Earlier this year, the U.S. Department of Energy moved to classify metallurgical coal (the type used for steelmaking) as a “critical” material for America’s supply chain. ABRA and a coalition of allied groups are pushing back, arguing that this designation is both legally improper and unsupported by the facts.
In joint comments to DOE, we pointed out that metallurgical coal simply does not meet the statutory definition of a critical material. By law, a “critical” mineral must be a non-fuel resource with a high risk of supply disruption – and metallurgical coal meets neither condition. First, coal is fundamentally a fuel. Even when it’s used to make steel, it can still be burned for energy, which means it fails the law’s “non-fuel” requirement. That alone should bar it from the critical minerals list. Second, there’s no sign of a supply shortage. The U.S. has stable access to plenty of met coal, with significant domestic production and secure trade partners. In reality, America is a net exporter of metallurgical coal, producing tens of millions of tons more than we use. Over the past decade the U.S. exported 40–60 million tons of met coal each year while importing less than 1.7 million tons. These are hardly the characteristics of a resource in short supply or vulnerable to foreign disruption. DOE’s own data showed no genuine supply risk or import reliance that would justify labeling met coal “critical.”
So why push to call it critical? The move appears to be a politically driven bid to prop up a declining coal industry rather than a response to any real need. In fact, DOE’s report frankly admitted that current law doesn’t support the designation and tried to lean on a “strategic goal” of boosting steel output as a backdoor justification. But giving metallurgical coal a special status under the guise of national security is dangerously short-sighted. U.S. steelmaking is already moving beyond coal: about 70% of our steel is produced in electric arc furnaces that use little or no coal, a share that’s rising every year. New cleaner technologies—like hydrogen-based iron reduction and other coal-free steel processes—are on the horizon. Meanwhile, Appalachian communities have borne the brunt of coal mining’s pollution and boom-bust economics for generations. Declaring met coal “critical” would only double down on coal’s destructive legacy, instead of investing in a just transition that builds sustainable jobs and healthier communities. ABRA will continue to advocate for fact-based, forward-looking energy policies—because propping up coal under a false “critical mineral” label is a step in the wrong direction.
Public Citizen Press Release