MORE THAN JUST PARKS
PART IV · WHO PAYS AND WHO PROFITS CHAPTER 4 The haul
The road is justified as a domestic supply of critical minerals. The company's own technical report plans to sell the copper concentrate to smelters in China, Japan and Korea, can't sell the zinc to China at all, has no buyer under contract, and names no American smelter in about 475 pages, because the United States has almost nowhere left to process ore.
What this chapter finds
Trilogy's technical report for the Arctic deposit, the only reserve in the district, lays out the concentrate's journey segment by segment. Copper, zinc and lead concentrates, 1,289 wet tonnes a day, 470,586 a year, loaded into about 46 shipping containers daily from a fleet of 1,770.
| Segment | Mode | Distance | Trips a day |
|---|---|---|---|
| Arctic mine to the Ambler Road junction | Truck, single trailer | 16 km | 46 |
| Junction to the Dalton Highway yard, on the Ambler Road | Truck, double trailer | 324 km | 23 |
| Dalton yard to Fairbanks, on the public Dalton and Elliott highways | Truck, single trailer | 391 km | 46 |
| Fairbanks to the Port of Alaska | Rail | 573 km | 3 a week |
| Port of Alaska to an Asian port | Marine bulk carrier | 9,000 km |
Arctic Project S-K 1300 Technical Report Summary, Ausenco for Trilogy Metals, November 30, 2022, filed as Exhibit 96.1 to the Form 8-K of February 14, 2023: Section 15, Table 15-4, and the concentrate handling narrative (1,289 wmt a day, 470,586 wmt a year, 46 containers a day, 1,770 containers). The first two segments are the Arctic mine's own access road and the Ambler Road.
Moving it's the largest single cost in the plan after mining and milling. The report's transport estimate is $324.37 per dry tonne: $215.89 of it for the truck haul to Fairbanks, $33.92 for the rail, $24.21 at the port, $42.55 for the ocean, $7.80 for the container. Trilogy's most recent reserve estimate, in its 2025 annual report, carries a lower transport assumption of $270.98 per tonne, a cost it dates to July 2020, two years before the technical report's figure. We print both. The road toll the same reserve assumes, $8.04 a tonne, exists in no agreement. That chapter is here.
Technical Report Summary, Section 16.5, Table 16-3. Trilogy Metals Form 10-K, FY2025, p. 42 (transport) and p. 66 (toll).
"The proposed operations will produce copper, zinc and lead concentrates from the Arctic deposit on site, which will then be transported to be sold in the Asia Pacific area. There are currently no contracts in place with any buyers for the concentrate." Arctic Project Technical Report Summary, Section 16.1
The report is more specific by metal. For copper: "Trilogy will have the option of selling some portion of the Arctic copper concentrate under long term contracts directly to smelters in China, Japan, and Korea, with the balance being sold under shorter term or spot contracts to the trade, with the same delivery points," noting that "US origin copper concentrates may be subject to Chinese import duties." For zinc: "Because of the elevated level of cadmium, China will not be a market for the zinc concentrate." The section on the Chinese market opens: "The significance of the Chinese market for concentrate cannot be understated... China represents between 55-75% of the traded spot concentrate business in the world."
So the line that circulates, that the ore goes to China, is half right and the half that's wrong matters. Some of the copper may well go to Chinese smelters; that's the company's stated option. The zinc can't. And none of it, in the company's plan, is processed in the United States, because the plan names no American smelter and the report's economics assume an Asian one.
Technical Report Summary, Sections 16.3.1, 16.3.2 and 16.3.3.
A concentrate is crushed ore with the rock floated off. It has to be smelted before it's copper or zinc anyone can use. The United States has two primary copper smelters. It has one primary zinc smelter, which passed to a Korean owner in April 2026. It has no primary lead refinery. It already exports 52 percent of its copper-in-concentrate, 94 percent of its mined zinc and effectively all of its lead concentrate, because there's almost nowhere at home to send them.
The trade data for zinc concentrate shows what that looks like, and it shows something else too.
| US zinc concentrate exports by destination, zinc content | 2024 | 2025 |
|---|---|---|
| Canada | 242,600 t | 269,292 t, 41 percent |
| South Korea | 90,522 | 116,996 |
| Spain | 80,223 | 79,582 |
| Belgium | 31,618 | 57,406 |
| Japan | 39,405 | 52,351 |
| Australia | 63,502 | 48,116 |
| China | 95,834 | 0 |
UN Comtrade, HS 2608, United States reported exports, zinc-content basis, run August 2026. These are national figures; Red Dog produces most of the zinc mined in the United States, so they are a strong proxy for zinc and not for lead. China's 2025 zero is US-reported; China has not filed mirror data. Corroborated by Teck Resources, FY2025 management discussion: the company "worked proactively with our global customers to reposition zinc and lead concentrate from our Red Dog Operations impacted by Chinese reciprocal tariffs." Smelter counts and export shares from the same research pass, US Geological Survey and industry sources in our record.
China was the second-largest destination for American zinc concentrate in 2024 and absent from the list in 2025, after tariffs. The concentrate didn't come home. It went to Canada, Korea, Spain, Belgium, Japan and Australia. The destination list is allies and treaty partners, and the finding isn't who buys it. The finding is that it leaves at all.
The sharpest illustration is already running, on the mining road AIDEA already owns, to Red Dog. Red Dog's zinc concentrate carries germanium, a mineral on the federal critical list. It's recovered at Teck's Trail smelter in British Columbia and sold back into the United States as a Canadian product. Teck's own words: Trail "produces refined zinc and lead, and critical minerals such as germanium, indium and antimony," and "We sell refined zinc and lead, and specialty metals such as germanium... from Canada into the United States."
An American mine digs an American critical mineral, ships it to Canada because no American plant can extract it, and America buys it back as an import. The Ambler Road is being permitted on a critical-minerals rationale into exactly that system, with nothing in the permit, the federal stake or the tariff that would change it.
Teck Resources, 2025 annual report and management discussion. Roughly a quarter to a third of Red Dog zinc concentrate goes to Trail; the only published split is 2017, "approximately 30 percent," and we do not state a current figure as Teck's.
The presidential decision that reinstated the permits rests on national security: "The proposed Ambler Road will provide the access necessary for the development and production of... critical minerals" like cobalt, germanium and gallium, "which would reduce reliance on foreign sources." The Department of War's stake in Trilogy was made "eliminating foreign supply vulnerabilities." We state that rationale plainly and don't sneer at it. Copper is a genuine critical mineral, listed in November 2025.
Then read the documents for what they require. The investment agreement restricts who may own the company and who may buy its products, barring a defined list of foreign adversaries, and gives the government an observer, the right to name an independent director and a say over borrowing above $1 billion. It doesn't require that any concentrate be smelted in the United States. Neither does the fast-track permitting designation, the critical-minerals listing, or the Section 232 copper action, whose 50 percent tariff left copper ores and concentrates out. A national security investment in a mine whose product is planned for Asian smelters sits in plain view, in the technical report, the agreements and the tariff text, side by side.
Presidential decision, October 2025, p. 18. Investment Agreement of August 28, 2026, Exhibit 10.1 to the Form 8-K filed September 14, 2026, Section 1.1 ("Restricted Entity") and Article 5; Cooperation Agreement, Exhibit 10.2, Section 24. The Section 232 copper proclamation and its concentrate exemption, as recorded in our ledger. The stake in full is the deal chapter.
Of the 936 miles the government's screening counts to a port, AIDEA would build and toll 211. The rest, "approximately 725 miles," in the Bureau of Land Management's words, "would be utilizing existing transportation infrastructure," and the agency records that AIDEA "appeared to be comfortable with" a distance it calls "a high number." Trilogy's own annual report describes the Dalton as "an all-weather State maintained public road." The state spent about $16.5 million a year maintaining it as of 2019, has put $465.6 million of capital into it since 2015 with $454 million more planned through 2031, and its own fiscal note says turning it into a toll road without adding new capacity would cost it its federal-aid eligibility. Twenty-three double-trailer trips a day on the new road become 46 single-trailer trips a day on the public one.
2024 Final SEIS, Vol. 1, p. 573 (route screening); the comparison table gives 808 miles to Anchorage at p. 383 and the 2020 FEIS at p. 265, a different measure, and we print both. Trilogy Metals Form 10-K, p. 44 and p. 79. Technical Report Summary, Table 15-4 (trips). The Dalton's costs and the failed 2026 toll bill are the precedents chapter.
What this chapter doesn't say
It doesn't say the ore goes to China. The company's plan names Chinese, Japanese and Korean smelters as options for the copper, says the zinc can't go to China, and has no contract with anyone. The 2025 trade data shows American zinc concentrate leaving for allies. "It all goes to China" isn't what the documents show and we won't print it.
It doesn't say the national security rationale is a pretext. Copper is a critical mineral and the agreements do restrict adversary ownership and offtake. The finding is narrower and it holds: nothing in them requires that the metal be made in America, and the company doesn't plan to.
It doesn't say the two transport costs are a contradiction. $324.37 is the technical report's 2022 figure, and the $270.98 in the 2025 annual report is dated July 2020. They're different documents with different assumptions. We print both with their dates.
It doesn't treat the Red Dog port as Arctic's port. Red Dog barges to ships offshore; Arctic's plan ships from Anchorage. The germanium loop is about what happens after the ship, not the dock.
Overseas. The trip from the Arctic mine to a ship is 731 kilometers by truck, 573 by rail and 9,000 by sea, to "a smelter in the Asia Pacific region." The company's plan names "smelters in China, Japan, and Korea" for the copper concentrate, states that "because of the elevated level of cadmium, China will not be a market for the zinc concentrate," and says "There are currently no contracts in place with any buyers."
Arctic Project S-K 1300 Technical Report Summary, Table 15-4 and Section 16.The United States has two primary copper smelters, one primary zinc smelter, sold to a Korean owner in April 2026, and no primary lead refinery. It already ships about a third of the copper it mines abroad as concentrate, and 94 percent of its mined zinc, by the USGS's 2026 Mineral Commodity Summaries. Nothing in the federal stake, the fast-track designation, the critical-minerals listing or the copper tariff requires domestic processing, and the 50 percent copper tariff left copper concentrate out.
UN Comtrade HS 2608; Investment Agreement and Cooperation Agreement, August 28, 2026. Full citations under How we know on this page.Of the haul, 211 miles would be new road, built and tolled by AIDEA. About 725 miles would ride on the Dalton, the Elliott and the Alaska Railroad, which the public already built. The government's own screening of the route notes that about 725 of those miles would use existing infrastructure, and that AIDEA "appeared to be comfortable with" the distance.
2024 Final SEIS, p. 573; Trilogy Metals Form 10-K, FY2025, p. 42 and p. 44.The technical report is the company's own filing with the Securities and Exchange Commission, about 475 pages, and both it and the Bornite report were added to our document record for this chapter. The trade figures were re-run by us from the United Nations database rather than taken from a summary. Where a figure is national rather than mine-specific, or US-reported without mirror data, the caveat is printed with it.
The question this chapter puts to the road's sponsors is one sentence and it has never been answered: name the American smelter. If the road is a domestic supply of critical minerals, the metal has to be made here, and the company's own plan says it won't be. Ask the Department of War, which now holds about ten percent of the company, whether it will condition anything on domestic processing. Ask your delegation whether they would.
If you're a reporter, the technical report's Section 16 is four pages and it's the whole story. It's in our record, searchable, with the page numbers above.