It's production performance ready. Within a reasonably short period of time, we can put those assets into production. Now, everybody asks me, "Please, don't allocate capital to drilling or developing or putting a mine into production while you can deploy it into the solar panel recycling facilities." I agree.

We are allocating capital first and foremost to the highest return, but also we want to capture as much of that market as possible. We do not want to lose leadership in that market. The mining assets are not going anywhere. They are very easy and simple to maintain. They are entitled. We are getting some inquiry now because of the robustness of the cycle of maybe someone wanting to joint venture, maybe someone wanting to help facilitate moving forward. We are open to all of that. At the end of the day, it is strategic in the sense that it gives us a safe platform of value. I am not sure it is being very well recognized. We are about to publish in the next couple of months a preliminary economic assessment that then has a third party say, "Here is the sensitivity of the economics of this mine.

Here is what we've been saying we know all along. I think that will go a long way to really credibly opening people's eyes to the potential economics of this.

Peter Gastreich
Managing Director of Energy Transition and Sustainable Investing, Water Tower Research

Okay. Got it. Thank you. Maybe moving over to the real estate holdings that you have in Nevada. How do some of the recent infrastructure developments in that area, and you have data centers as well, how is this impacting the value of those real estate holdings?

Corrado De Gasperis
Executive Chairman and CEO, Comstock Inc.

It's having an incredible impact, and it's very, very active. We have some real estate about 30 minutes from the mine site. It's all industrial. It sits right at the crossroads of the Tahoe-Reno Industrial Center where Tesla first showed up in a big way with their first gigafactory. There are a bunch of industrial companies there that are crown jewel companies. About five years ago, Switch started expanding their data center platform. Google and Microsoft showed up, and that was like, "Holy cow." Apple started expanding their data center platform. I don't know, I don't think it would be an exaggeration to say a dozen other hyperscalers, Track, Compass, all these, all showed up and are building out what's turning out to be one of the largest data center hubs in the world. We have properties right along that corridor.

They're entitled and situated perfectly for that same type of expansion. Now what we're getting is they call it land power data consortiums who are saying, "We have our own power. We have clean power. We have off-grid power. We'd like to come and invest and/or acquire these properties to build out more of this." In Silver Springs, it's really elevated the property values. We want to monetize this in a way that is best for our shareholders. It's very, very active. It's a lot of sophisticated counterparties. There's another part of this too, which is that a lot of our prior mineral properties, which either do not have mineral potentials or have been exploited in the context of previous mineral potentials, are pretty well suited to do the same thing.

This whole Highway 50 corridor from the Comstock all the way to Silver Springs presents some tremendous, tremendous opportunity. It is a little nascent. I do not think we really consider it a line of business today. It is real estate, and how do we optimize that real estate with the right best transactions?

Peter Gastreich
Managing Director of Energy Transition and Sustainable Investing, Water Tower Research

Okay. That's great. We have one business left to go through, and that's fuel. Regarding Bioleum Corporation, how did the company's involvement in Bioleum and advanced biofuel technologies originate? What is the strategic significance of the partnerships? You mentioned Marathon Petroleum before, and you've got RenFuel, Hexas Biomass, and perhaps the other proprietary technologies in this area you could mention.

Corrado De Gasperis
Executive Chairman and CEO, Comstock Inc.

Yeah. I'll say that how it originated, look, we stayed pretty darn close to home with our core competencies, which are mineral properties, metallurgy. It seems reasonably logical to hard rock mine go into urban mining and reprocessing of these metals. There's a lot of tech. There's a lot of differences. In a general scope of the types of people that you're working with, we speak the common languages, and we do similar things. With fuels, it was really as we got into the renewable space, we started making certain associations, and we were introduced to this technology that did exactly what we typically would look for. The renewable fuel industry has a lot of disparate technologies. I guess, Peter, I'd like to use the word necessary, but not sufficient to describe almost all of them.

One works really, really well on a feedstock that could not power a neighborhood. One does not work well at all on an abundant feedstock. One is a critical part of the technology stack, but on its own does not really get you there. The great part about this industry is there is such a tremendous amount of innovation going on. The horrible part about it is no one has aggregated it into a functional supply chain that actually works. We stepped back and we said, "What is the bottleneck? What is the constraint of this industry?" The first reaction, which everybody would agree to, feedstock. That is not incorrect. Let me say this. It is not incorrect, but it is not totally correct. It is the technology to convert that carbon into fuel, into oil, into fuel. That is the bottleneck.

That's what will unblock a ridiculous abundance of carbon that today sits in waste woody biomass. Today sits there. When we looked at it, there seems to be a lot of competency in taking cellulose, making pulp, making alcohol, ultimately making ethanol. Brewers can do that. Corn ethanol manufacturers can do that. Quite a few technologies exist to do it with cellulose. Cellulose is only a third of the composition of the wood. The other two-thirds of the carbon sits in the lignin. If you crack the code on the lignin, you go from producing 45 or 50 gallons of fuel per ton of waste wood to doing 120, 130, 140 gallons of fuel from the same exact ton of waste wood. We said that technology is extremely attractive. It's extremely promising. However, in and itself, it's also not sufficient.

Do we have a partner willing to take those oils today and convert them into fuels? Enter Marathon Petroleum. Do we have a really practical way of converting the crude lignin into a stable oil and to RenFuel? Are we comfortable, even though we know on a macro scale there is sufficiency of waste wood? Are we comfortable that that's sufficient for us? Because you want to tuck in a 500,000 ton a year facility near some lumber mills in Minnesota. You want to tuck in a 1 million ton a year or 3/4 million ton a year facility in Louisiana next to the sugarcane mills. Do you want to partner with the pulp and paper mills who are throwing off this kraft lignin and burning it or throwing it away? All that is a yes.

We also found that you can grow this carbon very, very fast in a way that enriches the soil, sucks CO2, of course, out of the air, puts most of it into the soil, retains most of it, I'm sorry, the other less than most of it, the other minority in the stock, and provides an endless source of carbon, a renewable regenerative source of carbon that allows you then to scale and aggregate the supply chain much less disparately, much more collectively, condensedly so that it becomes practical. From Hexas Biomass to Organosolv solution to RenFuel esterification to hydro treating to Marathon, we put together something that we believe is sufficient. At the same time, the National Renewable Energy Lab approached us and said, "Holy crap. It looks like you're approaching sufficiency." They did not say it that way, but they might as well have".

We think we have some breakthroughs that could reduce your capital, increase your energy, reduce your operating expense. We started looking at these models and saying, "It's not guaranteed. It's not certain. But if we could reduce our cost and capital to that degree, some of the petroleum guys are going to start scratching their head about their own capital allocation because if we start closing in on cost parity with petroleum." That's a moonshot goal. That's a real stretch goal, which I don't want to represent that we're there. What we are is designing the experiments and implementing experiments with the leading lignocellulosic scientists in the world, from Gregg Beckham at NREL to Joe Samec at RenFuel to our own people in Madison, Wisconsin. We have built an intellectual horsepower around lignocellulosic science. If these guys don't crack it, no one's cracking it.

No one's cracking it. Because these are the people who have dedicated their lives to doing just that. It's very exciting from that point. It's one cycle behind metals. We are TRL 7, two years mature, going to 8 in metals. We're trying to integrate TRL 6 because in the fuels business, we have mature digesters. We have mature enzymatic and fermenting from the corn ethanol industry. We have mature hydrocracking. It's just some of we have one or two steps taking that crude lignin into oil. That's our novel contribution. A lot of it's mature around it. We're one cycle behind. We want to integrate 6 and go to 7, where metals has proven 7 going to 8. That's what makes the business model so great. It's exciting that we have explosive revenues on metal.

It's exciting that it's a huge global market that we're addressing, seemingly with the leading tech and leading solution. Right behind it, we have another one. When we first started doing this in 2020, 2021, my only angst was, "I wish we didn't have two techs going so parallel." Metals pulled ahead. Feels a little better, quite frankly, to have a little staggering there. Although we want to get them both commercial as fast as we can.

Peter Gastreich
Managing Director of Energy Transition and Sustainable Investing, Water Tower Research

You have the leading scientists, leading technology. You have these incredible partnerships, the relationship with the National Renewable Energy Lab. What are the plans for scaling up this business? How do you kind of see that kind of going forward?

Corrado De Gasperis
Executive Chairman and CEO, Comstock Inc.

Yeah. Very question. By the way, we have exclusivity to the technology coming out of NREL because we're funding it and collaborating in this development. We have exclusivity with using these biomasses, Hexas Biomass, for fuels. We have exclusivity with RenFuel's technology. We basically convinced our partners that we're stronger as one than as separate components. In Madison, we're moving to a couple of barrel a week production scheme, which will prove TRL 6 in the same way that we did it over the last two years with metals in Silver Springs. It's a demonstration scale that can produce meaningful amounts of fuel, meaningful amounts of oil for fuel, and meaningful amounts of fuel.

Oklahoma has really stepped up and said, "We love what this portends." They gave us a $3 million grant to headquarter ourselves there for the oil and gas business, allocated $152 million of tax-free municipal bonds to support the financing of this scale-up in Oklahoma. We're site selecting as we speak. We already have one site nailed down. We're actually looking at a second site, in large part because of what the state's offering us to do that. I would say that over the next two years, we'll be a steady producer of oils at a smaller scale, just like we did with metals, exactly the same notion. Right beyond that, though, we will be scaling up to an integrated bio refinery, which we're targeting 100,000 tons a year of waste and/or purpose-grown biomass, which would produce 10 million-15 million gallons a year.

Then the next scale-up after that, which would be the TRL 8, would be 1 million tons doing 115 million-120 million gallons a year. The market for advanced biofuels, based on the U.S. mandate, is 16 billion gallons. It would take 50 of the facilities that I just described to you to meet half of that mandate. The liquid fuel market in the U.S. is not 16 billion. The liquid fuel market in the U.S. is 250 billion. It's just the advanced biofuel that's a subset of that market. Now, people say, "Wow, 50 facilities, Carroll, that's aggressive. That's like crazy." Okay, when the corn ethanol industry built their first facility, about 200 more were built in seven years, and they hit 16 billion gallons, which is what they're doing right now. It's not unprecedented. We're talking about half of that.

We are not necessarily saying we are going to build all those facilities, by the way. We are going to build the first few, but we are very happy to partner, to license, whatever accelerates the deployment of this technology, we are supportive of.

Peter Gastreich
Managing Director of Energy Transition and Sustainable Investing, Water Tower Research

Okay, Corrado, that's been a great overview of the business segments. We could easily dedicate an entire Fireside Chatter podcast to each one of those business segments independently, and you better bet we'll do that in the future. For today, we'll move on to our next topic, very important, and that is the regulatory and policy environment. With respect to policy and regulatory risks, what are the important aspects that investors should understand about your panel recycling and the fuels business?

Corrado De Gasperis
Executive Chairman and CEO, Comstock Inc.

Surely. The renewable fuel standard, start with the fuels business. The renewable fuel standard is law. It is supported law. We had maybe an inkling of anxiety when the new administration was coming in regarding their energy policy, which eliminated immediately when the new Department of Energy Secretary said, "We want energy, energy, energy. We want petroleum. We want nuclear. We want biofuels. We want geothermal. We want it." They do seem to have a chip on their shoulder with solar, but we do not care about that. We are recyclers. We are not deployers of solar. I do not really think it is stopping anything anyway. The renewable fuel standard is strongly established. The California version of the fuel standard is strongly established, which our materials qualify for the highest value renewable identification number.

The highest value RIN credits are the D3 and the D4 RINs, which are remarkably more valuable than D6, which is corn ethanol. The corn guys could get $1 a gallon for making the exact same ethanol that we make. We'd get $2-$3 a gallon extra, just like they get one, we get three. Our feedstock costs, of course, are way cheaper if we're using waste. We think it's very stable. When the new administration came out and said, "We need energy, energy, energy," we just breathed a big sigh of relief. On the solar panel cycle, we have zero reliance, zero reliance on the government. Maybe the one regulatory thing we would like to see is stronger laws against putting toxic materials into landfills. California took the lead on that. It's essentially prohibited these universal hazardous waste from going into landfills.

Texas just followed up, being the largest deployer today of panels with similar prohibitions. We think that's fantastic. We'd love to see the state assemblies across the country. They are picking up on it because the panels are coming out so aggressively. The landfills are feeling it. Most of the large landfills are already saying, "No moss. We can't deal with this." That would be nice to tighten that up. The other thing that we see happening is like a substack. It's a subsector, is people, sort of lower end, just shred this stuff and send it overseas. Now, if you shred this stuff, you're generating a hazardous waste. If you're shipping it overseas, it's ridiculously expensive to do that. They're shipping it. Some people are doing that.

I don't know if they're being honest with what they're shipping because I doubt they would pay what would be required to pay for that manifest. That manifest, sorry. I think we're more sensitive to the regulatory regime with fuels than we are with panels, but good in both instances.

Peter Gastreich
Managing Director of Energy Transition and Sustainable Investing, Water Tower Research

Okay, great. Carroll, this has been really great. We are getting close to the end of our time today. I do want to give you a moment here to share any key signposts ahead that investors should be focused on in the next 12 to 24 months or whatever time frame you think is relevant.

Corrado De Gasperis
Executive Chairman and CEO, Comstock Inc.

Yeah, absolutely. So, immediately, we're getting our permits. There's a written determination, which is the permit that allows us to process these universal waste materials. We were noticed of that permit last week. We were ecstatic. There's a short public notice period, which will end by Christmas. And then we're due to get the air quality permit, which is the sister permit for that same operating facility, any day. Interestingly, the public notice period for that is shorter, much shorter. So, both of them are synchronized that we get all of our final remaining permits issued by Christmas. Equipment was synchronized to that plan to land in December, so we could commence commissioning in January. We're going to commission during the first quarter and be fully up and running in the second quarter.

The only other thing to look out for, other than those great news data points, is new customers coming on board. The order pipeline is growing. It is growing not just in the number of customers that need our solution, but also in the size of those customers. I was saying the other day that just with our existing customer base, we could easily do 40,000 tons-50,000 tons next year, just with the existings. We are growing there. Those same customers, if we did not change a thing in 2030, could be 400,000 tons-500,000 tons because their end-of-life scenario is going up with the market. They are the market. We are positioning ourselves with the best customers that will result in inherent natural growth with them. We just have to have the capacity to process it. I think those are the most exciting things.

In the fuels business, there will be some announcements around the technology and the strengthening of that supply chain consistent with what we just talked about. It is going to be more metals news than fuels news.

Peter Gastreich
Managing Director of Energy Transition and Sustainable Investing, Water Tower Research

Okay, great. A lot to look forward to there. Thank you, Corrado. This has been very comprehensive and very helpful for investors. Before we close here, is there any concluding remarks you'd like to provide?

Corrado De Gasperis
Executive Chairman and CEO, Comstock Inc.

No, just to make sure people know that our website is comstockinc.com. Our New York Stock Exchange listing is, as you said at the beginning, LODE. Obviously, it comes from our legacy of the Comstock LODE. Very proud of it. Please put us on your screen. Please watch. There is a lot that is happening.

Peter Gastreich
Managing Director of Energy Transition and Sustainable Investing, Water Tower Research

Okay, excellent, Carroll. We'll look forward to hosting you for more events in the future. You can bet that we will be following developments very closely here, keeping investors up to speed on Comstock here at Water Tower Research. In closing, I'd like to encourage everyone to look at our website, www.watertoweresearch.com, for disclosures and other research on Comstock, ticker LODE. You'll also find research on other companies in the energy transition and sustainable investing sector. The views expressed in this Fireside Chat may not necessarily reflect the views of Water Tower Research and are provided for informational purposes only. This Fireside Chat of Water Tower Research may not be distributed or reproduced without the written consent of Water Tower Research and should not be considered research nor a recommendation.

WTR is an investor engagement firm, not a licensed broker, broker-dealer, market maker, investment banker, underwriter, or investment advisor. Additional disclaimers can be found at www.watertowerresearch.com. Thank you very much.

Corrado De Gasperis
Executive Chairman and CEO, Comstock Inc.

Outstanding.

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