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Grand Canyon Rainbow from Pima Point NPS Photo by Michael Quinn

If a mineral is “critical” then export should not be allowed. Crooks within government and without say national security, national security for oil and gas, and uranium, but then export some of it.

Draft List of Critical Minerals Comment Deadline is Mar 19, 2018 11:59 PM ET (US Eastern Time – presumably daylight savings time so it should say EDT, late Monday night)
Docket ID: DOI-2018-0001 Agency: Department of the Interior (DOI)
Comment can be anonymous. Comment here: https://www.regulations.gov/docket?D=DOI-2018-0001

How did uranium sneak into the list? Honeywell PAC campaign donations to Zinke? Honeywell does the uranium fuel conversion, the step before enrichment.
Ryan Zinke Open Secrets – Honeywell PAC donations: https://www.opensecrets.org/members-of-congress/summary?cid=N00035616&cycle=2016&type=C

Trump’s executive order “Presidential Executive Order on a Federal Strategy to Ensure Secure and Reliable Supplies of Critical Minerals“, December 20, 2017, actually has a couple of good points:
(i) a strategy to reduce the Nation’s reliance on critical minerals;
(ii) an assessment of progress toward developing critical minerals recycling and reprocessing technologies, and technological alternatives to critical minerals;….


A comment, found further below, points out the need for radiation monitoring recycled metals-imported steel.

Alternatives include innovations such as conductive plastics. Innovation, in conjunction with recycling and zero population growth, would allow the land, water, and trees to be saved from the devastation of mining. Zero population growth means just that – immigration should only be allowed if people leave (emigration) or if birth rate is below replacement. The US is a colonial settler state and the environment has been destroyed in record time. The environment was pristine and virtually undamaged under Native American care. See especially 1872 mining law, below.

Uranium is a fuel mineral. It is neither a “non-fuel mineral” nor a “mineral material”:
Mineral materials include common varieties of sand, stone, gravel, pumice, pumicite, clay, rock, and petrified wood.” https://www.blm.gov/sites/blm.gov/files/Brochure_How%20to%20Obtain%20Minerals.pdf

Critical Mineral Resources of the United States— Economic and Environmental Geology and Prospects for Future Supplyhttps://pubs.usgs.gov/pp/1802/pp1802_entirebook.pdf

Sec. 2.  Definition.  (a)  A “critical mineral” is a mineral identified by the Secretary of the Interior pursuant to subsection (b) of this section to be (i) a non-fuel mineral or mineral material essential to the economic and national security of the United States, (ii) the supply chain of which is vulnerable to disruption, and (iii) that serves an essential function in the manufacturing of a product, the absence of which would have significant consequences for our economy or our national security.https://web.archive.org/web/20171222124553/https://www.whitehouse.gov/presidential-actions/presidential-executive-order-federal-strategy-ensure-secure-reliable-supplies-critical-minerals/

One comment already submitted:
1. Uranium is not a “non-fuel mineral or mineral material.” Given the administration’s definition of a critical mineral as a “non-fuel mineral or mineral material,” it’s odd that uranium is on the list. That’s because, historically, uranium has been treated as a “fuel mineral.” The background document prepared by USGS to support the draft list even describes the value of uranium as lying in energy production. It’s not even on the U.S. Geological Survey’s current list of non-fuel minerals. “Mineral materials,” by definition, are things like sand, gravel, and rock and also don’t include uranium.

2. Access to uranium resources hardly needs “streamlining.” The administration intends “to streamline permitting and review processes related to developing leases; enhancing access to critical mineral resources; and increasing discovery, production, and domestic refining of critical minerals.”

But the Mining Law of 1872, which governs uranium extraction, is perhaps one of the least restrictive regulations on the books. It was implemented 146 years ago, under President Ulysses S. Grant, in order to promote development of the American West. The law allows private mining companies, with questionable environmental oversight, to take billions of dollars of locatable minerals (including uranium) from public lands without paying a single cent in royalties to taxpayers. Federal agencies see the mining law as so permissive that, without the mining ban around the Grand Canyon (which withdrew the area from claims location under the Mining Law of 1872), regulators are likely despite the known risks to approve mining activities in the region.

And if we want to know what happens if the environmental regulations available today are stripped away, we need look no further than the Navajo Nation, where over 500 toxic, abandoned uranium mines still remain, impacting families and the environment. These mines are remnants of the 1950s Atomic Era the last time the U.S. government propped up uranium mining, and for which the U.S. government is so far on the hook for nearly a billion dollars in liability. See comment here: https://www.regulations.gov/document?D=DOI-2018-0001-0171 (Emphasis our own.)

Another comment:
I urge you to remove Uranium from the List of Critical Minerals. Uranium is not a “non-fuel mineral or mineral material,” and therefore has no business being on the list in the first place.

Uranium mining also has dire consequences for the environment. Let’s take the example of the “Navajo Nation, where over 500 toxic, abandoned uranium mines still remain, impacting families and the environment. These mines are remnants of the 1950s Atomic Era the last time the U.S. government propped up uranium mining, and for which the U.S. government is so far on the hook for nearly a billion dollars in liability.” (Grand Canyon Trust, 2018 https://www.grandcanyontrust.org/blog/trump-administration-gives-boost-uranium-companies)

Give the West a break. The attitude of this department not just to the Uranium mining issue but to many other western causes has been to line the pockets of the oligopoly and to ignore the wishes and the will of the People. Some things can never be undone, and poisoning America’s vast and beautiful wilderness will have lasting and potentially devastating effects for generations to come.https://www.regulations.gov/document?D=DOI-2018-0001-0133

This comment points out the need for checking imported steel-recycled metals for radiation contamination:

Radioactive import steel should be concern of national regulatory authorities. strengthen the mechanism adopted for certifying radioactivity free steel materials that is import to USA. Harmonized level of standards for acceptance of contamination in steel products should be developed . radioactive contamination in steel would be anything showing radiation level above natural background radiation level, and above the exempt (activity concentration and total activity) level of IAEA. Main radioisotope of contamination is Co-60 of industrial use. Metals identified contaminated are rods, flanges, valves, door pull handles, man hole covers, nails, coils, bright bars, billets etc. the growing global threat of contaminated scrap metal. The major risk America import of steel face in our industry is radiation in steel scrap.

Wind turbine imported steel, should be inspected for Radiation , many birds have been found dead around windfarms, each turbine contains more than 8,000 different components, steel, cast iron, and concrete. magnets made from neodymium and dysprosium, rare earth minerals mined almost exclusively in China.

2003 to 2008 ; Work tools such as hammers and screwdrivers, were denied U.S. entry after customs and the Department of Homeland Security boosted radiation monitoring at borders.

Steel, iron, Cobalt, Rare Earth Elements ( REF) and lithium and should be added to the 3TG conflict minerals law, 2010 Dodd-Frank Wall Street Reform and Consumer Protection Act Title XV: Miscellaneous Provisions – Section 1502 Conflict Minerals (P.L.111-203) as well as US tariffs ; Section 232 under the authority of the Trade Expansion Act of 1962. the United States companies materially injured by reason of imports of materials, by reason of unfairly traded imports . Countries that mine and manufacture lack of visibility down the supply chain that leaves companies exposed to the breadth of social and environmental issues .

In 2009 report shows Germany got 150 tons of steel items imported from India which were contaminated with radioactivity, a leading newsmagazine said. 1998, 430,000 pounds of steel laced with Cobalt-60 made it to the US heartland from Brazil.

United States has no regulations specifying what level of radioactive contamination is too much in raw materials and finished goods. Mandatory radiation monitoring of the incoming raw material and finished products in the steel factories using scrap metal as input material should be introduced through suitable national legislation. US and state governments do not require scrap yards, recyclers and other businesses to screen metal goods and materials for radiation or report it when found. Federal agency is responsible for oversight of manufacturers and dealers from countries are exporting contaminated material and goods,

Radioactively contaminated scrap threatens both human and wildlife health and environment.

Report showed China-made grater bearing in a brand name was laced with the isotope Cobalt-60. Flint, Mich., scrap plant discovered a beat-up kitchen cheese grater that was radioactive.

Brazil 1998 import to America, Cobalt-60 tainted a 430,000-pound shipment of metal. Part of that load found its way to Michigan and then Indiana, where it was used to make brackets for chairs.

India radioactive metal found to be used by a Connecticut company.
Mexico: Construction reinforcement materials from Mexico laced with Cobalt-60 that were detected at the border in 2006.

US Government Accountability Office, which put the number of radioactively contaminated metal objects unaccounted for in the United States in 2005 at 500,000.
Others suggest the amount is far higher.

2015 China in South America Mining Ecuadorian Foreign Minister Ricardo Patio stated at the close of the third summit of the Community of Latin American and Caribbean States (CELAC) in Costa Rica 2015. Said The United States is no longer our privileged partner, now the privileged partner is China. ,

Larger electric vehicles with steel Cobalt and Lithium can have higher lifecycle greenhouse gas emissions than smaller conventional vehicles.” MIT data substantiate a study from the Norwegian University of Science and Technology .” Emphasis added. Original comment here: https://www.regulations.gov/document?D=DOI-2018-0001-0060

Streamlining increases environmental risk:
(b)  increasing activity at all levels of the supply chain, including exploration, mining, concentration, separation, alloying, recycling, and reprocessing critical minerals;(c)  ensuring that our miners and producers have electronic access to the most advanced topographic, geologic, and geophysical data within U.S. territory to the extent permitted by law and subject to appropriate limitations for purposes of privacy and security, including appropriate limitations to protect critical infrastructure data such as those related to national security areas; and
(d)  streamlining leasing and permitting processes to expedite exploration, production, processing, reprocessing, recycling, and domestic refining of critical minerals.