ICYMI: Manchin, Bipartisan Colleagues Urge Administration to Revisit Copper for Listing as a Critical Mineral

Washington, DC –  U.S. Senators Joe Manchin (D-WV), Chairman of the Senate Energy and Natural Resources Committee, Kyrsten Sinema (I-AZ), Mark Kelly (D-AZ), Mike Braun (R-IN), Raphael Warnock (D-GA), and Mitt Romney (R-UT) wrote a letter to U.S. Department of the Interior Secretary Deb Haaland urging the Secretary to reconsider adding copper as an official U.S. Geological Survey Critical Mineral. Recognizing copper — a mineral vital to our energy and national security — as a critical mineral would signal the need for the U.S. to increase investment in domestic production and ensure a secure and reliable supply of copper resources. 

The Senators said in part, “By recognizing copper as a ‘critical mineral,’ the United States’ federal government can more effectively ensure a secure and reliable supply of domestic copper resources in the years to come at all points of the supply chain including recycling, mining, and processing. Given the enormous investment required, the time lag for new sources of supply, and projected demand, time is of the essence.”

Dear Madam Secretary: 

On behalf of the undersigned bipartisan group of Senators, we write to urge you to revisit and consider the designation of copper as a critical mineral in accordance with the Mineral Security provisions of the Energy Act of 20201. While we believe that copper has always been key to our national security, water infrastructure, and electrical and clean energy infrastructure, you found that copper did not meet the United States Geological Survey’s requirements for designation as a critical mineral. However, recent economic and geopolitical events, such as the war in Ukraine, present a significant increase in the supply risk. 

Looking ahead to the near future, according to a recent S&P Global report2, “the chronic gap between worldwide copper supply and demand projected to begin in the middle of this decade will have serious consequences across the global economy and will affect the timing of Net-Zero Emissions by 2050”. With regard to global stability and national security the report found that “copper scarcity may emerge as a key destabilizing threat to international security” and “projected annual shortfalls will place unprecedented strain on supply chains”. The global situation has changed since the draft list was prepared in 2021, and we now have better data on future supply and demand projections – all of which has made reconsideration of copper for inclusion on the critical mineral list a necessity. 

With the United States Geological Survey’s release of the draft 2021 list, a new quantitative methodology was created to calculate a supply risk score that closely examines the economic vulnerability, disruption potential, and trade exposure of various minerals. Unfortunately, as noted in the methodology3, when USGS calculated the score the selected data set was only updated through 2018. Since 2018, the risks of disruption to global copper supplies, particularly from adversarial countries like China and Russia, have only increased. In addition, the share of copper consumption that is met by net imports has increased from 33% in 2018 to 44% in 2021 and 41% in 2022. According to trade data from USGS4, in the first half of 2022, the net import reliance stood at 48%. In 2021 Russia, China, Iran and North Korea now account for half of all non-U.S. global refined copper production. 

Recently, a third party hired an analyst to calculate an updated copper supply risk score with the most recently available data through the first half of 2022.5 With the new data, copper’s supply risk score in 2022 is up to 0.423 and the 4-year weighted average score is now up to 0.407 – both above the USGS 0.40 threshold for automatic inclusion on the list. We have attached the study and calculations to this letter. 

Given the significant change in the supply risk to copper, the other critical minerals produced as byproducts, and the growing importance of copper to our economic and national security, we urge you to exercise the authority given to you by statute to revisit your determination and reconsider the addition of copper to the critical minerals list, without waiting the maximum of 3 years allowed by law between revisions of the list. Earlier this year, USGS made this commitment, writing that “if the criticality status of a mineral commodity were to change significantly in the near term, the USGS would publish information on the changed circumstances without waiting for a 3-year update cycle.”6 Clearly, a dramatic rise in the supply risk score is such an incident that requires attention. 

In fact, with regard to helium, this week the USGS announced7 just such a review to determine if there is an increased risk of supply disruption. The same should be done for copper. 

If copper is found to meet the criteria, and we believe it will, designation will significantly benefit and protect the United States as we continue to substantially invest in a variety of copper intensive applications. By recognizing copper as a “critical mineral,” the United States’ federal government can more effectively ensure a secure and reliable supply of domestic copper resources in the years to come at all points of the supply chain including recycling, mining, and processing. Given the enormous investment required, the time lag for new sources of supply, and projected demand, time is of the essence.