Letter of comment to DOC Titanium Sponge Working Group

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Robert J. Dickson
Dickson Consulting
14415 Bishar Lane
Charlotte, NC 28277
724-272-1527
bo@dicksonconsulting.biz
www.linkedin.com/in/dickson1/
January 3, 2021
United States Department of Commerce (DOC)
RE:
This letter is in response to the U.S. Department of Commerce’s Bureau of industry and
Security’s Titanium Sponge Working Group (TSWG) request for comments. My comments are
my own and they do not represent the views of any company.
China is the world’s largest producer of titanium and Russia is second largest. At least two
major US industries, aerospace, and medical devices, are dependent on a reliable supply of
titanium products. Without an adequate supply of titanium, airplane production and
maintenance could be limited. Medical devices, such as orthopedic implants, could not be
produced. The United States cannot put these two important industries at risk!
My experience in the titanium industry was as chief financial officer of Dynamet Incorporated
for almost 20 years. Dynamet processed titanium ingots for customers serving the aerospace,
medical device, and other commercial markets. A key learning from my experience is that the
supply of titanium is critical to these industries and that availability of titanium sponge and
ingots can be tight and subject to long lead times and price increases during peak periods in the
industry cycles.
Dynamet processed the titanium ingots into bar, coil, and wire stock. The bar stock was
principally sold to customers in the aerospace industry to use for jet engine turbine blades and
medical device companies for orthopedic implants. The coil stock was sold to customers to
manufacture fasteners used in the aerospace industry. Wire was sold to customers in the
medical device and other commercial markets. In addition, Dynamet forged and machined
titanium bar into orthopedic implants and components for aircraft.

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Dynamet sold the titanium bar, coil, and wire processing operations to Carpenter Technology
(NYSE ticker: CRS) and spun the titanium bar forging and machining operations into a stand-
alone privately-owned company. Both companies are still operating, although I am no longer
affiliated with either of them.
My comments for the TSWG follow. My comments are in support of TSWG protecting the U.S.
titanium supply. The various U.S. government agencies, in cooperation with U.S. businesses,
are in a better position to evaluate how to do this than I am.
Comprehensive Review of Financial and Other Regulatory Filings. Companies significantly
involved in the titanium industry, particularly publicly traded companies, will disclose
information relating to their operations, contractual agreements, etc. in their periodic filings
with the Securities & Exchange Commission and other regulatory agencies. Accordingly, the
TSWG should have a compressive review performed of these filings, along with the company’s
websites, to obtain information relevant to the request for comments. Such companies would
include Boeing, Airbus, Allegheny Technologies, Carpenter Technology, Timet, RTI Technologies,
Sumitomo, VSMPO-AVISMA and The Perryman Company. Others should also be researched.
U.S. Manufacturing Base. It should be an objective of the DOC to restore and grow the
manufacturing base in the United States. Accordingly, every effort should be made by the US
government to incentivize and support processing of titanium sponge and products in the
United States.
Intellectual Developments. In the future, improvements in process and alloys may develop and
it would be preferable to retain these intellectual developments under the control of U.S.
companies. Every effort should be made by the U.S. government to retain these intellectual
developments.
Employment Base. Processing of titanium sponge and products in the U.S. supports the
employment base and provides quality jobs. It should be the objective of the DOC to support
the growth of the U.S. employment base in this industry and every effort should be made to
incentivize, support and strengthen this employment base.
Tariffs. Tariffs should be used when necessary to discourage dumping of titanium products into
the U.S. and to enable fair trade. Any funds received by the U.S. from tariffs should be invested
in U.S. titanium processing operations.
Stockpiling. Consideration should be given to the U.S. stockpiling titanium ingots during period
of low demand for use in an emergency situation for the defense and critical non-defense
industries.
Partnership/Joint Venture with Non-U.S. Titanium Sponge Producers. The U.S. foreign policy
efforts should include identification of and establishing strong relations with non-U.S. titanium,
sponge producers and establishing strong, diplomatic relations to the extent possible.

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Pandemic. A lesson learned from the Covid-19 pandemic is that the U.S. cannot leave itself
exposed to over reliance on foreign supply chains and producers. Accordingly, the U.S. must
plan for a worst-case situation to protect the U.S., it’s citizens and critical industries.
I hope that these comments help. Please contact me if I can be of additional assistance.
Sincerely yours,
RobertJ.Dickson
Robert J. Dickson