---

Introduction & summary

1. This is a review of statements made by Bathurst Resources Ltd (Bathurst) regarding the lodgement of their Fast-track Approvals Act 2024 (FTAA) application for the Buller Plateaux Continuation Project (Project).
2. According to the most recent analysis by law firm ‘Dentons’, the average fast-track decision timeline is 159 working days. Even if Bathurst Resources altered their timeline and launched their application this week (8 May), the average decision timeline would take the application until 21 December 2026 – well past the general electionNB: This is a generous assessment. It does not take into account the complex nature of Bathurst’s Denniston/Buller application (the largest coal proposal in NZ history), and it does not take into account any legal delays (such as Judicial Reviews), which might delay the application further
3. Bathurst’s 30 April announcement that the application has not yet been made marks a significant departure from previous timeline expectations, although these have been inconsistent. For example, this document outlines that:
   • On 27 February, Bathurst’s Half Year Results presentation said the application would be submitted in FYQ4 (April 2026).
   • On 29 January, Bathurst’s December 2025 Quarterly Report stated the application was expected to be submitted in March 2026, with consent anticipated in FY27.
   • On 22 January, Bathurst’s Annual report previously said the project was expected to receive approval by June 2026. 
   • On 3 December 2025, Page 29 of the 3 December AGM meeting presentation says the application will be lodged in June 2025, with approval expected in the first half of 2026. This is consistent with Bathurst’s update on Resources and Reserves, released 31 October 2025, which states that approvals were expected to be granted in mid to late 2026.
4. This document outlines that:
   • Bathurst’s April 30 announcement marks a clear and significant delay in the company’s advised lodgement date
   • Bathurst’s timeline expectations and communications change regularly, and Bathurst occasionally provides a variety of inconsistent information and dates within the same document.Current timeline 
5. The most recent update (on page 7 of the March Quarterly Report) released by Bathurst is that the substantive application is expected to be lodged “this quarter” (ending June 30 2026)
6. The Report states that “significant progress” was made in the quarter, with all key technical information complete and reviewed as of 30 April 2026. However, consultation with regulators is still progressing, and the application has not been made before the end of either March or April, as previous reports advised.
   
7. This timeline (indicating no application by the end of April 2026) is inconsistent with page 26 of the Half Year Results presentation (released 27 February 2026), which states that the submission of the application will be made in FYQ4 (April). :
   
   Previous indications
8. The lodgement of the substantive application has been delayed several times, and the current timeline is not consistent with the previously stated expectations of Bathurst.December 2025 Quarterly Report – 29 January 2026
9. The December 2025 Quarterly Report stated that the application was expected to be submitted in March 2026, with consent anticipated in FY27:
   
   Annual Report 2025 – 22 January 2026
10. Bathurst’s 2025 Annual Report makes several statements about the anticipated lodgement of the Project.
11. At page 33, the Report states that the application will be prepared for a submission in the first half of FY26:
12. At page 10, the 2025 Annual Report stated that the permits were expected to be received by June 2026:
    
    
13. Elsewhere (e.g. pages 41, 67 and 69), the Report stated that preparation of the Project application is well underway and that Bathurst anticipates lodging the application with the panel in late 2025:
    
    Q1 FY2026 Results Update – 3 November 2025
14. Pg 24 of the Q1 FY2026 Results Update stated that the application would be submitted in Q3 FY2026:
    
15. However, the Update has included earlier, contradictory timeframe indications:
    
    2025 AGM – 3 December 2025
16. Page 29 of the 3 December AGM meeting presentation similarly retained old timeframes, which suggest the application will be lodged in June 2025 with approval expected in the first half of 2026. We can assume this was an error, given the presentation was given in December 2025.Q1 FY26 Results Update – 3 November 2025
    
17. Page 24 and 29 of the Q1 FY26 Results Update stated that the application would be made in FY26 Q3:
    
    Update on Resources and Reserves – 31 October 2025
18. The Update stated that approvals were expected to be granted in mid to late 2026:
    
    Material Change Report – 31 October 2025
19. Section 2 ‘Reporting of Exploration Results’ of The Material Change Report stated that Bathurst intended to submit the application in late 2025:
    
    September Quarterly Report – 28 October 2025 
20. Page 7 of the September Quarterly Report said that the application was expected to be submitted by the end of 2025, with consents expected in FY26:
    
    Bathurst Resources FY2025 Results Update – 29 August 2025 
21. Page 22 of the FY2025 Results Update (released on 29 August 2025) states that Bathurst aimed to submit its application in June 2025, with an outcome expected in January 2026:
    
22. A more detailed timeline is presented on pages 24-25:
    
    
    June 2025 Quarterly Report – 29 July 2025 
23. The June 2025 Quarterly Report said the application would be submitted by the end of 2025:
    
    Conservation Board presentation – 12 June 2025
24. On 12 June 2025, a conservation board presentation said the targeted date for lodgement was November 2025:
    
    Q3 FY25 Results Update – 2 May 2025
25. Page 19 of the Results Update stated that the application would be submitted in the September Quarter of CY25:
    
    March 2025 Quarterly Report – 30 April 2025 
26. The March 2025 Quarterly Report stated that the Application was expected to be submitted by 30 June 2025: