Comstock Mining Urges U.S. EPA to Expand Renewable Fuel Incentives for Biointermediates

Comstock's patented, patent-pending and proprietary portfolio of breakthrough Cellulosic Fuels technologies efficiently converts wasted, unused, widely-available, and rapidly-replenishable woody biomass into intermediates for the production of carbon neutral gasoline, renewable diesel, sustainable aviation fuel, marine fuel, ethanol, oils and other advanced renewable replacements for fossil fuel products.

"Our technologies broadly enable a powerful new feedstock model for multiple renewable fuel platforms by converting wasted and under-utilized woody biomass into biointermediates, including cellulosic sugar and a mixture of hydrocarbons called biocrude," said Corrado De Gasperis, Comstock's executive chairman and chief executive officer. "Our cellulosic sugar products are chemically identical to pure glucose, and capable of directly offsetting corn as a feedstock for fermentation in existing ethanol facilities. Likewise, our biocrude products have specifications that are similar to fossil crude, and are qualified for refining into drop-in fuels, such as gasoline, renewable diesel, sustainable aviation fuel, and marine fuel."

Removing Limitations for Breakthrough Technologies

Under the current regulatory structure, Comstock would directly produce and sell renewable fuels to qualify for federal incentives under the RFS. However, the EPA proposed modifications to the RFS in December 2021 to accommodate the growing potential of using biointermediates in the production of renewable fuels. Comstock's February 2022 comments to the EPA supported and urged inclusion of the full range of America's available woody biomass resources to produce biointermediates for sale to multiple downstream renewable fuel producers, thereby expediting the transition from petroleum to renewable fuels, and enabling the transformational changes envisioned by the Biden Administration to address the challenges of climate change. Comstock also urged the EPA to revise the renewable identification number ("RIN") program to create ambitious additional categories for new and emerging technologies that can achieve 80%, 100%, and 120% greenhouse gas ("GHG") reductions, as compared to the existing 60% cap on GHG reduction in the current RIN program, to fairly incentivize and accelerate transformational change.

Transformational Economic Benefits

Comstock's technologies can produce enough cellulosic sugar and biocrude to refine more than 70,000,000 gallons of ethanol and 30,000,000 gallons of renewable diesel from each 1,000,000 dry tons of woody biomass. For context, according to the U.S. Department of Energy, America has the potential to produce upwards of one billion dry tons of biomass per year, substantially comprised of wasted and under-utilized forestry and agricultural residuals that Comstock's proven and shovel-ready Cellulosic Fuels technologies have the ability to convert into biointermediates.

"We plan to be extremely active in America's wood basket," added De Gasperis. "America has tremendous untapped reserves of woody biomass and under-utilized forestry and agricultural resources that could be simultaneously used to stimulate transformational economic and environmental change, by adding significant additional revenue and jobs into America's rural economies, while producing biointermediate and other products that dramatically reduce GHG emissions as compared to conventional renewable fuel feedstocks. While we are prepared to use our technologies to directly produce renewable fuels, we can grow much faster and achieve far greater gains by producing and selling biointermediates to other renewable fuel producers. We are excited by EPA's timely focus on these important regulations."

Comstock's team has extensive experience in the renewable fuel industry, having designed and built numerous biointermediate and renewable fuel production facilities in the United States. Most notably, Comstock's team invented and commercialized processes used by more than 95% of the U.S. corn ethanol industry to produce distillers corn oil, a value-added biointermediate that has played a vital role in the growth and development of the corn ethanol, biodiesel, and renewable diesel industries. Comstock plans to apply this expertise to building, owning, and operating a fleet of advanced carbon neutral extraction and refining facilities, with several potential sites currently under evaluation for development.

About Comstock Mining Inc.
Comstock Mining Inc. (NYSE: LODE) (the "Company") innovates technologies that contribute to global decarbonization and circularity by shifting the consumption patterns of industries and populations. Comstock's technologies are designed to do so by efficiently converting wasted and unused natural resources into valuable renewable energy products. Comstock intends to use its technologies to achieve exponential growth and extraordinary financial, natural and social gains by building, owning, and operating a fleet of advanced carbon neutral extraction and refining facilities, by selling an array of complimentary process solutions and related services, and by licensing selected technologies to qualified strategic partners. To learn more, please visit www.comstockmining.com.

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Some of those risks and uncertainties include the risk factors set forth in our filings with the SEC and the following: adverse effects of climate changes or natural disasters; adverse effects of global or regional pandemic disease spread or other crises; global economic and capital market uncertainties; the speculative nature of gold or mineral exploration, mercury remediation and lithium, nickel and cobalt recycling, including risks of diminishing quantities or grades of qualified resources; operational or technical difficulties in connection with exploration or mercury remediation, metal recycling, processing or mining activities; costs, hazards and uncertainties associated with precious metal based activities, including environmentally friendly and economically enhancing clean mining and processing technologies, precious metal exploration, resource development, economic feasibility assessment and cash generating mineral production; costs, hazards and uncertainties associated with mercury remediation, metal recycling, processing or mining activities; contests over our title to properties; potential dilution to our stockholders from our stock issuances, recapitalization and balance sheet restructuring activities; potential inability to comply with applicable government regulations or law; adoption of or changes in legislation or regulations adversely affecting our businesses; permitting constraints or delays; ability to achieve the benefits of business opportunities that may be presented to, or pursued by, us, including those involving battery technology, mercury remediation technology and efficacy, quantum computing and advanced materials development, and development of cellulosic technology in bio-fuels and related carbon-based material production; ability to successfully identify, finance, complete and integrate acquisitions, joint ventures, strategic alliances, business combinations, asset sales, and investments that we may be party to in the future; changes in the United States or other monetary or fiscal policies or regulations; interruptions in our production capabilities due to capital constraints; equipment failures; fluctuation of prices for gold or certain other commodities (such as silver, zinc, lithium, nickel, cobalt, cyanide, water, diesel, gasoline and alternative fuels and electricity); changes in generally accepted accounting principles; adverse effects of war, mass shooting, terrorism and geopolitical events; potential inability to implement our business strategies; potential inability to grow revenues; potential inability to attract and retain key personnel; interruptions in delivery of critical supplies, equipment and raw materials due to credit or other limitations imposed by vendors; assertion of claims, lawsuits and proceedings against us; potential inability to satisfy debt and lease obligations; potential inability to maintain an effective system of internal controls over financial reporting; potential inability or failure to timely file periodic reports with the Securities and Exchange Commission; potential inability to list our securities on any securities exchange or market or maintain the listing of our securities; and work stoppages or other labor difficulties. 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