The amount of people ringing through to Management on a daily basis is becoming a tad of a worry for me. Timelines are blowing out and the company needs all hands on deck IMO, Mgmt spending half their day answering questions to make you feel good is not a good use of investor funds IMO. With a chance to discuss the project with the company occurring this month, give the phone calls a rest !
I've read some commentary the past few days Re: "The Resource is too big to be ignored, it simply has to be mined". Whilst part of these types of statements are indeed true, the risks of development within Africa counter in the opposite direction of what is a monster of a deposit.
My case in point would be to look at the world of Iron Ore. In the (Very Quick) graph below I have plotted the Mineral Resources of Rio Tinto, Fortescue & Roy Hill and pinned them against the African Monster. The Simandou deposit is superior to Australian Iron Ore in Grade, impurities (Silica and Alumina) and has a massive resource potential that has only just been scratched. So how could it be that the #1 Deposit in the world (Potentially) has remained in the ground for the past 25 years ? There are a plethora of reasons for this, mainly due to the risks of mining in Africa, not even a Tier 1 company in Rio Tinto with no issues of financing the project themselves has been able to unlock to date.
In terms of Approvals Progress for Manono, I have no doubt in my mind that the current Management Team is learning on the fly, the general lack of understanding of approvals pathways, timeframes of government assessment, requests for further information, negotiation of management actions, understanding of environmental risks, potential conditions of approval and implementation appears minimal.
In April 2020 (DFS) the company stated that the ESIA was ready for submission to A.C.E.......... Yet here we are over 12 months later. In that time we have been provided information that additional environmental surveys were required and now completed, additional hydrogeological model conducted, update to the original impact assessment and underlying management plan also required prior to submission (which is yet to be submitted).
Of particular interest to me was the line that the company expects the approval process once submitted to A.C.E to take ~6 weeks. For anyone interested in the ESIA process in the DRC, the general model aligns with standard EIA globally. That being:
- Screening
- Scoping
- Assessment
- Community and Stakeholder Engagement
- Review
- Decision Making & Right of Appeal
- Issue of Environmental Certificate
When a proponent in the DRC submits an ESIA to the ACE for approval, the ACE has a period of 3 months to assess the proposal. The assessment panel can then make comments and request further information from the proponent (which they have 30 days to provide). The Panel then has a further 60 days to make a formal assessment on either approving or rejecting the ESIA. As a point of reference Ivanhoe Mines in the DRC took a tad over 4 months to receive approval of the ESIA for the Kamoa-Kakula Copper Project.
Mining Licence - I don't pertain to have knowledge of the timeframes for a conversion of the current Permis de Recherche into a Permis dÉxploitation (Mining Licence). But the fact that AVZ believes this process could take anywhere up to 6 months is a red flag. Important to note that the application cannot even be submitted until the ESIA has gone through the due process and been approved by the ACE (in conjunction with the revised DFS not due for middle of the year), before the Mining Licence can even be submitted which in itself could take up to 6 months after lodging the application.
The lollypop brigade on this forum still of the belief that both of these key approvals (which havent even been submitted yet) ís naive at best. I published a revised timeline a few days ago that I believe to be slightly optimistic given the nature of this current management team and a lack of understanding of approvals pathways, timeframes, consultation, revisions and ultimately approval. A further point to highlight my view would be the Hydro-Electric Scheme Agreement with the DRC Department of Energy, AVZ had submitted an application and believed that would lead straight to an approval, low and behold the government returned with questions and a request for further information (who would have thought that approvals pathways require consultation and revisions).
GLTAHs moving forward. I for one am not expecting FID for this project until Q4 2021 at the earliest given what we now know.
