Project Information from the FIN
Project Title: Black Pine Project
Sector:Mining
Project Location
Location Type: Coordinates
• Latitude *: 42.082 Longitude *: -113.047
Project Sponsor Contact Information
• Company Name/Agency: Liberty Gold USA Inc., a wholly owned subsidiary of Liberty Gold Corp. Project Sponsor: Liberty Gold USA Inc. Street Address 1 : 300 E. Mallard Drive Street Address 2 (Optional): Suite 250 City: Boise State: Idaho Zip Code: 83706 POC Name: Matthew Zietlow POC Title: Director, Regulatory Affairs and Sustainability POC Phone: 7753041682 POC Email Address: mzietlow@libertygold.ca
Alternative Point Of Contact (Optional)
No
Technical and Financial Ability
Technical Ability: Liberty Gold possesses the technical expertise and operational experience necessary to successfully construct, operate, and reclaim the Black Pine Project. The Project team is led
by President, CEO, and Director Jon Gilligan, B.Sc., Ph.D., who brings over 35 years of international, multicommodity experience in technical services, capital projects, and open pit mine construction and operations. Board Chair Greg Etter, B.S. Geology, J.D., adds more than two decades of senior executive leadership in the natural resources sector, managing diverse portfolios for multiple international mining companies. The Project team includes directors and senior managers with specialized expertise in engineering, permitting, environmental management, finance, and community relations. Liberty Gold has demonstrated success in authorizing and executing mineral exploration programs in complex regulatory environments, including engineering and environmental management for open pit mining, rock storage facilities, heap leach operations, water management systems, and ancillary infrastructure. Since 2016, Liberty Gold has maintained authorization under an approved Plan of Operations for exploration on USFS and BLM administered lands. Authorized exploration activities to date include 977 drill sites, 100.7 miles of drill roads, and 405.8 acres of disturbance, underscoring the company’s proven ability to manage largescale projects in compliance with federal requirements. In addition, the Project MPO was recently deemed technically complete by both the USFS and BLM. The Project area is well positioned for development, with regional access via Interstate 84, improved local roads, and existing line power from the electrical grid. Legacy mining features—including roads, drill pads, and reclaimed facilities—provide a foundation for efficient site development. Liberty Gold’s commitment to community engagement is demonstrated by its hiring of a local Community Relations Liaison to maintain direct communication with stakeholders and address potential concerns proactively. Regular community and county presentations and conducted to discuss Project status and answer related questions. Financial Ability: The Black Pine Project is 100% owned and controlled by Liberty Gold USA Inc. (Liberty Gold), based out of Boise, ID. Liberty Gold is a wholly owned subsidiary of Liberty Gold Corp., a publicly traded corporation headquartered in British Columbia, Canada. Liberty Gold Corp. is focused on the acquisition, exploration, and development of mineral properties for gold, copper, and other precious and base metals across North America. The company’s leadership team includes seasoned financial professionals with extensive experience in mining finance and capital markets. Chief Financial Officer Joanna Bailey, B.Sc., Ph.D., CA, brings over a decade of expertise in accounting and financial reporting, specializing in statutory audits for mining operations. Senior Vice President Brad Ralph, MBA, CFA, CPA, has more than 20 years of experience in investment banking, corporate finance, and advisory, including transaction structuring and capital raising through equity and debt instruments. This depth of financial knowledge ensures robust fiscal management and access to capital necessary for project development and long-term operations. The NI 43101 Technical Report confirms that the Project demonstrates strong economic potential and is well positioned for development. Based on positive prefeasibility results, the Project is expected to generate an average annual gold production of approximately 129,000 ounces over a 17-year mine life, with peak production of 231,000 ounces in Year 5. Estimated cash costs of $1,250 per ounce and all-in sustaining costs of $1,381 per ounce support robust margins, resulting in an after-tax cash flow of $871 million, an after tax NPV (5%) of $550.2 million, and a payback period of just 3.3 years. These metrics underscore the Project’s financial strength and its suitability to advance through permitting and into construction and production. Liberty Gold’s financial capacity is further supported by its ownership of a contiguous block of 668 unpatented federal mining claims and additional mineral rights, including a 20-year lease on Idaho state metallic mineral rights and strategic acquisitions of private land and water rights.
Project Assessment
The Black Pine Project meets the definition of a covered project under the FAST Act and satisfies all eligibility criteria established by the Federal Permitting Improvement Steering Council. Step 1, Eligible Infrastructure Category: The Project falls within one of the 19 infrastructure sectors identified by the Permitting Council—mining—as eligible for FAST 41 coverage. Specifically, the Project involves construction of mining infrastructure and the extraction and onsite refining of mineral resources, including gold and silver. Step 2, Eligibility Pathway – Standard Pathway: The Project meets all three criteria under the Standard
Pathway for covered project status:
1. Subject to NEPA Review The Project constitutes a major federal action under NEPA (42 U.S.C. §4332 et seq.) because mining activities have the potential to significantly affect the quality of the human environment. The Project will disturb approximately 3,151 acres within the 11,162-acre Project area and includes complex operations such as open pit mining, heap leach processing, and onsite refining of gold and silver into doré bars. The USFS and BLM have formally determined that an EIS will be required for the Project and will serve as co-lead agencies for the EIS. 2. Estimated Investment Exceeds $200 Million The Project has an estimated capital cost of $530 million. This total includes construction, extraction and refining, property and mineral rights acquisition, and permitting activities. 3. No Abbreviated Review Process Applies The Project does not qualify for any abbreviated authorization or environmental review process under applicable law. USFS and BLM have confirmed that the EIS will be prepared under standard NEPA procedures and agency implementing regulations issued in July 2025. Step 3, Submission of FAST 41 Initiation Notice: By submitting this FAST 41 Initiation Notice (FIN), Liberty Gold satisfies the third eligibility requirement established by the Permitting Council. The Project clearly meets the FAST Act definition of a covered project: it is a mining infrastructure project subject to NEPA review, requires significant federal authorizations, involves an investment well above the $200 million threshold, and does not qualify for expedited review under any other statute. FAST 41 coverage will provide coordinated interagency permitting, schedule transparency, and issue resolution mechanisms while maintaining full compliance with NEPA and other applicable laws.
Form Submitter Contact Information
• Name: Edward Gazzetti Title: Senior Consultant Work Phone: 6072871778 Email Address: eddie.gazzetti@wsp.com
Accept Agreement
Yes
Project Purpose
Liberty Gold USA Inc. (Liberty Gold) proposes the Black Pine Project (Project) in Cassia and Oneida Counties, Idaho, to construct, operate, reclaim, and close an open-pit, run-of-mine heap-leach gold mining operation on public lands administered by the U.S. Forest Service (USFS) and the Bureau of Land Management (BLM). The Project is designed to responsibly develop and extract a proven gold and silver resource while implementing rigorous environmental safeguards, mitigation, and a comprehensive reclamation and closure plan. The Project is located in rural southeastern Idaho, at a location where both small- and large-scale metal mines have operated and explored previously. At closure, previous and newly disturbed lands will be reclaimed for productive post-mining uses such as livestock grazing, wildlife habitat, hunting, and dispersed recreation, consistent with federal and state objectives for resource recovery and land stewardship. Development of the Project will contribute to a secure domestic supply of precious and critical minerals essential to U.S. manufacturing, technology, finance, and national defense. Gold has properties that make it an essential industrial metal in high-tech applications such as computers, spacecraft, and jet engines. Silver, recently designated as a critical mineral, is essential for renewable energy and advanced technologies, including solar photovoltaic systems, energy storage, electrical circuits, batteries, and anti-bacterial medical instruments. By providing a reliable source of gold and silver, the Project supports national priorities for mineral security, provides robust local and regional economic benefits, and creates over 300 full-time jobs while maintaining high environmental standards. Liberty Gold has designed this project to minimize environmental risk through integrated operating plans and best management practices covering water quality and conservation, air quality, wildlife stewardship, spill prevention and emergency response, environmental monitoring, mitigation, and reclamation. These measures will ensure compliance with federal and state requirements, prevent unnecessary or undue degradation, and support effective reclamation throughout the life of the mine. In summary, the Black Pine Project is needed to meet growing national demand for secure domestic sources of precious and critical minerals and to provide jobs and economic benefits to a rural part of southeastern Idaho. By achieving these objectives, the Project advances federal and state goals for responsible resource development and land stewardship while delivering measurable environmental improvements on a previously disturbed landscape.
Project Description
Overview & Location: Liberty Gold proposes to construct, operate, close, and reclaim the Black Pine Project—an open pit, run-of-mine heap leach gold mining operation largely situated on a previously disturbed site with several existing open pits and a reclaimed legacy heap leach facility. The Project is on the eastern flank of the Black Pine Mountains of southeast Idaho, approximately six miles north of the Utah border, within Cassia and Oneida Counties. The 11,162-acre Project area comprises 7,059 acres of public lands administered by the USFS, Sawtooth National Forest, Minidoka Ranger District, 3,952 acres administered by the BLM, Pocatello Field Office, and 151 acres of privately owned land held by Liberty Gold. Liberty Gold controls access and mineral interests on public lands through federal unpatented lode and placer mining claims and owns the private land within the Project area. MPO Acceptance & NEPA Framework: Liberty Gold submitted an initial draft Mine Plan of Operations (MPO) to USFS and BLM in February 2025. Following two additional comment & response periods, on November 21, 2025, USFS determined the MPO meets the information requirements of 36 CFR 228.4(c) and deemed it technically complete for operations on National Forest System (NFS) lands. On November 24, 2025, BLM determined the MPO meets the content requirements of 43 CFR 3809.401(b) and is complete for the portions of the Project requiring BLM authorization. A 2024 Memorandum of Understanding (MOU) executed by USFS, BLM, Idaho Department of Lands (IDL), Idaho Department of Environmental Quality (IDEQ), and the Idaho Governor’s Office of Energy and Mineral Resources (OEMR) established roles, responsibilities, and coordination for baseline data collection and environmental review. The MOU explicitly identifies the Project as a major federal action triggering the need for NEPA review and specifies that the Project will require an Environmental Impact Statement (EIS) for NEPA compliance. USFS and BLM will serve as joint lead agencies for the EIS, with USFS taking the lead in coordinating preparation of the EIS. The EIS will analyze effects on both NFS and BLM lands. Following completion, USFS will issue a Record of Decision (ROD) for activities on NFS lands, and BLM will issue a separate ROD for activities on BLM lands. IDL, IDEQ, and OEMR are Cooperating Agencies under 42 U.S.C. 4336e. Geospatial Summary & Planned Facilities: The Project will create approximately 2,328 acres of new disturbance, which combined with existing site disturbances will result in a total disturbed footprint of approximately 3,151 acres. This includes 95 acres of disturbance previously authorized for exploration and 728 acres previously disturbed by historic mining activities. Existing disturbance features include four open pits, partially reclaimed rock storage facilities (RSFs), mine roads, exploration disturbance, a reclaimed legacy heap leach facility (HLF), and a land application disposal (LAD) area. Planned facilities include expansion of existing pits and development of new pits using conventional open pit methods; construction of two RSFs; four temporary ore stockpiles; an engineered HLF; an Adsorption, Desorption, and Recovery (ADR) process plant and refinery; and associated roads and pipelines. Liberty Gold will extract oxide gold and silver ore and barren rock over a 17-year mine life using conventional surface mining methods, as the deposit’s grade does not support underground mining. Run-of-mine ore will be stacked directly on the HLF. Gold and silver will be recovered via a conventional on-site heap leach circuit, and the on-site ADR/refinery will produce doré bars. Environmental, Cultural, and Historic Resources: All proposed mining is designed to occur above the local water table, and no jurisdictional waters of the United States exist within the Project area. There are no known threatened, endangered, or candidate species or designated Endangered Species Act (ESA) habitat within the Project area. Mitigation and avoidance measures for resources such as greater sage-grouse mating periods, mule-deer winter range, sensitive plant species, and noxious-weed management are stipulated in the MPO. Between 2017 and 2024, Liberty Gold completed intensive cultural resource inventories over approximately 9,936 acres, and survey reports have been submitted to the relevant federal and state agencies. These environmental and cultural/historic resources will be analyzed in detail in the EIS, with agency and tribal consultation conducted in a manner consistent with NEPA and applicable statutes. Community Benefits: The Project is expected to generate approximately 400 direct and indirect jobs during the one-year construction period and approximately 300–350 jobs during the 17year operational phase. Postmining land uses will emphasize livestock grazing, wildlife habitat, hunting, and dispersed recreation, consistent with federal and state land stewardship objectives.
TBD
N/A
TBD
Summary of Financing, Reviews and Authorizations
Federal Financing: Liberty Gold does not currently have federal funding for the Project; however, the company has recently submitted materials to the U.S. Export-Import (EXIM) Bank for potential financing consideration. Progress of the Project is not contingent upon receiving EXIM financing. Environmental Review and Authorizations: Because most of the Project is located on lands administered by USFS and BLM, a comprehensive federal environmental review is required. Under the NEPA Statute (42 U.S.C. 4336e) and pursuant to an MOU signed in February 2025, the USFS will serve as Lead Agency and the BLM as Co-lead Agency for preparation of a joint EIS. The EIS will evaluate potential environmental effects, identify mitigation measures, and ensure compliance with NEPA and agency-specific implementing procedures issued by the Departments of Agriculture and Interior in June 2025. Liberty Gold has submitted a draft MPO to USFS and BLM; the agencies have deemed the MPO complete under 36 CFR 228 and 43 CFR 3809, respectively. The MPO serves as the basis for the proposed action analyzed in the EIS and related federal and state reviews. The MOU also establishes roles, responsibilities, and timelines for cooperating agencies. The following federal permits and authorizations from various federal and state agencies will be required to construct, operate, and reclaim the Project: • USFS Sawtooth National Forest and BLM Pocatello Field Office: Mine Plan of Operations (MPO), deemed “Administratively Complete” by both USFS and BLM under 36 CFR Subpart 228 and 43 CFR Subpart 3809. Following completion of the NEPA process, USFS will issue a Record of Decision (ROD) for activities on National Forest System lands, and BLM will issue a separate ROD for activities on BLM-managed lands. Both agencies will ensure compliance with their respective regulations to prevent unnecessary or undue degradation of public lands. • USFS Sawtooth National Forest: Special use Permit to allow the occupancy, use, rights, or privileges of agency-managed land, including certain Weeks Act lands under USFS jurisdiction. The permit(s) would allow specified rights or privileges for a defined period of time in compliance with 36 CFR 251.50. Proposed activities include ancillary, non-permanent disturbances such as stormwater ditches, temporary stockpiles, and access roads. • BLM Pocatello Field Office: Rights-of-Way (ROW) Leases to secure all necessary ROWs (e.g., pipelines, etc.) and leases in compliance with 43 CFR 2801 and 2920. • U.S. Fish and Wildlife Service (USFWS): Section 7 of the Endangered Species Act (ESA) (16 U.S.C. §§ 1531-1544) requires all federal agencies to ensure their actions, funding, or authorization do not jeopardize threatened or endangered species or harm their critical habitats through consultation with USFWS for terrestrial species. It also mandates conservation programs for listed species, prohibits "taking" (harming/killing) them, and regulates commerce in listed species; Incidental Take Permit (ITP) for the protection of bald and golden eagles under the Bald and Golden Eagle Protection Act (16 U.S.C. 668-668d), including potentially seeking an ITP pursuant to Section 7 of the ESA, if necessary. • U.S. Department of Treasury, Bureau of Alcohol, Tobacco, Firearms, and Explosives (BATFE): Explosives permit required for the transport, storage, and use of explosives within
the Project area. • Mine Safety and Health Administration (MSHA): Mine Identification (Mine ID) Number, which is a unique identifying number required for each U.S. underground and surface mine site before any operations begin. • Federal Communications Commission (FCC): Radio License for the electromagnetic spectrum for commercial users and for non-commercial users. • Environmental Protection Agency (EPA): Spill Prevention Control and Countermeasure Plan (SPCC) for EPA-regulated above-ground storage tanks under the Federal SPCC rule, including specific measures to prevent and control spills of regulated materials from storage tanks. • Advisory Council on Historic Preservation (ACHP): Section 106 of the National Historic Preservation Act (NHPA) (54 U.S.C. §§300101 et seq.) requires federal agencies to assess the impact of their projects on historic properties and other relevant cultural resources, and involve ACHP (when required), relevant tribes, and the public in the review process. It also requires that federal agencies consider any feasible ways to avoid, minimize, or mitigate any adverse effects on those properties before project approval or funding, through consultation with any relevant State and Tribal Historic Preservation Officers (SHPOs and THPOs).