Project 2025 plan targets mineral incentives, permitting, China trade issues

A more than 900-page document of recommendations for a future Republican US president takes aim at a host of mining-related regulatory and legislative issues.

The plan by the Heritage Foundation, a conservative think tank, known as Project 2025, features a repeal of a landmark climate law, permitting law overhauls, the reversal of public land mining withdrawals and actions to limit US supply chain dependence on China.

While some of the recommendations, like repeal of the Biden administration's signature energy and climate law, the Inflation Reduction Act (IRA), may be politically unpopular and difficult to implement, any that are adopted could shape the landscape of domestic mining and approaches to international mineral trade.

The plan aims to give a potential Donald Trump administration a running start if the former president is reelected in November. Though Trump has publicly distanced himself from the plan, its contributors include former senior Trump administration officials and individuals associated with Trump's campaign.

"Project 2025 does not speak for any candidate or campaign," a Heritage Foundation spokesperson said in a statement. "We are a coalition of more than 110 conservative groups advocating for policy and personnel recommendations for the next conservative president. But it is ultimately up to that president to decide which recommendations to implement."

The foundation did not respond to specific questions about the IRA and critical minerals.

Climate policy and industry funding

Project 2025 takes aim at major branches of the Biden administration's climate agenda, and critical mineral incentives are in the crosshairs.

The plan's call for repeal of the IRA, for example, would mean the elimination of a critical minerals production tax credit, along with the removal of federal incentives for mineral-intensive electric vehicles. Mining groups have called for the production credit, which equals 10% of the cost of production of certain critical minerals meeting purity standards, to be extended to upstream mining activities.

"What's weird about this is that the mining industry, the battery makers and the automakers, they all love the Inflation Reduction Act," said Aaron Mintzes, senior policy counsel at Earthworks, an environmental nonprofit focused on mineral and energy development. "I personally am skeptical that when push comes to shove and you have to vote 'aye' or 'nay,' that Congress would want to repeal all of the IRA."

Project 2025 also proposes the elimination of the Energy Department's Loan Programs Office (LPO), which, in addition to issuing loans for clean energy projects, has provided billions of dollars in grants and loans to critical minerals projects, including $2.26 billion for Lithium Americas Corp.'s Lithium Nevada operation. If an incoming administration cannot gain the congressional support necessary to cancel the LPO's billions of dollars in remaining loan authority, the document's backup option is for new loans to be restricted to electric grid, energy infrastructure, and national security-related projects.

The document calls for the repeal of the Infrastructure Investment and Jobs Act. Enacted in 2021, the so-called bipartisan infrastructure law enables appropriated funds and loan guarantees to go to critical minerals projects, paving the way for the LPO's offerings.

Mine permitting

Federal permitting procedures and public lands actions are another target of the plan, which calls for the White House Council on Environmental Quality to rewrite rules for project reviews under the National Environmental Policy Act (NEPA) in line with regulations the Trump administration introduced in 2020. The plan urges Congress to modify NEPA directly so the law may "meet its original goal" of acting as a "short, succinct, timely presentation of information regarding major federal action."

Proposed NEPA modifications include reduced consideration of climate impacts, page limits, and a pared back scope of judicial review, echoing the Trump-era changes and proposals introduced by Republicans in a March 2023 permitting package. Sens. Joe Manchin (I-W.Va.) and John Barrasso (R-Wyo.) introduced a long-awaited permitting bill of their own July 22, aiming to establish new deadlines for judicial reviews and agency actions linked to NEPA projects. The Trump-era changes backed by Project 2025 would instead set a one-year limit for environmental assessments and a two-year limit for environmental impact statements under NEPA.

Long lead times linked to NEPA reviews have been an ongoing mining industry complaint. Though the National Mining Association declined to comment for this story, mining groups backed the 2023 reforms.

On public lands, the Project 2025 document says a new president should restart the coal leasing program, which has seesawed between moratoriums and allowances of new coal leasing on federal land across administrations.

The plan also says an incoming administration should reverse the Interior Department's January 2023 land withdrawal in Minnesota's Boundary Waters area, home to Antofagasta PLC unit Twin Metals Minnesota LLC's proposed copper-nickel Maturi project. It also calls on Interior to approve the Ambler Road project in Alaska, which would act as an access road for Ambler Metals LLC to mine copper, zinc and cobalt in the region. Both moves would be deeply unpopular among Democrats.

"This isn't good governance or even good business — it's a political endorsement of unchecked corporate greed, plain and simple," Rep. Raúl Grijalva (D-Ariz.), ranking member of the House Natural Resources Committee, said in a statement to S&P Global Commodity Insights.

Cutting out China

Reducing Chinese influence in the global economy and curbing reliance on China is another major piece of Project 2025's recommendations.

While the document is divided on tariff use — one section calls for increasing tariffs on all imports of Chinese goods, while another calls for "tariff relief" — it does outline other suggestions to boost critical minerals supply chains.

The International Trade Administration, a US Commerce Department agency, should "spur action" on "emerging technologies," including rare earths, while the US State Department should prioritize relations with mineral-rich African nations, according to the document. The US should also rejoin the Trans-Pacific Partnership trade agreement, which includes mining heavyweight Canada. Trump withdrew from the partnership on his first day in office.