National Environmental Policy Act Scoping Comments for the Proposed Rosemont Copper Project Environmental Impact Statement

OVERVIEW: This scoping document contains comments on the Proposed Rosemont Copper Project (hereinafter “Mine”) in accordance with the National Environmental Policy Act of 1969, as amended (P.L. 91-190, 42 U.S.C. 4321-4347, January 1, 1970, as amended by P.L. 94-52, July 3, 1975, P.L. 94-83, August 9, 1975, and P.L. 97-258, § 4(b), Sept. 13, 1982) (hereinafter “NEPA”).

The document is divided into two main sections: (I) Potential Impacts of the Mine and (II) Alternatives to the Mine.

The Potential Impacts of the Mine section is organized into eleven major topics: (1) water resources, (2) pollution and safety, (3) scenic and recreational values, (4) wildlife and wildlife habitats, (5) regional rural economy, (6) electric power, (7) historic and cultural resources, (8) mine operator’s experience and qualifications, (9) mine remediation, reclamation, and closure, (10) emergency services, and (11) cooperating agencies. There is a lead comment for each major topic.

Within each major topic there may be subtopics with a narrowly focused comment for each. For each major topic or subtopic there may also be recommendations for potential measures for mitigation of adverse effects arising from plans or activities proposed by Augusta Resource Corporation/Rosemont Copper Company, Inc. (hereinafter “Augusta” or “Applicant”) in its Mine Plan of Operation (hereinafter “MPO”). The Potential Impacts of the Mine section closes with a Summary Statement.

The Alternatives to the Mine section sets forth a number of alternatives to the proposed Mine that may eliminate or reduce the environmental impacts of the proposed Mine. For each alternative there may be identified a number of comments in the Potential Impacts of the Mine section to which the alternative applies. Following the Alternatives to the Mine section are References and Attachments.

I. Potential Impacts of the Mine

COMMENT 1: ADVERSE IMPACTS OF THE MINE ON THE REGION’S FRAGILE WATERSHEDS AND INCREASINGLY STRESSED GROUNDWATER RESOURCES ARE CERTAIN, ARE UNDERESTIMATED BY AUGUSTA, AND MUST BE FURTHER AND INDEPENDENTLY STUDIED TO BE SUFFICIENTLY UNDERSTOOD AND AVOIDED OR FULLY MITIGATED. Independent hydrological studies estimate that the Mine will intercept substantial surface water that flows to the Davidson Canyon Wash. The same studies warn that dewatering of the Mine’s pit could significantly lower the groundwater levels south and north of the Mine in the region east of the Santa Rita Mountains. The Mine’s water production wells near Sahuarita in the Santa Cruz basin west of the Santa Rita Mountains will affect the basin’s ground water levels and nearby existing wells.

There are substantial remaining uncertainties pertaining to water runoff, recharge, evapotranspiration, and storage properties in the region east of the Santa Rita Mountains. The disruption of the water runoff and lowering of the local groundwater table by the Mine further may threaten the surface water of the Cienega Creek, classified by the U. S. Fish and Wildlife Service as a critical habitat for the Gila Chub (Gila Intermedia) which is designated as endangered with critical habitat under the Endangered Species Act of 1973. There is also a potential for the Cienega Creek to be polluted from the Mine operations during heavy rains. Independent original studies must be undertaken to produce for the Forest Service valid and reliable empirical data concerning the Mine’s impact on the quantity and quality of regional surface water and groundwater sufficient and necessary for developing the Environmental Impact Statement (hereinafter “EIS”) and demonstrating compliance with the Regional National Forest Policy on Groundwater.

COMMENT 1A: THE EXTENT THAT THE MINE’S WASTE ROCK, TAILINGS, AND ACID LEACH FIELDS DEPOSITED BEHIND CONTAINMENT BUTTRESSES IN BARREL AND OTHER NEARBY CANYONS WILL DISRUPT SURFACE WATER CHANNELS FLOWING INTO THE DAVIDSON CANYON WASH REMAINS UNDETERMINED.

Discussion: The Coronado National Forest Land and Resource Management Plan states the following:

“Much of the water used in Southern Arizona and New Mexico originates on the mountain Watersheds of the Coronado. Competition for available water is rapidly increasing, and concern is growing about quantity, and quality. The issue can be stated as follows:

1. Management of forest resources to protect or enhance watershed condition from both a hydrologic function and soil productivity standpoint.”

An independent hydrological study commissioned by Pima County (see Attachment A which is incorporated herein by reference) estimates that the Mine will intercept approximately 650 acre-feet per year of water flow to the Davidson Canyon Wash which in turn flows to the Cienega Creek—an important contributor to greater Tucson’s water supply. The amount that will be intercepted is approximately the same as the current flow that reaches the lower Cienega Creek from Davidson Canyon. The nearly 3,000 acres of waste rock, tailings, and acid leach fields will forever alter the Davidson Canyon Watershed and Cienega Creek.

Mitigation:

· Explicit Performance Standards must be established and continuously monitored by an independent entity at the ongoing expense of Augusta to ensure that the existing water quantity and quality is met during and following reclamation and closure. Such monitoring shall continue indefinitely until an independent entity can scientifically confirm that no long-term adverse effects exist.

· The proposed “Central Drain” does not address the adverse impacts of “upstream” surface runoff containing toxic materials entering the Davidson Canyon Watershed, Cienega Creek, and Pantano Creek. Mitigation of such adverse impacts must be provided and conclusively demonstrated via stringent performance standards and on-going monitoring (see above). A National Pollutant Discharge Elimination System (NPDES) permit will be required under the federal Clean Water Act (CWA). This will apply to liquid waste applied to land or released into waters of the nation, and to runoff from the site. In fact a permit would be required to re-inject the waste water into the groundwater basin.

COMMENT 1B: THE EXTENT THAT DEWATERING OF THE MINE’S PIT WILL ALTER THE LOCATIONS, LEVELS, AND/OR QUALITY OF GROUNDWATER IN THE REGION REMAINS UNDETERMINED.

Discussion: The Mine’s open pit, which may be as deep as 2,900 feet, will likely invade the ground water resources on the east side of the Santa Rita Mountains. Dewatering of the pit through pumping could dry up or significantly lower the water levels in the many existing residential and other wells in the region east of the Santa Rita Mountains. A hydrological study commissioned by Pima County (see Attachment B which is incorporated herein by reference) estimates that dewatering of the Mine’s pit could lower the regional ground water table by as much as 2,000 feet. Drilling at a cost of $30 per foot to increase the depth of these existing wells to reach a significantly lowered water level will place an unjustifiable financial burden on their owners. Furthermore, Augusta’s proposed recharging of the Santa Cruz basin (see COMMENT 1C) will not benefit the depleted ground water resources east of the Santa Rita Mountains.

Mitigation:

As a condition of Forest Service approval of Augusta’s MPO, Augusta and any successors in ownership of the Mine must be required to enter into a well protection agreement with the owner(s) of each existing well that could be adversely affected by the Mine. Moreover, as a condition of Forest Service approval of Augusta’s MPO, Augusta and any successors in ownership of the Mine must be required to agree in writing to pay all expenses necessary to restore fresh water service to all affected homes and businesses in the event the Mine pollutes the groundwater in the region east of the Santa Rita Mountains.

COMMENT 1C: THE ADVERSE IMPACT OF THE MINE’S PRODUCTION WATER WELLS ON REGIONAL GROUND WATER RESOURCES ARE UNSUSTAINABLE GIVEN ANTICIPATED POPULATION GROWTH IN PIMA AND SANTA CRUZ COUNTIES AND INCREASINGLY STRESSED WATER RESOURCES.

Discussion: Augusta plans to develop six high-volume production water wells in the Santa Cruz basin to the west of the Mine—also an important contributor to greater Tucson’s water supply—with a combined pumping rate of up to 9,000 gallons of ground water per minute. Despite a declaration in the MPO that the Mine will require 5,000 acre-feet of ground water per year, Augusta applied for and the Arizona Department of Water Resources (ADWR) issued Augusta a withdrawal permit for 6,000 acre-feet of ground water per year or 114,000 acre-feet over the 19-year lifetime of the Mine. According to ADWR calculations, 6,000 acre-feet of water is sufficient to meet the residential needs of 30,000 people for one year—equivalent to the population of Marana, Arizona. In total, after 19 years, the Mine will have pumped a minimum of 40-billion gallons of ground water from the Santa Cruz basin. Depletion of regional ground water on this scale will not be sustainable.

According to the ADWR, about 40 percent of the state's water use comes from groundwater sources. For over a hundred years, Arizona’s groundwater has been pumped out more rapidly than it has been replenished. This is especially true in Pima County. By continuing to overdraft the state's groundwater supplies, the state’s ability to ensure a secure water supply for the future is at risk. Despite an already stressed ground water supply and significant anticipated population growth in Pima and Santa Cruz counties, Augusta will have no legally enforceable obligation to replace, as it proposes, the ground water that it uses with water deliveries from the Central Arizona Project (CAP). Also, the recharge facility near the current terminus of CAP cannot, as Augusta proposes, replace the ground water lost to the Mine’s production wells far to the east. And, even if it could, 6,000 acre-feet per year represents 25 percent of the recharge facility’s maximum net recharge capacity. Lastly, the ground water that Augusta will remove for use at the Mine is of very high quality, while the CAP water that Augusta proposes as a replacement for groundwater lost to the Mine is of very low quality. This is a bad trade for the people who will be drinking the replacement water.

There is a growing number of increasingly competing municipal, tribal, and commercial interests vying for diminishing CAP water resources. Long-range forecasts are predicting continuing drought conditions and decreasing rainfall and snowmelt runoff in the upper Colorado River watersheds. When mandated Colorado River water allocations to California, Nevada, and pre-CAP Arizona cannot be met, Colorado River water diverted to CAP will be reduced under Federal law. Augusta, consequently, cannot guarantee that sufficient CAP water will be available to replace the ground water that it uses.

According to the MPO, Augusta does not plan to develop high-volume production water wells east of the Santa Rita Mountains. If such production wells were to be developed, however, they would have an adverse impact on existing residential and other wells nearby. Protection of Arizona’s diminishing high quality water resources must be given priority over protection of hard rock mining interests in Arizona.

Mitigation:

· Augusta’s proposed mitigation through groundwater recharge is flawed due to the unreliability of water sources for such recharge. Chronic drought conditions in the arid Southwest in combination with the projected population growth of the Phoenix/Tucson region severely reduce the long-term unreliability of CAP water. This situation is exacerbated by the legal limitations of CAP’s Junior Water Rights.

· As a condition of Forest Service approval of Augusta’s MPO, Augusta and any successors in ownership of the Mine must be required to agree in writing that it will voluntarily replace the ground water that the Mine uses or reduce the amount of ground water that the Mine uses to amounts that can be replaced by Augusta.

· As a condition of Forest Service approval of Augusta’s MPO, Augusta and any successors in ownership of the Mine must be required to enter into a well protection agreement with the owner(s) of each existing well that could be adversely affected by the Mine’s production wells wherever they may be.

· As a condition of Forest Service approval of Augusta’s MPO, Augusta and any successors in ownership of the Mine must agree in writing that should CAP allocations be reduced, the Mine’s reduction in CAP water will not be replaced at the expense of the citizens of greater Tucson, Green Valley, Sahuarita, or rural Pima County east of the Santa Rita Mountains, even if that will require slowing or stopping activity at the Mine.

COMMENT 2: AIR, NOISE, TRAFFIC, AND LIGHT POLLUTION BY THE MINE ARE CERTAIN. SOIL AND WATER POLLUTION BY THE MINE ARE MORE LIKELY THAN NOT DURING THE LIFETIME OF THE MINE AND FOR AN UNKNOWN NUMBER OF DECADES AFTER CLOSURE OF THE MINE. THESE ADVERSE EFFECTS ARE UNDERESTIMATED BY AUGUSTA AND MUST BE FURTHER AND INDEPENDENTLY STUDIED TO BE SUFFICIENTLY UNDERSTOOD AND AVOIDED OR FULLY MITIGATED. Of the ten Arizona facilities releasing the most Toxic Release Inventory (TRI) chemicals to the air, soil, and water in 2002 as reported in 2004 by the Environmental Protection Agency (EPA), seven were mining facilities (see Reference 1). TRI chemicals are defined by the EPA as being reasonably anticipated to cause acute or chronic adverse human health effects or adverse environmental effects. Of the 324-million total pounds of TRI chemicals released by these top-ten polluting facilities to the Arizona environment that year, 318-million pounds were released by mining facilities—an astounding 98 percent of that total.

Blasting will cause severe noise pollution in rural Pima County’s historically quiet environment. Nearly 100 heavy trucks and over 60 employee pool vans arriving at and departing from the Mine per day will cause severe and dangerous traffic congestion on normally uncongested Arizona Scenic Highway 83. Tons of dust released into the atmosphere by blasting at the Mine combined with Mine operations 24 hours per day, seven days per week, for 19 years will cause severe light pollution in traditionally astronomy-friendly Pima and Santa Cruz Counties.

These are unacceptable risks under any circumstance, but all the more so given the rural values and unspoiled environment in the region. When any pollutant released by the Mine rises to a level exceeding Federal Environmental Protection Agency standards or the standards of any other governmental agency with jurisdiction, the Mine operator must be penalized and required to comply in accordance with all applicable law(s). And, in the event of failure to comply, the Mine must be compelled to cease operations and pay all expenses for environmental pollution remediation, land reclamation, and mine closure.

COMMENT 2A: SOIL AND WATER POLLUTION ARE MORE LIKELY THAN NOT AND ARE THE MOST PERSISTENT AND EXPENSIVE TO REMEDY.

Discussion: The Mine’s potentially discharging facilities include: several ponds, leach pad, tailing fields, waste rock fields, open pit, concentrator, SX/EW operations, and other process and maintenance facilities. In addition, very large quantities of toxic chemicals are being delivered to and stored at the Mine including the following:

· Concentrated sulfuric acid (93%) will be delivered to the Mine in tank trucks with a capacity of about 24 tons nine times per day with an annual requirement of about 73,190 tons. The concentrated sulfuric acid will be stored in tanks at the Mine.

· Diesel fuel will be delivered to the Mine in tank trucks with a capacity of about 6,000 gallons four times per day with an annual requirement of nine-million gallons. The diesel fuel will be stored in tanks at the Mine.

· Other fuels and oils will be delivered to the Mine in trucks once a week with an annual requirement of 105,000 gallons. These other fuels and oils will be stored in tanks at the Mine.

· Miscellaneous reagents will be delivered to the Mine in trucks once a day with an annual requirement of 3,750 tons. These miscellaneous reagents will be stored at the Mine.

Despite being constructed to standards acceptable in the mining industry, such facilities and storage systems can and do fail due to deterioration, mechanical failure, negligence, accidents, human error, and unanticipated events. Moreover, all of the many daily truck deliveries of toxic materials to the Mine place the environment at risk due to collisions on the road or at the Mine, and to off-loading accidents at the Mine.

In a major case-study research report – “Comparison of Predicted and Actual Water Quality at Hardrock Mines: The Reliability of Predictions in Environmental Impact Statements” – Kuipers & Associates concluded that there are chronic underestimates of water quality problems in Environmental Impact Statements on hardrock mines. For example, of the 25 mines sampled

· 76% polluted groundwater or surface water severely enough to exceed water quality standards;

· 77% of those which exceeded surface water quality standards, did so despite predicting that mitigation would result in compliance;

· 73% of those which exceeded groundwater quality standards, did so despite predicting that mitigation would result in compliance;

· 93% of the mines near groundwater with elevated potential for acid drainage or contaminant leaching, exceeded water quality standards; of those mines that did develop acid drainages, 89% predicted that they would not;

· Of the mines that exceeded water quality standards, toxic heavy metals such as lead, mercury, cadmium, copper, nickel or zinc exceeded standards at 63% of mines.

This study underscores the urgent need not only to prepare MPOs which go beyond current industry standards, but also to require that mitigation measures be subjected to greater scientific rigor; that predictions of impacts be based in part on performance in past predictions and experiences at other mines; changes in procedures for selecting consultants to avoid the present conflict of interests present in the industry; and increased government expertise to ensure that staff has the technical expertise to provide analysis and oversight of the mine permitting process.

The Mine’s waste rock, tailings, and acid leach field containment buttresses are being engineered to survive, and its surface water management facilities are being engineered to handle, runoff water generated by a 100-year, 24-hour storm event. Should, however, a 100-year, 48-hour storm event, or a 500-year, 24-hour storm event, or a 1,000-year, 24-hour storm event occur, the Mine would suffer catastrophic destruction moving the waste rock, the tailing, and the acid leach field materials miles downstream, and with them all of the toxic materials being stored at the mine. The resulting soil and water pollution would be on an immense scale.

Despite being constructed to standards acceptable in the mining industry, such containment buttresses and surface water management facilities can and do fail due to unanticipated events. And, when toxic chemical releases do occur, the most persistent and expensive to remedy are those impacting soil and water. The Mine’s containment and water management facilities must be engineered to a higher standard.

Mitigation:

· In the event of failure to comply with all applicable water quality standards, Augusta must be compelled to cease operations and pay all expenses for remediation.

· Require that mitigation measures be subjected to greater scientific rigor; that predictions of impacts be based in part on performance in past predictions and experiences at other mines;

· Require that mitigation measures be designed by persons with the requisite technical expertise and experience, and that all proposed mitigation measures be subjected to independent review and determination of the risk of failure and the likelihood of success.

· All mitigation measures should be subjected to a “worst plausible case scenario” so that the adverse effects of plausible worst-case scenarios are explicitly studied and considered. For example, when the very safety of the domestic water supply for the City of Tucson could be at risk, it is not unreasonable to require the determination of the probably adverse impacts of a 200-year flood event on the proposed project.

COMMENT 2B: THE MINE WILL RELEASE TO THE AIR UNACCEPTABLE AMOUNTS OF DUST, HYDROCARBONS, AND OTHER TOXIC CHEMICALS.

Discussion: Augusta plans to blast and dig a mine pit that will be 6,500 feet long, 6,000 feet wide, and as much as 2,900 feet deep. Blasting will be done by exploding 20,000 tons of ammonium nitrate per year or 380-thousand tons over the Mine’s lifetime. Such blasting and digging will release tons of dust into the atmosphere.

Augusta plans to remove from the Mine’s pit some 600-million tons of below-average-grade copper-bearing ore and up to 1.9-billion tons of waste rock over the Mine’s lifetime. 513-million tons of ore will be milled on-site yielding over 500-million tons of tailing materials. The waste rock and tailing materials will be transported by haul trucks for permanent on-site storage in Barrel and other local canyons covering nearly 3,000 acres. The combined effects on these waste materials of exposure to strong sun light, extremely low relative humidity, and persistently moderate winds in the Rosemont area over a majority of months per year, will release tons of dust into the region’s atmosphere.

Digging and hauling will be done 24 hours a day, seven days a week, by heavy machinery burning and converting to tail-pipe emissions 9-million gallons of diesel fuel per year or 171-million gallons over the Mine’s lifetime. In addition to this, the 150 trucks and employee pool vans arriving at and departing the Mine daily will further increase the hydrocarbon emissions attributable to the Mine’s operation.

Mitigation:

· In the event of failure to comply with all applicable air quality standards, August must be compelled to cease operations and pay all expenses for remediation.

· Require that mitigation measures be subjected to greater scientific rigor; that predictions of impacts be based in part on performance in past predictions and experiences at other mines;

· Require that mitigation measures be designed by persons with the requisite technical expertise and experience, and that all proposed mitigation measures be subjected to independent review and determination of the risk of failure and the likelihood of success.

COMMENT 2C: BLASTING AT THE MINE WILL CAUSE UNACCEPTABLE NOISE LEVELS AND GENERATE POWERFUL SHOCK WAVES IN THE AIR AND GROUND.

Discussion: Unacceptable noise levels will adversely impact the lives, lifestyles, and livelihoods of nearby residents and businesses. Such noise levels will disrupt the reproductive cycles of resident and migrating species of insects, arachnids, fish, birds, and mammals. Such noise levels will adversely impact the enjoyment of the National Forest by its many thousands of visitors annually.

Powerful shockwaves traveling through the ground and air, generated by blasting at the Mine, will shake homes and rattle doors and windows up to six miles away, and possibly damage nearby residential, historical, and other structures. The Empire Ranch Foundation commissioned a seismic/structural engineering study of possible impacts of blasting at the Mine on four adobe buildings at the Empire Ranch Headquarters in the Las Cienegas National Conservation Area that are listed on the National Register of Historic Places (see Attachment C which is incorporated herein by reference). The study concluded in part that at a distance of five miles from the Mine:

“steady ground disturbance from blasting, similar to small earthquakes, would most likely precipitate the deterioration of the mortar between the adobe blocks. This loss of mortar has two effects. The first is the increased maintenance of the buildings through more frequent repointing of the adobe. Further there is a continuing cycling probable, almost a rocking of the block due to ground motion. While the amplitudes are small the continued vibration will have a deleterious effect on the adobe wall.”

Adverse effects of blasting at the Mine on nearby residential, historical, and other structures are underestimated by Augusta and must be further and independently studied to be sufficiently understood. Blasting must not be undertaken at the Mine unless independent studies prove that damage due to blasting at the Mine to residential, historical, and other structures will not occur.

Mitigation:

As a condition of Forest Service approval of Augusta’s MPO, Augusta and any successors in ownership of the Mine must be required to agree in writing to pay for all repairs to residential, historical, or other structures in the event damage due to blasting at the Mine should occur.

COMMENT 2D: THE MINE WILL SIGNIFICANTLY INCREASE DANGEROUS HEAVY TRUCK TRAFFIC AND CONGESTION ON ARIZONA SCENIC HIGHWAY 83.

Discussion: Augusta plans to transport all materials, supplies, equipment, parts, and employees to the Mine and all production output, employees, and waste from the Mine via Arizona Scenic Highway 83, a narrow, winding, two-lane road. On average, there will be 150 vehicles arriving at the Mine and 150 vehicles departing the Mine per day, the majority of which will be heavy trucks. There will be:

· 47 employee pool vans arriving at and 15 employee pool vans leaving from the Mine for the morning shift change, and there will be 15 employee pool vans arriving at and 47 employee pool vans leaving from the Mine for the evening shift change every day, seven days a week, 365 days a year, for 19 years.

· 56 tractor-trailers with 24-ton loads of copper concentrates leaving the Mine and 56 empty concentrate tractor-trailers returning to the Mine every day, seven days a week, 365 days a year, for 19 years.

· nine tanker trucks delivering sulfuric acid to the Mine and nine empty acid tanker trucks leaving the Mine per day.

· five trucks delivering pebble lime to the Mine and five empty pebble lime trucks leaving the Mine per day.

· four trucks delivering mill balls to the Mine and four empty mill ball trucks leaving the Mine per day.

· four tanker trucks delivering diesel fuel to the Mine and four empty diesel fuel tanker trucks leaving the Mine per day.

· four trucks hauling copper cathodes leaving the Mine and four empty cathode trucks returning to the Mine per day.

· four trucks delivering explosive ammonium nitrate to the Mine and four empty ammonium nitrate trucks leaving the Mine per day.

· one truck delivering miscellaneous reagents to the Mine and one empty reagent truck leaving the Mine per day.

· one truck delivering parts and explosives to the Mine and one empty parts and explosives truck leaving the Mine per day.

The U. S. Interstate-10 Marsh Station railroad bridge must be modified to permit passage of oversized loads on Interstate-10 which are currently being rerouted to SR83. This will eliminate oversized loads on SR83 and avoid a compounding of dangerous traffic congestion involving both oversized loads and heavy truck traffic arriving at and departing the Mine. Passing lanes must be added on SR83 to allow normal traffic to safely pass the hundreds of slower-moving trucks daily. Owing to a significantly increased volume of heavy-vehicle traffic on SR83, which was not engineered for such a volume of such heavy vehicles, road maintenance will be required much more frequently. Moreover, the Portland Cement mine if approved in the Empire Mountains will also be sending heavy trucks onto SR83—the effects of the Mine’s heavy-vehicle traffic and the cement mine’s heavy-vehicle traffic on the safety of SR83 must be considered cumulatively.

Augusta underestimates the adverse impact the Mine will have on local traffic. Arizona Scenic Highway 83—the primary route for school buses, tourists, commuters, and service providers between greater Tucson and the Elgin-Sonoita-Patagonia area—choked with dangerous heavy mine traffic, will no longer be scenic or safe. Further and independent studies must be conducted to determine the expected change in road maintenance costs and the expected change in traffic accident, injury, and death rates on Arizona Scenic Highway 83 due to increased traffic congestion from the Mine.

Within the next 20-year period it is highly likely that the Federal Government and the State of Arizona will adopt significantly higher mileage requirements for all forms of motor vehicles in light of energy supplies and costs along with climate change considerations. These requirements will clearly affect the proposed project, and the traffic, circulation, energy, and economic impact sections of the Draft EIS should address the implications of these considerations on the operation of the proposed project.

Mitigation:

· A large number of traffic mitigation measures exist, including, but not limited to the following list of “illustrative” measures; note that these measures should be provided by Augusta, and should not involve public monies::

o Improve the interchange at Highway 83 and U. S. Interstate 10 to accommodate the levels and types of equipment necessary to sustain the proposed project over its anticipated lifetime; such measures must first and foremost address considerations of public safety;

o Improve the interchange at Kolb Road (access point to the Port of Tucson) and U. S. Interstate-10 to accommodate the levels and types of equipment necessary to sustain the proposed project over its anticipated lifetime; such measures must first and foremost address considerations of public safety;

o Improve the intersections at all roads serving residential properties along SR83 to accommodate the levels and types of equipment necessary to sustain the proposed project over its anticipated lifetime; such measures must first and foremost address considerations of public safety;

o Provide additional driving lanes on Highway 83 between mile-marker 44 and U. S. Interstate 10;

o Require car pooling for employees;

o Establish split-shifts to reduce peak-hour traffic;

o Suspend travel operations during the morning and evening commute periods and during travel times for all school busses.

COMMENT 2E: THE MINE WILL SIGNIFICANTLY INCREASE LIGHT POLLUTION IN A REGION THAT IS HOME TO NUMEROUS FEDERALLY AND PRIVATELY FUNDED WORLD-CLASS ASTRONOMICAL OBSERVATORIES.

Discussion: Rural Pima and Santa Cruz Counties are highly valued by the amateur and professional astronomy communities for their dark, transparent, and tranquil night skies. Included among the world-class astronomical facilities in Pima and Santa Cruz Counties are the Kitt Peak National Observatory and the Fred Lawrence Whipple Observatory. Also a world-class astronomical facility potentially affected by light pollution from the Mine is the Mount Graham International Observatory located in Greenlee County. All three facilities were created with substantial Federal assistance and receive ongoing research support from a number of Federal agencies with hundreds of millions of taxpayers’ dollars.

The tons of dust released into the atmosphere by blasting at the Mine (see COMMENT 2B) combined with the Mine’s proposed 24-hours per day, seven days per week operating schedule with the Mine being fully illuminated during the night shift will severely compromise the region’s prized dark night skies. This will place the investment of hundreds of millions of taxpayers’ and private contributors’ dollars at risk. Dan Brocius from the Fred Lawrence Whipple Observatory states:

“Outdoor light pollution threatens the astronomy industry in Arizona which has an infrastructure worth about $250-million.”

Every major Federally funded and privately funded astronomical observatory, and every Federal Agency having funded or which is currently funding a major astronomical observatory potentially affected by the Mine must be consulted.

Mitigation:

As a condition of Forest Service approval of Augusta’s MPO, Augusta and any successors in ownership of the Mine must be required to agree in writing that, although exempt from the Pima County Outdoor Lighting Code, the Mine will voluntarily comply with the code or stop night mining operations.

COMMENT 3: DESTRUCTION OF THE REGION’S FRAGILE SCENIC BEAUTY AND RECREATIONAL VALUE BY THE MINE IS CERTAIN. THESE ADVERSE REGIONAL EFFECTS ARE UNDERESTIMATED BY AUGUSTA AND MUST BE FURTHER AND INDEPENDENTLY STUDIED TO BE SUFFICIENTLY UNDERSTOOD AND AVOIDED OR FULLY MITIGATED. The Coronado National Forest Land and Resource Management Plan states the following:

“As local and tourist populations increase in the Coronado's zone of influence, the demand for outdoor recreation on the National Forest can be expected to continue to exceed the ability of the Forest Service to provide needed services. Several issues are generated by this situation as follows:

1. Identification of potential overuse areas and establishment of carrying capacities (number of people who can use an area without damage to natural resources).

2. Regulation of Off-Road Vehicle use to protect other Forest resources and uses, while continuing to provide this much demanded recreational opportunity.

3. Use of land for recreational development and dispersed uses, and establishment of equitable fees for recreational use.

4. The role of the private sector in providing recreation services on and adjacent to the National Forest must be reassessed.

5. Inventory and management planning for the Coronado's many caves, and location of this resource to recreational, scientific, and wilderness uses.

6. Visual resource integrity in all land management decisions.”

Augusta plans to destroy 4,415 acres of steadily vanishing unspoiled wilderness valued for its scenic beauty and recreational opportunities. Arizona Scenic Highway 83 follows the eastern edge of the Santa Rita Mountains near Rosemont, a major reason for its designation as a Scenic Highway. The presence of the proposed open pit copper mine will forever scar the inspiring views from this scenic drive and from the many public Forest Service roads surrounding the Mine, and compromise the region’s recreational value.