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.
"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.
I always used J: (I didn’t expect to need to add that many hard drives).
I mainly did it so that CD installs wouldn’t lose their install drive since even Windows tracked it by the absolute path. Not as important with everything installed by download and Windows copying the install media to the hard drive anyway.
After C:, it really is just allocated in order.
Between CD/DVD drives, writers, Zip Drives, and extra hard drives, it wasn't unusual for a workstation to naturally end up with G: or H:, before mapped network storage became common.
> A was the first floppy drive, B the (typically absent) second floppy drive
As another commenter mentioned, when you didn't have a second floppy drive, A: and B: mapped to two floppy disks in the same floppy drive, with DOS pausing and asking you to insert the other floppy disk when necessary. Which explains why, even on single-floppy computers, the hard disk was at C: and not B: (and since so much software ended up expecting it, the convention continued even on computers without any floppy disk drive).
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.