Mining next to ecologically sensitive protected areas poses material climate, regulatory and reputational risks.

At 438,000 acres, the Okefenokee Swamp is one of the world's largest freshwater wetlands. Over 402,000 acres are protected in the Okefenokee National Wildlife Refuge, the largest refuge in the eastern United States and home to hundreds of plant and animal species. The Okefenokee also stores over 400M tons of CO2 equivalent, making it one of the largest natural carbon sinks in North America.

Twin Pines Minerals, LLC (TPM) has applied for permits to mine titanium on Trail Ridge, the swamp's eastern hydrologic boundary, for production of titanium dioxide. TPM's northern neighbor has publicly called for mining on its land and TPM's new western neighbor has leased its land for titanium mining elsewhere in Georgia.

As Home Depot is a major carrier of titanium dioxide-based paint, links between the company's paint products and titanium mined on Trail Ridge could expose the company to unnecessary risks:

Climate: Overwhelming scientific consensus states that TPM's project would significantly damage the Okefenokee by drawing down its water level and increasing risk of drought and landscape-level fires. Such events would destroy wildlife habitat, damage thousands of acres of timberland and release significant carbon emissions. Home Depot's greenhouse gas emissions could skyrocket in the event of a major peat fire, as the carbon stored in the Okefenokee is over 100 times greater than the Company's 2022 Scope 3 emissions. Any link to mining at the Okefenokee would conflict with Home Depot's efforts to reduce emissions and mitigate climate risk, all while exacerbating the business performance risks associated with climate change.
Regulatory and Legal: The 2023 Okefenokee Protection Act, which would prohibit mining on Trail Ridge, garnered 96 bipartisan cosponsors in Georgia's House of Representatives and will return in 2024, presenting regulatory risk. Furthermore, organizations with a history of litigating to protect natural resources have publicly criticized the project, and potential litigation from timber companies suffering fire damage to their assets present additional legal risk.
Reputational: In early 2023, over 100,000 comments were submitted to Georgia's Environmental Protection Division opposing TPM's draft Mining Land UsePlan and approximately 70% of Georgians want Governor Kemp to deny TPM's permits. Okefenokee is being nominated for inclusion on UNESCO's World Heritage Site List, and the issue has received significant media coverage in the New York Times, Wall Street Journal, AP and Bloomberg.
A commitment to avoid sourcing titanium dioxide from the Okefenokee would help Home Depot more fully operationalize the conviction articulated in its 2023 ESG report, "when we invest in running a responsible, sustainable company, we make our business stronger, more agile, and more resilient."