On July 7, 2026, the USDA Forest Service issued its final Record of Decision for South32's $3.3 billion Hermosa Critical Mineral Project in Arizona, completing the federal environmental review process in what officials describe as record time under the FAST-41 framework. The decision sets a September 4 authorization deadline and positions Hermosa as the proof-of-concept for an accelerated permitting model now being applied to 57 additional mining projects. But the approval has also exposed the fault lines that will define every major mine decision to come: speed versus scrutiny, national security versus ecological risk, and the question of who bears the cost of America's mineral dependence.
Introduction
Somewhere beneath the Patagonia Mountains in Santa Cruz County, Arizona, two shafts are descending into the earth at roughly seven feet per day. They have already passed twelve hundred feet. The crews working them are not waiting for permission. Construction on the privately held portion of South32's Hermosa project is already half complete, an unusual circumstance that speaks to a larger gamble: that the federal government would eventually catch up to the geology.
It did, on July 7, 2026, when the USDA Forest Service signed a 163-page Record of Decision authorizing the ancillary infrastructure South32 needs on national forest land, including a new access road, a dry-stack tailings facility, and a 138-kilovolt power line through the Coronado National Forest. The decision formally concluded the National Environmental Policy Act process for the project, cleared the final significant bureaucratic hurdle before full authorization, and was hailed by Secretary of Agriculture Brooke Rollins as a demonstration of what she called "Trump speed" in responsible project approvals.
The phrase is politically loaded, but the underlying timeline is genuinely striking. From its entry into the FAST-41 permitting program to a completed Record of Decision took just over two years. By the standards of American mining permitting, that is not merely fast. It is historically anomalous. Emily Domenech, executive director of the Federal Permitting Improvement Steering Council, put the contrast in stark terms: prior to the current administration, she said, the average time to permit a mining project in the United States was twenty-nine years. Whether that figure captures the full complexity of what permitting actually involves is contested. What is not contested is that Hermosa has now become the first mining project to complete the full FAST-41 cycle from nomination to Record of Decision, a status that makes it something more than a single project approval. It is a policy experiment whose results will reverberate across fifty-seven other mining projects now enrolled in the same program.
The Deposit Beneath the Sky Islands
The Patagonia Mountains are not, at first glance, an obvious venue for a national industrial strategy. They form a fifteen-mile range in the Madrean Sky Islands, an archipelago of elevated terrain that bridges the Sierra Madres of Mexico and the Rocky Mountains to the north, and they are home to some of the most biodiverse ecosystems in North America. Jaguars have been photographed in these mountains. Mexican spotted owls nest here. The range sits within the Coronado National Forest, and the surrounding area has the character of a community that has spent decades defining itself against the extractive economy.
And yet underneath it lies what South32 President Pat Risner describes as one of the most significant undeveloped mineral deposits discovered globally in the last fifteen years. The Taylor deposit alone, under JORC-compliant reserve figures, holds sixty-five million tonnes of ore grading 4.35 percent zinc, 4.90 percent lead, and eighty-two grams per tonne of silver. At nameplate capacity, the underground concentrator processing 4.3 million tonnes annually is forecast to yield 123,000 tonnes of zinc, 155,000 tonnes of lead, and 8.2 million ounces of silver per year. Those are numbers that command attention in any commodity cycle. In the current one, they are treated as strategically urgent.
Beyond zinc and lead, the Hermosa site encompasses the Clark deposit, which holds battery-grade manganese, and the Peake copper deposit. Taken together, the project covers five federally designated critical minerals: zinc, lead, silver, copper, and manganese. The last of those carries particular weight. The United States has had no domestic primary manganese production since the 1970s, and the USGS has assessed that the country has essentially no known manganese resources of suitable extraction grade. Every tonne of battery-grade manganese used in American manufacturing currently arrives from abroad, and by the government's own reckoning, essentially all of it is refined in China. Risner is blunt about the implication: "All of the battery-grade manganese at the moment comes from China."
The project's mine life, as now approved, runs to seventy years, though the Taylor deposit's operating life has been updated to approximately thirty-three years following a fifty-two percent boost to its ore reserve in April 2026. The same update pushed first production from Taylor to the second half of fiscal 2028, with nameplate capacity targeted by fiscal 2031. The capital cost for Taylor alone has risen from a 2024 estimate of $2.2 billion to $3.3 billion, a more than fifty percent increase that the company attributed to scope changes and inflation. At steady-state production, South32 projects annual EBITDA of approximately $650 million, rising to around $800 million at spot prices.
The Permitting Machine and Its Claims
FAST-41 has an unglamorous origin. It was created by Congress in 2015 as Title 41 of the Fixing America's Surface Transportation Act, initially designed to streamline environmental reviews for infrastructure projects broadly defined. Its application to mining came later, when federal officials designated zinc and manganese as critical minerals and brought Hermosa into the program in 2023, making it the first mining project ever to receive FAST-41 coverage. South32 says that from start to finish, the federal permit is on track to be issued in just over two years under that framework. The final mine authorization is scheduled for September 4, 2026.
The Trump administration has since added fifty-seven additional mining projects to FAST-41, citing Hermosa as the template. Domenech's council announced in late 2025 that fifty critical mineral and mining projects were now receiving the program's benefits, with forty-nine of them added since January 2025. The political framing has been aggressive: three executive orders underpin the acceleration, including EO 14154 on unleashing American energy, EO 14156 declaring a national energy emergency, and EO 14241 on immediate measures to increase American mineral production. Together, they give agencies both legal cover and political instruction to prioritize speed.
Coronado National Forest Supervisor Kerwin S. Dewberry struck a more measured tone when he announced the Record of Decision, noting that all FAST-41 milestones had been met and laying out the remaining steps with procedural precision: South32 must still submit financial assurance and a final Mine Plan of Operations before the September 4 authorization date. That sequence matters. FAST-41 is a coordination and transparency mechanism, not a waiver of substantive requirements. South32 itself has pushed back on characterizations that the framework cut corners, stating that Hermosa's inclusion "did not reduce the robustness of environmental review or limit public input." The company ultimately committed to more than 135 conservation, mitigation, and monitoring measures developed in conjunction with federal agencies, tribal governments, and local stakeholders.
The federal investment in the project has been substantial. The Department of Energy has directed $166 million toward Hermosa, and the Department of Defense awarded a $20 million Defense Production Act grant, the first ever awarded specifically for manganese. That DoD grant, announced in May 2024, reflected a straightforward national security calculation: the United States is one hundred percent import-dependent for manganese, and the only way that changes is if a domestic source comes online. All state-level permits from the Arizona Department of Environmental Quality have already been granted, removing one of the more common sources of delay in complex mine developments.
A Mine Designed to Argue Its Own Case
South32 has been deliberate about the design of Hermosa in ways that reflect an awareness of the political and legal environment it was navigating. The project uses a fully underground extraction model, which limits surface disturbance to roughly 750 acres, a fraction of the footprint associated with conventional open-pit operations of comparable scale. Unlike the contested copper projects elsewhere in Arizona, Hermosa sinks shafts rather than excavating pits, a distinction that matters enormously in a landscape defined by its ecological sensitivity.
The mine incorporates a dry-stack tailings facility, a technology that eliminates the wet tailings ponds associated with some of the most catastrophic failures in mining history. A water recycling circuit is designed for ninety percent reuse efficiency, a figure the company presents as central to its argument about aquifer impact. The mine fleet will be electrified and remotely operated, reducing diesel emissions on-site and improving safety outcomes. A dedicated seventeen-mile power line connects to the UniSource Energy Services grid, and the project is designed to be capable of drawing from renewable energy sources.
One of the more strategically interesting infrastructure decisions is the location of the Integrated Remote Operations Centre, known as the iROC, in Nogales, Arizona. Remote operations centres allow mining companies to centralize monitoring, process control, and equipment management away from the physical mine site, reducing personnel requirements on-site and improving safety. Locating the iROC in Nogales, a border city with substantial cross-border logistics infrastructure, also allows South32 to leverage supply chain connections across both sides of the US-Mexico border. The facility will employ around two hundred full-time staff working across multiple shifts, and Risner has described a commitment to sourcing concentrate for North American smelters specifically, rather than exporting raw material to Asia.
The economic case extends beyond the mine perimeter. The project is expected to create up to 900 direct jobs, with an eighty percent local hire target that would concentrate employment benefit in Santa Cruz County, one of the economically less developed counties in Arizona. South32 has invested over $3 million in local nonprofits, social services, and schools, and negotiations are ongoing between the company and the town of Patagonia, the city of Nogales, and Santa Cruz County over the terms of a formal community benefits agreement. The company is also collaborating with the Pueblo of Zuni to maintain connections to ancestral landscapes within and adjacent to the project area.
The Costs That Do Not Appear on the Balance Sheet
The Record of Decision has not resolved the project's contested status in the communities nearest to it. Local environmental groups moved quickly to condemn the approval, and their objections are specific rather than broadly oppositional. The Forest Service's own environmental impact statement identifies twelve species listed under the Endangered Species Act that may be adversely affected by the project, including jaguars and Mexican spotted owls, both of which use the Patagonia Mountains as habitat. The approval grants thirty-one exemptions under the Coronado National Forest Plan, exemptions that critics argue conflict with the planning guidance for the area's public lands.
Anna Darian, executive director of the Patagonia Area Resource Alliance, did not mince her position. "The Forest Service approved this project while serious legal questions remain unresolved," she said, "leaving many residents wondering whether these agencies are still serving the public interest." Her organization and the Center for Biological Diversity have said they are evaluating all available options, including potential litigation. That is not a pro forma threat. Legal challenges to mine approvals have derailed or significantly delayed projects for years, and the complexity of Endangered Species Act obligations in a biologically rich landscape is not easily resolved by procedural acceleration.
The water question may be the most durable source of legal and community concern. Over the seventy-year life of the mine, an estimated 195,000 acre-feet of water would be removed from the aquifer. The mine's dewatering operations are projected to draw the water table down by 250 feet across an area of nearly fifty square miles, affecting wells within three miles of the site. While the plan provides for discharging water into three local creeks and the company's ninety percent recycling efficiency claim addresses on-site reuse, the final environmental impact statement projects a net aquifer loss of 34,000 acre-feet over the life of the project, equivalent to more than a billion gallons. In an arid region where groundwater is not a renewable resource on any human timescale, that number is not abstract to the families and farms that depend on those wells.
The mine's operational record has also provided ammunition to critics. In October 2025, water discharge from the existing operation into a local creek exceeded the state regulatory limit for antimony, prompting an investigation by the Arizona Department of Environmental Quality. South32 has not disputed that the exceedance occurred. The incident has been cited in community forums as evidence that the company's environmental commitments require more than voluntary statements to be credible. Arizona Representative Adelita Grijalva wrote to Forest Service Chief Tom Shultz in April 2026 warning that Hermosa's status as the first critical minerals project under FAST-41 made it "especially consequential" and that expedited permitting should not come at the expense of public participation. Her letter predated the Record of Decision by three months and did not succeed in altering its timeline.
The Supply-Demand Arithmetic That Drives Everything
Stepping back from the legal and ecological particulars, the strategic rationale for Hermosa rests on supply-demand arithmetic that Pat Risner recites with the fluency of a man who has been making the case for years. The global zinc market is heading toward a four-million-tonne gap between supply and demand by 2033, he argues, driven by grade decline and mine depletion rather than demand destruction. To close that gap through new projects of Hermosa's scale would require developing three comparable mines every single year between now and 2033. "And Hermosa is the only zinc deposit of this scale discovered globally in the last fifteen years," he noted.
The manganese situation is arguably more acute. As I have covered in my reporting on the broader architecture of Western mineral strategy, China's processing dominance across nineteen of the twenty minerals the IEA tracks as strategically sensitive is not a vulnerability in isolation. It is a system of leverage. Battery-grade manganese, which is critical for certain lithium-ion cathode chemistries used in electric vehicles, flows almost entirely through Chinese refineries. By 2035, projections suggest China will still supply approximately seventy percent of battery-grade manganese to global markets. Hermosa's Clark deposit, if developed on schedule, would be the only fully integrated source of battery-grade manganese in North America, mined and processed into finished product domestically. "Hermosa would be the only fully integrated source of battery-grade manganese in North America," Risner said, "where it is mined and processed into a finished product that can go into precursor material domestically." South32 has already engaged sixteen entities in the battery supply chain, with two non-binding memoranda of understanding in place.
The IEA estimates that the iterative process from mineral exploration to feasibility takes 12.5 years on average, and S&P Global's data on copper mines suggests US projects run considerably longer than that global average, averaging 31.8 years from discovery to production. Against that backdrop, even a two-year permitting timeline represents only one component of a far longer development cycle. South32 acquired the Hermosa project in 2013. First zinc production is now targeted for the second half of fiscal 2028. That is fifteen years from acquisition to first metal. The FAST-41 framework compressed the most visible federal bureaucratic interval, but it did not compress the geology, the capital formation, or the engineering.
That distinction is important as the Trump administration presents Hermosa to the fifty-seven other projects now in the FAST-41 pipeline. Many of those projects are at far earlier stages of development. The permitting milestone that Hermosa crossed on July 7 is real and meaningful. But as the Council on Foreign Relations observed in a February 2026 assessment, accelerating permitting for new mines is a necessary approach that "takes years, often decades, and is insufficient to address potential escalation of tensions with China in the present." The architecture being built around Hermosa, including the FAST-41 expansion, the executive orders, the IEA mandate enlargement agreed at Evian, and the stockpiling frameworks I reported on earlier this month, represents a coherent Western strategic response. Whether it can move fast enough to close the gaps before they become crises is the harder question, and Hermosa does not answer it. It only changes the terms in which the question can be asked.
September 4
On a morning in early September, if the financial assurance paperwork clears and the Mine Plan of Operations passes muster, Coronado National Forest Supervisor Kerwin Dewberry is scheduled to sign the final authorization for the Hermosa Critical Mineral Project. It will be, by the USDA's account, a historic moment in American mining permitting: the first critical mineral project to run the full FAST-41 course, the template for fifty-seven others, and a practical demonstration of what the federal government can do when executive orders, permitting reform, and departmental coordination align.
Down in the Patagonia Mountains, the shafts will keep descending regardless. At seven feet a day, they will be another two hundred feet deeper by then, pushing further into a deposit that Risner believes will eventually reshape America's manganese dependency and make a meaningful contribution to closing the global zinc supply gap. The iROC in Nogales will be staffed with local workers monitoring remote equipment from what looks, in the project's promotional materials, deliberately like an office park rather than a mine.
In the town of Patagonia, a few miles from the fence line, Anna Darian and the Patagonia Area Resource Alliance will be consulting with lawyers about what remedies remain available in federal court. The community benefits agreement negotiations between South32, Nogales, and Santa Cruz County will continue into the autumn. The wells within three miles of the site will still be drawing from an aquifer that the company's own impact statement projects will lose more than a billion gallons of net water over the life of the mine.
Senator Mark Kelly, a Democrat from Arizona who has spent his post-astronaut career thinking about national security dependencies, summed up the political coalition that has formed around the project with characteristic precision. "If we're serious about bringing supply chains back to America and reducing our dependence on foreign countries," he said, "we need to responsibly produce more critical minerals here at home." The word "responsibly" is doing considerable work in that sentence. Whether the September 4 authorization, and the fifty-seven projects following in Hermosa's regulatory wake, will ultimately be judged to have met that standard is a question whose answer will take most of the mine's thirty-three-year operating life to fully resolve.