To: U. S. Forest Service

Submitted by:
Nancy Freeman
P. O. Box 934
Green Valley , AZ 85622
520/398-4340
January 18, 2012

Comments on the NEPA cumulative effects

The NEPA process takes a comprehensive look at how the proposed project will impact the local environment, water levels and quality, wildlife and their habitat, and the well-being of the surrounding community. The cumulative effect was not addressed in the DEIS. To fulfill that requirement of NEPA my friends and neighbors have helped me compile a list of 145 reasons why the proposed mining project will cause untold pollution and depletion of our water supply, even though the Forest Service website states that “public concern about adequate supplies of clean water led to the establishment in 1891 of federally protected forest reserves.”

Further, we are told that we should refer to chapter and page in the DEIS for our comments. The sad truth is that many of the problems are issues that were left out of the DEIS, even though they were presented during the scoping period. For example, my extensive comments on TENORM, Technologically Enhanced Naturally Occurring Radioactive Materials. I presented a summary at the Sonoita hearing along with a hard copy. I also furnished the data on a webpage for ease of assessing documentation through links. Further, we were told during the scoping period that our comments would be answered individually. This did not happen.

Cumulative effects on Forest Service land by Augusta Resource Corp./Rosemont copper project

General Issues:

1) The first issue is the cumulative impacts of the region were not considered in the Rosemont Project DEIS.

2) The second issue is that we do not know how big the project will be. The EIS should evaluate the entire project, not just a piece at a time. The size of the project is an unknown:

a) From Augusta Resource/Rosemont Mining Plan of Operations: The properties on the west side of the mountains to be developed are called out in the 2007 Rosemont Plans: “… the Peach-Elgin deposit occupies a klippe floored by a low-angle fault. The Copper World Mine deposit is situated in a complexly faulted sliver of Palaeozoic rocks. The Broadtop Butte deposit is located on the western side of a complex fault system, as is the Rosemont deposit.” (pg. 4) www.augustaresource.com/Theme/Augusta/files/doc_downloads/Final_MPO_071107.pdf

b) The 2009 ASU Carey School of Business states that the Project is “an open-pit mining operation to be developed on a 15,000 acre site” (pg. 1) www.rosemontcopper.com/assets/files/reports/ASU%20Final%20Report11-09.pdf
Does the number seem impossible: in a news report it is stated that Rosemont Ranch is 30,000 acres. http://thewesterner.blogspot.com/2011/06/rosemont-ceo-says-worker-caused-may-2.html

c) From August Resource current Investor Presentation
“Our objective: Build and operate the world-class Rosemont Mine ; Develop a robust portfolio of copper assets in North America; Focus on early stage acquisitions and organic growth… Expected to be the 4th largest copper mine in the U.S. ” Also states: “Creates almost 3,000 jobs” (pg. 29)
www.augustaresource.com/Theme/Augusta/files/doc_presentations/Augusta%20Investor%20Presentation%20January%202012.pdf

d) From Augusta Resource: 2011 Financial report to stockholders:
“Mineralization also is known to occur in the Broadtop Butte, Copper World and Peach-Elgin deposits on the Rosemont Property, which could potentially add to the total mineral resource base of the Rosemont area…. A base case mining pit shell generated at metal prices of $1.75/lb Cu, $15.00/lb Mo and $10.00/oz Ag and anticipated operating costs was used to design an ultimate pit for mineral reserve estimation and subsequent mine planning.” (pg. 24) www.augustaresource.com/Theme/Augusta/files/doc_financials/AIFMarch292011.pdf  

3) Confirming their expansion plan, Augusta/Rosemont's mineral claims on the west side of the mountain are being backed up with purchases of private ranches in that area, 186 parcels listed on the County Accessor's records—including two ranches equaling 500 acres in 2010 on the west side of the Santa Ritas. More details: www.savethesantacruzaquifer.info/Rosemont-Mining-Properties.htm

4) This project does not comply with the Forest Service motto: “Caring for the lands and serving the people”. www.fs.fed.us/aboutus/chief/

5) This project does not comply with the stated Forest Service conservation goals on their website: www.fs.fed.us/aboutus

The website states that the agency's purpose is twofold: “(1) to make sure that America 's forests and grasslands are in the healthiest condition they can be; and (2) to see to it that you [the public] have lots of opportunities to use, enjoy, and care for the lands and waters that sustain us all.”

6) This project does not comply with Forest Service watershed goals as stated in their own reports, for example: Water and the Forest Service www.stream.fs.fed.us/publications/PDFs/Water_and_FS.pdf

This report focuses on the role of forests in water supply—including quantity, quality, timing of release, flood reductions and low flow augmentation, economic value of water from national forest lands, and economic benefits of tree cover for stormwater reduction in urban areas…

HEALTHY FORESTS ARE VITAL TO CLEAN WATER
Forests are key to clean water. About 80 percent of the Nation's scarce freshwater resources originate on forests, which cover about one-third of the Nation's land area….

MAINTAINING AND RESTORING WATERSHEDS WERE PRIMARY REASONS FOR ESTABLISHING THE NATIONAL FORESTS
Use and development of the water resources of the United States underwent major changes during the 19th century in response to the growing demands of a population that had increased nearly 20-fold since the founding of the country…

7) The land will never be the same: At a meeting (3/28/07), Mr. Bill Auby of Tucson Bureau of Land Management was asked if the land will be the same. Mr. Auby replied, “Given the many abandoned and failed reclamations throughout Arizona , that the public at large is left with, this [mining] is not in the public's best interest.”

8) The DEIS states that it is unable to examine the negative economic impacts of the mine due to such an examination being “speculative…difficult to predict and quantify.” Yet the DEIS confidently predicts the level of copper production and its impacts on employment and payroll 23 years into the future in its positive economic impact analysis [with anomalies as stated in no. 4) above]. The Forest Service's willingness to speculate on the positive impacts, but dismisses potential negative impacts clearly represents a bias.

9) Forest Service management objectives are inconsistent with the devastation of mining. The Organic Act was passed in 1897 to created Forest Reserves (later, renamed National Forests) to secure water & timber for the U.S. In Arizona and New Mexico this comprised 14% of the land, which produced 40% of the water. This Act was basis for successfully halting & modifying FS clear cutting practices, what is different about the devastation of mining—except with the toxic pit lake, it is worse.

10) The Santa Ritas are a blessing. They are just there, for themselves and for all, giving us beauty, water and oxygen. Once gone they're gone. We will be the thirsty guilty ones.

Forest Plan Issues:

11) The Santa Rita section of the Coronado National Forest formed to protect the region from devastation by mining and overgrazing by ranchers and preserve it for urban recreation. In fact, forest officials have complained about its degradation from overuse by recreationists.

12) Forest Service 1960 multi-use sustained Yield Act named Water, Wood, Wildlife, Grazing and Recreation. The local Forest Department (Mindy Roth) told me that mining was a part of their multiple-use mandate. Where did she get that information?

13) The Forest Service has circumvented an on-going (4 year) process on a revised Forest Plan. The plan that has been going through a public process has never mentioned mining. So why was the Amendment to the Forest Plan stuck in the Rosemont DEIS with no prior public notice as the Mining Plan had been accepted by the Forest Service in 2007. The Forest Service had plenty of time to bring up their intent during 2008 to 2010.

14) The current Forest Plan does not provide for mining in the proposed area. The Forest Plan contributors were most concerned about disturbance by ATV riders, while the Forest Service intends to permit haul trucks, which will have to pass through designated Forest Service land that is not on Rosemont's property holdings.

A description of the six alternatives considered in detail in this DEIS is provided in this chapter. Only the no action alternative (alternative 1) is consistent with the management direction contained in the “ Coronado National Forest Land and Resource Management Plan,” as amended (forest plan) (U.S. Forest Service 1986). The action alternatives (alternatives 2 through 6) would require a programmatic amendment that would permanently alter the Coronado 's forest plan for the area covering the proposed project area, along with the associated plan components for that area. (pg.44) www.fs.fed.us/r3/coronado/documents/DEIS-ch2Vol1.pdf

15) No public notice of a new Amendment proposed in page 89 in Chapter 2 has been given. The DEIS cannot serve as a Public Notice for an Amendment because this Public Notice was not given with the release of the DEIS. A notice tucked into the back of a chapter of a 1,000 page document does not qualify under the NFMA. I have been participating and receiving notices on the Forest Plan by e-mail. I received no notice.

16) We are dealing with a Forest Service personnel that states “a preliminary review of the proposed amendment indicate that it would likely not be a significant amendment to the Coronado Forest Plan.” (DEIS, pg. 95) A toxic pit lake forever, the destruction of 6,000 acres of forest forever that includes 33,000 mature trees? We deserve better.

17) There are Rosemont company contractor drill trucks on the Forest Service roads now that are not allowed on the Travel Management Plan, which was created by a public process.

18) At the present time, large drill trucks that take up the whole road in the Rosemont Junction area are a danger, much greater than ATV's. I had damage to a tire because of having to pull off the road into a sharp rock area to let one of them pass.

19) There is a precedent of destruction of watershed by dump trucks, etc. (not including haul trucks) in Oregon (where they have more water and trees than in Arizona ).

www.mining-law-reform.info/FSRuling.pdf

Cost to the public of potential law suits:

20) The highway safety issue is very grave, for the state highway where the trucks hauling ore and chemicals will be on a scenic two-lane highway, near an urban area. The people who live in this region have to use this highway to Tucson to get groceries. The safety analysis would have stopped any decent corporation short. Nevertheless, since the notice for the highway accidents and death are known and publicly posted, the accidents will occur with “foresight,” so it would not be considered an “accident” in a law suit.

From the Draft Environmental Impact Statement: Executive Summary, page xxv
http://www.fs.fed.us/r3/coronado/documents/DEIS-ExecSummaryVol1.pdf

Public Health and Safety

When combined with increases in traffic on State Route 83 resulting from population growth, the proposed action would result in traffic increases up to 10 to 88 percent during year 1 of the construction phase (under a 75 percent commuter carpool scenario), 128 to 290 percent during year 5 of the operation phase (no carpool scenario), and 204 to 356 percent by the end of mine life (no carpool scenario). A corresponding decrease in traffic safety would occur that may result in 61 to 107 accidents per year (from current rate of roughly 30 accidents per year), with a fatality occurring between one and two times per year (from a current rate of roughly one fatality every 3 years). By applying the mitigation measure of a partial carpool during the operation phase growth would be 67 to 135 percent at year 5 of operations and 137 to 201 percent during year 20 of operations. Direct impacts to public health and safety associated with traffic would remain after mitigation.

21) The Arizona Constitution has a “takings” clause, as the property value in the region of the mine will definitely be lowered: 17.  Eminent domain: just compensation for private property taken; public use as judicial question

Section 17.  Private property shall not be taken for private use, except for private ways of necessity, and for drains, flumes, or ditches, on or across the lands of others for mining, agricultural, domestic, or sanitary purposes.  No private property shall be taken or damaged for public or private use without just compensation having first been made, paid into court for the owner, secured by bond as may be fixed by the court, or paid into the state treasury for the owner on such terms and conditions as the legislature may provide, and no right of way shall be appropriated to the use of any corporation other than municipal, until full compensation therefore be first made in money, or ascertained and paid into court for the owner, irrespective of any benefit from any improvement proposed by such corporation, which compensation shall be ascertained by a jury, unless a jury be waived as in other civil cased in courts of record, in the manner prescribed by law.  Whenever an attempt is made to take private property for a use alleged to be public, the question whether the contemplated use be really public shall be a judicial question, and determined as such without regard to any legislative assertion that the use is public.

22) Forest service personnel are not following their own rules. There were 58 prosecutions in the past year for destroying a tree in the National Forest. Since there are 33,000 mature trees in the forest, it would be an opportunity for the public to recover the funds spent for management of the forests in this region since 1908, nearly 100 years. We were not paying the Forest Service to reserve these lands in trust for a mining company. We will be able to file a law suit against the individuals who have taken taxpayer salaries to enable this Rosemont Copper project, ignoring the Forest Plan and the their stated priorities and mission: Jim Upchurch, Reta Laford, Beverly Everson, Melinda Roth, Heidi Schewel, Jeanine Derby, John Able.

The penalty comes under Title 16 – Conservation, Chapter 3, Sec. 551.

Here are the relevant excerpts:

The Secretary of Agriculture shall make provisions for the protection of the forests against destruction, to regulate the occupancy and use and to preserve the forests thereon from destruction; and any violation of the provisions of this section or such rules and regulations shall be punished by a fine of not more than $500 or imprisonment for not more than six months, or both. Any person charged with the violation of such rules and regulations may be tried and sentenced by any US magistrate judge.

Here are the stated priorities of the Coronado National Forest that they should be accomplishing with taxpayer dollars. Destruction of 6,000 acres by mining flies in the face of all the Forest 's stated priorities:

• Biological diversity
• Quality outdoor recreation opportunities
• Fire protection and management
• Public relations and collaboration
• Organizational effectiveness

Economic Impacts:

23) The DEIS ignores the economic role of public lands, mountains and open space in supporting local economic health. In 2011, 100 economists urged Obama to protect public lands. Their letter states: The West's public lands contribute to our economic well being in a variety of ways, including resource extraction and recreation. These activities can and must coexist with expanding protections for America 's world-class natural amenities.
http://headwaterseconomics.org/wphw/wpcontent/uploads/Release_Pres_Letter_EconomicsProtected_Lands.pdf

24) The economic impacts in the DEIS were exaggerated by assuming that most of the equipment and supplies needed to operate the mine would be produced by and purchased from local business firms. This led to estimates of “indirect impacts” (i.e., benefits) that were 3 to 5 times too large. Contrary to previous announcements touting local purchases, it was recently reported in the local newspaper, that Rosemont announced it is seeking hundreds of millions dollars in loans from foreign lenders to buy equipment from companies in these foreign countries. Even now they are using a Utah company for their drilling.

25) The DEIS ignores the fact that destroying adjacent public land resources substantially reduces Tucson's attractiveness as a place to live, work, and do business.

26) We need to think of the impact on our grandchildren who will not have copper because a Canadian company had to take the easy copper now to furnish infrastructure in China , India and Korea ? The copper will only increase in value for future generations.

27) The Organic Act prevented the clear-cutting of our public Forests. What is different about this mining operation that will destroy 33,000 mature trees, including century old oaks, over 6,000 acres of forest lands?

28) The Federal government is spending millions on watershed restoration projects, yet they are considering permitting a project that will destroy a watershed that delivers water to the Tucson Basin and sustains a large conservation area.

29) The Federal Government is spending millions on forest restoration while considering a project that will destroy 6,000 acres of National Forests lands, including 33,000 mature trees.

30) Our real estate values are already bad. “ Tucson 's housing market has fallen so hard so fast that more than one in three homes sold last year went for less than $100,000….. Hundreds of homes sold last year at what can only be called extreme prices: 800 homes sold for under $35,000, nearly 300 of them going for under $25,000 and 15 going for under $10,000.” [From 1-1-2012 AZ Star]

31) Thirty-tree thousand mature trees, and thousands of small ones will be destroyed near an urban area while organizations all over the world are planting trees for the sake of watershed, production of oxygen and climate change, as the shade of trees prevent fast evaporation of rain.

32) The Forest Service has published information on the importance of forests for clean water, particularly in urban areas. www.savethesantacruzaquifer.info/FSGoal-of-Abundant-Clean-Water.htm

33) While the USGS is spending taxpayer money to investigate the “ Watershed Contamination from Hard Rock Mining,” the Forest Service is spending taxpayer money to enable a hard rock mine in our National Forest.

Watersheds affected by active and/or abandoned hard rock mining (HRM) often have hundreds of mining-related sites with little information on their relative significance as sources of metals contamination and acid mine drainage. Furthermore, natural weathering of the geologic deposits, which are sought out for metal deposits, can be a source of contamination even in the absence of mining activities. The nature of such distributed natural and anthropogenic sources makes a traditional site by site cleanup approach grossly inefficient and likely ineffective. http://toxics.usgs.gov/regional/mining/index.html

34) The Federal Government is proposing to permit a project that will destroy 6,000 acres of trees in Arizona , where the forest cover is only 4%, ranking it 43 rd in the U.S. What will it cost to replace 33,000 mature trees?

35) The value of my home will go down—will the mine pay for this depreciation?

36) The costs to taxpayers for government agencies to monitor this mining company, which has no mining record [except the bad records of their Environmental Manager at Cyprus Minerals, see nos. 8-9) below under “personnel”) and, as shown in no. 2) above and no. 40) below, they do not keep their records straight.

37) At best, mining operations become ghost towns sooner rather than later. Once a mountain is cut down, there is no way it can be reclaimed, no way to reforest the area. The Forest Service cannot claim to be stewards of the land if they allow Rosemont to move forward.

38) Would U.S. taxpayers eventually pay the price for reclamation (if any is possible), due to the possible bankruptcy of the owners of the mine...or the companies they sell the rights to?

39) Although we know that mining jobs are not going to solve any problem as there were three operating mines when the financial crunch occurred. The mining industry was not affected at this time and they have continued to have difficulty finding workers during all of 2011: www.savethesantacruzaquifer.info/CurrentJobs.htm

40) Augusta Resource and the Forest Service have had a problem with coordinating their numbers for jobs:

(a) Augusta Resource 2011 financial report: 1,000 indirect jobs, and 450 mining jobs.
(b) The Augusta Resource webpage states 1,700 indirect jobs, and 406 direct jobs, but these are numbers for a larger 15,000 acre operation that is mentioned in No. 2 (b) above.
(c) The DEIS states 2,400 jobs (during construction), and 350 to 480 annual jobs (Chapter 2, page 104)
(d) The Forest Service states 1,600 indirect job and 350 to 480 permanent jobs in presentation by Mr. Upchurch at Elgin and Green Valley hearings. (The Public Materials presentation has been removed from the Coronado National Forest website.)

Issues on Tax Revenue

41) Augusta claims they will bring money into the community, for example, they state annual property taxes, would equal $3.5 million. If so why are they circumventing paying their fair share of taxes by claiming agricultural use for their industrial facility at Hidden Springs Ranch? A year ago, I was told by their security guard that it was a construction zone and a hard-hat area. So why are they still paying only $348 taxes in 2010 on 160 acres = $2.18 an acre.
www.savethesantacruzaquifer.info/Rosemont.Facility.htm

42) Pima County taxpayers will have to pay for road improvements: $76 million for road improvements on 83 to I-10; $26 million to improve railroad siding

43) I do not want my state and federal taxes increased to pay for the road improvements necessary on State Highway 83 and the exchange onto Interstate I-10.

Cultural and Historical sites and artifacts

44) Research conducted for the Sonoran Desert Conservation Plan reveals that the Cienega Creek Valley is also rich in archaeological resources. Archaeologists from the University of Arizona began to investigate the Cienega Creek area beginning in the 1920s focusing on sites occupied by the Hohokam people, the ceramic bearing culture that settled the region between A.D. 750 and A.D. 1450.

45) The cultural home and sacred sites of the Hohokam, the ancestors of O'odham would be destroyed. All human societies treasure the historical sites of their ancestors.

46) Cultural Artifacts have been located and confirmed by the local Tohono O'odham Nation including a ball court and structures, pottery, stone tools.

47) The historical Andrada Ranch is listed on the 1800's map of the area along the Davidson Canyon .

48) Regional heritage tourism has a long term potential economically and intellectual study. The importance of experiencing cultural artifacts in a natural setting is being recognized of experts.

49) The ruins of the first Forest Service building in the region still remains.

Environmental Degradation

50) Canada 's Augusta Resource, through its proposed Rosemont Copper Mine in Arizona 's Santa Rita Mountains , will pump our groundwater, dump the mine waste on our public forest land and ship the ore out of the country.

51) Those mountains are living things. They are not simply a “view” or tourist destination. They are beautiful in and of themselves, disinterested and perfect. As living things ourselves, we often worship science and dismiss beauty. “Then beauty is its own excuse for Being,” wrote poet Ralph Waldo Emerson in the late 1800's, praising a certain flower in the woods and by extension all life. 

52) Since we are at the top of the food chain, we have the power. As power brokers, we are also stewards. What's the point of plundering this planet, our only home? Why not use our big brains to choose the wise caretaker path instead, to find better solutions to human needs and along the way protect water and water's best work, beauty? 

53) Davidson Canyon 's rare perennial and low-elevation desert waters feed Cienega Creek, also state designated as Outstanding Waters of Arizona, downstream were Pima County has established Cienega Creek Natural Preserve.

54) The pit will always be there, a danger to all wildlife.

55) There are 51 CERCLIS sites already in Arizona , according to EPA, Region 9 records.
www.savethesantacruzaquifer.info/CERCLIS.htm

Environmental Issues

56) On June 29, 2011, two months after the blaze that destroyed 2,000 acres, the Rosemont CEO says worker caused May 2 blaze. He said welding work done by a ranch hand working for the company accidentally sparked a fire that burned about 2,200 acres near the Santa Rita Mountains in early May. The ranch worker was welding a broken well bracket in the back of a pickup truck in a manner that followed procedures outlined in the ranch operation's permit to graze on federal land, said Rod Pace, Rosemont Copper's president and CEO. The fire started on the company's Rosemont Ranch, which spans about 30,000 acres of mostly federal land in the grasslands and oak woodlands east of the Santa Ritas and west of Arizona 83.

57) Eight months later, the “environmentally-advanced” company, is going to use the latest technologies to restore the waste rock piles, has not done any restoration.

58) The mining companies tout copper is needed green energy for wind turbines. However, according to the Department of Energy's report in 2008, copper is undesirable because it is too heavy. They recommend other technologies. www.nrel.gov/docs/fy08osti/41869.pdf

59) Pima County has designated Davidson Canyon as a Biological Core area and an Important Riparian Area within its Conservation Lands System, therefore, needs special protection from disturbances and damaging action.

60) Pima County had identified Davidson Canyon as one of six Critical Landscape Linkages in its Sonoran Desert Conservation Plan and in its Comprehensive Land Use Plan because large mammals and other unique species use this corridor to move between the Empire, Santa Rita, and Rincon mountains.

61) The reclamation promises are simply not feasible. The company still has not grown a blade of grass on their test plot in 4 years, with regular water and top soil!!

62) We see that the slopes of top soil scraped off Twin Buttes mine in the 1960's still remain without any vegetation. ASARCO did get some trees to grow with a drip system. As soon as they took the drips off, the trees died.

63) Dry stack tailings method is untried in this region and will be a producer of dust. The mining company is depending on rain (or watering) to make a crust on the soil… but it doesn't rain often in Arizona and when it rains it pours. The top soil will run-off in the storm water before it ever forms any crust. This webpage regarding flooding on the west side of the Santa Ritas, tells the whole story: www.g-a-l.info/Sahuarita-Flood.htm

64) Diversion of stormwater around the mine will be silted up in no time. It cannot work.
The linked photos below will show you what happened at Sahuarita Highlands when the County told a developer to just push some dirt over to the side of the wash to keep the storm water contained. The flooding started to occur about 2004, when water started spilling over the washes, sending sheet-flooding through the region. It has increased since that time.

All of the regions were already populated during the great 1983 and 1993 floods, and all the residents report none of their properties had any flooding (except on one property).

The washes in the region have silted up to 50% of their capacity or less. On the rare occasion that sand is taken out of the washes by the County, it is put along the banks of the wash, so that it just sweeps back in at the next rain to silt up the wash again. Here's what has happened downstream: www.tucsonpimawaterstudy.com/meetings/meeting_Archives/meetings/10.15.08/presentations/Stormwater%20Recharge%20v2.pdf

Note: This is the same unincorporated area, mostly with mobile homes, that Augusta Resource is taking its water from, so it is an environmental justice situation also.

65) The pipeline to carry water to the mine will cause undue stress to the community—their roads and the habitat across the valley.

Water considerations

66) To live, we must have water. It is essential for life-reaffirming beauty of nature and its life-giving oxygen.

67) Destroying 6,000 acres [or more as shown in no. 2) above] of watershed, along with 33,000 mature trees, will forever alter the ecosystem and climate of that region.

68) The mining company has already impacted the watershed by trucking water through a wash on the National Forest lands to Hidden Springs Ranch. What fine did the company pay for this infraction of rules?

69) A Federal Government agency is considering permitting a large water user in this urban region when the Federal Government as spent billions to bring water to Arizona urban areas. Construction began at Lake Havasu in 1973 and was completed twenty years later south of Tucson . The entire project cost of $4.7 billion to construct. $3.05 billion of the costs were footed by Federal taxpayers.

70) In addition, AZ state taxpayers pay in the CAWCD (CAP) counties of Maricopa, Pinal, and Pima pay $230 million annually of maintenance of the agency, whether they are being delivered CAP water or not.

71) Locally, in the Green Valley, Sahuarita region, state/county taxpayers spent $1,000,000 for a feasibility study bringing CAP (renewable supply) water to Green Valley and Sahuarita to offset the over-pumping of 40,000 acre feet annual. The $28 million cost for a pipeline was prohibitive. A later study has determined a pipeline could cost between $9 and $17 million. The Bureau of Reclamation is proposing another $500,000 study; half the cost would go to Federal taxpayers and half to local water users.

72) Rosemont project claims they will use 5,000 acre feet out of the Tucson Basin region, thus putting a burden on a region that is already drawing down at a rate of 5 ft. to 8 ft. annually. Further, they know that according to Arizona Water Law, mining is exempt from any groundwater rules and can pump as much as they need in the future, so they can always say the need more. These wells will deplete the water table west of the operations.

73) In addition to the 5,000 acre feet of groundwater, according to the current ADWR well registry, Rosemont project has claims for 103 exempt rural water wells (1 acre foot a year) and four industrial wells, from which they can pump as much water as the pump will pull up, but the usage has to be reported to ADWR. These are principally in the region of the forest itself that provides watershed through the Cienega Creek, then the Tucson basin. These wells will deplete the water table east (some are located west) of the operations.

74) The region where the mine proposes to pump the principal supply water in Sahuarita has been targeted by USGS as an area of subsidence due to the over-pumping in the region, particularly by agriculture, with established water rights, and two mines.

75) The pumping for mining operations (26,000 acre feet by Sierrita, a local, equal-sized mine in the region) will cause undue water shortages for desert habitat east and west of the mountain. (First, Rosemont Copper managers said it would be half the size of Sierrita, now they are saying they will have the 4 th largest mine in U.S. ) http://www.augustaresource.com/Investors/Overview/default.aspx

76) The water table will be affected by the pit. Some experts say that the cone of depression will remain and hold the water in the pit, which means water depletion in the region. Some experts say that the water will eventually level out, thereby releasing the pollutants into the water table. Either way the public loses.

77) In the report, “Predicting Water Quality Problems at Hard Rock Mines” (Maest, Kuipers), it was shown that o f the 25 mines sampled 60% of mines polluted surface water severely enough to exceed water quality standards. www.mining-law-reform.info/EIS_REPORT.pdf

78) In the same report, it was shown that at least 13 mines (52%) polluted groundwater severely enough to exceed water quality standards.

79) Taxpayers would have to pay for additional oversight on water: “Among their recommendations to improve future water quality predictions, Kuipers and Maest suggested that regulators be required to review past predictions at other mines when permitting new mines. They also recommend that regulators “should require better information about the mine site—before, during and after operations.” www.mineweb.com/mineweb/view/mineweb/en/page15831?oid=16510&sn=Detail

80) Many well-owners in the region of the mining supply wells have been misled by a contract with the company that states the company will drill their wells deeper when their wells run dry. They do not take into account the higher cost of electricity to pump from deeper wells, or the lowering of the water quality and the potential need for water treatment. Arsenic is prevalent in deeper water in the whole region.

81) I have been living in Sahuarita enjoying the use of a shared well which was about 300 feet deep. Just east of where I was living in Sahuarita Heights area, Rosemont was reported to be drilling test wells 1100 to 1200 feet deep claiming that this would not affect us. We were getting more and more sand from our wells— evidenced by buildups in the bottom of toilet tanks. It does not look good. Note: many well-owners in the region decided not to sign a contract with the mine, not wanting to enable mining.

82) Rosemont's projected water use is mind boggling. I installed water saver toilets in my home, and daily am conscious of not being wasteful of shower water or when brushing my teeth. So it irks me a lot to know that their mining use of water is unrestricted, and that their operation would even endanger the aquifer by chemical toxic pollution in addition to pumping it our “public” (that's what the Groundwater Code state) water supply dry.

83) A continual augmentation of the water quality problems in Green Valley has been the sulfuric acid spills due to faulty valves or breaks in the pipelines. [Data given in separate report.]

84) The toxic metal residues are high in the mill area. Since local Sierrita mine is on private land the data is sparse. In 1990 tests some of the toxic heavy metals were extremely high. The regulated level is given in parenthesis after the results.

Copper = 12,920 ug/l [10 ug/l], Iron = 3,720 ug/l [50 ug/l], Managese = 16,620 ug/l [10 ug/l], Zinc 26,030 ug/l [10 ug/l] [More data is given in separate report.]

Noise Pollution

85) Noise from blasting will affect the quality of life of animals and people.

86) Noise from heavy haul trucks and wide-loads will affect the quality of life of the region.

Air Pollution

87) We already have 3 copper mines in the region that dump dust on my house and hundreds of others when the wind blows in Arizona —which is often. The mines were here first, but their tailings impoundments are ever-growing: 8 feet per year.

88) I live in the Villages of Green Valley; I get major dust cover on my car in my enclosed carport whenever the wind blows.

89) The dust will affect the visibility at the Mt. Wrightson observatory, and for hundreds of astronomy hobbyists in the region.

90) The dust will coat the leaves of the trees in the surrounding area and affect their growth and production of oxygen.

91) There has not been an adequate analysis of the contaminants in the bedrock that could be airborne, such as chromium, uranium, arsenic.

92) They should have to monitor wind speeds and stop handling when winds exceed 25 mph to avoid the heaviest coverings of dust on the surrounding territory.

93) Valley Fever spores are transported by dust in top soil. Valley Fever is primarily a disease of the lungs caused by the fungus Coccidioides species, which grows in soils in areas of low rainfall, high summer temperatures and moderate winter temperature. The fungal spores become airborne when the soil is disturbed by winds, construction, farming and other activities. Infection occurs when a spore is inhaled. Within the lung, the spore changes into a larger, multi-cellular structure called a spherule . It can lead to lung infections when the spores are inhaled by people and animals. Symptoms include fever, chest pain and coughing. There were 877 cases of Valley Fever reported in Pima County in 2007. www.vfce.arizona.edu/ValleyFeverInPeople/WhatIsIt.aspx

Recreation:

94) We residents will lose up to 33 miles of public roads and trails

95) Some of the region would qualify for “wilderness” status. Try to access McCleary wash.

96) A five mile stretch of the Arizona National Scenic Trail that volunteers have put in hours to create will have to be moved.

97) I moved to Green Valley because it has splendid hiking nearby in peaceful, quiet environs.  The mine will change our whole easy access to hiking trails in the Santa Ritas.

98) I hike in Madera Canyon and I go there several times weekly to view the flora and fauna that will be negatively impacted by the blasting and mine disturbances.

99) Visitors come from all over the world to see the birds in Madera Canyon and Patagonia .  We will lose valuable tourist dollars if these areas are corrupted.

100) I take visitors on Scenic 83 to savor the beauty of Arizona's forests and scenic beauty....but would not do so if the mine were to be opened, reducing the scenic beauty, and their heavy truck traffic were to endanger our safety.

101) As a "birder" I would be greatly distressed to have a prime bird habitat and migration route destroyed, with no hope for eventual restoration—riparian areas and hundred-year-old oaks will not be replaced by grass seeds.

102) We do not want the access to the public lands, the National Forest, cut off from our hiking, biking, camping and enjoyment of nature.

103) Rosemont security trucks are already disturbing recreationists. In May, 2011, we had a large gathering to celebrate the oak trees on Forest Service land on Helvetia Rd. Large security trucks would pull off the road and circle our camp circle three or four times. This happened about every 30 minutes for 4 hours.

Highway and Road Safety

104) I use Highway 83 regularly for hiking trips and I do not want to be one the 2-6 people who will be killed by auto accidents each year.

105) School buses travel on Highway 83—we cannot put our children at risk competing with a haul truck on a 2-lane road. One accident is one too many.

106) The current Travel Management Plan that was created by public process does not include haul trucks in the National Forest land.

107) We who live along Highway 83 will be subjected to high volume of heavy truck traffic.

108) We who live along Highway 83 will be subjected to wide/oversized loads, for which there are special envoys. www.youtube.com/watch?v=T9nR4SiJCj8

109) Here's what it will be like in the construction phase with wide/oversized loads even at night when the wildlife roams. www.youtube.com/watch?v=t__kxbMdPJ0&feature=related

110) It is not practical or safe for haul trucks and wide-loads with heavy equipment on Helvetia Road . There are already headcuts at a wash near the Forest Information Stand due to the company's damage to the road because of their heavy use of it.

111) SR83 is currently used to route oversized loads from I-10 that are unable to pass under the Marsh Station railroad bridge or too heavy to travel over the Davidson Canyon bridge. The Arizona Department of Transportation mentioned this problem and suggested fixing I-10 to eliminate these oversized loads and reduce truck traffic on the scenic highway. Unfortunately this has still not been completed, nor is it planned.

112) There will be a danger of these oversized loads, shown in 107) and 108), to go over the dirt Forest Service roads.

113) In case of accidents or break-downs, very limited cell phone service.

114) Our windshields are chipped from road debris in truck tires.

115) Old Sonoita Hwy is only a chip and seal road that would have to be improved to handle mining haul trucks.

Light Considerations

116) More lights will ruin our precious, beautiful skies. 

117) The lights and dust will obscure visibility at Mt. Wrightson observatory and for hobbyist astronomers.

118) Adequate lighting is necessary for mine safety. In January of 1995, a fatality occurred at a waste rock dump area at the Sierrita mine site in nearby Green Valley , then owned by Cyprus Minerals Corporation. A Caterpillar dump truck backed over a berm, and turned over, fatally injuring the driver. There was no illumination provided at the dump area. The truck was equipped with two back-up lights that were quite dirty. The Labor Board investigated and required that portable lighting plants be installed at all dumping areas to provide sufficient illumination for safe dumping operations.

119) Haul truck speeds will not exceed 35 mph (MPO, pg. 11). This speed is inconceivable on these dirt roads. Back country off-road vehicles are permitted at 15 mph.

Wildlife and plants

120) The pit lake and sulfuric acid leach fields must be protect from migratory birds. In 2004, Phelps Dodge was fined $15,000 federal fine after dozens of migratory birds died from drinking acidic water at its Morenci copper mine.

121) The project will destroy homeland of a half-dozen animal species including deer, coatimundi, squirrel

122) Impact on two invertebrate species: sonoran and rosemont talussnail

123) Loss of two plant species (beardless chinchweed and Coleman's coral root)

124) Loss of agave, which is a source of nectar the lesser long-nosed bat, which is protected federally. Also, the Mexican long-tongued bat is considered a Federal Species of Concern.

125) The loss of a high biological significance area containing habitat for vulnerable species Gila topminnow, Gila chub, Mexican garter snake, lowland leopard frog, lesser long-nosed bat and many migratory birds.

126) State designated regionally critical wildlife corridor that runs underneath I-10, connecting the Santa Rita, Empire and Rincon Mountain ranges

127) Loss of priority vulnerable species listed on the Sonoran Desert Conservation Plan. www.pima.gov/CMO/SDCP

128) The Davidson Canyon includes perennial springs and is a good site for restoration of lowland leopard frog habitat.

129) Davidson Canyon is designated an Important Riparian and watershed area, in the biological core of the Conservation Land System and could be seriously jeopardized.

130) The habitat will be destroyed in a region has been designated as an Important Bird Area by Audubon Society.

131) The Forest Service is ignoring the fine work that Pima County has done in planning for and choosing the best areas for conservation. This mine will unduly impact the water supply to Bar V Ranch conservation project. www.pima.gov/cmo/sdcp/reports/d29/BarVReport.pdf

132) The Forest Service is ignoring the fine work done by BLM in the Las Cienegas National Conservation Area. This mine will unduly impact the water supply to this conservation project.
www.blm.gov/az/st/en/prog/blm_special_areas/ncarea/lascienegas.html

133) I do not want this area turned into a mining area instead of a choice area for bird watching. The Patagonia birding area was featured in movie: “The Big Year.”  

Health Issues:

134) I live six miles northeast of the proposed mine site. Our air is clean enough that I rarely have to rely on medication to breathe freely. I fear that the tremendous amount of air-borne particulates from the mining operations will force my husband and me to sell our home at a greatly reduced price so that we can move to where the air is still clean.

135) Arizona had been the haven for clean air for person with lung problems to come and recuperate. The mines in Pima County already have pushed the air quality curve to the point that even healthy people are suffering from sinus and allergy.

136) As mentioned in the air section, no. 92), Valley Fever is prevalent in this region. It should be added that visitors to the region can develop Valley Fever after returning home from the Southwest, and their physician may not be familiar with the disease. www.vfce.arizona.edu/ValleyFeverInPeople/WhatIsIt.aspx

137) There will have to be evacuation plans in case of spills of sulfuric acid or other chemicals used in mine processing. The residents and wild life would suffer the ill effects of the fumes, if not the liquid itself.

Impacts on well-being of community

138) I'm raising my children. I want to have a nice place somewhere out in the country and it's very sad to see that we may have our nice community being destroyed.

While it's true that I am a landscaper and I need work, it's not right what the mining company is doing destroying all these trees. They are hiring different contractors to cut them down in different regions, so no one contractor will realize the extent of their destruction.

139) I do not want my well-being and property values lowered because of the dust and declining water in this area because of the copper mine. 

140) It would grieve me to have our way of life destroyed for a product that would not even be used by U.S. businesses, the profits from which would accrue to a foreign business that is already in financial trouble, and that has never ever conducted mining.

141) I didn't move to Green Valley in order to live in a ghost town, which is surely what will happen if the mine goes in. We know how mining brings lack of prosperity. The copper region of Miami , Globe and Hayden look like a third-world country. Mining has been going on there continually for 100 years, including today. Of course, we have to omit Ray because it disappeared into the pit in an expansion program.

142) It is upsetting to attend public events (such as the free concerts under the stars at Reid Park ), and be bombarded with the publicity that Rosemont has contributed toward that event. Why do they feel they have to do all this Public Relations, including TV ads that insinuate the mine has already been permitted? if they are a legit company with legit methods, why are the smoke and mirrors?

143) If the company fails, it will just be another tax write-off for them, but the community will always have an impact of the mining scars and clean-up.

144) My solace during my 10 years of environmental work to help my community to get clean water and a water supply, which was impacted my mining, in Green Valley has been to go out to spend the night under a huge Emory oak and watch the stars twinkle through its branches in the black sky. That tree and hundred of other Emory oaks and white oaks—some of which are shown as mature trees on 100-year-old photos—will be destroyed.

145) I spent 6 years of my life to get clean water for my community of Green Valley. I sacrificed thousands of volunteer hours and my small life's savings. There are many others that have done the same in their communities because of the lack of foresight of government agencies. I don't want anyone else to have to make the sacrifice that I made. Please do your job and say “too much environmental and community degradation” to permit this project.

"The conditions of the forests and the wasteful manner in which their destruction is taking place give cause for serious apprehension."
—U..S. President Chester A. Arthur in 1882!!

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