CDA Government Affairs Council Policy Positions

• CDA believes infrastructure funding should focus investment into solutions supported by resilient, long term, sustainable products and materials. This country needs to modernize and invest in the use of materials which have a demonstrated working service life of 50 years or more. As the world's oldest metal, copper is a proven, reliable material and is critical for many technological advances. Specifically, we believe in a definition of “infrastructure” which includes:
• Durable and Resilient Water Infrastructure: Robust, resilient and sustainable water and wastewater infrastructure materials like copper and copper alloy tube and fittings ensure safe drinking water and a clean environment for generations to come. To ensure long-term, safe and resilient operation of water and wastewater systems, funding and program prioritization should include recognition of local engineer decisions on system and material compatibility and use and require decisions based on total life-cycle cost, durability and expected life span of system components and materials. Lead contamination of multiple water systems has demonstrated the persistent and permanent danger of allowing drinking water to continue to be distributed through legacy lead service lines. Water infrastructure policy should prioritize near-term removal and replacement of the nation's entire lead service line inventory, with safe, reliable copper piping.
• Electric Vehicles, School Buses and Related Charging Infrastructure: Long-term funding for our nation's surface transportation is essential in modernizing our roads, bridges and transit systems. Copper is an essential component in leading-edge electric vehicles through its use in batteries, motors, wiring, and charging infrastructure. In addition to transition to the electrification of light-duty passenger vehicles CDA supports accelerating the build-out of high-speed, interstate EV charging infrastructure, policy that facilitates the expansion of electric school bus fleets, transit buses and heavy trucking for a cleaner, healthier economy and nation.
• Expedited Permitting for Transmission Siting for a Reliable & Secure Electric Grid: As demand on the US energy grid continues to grow the nation needs to support a transmission system that is resilient, reliable, and secure. Copper plays a critical role in the entire electrical grid. It is the world's most recyclable engineering metal, and can be used without degradation of its engineering properties like high conductivity, durability and energy efficiency. CDA supports policies that encourage undergrounding of electrical transmission and distribution infrastructure to improve grid resilience in the face of severe weather (hurricanes, tornadoes, floods), wildfires and other natural or manmade disasters.
• Green & Healthy Federal Buildings: The most efficient energy is the energy that you don't use. We call upon existing and new federal buildings to meet high-performance standards in electrical, thermal energy and water efficiency. Copper is a key component in these goals through electrical & mechanical systems, pipes, architecture and design elements. Copper's natural antimicrobial properties in particular help ensure the health and well-being of a building's occupants.

CDA fully support efforts to invest in our nation's infrastructure. In doing so, however, the federal government should not enact policies, such as the IMAGINE Act or other federal or state legislative efforts that favor particular materials or undermine the ability of communities to determine the best materials for their unique needs.

Copper should be formally recognized as a critical mineral. Copper is critical to our national security and intertwined with nearly every facet of the economy. With the copper supply chain at risk for disruptions and the unabating foreign demand for the mineral, there should be a concerted effort to streamline leasing and permitting processes for exploration, production, processing, and recycling of copper in the U.S.. These efforts should be based on sound economic, environmental and sustainability principles. Currently, the permitting and development of a new copper mine takes an estimated 10 years or more and is the most significant risk to mining projects in the U.S. and thus places the availability of this critical mineral at risk.

CDA opposes legislation which would impose a 12.5% gross royalty on the exploration and mining of copper, a new 8% royalty on existing mining, and a new 7-cent per ton dirt tax – these efforts will have devastating impacts on the availability of copper.

The United States must maintain a domestic supply chain of copper. While copper products contain roughly 35% recycled content, the world still needs 18.2M tonnes of new copper each year. For the US to keep up with demand, we must not hamstring domestic mining and exploration with costly royalties.

The copper industry is a responsible environmental and corporate citizen and is leading the way on responsible sourcing and production with the “Copper Mark”. Domestic copper producers also adhere to the International Council on Mining and Materials (ICMM) 10 Principles of sustainable mining. Existing environmental assurance standards and laws are strong and supported by CDA. Laws today give federal and state authorities broad inspection and enforcement authority including fines, operation suspension and criminal prosecution – preventing environmental abuse.

Copper is a highly efficient conductor. Because of this, it is used in renewable energy systems to generate power from solar, hydro, thermal and wind energy. Renewable sources today already provide nearly 25% of the world's power which is only expected to grow. Generation of clean energy from solar and wind use 4 – 6 times more copper than fossil fuels. Likewise, electric vehicles, powered by copper in the motors, batteries, inverters, wiring and in the charging stations, contain 4 times more copper than traditional vehicles. The clean energy economy of tomorrow is not possible without copper. CDA therefore supports legislation and policy which ensure the transition to a clean energy economy without placing undue burdens, regulations and costs on industry. CDA also supports strong funding for important research and initiatives at the Department of Energy including the offices of Energy Efficiency and Renewable Energy (EERE) and the Advanced Research Projects Agency – Energy (ARPA-E).

Copper alloys are safe, proven, EPA-registered engineering materials that are inherently antimicrobial and produced by multiple U.S. copper and brass mills to tightly controlled industry quality standards. EPA public health registration and over 200 peer-reviewed scientific papers have rigorously validated the broad-spectrum antimicrobial efficacy of copper alloys. Notably, surfaces made from copper alloys:

• Continuously kill >99.9% of bacteria including MRSA within 2 hours in EPA approved testing;
• Reduced hospital acquired infection rates by 58% in U.S. DoD clinical trials; and
• Begin inactivating the Covid-19 virus immediately, with complete inactivation of extensive viral loading in 4 hours as reported in a U.S. CDC/NIH study.

Unfortunately, despite these remarkable public health benefits, EPA regulatory burdens and costs have stifled the supply chain which has severely limited the commercialization, marketing and adoption of this evidence-based solution. CDA has called on the Federal Government to add an exemption for properly registered Antimicrobial Copper Alloy Products to 40 CFR §152.25 (g) of the FIFRA regulations to enact reasonable material producer versus end-use product requirements.

CDA is committed to promoting the proper use of copper materials in sustainable, efficient applications for business, industry and the home. For many reasons, a more sustainable future relies on the use of copper. CDA believes the basis for improving product, market and industry sustainability lies in transparency. We work collaboratively with our members to create transparency around the health-, environment- and sustainability-related considerations associated with the production, manufacture, and recycling of copper and its alloys. We do this by developing and sharing meaningful, credible, scientific knowledge and data with government decision-makers and other stakeholders, to inform policy decisions and ensure users can take full advantage of the benefits of copper.

We also encourage corporate, societal and environmental responsibility as demonstrated by, for example, the Copper Mark, an assurance framework set up to promote the responsible production of copper. Several CDA members have either received the Copper Mark for their sites or are Copper Mark partners, having made a public commitment to the Copper Mark's vision and objectives.