The Honorable Doug Burgum
Secretary
United States Department of the Interior
1849 C Street, N.W. Washington, DC 20240
Dear Secretary Burgum:
I write from the Copper Development Association (CDA), the North American based not-forprofit association of the copper industry, bringing together the North American copper and copper alloy semis fabricators and global copper mining and production industries, to bring awareness to the increased need for copper to be recognized as a critical mineral.
CDA requests your assistance to exercise your statutory authority under section 7002(c)(4)(B) of the Energy Act of 2020 to immediately designate copper as an official Critical Mineral by the United States Geological Survey (USGS). Waiting for the 2025 list to be released later this year further delays support for this critical industry. Copper is inextricably linked to America’s most pressing policy objectives, particularly national security, energy dominance and global A.I. leadership. From powering data centers, augmenting energy supplies and enabling advanced technology vital to the defense industrial base, copper and the domestic copper industry are strategic assets to our national security, geopolitical standing, and economic interests.
When the 2022 USGS Critical Minerals list was released, CDA filed detailed comments citing our concerns with copper not being on the list. One of our primary concerns was that USGS was relying on data only through 2018, even as copper’s supply risk was already rising at that point. We followed up later with a consultant study, based on USGS’s own methodology, updating copper’s supply risk score through 2022 data. That study noted copper’s four-year weighted average was at .407 – above the .40 threshold for inclusion. CDA, Members of Congress, and others (including yourself as Governor of North Dakota) asked then-Secretary Haaland to immediately add copper to the list. Unfortunately, USGS declined an “out of cycle” addition of copper to the list at that time.
Regrettably, the situation has grown worse as imports continue to grow. Given these trends, we have updated copper’s supply risk score with the most recent data available. Net import reliance has grown from 29.6% in 2016 to 41.2% in 2023 and is projected to grow to 60% in 2035 without new domestic production. China, Russia and Iran accounted for 52% of all nonUS global refined copper production in 2023, up from 42% in 2016.
These trends are the reason copper’s supply risk score has skyrocketed to .488 in 2023, with a four-year weighted average of .456 – even further above the 2022 threshold. The referenced study is attached to this letter and can also be downloaded online and viewed at www.copperiscritical.org. Given the massive increases in copper’s supply risk score, we strongly urge that you include copper on the USGS Critical Minerals list without delay.
Thank you for your consideration of this request. Copper’s major role in our local economies and national economic development, national security, and infrastructure, necessitates that you immediately include copper on the USGS list of “critical minerals” to ensure a secure and reliable supply of domestic copper resources in the years to come.
Regards,
ADAM ESTELLE
President & CEO
Note: This press release is available as a PDF document. Download the original PDF.