By Charles Pitts
The U.S. Forest Service just moved the needle on domestic mineral security.
On March 6, 2026, the agency officially released the Final Environmental Impact Statement (EIS) and Draft Record of Decision for South32’s Hermosa project in Arizona. This isn’t just another regulatory milestone in a dusty file cabinet. It is the definitive signal that the first mining project to be covered under the federal FAST-41 permitting mandate is entering its final descent toward construction.
The stakes are high. Hermosa isn’t just a mine; it’s a litmus test for whether the United States can actually build the infrastructure required for the energy transition without drowning in decades of litigation and red tape. Located in the Patagonia Mountains of the Coronado National Forest, the project is positioned to become a Tier-1 producer of zinc, silver, and: most critically: high-purity manganese.
For an industry used to waiting ten to fifteen years for federal approvals, the Hermosa timeline is an anomaly. That is by design.
The FAST-41 Guinea Pig
To understand why this development matters, you have to look at the mechanism behind it. FAST-41 (Title 41 of the Fixing America’s Surface Transportation Act) was designed to bring transparency and accountability to the federal permitting process for large-scale infrastructure.
Hermosa became the first mining project added to the dashboard, and the results are finally manifesting. By forcing agencies like the U.S. Forest Service, the Army Corps of Engineers, and the Fish and Wildlife Service to adhere to a coordinated, public schedule, the government is attempting to shave years off the development cycle.
The strategic calculus here isn’t subtle: the U.S. is desperately behind on domestic production of battery-grade minerals. Manganese, in particular, is a glaring vulnerability. Currently, the U.S. has zero domestic production of manganese. South32’s project aims to change that.
The Mineral Profile: Beyond Just Zinc
While Hermosa is often touted for its zinc potential: one of the largest undeveloped resources in the world: the real story for 2026 is manganese.
Manganese is the “forgotten” battery metal. While lithium and nickel grab the headlines, manganese is essential for the NCM (Nickel-Cobalt-Manganese) cathodes that power the majority of long-range electric vehicles. As the industry sees a battery metals rebound, the demand for high-purity manganese is expected to skyrocket.
South32’s Taylor and Clark deposits at Hermosa represent a massive shift. The Taylor deposit is an underground mine focused on zinc, lead, and silver, while the Clark deposit is specifically geared toward battery-grade manganese.
The numbers are staggering:
- Total construction cost: Approximately $1.7 billion.
- Life of Mine: Estimated at 70 years.
- Federal Funding: Seeking $20 million under the Defense Production Act Title III, with a $43 million match from South32.
This level of investment is consistent with a broader trend where Nevada reclaims the crown and other U.S. jurisdictions fight to prove they are “open for business.”
The Regulatory Gauntlet: Water and Wildlife
Despite the “fast-track” label, the Forest Service’s Final EIS is a massive document that addresses the primary friction points: water and the “cone of depression.”
Environmental impact assessments have highlighted the potential effects on groundwater in the Santa Cruz Active Management Area. Critics and local conservation groups have pointed out that the mine’s dewatering process could create a drawdown effect extending far beyond the project’s 750-acre footprint. Over its 70-year lifespan, the mine is estimated to utilize approximately 195,000 acre-feet of groundwater.
In the desert Southwest, water is more than a resource: it’s a political third rail.
The U.S. Forest Service has had to balance these hydrological concerns against the federal mandate to secure rare earth and critical mineral supplies. The Draft Record of Decision likely includes extensive mitigation requirements, including long-term water monitoring and potential offsets for local well-owners.
A Test Case for the Trump and Biden Administrations
Interestingly, the Hermosa project has enjoyed a rare moment of bipartisan continuity. The FAST-41 designation began under one administration and has been aggressively pushed forward by the next. Both sides of the aisle realize that the “Green Revolution” is physically impossible without more holes in the ground.
However, the streamlined process doesn’t mean a “free pass.” The project still requires:
- Section 404 Permit: From the Army Corps of Engineers for impacts to “waters of the United States.”
- Endangered Species Act Consultation: Specifically regarding the jaguar and ocelot habitats in the Patagonia Mountains.
- National Historic Preservation Act (Section 106): Consultation with tribal nations who have ancestral ties to the land.
The difference now is that these agencies are no longer working in silos. They are working against a clock. The estimated completion date for the entire federal review process is September 7, 2026.
The Economic Impact on Santa Cruz County
For Santa Cruz County, Hermosa is an economic titan. The $1.7 billion construction spend and hundreds of high-paying permanent jobs would represent a fundamental shift for a region heavily dependent on cross-border trade and tourism.
But with that growth comes the usual “boomtown” anxieties: infrastructure strain, housing shortages, and the long-term environmental legacy. South32 has attempted to get ahead of this with early investments in local education and infrastructure, but the release of the Final EIS will likely reignite local debate.
What Happens Next?
The release of the Final EIS and Draft Record of Decision triggers a final “objection period.” This is the last chance for stakeholders: both pro and anti: to challenge the findings before the Final Record of Decision is signed.
If South32 clears this final hurdle, the company will likely move toward a final investment decision (FID). Given the current geopolitical climate and the volatility in global mining jurisdictions, a stable, high-grade project on U.S. soil is an incredibly attractive asset for investors.
The strategic calculus isn’t just about profit; it’s about survival. Without Hermosa, the U.S. remains 100% dependent on foreign sources for battery-grade manganese.
The Bottom Line
Hermosa is the new blueprint. If South32 successfully navigates the FAST-41 process to a final permit, expect a wave of other critical mineral projects to apply for the same designation. The era of the “20-year permit” is being challenged by a federal government that has finally realized you can’t build a 21st-century economy on 20th-century bureaucracy.
We will be watching the September 2026 deadline closely. For the mining industry, that date represents more than just a permit: it represents the viability of the American mining renaissance.
For more in-depth analysis on the domestic supply chain, check out our report on rare earth supply outlooks or follow our latest news updates.
