August 21, 2026
Submitted via regulations.gov
Bureau of Ocean Energy Management
Office of Strategic Resources
45600 Woodland Road
Sterling, VA 20166
RE: Docket No. BOEM-2026-0100-0001, Request for Information and Interest: Commercial Leasing for Outer Continental Shelf Minerals Offshore the Commonwealth of Virginia
To whom it may concern,
The Responsible Battery Coalition (RBC) is a coalition of companies, academics, and organizations committed to the responsible management of the batteries of today and tomorrow. Founded in 2017, the RBC was created to advance the responsible production, transport, sale, use, reuse, recycling, and resource recovery of transportation, industrial, and stationary batteries, as well as other energy storage devices. RBC’s diverse membership spans the entire battery lifecycle and includes the world’s leading battery manufacturers, recyclers, automotive fleet management, automotive retail, and original equipment manufacturers. For more information: https://www.responsiblebatterycoalition.org/.
The RBC appreciates the opportunity to comment on the Bureau of Ocean Energy Management’s (BOEM) Request for Information (RFI) on offshore mineral leasing. As an organization committed to the sustainable, responsible management of energy storage technologies and their underlying critical-mineral supply chains, we strongly support the exploration of domestic resources. The critical minerals potentially present in the Virginia Offshore Minerals Project, including titanium and zirconium, are used in advanced battery technologies. Evaluating the Project is a critical step toward secure American supply chains and true national sovereignty.
Batteries are essential for transportation, industrial equipment, power plants, data centers, critical infrastructure, and defense applications. Expanding responsible access to domestic mineral sources can reduce reliance on foreign-controlled supply chains and provide American manufacturers with reliable resources. When paired with reuse and recycling, domestic production can help strengthen the circular economy by keeping critical materials within American supply chains longer.
Countering China’s Midstream Monopoly and Supply Chain Risks
Over-reliance on China for critical materials poses an immediate and severe economic and national security threat to the United States. Findings from the Coalition for a Prosperous America (CPA) and RBC joint report, "Wartime Footing: How the United States Can Reverse China’s Dominance of Battery Minerals Processing," emphasize that America's vulnerability is primarily "processing-constrained". Even when minerals are extracted globally, they flow heavily to China, which controls the vast majority of midstream refining and chemical conversion.
This severe concentration gives foreign adversaries strategic leverage to execute gray-zone economic coercion, weaponize export restrictions, and manipulate prices. For example, recent restrictions on antimony and other key materials directly disrupt U.S. defense infrastructure and automotive manufacturing. Diversifying upstream extraction and domestic processing establishes a parallel, resilient supply block. This ensures that next-generation energy storage can be built reliably without adversarial veto power.
Alignment with Recent Executive Actions on Defense Supply Chains
Advancing domestic critical mineral initiatives directly aligns with urgent federal mandates designed to secure defense manufacturing and protect critical infrastructure:
Strategic Support for the Virginia Offshore Minerals Project
The Virginia Offshore Minerals Project offers a practical opportunity to evaluate heavy mineral sand deposits containing titanium, zirconium, and rare earth element-bearing minerals. We support this initiative based on the following pillars:
Conclusion
The RBC urges BOEM to facilitate responsible exploration of domestic resources. Securing these pathways is essential to protecting national infrastructure, meeting recent executive directives, and ensuring a sovereign energy future.
Respectfully submitted,
Steve Christensen
Executive Director
Responsible Battery Coalition
1455 Pennsylvania Ave., NW, Suite 400
Washington, DC, 20004
