TOE requirements before 9 January 22, page-8

The Fedral permit you are looking at from Toro's announcement released on the 10th July 2017 has the definition of "Substantially Commenced" on Page 4 of the permit. See below.


In regards to the 5 years , Toro is completing a engineering study to include Vanadium as a by-product this will need to be submitted to the government as a change to the current permit , once assessed the permit is extended another 5 years. This is common in the industry as new technologies or mining processes are introduced and new resources found. This will fall under
"Section 46 of the EPA Act 1986" . See below

If you go through the Toro threads alot of good people supply the information and answers some may seek.