SEMA Comments on USGS 2025 Draft List of Critical Minerals

The Solar Energy Manufacturers for America (SEMA) Coalition appreciates the U.S. Geological Survey (USGS) at the Department of Interior’s (DOI) leadership in advancing a resilient and secure domestic energy supply chain and welcomes the opportunity to provide input on the 2025 USGS Draft List of Critical Minerals. As detailed in the following comments, the solar manufacturing industry faces persistent vulnerabilities stemming from concentrated global supply chains, particularly for critical and byproduct materials. These materials are foundational to solar energy technologies and warrant inclusion in the critical mineral list. We commend USGS for considering the inclusion of silicon in the 2025 Draft List of Critical Minerals and urge the agency to consider maintaining tellurium on the list so the U.S. can build out every node of its domestic solar manufacturing supply chain. We can only achieve lasting resilience by addressing vulnerabilities across the entire supply chain.