Subject: File No.
From: Stacey Foreman
Affiliation: Sustainable Procurement Coordinator, City of Portland, OR

February 21, 2017

February 21, 2017

Dear Chairman Piwowar,

Thank you for calling for comments with regard to the Conflict Mineral Implementation Rule. My name is Stacey Foreman and I currently oversee implementation of the City of Portland, Oregons Conflict Minerals Resolution (Resolution 37150, passed by our City Council in August 2015). The Citys resolution specifically supports and builds upon the work initiated by Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank) by demanding transparency from our suppliers on their actions to build conflict-free supply chains for tin, tungsten, tantalum and gold (3TG). As demonstrated by the Citys Conflict Minerals Resolution, it is important to our constituents that the City seek to purchase electronics that contain 3TG from certified conflict free mines. The rule in question helps to make both this supplier transparency and conflict-free sourcing attainable.

Since the implementation of the Conflict Minerals Rule, we have seen the market value of minerals sourced from conflict mines decrease, thereby making the trade of these minerals less lucrative for armed groups and stabilizing formerly unstable mines and thereby promoting stability for local Congolese. Further, in 2016 the International Peace Information Service (IPIS) found that:

Three out of the four conflict minerals have largely become peaceful, as 79 percent of miners at tin, tantalum, and tungsten mines surveyed in Congo now work at conflict-free mines. This is a major change, as the U.N. stated in 2010 that "almost every mining deposit was controlled by a military group.


The number of internally displaced people has decreased from 3.4 million in 2008 to 1.9 million at the end of 2016.

( Conflict-Free Sourcing Initiative, Conflict-Free Smelter Program Indicators, available at (last accessed December 5, 2016).

Since 2010, we have seen the infrastructure required for companies to audit their supply chains develop and prosper. Companies such as Intel have remained committed to sourcing from the region, not to mention other companies which partner with nonprofit organizations such as The Enough Project and Eastern Congo Initiative to support local Congolese through farming of cocoa and coffee beans. The Conflict Mineral Rule is but one piece of the puzzle to help bring sustained peace to Congo, and its an important piece which must be built upon, not taken down.

As the primary staff person responsible for implementing the City of Portlands Conflict Minerals Resolution, I have experienced firsthand how useful and critical it is to have the Conflict Mineral Rule drive uniform reporting requirements and expectations. Without this Rule, there would be more ad hoc, disparate reporting requirements from public and private institutional purchasers, thus increasing costs for suppliers in responding to such procurement requirements. I support the standardized and publicly available Conflict Minerals reporting required by the Section 1502 of Dodd-Frank. Defunding or repealing this mandate will only not only reverse all the progress that has been made to decouple Congos mineral wealth from various rebel groups but also contribute to confusion in the marketplace for institutional purchasers such as the City of Portland seeking conflict-free supply chains and products.

I submit this statement to strongly affirm my support for Section 1502 of Dodd-Frank, the Conflict Minerals Provision pertaining to conflict minerals sourced from the Democratic Republic of Congo (DRC) and the surrounding region.

Stacey Foreman