Taking Stock – 12 February 2026

The fast-track panel's decision to take the full 140 working days to reach a final determination on Santana Minerals' application should be seen as a positive and necessary step rather than a delay.

By the time a decision is issued, it will be close to a full year since Santana formally entered the fast-track approval pathway, displaying that the panel is intent on running a thorough and defensible process, grounded in evidence rather than shortcuts and speed.

The purpose of the fast-track legislation was never to bypass environmental scrutiny. It was designed to bring certainty and timeliness to nationally significant projects while retaining a thorough and rigorous assessment.

Proof of this can be seen by the recent draft decision from the fast-track panel not to grant consent for a seabed mining project. While the fast-track process will produce faster outcomes, applicants still face a high level of scrutiny before being able to proceed.

In Santana's case, the panel will be larger than many other consent panels, ensuring that the decision isn't shaped by one or two individuals, but by a broad range of experts with relevant technical, environmental, economic, and regulatory experience. This materially reduces the risk of narrow or ideological decision-making and increases confidence that the final outcome, whether for or against, will be well-reasoned and robust.

Equally important will be how submissions are handled.

The panel can invite feedback from relevant parties, but relevance matters. This is not a popularity contest, nor a forum for ideological advocacy.

It would be inappropriate for shareholders to submit that the project should proceed simply because they support it. In the same way, it would be wrong for opposition groups to submit their personal views that mining shouldn't occur in their back yard. Other venues exist for the expression of such views.

Feedback must be from experts using the latest evidence, rather than based on speculation and claims about potential shortcuts in environmental management. This includes claims that there will be a tailings dam failure that have no basis in the engineering evidence actually before the panel.

New Zealand's regulatory framework is among the most rigorous in the world. Suggestions that this project will operate to substandard environmental controls ignore both our consent regime and the Santana management's demonstrated track record.

The panel's task is to assess facts, evidence, and enforceable conditions, not sentiment or fear.

Ultimately, the fast-track process for Santana is doing exactly what it was intended to do. It's testing the project against environmental impacts, economic benefits, engineering design, and risk management in a disciplined and independent way, within a defined timeframe.

A further development that reinforces the integrity of the process is Santana Minerals' recently executed land access agreement with Central Otago District Council.

Following extensive negotiations, the council has approved access arrangements over council-owned roads required for the project. This agreement relates solely to land access and constitutes neither approval for mining activity, nor disapproval.

The agreement provides clarity and certainty around access while explicitly preserving the independence of the consenting process. The council has been clear that it hasn't taken a position for or against the mine, and that the ultimate decision rests with the relevant regulatory and fast-track panels.

From a community perspective, the agreement establishes a transparent financial framework. Santana has committed to a CPI-indexed annual payment of $1.25 million to the council, equivalent to roughly $100,000 per month, every month, for the life of the mine (once commencing commercial production). These funds will be directed toward infrastructure, environmental initiatives, and broader economic development across the region.

This arrangement shows how local government can engage pragmatically with major projects without compromising neutrality. The agreement will deliver tangible, long-term community benefit which is a significant win for the Otago district.

Separately, there's been some noise recently about the project economics being misrepresented. However rather than being misrepresented, it is likely being understated by the constraints demanded by ASX listing rules.

When Santana published its feasibility study in July 2025, corporate tax payable to the New Zealand Government over the life of mine was estimated at $983 million. At the current gold price, that figure is now $1.7 billion. Estimated Crown royalties have also increased from $410 million to $703 million.

That's $2.403 billion in taxes and royalties alone. And that's before you add PAYE tax from the hundreds of employees who'll be working on site throughout the mine life.

These are material contributions to the New Zealand economy, and suggesting that the economics don't stack up or have been inflated ignores the reality of updated modelling and the very real increase in gold prices since the feasibility study was completed.

It would also be ridiculous for an opponent to claim to know more about the modelling than highly experienced, and accountable, experts.

Concerns about taxpayers being left to cover environmental cleanup costs don't reflect how modern mining regulation works. Western Australia's Mining Rehabilitation Fund, for example, provide an example of how some jurisdictions managed these costs.

The fund covers nearly 1,000 active mine sites. Since 2013, mining operators have contributed A$374 million to the fund through annual levies, yet actual expenditure on failed mine rehabilitation has been minimal.

The system ensures that when mining companies fail to meet their rehabilitation obligations, the fund covers the costs rather than taxpayers. 

New Zealand operates similar requirements, where companies must provide financial assurance covering full rehabilitation costs, protecting taxpayers from being left with cleanup bills. 

A rigorous process is ultimately in Santana's best interest. A consent that's been properly tested is far less vulnerable to challenge down the track.

A consent granted following a robust fast-track process is more likely to endure changes in political climate, judicial review risk, and public pressure. In that sense, the additional time being taken by the panel should be viewed as an investment in durability. It increases confidence that whatever the outcome, the decision will be grounded in fact, legally defensible, and able to withstand scrutiny.

It's also realistic to expect continued share price volatility through this final phase of the regulatory process.

As the fast-track panel undertakes its work, commentary and speculation will inevitably increase, generating noise that may have little to do with the project's actual merits. That volatility is a feature of all such projects at this stage, not a signal about the quality or integrity of the process underway.

At the same time, broader market conditions remain supportive.

Public support continues to build, with more than 22,000 New Zealand based shareholders now invested in the project, representing the majority of all Santana shareholders. The gold price has risen approximately 8% over the past month alone, materially increasing the economic benefit to the country. And recent drilling indicates significantly more gold than what is currently reflected in Santana's modelling.

The direction of travel is positive and has encouraging implications for long-term project value.

For shareholders, this final phase requires a clear-eyed understanding of risk and volatility. Each investor must consider their own risk tolerance and time horizon as the consent process runs its course.

The fast-track panel's role isn't to manage share price movements, but to reach a decision based on evidence from experts, not pressure from advocacy groups on either side.

If the project is ultimately consented, the value created for New Zealand, for shareholders, and through government royalties and tax revenue would be substantial.

That outcome, however, must be earned through process, not assumed.

_ _ _ _ _ _ _ _ _ _ _

Linkedin

If you would like to follow us on LinkedIn, you can do so on the link below:

https://www.linkedin.com/company/107542123/

_ _ _ _ _ _ _ _ _ _ _

Travel

18 February – Christchurch – Johnny Lee

2 March – Christchurch – Chris Lee

3 March (am) – Christchurch – Chris Lee

3 March (pm) – Ashburton – Chris Lee

4 March – Timaru – Chris Lee

6 March – Wanaka – Chris Lee

Edward Lee 

Chris Lee & Partners Limited