A Path Forward

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Unfortunately, half of the known critical mineral deposits in the U.S. are within trout and salmon habitat, and one in ten deposits are in protected public land areas like wilderness, Forest Service roadless areas and wilderness study areas. Many other critical mineral deposits overlap with sensitive sage grouse habitat and big game migration corridors. While developing more critical minerals domestically – thus reducing our dependence on vulnerable supply chains – is important to our future, we cannot put at risk some of the country’s most pristine natural areas in the process.

As a nation, we cannot solely mine our way out of supply chain challenges. Meeting those challenges without needlessly sacrificing some of our most precious natural areas requires a responsible, strategic approach. We need to reduce demand, recycle, and mine carefully. Such an approach will allow us to meet our critical mineral needs without compromising fish and wildlife habitat and the billions of dollars of economic activity generated by hunting, fishing, and outdoor recreation. When utilized in technologies that help reduce fossil fuel use, some critical minerals can also help address climate change and associated impacts on fish and wildlife.

By implementing holistic policies that create public transparency in planning processes and incorporate the best available science, we can create stronger natural resource management practices that safeguard sensitive fish and wildlife habitat and ensure the future of our hunting and fishing traditions and the growing outdoor recreation economy. The following tenets for exploration and extraction of critical minerals ensure that these natural resource values are given due consideration when developing policy and evaluating mine proposals.

Tenets for Responsible Critical Mineral Development

  • Before seeking new sources of raw materials, prioritize and fully utilize alternatives, such as recycling, substitutes to critical minerals, reprocessing old mine waste piles and ash material, and engineering advancements to reduce use and need for new mines.
  • Evaluate critical mineral mine site proposals on public land through transparent, effective and predictable public processes – ones that include public land users, affected communities and indigenous tribes, as well as appropriate state and local governments and other stakeholders.
  • Avoid and minimize critical mineral development impacts to important fish and wildlife habitat, including focusing operations on landscapes that already have established infrastructure.
  • Encourage federal and state policies that support responsible critical minerals mining and avoid impacts to special places, recreational assets and high quality fish and wildlife habitat. Where impacts are unavoidable, effects must be mitigated including through the use of compensatory mitigation.
  • Ensure that environmental safeguards, such as the National Environmental Policy Act and current public land protections, are not circumvented, repealed or weakened for the purposes of developing critical minerals.
  • Utilize the best available science to map critical mineral resources, identify key fish and wildlife habitat, and develop avoidance and mitigation strategies.
  • Where critical minerals are a byproduct of other mining objectives, enforce all applicable laws – including those that govern non-critical minerals – to ensure uniformity of policy.
  • To be considered “critical,” minerals should be subject to import vulnerability, not just import reliance. Supplies from some allies may be part of secure supply chains, even if those minerals are imported.
  • Some places are simply too special or sensitive to mine. Where other values are deemed more important and risks too high, critical mineral mine proposals should not be approved.
  • Allocate a portion of the revenues generated from mineral development on public lands, including critical minerals, to offset expenses for mitigation and abandoned mine reclamation.
  • Develop new policies in formalized collaboration with all affected stakeholders, including hunters and anglers, tribes, outdoor recreation interests, labor, manufacturers and the mining industry.
  • Seek to build enduring trust, transparency, and partnership with all stakeholders and impacted communities, which should result in more responsible mining projects, and reduced community opposition.

As a country, we need to realize that an analysis of the impacts of mining must look at the entire lifecycle of a mine, from extraction to processing to end-of-life options. Too many parts of the U.S. are polluted by poorly-planned, hastily-built, ultimately-abandoned mines. It is estimated that there are upwards of 500,000 abandoned mines in the western United States and cleanup of these sites could cost taxpayers up to $54 billion. We cannot let this current demand for critical minerals add to this problem. We also need to recognize that it would be irresponsible to try and mine our way out of these supply chain concerns and that other options, like recycling, must be considered. At present, we ship most of our collected lithium-ion batteries for recycling to China, South Korea and Europe (Robert Kang testimony – Senate ENR 9-17-2019). Increasing U.S. processing capacity for recycling will allow better control of these metals earlier in the supply chain. Recycling is but one solution to the supply chain challenge. Priority should be placed on policies designed to stimulate the recycling industry in the U.S. 

If implemented, these tenets will help prevent unnecessary environmental, social and economic harm as the nation strives to satisfy its critical minerals needs. To this end, we intend to work with a diverse group of partners to translate these tenets into specific state and federal policy recommendations.