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COMSTOCK FUELS AND SACL EXECUTE DEFINITIVE COMMERCIAL AGREEMENTS
Expands Licensing Agreement into Malaysia for SAF and Other Renewable Fuels
OKLAHOMA CITY, OKLAHOMA – JANUARY 30, 2025 – Comstock Inc. (NYSE: LODE) (“Comstock” and the “Company”) today announced the execution of definitive agreements between Comstock Fuels Corporation (“Comstock Fuels”) and SACL Pte. Limited (“SACL”), a Singapore-based renewable fuel project developer, under which Comstock Fuels and SACL signed an exclusive marketing agreement for Comstock Fuels’ advanced lignocellulosic biomass refining processes in Australia, New Zealand, Vietnam and Malaysia. The definitive agreements finalized all documentation and increase SACL’s territory to facilitate the financing, construction, and operation of additional SACL’s sites in Malaysia, adding to the four existing sites currently under development in Australia and Vietnam, now totaling over 400 million gallons of renewable fuel per dry metric ton of feedstock (on a gasoline gallon equivalent basis, or “GGE”).
Early Adopter License Terms
SACL and its stakeholders previously identified four qualified sites for the construction of four BioleumTM Refineries based on Comstock Fuels’ industry leading yields and decarbonizing impact, including (1) a 250,000 metric ton per year (“MTPY”) refinery located at Myamyn, near Portland, Victoria, Australia, (2) a 250,000 MTPY refinery located near Moree, New South Wales, Australia, (3) a 750,000 MTPY refinery located near Mackay, Queensland, Australia, and (4) a 750,000 MTPY Bioleum Refinery in Quang Tri Province, Vietnam. SACL also has sites under negotiations in New Zealand and Malaysia.
Under the terms of Comstock Fuels’ agreement with SACL, Comstock Fuels will contribute site specific technology rights in exchange for a 20% equity stake in each Bioleum Refinery, plus a royalty fee equal to 6% of each refinery’s sales of licensed products, and engineering fees equal to 6% of total construction costs. At least one of the Bioleum Refineries will initially start with a capacity of 75,000 MTPY prior to scaling-up to 250,000 MTPY or more, with early adopter royalty fees of 3% of sales and engineering fees equal to 3% of construction costs until scaling-up to 250,000 MTPY, with an initial upfront payment of $2,500,000 payable upon execution of each applicable site-specific license agreement for each refinery.
The four planned Bioleum Refineries will have an estimated total construction cost of over $4.0 billion and produce approximately 280 million gallons per year of gasoline, sustainable aviation fuel, and other renewable fuels from lignocellulosic biomass (on a gasoline gallon equivalent basis, or GGE), and about another 180 million GGE from vegetable oils, with over $3.0 billion per year in sales at current prices.
Best-in-Class Yield and Carbon Intensity
Comstock Fuels offers advanced lignocellulosic biomass refining solutions that produce market-leading yields of cellulosic ethanol, gasoline, renewable diesel, sustainable aviation fuel, and other renewable fuels at extremely low carbon intensities. The Comstock Fuels process generally involves: (1) digestion and fractionation of lignocellulosic biomass, (2) bioconversion of cellulose into Cellulosic Ethanol, (3) esterification of lignin and other derivatives into Bioleum Oil, (4) hydrodeoxygenation of Bioleum Oil into Hydrodeoxygenated Bioleum Oil, (5) refining of these extremely low carbon oils and fuels into ASTM compliant renewable fuels, and (6) gas-to-liquids emissions capture and fuel conversion. The first five of these processes are proven to produce up to 125 GGEs per dry metric ton of feedstock on a gasoline gallon equivalent basis, depending on feedstock, lignin content, site conditions, and other process parameters, with extremely low carbon intensity scores of 15.
Wide Open Market, Unprecedented Results
“Comstock Fuels’ breakthrough yields unlock an abundant, available and efficient feedstock source that enables extraordinary new opportunities for renewable fuels project developers, especially given the ongoing global surge in demand for sustainable aviation fuel,” said Garry Millar, SACL’s founder and director. “Comstock’s process uses reliable, available equipment and standard refining processes to convert woody and woody-like biomass, such as purpose grown eucalyptus and Hexas’ XanoGrass™ into renewable intermediates and fuels that leverage existing supply chains. We are pleased to have these definitive agreements completed, including the expansion into Malaysia, and we are looking forward to working with David and the expanded local team to develop our growing portfolio of projects.”
“SACL’s team has continued advancing and expanding their projects, and I look forward to meeting with Garry next week in Australia, as we collaborate and advance all of our mutual objectives in Asia,” stated David Winsness, president of Comstock Fuels. “The prospective site in New Zealand is truly outstanding.”
Comstock Fuels is concurrently executing on its own plans to build, own, and operate the first 75,000 MTPY demonstration scale facility in Oklahoma, followed by three additional 75,000 MTPY facilities, each of which would then be scaled-up to 1,000,000 MTPY commercial scale Bioleum refineries. Collectively, the first four planned U.S. facilities will produce more than 920 million GGE per year of renewable fuels, including about 560 million GGE from woody and woody-like biomass and another 360 million GGE from vegetable oils. Between SACL and our initial plans alone, Comstock Fuels is planning for over 1.38 billion GGE per year of initial renewable fuel production before considering all other licensees and projects in the commercial development pipeline.

COMSTOCK FUELS AND SACL EXECUTE DEFINITIVE COMMERCIAL AGREEMENTS
Expands Licensing Agreement into Malaysia for SAF and Other Renewable Fuels
OKLAHOMA CITY, OKLAHOMA – JANUARY 30, 2025 – Comstock Inc. (NYSE: LODE) (“Comstock” and the “Company”) today announced the execution of definitive agreements between Comstock Fuels Corporation (“Comstock Fuels”) and SACL Pte. Limited (“SACL”), a Singapore-based renewable fuel project developer, under which Comstock Fuels and SACL signed an exclusive marketing agreement for Comstock Fuels’ advanced lignocellulosic biomass refining processes in Australia, New Zealand, Vietnam and Malaysia. The definitive agreements finalized all documentation and increase SACL’s territory to facilitate the financing, construction, and operation of additional SACL’s sites in Malaysia, adding to the four existing sites currently under development in Australia and Vietnam, now totaling over 400 million gallons of renewable fuel per dry metric ton of feedstock (on a gasoline gallon equivalent basis, or “GGE”).
Early Adopter License Terms
SACL and its stakeholders previously identified four qualified sites for the construction of four BioleumTM Refineries based on Comstock Fuels’ industry leading yields and decarbonizing impact, including (1) a 250,000 metric ton per year (“MTPY”) refinery located at Myamyn, near Portland, Victoria, Australia, (2) a 250,000 MTPY refinery located near Moree, New South Wales, Australia, (3) a 750,000 MTPY refinery located near Mackay, Queensland, Australia, and (4) a 750,000 MTPY Bioleum Refinery in Quang Tri Province, Vietnam. SACL also has sites under negotiations in New Zealand and Malaysia.
Under the terms of Comstock Fuels’ agreement with SACL, Comstock Fuels will contribute site specific technology rights in exchange for a 20% equity stake in each Bioleum Refinery, plus a royalty fee equal to 6% of each refinery’s sales of licensed products, and engineering fees equal to 6% of total construction costs. At least one of the Bioleum Refineries will initially start with a capacity of 75,000 MTPY prior to scaling-up to 250,000 MTPY or more, with early adopter royalty fees of 3% of sales and engineering fees equal to 3% of construction costs until scaling-up to 250,000 MTPY, with an initial upfront payment of $2,500,000 payable upon execution of each applicable site-specific license agreement for each refinery.
The four planned Bioleum Refineries will have an estimated total construction cost of over $4.0 billion and produce approximately 280 million gallons per year of gasoline, sustainable aviation fuel, and other renewable fuels from lignocellulosic biomass (on a gasoline gallon equivalent basis, or GGE), and about another 180 million GGE from vegetable oils, with over $3.0 billion per year in sales at current prices.
Best-in-Class Yield and Carbon Intensity
Comstock Fuels offers advanced lignocellulosic biomass refining solutions that produce market-leading yields of cellulosic ethanol, gasoline, renewable diesel, sustainable aviation fuel, and other renewable fuels at extremely low carbon intensities. The Comstock Fuels process generally involves: (1) digestion and fractionation of lignocellulosic biomass, (2) bioconversion of cellulose into Cellulosic Ethanol, (3) esterification of lignin and other derivatives into Bioleum Oil, (4) hydrodeoxygenation of Bioleum Oil into Hydrodeoxygenated Bioleum Oil, (5) refining of these extremely low carbon oils and fuels into ASTM compliant renewable fuels, and (6) gas-to-liquids emissions capture and fuel conversion. The first five of these processes are proven to produce up to 125 GGEs per dry metric ton of feedstock on a gasoline gallon equivalent basis, depending on feedstock, lignin content, site conditions, and other process parameters, with extremely low carbon intensity scores of 15.
Wide Open Market, Unprecedented Results
“Comstock Fuels’ breakthrough yields unlock an abundant, available and efficient feedstock source that enables extraordinary new opportunities for renewable fuels project developers, especially given the ongoing global surge in demand for sustainable aviation fuel,” said Garry Millar, SACL’s founder and director. “Comstock’s process uses reliable, available equipment and standard refining processes to convert woody and woody-like biomass, such as purpose grown eucalyptus and Hexas’ XanoGrass™ into renewable intermediates and fuels that leverage existing supply chains. We are pleased to have these definitive agreements completed, including the expansion into Malaysia, and we are looking forward to working with David and the expanded local team to develop our growing portfolio of projects.”
“SACL’s team has continued advancing and expanding their projects, and I look forward to meeting with Garry next week in Australia, as we collaborate and advance all of our mutual objectives in Asia,” stated David Winsness, president of Comstock Fuels. “The prospective site in New Zealand is truly outstanding.”
Comstock Fuels is concurrently executing on its own plans to build, own, and operate the first 75,000 MTPY demonstration scale facility in Oklahoma, followed by three additional 75,000 MTPY facilities, each of which would then be scaled-up to 1,000,000 MTPY commercial scale Bioleum refineries. Collectively, the first four planned U.S. facilities will produce more than 920 million GGE per year of renewable fuels, including about 560 million GGE from woody and woody-like biomass and another 360 million GGE from vegetable oils. Between SACL and our initial plans alone, Comstock Fuels is planning for over 1.38 billion GGE per year of initial renewable fuel production before considering all other licensees and projects in the commercial development pipeline.