It’s been a while, so it’s time for an update. If you’re new to $LODE, see my previous three pieces before reading this one.
Below are my thoughts on the four main value drivers in the order in which I expect value-influencing catalysts.
By all accounts, the first commercial scale Metals’ PV recycling plant should be coming online sometime in the next 4 weeks. In my last update 10 months ago, I forecast a June 2026 switch-flip, so we’re pretty close, but with a new tech and FOAK facility, we should be careful about counting our chickens. Here’s hoping for a relatively smooth commissioning and ramp to nameplate.
Looking at my model with nearly a year’s hindsight, it is clear I was too aggressive with the facility build-out and associated rate of anticipatory tipping fees, but was too conservative on operating costs and offtake revenues. The jury is still out on the tipping fee rate.
The list of things we really, really, really, wish we knew:
The supply of end-of-life PV panels.
Yup, everything depends on that:
The utilization ramp of the first plant.
The build-out schedule for the next 5 plants.
The tipping fee.
But sadly, we’re all just guessing, even Comstock, although their (internal) guesses are better informed than ours.
The company has guided to ~25k tons this year, ramping to 70% utilization by year-end 2027, and then to 90% the year after.
Here are my latest ‘base case’ model assumptions:
Average 20% utilization in 2026.
For 2027 forward, plants start at 25% utilization, rising in 70% in 12 months and 90% in 24 months.
A new plant every 18 months.
Tipping fee $450/ton in 2026, falling $50/ton per year.
Offtakes at $400/ton (guidance is $500/ton at $60 silver).
Costs: SG&A $2M, facility fixed costs $10M/plant, variable costs $40/ton.
One wildcard is the in-house metals recovery efforts underway (née “refining”). They have guided to a 1 ton/d pilot plant to be online by end of 2026, scaling to 25 ton/d, and then 250 ton/d. There is a real chance in-house refining starts to add 50%-100% upside to the offtake revenues by 2028/2029, but given both the technological and timeline uncertainty, I’m assigning no value to that very real, and very large upside potential.
I’m also using a very unambitious 20x for PE. The market is known for paying more for 50% growth, with real catalysts to increase that.
There is a lot of guesswork in the utilization, tipping fees, and offtake numbers, so some sensitivity analysis was in order. Above is my “Base” case. I added “High” (optimistic, but not crazily so), and “Low” (bordering on unrealistically pessimistic), and generated a 30/50/20 High/Base/Low blended valuation.
If you really want to know the details of my scenarios, see the bottom of this piece.
The signaling from management is very confident and becoming more precise: expect a divestment, in one form or another, of the mining asset in 3Q2026. It’s not hard to connect the dots and speculate that Mackay is the most likely bidder: previous partner, cashed-up, and obsessed with the Comstock lode.
Comstock put a $50M-$60M value on the asset earlier this year, but let’s be conservative and say $30M, with $10M-$15M cash, the remainder as a royalty or some similar structure. The cash will be great, but it will also be valuable to remove the distraction and let the market stop worrying about mining capex.
Real progress has been made here:
SSOF should own outright 2,200 acres in Silver Springs by the time I click publish on this piece. This is in addition to the mostly adjacent 258 acres that Comstock already owned.
Comstock’s ownership of SSOF is now ~50%.
50k Dekatherms of gas, enough for 300 MW of genset or fuel cell power, has been secured for November 2028.
The value of this land has been a real moving target, but fortunately it has been moving in the right direction. On the 1Q2026 earnings call, Corrado talked about valuing the land at $1M-$4M per MW of power delivered, which mirrors a trend in the datacenter world of valuing based on power, not acreage - this is the best approach so long as there is sufficient land for the power (1-3 acres per MW).
My own research suggests those numbers are reasonable, but the catch is SSOF is only delivering gas, not actual power, so won’t realize the full value of a powered site. To be conservative I’d say we should set expectations more like $500K-$1M/MW. However, Comstock has indicated they are pursuing enough gas for 1+ GW by 2030, and that would definitely move the line up and to the right again. Honestly, I have no idea how to value that upside, so I am going to use $1M/MW * 300 MW => $300M for the ~1,000 acres they are planning to package for a datacenter.
As a check on that $300M valuation, we can look at a nearby block of land at Fernley that Microsoft purchased in March 2025, which is a very good comparable for the SSOF land. They paid $70M for 300 acres, with no power, but by looking at the developer (Victory Logistics), we can infer that they were promised some gas-generated power by 2030. That Microsoft purchase was at $233k/acre vs my power-based valuation for SSOF that implies $300k/acre. The higher price seems plausible given a 15 months of inflation, gas allocation certain and available earlier, and the possible upside of 1+ GW of power by 2030.
After the ~1,000 acres is sold for a datacenter, there is still another ~1460 acres of land (including the airport, the Metals site, and some residential zoned land) that has value, but it’s worth much less, and I’m a lazy bird, so I’m valuing it at zero.
Ruh roh, trouble in the hen house - things have not gone according to plan at Bioleum. This year we’ve had the CEO, CTO, and Chief Engineering Officer all leave. Not good, Bob.
This is a setback for our biofuel moonshot, no question, but they still own the IP for their lignin-preserving digestion, the RenFuel esterification, and Hexas. I am still unaware of anyone who has a better shot at producing cellulosic SAF. And nobody has a better a feedstock than Hexas Xanograss.
But that moonshot call option I’ve talked about is currently far out of the money. The timeline to building their first refinery in Oklahoma is anybody’s guess, but it sure isn’t 2028 like I’d previously hoped.
Series A, the funding Bioleum needs to keep going, was expected to close long ago, but sadly the bid that was coming from Big Oil vanished when shareholders revolted at AGMs, telling CEOs exactly what they thought about green energy investments. That money is gone.
Raising more funding for Bioleum is now high priority, and with the recent re-org at the highest levels in the company, I understand it is getting the focus and effort it deserves. But we need to be realistic and accept that there is a chance Comstock will need to put some more capital into Bioleum. In talking to management, I was reassured that they’ll be no money for nothing nor chicks for free: Bioleum management has equity, is responsible for fund raising, and it’ll smart if they come to Comstock for bridge financing.
My previous understanding was the last $20M investment into Bioleum was done at a ~$1billion valuation, but I now think it was done with a ~$1billion ceiling. Those, in this case, are very different things. I saw an industry insider investing at that valuation and wrote that into my previous model. Oops. Some folk pushed back against that, and they were right.
Bioleum still has great promise, but the path to commercialization is currently so uncertain, I am writing it down to zero in my model.
The dreaded SOTP. This time is different. Honest.
The Metals divestment is expected this quarter, and SSOF should be sometime in six months after that. The money is coming soon; this is not some theoretical exercise on what the parts could be worth.
Yes, I should do something more sophisticated with the carrying value of those asset sales. No, I’m not going to do that. As I keep telling you, I’m a lazy, drug-addled bird, and I’m leaving that work for you, dear reader.
So, after doing my best at being conservative, I’m still coming up with $14/share in two years. As for downside, Mining + SSOF + cash pretty much cover the current market cap. Even if the chicks aren’t free, Comstock Metals very much is.
The past few months have seen a cluster of heavy, on-market purchasing by Comstock insiders.
These are the guys with behind the scenes views of whats going on at Metals and the progress with Mining and SSOF divestments. And they are YOLOing. As they say, there are lots of reasons why insiders sell, but typically only one for why they buy.
I am a low IQ bird with advanced degrees in wood whittling – you’d be a fool to take anything written here as advice or a recommendation.
I’m still long, and ain’t selling my cheapies here.
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