Fourth in a series on the money behind the Copperwood Mine. Everything here comes from Highland Copper’s own filings and from the State of Michigan’s own records. Sources are at the end. Previous pieces at lakesuperiorregister.com.

The short version

On Tuesday, August 25, the Michigan Strategic Fund Board votes on a resolution to send $44,971,691 to Copperwood Resources Inc. and $5,028,309 to the Gogebic County Road Commission — fifty million dollars of public money for site readiness at a mine that has not yet begun construction. (1)

I have written previously about the gap between what Michigan’s mining permit says reclamation will cost and what the state actually holds against it. (2)

This piece is about three things I have not written about, all of which come from Highland Copper’s own audited statements.

First: if this project fails, Michigan does not stand first in line. A Toronto royalty company holds a mortgage on the Copperwood property and a security interest that includes a pledge of the shares of Copperwood Resources Inc. itself — the Michigan subsidiary that owes the reclamation obligation.

Second: the financial assurance is not a floor. It has already been reduced once. Highland reported $240,188 returned to the company during the six months ended December 31, 2025.

Third: the last time the Michigan Strategic Fund approved money for this project, it attached a condition. That condition concerned Highland’s ability to raise private capital. Whether it has been met is a question the Board is in a better position to answer than I am.

What the state actually holds

Nonferrous Metallic Mineral Mining Permit No. MP 01 2012 was issued on April 30, 2012, originally to Orvana Resources US Corp; the permit holder was renamed Copperwood Resources Inc. in 2017. (3)

Special Condition N.1 of that permit sets the reclamation figure:

“The total financial assurance estimated for the Copperwood Mine for reclamation costs at the closure stage of production is determined to be $37,960,000 as of the date this permit was issued.” (4)

Against that, the state holds a surety bond of $6,479,089, secured in July 2023. (5) Behind the bond sits a cash deposit of $2,267,680 — roughly thirty-five percent collateral. (5) EGLE’s own file records the instruments arriving on July 27, 2023 and being accepted on August 2, 2023. (6)

That is the arithmetic from the first piece in this series. What follows is what sits underneath it.

Who is ahead of Michigan in line

Highland Copper Company Inc. is headquartered in Vancouver, British Columbia, and trades on the TSX Venture Exchange under HI and on the OTCQB under HDRSF. (7) The corporate chain runs from Highland in Canada, through Upper Peninsula Holding Company Inc., a Delaware entity, to Copperwood Resources Inc., the Michigan company that holds the permit and owes the reclamation obligation. (8)

Osisko Gold Royalties is both a shareholder in Highland, at roughly six percent, and a secured party. Highland’s annual financial statements for the years ended June 30, 2024 and June 30, 2025 disclose, in the notes concerning the Osisko royalty arrangement, a mortgage on the Copperwood property and a general security agreement over company assets that includes a pledge of the shares of Copperwood Resources Inc. (9)

Read that twice. The security package does not merely encumber the ore body. It reaches the equity of the subsidiary that carries the permit.

I want to be careful about what this does and does not establish, because the legal question is genuinely more complicated than a headline can carry. Michigan’s reclamation claim is not simply an ordinary unsecured debt; states have statutory tools, and how a mining reclamation obligation would rank against a perfected security interest in a distressed scenario is a question for lawyers with the actual documents in front of them.

But here is what can be said plainly. A secured creditor holding a mortgage and a share pledge is, by design, positioned ahead of general claimants in a default. The bond covers $6.48 million. Everything above that number — and the permit itself puts the number at nearly $38 million in 2012 dollars — is a claim that has to compete. Michigan would be competing.

That is a question the Board should have answered before it votes, not after.

The number that goes down

There is a second feature of the financial assurance that is easy to miss and hard to unsee.

Highland’s interim financial statements for the periods ended December 31, 2025 report $240,188 returned from the financial assurance cash deposit in respect of completed site work. (10)

That is how these instruments are designed to function — assurance is released as obligations are discharged. It is not improper. But it means the $6,479,089 is not a floor beneath the state’s exposure. It is a balance, and the balance declines.

There is a third number worth setting alongside it. On its own balance sheet, Highland carries an asset retirement obligation with undiscounted cash flows of $1,722,673, with payments modeled in years 16, 17 and 35 from the start of construction. (11)

So the state’s permit says the closure job is worth $37.96 million. The state holds $6.48 million, declining. And the company’s own accounting provision for retiring the asset is $1.72 million, most of it modeled decades out.

Three numbers, three orders of magnitude apart, describing the same hole in the ground.

The Board’s own condition

This is not the first time the Michigan Strategic Fund has considered money for Copperwood.

An earlier approval attached a condition relating to Highland’s ability to raise private capital — on the order of $150 million — before state support would flow. Subsequent attempts to route funding to the project stalled in Senate Appropriations and were later removed from the state budget in October 2025. (12)

Meanwhile the capital picture has not resolved. Highland announced a non-binding Letter of Interest from the Export-Import Bank of the United States for up to US$250 million in September 2025. (13) Non-binding is the operative word; a letter of interest is not a commitment of funds. Development capital expenditure for the project has been put at roughly $425 million, with a construction decision targeted for the second half of 2026. (14)

I do not know whether the prior condition has been satisfied, modified, or waived. The Board does.

Questions this raises

These are open to the Michigan Strategic Fund Board, to MEDC staff, to Highland Copper, and to EGLE:

Has the Board reviewed the State of Michigan’s creditor position with respect to reclamation costs, given the security interests disclosed in Highland Copper’s audited statements?

Was the private-capital condition attached to the earlier approval satisfied, modified, or waived? If it was not satisfied, on what basis does the current resolution proceed?

What is the state’s current reclamation cost estimate for Copperwood in today’s dollars? General Permit Condition F.6 requires an updated reclamation cost estimate on or before March 15 of every third year following issuance. (4) I have been unable to locate any such update in the public file, and I have an inquiry outstanding with EGLE on this point.

I will publish any answer I receive, in full, including any that shows I have gotten something wrong.

I have submitted these findings to the Michigan Strategic Fund Board as written public comment ahead of Tuesday’s vote. I have not asked the Board to vote any particular way. I have asked it to answer the questions above.

Previous pieces: “Copperwood Mine: The $31 Million Hole in the Cleanup Fund,” “Copperwood Mine: Its Owner Told Investors It Might Not Survive,” and “Copperwood Mine: The Group Vouching for the Mine Has the Mine’s CEO on Its Board.”

How this publication is researched and written, including my use of AI as a research and drafting tool, is on the About page.

Sources

1. Michigan Strategic Fund Board Meeting Agenda, August 25, 2026, 9:00 a.m., Item VI.a. michiganbusiness.org, MSF board meeting agendas.

2. Lake Superior Register, “Copperwood Mine: The $31 Million Hole in the Cleanup Fund.”

3. Mining Permit No. MP 01 2012, issued April 30, 2012 by the Michigan Department of Environmental Quality to Orvana Resources US Corp (Orvana Minerals release, April 30, 2012); permit holder renamed Copperwood Resources Inc., 2017 (EGLE MiEnviro site file).

4. Nonferrous Metallic Mineral Mining Permit No. MP 01 2012, Special Permit Conditions § N.1; General Permit Conditions § F.6.

5. Highland Copper Company Inc., Consolidated Financial Statements for the years ended June 30, 2025 and 2024: surety bond secured July 2023, valued $6,479,089; cash deposit $2,267,680.

6. EGLE MiEnviro, Copperwood site file: Financial Assurance Documents — shipment tracking correspondence, July 26 – August 2, 2023; arrival July 27, 2023, acceptance August 2, 2023.

7. Highland Copper Company Inc. trades on the TSX Venture Exchange (HI) and OTCQB (HDRSF), headquartered in Vancouver, British Columbia. Filings at highlandcopper.com and on SEDAR+.

8. Highland Copper Company Inc., corporate structure disclosures: Highland Copper Company Inc. (Canada) → Upper Peninsula Holding Company Inc. (Delaware) → Copperwood Resources Inc. (Michigan).

9. Highland Copper Company Inc., annual financial statements for the years ended June 30, 2024 and June 30, 2025, notes concerning the Osisko royalty: mortgage on the Copperwood property and general security agreement over company assets, including a pledge of the shares of Copperwood Resources Inc.

10. Highland Copper Company Inc., interim financial statements for the periods ended December 31, 2025: $240,188 returned from the financial assurance cash deposit in respect of completed site work.

11. Highland Copper Company Inc., annual financial statements (June 30, 2025): asset retirement obligation, undiscounted cash flows of $1,722,673, with payments modeled in years 16, 17 and 35 from the start of construction.

12. Michigan Strategic Fund prior approval and conditions; subsequent legislative history, including removal of Copperwood infrastructure funding from the state budget, October 2025.

13. Highland Copper Company Inc. press release, September 2025: non-binding Letter of Interest from the Export-Import Bank of the United States, up to US$250 million.

14. Highland Copper Company Inc., 2026 work plan release (January 27, 2026) and investor materials: development capital expenditure of approximately $425 million; construction decision targeted for the second half of 2026.

Third in a series on the money behind the Copperwood Mine. Everything here comes from documents you can read yourself. Sources are at the end.

The short version

An organization called InvestUP has spent two years telling the Michigan Legislature, the press, and the people of Gogebic County that the Copperwood Mine deserves a $50 million public grant.

In one of those releases, InvestUP told the public that the mine’s cleanup costs are covered by the company “no matter what.”

Michigan’s own mining permit estimates the cleanup at $37,960,000. The state actually holds a bond worth $6,479,089.

And the chief executive of the mining company sits on InvestUP’s board of directors.

None of InvestUP’s releases about the Copperwood Mine mention that last part.

That’s the whole story. The rest of this is the evidence.

The sentence

In December 2024, InvestUP published a press release headlined “Don’t Let Misinformation Kill a Once in a Generation Opportunity.” (1)

It was a fact-check. Nine bullet points under the heading “Here are the facts.” The last one:

“As required by Michigan law, Highland Copper maintains a bond with the state to ensure that the cost of mine closure and remediation is covered by the company, no matter what.”

Here is what Michigan’s mining permit actually says, in Special Condition N.1:

“The total financial assurance estimated for the Copperwood Mine for reclamation costs at the closure stage of production is determined to be $37,960,000 as of the date this permit was issued.” (2)

That permit was issued in April 2012. The bond currently on file, according to the company’s own audited financial statements, is $6,479,089. (3)

About seventeen cents on the dollar, measured against a fourteen-year-old estimate. I wrote about that gap two weeks ago, before I knew this press release existed.

Who InvestUP is

InvestUP calls itself the regional economic development organization for the Upper Peninsula, working across all fifteen counties. Its chief executive is Marty Fittante, who spent fourteen years working in the Michigan Legislature before taking the job in 2019. (4)

Nobody expects InvestUP to be neutral about economic development. Promoting it is the organization’s stated purpose, and it does real work on housing, workforce, and business growth across a region that badly needs all three.

But a booster saying “this project would be good for us” is a different thing from a booster saying “here are the facts, ignore the misinformation.” The second one asks you to trust it as a referee. And that’s when it matters who is on the team.

The name on the list

InvestUP files an IRS Form 990 every year. It is a public document. Anyone can read it on ProPublica’s Nonprofit Explorer.

The 2024 return lists thirty-three voting directors. Number twenty-four is Barry O’Shea. (5)

Barry O’Shea is the Chief Executive Officer of Highland Copper Company — the parent company of Copperwood Resources Inc., which owns the Copperwood Mine.

He is quoted by name, as Highland Copper’s CEO, in that same December 2024 release and in at least four others InvestUP has published about the project. (1, 6, 7, 8) One of them is datelined “Marquette, Mich. and Vancouver, Canada,” carries both organizations’ logos, and lists media contacts for both.

So when InvestUP told Michigan that Copperwood’s cleanup costs were covered no matter what, the organization saying it had the company’s chief executive on its board.

None of the releases mention that.

What the governance answers say

The same Form 990 asks a series of standard questions about how a nonprofit polices itself. (5)

Line 12a: Does the organization have a written conflict of interest policy? Yes.

Line 12b: Are officers, directors, and key employees required to disclose annually interests that could give rise to conflicts? No.

Line 13: Whistleblower policy? No.

Line 14: Document retention and destruction policy? No.

Schedule O explains that the expectation is for a conflicted director to recuse himself, “as evidenced by past practice.”

That is an honor system. It may work fine. But it is worth knowing that it is the only mechanism in place on a board where one member’s company is the subject of the organization’s most sustained public advocacy campaign.

One more number from the same return: of $2,311,288 in contributions and grants, $1,626,053 came from government grants. (5) InvestUP is substantially funded by public money.

The poll released three days before the vote

On the morning of Friday, August 21, 2026, InvestUP issued a press release announcing new statewide polling conducted by EPIC-MRA. The headline number: 71 percent of Michigan voters support the Copperwood Project. The release added that 46 percent of respondents expressed some concern about environmental impact, and that 61 percent remained in favor after environmental factors were considered. (13)

WLUC TV6 and WUPM both carried it. (13, 14)

EPIC-MRA is a legitimate firm. It has operated in Lansing since 1985 and is the most frequently cited pollster in Michigan, quoted by NBC, CBS, CNN, NPR, and most major newspapers in the state. Nothing here questions their competence.

What is missing is everything a reader would need to evaluate the number.

The release did not disclose who commissioned the poll. It did not give the sample size, the field dates, the margin of error, or — most importantly — the wording of the questions asked. When EPIC-MRA polls for media clients, the full instrument is routinely published; WOOD TV, for example, posts the complete frequency-of-response tables. Nothing comparable was released here.

That matters because EPIC-MRA, like most survey firms, runs a monthly statewide omnibus survey in which outside organizations can purchase a battery of questions. Under that arrangement, a poll can accurately be described as “conducted by EPIC-MRA” while the questions themselves were written and paid for by an interested party. I do not know whether that is what happened here. I asked. (See below.)

Tom Grotewohl of Protect the Porkies called the poll “bogus” and argued that question wording drives the result. (13) He may be right, but neither he nor I can demonstrate it without seeing the instrument.

The timing is a matter of public record. The Michigan Strategic Fund Board is scheduled to take up roughly $50 million in state support for Copperwood infrastructure in the coming days — the third such attempt, after the first stalled in Senate Appropriations in 2024 and a second was stripped from the state budget in October 2025. (15, 16)

A favorable poll, released by the project’s principal advocacy organization, with no methodology attached, on the last business day before that vote.

The pattern

InvestUP’s handling of public money has drawn scrutiny before, and the reporting is not mine.

In August 2025, Craig Mauger of The Detroit News published “Nonprofit uses tax money to fund ‘upscale’ U.P. apartments developed by its founder.” (9) The story concerns a $15 million state earmark to InvestUP for housing, and money flowing to apartments developed by Robert Mahaney, who was InvestUP’s chairman at the time. The Detroit News followed with additional reporting in December 2025. (10, 11)

Mahaney remains on the board; he appears as director number nineteen on the same Form 990. (5)

He has responded publicly. In an October 2025 Q&A with The Mining Journal, Mahaney said his company followed every applicable guideline, never sought favorable treatment, never spoke with Build UP decision-makers about the awards, and that board membership at InvestUP follows automatically from being one of roughly thirty-five member organizations. (12)

I have not independently verified The Detroit News reporting. I cite it as published work by a statewide newspaper, for context — not as a finding of my own. Readers should read it and judge for themselves.

The relevance here is narrow and I want to state it precisely: an organization substantially funded by public money, whose stewardship of public money has already been the subject of newspaper investigation, does not require its directors to disclose conflicts annually — and has the CEO of the mine it promotes sitting on its board.

Questions this raises

These questions are open to InvestUP, to Highland Copper, and to any member of InvestUP’s board:

When did Barry O’Shea join the InvestUP board? Did he recuse himself from any decision relating to InvestUP’s Copperwood advocacy? Is Highland Copper a dues-paying member or financial contributor to InvestUP?

Who commissioned the EPIC-MRA polling released on August 21, and will the full question wording and methodology be made public?

And on what basis did InvestUP tell the public that closure costs are covered “no matter what”?

I have not received answers to any of these. I will publish any response I get, in full, including any that shows I have gotten something wrong.

Questions also remain outstanding with the Michigan Department of Environment, Great Lakes, and Energy: whether the reclamation cost estimate updates required every three years by General Permit Condition F.6 have ever been filed, and what the state’s current cleanup estimate is in today’s dollars. (2)

Twenty-two units of local government passed resolutions supporting this project. They were reading material like this. I would like to know whether anyone showed them the permit at the same time.

Previous pieces: “Copperwood Mine: The $31 Million Hole in the Cleanup Fund” and “Copperwood Mine: Its Owner Told Investors It Might Not Survive.”

How this publication is researched and written, including my use of AI as a research and drafting tool, is on the About page.

Sources

1. InvestUP, “Don’t Let Misinformation Kill a Once in a Generation Opportunity,” December 16, 2024. investupmi.com.

2. Nonferrous Metallic Mineral Mining Permit No. MP 01 2012, Special Permit Conditions § N.1. Permit issued April 30, 2012. General Permit Conditions § F.6 requires an updated reclamation cost estimate on or before March 15 of every third year after issuance.

3. Highland Copper Company Inc., Consolidated Financial Statements for the years ended June 30, 2025 and 2024: surety bond of $6,479,089 secured July 2023 as financial assurance for the Copperwood Project.

4. InvestUP, “Meet the Team,” investupmi.com.

5. Invest Up, IRS Form 990 for fiscal year ending December 2024, EIN 82-2441360, filed January 2026. Part VII Section A (directors); Part VI Section B lines 12a, 12b, 13, 14; Schedule O; Part VIII line 1e. Available at ProPublica Nonprofit Explorer.

6. InvestUP, “Upper Peninsula Leaders Commend $50 Million State Investment in Copperwood Mine Project,” 2024.

7. InvestUP, “Western Upper Peninsula Communities Demonstrate Continued Support for the Copperwood Mine Project,” datelined Marquette, Mich. and Vancouver, Canada.

8. InvestUP, “’We’re Not Slowing Down’: U.P. Resilience Powers Copperwood Mine Project Despite State Budget Decision,” 2025.

9. Craig Mauger, The Detroit News, August 26, 2025: “Nonprofit uses tax money to fund ‘upscale’ U.P. apartments developed by its founder.” Also carried by The Mining Journal, August 28, 2025.

10. The Detroit News, December 8, 2025: “U.P. business group reported lobbyist, whiskey glass bills after getting taxpayer cash.”

11. The Detroit News, December 8, 2025: “3 projects involving same U.P. developer netted help from state lawmakers.”

12. The Mining Journal, October 23, 2025: “Mahaney addresses Detroit News article in Q&A session.”

13. WLUC TV6, August 21, 2026: “Poll suggests 71% of Michiganders support Copperwood Project; Protect the Porkies calls poll ‘bogus.’”

14. WUPM 106.9, August 21, 2026, news summary carrying the InvestUP polling release.

15. Bridge Michigan, October 2025: reporting on the removal of $50 million for Copperwood infrastructure from the state budget.

16. Reporting on the Michigan Strategic Fund Board’s scheduled reconsideration of approximately $50 million in state support for the Copperwood Project, August 2026.

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I’m Don Dey. I hold two bachelor’s degrees from the University of Wisconsin–Madison, including one in journalism, and a Master of Library and Information Science from UW–Milwaukee. I taught high school science for twenty-five years and worked as a school library media specialist. I’m retired, I live in Gogebic County, and I have no financial interest in the Copperwood project or in any organization opposing it.

I use AI — Claude, specifically — as a research and drafting tool. It helps me locate documents, work through regulatory and accounting language, and turn my reporting into finished prose. I say that plainly because you’d find out anyway if you scanned this page, and I’d rather you hear it from me.

What that means in practice: I decide what to investigate. I read the primary documents myself — the permit, the rules, the financial statements — and every figure in this piece is checked against one. Thirty years of research training is mostly training in not believing things, and I apply it to what the AI gives me the same way I’d apply it to anything else. If I can’t source a claim, it doesn’t run.

If I’ve gotten something wrong, write to me at editor@lakesuperiorregister.com. I’ll correct it in public and credit you.

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Last week I wrote about a number the State of Michigan put in the Copperwood mining permit in 2012: $37,960,000, the estimated cost of hiring a contractor to reclaim and monitor the site if the company that dug it couldn’t or wouldn’t. Against that, Michigan holds a surety bond of $6,479,089.

The obvious objection to that piece is the reasonable one. Why does the gap matter, if the mine is going to be built and run and cleaned up by a functioning company?

Fair question. So I went and read what the company says about itself when it is talking to its investors instead of to Wakefield.

The sentence

On February 19, 2026, Highland Copper Company Inc.’s board of directors approved the company’s financial statements for the six months ending December 31, 2025. On page eight of that document is this:

“The conditions and uncertainties described above indicate the existence of a material uncertainty that casts significant doubt about the Company’s ability to continue as a going concern.” (1)

Two sentences later:

“If management is unable to obtain adequate funding, the Company may be unable to continue its operations, and amounts realized for assets may be less than amounts reflected in these financial statements.” (1)

That is not my characterization of Highland Copper. It is Highland Copper’s characterization of Highland Copper, signed off by its chief executive and a director, and filed with Canadian securities regulators, where lying carries consequences.

What “going concern” actually means

This is a term of art, and it’s worth being precise about it rather than letting it sound scarier or milder than it is.

When accountants prepare financial statements, they normally assume the business will still exist in a year. That assumption is called the going-concern basis, and it’s what lets a company value its assets at what they’d be worth in ordinary operation rather than at fire-sale prices.

When there is significant doubt about that assumption, the company is required to say so, in those words. It is a formal disclosure with a defined meaning, not a figure of speech. Auditors and regulators treat it as a serious signal, which is exactly why the language is standardized.

It does not mean a company is about to fail. It means the company has told the people who bought its stock that it might.

Why they said it

The statements lay out the reasons plainly. (1)

Cash on hand at December 31, 2025: $5,696,419. Six months earlier it had been $10,356,450. Roughly $4.7 million burned in half a year, with no revenue coming in — Highland has never produced or sold anything.

Negative working capital of $6,256,353, meaning short-term obligations exceeded short-term assets.

An accumulated deficit of $71,412,421 — the running total of every dollar the company has lost since it began.

A net loss of $7,014,882 for those six months alone.

And a loan from its joint-venture partner Kinterra of $10,918,231, at 10 percent interest compounding annually, coming due July 24, 2026.

That’s the picture as of the last day of 2025: a company with no revenue, a burn rate above $9 million a year, $5.7 million in the bank, and an eleven-million-dollar bill arriving in July.

What happened next, in fairness

Highland fixed it. I want to be as clear about this as about everything above, because a piece that leaves it out isn’t reporting.

On January 13, 2026, Highland signed a definitive agreement to sell its 34 percent stake in the White Pine North project to Kinterra for approximately US$30 million. (2) The deal closed in early March. The proceeds retired the Kinterra loan and refilled the treasury; by mid-2026 the company was describing itself as debt-free with roughly $24 million in cash. (3)

So the immediate crisis passed. Anyone telling you Highland Copper is on the brink today is overstating it, and I’m not going to.

Two things about that, though.

First, the mechanism. Highland didn’t solve its cash problem by earning money or by raising it from investors. It solved it by selling its only other asset. Before January, Highland had two projects in the Upper Peninsula. Now it has one. Every dollar of value in that company, and every dollar available to meet any obligation it has, now depends on Copperwood.

Second, the scale. Copperwood’s construction cost has been put at roughly $400 million. Highland’s entire market value is around C$110 million, and it has about $24 million in the bank. (3) The money to build this mine does not exist yet. It has to come from a federal loan program, a bank syndicate, an offtake partner, or new shareholders — and the company’s own outlook describes those as things it is pursuing, not things it has. (2)

A going-concern warning that gets resolved by selling half the company is a resolved warning. It is not the same as a company that no longer needs one.

Where this meets the cleanup fund

Put the two pieces together.

Michigan’s estimate for reclaiming Copperwood, written into the permit in 2012 and never publicly updated, is $37,960,000. Michigan holds $6,479,089. On Highland’s own books, the money set aside for reclamation is $1,122,395 at present value — $1,722,673 undiscounted, with payments modeled 16 to 35 years out. (1)

The obligation is held by Copperwood Resources Inc., the Michigan subsidiary. Its parent has no revenue, one asset, an accumulated deficit of $71 million, and a filed disclosure stating there was material uncertainty about its survival as recently as February of this year.

That is not an argument that the mine will fail. It is an argument about who is holding the risk if it does — and the answer, on the documents, is that Michigan is holding considerably more of it than $6,479,089 covers.

What I am not claiming

Going-concern warnings are common among pre-revenue mining companies. Development-stage miners spend for years before earning anything, and their auditors flag it routinely. Anyone who tells you this disclosure is unusual in the junior mining sector is wrong, and I’d rather you hear that from me.

I am also not saying Highland has misled anyone. The opposite: they disclosed it, in the required language, in a public document, because Canadian securities law requires it. The reason I can write this article is that they told the truth to their investors.

My point is only that the same fact ought to be available to the people in Gogebic County who are being asked to accept the environmental risk. Wakefield Township, Ironwood Township, Erwin Township, the Gogebic County Board of Commissioners, and the Gogebic County Road Commission all passed unanimous resolutions of support for this project. (4) I would like to know whether the going-concern disclosure was ever put in front of them, and whether anyone told them Michigan’s cleanup estimate was fourteen years old.

Routine in the mining sector and adequate for a $37.96 million cleanup obligation are two different standards.

Questions I’ve asked

To EGLE, still outstanding from last week: whether the triennial reclamation cost estimate updates required by Permit Condition F.6 have been filed, what the department’s current closure estimate is in today’s dollars, and what conditions remain before the mining permit becomes effective.

New, and I’ll be putting them to the county and township boards: were you shown Highland Copper’s financial disclosures before you voted on your resolutions of support? Were you told the state’s reclamation estimate dated from 2012?

I’ll publish the answers, including any that show I’ve gotten something wrong.

A note on how this was written

Everything above comes from documents anyone can read: Highland Copper’s condensed interim consolidated financial statements and management’s discussion and analysis for the period ended December 31, 2025, filed on SEDAR+ and posted on the company’s own website; the company’s press releases; and the Copperwood mining permit. I am one person in Gogebic County working from public records, with no fact-checking desk and no lawyer. Where I wasn’t certain, I said so.

If Highland Copper believes I have mischaracterized anything here, I will publish their response in full and correct the record. That invitation is open and standing.

Sources

1. Highland Copper Company Inc., Condensed Interim Consolidated Financial Statements for the three and six months ended December 31, 2025 (unaudited), Note 2 “Going Concern”; Statements of Financial Position; Note 5 “Loans and Borrowings”; Note 6 “Asset Retirement Obligation.” Approved by the Board of Directors February 19, 2026. Available at highlandcopper.com and on SEDAR+ (sedarplus.ca).

2. Highland Copper Company Inc., Management’s Discussion and Analysis for the three and six months ended December 31, 2025, sections “Proposed Transactions” and “Outlook.”

3. Highland Copper Company Inc. investor communications, June 2026: cash position and elimination of debt following the White Pine transaction. Market capitalization figure from published equity research coverage, 2026.

4. Highland Copper press release, January 27, 2026: “Highland Copper Recaps 2025 Execution and Announces 2026 Work Plan,” noting unanimous resolutions of support from Ironwood Township, Wakefield Township, Erwin Township, the Gogebic County Board of Commissioners, and the Gogebic County Road Commission.

This article contained an error in its central figure. The correction is set out here in full. The finding it replaces is stronger, not weaker.

The article treated the $6,479,089 surety disclosed in Highland Copper’s audited financial statements as financial assurance against closure and reclamation, and framed the story as a shortfall between that amount and a closure estimate of roughly $37 million. That was wrong.

In a records response on August 24, Melanie Humphrey, a mining specialist with the Geologic Resources Management Division of the Michigan Department of Environment, Great Lakes, and Energy, confirmed that the $6,479,089 consists of two surety bonds covering early site works. It is not closure assurance and was never intended to be.

The corrected picture is this. Special Condition N.1 of Nonferrous Metallic Mineral Mining Permit MP 01 2012 sets the closure and reclamation estimate for Copperwood at $37,960,000 — a figure this article previously reported as approximately $37 million on the authority of a law review article, and which is now confirmed directly from the state’s permit record. EGLE’s Geologic Resources Management Division has not received financial assurance in that amount. Because posting that assurance is a condition of the permit taking effect, the mining permit has been issued but is not yet effective.

The article asked whether the bond was large enough. The correct question is narrower: the closure bond has not been posted at all.

The reporters to whom the earlier version was sent were notified of this correction directly. The original text below is unaltered.

This article was originally published on August 14, 2026, under the title “Copperwood Mine: The $31 Million Hole in the Cleanup Fund.” The headline has been changed to reflect the corrected finding; the subtraction it described was based on the error corrected above.

— Don Dey, Editor

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In 2012, the State of Michigan put a price on cleaning up the Copperwood Mine.

Not the cost of building it. The cost of undoing it — tearing down the buildings, breaking out the concrete, capping the waste pond, flooding and sealing the tunnels, pumping contaminated water for years afterward, and watching the site for two decades after that. The cost the state would have to pay a contractor to do all of it, if the company that dug the hole couldn’t or wouldn’t.

number is written into the mining permit, exact to the dollar:

$37,960,000. (1)

Here is what the State of Michigan actually holds against it today:

$6,479,089. (2)

About seventeen cents on the dollar. And the $37,960,000 is a 2012 price — the permit says so in its own words, “as of the date this permit was issued.” (1) Anyone who has paid for a roof, a well, or a stretch of driveway since 2012 knows what has happened to that kind of money in fourteen years.

Let me say plainly what I am not claiming

I am not saying this mine will fail. I am not saying anyone has broken a law. I am not against copper, or jobs, or Wakefield finally getting a break. Highland Copper has done real work on that site already — roughly 18 acres of new wetland and some 20,000 native trees and plants, planted before a single ton of ore has been mined. (3) That deserves saying out loud.

This isn’t an argument about fish or vents or viewsheds. Other people are having that argument and they don’t need my help. This is an argument about arithmetic, and it’s aimed as much at people who want this mine as at people who don’t.

Because if the mine works, none of this money is ever spent. The bond gets released bit by bit as the company cleans up behind itself, and everybody goes home. This money only ever gets spent one way: the company stops, and the rest of us are holding the bag.

That’s what a cleanup bond is. It isn’t a fee. It isn’t a tax. It’s the insurance policy the public holds in case the whole thing goes sideways. Nobody buys insurance expecting the house to burn.

What the money has to cover

The permit spells it out. The fund must be enough to cover what it costs the state “to administer, and to hire a third party to implement” the reclamation — including cleaning up any contamination of the air, surface water, or groundwater that breaks the permit’s rules. (4)

Hire a third party. That phrase is the whole thing. It assumes the company isn’t there.

And the job is long. Under the permit, contaminated water gets pumped out of the tailings facility to a treatment plant for at least five years after mining stops. (5) The site gets monitored for twenty years after the state signs off on reclamation. (6) Somebody pays for those decades. The bond is the answer to who.

The number was supposed to be updated. I can’t find the updates.

The state knew a 2012 estimate wouldn’t hold. So the permit requires the company to file a fresh reclamation cost estimate with the state’s Upper Peninsula District Geologist on or before March 15 of every third year after the permit was issued. (7) A separate condition requires the company to periodically update the amount of financial assurance itself. (8)

On that schedule, updates were due in 2015, 2018, 2021, and 2024.

I have not been able to find them in the public file. I am asking the Department of Environment, Great Lakes, and Energy for them, and I will publish what comes back. If they exist and show a higher number, that’s important. If they exist and show the same number, that’s important too. If they don’t exist, that is the most important answer of the three.

What’s actually on deposit

The $6,479,089 is a surety bond — an insurance product, not cash in a vault. Highland Copper put up $2,267,680 behind it, about 35 percent. (2)

The paperwork was couriered to Lansing in July 2023 and accepted in about four business days. (9)

The amount also goes down as well as up. In late 2025, Highland got $240,188 back from that deposit as some site work was finished. (10)

And in the company’s own audited books, the amount formally set aside for reclamation is smaller still: $1,722,673, with the payments imagined 16 to 35 years in the future. (11)

One honest caveat: whether that $6.48 million is the mining permit’s financial assurance at a partial amount, or money posted under separate wetland and stream permits for early site work, isn’t clear from the public file. I am asking. I’ll publish whatever comes back.

A quarter of it never has to be money

This is the part I’d underline if I could underline one thing.

Michigan’s rules say that real financial instruments — a bond, a letter of credit, a trust, something the state can actually cash — have to cover at least 75 percent of the required amount.

The other 25 percent can be satisfied by something the rules call a “statement of financial responsibility.” (12)

That is a document. It is the company saying, on paper, that it is good for the money.

On a $37.96 million requirement, roughly $9.5 million can lawfully be a promise instead of a fund. Which raises a question worth asking out loud: whose promise, and backed by what?

Who gets paid first if it all goes wrong

Here’s the part that took me longest to understand, so let me put it the way I’d explain it across a kitchen table.

Imagine a man who owes the township money for a cleanup. Before that bill ever came due, he had already mortgaged his house and signed over everything he owns to a bank. When he goes under, the bank is first in line. The township gets whatever is left, which is usually nothing.

That’s roughly the position Michigan is in.

The permit is held by Copperwood Resources Inc., a Michigan company. It’s owned, through a chain, by Highland Copper Company — a small firm in Vancouver, traded on a junior stock exchange, that has never operated a mine and has no revenue. (13)

A Toronto financing company called Osisko already holds a mortgage on the Copperwood property, plus a claim on essentially everything Highland owns — including the shares of Copperwood Resources Inc. itself. (14) Not the copper. The company.

Highland is also working to turn a federal Export-Import Bank letter of interest, up to $250 million, into a construction loan. (15) That’s not signed yet. If it is signed, that lender gets secured too.

So if Highland fails, one and likely two sophisticated creditors stand ahead of the State of Michigan — holding claims on the very property and the very company that owe the cleanup. Michigan’s claim beyond the bond would be unsecured. Which is a formal way of saying: at the back of the line.

One more thing about “fully permitted”

Highland describes Copperwood as fully permitted. It’s worth knowing what’s still outstanding.

The tailings disposal facility — the dammed impoundment that would hold the mine’s waste for good — does not yet have its final dam safety permit. What exists is a preliminary approval, a “permit in concept,” extended more than once. (16) The mining permit itself bars construction of that facility until the state approves the final plans and specifications. (17)

That’s not a scandal. Projects get permitted in stages. But “fully permitted” and “the waste dam still needs its permit” are both being said about the same project, and only one of them is on a state document.

Three questions for the state

I am sending these to the Department of Environment, Great Lakes, and Energy today. I will publish the answers here, whatever they say — including any that show I’ve gotten something wrong.

1. Have the reclamation cost estimate updates required by Permit Condition F.6 been filed for 2015, 2018, 2021, and 2024 — and what is the department’s current closure cost estimate in today’s dollars?

2. Does the department intend to accept a statement of financial responsibility for any portion of Copperwood’s financial assurance, and if so, from which entity and on what financial statements?

3. What conditions remain outstanding before Mining Permit MP 01 2012 becomes effective?

If this mine is as solid as the people building it believe, then posting a full bond costs the company very little and costs the rest of us nothing. If the company can’t post a full bond, that tells you something too.

“Make them post a real bond” is not anti-mining. It’s anti-getting-stiffed.

A note on how this was written

I want to be straight with you about what this is and what it isn’t.

I am one person in Gogebic County working from public records. I am not a newsroom. There is no fact-checking desk behind me, no lawyer reading this before it posts, no editor telling me to hold it another week.

Everything above is written in good faith from documents anyone can pull up: the mining permit the State of Michigan issued in 2012, Michigan’s administrative rules, the state’s own mining permit files, and Highland Copper’s audited financial statements filed with securities regulators. Every number is footnoted to its source so you don’t have to take my word for any of it. Where I wasn’t sure, I said so in the text rather than smoothing it over.

I have questions out to the state that are not yet answered. Ordinarily I’d wait. I’m not waiting, because decisions about this project are being made right now — by regulators, by lawmakers, by the company’s board, and by people in this county who deserve to be asking about the money while it still matters. Publishing after the decisions are made is a different job than the one I’m trying to do.

So: this is my best effort with what I could gather as of publication. If the state’s answers change any of it, I will say so plainly, here, and I will not quietly edit the original. If you find an error, write to me and I’ll correct it and credit you.

That’s the deal.

The Lake Superior Register is written in Gogebic County, Michigan. Corrections welcome and will be published.

Sources

1. Nonferrous Metallic Mineral Mining Permit No. MP 01 2012, Special Permit Conditions, § N.1: “The total financial assurance estimated for the Copperwood Mine for reclamation costs at the closure stage of production is determined to be $37,960,000 as of the date this permit was issued.” Permit issued April 30, 2012, by the Michigan Department of Environmental Quality (now EGLE) to Orvana Resources US Corp; the subsidiary was later acquired by Highland Copper and renamed Copperwood Resources Inc.

2. Highland Copper Company Inc., Consolidated Financial Statements for the years ended June 30, 2025 and 2024: surety bond secured July 2023 as financial assurance for the Copperwood Project, valued at $6,479,089, with a cash deposit of $2,267,680 representing 35 percent. Available at highlandcopper.com, investor filings.

3. Highland Copper press release, January 27, 2026: 2025 concurrent reclamation, including approximately 18 acres of compensating wetlands and approximately 20,000 native trees and plants.

4. Mining Permit MP 01 2012, § N.1; Mich. Admin. Code R. 425.301(2). The rule requires the estimate to include, at minimum, reclamation; remediation of permit-violating contamination; administrative oversight; reasonable contingencies; and other necessary environmental protection measures.

5. Mining Permit MP 01 2012, Special Permit Conditions, § O.9.

6. Mining Permit MP 01 2012, Special Permit Conditions, § K.30: post-closure monitoring period of 20 years following completion and approval of reclamation.

7. Mining Permit MP 01 2012, General Permit Conditions, § F.6.

8. Mining Permit MP 01 2012, Special Permit Conditions, § N.2.

9. EGLE MiEnviro Portal, Copperwood site file (registration P0304): correspondence regarding financial assurance document shipment, July 26 – August 2, 2023.

10. Highland Copper Company Inc., Condensed Interim Consolidated Financial Statements for the periods ended December 31, 2025.

11. Highland Copper Company Inc., annual financial statements (June 30, 2025): asset retirement obligation, undiscounted cash flow of $1,722,673 for early-works reclamation and monitoring wells, payments modeled in years 16, 17, and 35 from construction start.

12. Mich. Admin. Code R. 425.301(3). In deciding how much of the balance may be met by a statement of financial responsibility, the department considers the operator’s ability to pay for potential remediation costs, whether it carries pollution or environmental liability insurance, and whether it holds third-party certification of an environmental management system.

13. Highland Copper Company Inc. trades on the TSX Venture Exchange (HI) and OTCQB (HDRSF), headquartered in Vancouver, British Columbia. Company filings at highlandcopper.com.

14. Highland Copper Company Inc., annual financial statements (June 30, 2024 and 2025), Osisko royalty notes: mortgage on the Copperwood property and general security agreement over company assets, including a pledge of the shares of Copperwood Resources Inc.

15. Highland Copper press release, September 2025: non-binding Letter of Interest from the Export-Import Bank of the United States for potential debt financing of up to US$250 million.

16. Part 315 dam safety permit status for the Copperwood tailings disposal facility, EGLE permit file. This is the one item in this article I am reporting from my own review of the state’s file rather than from a document I can link directly. I am asking EGLE to confirm the current status and will publish the answer.

17. Mining Permit MP 01 2012, Special Permit Conditions, § F.1: construction of the tailings disposal facility shall not begin until the permittee demonstrates the design is consistent with Rule 425.409 and receives approval of plans and specifications from the department.