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Solving America’s Uranium Crisis—

Why Mining Domestic Uranium Is Vital To


U.S. National and Economic Security

Prepared By

Dr. Ned Mamula, Geologist


Formerly with U.S. Geological Survey
Author, Groundbreaking! America’s
New Quest for Mineral Independence

Stephen Moore, Senior Economist


Economic Consultant with Freedom Works and
Distinguished Visiting Fellow for
Economic Growth at Heritage Foundation

September 3, 2019
Table of Contents

Executive Summary......................................................................................................................... 2

Dangerous Decreases in U.S. Uranium Production ........................................................................ 5

National Security and Economic Costs of Losing Domestic Uranium ........................................... 10

Strategic Importance of Reviving Domestic Uranium Production................................................ 12

Disparity Between U.S. vs. State-Owned Uranium Companies .................................................... 16

Broad Steps to Stabilize Domestic Uranium .................................... Error! Bookmark not defined.

Specific Policies to Revitalize America’s Uranium Industry .......................................................... 21

Conclusion ..................................................................................................................................... 21

Appendix in separate volume

2
Executive Summary

The U.S. uranium mining industry is in crisis today due to certain foreign state-owned
companies and entities undermining free-market uranium through predatory practices. U.S,
uranium production has also suffered from years of anti-mining regulatory and environmental
policies that have left the domestic industry dormant.

As of 2019, more than 99 percent of U.S. uranium supplies are imported, much of it from
Russia, Kazakhstan, and Uzbekistan. China is also ramping up its ability to supply more cheap
uranium to the U.S. These are not friendly ally nations that America can depend on.

Because of those foreign imports, and for a variety of regulatory and policy reasons, domestic
uranium production and employment are at historic lows not seen since the dawn of the
industry in the 1940s. The private industry on which the nuclear fuel cycle has traditionally
relied is on the verge of collapse. Were the nation’s domestic uranium mining industry to
disappear, could it make a comeback? If a comeback were possible, how long would it take and
at what cost to our energy, medical and military needs?

Despite the existence of vast uranium deposits in the U.S., domestic producers expect 2019
production to dip below one percent of what our nation requires to fuel its commercial nuclear
reactors—i.e. less than the amount required to fuel even one of the 97 commercial reactors
that produce electricity, and enable nuclear and medical research in the U.S.

It is dangerous to have the world’s largest network of nuclear reactors operating without some
basic level of uninterruptable supply of domestic uranium to fuel them, rather than the near
100 percent import reliance now expected for 2019 and 2020. In addition, the nation is
ultimately at risk of not being able to provide its mandated supply of domestic uranium for
national defense and national security requirements.

Western companies operating in free-market capitalism environments are not and have not
been on a level playing field with state-sponsored companies and entities who are more
interested in geopolitical advantage over the West, than in profitability.

While we certainly believe in free trade, the increasing uranium market dominance from state-
sponsors threatens not just the production of U.S. uranium, but also the prospect of a vibrant
civilian nuclear reactor fleet—i.e. the entire nuclear fuel cycle. Civilian nuclear reactors provide
critical baseload power that keeps the electrical grid stable. The U.S. can ill-afford the possibility

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of geopolitically motivated uranium fuel supply disruptions because nuclear energy provides 20
percent of the nation’s electricity, as well as 55 percent of our carbon‐free power generation.

Unfortunately, U.S. domestic uranium production has been reduced to three mining
companies. Currently the total U.S. uranium workforce has been reduced to less than 400
employees from over 21,000 in the early 1980’s. In addition, the nation has lost considerable
technical talent and expertise that has become increasingly difficult to replace.

The uranium industry has capacity to produce significant quantities of uranium from mines
idled and on standby, but the ability of the industry to sustain idle operations is severely limited
by the following factors:

• State laws that restrict the length of time mines can remain on standby and, forcing
premature decommissioning of mining capacity.

• Nongovernmental organizations that actively pursue litigation to force the closure of mines
currently on standby.

• State and tribal governments considering uranium mining bans, who have been emboldened
by the U.S. Supreme Court’s recent upholding of Virginia’s uranium mining ban.

• For smaller domestic uranium companies, the sheer cost of maintaining non-producing mines
is not sustainable and will result in closures under current market conditions.

Unless conditions improve dramatically or the federal government provides immediate


assistance to create a level playing field, much of current uranium production capacity is at risk
of being permanently stranded or lost, immediately jeopardizing U.S. uranium-dependent
power generation and national security and national defense programs. Rebuilding production
capacity and intellectual capital to support the minimum uranium industrial base needed for
defense programs would also probably take decades.

4
Dangerous Decreases in U.S. Uranium Production

Over the last decade, nations that do not share our democratic and free-market values have
expanded uranium production and overrun the global nuclear market with subsidized uranium.
This has forced free-market producers in the U.S. and our allies to reduce production, close
mines, and lay off workers, because state-owned or state-sponsored companies or entities in
Russia, Kazakhstan, Uzbekistan, China, and elsewhere are targeting the U.S. uranium market for
destruction, jeopardizing the entire domestic nuclear fuel cycle.

Foreign, state-mandated production is attempting to bring an end to U.S. uranium mining,


milling, and enrichment. That strategy is working, unfortunately. The U.S. has the ability to
compete on a level playing field, but our geopolitical adversaries provide massive financial and
other support to their uranium mining entities, making it almost impossible for U.S. companies
to compete. The biggest problem are the state-owned uranium producers within the Russian
sphere of influence.1 For example,

• Over 40 percent of uranium delivered to U.S. nuclear utilities in 2018 came from Russia,
Kazakhstan, and Uzbekistan.2

• Kazakh imports have benefited from an 87 percent devaluation of the national currency in
comparison to the U.S. dollar. 3

• State-owned uranium companies in these countries receive massive subsidies, and are price-
insensitive, producing uneconomic uranium despite depressed prices and a global surplus.

Figure 1. In 2016, imports from state-owned companies overwhelmed domestic production. In 2019, the
situation is much worse because the U.S. is expected to produce less than 400,000 pounds of U3O8, or
less than one percent of domestic fuel requirements. Source: Energy Information Agency (EIA). 4

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Within Russia, Kazakhstan, Uzbekistan, and China, state-owned uranium companies are able to
utilize their unique national ownership structures, leveraging their country’s resources to gain
market control and eliminate free-market competition through the sale of uranium and
uranium equivalents at below worldwide average costs.

Evidence of these practices includes the Russian government handing over billions of dollars of
enrichment capacity to subsidiaries of their state-owned Rosatom, by increasing issuance and
ownership of subsoil licenses in Kazakhstan, and by increased Chinese construction of
enrichment capacity well in excess of their current or expected domestic requirements.

If we were talking about toothpaste, toys or tomatoes, these state subsidies and other non-
market interventions to create an un-level playing field would not be worrisome. But uranium
has enormous marketplace and security implications that Washington should carefully
consider.

The figure below provides a look at how the entire uranium industry is shifting from the free-
market to non-free-market state-owned enterprises. In 2011, about half of the global supply
was produced from companies and entities operating in the free-market. By 2021, despite
plummeting prices and continued oversupply, it is expected that state-owned companies and
entities will mine 75 percent of global uranium ore each year.

Figure 2: Global supply from free-market companies decreased, while supply from state-owned
companies and entities increased, despite declining spot price. This trend is expected to continue
through 2021, at which point free-market producers in Australia, Canada, and the U.S. will only supply
about 25percent of global mine production with the remainder coming from non-free-market producers
in Russia, Kazakhstan, Uzbekistan, China, and a few others. Source: EIA, World Nuclear Association. 5

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The uranium industry in other western, free-market economies who the U.S. has previously
relied on for uranium, are also at an enormous competitive disadvantage compared to state-
owned companies and entities in Russia, Kazakhstan, Uzbekistan, and China. Our allies are no
longer reliable sources of uranium.

The state ownership of Rosatom—Russia’s state nuclear energy corporation—allows Russia to


leverage market control at the expense of the entire western uranium industry. As a result,
Russia is currently responsible for approximately 40 percent of the world’s enrichment capacity,
in large part by totally backstopping Rosatom. This is the juggernaut that the American uranium
producers are up against.

The U.S. is beholden to government-backed uranium industries in Russia, Kazakhstan and


Uzbekistan for over 40 percent of U.S. uranium imports. That number is likely to go higher
because of the fragility of the entire U.S. domestic nuclear cycle—from exploration, mining,
conversion, enrichment, and disposal—due to environmental activism and an unwarranted fear
of today’s nuclear energy source. 6 We have seen in recent years how China has tried to use trade
advantages as a political weapon—and to allow nations like Russia to do the same raises a
vulnerability that could be highly problematic in the years to come.

As of 2016, four major and eleven minor exporting countries provide almost all of the uranium
to power U.S. nuclear reactors: 7

• Canada 25 percent, Australia 20 percent


• Russia 14 percent, Kazakhstan 24 percent, Uzbekistan 4 percent
• Malawi, Namibia, Niger, South Africa 10 percent (combined)
• Brazil, Bulgaria, China, Czech Republic, Germany, Ukraine 2 percent (combined)

Figure 3. As domestic uranium production (in millions of pounds of U3O8) has declined over the past
several decades, owners and operators of commercial nuclear power plants in the U.S. have obtained
more uranium from foreign sources. Canada has historically been the largest single source of uranium,
followed by Australia, Russia, and Kazakhstan, countries in which the cost of uranium is lower than in
the U.S. Recently, however, imports from Russia, Kazakhstan, and Uzbekistan are nearing 45 percent.
Source: Energy Information Agency. 8

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Consequently, two U.S. uranium operators, Energy Fuels and Ur-Energy, on January 16, 2018,
again petitioned the Commerce Department under Section 232 of the Trade Expansion Act of
1962 (as amended) to investigate uranium import dumping in the U.S. by Russia and its
surrogates Kazakhstan and Uzbekistan. Both companies are seeking relief from imports of
uranium products that threaten U.S. national security. 9

As a real-world example of what could happen, consider the oil embargo of 1973. Prices for oil
rose from $6-7/barrel to over $40—a 600 percent jump. At that time, the U.S. imported a mere
6 percent of its oil requirements from the Arab countries imposing the embargo. However, the
huge increase in market prices and the massive disruption of nationwide gasoline lines over an
embargo of 6 percent of U.S. supply is very instructive, even frightening, considering that the
import supply of uranium is fast approaching 100 percent.

Why does the U.S. import so much of its uranium fuel from adversaries and unstable countries,
especially when uranium is in relative abundance in our own land? Ostensibly, the U.S. could
mine and produce many tens of millions of pounds a year as was done in the 1980s, relying on
friendly countries for the any shortfall in domestic requirements.

The answer is because uranium import over-reliance and uranium mining underperformance are
locked together—each is caused by the other—and the cycle continues to spiral downward in a
race to the bottom.10

In addition to dwindling mining output previously discussed, another problem that drives
increasing imports is the U.S.’ limited capability to process uranium after the metal has been
mined. According to EIA, at the end of June 2018, production of uranium concentrate (U3O8) in
the U.S. relied on one conventional uranium mill in White Mesa, Utah, and five insitu recovery
(ISR) facilities in Wyoming, and one in Nebraska. But by early September 2018, only White Mesa
and three ISR facilities were in operation, two in Wyoming and one in Nebraska. 11

The White Mesa uranium processing mill in southeast Utah was idled during much of 2017.
During that time, all uranium mined in the U.S. needed to be sent to France and Canada for
processing into UF6 (known as “uranium hexaflouride”), and then reimported for enrichment,
and use in domestic nuclear power plants. It is hard to imagine why the nation would have to
send something as critical as its nuclear fuel out of the country for processing, especially due to
heightened security concerns of yellowcake falling into the “wrong” hands. 12

As of February 2018 the White Mesa facility again became operational. However, America’s
uranium processing capabilities are far too fragile still, and represent too much of a bottleneck
to the country’s power generating capability. 13

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Figure 4. U.S. uranium concentrate production (millions of pounds of U3O8) plummeted from 1980 to
2019. The U.S. produced 1.47 million pounds of uranium concentrate in 2018, down for the fourth
consecutive year and the lowest total since 1950, based on preliminary production data. Uranium
production in the U.S. has declined since its peak of 43.7 million pounds in 1980 and has remained
below 5 million pounds annually for more than 20 years. Source: Energy Information Agency. 14

Domestic uranium concentrate production peaked at over 40 million pounds in 1980 and has
persistently remained below 5 million pounds annually since 1997. Uranium concentrate totaled
2.44 million pounds in 2017, down 16 percent from 2016, and the lowest annual output of
concentrate since 2004. 15 Output for 2018 was lower and forecasts for 2019 are lower still.

In yet another blow to the U.S. nuclear fuel cycle output, the nation’s sole uranium conversion
facility that converts U3O8 yellowcake into uranium hexafluoride (UF6) for later enrichment was
shuttered in November 2017, and has been idled since. The company in charge of the Metropolis,
Illinois plant—one of the few such facilities in the world—suspended uranium hexafluoride
production pending an “improvement in business conditions.” 16

That company, Honeywell, made their decision to suspend production as the result of “significant
challenges” faced by the nuclear industry. For example, they attribute decreased demand for
UF6, especially from Japan and Germany, to the 2011 Fukushima nuclear incident in Japan. The
company also cites current worldwide oversupply of UF6, an oversupplied uranium fuel cycle, and
downward trend in uranium markets. 17

In addition to the fragility in mining and processing, the federal government has a history of
making the uranium import over-reliance situation worse. For example, over the past decade the
DOE routinely exchanged excess stockpiled uranium—some from decommissioned nuclear
weapons—as payment to contractors for cleanup services at a DOE contaminated site in Ohio.
Officially known as “barter”, this process apparently was used to sidestep the lack of
congressional funding for various DOE site cleanup activities. 18

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Contractors ultimately sold the excess inventory without having to account for finding, mining,
or processing costs, which undercuts the relatively small U.S. uranium market. Unfortunately, for
the past seven years, the DOE has bartered away more uranium than was produced domestically.
And in 2016 and 2017 a milestone of sorts was reached when the amount bartered to contractors
was more than double the amount of U.S. uranium production in both years. 19 20

If the DOE sold all of its uranium in the open marketplace, those funds would go to the U.S.
Treasury, and not be transferred to the department in exchange for contract work. But because
bartering circumvents Congress's power of the purse, the Government Accountability Office
(GAO) declared it illegal in 2006 and again in 2011. 21

However, the DOE persisted.22 Finally, the Secretary of Energy on March 20, 2018, suspended
the practice of bartering excess U.S. uranium to contractors as payment, and mandated that
funding for cleanup of DOE facilities should be only be provided through congressional
appropriations. Unfortunately, many years’ worth of damage to the market had already
occurred.23

Players such as Russia, Kazakhstan and Uzbekistan, and some other uranium exporters are
benefitting from the U.S.’ current uranium policy debacle by continuing to flood the U.S. with
cheap uranium to gain geopolitical leverage. American uranium production continues to decline
under historically low uranium prices. During 2017 the price of uranium ore (U3O8) was between
$20 and $25 per pound—lower than at any time since 2004.24

But it gets worse. While the U.S. does not import significant quantities of uranium from China at
this time, the Chinese have significantly grown their state-owned nuclear enterprises and
announced that they intend to penetrate the U.S. nuclear market with nuclear fuel that will
compete directly with U.S. uranium miners. 25 This fuel is now coming from new Chinese interests
in Namibia.26

National Security and Economic Costs of Losing Domestic Uranium

Uranium produces one fifth of the nation’s electricity, which is why the uranium import issue is
rightfully discussed within the context of national security. As the nation approaches 100 percent
reliance on uranium imports, there is always the possibility for an embargo or partial restriction
of exports to the U.S. by one or more foreign sources, resulting in substantial economic costs.

Therefore, on July 12, 2019, the Administration issued a Presidential Memoranda, in which
President Trump stated: “the United States uranium mining industry faces significant challenges
in producing uranium domestically and that this is an issue of national security.” 27

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One of those challenges is the possibility of needing to recreate today’s uranium industry
infrastructure and knowhow in the future if domestic uranium were to collapse. Rebuilding
would be expensive, time-consuming, risky, and not assured of success. For example:

• With an estimated time of 12-20 years to rebuild the existing uranium infrastructure in
accordance with current laws and regulations, a viable domestic industry probably could
not be rebuilt fast enough to satisfy expanding national security needs.28

• Preserving existing U.S. domestic uranium production capabilities today will preserve
the existing licensed production capacity and expertise required to supply most our
domestic needs quickly and at the lowest cost possible.

The U.S. uranium mining industry is in crisis today due to the geostrategic leverage of certain
foreign state-owned enterprises that undermine the free-market through predatory practices.
Domestic uranium production is at record lows, and the private industry on which the fuel cycle
has traditionally relied, is on the verge of collapse, leading to the need to consider:

• If the nation’s domestic uranium mining industry disappeared, could it return?

• If the domestic uranium industry could return, how long would it take and at what cost?

Recreating a uranium mining industry sufficient to meet U.S. national security and clean energy
needs would require an immense investment, similar to what occurred during the Manhattan
Project or the Cold War. The costs would be enormous, for example:

• Approximately $3.7 billion and 12-20 years to relicense and rebuild the existing facilities
and capacity the nation has today, if it were even possible. 29

• Approximately $10-$12 billion of exploration and development was spent between 1968
and 2000, to discover and define the uranium deposits that were mined during that
period, along with the deposits being mined today. 30

A similar amount will be required to discover and define the deposits required to meet future
needs. If a vibrant uranium industry is preserved today, all or a large portion of this amount
would be paid by private industry versus by the U.S. government.31

These figures assume successfully overcoming other enormous challenges that are difficult to
quantify in terms of time and/or cost, including: 32

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• Loss of mining, milling, insitu recovery, and technical expertise specific to U.S. deposits.
• Need to re-assemble land and property tenure regarding reserves and resources.
• Need to address increasing challenges to access uranium deposits on public lands.
• Loss of technical, geological, geophysical, and geochemical data.
• Legal challenges to new licenses and facilities construction.

Furthermore, even if the U.S. was successful in rebuilding its uranium industry institutional
knowledge base and recreating the nation’s existing infrastructure, there is no guarantee that
these projects will be successful, as many newly-constructed uranium projects around the
world are failing. It is far less risky to preserve existing production facilities that have a proven
track record of successful and responsible operation.

Finally, much has changed since the Manhattan Project and Cold War, especially with the
proliferation of new laws and regulations over the last 45 years (including those concerning
environmental and cultural protection), along with associated litigation. America also faces
wildly divergent public and political views about how, or even if, America’s abundant uranium
resources should be utilized.

But unless and until there is a replacement of one fifth of the nation’s power generation and a
substitute for military requirements for nuclear materials, there is no other substitute choice
that makes sense or that is important to national security as nuclear power and the domestic
uranium that should be fueling it.

Strategic Importance of Reviving Domestic Uranium Production

According to the most recent data from the Energy Information Administration (EIA), today’s
U.S. uranium mining infrastructure consists of a network of conventional uranium mines, insitu
recovery mines, processing plants, and uranium mills. 33

This infrastructure is indispensable for the revival of our uranium industry to be able to fuel at
least some small fraction of America’s electric power generation capacity because uranium
mining and milling is the first step required for the production of the nuclear fuel that is used in
America’s commercial nuclear reactors that in turn produce 20 percent of the nation’s
electricity.

The loss of either mining or milling, and the restriction of uranium imports by the current
suppliers to the U.S. could plunge the nation right back into a 1970s-style energy “crisis” over

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diminished domestic electric power generation. In addition, military requirements and
readiness could also be negatively affected because of a uranium import restriction.

Consequently, the Section 232 petition of the Trade Act, proposed a uranium quota that would
have returned the nation’s domestic uranium industry to economically sustainable levels of
approximately 12.5 million pounds of U3O8 per year within approximately five years. 34 We are
not convinced that quotas are the right solution to creating a level playing field, but it is one
option on the table.

Supporting domestic production at these levels would maintain all of the nation’s existing
licensed uranium production capacity of approximately 33 million pounds of U3O8 per year and
encourage the licensing and construction of additional production capacity. That represents 66
percent of current U.S. uranium requirements. Existing and new capacity would be maintained
and operated in accordance with all existing environmental and cultural protection laws.

Alternatively, a strategy that supports a production capacity of less than 33 million pounds of
U3O8 per year would also be helpful, and much preferable to trying to engage in an expensive
and risky effort to rebuild future capacity if it were to fail near term.

Either scenario would probably also help preserve the unique existing infrastructure associated
with mining, milling, enrichment, and disposal, as well as the institutional knowledge and
industry expertise requirements. Also, in the event of a national security need, production
could be ramped up very quickly within either licensed capacity scenario.

To rebuild today’s existing infrastructure, in the normal course of business, would


conservatively take one or more decades and billions of dollars. However, in a national
emergency, these timelines could perhaps be reduced, but the cost would skyrocket. Recent
experience has also demonstrated that the nation’s security priorities can be stymied by courts
and public opposition.

In addition to the uranium industry’s physical plant and infrastructure, there are other factors
of enormous importance that would affect the capability, cost, and timing of reviving a
collapsed uranium mining industry—if it were even possible at all. These factors include
uranium industry expertise, company leases, land positions, and property rights.

For example, the U.S. would lose valuable uranium mining, milling and insitu recovery
expertise, slowing the production of ore deposits going forward. Today’s industry is already
down to less than 400 people, and if the industry is allowed to diminish any further, existing

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intellectual knowledge will also be in danger of totally disappearing as uranium professionals
retire, pass on, or move to other industries.

During the last uranium market upturn from 2004 to 2009, new projects that were discovered
during this period, were developed, mined, and some are still producing at present. Mining
companies were fortunate that some former technical experts who worked uranium deposits in
the 1970s and 1980s were still available during the last market upturn—many of those in their
70s and 80s. However, obtaining the knowledge of these very senior and experienced
professionals in the future becomes increasingly difficult. 35

Another key issue is the existence of current leases, land positions, property rights, and
exploration data associated with mineable uranium deposits that have been created and
consolidated over the past 50+ years. Were this information to be lost, it would be another
major setback to the industry. If the uranium industry disappeared over the next year or two,
the land packages and property rights that currently exist for mines, mills, and ISR facilities,
uranium deposits, and exploration targets would undoubtedly disappear.

The loss of technical and scientific data required to mine uranium deposits would probably
require expensive time-consuming reconstruction of reliable of uranium databases that were
built by from scratch decades ago. For example, from 1968 to 2000, it is estimated that private
industry spent $10 billion-$12 billion (in CY2000 dollars) for exploration and development to
discover and delineate the uranium deposits that are still being mined today.

During the 2005-2009 uranium market upturn, the level of exploration drilling to accurately
define, extend, and identify new uranium resources was short-lived and limited. As a result,
new deposits to replace the previously mined ones have not been fully defined and identified.
There is good confidence, backed up by USGS analysis, for the existence of uranium minerals;
however, additional drilling is needed. As discussed above, there is no central repository with
extensive geophysical data that can become the basis of new uranium production. That will
have to be effectively “bootstrapped” before new projects could be developed in the future. 36

Fortunately, large amounts of technical data, such as geophysical and geochemical information
for uranium deposits is still available. However, because much of this data was collected in the
1960’s and 1970’s, much of it often exists only in physical hard copy stored at operating
facilities. When those facilities are closed, as in the past, the data was dispersed or disposed of.
Some of this hard data is even stored in old offices, storage units, and individual’s homes.
Therefore, obtaining access is a challenge that will only grow more difficult with time. 37

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It will be expensive and time-consuming, and may be impossible, to reassemble the land
packages and reacquire the property rights given the patchwork of ownership that underpins
the various mineral, water and surface rights. And, even if it were possible, the cost to do so in
a short period of time could be immense, especially if a national emergency requires the use of
eminent domain.

Furthermore, subsequent administrations and congresses can place various restrictions on


public land, including mineral withdrawals, as well as creating national parks, national
monuments, wilderness areas, and other federally-designated categories that make access to
uranium deposits off limits to future development. In addition, many environmental laws or
nuisance legal actions pertaining to mines and mills represent other wasteful limitations to
uranium production. 38

For example, consider the Arizona Strip uranium withdrawal. In January 2012, then president
Obama’s Secretary of the Interior Ken Salazar withdrew more than 1,000,000 acres of land
containing valuable uranium deposits and more than 3,200 active mining claims in northern
Arizona. The withdrawal area includes enough uranium (between 325-375 million pounds) to
power the entire state of California’s 40 million people for over 20 years. 39

Even the U.S. Department of Agriculture’s Forest Service identified this mineral withdrawal as a
potential burden to domestic energy production. After a December 2017 lawsuit that claimed
the withdrawal was illegal, the Ninth Circuit Court upheld the withdrawal. The Supreme Court in
October 2018 decided not to hear the case and the withdrawal remains in effect. 40

Therefore, the current uranium production problems are not caused by a shortage of domestic
resources. In fact, the U.S. is well-endowed with uranium according to numerous reports by the
U.S. Geological Survey and others (see Appendix: How Much Uranium Does America Have?). The
U.S. was uranium self-sufficient as recently as the 1980s, when it led the world in mining output.

However, beginning in the 1990s the U.S. began to lose much of its capacity to mine, refine,
smelt, or process critical minerals and metals—especially uranium—due in large part to a broad
anti-mining agenda among many of increasingly militant environmental groups.41 This trend has
resulted in a lack of domestic mining and resultant over-reliance on imports for dozens of
minerals defined as “critical” by the Department of the Interior, particularly uranium. 42

15
Figure 5. U.S. critical mineral import dependence (percent) and source country. All 33 critical minerals are
at least 50 percent imported, and 15 are at 100 percent. Note: there are 15 rare earth metals listed as
“rare earths” by U.S. Geological Survey. Therefore, the list technically contains 48 critical minerals and
metals. Uranium indicated at 90 percent is presently closer to 99 percent. Source: U.S. Geological Survey.

The real problem highlighted by the table above is that most of the critical mineral imports,
especially uranium, are coming from China, Russia, and third-world dictatorships. The U.S.’
vulnerability to a mineral embargo has become sufficiently serious that President Trump
issued Executive Order 13817 on December 20, 2017, to ensure secure and reliable supplies of
critical minerals for the nation.43

Disparity Between U.S. vs. State-Owned Uranium Companies

A case has been made for state-owned companies and entities from Russia, Kazakhstan,
Uzbekistan, and China targeting the U.S. nuclear market, weakening the domestic nuclear fuel
cycle, and creating serious problems for U.S. national security.

As a result, free-market producers in the U.S. and allied nations have had to reduce production,
suspend operations, close mines, lay off workers, or exit the business altogether. However, the
U.S.’ geopolitical foes provide massive financial and other support to their uranium mining and

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nuclear fuel entities, making it impossible for U.S. companies to compete. As a result, the U.S.
uranium industry is on the verge of collapse.

As previously mentioned, state-owned uranium producers within the Russian and Chinese
spheres of influence have led the assault on this critical U.S. industry, for example:

• In 2018, over 40 percent of uranium delivered to U.S. nuclear utilities in 2018 came from
Russia, Kazakhstan, and Uzbekistan. 44

• Imports of uranium in 2018 from Russia, Kazakhstan, and Uzbekistan increased by 16 percent
over 2017, while at the same time, imports from Canada and Australia fell by 25 percent, and
U.S. uranium production plummeted by 33 percent. 45

• Uranium producers in these countries are state-owned, they receive massive subsidies, and
they are price insensitive, producing uranium without regard to price or cost, despite depressed
prices and a global surplus.

As a result, the global uranium market has already shifted towards state-sponsored entities
owned by the governments of China, Russia, and Russia’s allies, and away from the traditional
free-market of global suppliers in the U.S., Canada, and Australia. Today, 70 percent of the
global uranium market is dominated state-owned companies. This percentage is continuing to
increase year over year.

In addition to activities within their own borders, Chinese and Russian state-owned companies
and entities advance their national government’s policies by displacing the operations of
Western uranium companies in other countries. For example, Chinese state-owned entities are
implementing China’s “Belt and Road” Initiative by taking control of Namibia’s uranium
production that has traditionally been a major supplier in the global free-market. 46

Likewise, utilizing the traditional relationship between Russia and Kazakhstan, Rosatom has
taken control of a significant amount of Kazakhstan’s uranium production, again displacing
former Western joint venture partners from Canada, Japan, France and elsewhere within
Kazakhstan.

Moreover, Kazatomprom, Kazakhstan’s national uranium mining company, is leveraging


government power to impose highly-unfavorable terms on Western joint venture partners,
thereby squeezing out the partners who provided the significant financial support and technical
expertise that have enabled these deposits to dominate the market today.

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In contrast, the current U.S. uranium industry has no national support or deep financial pockets
of large corporations as was the case 30 to 40 years ago. Nor is the uranium mining industry
supported by the commercial U.S. nuclear power industry, which itself is also under financial
pressure, and therefore seeks out the cheapest nuclear fuel it can find.

State-owned companies and entities are using their countries’ national policies, infrastructure
and ownership to deploy predatory pricing offered to U.S. nuclear utilities, forcing the loss of
most of the components of the U.S. nuclear fuel cycle that supports the defense industrial base.
The world has recently witnessed how China seized control of the global rare earth elements
industry, and the U.S. is totally unable to compete against the current Chinese rare earth
monopoly.

The same dynamic is happening in uranium and nuclear fuel today but at an even greater scale.
Here too, the U.S. uranium industry cannot compete head-to-head with the state-owned
uranium mining and nuclear fuel companies from Russia, Kazakhstan and now China.

First, unlike its competition from the “Russian block” (Russia, Kazakhstan, Uzbekistan), the
uranium nuclear fuel program in the U.S. has no nationalized ownership or financial support.
None of the uranium companies that make up the current domestic uranium industry are state-
owned or supported, with the single exception of Uranium One’s (Russian-owned) Wyoming
leases.

All of the remaining domestic uranium miners except for the Canadian miner Cameco, are tiny
micro-cap companies with a limited ability to raise significant capital to operate existing
uranium mining infrastructure—or even to maintain that infrastructure on standby for any
extended period of time. As a result, the U.S. uranium industry is now reliant on micro-cap,
capital market forces to maintain a vital domestic industry.

On a global scale, the U.S. industry and our free-market counterparts in Canada and Australia
are required to respond to market signals and to provide a return on investment and profits to
its investors. In comparison, the state-owned companies are immune to responding to market
signals or investors. As a result, they behave in an inelastic, cost-insensitive manner within the
global uranium market.

The regulatory environment in the U.S. nuclear fuel industry is some of the most rigorous and
expensive in the world. Nuclear Regulatory Commission (NRC) standards for protection of the
environment and human health are some of the most protective in the world. State-owned
companies in the Russian block and China do not pay for or enforce regulatory guidelines.

18
In addition, the U.S. uranium industry has rigorous decommissioning and reclamation standards
that are very expensive. The industry carries significant financial assurance and reclamation
liability that the state-owned companies can simply pass on to the state. Also, there exists in
the U.S. significant duplicative regulatory and statutory requirements that foreign state-owned
companies don’t have to deal with.

The costs of these all these requirements are a continued burden to the U.S. uranium industry
when competing in an already challenging and unfair market. U.S. uranium mining companies
do not enjoy a special relationship with the federal government, like Kazatomprom has with the
Kazakh government, for example.

Another extremely important issue for uranium mining is land access and tenure. These are
subject to various ownership, legislation, and taxation requirements, even among the different
states. Texas, for example, predates the Homestead Act and the Mining Law of 1872, and there
is limited federal and state lands containing mineral resources. Therefore, land tenure is based
on direct negotiation with individual private landowners that create unequal land acquisition
and tenure costs.

In the western states such as Wyoming and Utah, there are significant mineral properties that
are bifurcated between federal, state, and private ownership. In many cases, the surface estate
is severed from the mineral estate, creating private/federal ownership. None of these types of
burdens are carried by the foreign state-owned companies in the Russian block because the
government is both the landowner and the uranium miner.

Finally, litigation is a constant factor in the development, operation and maintenance of the
U.S. uranium industry. The industry is under constant assault by activist groups, who use the
courts and media to further weaken the industry position were possible. There are many cases
where the regulatory process has been further complicated through litigation.

All aspects of uranium mining—from initial permits, to licenses, to operations, to


decommissioning—are subject to constant challenge and litigation. This is expensive and time-
consuming cost of doing business in the West that state-owned companies are not exposed to.

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Broad Steps to Stabilize Domestic Uranium

President Trump’s Presidential Memoranda (July 12, 2019) establishing the Nuclear Fuel
Working Group agreed with the Secretary of Commerce’s finding that uranium imports from
state-sponsored companies or entities are an issue of national security. 47

The Department of Commerce report will undoubtedly represent the most current and
comprehensive review of the state of the U.S. nuclear fuel cycle, and should be released as
soon as possible to inform stakeholders and the Nuclear Fuel Working Group as it works to
complete its principles and recommendations.

In lieu of the Commerce report findings, there are some broad recommendations discussed
below that would help provide relief to the struggling U.S. uranium industry. These are based
on decades of successful domestic experience with U.S. uranium mining and processing, which
have been overshadowed by the reality of today’s foreign state-sponsored uranium mining
companies now unfairly out-competing U.S. uranium miners.

• Continue to designate uranium as a “critical mineral” (Department of Interior). Maintain


and strengthen uranium's status as a federally‐recognized critical mineral, by fully
implementing the President’s Executive Order 13817—to ensure a secure and reliable
supply of critical minerals like uranium that are vital to our nation’s security, national
defense, and economic prosperity. 48

• Revamp the federal approach to uranium inventories and stockpiles and streamline
unnecessary federal regulations for both.

• Ensure transparency and prioritize the viability of the domestic uranium industry and
the national ability to meet defense needs to prevent the possibility of any uranium
supply disruption to the U.S.

For example, the lead time for a new domestic uranium project is between 10-20 years due to
development, permitting requirements, and litigation hurdles. This assumes some prior history
of exploration of a deposit, and the timeline is even longer and more uncertain if the industry is
ever forced to start from scratch with resources that haven’t been drilled and evaluated.

Even with regulatory reform, the National Environmental Policy Act (NEPA), National Historic
Preservation Act (NHPA), and state regulations still tend to waste time, drain resources, and
create impediments to new projects. A streamlined regulatory effort is badly needed.

20
The difficulty in bringing new U.S. mines into production is illustrated by the industry’s
challenges to take advantage of favorable market conditions. Despite a hospitable market, U.S.
mine production only increased from 2.5 million pounds in 2004 to 4.9 million pounds in 2014.
Much of the necessary permitting and licensing not concluding until after market conditions
worsened drastically before 2004.49

For comparison, Kazakhstan’s production increased from 8.6 million pounds in 2004 to 59.3
million pounds in 2014. As recently as the 1990s, Kazakhstan’s uranium production was
negligible.50

• Establish federal facilitation of domestic uranium production of at least 7.5 million


pounds annually by 2025, and 10 million pounds annually by 2030, along with the
equivalent uranium conversion production and continued development of domestic
enrichment. Evaluate only proposed recommendations that will meet these targets. 51

• Prioritize immediate executive branch actions that are ready to implement and that can
be pursued administratively, followed with longer-term legislative action.

• Leverage the purchasing power of federal government and military entities to the
extent possible to lock out excessive imports.

Specific Policies to Revitalize America’s Uranium Industry

Executive Branch. Swift and immediate administration actions are crucial to mitigate the
impact of state-backed companies and entities, and to prevent the collapse of the domestic
uranium industry. Each of the following measures would help counter today’s dismal conditions
in the near term and set the U.S. on a path towards ensuring domestic production of at least
7.5 million pounds annually by 2025 and 10 million pounds annually by 2030. 52

• Premium Power Contracts (Department of Defense). The Nuclear Fuel Working Group
(NFWG) should recognize the necessity of viable and resilient civilian demand for
nuclear power to sustain the nuclear fuel industrial base for national security needs.

• Deploy the President’s authority under the Defense Production Act (DPA) to direct the
Defense Department to negotiate premium power contracts with utilities to source
clean, reliable, and resilient nuclear energy powered by domestic uranium.

21
• Use the DPA to make direct payments to domestic uranium companies for newly
produced uranium sold to utilities. This will help ensure a viable domestic industry to
support national security requirements. Potential Impact: 3‐5 million pounds annually.

• “Buy American” Requirement (Department of Energy/Tennessee Valley Authority and


Bonneville Power Administration). The NFWG should recommend that the federally-
backed utilities, TVA and BPA, establish a “Buy American” requirement. This would help
ensure that all, or a substantial portion of the nuclear power they produce will be fueled
by domestic uranium. Potential Impact: 3 million pounds annually.

• Use Existing Federal Inventories of Natural Uranium (Department of Energy). The DOE’s
management of the federal excess uranium inventory has previously flooded the
domestic uranium market at the expense of domestic uranium miners and convertors
over multiple previous administrations. The limited amount of material in the inventory
suitable for fuel purposes could be repurposed as a temporary, targeted, short‐term
incentive for utilities to purchase domestic uranium, such as a matched purchase
program under which U.S. utilities will be given the ability to acquire uranium from
government inventories at lower than market prices to offset domestic purchases. Such
a program would have to be implemented with strict limitations on the use of the
material given DOE’s history of mismanagement. Potential Impact: 8.5 million pounds.

• Create a New Federal Uranium Security Stockpile (National Nuclear Security


Administration). Direct the NNSA, in coordination with DOD, to negotiate long-term
contracts with the domestic uranium industry for the purchase of domestic uranium to
stockpile for defense needs, for utilities in the event of a severe supply disruption, and
as a source of high-assay, low-enriched uranium for the development of advanced
nuclear reactors. Federal stockpiles should help secure and support the domestic
uranium industry, not harm it. DOE has in the past interpreted the law as affording them
unprecedented authority to use existing inventories for contractor barter in lieu of
payment to DOE contractors, at the expense of the domestic industry, whereas a new
uranium stockpile should be managed solely for these energy and national security
objectives. Potential Impact: 5‐10 million pounds annually.

• Guaranteed Loans (Department of Energy). Utilize existing guaranteed loan authority to


provide financing for domestic uranium producers. This will help level the playing field
with state‐sponsored producing companies in countries that deploy market distorting,
price‐insensitive tactics. Potential Impact: 5‐10 million pounds annually.

22
Congress. While it is imperative that the executive branch immediately pursue the above
mentioned actions to increase domestic production, legislative options should be also
immediately considered by Congress as ways to help level the global playing field by improving
the viability of the U.S. uranium industry. 53

• Domestic Uranium Tax Credit. Establish a tax credit for utilities to purchase
domestically-produced uranium. Consideration must be given to the current financial
status of nuclear power operations and their unique tax structure.

• Federal Excess Uranium Inventory Reform. Create a long-term framework for the
management of existing federal uranium inventories to bolster transparency and
eliminate detrimental impacts on the domestic uranium mining and conversion industry.

• Guaranteed Loan Program. Create new guaranteed loan authorities tailored specifically
to leveling the playing field between domestic producers and state-sponsored uranium
mining companies.

Finally, the removal of unnecessary government-wide regulatory impediments will help also
support the long-term viability of the domestic uranium industry such as listed below.

• Clarify the Roles and Responsibilities of the Nuclear Regulatory Commission (NRC) and
Environmental Protection Agency (EPA) in regulating uranium production.

• Comprehensive Review of the entire suite of uranium production policies (NEPA and
others) to streamline unnecessary regulations.

• Initiate Limited Federal Research and Development (Department of Energy). Direct


DOE’s National Labs to expand, intensify, and prioritize efforts to research and develop
technologies that reduce insitu recovery (ISR) production and reclamation costs.

• Resolve Federal Land Management Conflicts (Department of the Interior). Review and
develop comprehensive plans to address barriers to accessing uranium deposits on
federal land. For example, the DOI should engage stakeholders with various and diverse
surface and mineral ownership rights to resolve access issues that result in landlocked
uranium properties in the western New Mexico “checkerboard” acreage.

• Remove Land Withdrawal Restrictions (Department of the Interior) Certain Bureau of


Land Management (BLM) managed lands that are currently withdrawn hold the highest‐

23
grade domestic uranium deposits that would provide for global cost competitive
production and national security purposes should they be available for development. A
specific example are the uranium deposits within the Arizona Kanab Plateau (Northern
Arizona Strip). Properly regulated and mitigated uranium mining in this area would have
no adverse impact on surrounding public lands.

Conclusion
While this report does not endorse any particular method of rebuilding an American uranium
production capability, to do so is in America’s national and economic security interests. We
have learned from OPEC and now more recently China and Russia’s predatory behavior, that to
be dependent on unreliable nations for energy and critical mineral imports can be dangerous to
American national and economic security interests.

Multiple factors place the U.S. at a severe competitive disadvantage to the state-owned
corporate juggernauts. The only answer would be for the U.S., in partnership with the private
sector, to invest in its uranium nuclear fuel industrial base, not only to provide the ability
compete for power generation, but also to assure there is a domestic source of non-obligated
uranium for national security needs.

Very low-cost imports of uranium can be a blessing to American producers of nuclear energy
and electric consumers, however, this could be a penny wise and pound foolish strategy for the
long run. The U.S. has great mineral wealth, especially uranium, and using the nation’s
domestic uranium makes perfect economic and national security sense. There is no reason to
enable mineral resource leverage to other countries when America is blessed with an
abundance of uranium—similar to all the other mineral wealth this nation possesses.

Benign neglect of America’s incredible mineral wealth is clearly not working—it absolutely must
be replaced with a smart strategy that ensures reliable and affordable domestic uranium for
years to come. This is not the current federal policy, and it needs to change before the nation’s
domestic uranium mining capacity is permanently crippled.

24
1
Energy Fuels Resources Inc., has produced two white papers that have been extensively referenced below: These
are titled: The U.S. Nuclear Fuel Industrial Base is Being Undermined by Predatory Anti-Competitive Activities
by State-Owned Companies from China, Russia, and Russia’s Allies; and If Current Uranium Production
Capacity is Lost There Likely Will be no Viable Alternative to Bring it Back. These are both dated August 1,
2019, and have been presented to the President’s U.S. Nuclear Fuel Working Group. A third white paper titled:
Policy Solutions for United States Nuclear Fuel Working Group, from the Uranium Producers of America,
dated August 14, 2019, has also been referenced below.
2
Energy Information Agency, Where Our Uranium Comes From,
https://www.eia.gov/energyexplained/index.php?page=nuclear_where
3
Energy Fuels Resources (USA) Inc., The U.S. Nuclear Fuel Industrial Base is Being Undermined by Predatory
Anti-Competitive Activities; A white paper presented to the President’s U.S. Nuclear Fuel Working Group,
August 1, 2019
4
Energy Information Agency, Where Our Uranium Comes From,
https://www.eia.gov/energyexplained/index.php?page=nuclear_where
5
Energy Information Agency, Where Our Uranium Comes From,
https://www.eia.gov/energyexplained/index.php?page=nuclear_where
6
Ned Mamula, and Ann Bridges, Groundbreaking! America’s New Quest for Mineral Independence, Chapter 5,
American Uranium Debacle, Penned Source Production, 2018, 278 p.
7
Energy Information Agency, Where Our Uranium Comes From,
https://www.eia.gov/energyexplained/index.php?page=nuclear_where
8
Energy Information Agency, 2018 Uranium Marketing Annual Report, May 6, 2019
https://www.eia.gov/todayinenergy/detail.php?id=39352
9
Ur-Energy and Energy Fuels, Jointly File Section 232 Petition with the U.S. Commerce Department to Investigate
Effects of Uranium Imports on U.S. National Security, News Release, January 16, 2018,
http://www.energyfuels.com/news-pr/energy-fuels-ur-energy-jointly-file-section-232-petition-u-s-commerce-
department-investigate-effects-uranium-imports-u-s-national-security/
10
Ned Mamula, and Ann Bridges, Groundbreaking! America’s New Quest for Mineral Independence, Chapter 5,
American Uranium Debacle, Penned Source Production, 2018, 278 p.
11
Energy Information Agency, Domestic Uranium Production 2nd Quarter 2018, August 2018,
https://www.eia.gov/uranium/production/quarterly/pdf/qupd.pd
12
Ned Mamula, and Ann Bridges, Groundbreaking! America’s New Quest for Mineral Independence, Chapter 5,
American Uranium Debacle, Penned Source Production, 2018, 278 p.
13
Jasper Fakker, US Has Only 1 Operating Uranium Mill Left, The Epoch Times, June 4, 2018,
https://www.theepochtimes.com/u-s-has-only-one-operating-uranium-mill-left_2548808.html
14
Energy Information Agency, 2018 Uranium Marketing Annual Report, May 6, 2019
https://www.eia.gov/todayinenergy/detail.php?id=39352
15
Energy Information Agency, 2017 Uranium Marketing Annual Report, February 26, 2018,
https://www.eia.gov/todayinenergy/detail.php?id=35092
16
World Nuclear News, U.S. conversion plant suspends UF6 production, November 21, 2017, http://www.world-
nuclear-news.org/UF-US-conversion-plant-suspends-UF6-production-2111177.html
17
World Nuclear News, U.S. conversion plant suspends UF6 production, November 21, 2017, http://www.world-
nuclear-news.org/UF-US-conversion-plant-suspends-UF6-production-2111177.html
18
Sightline, Glimmers of Hope for U.S. Miners, March 29, 2018, https://sightlineu3o8.com/2018/03/editorial-
glimmers-of-hope-for-uranium-miners/

25
19
Exchange Monitor, Nuclear Industry Group Wants DOE Uranium Barter to Cease, April 17, 2017,
https://www.exchangemonitor.com/nuclear-trade-group-wants-uranium-barter-cease/?printmode=1
20
Energy Information Agency, 2017 Uranium Marketing Annual Report,
https://www.eia.gov/uranium/marketing/pdf/umar2017.pdf
21
Government Accountability Office, Excess Uranium Inventories: Clarifying DOE's Disposition Options Could
Help Avoid Further Legal Violations, September 26, 2011, https://www.gao.gov/products/GAO-11-846
22
Government Accountability Office, Uranium Mining, Opportunities Exist to Improve Oversight of Financial
Assurances, GAO 12-544, May 2012, https://www.gao.gov/assets/600/590929.pdf
23
Josh Siegal, Rick Perry suspends policy of selling excess uranium, Washington Examiner, March 20, 2018,
https://www.washingtonexaminer.com/policy/energy/rick-perry-suspends-policy-of-selling-excess-uranium
24
Energy Information Agency, 2017 Uranium Marketing Annual Report,
https://www.eia.gov/uranium/marketing/pdf/umar2017.pdf
25
Ur-Energy and Energy Fuels, Jointly File Section 232 Petition with the U.S. Commerce Department to Investigate
Effects of Uranium Imports on U.S. National Security, News Release, January 16, 2018,
http://www.energyfuels.com/news-pr/energy-fuels-ur-energy-jointly-file-section-232-petition-u-s-commerce-
department-investigate-effects-uranium-imports-u-s-national-security/
26
Energy Fuels Resources (USA) Inc., If Current Uranium Production Capacity is Lost There Likely Will be no
Viable Alternative to Bring it Back; A white paper presented to the President’s U.S. Nuclear Fuel Working
Group, August 1, 2019
27
The White House, Memorandum on the Effect of Uranium Imports on the National Security and Establishment of
the United States Nuclear Fuel Working Group, July 12, 2019, https://www.whitehouse.gov/presidential-
actions/memorandum-effect-uranium-imports-national-security-establishment-united-states-nuclear-fuel-
working-group/
28
Energy Fuels Resources (USA) Inc., If Current Uranium Production Capacity is Lost There Likely Will be no
Viable Alternative to Bring it Back; A white paper presented to the President’s U.S. Nuclear Fuel Working
Group, August 1, 2019
29
Energy Fuels Resources (USA) Inc., The U.S. Nuclear Fuel Industrial Base is Being Undermined by Predatory
Anti-Competitive Activities; A white paper presented to the President’s U.S. Nuclear Fuel Working Group,
August 1, 2019
30
Comments on Section 232 National Security Investigation of Imports on Uranium (Federal Register 83 FR 35204,
dated July 25, 2018; Docket ID BIS-2018-0011)”, Laramide Resources Ltd., September 19, 2018.
31
Energy Fuels Resources (USA) Inc., The U.S. Nuclear Fuel Industrial Base is Being Undermined by Predatory
Anti-Competitive Activities; A white paper presented to the President’s U.S. Nuclear Fuel Working Group,
August 1, 2019
32
Energy Fuels Resources (USA) Inc., If Current Uranium Production Capacity is Lost There Likely Will be no
Viable Alternative to Bring it Back; A white paper presented to the President’s U.S. Nuclear Fuel Working
Group, August 1, 2019
33
Energy Information Agency, Domestic Uranium Production Annual Report, May 16, 2019,
https://www.eia.gov/uranium/production/annual/
34
Ur-Energy and Energy Fuels, Jointly File Section 232 Petition with the U.S. Commerce Department to Investigate
Effects of Uranium Imports on U.S. National Security, News Release, January 16, 2018,
http://www.energyfuels.com/news-pr/energy-fuels-ur-energy-jointly-file-section-232-petition-u-s-commerce-
department-investigate-effects-uranium-imports-u-s-national-security/
35
Energy Fuels Resources (USA) Inc., If Current Uranium Production Capacity is Lost There Likely Will be no
Viable Alternative to Bring it Back; A white paper presented to the President’s U.S. Nuclear Fuel Working
Group, August 1, 2019

26
36
Energy Fuels Resources (USA) Inc., If Current Uranium Production Capacity is Lost There Likely Will be no
Viable Alternative to Bring it Back; A white paper presented to the President’s U.S. Nuclear Fuel Working
Group, August 1, 2019
37
Energy Fuels Resources (USA) Inc., If Current Uranium Production Capacity is Lost There Likely Will be no
Viable Alternative to Bring it Back; A white paper presented to the President’s U.S. Nuclear Fuel Working
Group, August 1, 2019
38
Energy Fuels Resources (USA) Inc., If Current Uranium Production Capacity is Lost There Likely Will be no
Viable Alternative to Bring it Back; A white paper presented to the President’s U.S. Nuclear Fuel Working
Group, August 1, 2019
39
Ned Mamula, and Ann Bridges, Groundbreaking! America’s New Quest for Mineral Independence, Chapter 5,
American Uranium Debacle, Penned Source Production, 2018, 278 p.
40
Farris J. Gillman, Supreme Court Declines to Review Decision preventing New Uranium Mines Near Grand
Canyon, October 25, 2018, http://www.swlaw.com/blog/environmental-and-natural-
resources/2018/10/25/supreme-court-declines-to-review-decision-preventing-new-uranium-mines-near-gra
41
Ned Mamula and Stephen Moore, A Groundbreaking Opportunity: Mining Critical Minerals in America, National
Review, March 15, 2018, https://www.nationalreview.com/2018/03/mining-strategic-minerals-
environmentalists-make-america-vulnerable/
42
Department of the Interior, Interior Releases 2018’s Final List of 35 Minerals Deemed Critical to U.S. National
Security and the Economy, https://www.usgs.gov/news/interior-releases-2018-s-final-list-35-minerals-deemed-
critical-us-national-security-and
43
The White House, Memorandum on the Effect of Uranium Imports on the National Security and Establishment of
the United States Nuclear Fuel Working Group, July 12, 2019, https://www.whitehouse.gov/presidential-
actions/memorandum-effect-uranium-imports-national-security-establishment-united-states-nuclear-fuel-
working-group/
44
Energy Information Agency, Where Our Uranium Comes From,
https://www.eia.gov/energyexplained/index.php?page=nuclear_where
45
Energy Fuels Resources (USA) Inc., The U.S. Nuclear Fuel Industrial Base is Being Undermined by Predatory
Anti-Competitive Activities; A white paper presented to the President’s U.S. Nuclear Fuel Working Group,
August 1, 2019
46
Energy Fuels Resources (USA) Inc., The U.S. Nuclear Fuel Industrial Base is Being Undermined by Predatory
Anti-Competitive Activities; A white paper presented to the President’s U.S. Nuclear Fuel Working Group,
August 1, 2019
47
The White House, Memorandum on the Effect of Uranium Imports on the National Security and Establishment of
the United States Nuclear Fuel Working Group, July 12, 2019, https://www.whitehouse.gov/presidential-
actions/memorandum-effect-uranium-imports-national-security-establishment-united-states-nuclear-fuel-
working-group/
48
The White House, Memorandum on the Effect of Uranium Imports on the National Security and Establishment of
the United States Nuclear Fuel Working Group, July 12, 2019, https://www.whitehouse.gov/presidential-
actions/memorandum-effect-uranium-imports-national-security-establishment-united-states-nuclear-fuel-
working-group/
49
Uranium Producers of America, Policy solutions for United States Nuclear Fuel Working Group, August 14, 2019
50
Energy Fuels Resources (USA) Inc., The U.S. Nuclear Fuel Industrial Base is Being Undermined by Predatory
Anti-Competitive Activities; A white paper presented to the President’s U.S. Nuclear Fuel Working Group,
August 1, 2019
51
Uranium Producers of America, Policy solutions for United States Nuclear Fuel Working Group, August 14, 2019
52
Uranium Producers of America, Policy solutions for United States Nuclear Fuel Working Group, August 14, 2019
53
Uranium Producers of America, Policy solutions for United States Nuclear Fuel Working Group, August 14, 2019

27

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