Policy Archives | 麻豆直播 & Lardner LLP Legal services in Boston, Massachusetts Tue, 21 Apr 2026 21:04:14 +0000 en-US hourly 1 https://wordpress.org/?v=7.0.4 /wp-content/uploads/2024/11/cropped-麻豆直播-Favicon-1-32x32.png Policy Archives | 麻豆直播 & Lardner LLP 32 32 Trump Administration and Export-Import Bank Establish a $12B U.S. Strategic Critical Minerals Reserve: Five Things Critical Mineral Mining Companies Need to Know Now /p/102mi2h/trump-administration-and-export-import-bank-establish-a-12b-u-s-strategic-criti/ Wed, 11 Feb 2026 15:28:39 +0000 /p/102mi2h/trump-administration-and-export-import-bank-establish-a-12b-u-s-strategic-criti/ On February 2, 2026, the Export-Import Bank of the United States (EXIM) and the聽Trump Administration announced Project Vault, a $12...

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On February 2, 2026, the Export-Import Bank of the United States (EXIM) and the  Project Vault, a $12 billion initiative establishing the . This independently governed public-private partnership will store essential raw materials in facilities across the United States to protect against supply shocks and strengthen the domestic industrial base. The program covers all minerals  as critical by the U.S. Geological Survey (USGS). 

For companies mining critical minerals in the U.S., this development provides a new framework for financial support and regulatory prioritization. Here are five things your company needs to know and do:

1. Leverage “National Security” Status to Expedite Permitting

Project Vault is explicitly designed to advance the National Security Strategy and reduce dependence on foreign-controlled supply chains. Because the project is framed as a “frontline economic tool” to ensure “uninterrupted access” to essential materials, mining companies can leverage this federal designation to advocate for faster regulatory timelines.

Action: In all state and federal permitting applications, your legal counsel should formally cite the project鈥檚 alignment with Project Vault鈥檚 national security objectives to justify more efficient environmental and operational reviews.

2. Access to Unprecedented Long-Term Financing

The EXIM Board of Directors has approved a Direct Loan of up to $10 billion to provide long-term financing for this initiative. This capital is intended to support the partnership between original equipment manufacturers (OEMs) and private sector capital providers.

Action: Evaluate how your mining operations can integrate into this $10 billion ecosystem, either by seeking direct project financing from EXIM or through off-take agreements with the designated reserve suppliers.

3. Utilize High-Level Industry-Government Coordination

The initiative represents a “transformative approach” where industry and government move “decisively together”. The presence of the President and Cabinet Secretaries at the launch underscores a unified federal commitment to domestic critical mineral production.

Action: Leverage this “decisive” coordination to request inter-agency streamlined meetings. Use the administration’s focus on “revitalizing American industry” to press for synchronized reviews between the various federal and state departments and agencies (including EXIM) to resolve bureaucratic bottlenecks more efficiently.

4. Stabilization Against Market Volatility and Supply Shocks

The Reserve is designed to store materials to protect domestic manufacturers from supply shocks and market disruptions. For miners, this creates a stable, government-backed destination for domestic production.

Action: Position your mining project as a “resilience provider” for the U.S. industrial base. Highlighting that your minerals can be stored domestically to prevent supply disruptions can enhance the social license to operate and reduce local or state-level political opposition to new mining permits.

5. Strategic Integration with Major Industrial OEMs

Project Vault is supported by major U.S. manufacturers who require these minerals for advanced manufacturing and critical technologies. These companies are increasingly focused on strengthening “supply chain resilience”.

Action: Engage with these initial OEM participants. By becoming a domestic supplier for the minerals required by these companies, your project gains additional strategic value that can be used to argue before state and federal regulators that any delay in your permitting process directly threatens the manufacturing jobs and economic security highlighted by EXIM leadership.

About 麻豆直播鈥檚 Energy & Infrastructure Sector

麻豆直播鈥檚 cross-disciplinary Energy & Infrastructure team of more than 200 attorneys regularly represents clients in the traditional and renewable power, oil & gas, nuclear, and infrastructure and energy transition industries. 麻豆直播 offers comprehensive legal services for energy and infrastructure companies and projects to guide clients through every phase鈥攆rom development and site control to investment, commercial contracting and financing. 麻豆直播 can also assist companies involved in mining, processing, and disposal to navigate the various state and federal regulations, international agreements, and national security considerations.

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Uranium Designated as a US Critical Mineral in the 2025 USGS List: Three Things You Need to Know Now About this Landmark Action /p/102ltvj/uranium-designated-as-a-us-critical-mineral-in-the-2025-usgs-list-three-things-y/ Fri, 07 Nov 2025 17:59:09 +0000 /p/102ltvj/uranium-designated-as-a-us-critical-mineral-in-the-2025-usgs-list-three-things-y/ On November 7, 2025 the U.S. Geological Survey (USGS), on behalf of the Secretary of the Interior, issued its Final 2025 List of Critical...

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On November 7, 2025 the U.S. Geological Survey (USGS), on behalf of the Secretary of the Interior, issued its , including uranium among four minerals that were not on the .  For those involved in the US nuclear fuel supply chain, here are 3 things you need to know now about this designation:

1. Designation Confirms that Uranium is Essential to the US Economy and its National Security:

The USGS Critical Minerals List serves as a foundational document for American industrial and defense strategy. Its fundamental purpose is to identify minerals that are essential for national security, economic stability, and supply chain resilience. These designated minerals are recognized as the bedrock of key industries, drivers of technological innovation, and the support structure for the critical infrastructure vital to a modern American economy. The core rationale for the list stems from the significant vulnerabilities created by reliance on foreign mineral sources. As the USGS Notice states, 鈥淭he United States鈥 dependence on imports and the vulnerability of supply chains raise the potential for risks to national security, defense readiness, price stability, and economic prosperity and resilience.鈥  The list is therefore a key component of a national strategy aimed at mitigating these risks by securing domestic mineral supply chains and facilitating domestic production.

Uranium demand has increased significantly in the last few years, driven by renewed interest in nuclear power.[1] Artificial intelligence (鈥淎I鈥) is seen as an important strategic asset and requires large amounts of energy, and many see nuclear power as being a core source of that energy.[2] Uranium was included on the initial 2018 final list of 35 critical minerals.[3] However, it was removed in the 2022 final list of 50 critical minerals due to its classification as a fuel mineral under the Energy Act of 2020 (Section 7002), which excludes fuel materials like uranium from the definition. However, Section 7002(c)(4)(C) of the Energy Act requires the Secretary of the Interior to consult with other department secretaries to obtain their recommendations for materials to include. The Department of Energy recommended including uranium.[4] And the inclusion of uranium in the 2025 List follows (“Unleashing American Energy”), which directed the USGS to reconsider uranium鈥檚 inclusion, alongside additions like copper, silver, metallurgical coal, potash, rhenium, silicon, and lead.[5]

2. Designation Provides Tangible Benefits to the US Uranium Industry

The designation of uranium as a 鈥渃ritical mineral鈥 is far more than a simple label; it is a formal recognition that aligns uranium with pressing national priorities. For the domestic uranium industry, this designation unlocks five core strategic benefits by formally recognizing its importance to the nation’s security and economic well-being:

  1. Elevated Strategic Importance: Inclusion on the list formally recognizes uranium 鈥渁s essential for national security, economic stability, and supply chain resilience.鈥[6] This official validation elevates the industry鈥檚 profile from a commercial enterprise to a strategic national asset. This status provides a powerful mandate in policy discussions and national planning, formally cementing its role in the country鈥檚 long-term strategic calculus.
  2. Alignment with National Security and Defense Mandates: The Notice cites the Department of Energy鈥檚 recommendation to include uranium as a critical mineral due to uranium鈥檚 importance in 鈥渆nergy, and defense,鈥 which provides an unambiguous link between the mineral and the nation’s industrial and defense apparatus.[7] This direct alignment positions the domestic uranium industry as a key partner in strategic readiness and national security infrastructure.

  3. Catalyst for Securing Domestic Supply Chains: The primary goal of the Critical Minerals List is to 鈥済uide strategies to secure the Nation鈥檚 mineral supply chains.鈥 Uranium’s inclusion on this list is a clear signal of federal intent to reduce U.S. reliance on foreign sources thereby mitigating the risks of potential supply disruptions. This focus provides a strong justification for policies and initiatives aimed at strengthening and expanding the domestic uranium supply chain from mining and milling all the way through to conversion and enrichment.
  4. Prioritization for Domestic Production Support: The official notice affirms that 鈥渢he United States is taking actions to facilitate domestic mineral production.鈥[8] By being officially designated as critical, the domestic uranium industry is positioned as a primary candidate for these federal facilitation efforts and support mechanisms. The designation serves as a prerequisite for prioritization in government-led efforts to bolster domestic resource development.
  5. Influence on Future Government Policy and Strategy: The 2025 List is explicitly designed to 鈥済uide strategies to secure the Nation鈥檚 mineral supply chains鈥 across the government.[9] Consequently, uranium鈥檚 critical status will now inherently influence future government policy, strategic planning, and investment decisions. This includes considerations related to energy independence, defense stockpiling, and the development of next-generation energy and defense infrastructure, ensuring the domestic supply of uranium remains a key factor in these deliberations.

3. Designation Could Lead to Several Key Changes for the US Nuclear Fuel Supply Chain Industry

Having a mineral designated as critical by the U.S. Geological Survey (USGS) provides industries with targeted support to address supply vulnerabilities, fostering long-term stability and growth. Based on USGS analyses and federal policy frameworks, here are the five primary benefits:

  1. Enhanced Supply Chain Resilience and Risk Mitigation: The U.S. nuclear fuel supply chain industry should expect to gain access to detailed USGS assessments of supply chain vulnerabilities, enabling proactive planning for disruptions. This includes the modeling by USGS of over 1,200 trade scenarios across 400+ industries to quantify economic impacts, helping companies identify risks and build more robust sourcing strategies.[10]
  2. Access to Federal Investments and Funding: Listing may qualify uranium for direct government investments in domestic mining, processing, and resource recovery (e.g., from mine waste). This supports expansion of U.S.-based production, reducing import reliance and stabilizing costs for downstream users in sectors like defense and clean energy.
  3. Potential Tax Incentives and Financial Relief: Critical minerals are sometimes eligible for tax credits and incentives under laws like the Energy Act of 2020, lowering operational costs for exploration, extraction, and manufacturing. This encourages innovation and efficiency, particularly for high-value applications in semiconductors and electric vehicles. Participants in the U.S. nuclear fuel supply chain should explore whether that is the case for uranium.
  4. Accelerated Permitting and Regulatory Processes: Projects involving critical minerals benefit from streamlined federal permitting under initiatives like the (Earth MRI). This can reduce development timelines, enabling faster project deployment and minimizing delays for industries dependent on timely mineral access.
  5. Strategic Stockpiling and Resource Allocation: The designation informs national stockpiles and scenario planning, ensuring prioritized reserves during shortages. Industries can leverage this for better resource allocation, substitute material R&D, and collaboration with federal agencies, ultimately safeguarding production continuity and economic contributions from minerals-based sectors.

The inclusion of uranium on the 2025 USGS Critical Minerals List is a landmark development. The potential benefits described above represent a fundamental shift in the strategic landscape for the domestic uranium industry. The designation was not a result of routine methodological updates but was driven by specific executive directives and a direct national security-based recommendation from the Department of Energy. The benefits are substantial and far-reaching, including elevated strategic importance and alignment with defense mandates to prioritization for domestic supply chain support. Ultimately, this designation formally aligns the domestic uranium industry with the highest strategic priorities of the United States and signals a more assertive federal posture in securing supply chains critical to defense and energy independence.

About 麻豆直播鈥檚 Energy & Infrastructure Sector

麻豆直播鈥檚 cross-disciplinary Energy & Infrastructure team of more than 200 attorneys regularly represents clients in the traditional and renewable power, oil & gas, nuclear, and infrastructure and energy transition industries. 麻豆直播 offers comprehensive legal services for nuclear energy companies and projects to guide clients through every phase 鈥 from development and site control to investment, commercial contracting and financing. 麻豆直播 can also assist companies involved in the nuclear fuel supply chain 鈥 including mining,  processing, and disposal 鈥 to navigate the various state and federal regulations, international agreements, and national security considerations.


[1] Christian Purefoy, The Oregon Group, Nuclear Energy is Back (7 Oct 2024), https://theoregongroup.com/commodities/uranium/nuclear-energy-is-back/.

[2] Anthony Milewski, The Oregon Group, Small Reactors, Big Stakes: How the Global SMR Race is Reshaping Uranium Demand (2 Jul 2025), https://theoregongroup.com/commodities/uranium/small-reactors-big-stakes-how-the-global-smr-race-is-reshaping-uranium-demand/.

[3] U.S. Dep鈥檛 of the Interior, Final List of Critical Materials 2018, 83 Fed. Reg. 23295 (18 May 2018).

[4] U.S. Dep鈥檛 of the Interior, Final 2025 List of Critical Materials, 90 Fed. Reg. 50495 (11 Nov 2025).

[5] Exec. Order No. 14154, 90 Fed. Reg. 8353 (2025).

[6] U.S. Dep鈥檛 of the Interior, Final 2025 List of Critical Materials, 90 Fed. Reg. 50495 (11 Nov 2025).

[7]Id.

[8]Id.

[9]Id.

[10] United States Geological Survey,  Methodology and Technical Input for the 2025 U.S. List of Critical Minerals鈥擜ssessing the Potential Effects of Mineral Commodity Supply Chain Disruptions on the U.S. Economy, Open-File Report 2025-1047 (25 Aug 2025), https://doi.org/10.3133/ofr20251047 

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What鈥檚 Next for the ITC and PTC Following the Inflation Reduction Act /insights/publications/2022/08/whats-next-itc-ptc-inflation-reduction-act/ Tue, 30 Aug 2022 05:00:00 +0000 The post What鈥檚 Next for the ITC and PTC Following the Inflation Reduction Act appeared first on 麻豆直播 & Lardner LLP.

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The United States Seeks Consultations with the Mexican Government Regarding Mexico Energy Policy under the USMCA /insights/publications/2022/07/united-states-consultations-mexican-govt-energy/ Tue, 26 Jul 2022 05:00:00 +0000 https://foley.com/insights/publications/2022/07/united-states-consultations-mexican-govt-energy/ The post The United States Seeks Consultations with the Mexican Government Regarding Mexico Energy Policy under the USMCA appeared first on 麻豆直播 & Lardner LLP.

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Proposed Changes to California Net Metering Tariffs Under Review by CPUC /insights/publications/2022/02/proposed-changes-california-net-metering-tariffs/ Tue, 15 Feb 2022 05:00:00 +0000 The post Proposed Changes to California Net Metering Tariffs Under Review by CPUC appeared first on 麻豆直播 & Lardner LLP.

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Army Corps Changes Course: CWA Jurisdictional Determinations May Require a New Look /insights/publications/2022/02/army-corps-changes-course-cwa-jurisdictional/ Tue, 01 Feb 2022 05:00:00 +0000 https://foley.com/insights/publications/2022/02/army-corps-changes-course-cwa-jurisdictional/ The post Army Corps Changes Course: CWA Jurisdictional Determinations May Require a New Look appeared first on 麻豆直播 & Lardner LLP.

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Off to the Races: EPA鈥檚 Aggressive New Fuel Efficiency Standards Will Fundamentally Reshape How Cars are Made and Powered /insights/publications/2021/12/epas-aggressive-new-fuel-efficiency-standards-cars/ Wed, 29 Dec 2021 05:00:00 +0000 The post Off to the Races: EPA鈥檚 Aggressive New Fuel Efficiency Standards Will Fundamentally Reshape How Cars are Made and Powered appeared first on 麻豆直播 & Lardner LLP.

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President Signs Uyghur Forced Labor Prevention Act 鈥 Next Steps for Compliance /insights/publications/2021/12/president-signs-uyghur-forced-labor-prevention-act/ Thu, 23 Dec 2021 05:00:00 +0000 The post President Signs Uyghur Forced Labor Prevention Act 鈥 Next Steps for Compliance appeared first on 麻豆直播 & Lardner LLP.

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Section 48D: A New Tax Credit for Electric Transmission Property /insights/publications/2021/10/new-tax-credit-electric-transmission-property/ Fri, 15 Oct 2021 05:00:00 +0000 The post Section 48D: A New Tax Credit for Electric Transmission Property appeared first on 麻豆直播 & Lardner LLP.

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The Future of Illinois Energy Policy: Renewable Energy Set to Expand /insights/publications/2021/09/future-illinois-energy-policy-renewable-set-expand/ Fri, 17 Sep 2021 05:00:00 +0000 https://foley.com/insights/publications/2021/09/future-illinois-energy-policy-renewable-set-expand/ The post The Future of Illinois Energy Policy: Renewable Energy Set to Expand appeared first on 麻豆直播 & Lardner LLP.

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