Category Archives: Business and Society

No, the Shift to Renewables Will Not Be the End of Toil

Energy derived from sources like the sun, air, and water, on the other hand, is imbued with immense liberatory potential. In principle every house, farm, and factory could free itself from the grid by generating its own power. No longer would power lines and gigantic, leak prone tankers be needed for the transportation of energy; no longer would workers have to toil in underground mines or remote deserts or rough seas; there would be no need for the long supply chains required by fossil fuels. (Amitav Ghosh, The Nutmeg’s Curse, p. 102, emphasis mine)

Context makes it clear Ghosh is thinking of coal mining, oil fields, and offshore platforms when he dreams of a world where workers no longer toil. But in his reverie, Ghosh neglects an important and undeniable feature of renewable energy: it is mining intensive.

The IEA sees demand for critical minerals surging from 2020-2050 even as the demand for and value of coal drops. In green growth scenarios, workers will likely have to keep toiling in mines as they now do in Chile’s Atacama desert, the cobalt mines of the Democratic Republic of Congo, or the copper and nickel mines of South Asia, South America, or Siberia. The list of potential sacrifice zones will grow and could someday extend from American public lands to offshore oil platforms converted to deep-sea mining.

This observation is not an argument against the transition from fossil fuels. It’s just to say that right now there are no signs the shift to renewables will undo the resource curse. Extraction for global markets continues to exact a local toll: serious human rights violations, unremediated (or irremediable) environmental destruction, conflicts over water (which Ghosh himself mentions briefly in a list of “conflicts that global warming will create or exacerbate,” p. 127), and social division. And for the foreseeable future, mineral supply chains will be nearly as long as those required by fossil fuels, strung across the globe and fraught with geopolitical tension.

A decisive shift from fossil fuels could see the end of the petro-dollar and the toppling of “global hierarchies of power,” as Ghosh imagines: “The liberatory potential of renewable energy has a very important international dimension as well: if adopted at scale it could transform, indeed revolutionize, the current global order” (p. 103). It could also precipitate another set of crises – environmental, humanitarian, and military — and it’s worth considering that eventuality.

Postscript, 20 January 2022: For more on the geopolitical risks of the energy transition, see Jason Bordoff and Meghan L. O’Sullivan, “Green Upheaval The New Geopolitics of Energy,” Foreign Affairs, January/February 2022.

Public Comment on the Rainy River Watershed Withdrawal

My written comments ran to five pages, so instead of posting them here, I put them online as a PDF, which you can read here. I also made a three-minute comment in the live session hosted by the Bureau of Land Management and the US Forest Service this afternoon. My comments focus mainly on the story I’ve been pursuing for the past few years — a story of corruption. The first couple of paragraphs convey the general idea:

Federal lands in the Rainy River Watershed should be withdrawn from disposition under US mineral and geothermal leasing laws for the proposed initial twenty-year period, if not permanently. This is an overdue decision, grounded in science, economics, law, and environmental ethics.

Why, then, hasn’t it already happened? How did this withdrawal process, which started in 2017, go off track? Agency records obtained through the Freedom of Information Act show clearly that a foreign mining company, Antofagasta plc, acted to prevent the withdrawal; and from 2017-2021, members of Congress and the executive branch ran political interference on its behalf. Decisions taken behind closed doors during that period served foreign private interests, not the American public interest. The agencies now have an opportunity to rectify the situation.

I end with three recommendations:

The announcement on October 20, 2021, that the Biden administration will complete the “science-based environmental analysis” was encouraging. Given all the political interference, the two-year study really ought to have been started all over again, from scratch, in the interest of scientific integrity. At the very least, USDA Secretary Tom Vilsack should release – unredacted — the preliminary findings of the canceled two-year scientific study, so that they can be compared with the new and complete analysis.

As agencies work toward a science-based decision on the twenty-year withdrawal, they also need to take additional steps to restore public confidence and guard against undue influence. As a first step, the USDA Inspector General could review Secretary Perdue’s decision to cancel the 2017 withdrawal process and report on scientific independence, ethical conduct, and political interference at the agency.

Finally, the agencies can help raise standards. Industry repeatedly assures us that non-ferrous mining in the Rainy River Watershed and elsewhere can be done “responsibly,” and there are a growing number of calls, from Congress and from within the Biden administration, for “responsible mining” for the transition to renewables. How should government respond? Rigorous and practical guidance for agencies on the law and ethics as well as the technical and scientific aspects of “responsible mining” would be a good start.

Here is a recording of my three-minute live comment, which tracks all this pretty closely. Video is cued to the mark.

The Boundary Waters, Offshore: Luksic in the Pandora Papers

A chart of Luksic-connected offshore entities included with the CIPER report.

Last week, El Centro de Investigación Periodística (CIPER) published an investigative report on the offshore financial activities of Andronico Luksic Craig and the Luksic family, based on the Pandora Papers — a trove of over 11 million records leaked from tax havens in the British Virgin Islands. The investigation cast some new light on the elaborate network of offshore corporations, foundations, law firms, and corporate services companies involved in managing some of the Luksic family’s vast fortune, and brought me back to some of the records I’d uncovered in connection with Luksic’s purchase of the Washington, DC mansion where Jared Kushner and Ivanka Trump lived while serving in the Trump White House.

Luksic acquired that $5.5 million Kalorama property right after Trump won the 2016 election, right around the time Kushner-Trump were preparing for their move to the nation’s capital and at a critical moment when Antofagasta plc, the Chilean mining company controlled by Luksic, was counting on the Trump administration to reverse policies of the Obama administration (which it duly did). This neat arrangement may not have been a simple quid pro quo, a mansion provided in return for government approvals to mine copper and nickel on the edge of the Boundary Waters, but even to the casual observer it looks an awful lot like a foreign emolument. Unfortunately but not surprisingly, the matter never underwent a formal ethics review. (More on all that here, here, and here.)

While these new documents do not directly shed light on the Kalorama emolument, they provide some insight into how Luksic’s control of Antofagasta is connected to offshore schemes and how the Kalorama mansion might figure into a network of Luksic-controlled US property holdings.

One company called out in the CIPER investigation, FDMDA Corp, looks like a more elaborate version of a company I came across in Boston property records, LDMD Corp, which was registered as the owner of two Avery Street properties from 2011 to 2013. FDMDA carries the first initials of the names of Luksic’s five children, while LDMD appears to have been created solely for the male heirs. (I am assuming the L in LDMD stands for Andronico Luksic, the first-born son, with DMD representing Davor, Maximiliano, and Dax.) Two others, Beacon Eagle Corporation and Avery Eagle Corporation, also look like another iteration of Boston property-holding companies formed by Luksic attorneys, Avery Bicentennial Corp and The Avery Millennium Corp.

These corporations owned and still own condominiums on Avery and Beacon streets in Boston. The Beacon Street property includes a penthouse that Luksic (or, rather, Avery Bicentennial) purchased from quarterback Tom Brady in 2012 — which is right around the time that Luksic says he and Donald Trump “said hello” or exchanged a greeting at a New England Patriots’ game, where they would have been guests of Brady, a mutual acquaintance, or of billionaire owner Robert Kraft. So Brady connects Luksic to Trump — suggesting there might be a little more to the Kalorama mansion story than serendipity. What’s not clear is how the entities formed around the Boston properties, or even Luksic’s Miami and Washington DC properties, might be legally connected with the two Eagle companies mentioned in the Pandora Papers.

On April 28, 2017, FDMDA Corp and Beacon Eagle Corporation were relocated from the British Virgin Islands to Liechtenstein, where they were subsumed under an entity called The Lazare Tcherniak Foundation. (The disposition of Avery Eagle remains unclear.) The Lazare Tcherniak Foundation “provides for the economic furtherance of the descendants of Nadia Malvine Tcherniak” — Patricia Lederer Tcherniak is Luksic’s ex-wife and mother of his five children — “that bear the name Luksic as their first or second name and that are also biological descendants of Andronico Luksic Abaroa [Andronico Luksic Craig’s father]. They are all members of a generally defined and fully discretionary class of beneficiaries.”

While Beacon Eagle appears to be bound up with US-based real estate investments, FDMDA Corp. serves Lazare Tcherniak Foundation beneficiaries by managing and distributing stock dividends. Records reviewed by CIPER describe the source of FDMDA Corp’s funds as “mining activities in the Republic of Chile. The funds are mainly dividends indirectly received from Antofagasta plc, a public company listed on the London Stock Exchange.” Here, “indirectly” probably indicates that there is an entity — a partnership — to which the Antofagasta plc dividends are paid before they are distributed, in whole or in part, to the Liechtenstein-based FDMDA Corp.

Of course, all of this appears to be perfectly legal, as Andronico Luksic himself pointed out in a tweet responding to the CIPER report.

While technically true (“Liechtenstein is NOT a tax haven” because Chilean tax authorities don’t include it in their list of tax havens), this statement was rapidly ratioed. Along with President Sebastian Piñera’s own exposure in the Pandora Papers, Luksic’s exposure and his carefully lawyered response just provide more fodder for the debate over inequality in Chile.

Luksic’s  October 6 statement also prompts questions about corporate governance, the extent of the Luksic Group’s reach, and its attendant responsibilities. With a controlling interest in Antofagasta plc, the Luksic Group can easily thwart any shareholder resolutions not to its liking and effectively determine how the company and its subsidiaries are run, all from behind the scenes and with little accountability. That is shadow governance, and it’s the very model of corporate governance that Antofagasta brings to its Twin Metals project near the Boundary Waters.

Postscript. Oct 20, 2021. The same elaborate network of Luksic foundations, offshore companies, tax havens, and investment vehicles is evident in the disclosures filed by Antofagasta’s three lobbying firms: Brownstein Hyatt, Wilmer Hale, and The Daschle Group. I addressed the topic in this Twitter thread:

Read more about the Boundary Waters reversal here

John Ruggie (1944-2021)

Word of John Ruggie’s passing prompted me to look back at the times I engaged with his work on business and human rights, including these ten posts, and to revisit the one instance I know of where he engaged with mine. This was an endnote he wrote, with a link to this blog, for Life in the Global Public Domain.

It was nothing more than a brief reference (“also see…”), but it made an impression on me. After all, who was I to John Ruggie? Not a student, not a colleague in any formal sense. We never even met. But I read him and respected his work; and to my great astonishment, he read me and repaid me in kind with a small, gracious gesture.

Here, the Business and Human Rights Resource Centre has collected tributes to John Ruggie from around the world.

The Latest Records in my Boundary Waters FOIA Case

This morning, after some prodding, Interior sent the 18th supplemental production of records in my Boundary Waters FOIA case. This release numbers only 108 pages. I reviewed the documents this morning in this Twitter thread.

At the moment, the biggest takeaway for me is that we still don’t know nearly enough about coordination among the Department of Interior, the Trump White House, and the USDA, and how politics — and pressure from the mining company — played into the Trump administration’s decisions around Antofagasta’s mineral leases near the Boundary Waters.

Today’s release shows that legal memoranda from the mining company on the mineral withdrawal circulated at Interior just days before Solicitor Daniel Jorjani met with David Bernhardt’s close associate Michael J. Catanzaro, then with the Executive Office of the President, and Stephen Vaden, an attorney at USDA who seems to have been charged with keeping Sonny Perdue apprised of developments on this front.

Perdue had promised Representative Betty McCollum in May of 2017 that “we are absolutely allowing [the mineral withdrawal study] to proceed.” By August of 2017, the mining company had offered a whole host of legal arguments that would help Perdue move away from that declaration. But remarkably enough, he didn’t take that route. Instead, in September of 2018, after a year-long pressure campaign, he abruptly cancelled the two-year mineral withdrawal study, then in its eighteenth month, and declared the Rainy River Watershed open to new exploration. Why? Probably because Trump had publicly fingered him, on a May 2018 visit to Duluth: “It’s now up to Secretary Perdue, and I know he’s looking at it very strongly.” It was clear enough what Sonny Perdue had to do. Where legal arguments had failed, coercion succeeded.

I still believe Secretary Vilsack ought to ask the USDA Inspector General to look into the matter, because there’s pretty clear evidence that Perdue acted corruptly, or at least arbitrarily and at the caprice of the president, but it’s seeming less likely Vilsack will do the right thing. Secretary Vilsack has steered clear of making any comments about mining near the Boundary Waters, citing ongoing litigation in Wilderness Society v. Bernhardt and the review of the matter that Interior is undertaking in connection with that litigation — which is now supposed to be completed by October 22, according to court filings. But as I have said repeatedly, the Secretary as head of a federal agency has an independent obligation to the American public and does not need permission from another agency to investigate corruption at the one he leads.

The new records are here.

And all the Boundary Waters FOIA records I’ve obtained to date are here.

Read more about the Boundary Waters reversal here.

Ask as Ideological Blinder

I started the Asking Project several years ago, out of irritation. The nominative use of the verb “ask” grates on my ears and, in organizations, it presents an illocutionary act of bad faith: an attempt by superiors to disguise orders or commands as requests. There is no negotiating an order issued in this form. You might talk about how you’re going to accomplish the task set for you, but not whether you are going to do it. No bids counter the ask, as they do on the trading floor, and refusal would amount to insubordination. 

In Private Government, Elizabeth Anderson finds the same bad faith gesture — and denial of an unwelcome truth — in the theory of the firm (here, as set out by Alchian and Demsetz in 1972). 

The question the theory is supposed to answer is why production is not handled entirely by market transactions among independent, self-employed people, but rather by authority relations. That is, it is supposed to explain why the hope of pro-market pre-Industrial Revolution egalitarians did not pan out. Alchian and Demsetz cannot bear the full authoritarian implications of recognizing the boundary between the market and the firm, even in a paper devoted to explaining it. So they attempt to extend the metaphor of the market to the internal relations of the firm and pretend that every interaction at work is mediated by negotiation between managers and workers. Yet the whole point of the firm, according to the theory, is to eliminate the costs of markets — of setting internal prices via negotiation over every transaction among workers and between workers and managers. 

Instead of allowing for negotiation, asks and bids, which it (rightly) sees as inefficient, the theory of the firm offers a hierarchy where managers have open-ended authority, or what Anderson sometimes calls “ incompletely specified authority.” Anderson herself muddles things a bit when she introduces this point: 

The key to the superior efficiency of hierarchy is the open-ended authority of managers. It is impossible to specify in advance all of the contingencies that may require an alternation in an initial understanding of what a worker must do. Efficient employment contracts are therefore necessarily incomplete: they do not specify precisely everything a worker might be asked to do. 

The larger point here is that presenting orders as requests — the ask —  is another “ideological blinder,” to use Anderson’s term: it borrows the jargon of the stock trader and market relations to describe (authoritarian) governance relations. Instead of the republican freedom that pre-industrial market advocates envisioned, workers are managed, or governed, as teams: 

The theory of the firm explains why [market relations among equals, or “anarchy”] cannot preserve the productive advantages of large-scale production. Some kind of incompletely specified authority over groups of workers is needed to replace market relations within the firm….in the great contest between individualism and collectivism regarding the mode of production, collectivism won, decisively. Now nearly all production is undertaken by teams of workers using large, indivisible forms of capital equipment held in common. The activities of those teams are governed by managers according to a centralized production plan. This was an outcome of the Industrial Revolution, and equally much embraced by capitalists and socialists. That advocates of capitalism continue to speak as if their preferred system of production upholds “individualism” is simply a symptom of institutional hemiagnosia, the misdeployment of a hopeful preindustrial vision of what market society would deliver as if it described our current reality, which replaces market relations with governance relations across wide domains of production.

 

Are We Ever Going to Find Out How the Boundary Waters Reversal Really Went Down?

I can make a few additions to the Twin Metals timeline based on the latest release of records in my FOIA case against the Department of Interior, and I hope to get around to that soon. For those who would like to review these documents for themselves, the 16th supplemental production in Galdieri v. Dept. of Interior is online here; and all the public records concerning the Trump administration’s actions on Antofagasta’s mineral leases I’ve obtained through Freedom of Information Act requests may be found here.

This new set of records dates from the final months of 2017, when attorneys at the Department of the Interior are drafting, editing, and preparing to release the M-Opinion that would reverse the Obama administration’s actions and grant Chilean mining company Antofagasta, Plc “non-discretionary right” to a third renewal of its Twin Metals mineral leases. The emails included here span the period from then-Deputy Secretary David Bernhardt’s briefing on the matter in early October 2017 to the release of the M-Opinion in late December.

We get a little more detail here about the Bernhardt briefing — or, at least, evidence of continued sensitivity around it. For example, DOI has redacted the phrase that Karen Hawbecker used to describe one of the briefing documents. 

Why the redaction? Why should this phrase be subject to Exemption 5?  It refers to a document dated August 9, 2017, and its title is clearly indicated in the list of attachments: “Draft Lease Renewal Scenarios w[ith] comment.” How did Hawbecker characterize these scenarios?* Or could this be a case of sloppy redaction, where the reviewer did not notice the paper title in the list of attachments? If so, why should the reviewer not want to indicate that David Bernhardt was presented with a list of “lease renewal scenarios” prepared in August 2017?

Clearly, legal issues as well as political sensitivities were at play, and still are. In December 2017, the Solicitor’s office brings Ron Mulach, Office of the General Counsel at USDA, into the loop; OGC makes some changes to the letter the Bureau of Land Management will send to the Forest Service, notifying them of the new disposition. Other communications with attorneys at the Department of Justice, most likely regarding ongoing litigation, were not included in this release because they will “require consultation” with DOJ, according to the letter accompanying these records. A December 5 note about comments received on the draft from the Environmental and Natural Resources Division and a query from an ENRD attorney asking when the new M-Opinion will be issued are among the traces of those communications.

These documents also heighten the impression that there might have been some tension between political appointees and career attorneys at DOI in that first year of the Trump administration. Duplicates of some previously released emails show Gary Lawkowski, the political appointee who was then serving as Counselor to fellow Koch alumnus Daniel Jorjani, running some kind of independent operation within DOI. Lawkowski asks to see the mineral leases in November. He then drafted, or announced that he was drafting, his own version of the M-Opinion, which appears to have created confusion. As we know, he also floated the idea that the new M-Opinion should be positioned as a critical minerals play. While Lawkowski is pushing that industry-friendly line, Richard McNeer, who has been with the Solicitor’s Office since 1998, suggests including some talking points about how the public can make its views known to the Bureau of Land Management and the Forest Service.

Overall, then, this latest release contributes to the impression that the Boundary Waters reversal was a political project from the get-go. We still don’t know enough about the forces behind that project or about the ways it connected with other schemes run behind the facade of government during the last administration. I remain convinced there is a larger, untold story here, but I am less confident than I was a few months ago that the current administration is going to pull back the curtain or investigate how this all went down.

Read more about the Boundary Waters reversal here

*Update, 23 June 2021: It turns out we know exactly how this email read before it was redacted this time around.

And among the documents I’ve obtained is a fully redacted copy of the scenarios paper. It’s entitled “Twin Metals Potential Scenarios for Lease Renewal.” The title almost suggests that Twin Metals (or, more likely, Antofagasta’s WilmerHale lobbyists) provided the scenarios or developed them with Karen Hawbecker.

Perhaps the “comments” included were Hawbecker’s comments on scenarios created by lobbyists or with them? It’s worth noting that these scenarios emerge in the workflow at the Solicitor’s office just a couple of weeks after a July 25, 2017 meeting with Antofagasta, as the timeline shows. Did Antofagasta executives and their lobbyists arrive with these scenarios in hand? Were the scenarios the subject of the meeting?

In any case, Karen Hawbecker worked on the scenarios and forwarded them as separate documents, as scenarios 1, 2A, 2B, and 3, on August 6 and 7 2017 to Jack Haugrud, correspondence shows. The scenarios were then combined into the scenarios paper. Haugrud offers his opinion (“Karen, I”) in some back and forth with Hawbecker on August 7, 2017 that is also redacted.

So the latest redaction only served to direct my attention to these documents and raise the question why there should be sensitivity around them now. It would be troubling if attorneys at Interior were now trying to cover their tracks after following Antofagasta’s lead during the Trump era.

The Second Most Important Chart in the New IEA Report

This is probably the most important chart in the new IEA report, Net Zero by 2050:

It answers the question I asked when I first read about the report in today’s New York Times: what happens without the “unprecedented” global cooperation the report calls for?

In that likely scenario, the IEA does not see the world arriving at Net Zero emissions until around 2090 — which means we will have missed important targets (including limiting average global temperature rise to 1.5° Celsius warming). It also means a much less livable human future.

The second most important chart, to my mind, is this one, predicting  growth in demand for critical minerals such as copper, nickel, cobalt, lithium, and rare earth elements.

The report breaks it down further:

In a short Twitter thread I wrote this morning, I offered this guess:

 

A BLM Map of Critical Minerals Near the Boundary Waters

The latest release of Boundary Waters documents arrived today, a 14th supplemental production in response to my FOIA lawsuit v. the Department of the Interior. I’ve put them online here.

Two things caught my attention right away: first, an inventory of documents the Solicitor’s office at the Department of the Interior put together, apparently in connection with the Voyageur litigation. A short Twitter thread calls out some items of interest.

Also among the records I received today: a Bureau of Land Management map showing prospecting permits and preference rights leases in Superior National Forest.

There are already a significant number of active leases and many more in the application stage that could eventually come online.

The purple plume of inferred and hypothetical reserves of critical minerals is especially noteworthy here.

We know from other documents I obtained that political appointees in the Solicitor’s office intended to position Antofagasta’s mine as a source of critical minerals; and after the Trump administration published a new list of critical minerals in 2017, Antofagasta itself even flirted briefly (in its 2017 Annual Report) with the notion that Twin Metals had significant cobalt reserves.

The Biden administration is currently reviewing the actions the Trump administration took on Twin Metals and — maybe just as importantly — they are undertaking a review of the critical and strategic minerals supply chain. If it were to be fully developed, that purple plume of hypotheticals and inferences could become a real-world industrial corridor.

Update, 12 May 2021: According to a May 10 Settlement Agreement in Center for Biological Diversity et al. v. Mitchell Leverette et al. (a case in the US District Court of the District of Columbia), the Bureau of Land Management will review its May 1, 2020 decision authorizing the extension of 13 of the prospecting permits indicated on this map. The renewals were made without an Environmental Assessment under NEPA or an effects determination under the Endangered Species Act. These thirteen prospecting permits are for all intents and purposes suspended until BLM completes its review; Antofagasta agrees not to engage in any ground disturbing activities. Antofagasta’s two mineral leases are also under review at Interior and USDA, and we can expect some news on that front in the June 22 filing in Wilderness Society v. Bernhardt.

A Return to Science and a Push for Responsible Mining — Whatever That Means

New Boundary Waters documents arrived yesterday. I posted a short thread on Twitter as I reviewed them.

These records traverse familiar ground. Most date from January, 2018, when attorneys at Interior were preparing letters notifying the Forest Service and Twin Metals that the Solicitor’s Office had reversed the Obama administration.

For Twin Metals, this would mean that the Department of Interior had rescinded its rejection of their application for lease renewal. Not a green light — that would come more than a year later, in 2019 — but an encouraging sign of new and friendly disposition. For the Forest Service, the reversal would send an early signal that the two-year mineral withdrawal study would either have to favor renewal of Antofagasta’s leases (unlikely), or it would have to be cancelled if it were going to stand in the way of renewal. The issue raised questions about compliance with NEPA, as one heavily redacted exchange suggests:

It would be helpful to know more about how these attorneys saw the problem with NEPA at this time, especially when evaluating the action then-USDA Secretary Sonny Perdue in September of that same year, when under political pressure he abruptly cancelled the planned study.

The document trail invariably takes us back to that critical decision. It deserves careful and comprehensive review. There was some movement in this direction yesterday, when Senator Tina Smith wrote to Perdue’s successor at USDA, Tom Vilsack, and Secretary of the Interior Deb Haaland to ask that the BLM and Forest Service to start a new mineral withdrawal and segregation process and resume the study Sonny Perdue interrupted.

Smith’s letter calls for a return to science but recommends a more limited review than the situation warrants. She wants the agencies to determine whether copper and nickel can be “safely” mined in this area, and she also wants to present herself as a champion of Minnesota mining. It’s a move she seems to have learned from Amy Klobuchar.

Be that as it may, Smith offers Vilsack and Haaland one way forward over the next few months, during the court-ordered 90-day stay in Wilderness Society v. Bernhardt.

We must protect our precious wilderness. At the same time, we must pursue opportunities for both recycling and responsible mining of important mineral resources in the United States. If you believe—as I do— that the United States should lead the way in creating a clean energy future, then we must support public policy which allows for responsibly mining the minerals that this future requires. It is irresponsible and unethical to outsource exploitive [sic] labor practices and environmental degradation to other places while we reap the benefits. However, copper-nickel mining is not right for all places. There are some places too sensitive to mine. This is why we the [sic] mineral segregation and withdrawal study is so essential.

The letter simultaneously recommends precautions for the Rainy River Watershed and “responsible mining” to build “a clean energy future.” Those two things aren’t necessarily incompatible, but it’s unclear how this statement translates to coherent rule-or decision-making. It’s also the same line on mining that Secretary of Energy Jennifer Granholm has taken in recent public statements. How will the new administration determine what responsible mining for the clean energy future looks like? That is going to take some difficult conversations, but it’s not an issue Granholm, Vilsack, and Haaland can or should put off for very long.