Summary of Mountain Empire Action Alliance National Environmental Policy Act Scoping Comments for the Proposed Rosemont Copper Project Environmental Impact Statement

This scoping document contains comments on the Proposed Rosemont Copper Project (hereinafter “Mine”).  The document is divided into two main sections:  (I) Potential Impacts of the Mine and (II) Alternatives to the Mine.

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.

·         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.

·         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. 

·         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.

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.

·         COMMENT 2A:  Soil and water pollution are more likely than not and are the most persistent and expensive to remedy.

·         COMMENT 2B:  The mine will release to the air unacceptable amounts of dust, hydrocarbons, and other toxic chemicals.

·         COMMENT 2C:  Blasting at the mine will cause unacceptable noise  levels and generate powerful shock waves in the air and ground.

·         COMMENT 2D:  The mine will significantly increase dangerous heavy truck traffic and congestion on Arizona Scenic Highway 83.

·         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.

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 studies to be sufficiently understood and avoided or fully mitigated.  

·         COMMENT 3A:  The presence of a large open pit copper mine at Rosemont in the Santa Rita Mountains will adversely impact the scenic values of the Coronado National Forest.

·         COMMENT 3B:  The presence of a large open pit copper mine at Rosemont in the Santa Rita Mountains will adversely impact the regional recreational values of the Coronado National Forest.

COMMENT 4:  Destruction of irreplaceable and invaluable wildlife and wildlife habitat by the mine is certain.  Operation of the Mine will disrupt species reproduction within and beyond the Mine’s physical footprint, and block established animal migration routes within a declared major bio-diversity corridor.  These adverse regional effects are underestimated by Augusta and must be further and independently studied to be sufficiently understood and avoided or fully mitigated.  

·         COMMENT 4A:  The mine’s sulfuric acid solution leach pad/collection ponds and the  process water temporary storage pond pose deadly threats to wildlife.

·         COMMENT 4B:  Disruption by the mine of water runoff to Davidson Canyon wash poses deadly threats to endangered wildlife.

COMMENT 5:  The mine will threaten the region’s rural economy, property values, and lifestyle and must the further and independently studied to be sufficiently understood and avoided or fully mitigated.

COMMENT 6:  The mine’s electrical power demands cannot be met by local producers’ current production capacity and existing delivery infrastructure.

COMMENT 7:  Many historic and cultural resource sites have been identified within and nearby the mine’s proposed perimeter in previous archeological surveys.  Most mapped site locations are suspect and must be independently relocated using GPS or GIS technologies, re-documented, and re-examined by pertinent tribal and other authorities. 

COMMENT 8:  The mine operator fails to meet a reasonable industry standard of experience and qualification. 

·         COMMENT 8A:  The Coronado National Forest land and resource management plan must not be revised or waived in part or in whole to accommodate any deficiency in Augusta, its MPO, or its supporting documents.

COMMENT 9:  Augusta underestimates the scope and costs of mine remediation, reclamation, and closure.  The assumptions underlying Augusta’s initial reclamation bond cost estimate must be carefully examined in detail and the estimate must be modified as necessary. 

·         COMMENT 9A:  Well defined criteria for determining successful completion must be developed for each reclamation activity under the reclamation plan to avoid premature phased bond releases.

·         COMMENT 9B:  Costs of implementing the mitigation plan and of remediation of possible environmental contamination must be accurately estimated and included in the reclamation bond estimate.

·         COMMENT 9C:  Well defined criteria for determining   successful completion of mine closure must be developed under the reclamation plan to avoid premature phased bond releases.

COMMENT 10:  The mine will adversely impact local emergency services.

COMMENT 11:  The U. S. Environmental Protection Agency, the U. S. Department of Homeland Security, the U. S. Bureau of Land Management, the U. S. Army Corps of Engineering, the State of Arizona, and Pima County must be invited to participate more directly as cooperating agencies in the NEPA review process. 

II. Alternatives to the Mine

This section of the scoping document identifies twelve (12) alternatives in addition to the proposed project.  These alternatives reflect a range of strategies to significantly reduce adverse environmental impacts: reduction of project scale, alternative types of mining, alternative locations for selected elements of the proposed project; transportation types and routes, timetable; and alternative processing technologies.  This list is not intended to be exhaustive, and during the preparation of the Draft EIR other alternatives will surely be generated and evaluated accordingly.

The following alternatives are generally listed in order of preference as regards reducing or eliminating adverse environmental impacts. 

Alternative 1: No Action.  This alternative would prohibit placement of all spoils and overburden on public lands thus protecting the five square miles of public land designated for permanent mine tailings, facilities, waste rock storage, and open pit excavation proposed in the current Mine Plan of Operation. 

Alternative 2: Limited Project.  Under this alternative, mining excavation and placement of all spoils would be limited wholly to fee simple lands and patented mining claims, and thus provide maximum protection of all public trust lands – National Forest, Bureau of Land Management, and State of Arizona. 

Alternative 3: In-Situ Mine.  In-situ means “in the natural or original position.”  This alternative involves obtaining the desired material with only minimum physical disturbance of the mine site, as the ore is leached in its existing underground location. 

Alternative 4: Underground Mine.  This alternative would involve sinking mine shafts to subterranean levels containing ore and then constructing horizontal tunnels, called adits, to reach the underground ore deposits.  Through the use of this alternative, the large, highly visible open-pit excavation would be avoided, along with the surface deposition of a large volume of overburden waste rock.

Alternative 5: Continuous Pit Backfill. Under this alternative the project would utilize a continuous backfill technology, whereby the open pit would be progressively filled with the waste rock, spoils, and overburden generated as the excavation proceeds.

Alternatives 6 through 10 are concerned with alternative modes and routes for transporting materials – including ore, waste rock and tailings – equipment, and personnel to and from the mine site.  These alternatives include the use of rail transportation, mechanical conveyances, and hydraulic conveyances as well as alternative vehicular routing in order to reduce the potential adverse impacts of the proposed project.

Alternative 6: Rail Transport of Ore, Spoils and Tailings from the Mine Site.  Under this alternative, all material – ore, spoils, tailings, and waste rock would be transported from the site via a new rail line constructed to the mine site.

Alternative 7: Rail Transport of All Ore from the Mine Site.  Under this alternative, all ore would be transported to an off-site processing location, preferably adjacent or near an existing smelter

Alternative 8: Mechanical Conveyance of Ore to Rail Head.  This alternative is similar to Alternative 7 but would utilize some form of mechanical conveyance, such as a mine cart conveyor system, down the west side of the Santa Rita Mountains to a rail head for shipment on the existing rail line connecting Nogales and Tucson. 

Alternative 9: Hydrologic Conveyance of Wet Ore Concentrate to Processing Site West of the Santa Rita Mountains.  This alternative is similar to Alternative 8, but would utilize some form of hydrologic/pipeline conveyance down the west side of the Santa Rita Mountains to a processing/drying site near Santa Rita Road. 

Alternative 10: Loop Road Circulation System.  This alternative would utilize either a tunnel through or a summit road over the Santa Rita Mountains so that full ore trucks would road through a tunnel or over the top so that full trucks would go west to I-19, north to I-10, and then to the Port of Tucson railhead at Kolb and I-10; empty trucks would return on the East side of the Santa Rita Mountains via SR83.

Alternative 11: Modified Time-Table.  The following alternatives address extensions or other changes in the timetable for mine operations which could result in reduced impacts:

a.      Extend Mine lifetime to 40 or 50 years

b.      Suspend mining operations during high winds

c.      Suspend mining operations during extreme drought conditions

d.      Suspend mining operations during periods of excellent “seeing conditions” at the surrounding dark-sky observatories

Alternative 12: Alternative Processing Technologies.  In addition to the alternatives listed above, the Draft EIS should expand the range of technical alternatives within the various processes and techniques proposed in the MPO and alternatives to the MPO as augmented in this scoping document and in subsequent alternatives generated through scoping and the formal environmental assessment phase.

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