Atlas/Risks
Risk Register

Risks, tracked against evidence

Atlas surfaces risks and tracks their status against the evidence that supports them. It does not rank or resolve risks automatically.

R-001Spheronization capacity bottleneck
HighOpen
Graphite America·Updated 2026-02-11

Limited non-domestic facilities convert flake to battery-grade spherical graphite; delays here block the entire pathway.

Linked evidence: EV-001
R-002Qualification cycle length
MediumOpen
Graphite America·Updated 2026-02-20

Cell makers require long qualification lead times before switching anode suppliers, extending time to revenue.

Linked evidence: EV-004EV-007
R-003Water availability constraint
MediumMonitoring
Graphite America·Updated 2026-02-08

Processing facility siting in the Imperial Valley is sensitive to regional water allocation limits.

Linked evidence: EV-008
R-004Mozambique security and logistics exposure
HighOpen
Graphite America·Updated 2026-03-01

Security conditions in northern Mozambique introduce logistics and personnel risk for Cabo Delgado sourcing.

Linked evidence: EV-012EV-013
R-005Madagascar export infrastructure risk
MediumOpen
Graphite America·Updated 2026-03-03

Export infrastructure serving Madagascar deposits is less developed than Brazilian alternatives, raising logistics risk.

Linked evidence: EV-014
R-006Sri Lanka vein deposit volume risk
MediumMonitoring
Graphite America·Updated 2026-03-05

Vein graphite deposits typically yield lower volumes than flake sources, limiting scale-up potential.

Linked evidence: EV-015
R-007Tanzania rail dependency risk
MediumOpen
Graphite America·Updated 2026-03-07

Planned rail expansion serving Tanzania deposits is not yet complete, creating a timing dependency.

Linked evidence: EV-016
R-008Single-country concentration risk (Brazil)
MediumMonitoring
Graphite America·Updated 2026-03-09

Continued reliance on Brazil as the primary source region concentrates geopolitical and trade-policy exposure.

Linked evidence: EV-003EV-017
R-009Gulf Coast hurricane exposure
MediumOpen
Graphite America·Updated 2026-03-11

A Gulf Coast processing site would be exposed to seasonal hurricane risk affecting operations and logistics.

Linked evidence: EV-018
R-010Ontario site incentive uncertainty
LowMonitoring
Graphite America·Updated 2026-03-13

Canadian critical-minerals incentive programs supporting the Ontario site are subject to policy change.

Linked evidence: EV-019
R-011In-country Brazil processing capital risk
MediumOpen
Graphite America·Updated 2026-03-15

An in-country Brazilian processing site would require capital deployment in a jurisdiction with currency volatility.

Linked evidence: EV-020
R-012Non-domestic purification concentration risk
HighOpen
Graphite America·Updated 2026-03-17

Purification capacity remains concentrated in a small number of non-domestic facilities, mirroring the spheronization bottleneck.

Linked evidence: EV-001EV-021
R-013Purification capacity benchmarking uncertainty
LowResolved
Graphite America·Updated 2026-03-19

Initial uncertainty in purification throughput benchmarking has been resolved via direct facility audit.

Linked evidence: EV-022
R-014Domestic purification line unproven at scale
MediumOpen
Graphite America·Updated 2026-03-21

A domestic purification line has not yet been demonstrated at the scale required for full program volume.

Linked evidence: EV-023
R-015Spheronization single-region dependency
HighOpen
Graphite America·Updated 2026-03-23

Both primary and alternative spheronization facilities are located in the same broad region, limiting true diversification.

Linked evidence: EV-024EV-025
R-016Anode line qualification timeline risk
MediumOpen
Graphite America·Updated 2026-03-25

Cell Maker A's anode line qualification timeline has slipped relative to the original program schedule.

Linked evidence: EV-026
R-017Cell Maker B anode capacity constraint
MediumMonitoring
Graphite America·Updated 2026-03-27

Cell Maker B's anode line has limited spare capacity for a new material qualification cycle.

Linked evidence: EV-027
R-018Independent anode producer counterparty risk
LowOpen
Graphite America·Updated 2026-03-29

An independent anode producer being evaluated as an alternative has limited operating history.

Linked evidence: EV-028
R-019Port of Santos congestion risk
MediumMonitoring
Graphite America·Updated 2026-03-31

Port of Santos has experienced periodic congestion affecting bulk export schedules.

Linked evidence: EV-029
R-020Port of Beira infrastructure risk
MediumOpen
Graphite America·Updated 2026-04-02

Port of Beira's bulk handling infrastructure is less developed than alternative regional ports.

Linked evidence: EV-030
R-021Rail corridor capacity risk (Southern California)
LowMonitoring
Graphite America·Updated 2026-04-04

The Southern California rail corridor has adequate current capacity but limited headroom for peak-volume years.

Linked evidence: EV-031
R-022Vitória-Minas Railway shared-capacity risk
LowMonitoring
Graphite America·Updated 2026-04-06

The Vitória-Minas railway is shared with other commodity exporters, introducing scheduling risk.

Linked evidence: EV-032
R-023Bonded warehouse capacity risk
LowOpen
Graphite America·Updated 2026-04-08

Long Beach bonded warehouse capacity has not yet been contractually secured for program volumes.

Linked evidence: EV-033
R-024Feedstock warehouse siting risk
LowOpen
Graphite America·Updated 2026-04-10

The candidate feedstock warehouse site has not been confirmed against final processing-site layout.

Linked evidence: EV-034
R-025European transshipment cost risk
LowMonitoring
Graphite America·Updated 2026-04-12

Routing through a European transshipment point would add cost and transit time versus direct shipment.

Linked evidence: EV-035
R-026Grid interconnection timeline risk
MediumOpen
Graphite America·Updated 2026-04-14

Grid interconnection studies for the processing site have not yet been completed, creating schedule risk.

Linked evidence: EV-036
R-027Solar array permitting risk
LowMonitoring
Graphite America·Updated 2026-04-16

The candidate solar array supplementing site power has not yet secured land use approval.

Linked evidence: EV-037
R-028Land parcel title risk (Parcel A)
LowResolved
Graphite America·Updated 2026-04-18

An initial title review question on Parcel A has been resolved with no outstanding issues.

Linked evidence: EV-038
R-029Land parcel rail access risk (Parcel B)
MediumOpen
Graphite America·Updated 2026-04-20

Parcel B is farther from existing rail access, which would require additional inland transport infrastructure.

Linked evidence: EV-039
R-030Colorado River allocation negotiation risk
HighOpen
Graphite America·Updated 2026-04-22

Water allocation for the processing site depends on an unresolved regional negotiation among existing users.

Linked evidence: EV-040
R-031DTSC permitting timeline risk
MediumOpen
Graphite America·Updated 2026-04-24

California DTSC review timelines for comparable chemical-handling facilities have historically extended past initial estimates.

Linked evidence: EV-041
R-032County zoning approval risk
LowMonitoring
Graphite America·Updated 2026-04-26

Imperial County zoning approval is proceeding on schedule but is not yet finalized.

Linked evidence: EV-042
R-033Army Corps wetlands review risk
MediumOpen
Graphite America·Updated 2026-04-28

Federal wetlands review tied to water infrastructure could extend the overall permitting timeline.

Linked evidence: EV-043
R-034Air basin emissions compliance risk
MediumMonitoring
Graphite America·Updated 2026-04-30

Processing-site emissions would need to comply with Salton Sea Air Basin monitoring requirements.

Linked evidence: EV-044
R-035Cross-border habitat review risk
LowOpen
Graphite America·Updated 2026-05-02

Colorado River Delta habitat considerations could introduce cross-border review requirements.

Linked evidence: EV-045
R-036European customer qualification risk
MediumOpen
Graphite America·Updated 2026-05-04

A European offtake customer's qualification requirements have not yet been fully scoped.

Linked evidence: EV-046
R-037Grid storage customer volume uncertainty
LowMonitoring
Graphite America·Updated 2026-05-06

Grid storage integrator demand volume is less certain than primary battery-cell offtake.

Linked evidence: EV-047
R-038Process chemical supplier concentration risk
MediumOpen
Graphite America·Updated 2026-05-08

Sulfuric acid supply for purification currently depends on a single candidate supplier.

Linked evidence: EV-048
R-039Synthetic feedstock cost volatility
LowMonitoring
Graphite America·Updated 2026-05-10

Petroleum coke feedstock pricing for the synthetic hedge pathway has shown recent volatility.

Linked evidence: EV-049
R-040Federal loan guarantee approval uncertainty
MediumOpen
Graphite America·Updated 2026-05-12

Department of Energy loan guarantee approval timing and terms remain uncertain.

Linked evidence: EV-050
R-041Offtake prepayment structuring risk
LowMonitoring
Graphite America·Updated 2026-05-14

Prepayment facility terms are still under negotiation and could affect capital structure assumptions.

Linked evidence: EV-051
R-042Production tax credit policy risk
MediumMonitoring
Graphite America·Updated 2026-05-16

The critical minerals production tax credit is subject to future policy change.

Linked evidence: EV-052
R-043Mozambique jurisdictional policy risk
MediumOpen
Graphite America·Updated 2026-05-18

Mozambique's regulatory and export policy environment for critical minerals is still developing.

Linked evidence: EV-053
R-044Madagascar jurisdictional policy risk
LowMonitoring
Graphite America·Updated 2026-05-20

Madagascar's export policy for graphite has been broadly stable but is not contractually locked in.

Linked evidence: EV-054
IVR-001Water allocation constraint
HighOpen
Imperial Valley Corridor·Updated 2026-02-10

Colorado River allocation is fully subscribed to agricultural use; any industrial siting decision must account for this before land or power availability.

Linked evidence: IVE-001
IVR-002Unproven commercial-scale lithium extraction
MediumOpen
Imperial Valley Corridor·Updated 2026-02-14

Direct lithium extraction from geothermal brine has not yet been demonstrated at commercial scale at this specific site.

Linked evidence: IVE-003
IVR-003Border crossing congestion
MediumMonitoring
Imperial Valley Corridor·Updated 2026-02-17

Calexico crossing capacity is adequate today but sensitive to periodic congestion that could affect cross-border logistics scenarios.

Linked evidence: IVE-005
IVR-004Transmission backbone chokepoint
HighOpen
Imperial Valley Corridor·Updated 2026-02-24

New geothermal and solar generation cannot reach industrial load faster than the transmission backbone can be upgraded — the chokepoint is transmission capacity, not generation capacity. This constrains the power arm, the semiconductor candidate site, and the battery materials candidate site simultaneously.

Linked evidence: IVE-009
IVR-005Cascading water-to-industrial reallocation effect
HighOpen
Imperial Valley Corridor·Updated 2026-02-25

Any reduction in agricultural water use to free capacity for industrial siting cascades through the Agricultural Water District's allocation process and is affected by cross-border New River flow conditions — a change in one is not isolated from the other two.

Linked evidence: IVE-001IVE-010
IVR-006Semiconductor siting double-constraint
MediumMonitoring
Imperial Valley Corridor·Updated 2026-02-26

The semiconductor fabrication candidate site is simultaneously constrained by water allocation and transmission capacity, meaning resolving only one constraint would not be sufficient to unblock siting.

Linked evidence: IVE-011
Recent Activity
Risk Opened: Madagascar jurisdictional policy risk2026-05-20

Madagascar jurisdictional policy risk logged in the risk register.

Risk Opened: Mozambique jurisdictional policy risk2026-05-18

Mozambique jurisdictional policy risk logged in the risk register.

Risk Opened: Production tax credit policy risk2026-05-16

Production tax credit policy risk logged in the risk register.

Risk Opened: Offtake prepayment structuring risk2026-05-14

Offtake prepayment structuring risk logged in the risk register.

Risk Opened: Federal loan guarantee approval uncertainty2026-05-12

Federal loan guarantee approval uncertainty logged in the risk register.