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ARPN’s Daniel McGroarty Submits Public Comments on DoI Critical Minerals List

Presidential Executive Order (EO) 13817 on a Federal Strategy to Ensure Secure and Reliable Supplies of Critical Minerals, was issued on December 20, 2017. Pursuant to the EO, the Department of Interior, in coordination with the Department of Defense, was tasked with compiling a list of Critical Minerals within 60 days. The DOI List was published on February 16, 2018, with a public comment period running through March 19, 2018.

ARPN’s Daniel McGroarty filed two sets of comments, the first identifying a group of “gateway” metals critical for defense applications but absent from the DOI List, and the second articulating the gateway/co-product relationships between metals and minerals on the DOI List. The articulation exercise revealed four metals and minerals absent from the DOI List which are gateways to minerals that are on the List.

The DOI list as published on February 16, 2018, includes the following 35 minerals:

  • Aluminum (bauxite), used in almost all sectors of the economy
  • Antimony, used in batteries and flame retardants
  • Arsenic, used in lumber preservatives, pesticides, and semi-conductors
  • Barite, used in cement and petroleum industries
  • Beryllium, used as an alloying agent in aerospace and defense industries
  • Bismuth, used in medical and atomic research
  • Cesium, used in research and development
  • Chromium, used primarily in stainless steel and other alloys
  • Cobalt, used in rechargeable batteries and superalloys
  • Fluorspar, used in the manufacture of aluminum, gasoline, and uranium fuel
  • Gallium, used for integrated circuits and optical devices like LEDs
  • Germanium, used for fiber optics and night vision applications
  • Graphite (natural), used for lubricants, batteries, and fuel cells
  • Hafnium, used for nuclear control rods, alloys, and high-temperature ceramics
  • Helium, used for MRIs, lifting agent, and research
  • Indium, mostly used in LCD screens
  • Lithium, used primarily for batteries
  • Magnesium, used in furnace linings for manufacturing steel and ceramics
  • Manganese, used in steelmaking
  • Niobium, used mostly in steel alloys
  • Platinum group metals, used for catalytic agents
  • Potash, primarily used as a fertilizer
  • Rare earth elements group, primarily used in batteries and electronics
  • Rhenium, used for lead-free gasoline and superalloys
  • Rubidium, used for research and development in electronics
  • Scandium, used for alloys and fuel cells
  • Strontium, used for pyrotechnics and ceramic magnets
  • Tantalum, used in electronic components, mostly capacitors
  • Tellurium, used in steelmaking and solar cells
  • Tin, used as protective coatings and alloys for steel
  • Titanium, overwhelmingly used as a white pigment or metal alloys
  • Tungsten, primarily used to make wear-resistant metals
  • Uranium, mostly used for nuclear fuel
  • Vanadium, primarily used for titanium alloys
  • Zirconium, used in the high-temperature ceramics industries

Daniel McGroarty: Public Comment DOI-2018-0001-0126 posted on March 6, 2018 concerning Secretary Zinke’s Draft Critical Minerals list

I want to commend the Department of Interior for its work to establish a unified Critical Minerals List (the “DOI List”), and to open the list for comment. Any list is a moment-in-time exercise, based on many factors, not least of which are technology development and industrial demand, which without question contribute to our evolving understanding of what is and is not a critical mineral or metal.I have testified on critical minerals before various House and Senate committees, I serve on the advisory boards of several U.S. companies developing critical minerals and metals projects, both mining and reclamation/recycling, and I am founder of the American Resource Policy Network, a virtual think-tank that educates and informs on resource dependencies and their impacts.

I offer here four additional metals, in rank order, that I believe merit inclusion on the DOI List, largely from a national security perspective.

From a national security perspective, the single best unclassified source for metals and minerals dependency assessments remains the Reconfiguration of the National Defense Stockpile Report to Congress (2009) and its appendices, which offer a rare view into defense scenarios which may be adversely impacted by lack of timely access to critical metals and minerals. While these studies are nearly a decade old, most of the weapons platforms dependent on critical metals/minerals remain in service today, and in many instances, U.S. foreign supply dependencies have only grown more acute.Many of the DOI List metals/minerals figure repeatedly in the Reconfiguration Report. Detailed here are several additional metals and minerals that are not on the DOI List, and should be added, based on relevant defense criteria.Cause of Significant Weapons System Delay. Appendix C of the Reconfiguration Report, Table 1, lists a declassified study, based on classified scenarios, that indicates that lack of access to various metals and minerals has “already caused some kind of significant weapon system production delay for DoD.”

Of the 21 metals/minerals found to have caused a significant delay, 16 are on the Department of Interior List; 5 are not:

  • Copper
  • Molybdenum
  • Zinc
  • Nickel
  • Cadmium

Shortfall Scenarios. Appendix C of the Report, Table 1, lists a declassified study, based on classified scenarios, that assesses the likelihood of a shortfall of various metals and minerals during 1) a National Security Emergency, and 2) a Peacetime Supply Disruption scenario. Of the 25 metals/minerals found to be in shortfall during a National Security Emergency or Peacetime Supply Disruption, 17 are on the DOI List, while 8 are not:

  • Copper
  • Zinc
  • Quartz
  • Lead
  • Mercury
  • Nickel
  • Silicon carbide
  • Silver

Defense Use by Volume. Appendix B of the Report, Table ES-1, lists DoD defense materials, usage by volume. 6 of the Top 10 materials in the table are included on the DOI List; 4 are not:

  • Copper
  • Lead
  • Zinc
  • Nickel

Three metals are present in each of these snapshots: Copper, Zinc and Nickel, while Lead appears twice.The first three are also the primary “gateway” to co-product metals/minerals not typically mined in their own right. Copper is the practical access point to at least 4 minerals on the DOI List (Cobalt, Rhenium, Tellurium and potentially the Rare Earths [100% dependency]). Zinc is the gateway to DOI Listed minerals Indium, Gallium (100% dependencies) and Germanium, while Nickel is gateway to Cobalt and the Platinum Group Metals. Lead is gateway to Antimony, Bismuth and Tellurium.Gateway/Co-Product issues have a significant impact on the DOI List.To cite just one example, such is the dependence of cobalt, for instance, on copper and nickel mining, according to a February 2018 report by the Columbia (University) Center on Sustainable Investment:

“…The survival of a cobalt project therefore largely depends on nickel and copper prices. If the prices of these two metals are unfavorable, then it is highly unlikely that a mining project will undergo development, regardless of how high cobalt prices are.”

Recommended Expansion of the DOI List:For these reasons, I recommend that the DOI Critical Minerals List be expanded to include, in this rank order:

  1. Copper
  2. Zinc
  3. Nickel
  4. Lead

I would be pleased to provide additional detail upon request.# # #

Daniel McGroarty: Public Comment DOI-2018-0001-0303 posted on March 14, 2018
Primary Minerals, Gateways & Co-Products – Articulated Chart of DOI’s 35 Critical Minerals

***Supplementing Public Comment DOI-2018-0001-0126 posted on March 6, 2018

The DOI Critical Minerals List (released Feb. 16, 2018) contains 35 minerals/metals. What the alphabetized list does not convey are the relationships of the various metals/minerals – most importantly, the fact that, as a practical matter, many of the metals/minerals are not mined in their own right, but obtained as “co-products” of primary metal mining.

The attached chart articulates the 35 metals and minerals into Primary and/or “Gateway” Minerals and Co-Product minerals, indicating which Primaries are typically “gateways” to DOI Listed co-products.

Two additional categories are depicted:

• “Hybrids” (metals/minerals that, depending on the deposit, are primary mining products or co-products of other metals/minerals)

• “Recovered” (3 of the 35 DOI Listed minerals, that are neither mined nor co-products of primary mining, but recovered by individualized processes)

Working back from the Listed Co-Products to their “gateway” metals/minerals indicates that there are 4 “gateway” metals/minerals that are not on the DOI List:

Copper, Gold, Nickel and Zinc (see comment below)

I offer to the DOI review team several observations based on the chart:

Encouraging Co-Product Production is Key to Meeting Strategic/Critical Mineral Needs.

As is shown, 13 of the 35 DOI Listed minerals are Co-Products – more than 1/3 of the entire List – essentially only accessible via primary mining of other metals/minerals.

Important Metals/Minerals are Missing from the DOI List.

A depiction of Gateway/Co-Product relationships shows that 4 metals/minerals missing from the DOI List — Copper, Gold, Nickel, Zinc – access 7 unique minerals that are deemed Critical.

Copper is Gateway to Critical Co-Products.

Of the Gateway metals/minerals, Copper is the most “versatile” – with 5 potential Co-products on the List.

# # #

For a full size pdf version of the chart click here.