Public Comment of Daniel McGroarty : Critical Minerals List

While I commend USGS for expanding the 2021 Critical Minerals List from the 2018 “generic” or category references to Rare Earth Elements and Platinum Group Metals, given the widely varying and rapidly developing uses of individual Rare Earths and PGMs, as well as the inclusion of nickel and zinc on the 2021 Critical List, I focus my comment on the need to develop a protocol for de-Listing Critical. [...] While USGS notes in its methodology that criticality should be viewed as a “continuum1” and not as a sharp either/or designation, the Critical List’s value as a market signal to private sector minerals and metals developers and private capital warrants careful attention to the way in which minerals and metals are dropped from the List equal to the attention given those added to it. [...] But in the case of three of the de-Listed Criticals – rhenium, strontium and potash -- each of which fall fractionally below the USGS methodological cut-off, no such shift has taken place from 2018 to 2021.1 Rhenium import-dependency in the year prior to the promulgation of the 2018 Critical Minerals List was 81%; it was 76% in 2020 – during COVID’s first wave and the broad shutdown of the nationa. [...] Without such a watch list, the prospect of minerals and metals near the cutoff moving on and off the Critical List over 3-year periods undercuts the value of a consistent signal to private industry that these materials matter, and warrant the application of capital – both intellectual and financial – to develop new ways to extract, recycle and reclaim them. [...] Part of the challenge in making the connection between Critical Minerals and the applications they enable is a perception that what have long been called the “minor metals” are of marginal importance.