It's just whatever happens to end up there? That's why D was typically the CD-ROM: A was the first floppy drive, B the (typically absent) second floppy drive, C the only hard disk, and then D was the next free letter.

On my laptop, D is the SD card slot. On my desktop, it's the 2nd SSD.

When recordable CDs were brand new, we set up a station at work with two hard drives (C: and D:) and the CD burner (E:). Naturally, the CDR burning software was hard-coded for D: but didn't mention that anywhere (including the error message). Took us a few hours to figure it out.

"That's why D was typically the CD-ROM:"

We used to set our machines so the CD-ROM was always drive L. This way we always had 'room' to add HDs so there was no gap in the alphabetical sequence. Drive D - data drive, E - swapfile, etc.

Test and external drives (being temporary) were assigned letters further down than L. Sticking reasonably rigidly to this nomenclature avoided stuff-up such as cloning an empty drive onto one with data on it (cloning was a frequent activity).

Incidentally, this rule applied to all machines, a laptop with HD would have C drive and L as the CD-ROM. Machines with multiple CD-ROMs would be assigned L, M and so on.