Scoping Summary Report #2

United States Department of Agriculture	Scoping Summary Report #2
Forest Service
	Extent of Public Participation
August 2009
	Rosemont Copper Project
	A Proposed Mining Operation in Southern Arizona
	Coronado National Forest Arizona

The following is a summary of the Coronado National Forest’s (Coronado’s) scoping efforts to solicit comments on the Proposed Action for the Rosemont Copper Project and to characterize the corresponding public participation. Scoping is the process by which federal agencies invite the public, organizations, and other agencies to provide input on the scope of a proposed project. More specifically, it is the process that federal agencies use to identify issues and potential effects related to a Proposed Action. The Council on Environmental Quality’s (CEQ’s) scoping definition states,

There shall be an early and open process for determining the scope of issues to be addressed and for identifying the significant issues related to a proposed action. This process shall be termed scoping. (40 Code of Federal Regulations [CFR] 1501.7)

Coronado will prepare an environmental impact statement (EIS) that will track significant issues within the scope of analysis in order to guide 1) the development of alternatives to the Proposed Action; and 2) the analysis of potential effects of the Proposed Action and alternatives. Scoping may also be used to identify potential mitigation for impacts. It is important to note that the scoping process is not a voting process and comments are not weighted in any manner. The intent of scoping is to identify important issues raised by the public, organizations, and other agencies to determine the scope of analysis. Therefore, no matter how many times an issue is raised by the same or different entities, it is still considered to be one issue.

This is the second of three reports that describe the scoping and content analysis process. Federal agencies typically prepare one report to document this process. However, Coronado has decided to prepare three interrelated reports to more fully explain the scoping and content analysis process for the Rosemont Copper Project. This decision was based on the complexity of the Proposed Action and the correspondingly complex public comments. The first report, Scoping Summary Report #1, Extent of Public Participation, described Coronado’s efforts to solicit comments on the Proposed Action and to summarize the corresponding public participation.

This second scoping report explains the content analysis process and provides an overview of the prominent themes identified in the public comments. This report will do the following:

• describe the methodology used to process response submittals;
• categorize the issues raised during scoping into thematic groupings; and
• list comments grouped by category and subcategory.

The final report, Scoping Summary Report #3, Comment Disposition, will do the following:

• address how comprehensive themes are proposed to be treated in the EIS;
• group themes into one of the following categories: Issues that Guide Alternative Development,
• Issues that Focus on Description of Effects, Issues that Address Process, and Issues Out of Scope for this Analysis; and
• provide a table that tracks the disposition of comment themes.

These reports should be approached with caution. Received comments do not necessarily represent the sentiments of the public as a whole, nor are they always technically accurate. As previously noted, in considering these views it is important for the public and decision makers to understand that this process makes no attempt to treat input as if it were a vote. Furthermore, the same comment stated multiple times by the same inidual, or groups of iniduals, is not weighted in the final analysis. No matter how many times the same comment is made during scoping, it is treated as one comment. For example, form letters submitted dozens of times constitute the same input as one letter with the same content. Again, the purpose of scoping is to determine the scope of issues to be addressed and to identify the significant issues related to a Proposed Action.

The Rosemont Copper Project is a proposed open-pit copper mine, to be located on Coronado National Forest, Nogales Ranger District, in the northern Santa Rita Mountains in Pima County, Arizona. Augusta Resource Corporation, the parent company of Rosemont Copper Company (Rosemont Copper), acquired the Rosemont Mine property in 2005. Although ore was historically mined in the area, there has been no production of copper, zinc, lead, silver, or gold since 1951. A significant increase in the value of copper over the past several years has made the mining of claims economically viable. There are 132 patented lode claims, 850 unpatented lode claims, and 14 parcels of fee land in the project area.¹

In July 2007, Rosemont Copper submitted a Mine Plan of Operations (MPO), including a reclamation plan, to Coronado, requesting approval to construct and operate a mine and related ore-processing facilities on and adjacent to National Forest System land. Ore deposits that would be mined as part of the project are, for the most part, on Rosemont Copper private property. The proposed mine is expected to annually produce 234 million pounds of copper, 4.5 million pounds of molybdenum, and 2.7 million ounces of silver over the anticipated 20-year life of the mine. The MPO was accepted in February 2008 after Rosemont Copper submitted supplemental information at the request of Coronado. Decisions regarding approval and the content of the final MPO will not be made until a thorough environmental review has been completed. In accordance with 40 CFR 1501.4, Coronado has reviewed the proposal and determined that preparation of an EIS is necessary.

An EIS is being prepared to analyze and disclose to the public the environmental, social, and economic impacts of the proposed Rosemont Copper Project. The EIS will be prepared in compliance with the National Environmental Policy Act (NEPA) of 1969, as amended; CEQ regulations for implementing NEPA; and other associated regulations. The U.S. Forest Service (Forest Service) decision will be based on the results of this NEPA process (i.e., the findings of the impacts analyses reported in an EIS) and further, on the National Forest Management Act determination of the consistency of the proposed use with the parameters specified in Coronado’s Land and Resource Management Plan.

The proposed Rosemont Copper Project is located approximately 30 miles southeast of Tucson, Arizona, in Pima County (Figure 1). The project is located just west of State Route 83, on the northern edge of the Santa Rita Mountains in the Helvetia-Rosemont Mining Districts. The area covered by Rosemont Copper’s patented claims, unpatented claims, and fee lands totals approximately 14,880 acres, which include the Rosemont, Peach-Elgin, Broad Top Butte, and Copper World deposits. Rosemont Copper’s proposal is to mine the Rosemont deposit, which would disturb approximately 4,415 acres (including utility corridors) that encompass 3,670 acres administered by Coronado, 995 acres of private land, 75 acres of Arizona State Land Department State Trust land, and 15 acres administered by the Bureau of Land Management.

¹ Lode claims include a deposit of valuable ore occurring within definite boundaries that separate it from surrounding rock.
A patented mining claim is one for which the federal government has passed its title to the mining claimant, making it private land. A person may mine and remove minerals from a mining claim without a mineral patent. It also gives the owner title to the surface and other resources.
An unpatented mining claim gives the claimant the right to explore for, extract, and process locatable minerals in an area known as a mining claim.
For the purposes of this document, fee land is private land, including all surface and subsurface mineral rights, that is owned by Rosemont Copper Company.

All federal agencies are required to comply with the scoping regulations promulgated by CEQ under NEPA (40 CFR 1501.7). The regulations relating to scoping are general and provide federal agencies with the latitude to conduct scoping appropriate for each agencies’ mission and specific to each Proposed Action. The CEQ regulations direct federal agencies preparing an EIS to engage in a public scoping process (40 CFR 1501.7). Subsequent to enacting 40 CFR 1500, CEQ published Guidance Regarding NEPA Regulations in 1983 (Federal Register 48[146]:34283), which clarified the purpose of scoping:

The purpose of this process is to determine the scope of the EIS so that preparation of the document can be effectively managed. Scoping is intended to ensure that problems are identified early and properly studied, that issues of little significance do not consume time and effort, that the draft EIS is thorough and balanced, and that delays occasioned by an inadequate draft EIS are avoided. The scoping process should identify the public and agency concerns; clearly define the environmental issues and alternatives to be examined in the EIS including the elimination of nonsignificant issues; identify related issues which originate from separate legislation, regulation, or Executive Order (e.g. historic preservation or endangered species concerns); and identify state and local agency requirements which must be addressed.

Furthermore, the CEQ regulations for implementing NEPA state that ―there shall be an early and open process for determining the scope of issues to be addressed‖ which ―shall be termed scoping,‖ but they have few specific requirements. These requirements (40 CFR 1501.7[a]) include the following:

1. Invite the participation of affected federal, state, and local agencies, any affected Indian tribe, the proponent of the action, and other interested persons (including those who might not be in accord with the action on environmental grounds), unless there is a limited exception under §1507.3(c). An agency may give notice in accordance with §1506.6.
2. Determine the scope (§1508.25) and the significant issues to be analyzed in depth in the EIS.
3. Identify and eliminate from detailed study the issues that are not significant or that have been covered by prior environmental review (§1506.3), narrowing the discussion of these issues in the statement to a brief presentation of why they will not have a significant effect on the human environment or providing a reference to their coverage elsewhere.
4. Allocate assignments for preparation of the EIS between the lead and cooperating agencies, with the lead agency retaining responsibility for the EIS.
5. Indicate any public environmental assessments and other EISs that are being or will be prepared and that are related to but are not part of the scope of the EIS under consideration.
6. Identify other environmental review and consultation requirements so that the lead and cooperating agencies may prepare other required analyses and studies concurrently with, and integrated with, the EIS, as provided in §1502.25.
7. Indicate the relationship between the timing of the preparation of environmental analyses and the agency’s tentative planning and decisionmaking schedule.

   Aside from these general requirements, the Forest Service has provided further regulations and policies, as allowed by NEPA, to supplement the CEQ regulations. Specifically, 36 CFR 220 clarifies, ―Because the nature and complexity of a proposed action determined the scope and intensity of analysis, no single scoping technique is required or prescribed‖ (CFR 220.4[e][2]). Forest Service Manual 1900, Chapter 1950—Environmental Policy and Procedures, contains the agency’s policies on scoping. These policies require the Forest Service to do the following:

   • give early notice of upcoming proposals to interested and affected persons (Forest Service Manual 1950.3[2][a]);
   • give timely notice to interested and affected persons, federal agencies, state and local governments, and organizations of the availability of environmental and accompanying decision documents (Forest Service Manual 1950.3[2][b]); and
   • have a responsible official to ―ensure that an appropriate level of scoping occurs‖ (Forest Service Manual 1950.41[2]).

   As noted in Scoping Summary Report #1, Extent of Public Participation, to ensure that an appropriate level of scoping occurred, Coronado consulted with its Southwestern Regional Office; the Regional Forester found that sufficient scoping activities were conducted and that it was appropriate for the initial scoping to conclude in July 2008.

   THE SCOPING PROCESS

   On March 13, 2008, Coronado published a Notice of Intent (NOI) to prepare an EIS for the Rosemont Copper Project in the Federal Register (73:13527–13529). The NOI identified the purpose and need for the action and the scoping process and summarized the Proposed Action. Coronado later extended the scoping period from 30 to 120 days. During that period, Coronado held six open houses and three public hearings. Comments received within this period, as well as comments received until August 1, 2008, were used for content analysis. Coronado’s efforts to solicit comments, and the corresponding public participation, were described in Rosemont Copper Project, Scoping Summary Report #1, Extent of Public Participation.

   METHODOLOGY FOR CONTENT ANALYSIS OF PUBLIC COMMENTS

   This section provides a description of the methodology used to document and analyze the 11,082 submittals received during scoping on the Proposed Action for the Rosemont Copper Project EIS. Contained within the 11,082 submittals were more than 16,000 unique comments. Each submittal contained between zero and more than 200 unique comments. For instance, some submittals only requested placement on a mailing list and did not have a comment on the Proposed Action. Some submittals contained multiple comments on multiple resource concerns (e.g., air quality, recreation, night skies, water, etc.). Coronado used a process called content analysis, which is a systematic method of compiling and categorizing the full range of public viewpoints and concerns regarding a plan or project. Content analysis is intended to facilitate good decisionmaking by helping analysts to clarify, adjust, or incorporate technical information into a planning document.

   Through the content analysis process, analysts strive to identify all relevant issues, not just those represented by the majority of respondents. The breadth, depth, and rationale of each comment are especially important. Analysts organize the statements to facilitate systematic review and consideration by decision makers. All submittals (i.e., public hearing transcripts, letters, emails, facsimiles, and other types of input) are included in this analysis.

   In the content analysis process used for the Rosemont Copper Project, each comment submittal is given a unique identifying number that allows analysts to link specific comments to original letters. Commenters’ names and addresses are then entered into a project-specific database program, which allows for the creation of a complete mailing list of all respondents. The database is also used to track pertinent demographic information, such as responses from special-interest groups and from tribal, federal, state, county, and local governments.

   This process and the resulting summary are not intended to replace comments in their original form. Rather, they provide a map of the content of the comment submittals. Original comments are posted on the Internet on a dedicated web page.²

   ² The Coronado comment web page is available at: < http://www.fs.fed.us/r3/coronado/rosemont/comments.shtml>.

   As stated earlier, it is important to understand that this process makes no attempt to treat comments as votes. In no way does content analysis attempt to sway decision makers toward the will of any majority. Rather, content analysis ensures that every comment is considered in the decision process and that pertinent issues receive an appropriate level of scrutiny throughout the EIS process.

   Content Analysis Process

   The first step in content analysis is to assign a unique identifying number to each submittal (from 1 through 11,082). As noted above, a submittal is any document that has from zero to multiple unique comments specific to any number of concerns regarding an issue or resource. This unique identifying number was written in the upper right-hand corner of the first page of each document. In the case of petitions, a unique identifying number was assigned to each inidual signatory. In the case of oral comment transcripts, a unique identifying number was assigned to each inidual speaker. Duplicate submittals that were submitted on different days or via different media received unique numbers. This was done to ensure that all comments would be read in case there was even a slight change in the submittal.

   Analysts then identified pertinent inidual comments numerically in order of appearance in the submittal. Inidual comments were assigned to one of 31 resource categories (Table 1). Subcategories were developed during the analysis on the basis of the subject matter contained in the comment. This allowed analysts flexibility in further defining potential issues. At a minimum, all categories contained subcategories of ―general comment‖ and ―cumulative effect.‖ Nine of the 31 resource categories had more than these two subcategories (Table 2). Appendix A provides the database output of all comments by resource category.

   Table 1. Resource Category Codes
   
   

   Code	Resource Category		Code	Resource Category
   ALT	Alternatives		PHS	Public Health and Safety
   AQ	Air Quality		PRP	Process and Procedure
   CC	Climate Change		RCL	Reclamation
   CUL	Cultural Resources		REC	Recreation
   FIR	Fire Management		RIP	Riparian
   FOI	FOIA Request		SOC	Socioeconomics
   GRA	Livestock Grazing		SOL	Soils and Geology
   HZ	Hazardous Waste		SSS	Special Status Species
   JUS	Environmental Justice		TEC	Technical Feasibility
   LGT	Light Pollution		TRA	Transportation and Access
   LU	Land Use		VEG	Vegetation
   MLO	Locatable Minerals		VRM	Visual Resource Management
   NO	Noise		WL	Wildlife and Habitat
   OTH	Other		WLD	Wilderness
   OUT	Out of Scope		WR	Water Resources
   PAL	Paleontology

    

    

   Table 2. Subcategories by Resource

   Category	Subcategory Code
   All	01 General comment 99 Cumulative effect
   Air Quality	02 Emission
   Other	02 In opposition 03 In support 04 Request copy of Draft EIS
   Process and Procedure	02 Scoping meetings 03 NEPA process 04 Cooperating agencies 05 Working groups 06 Regulations 07 Monitoring and compliance 08 Trustworthiness 09 Third-party selection 10 Forest Service plan revision
   Reclamation	02 Bonding
   Socioeconomics	02 Economy 03 Tourism 04 Land value 05 Quality of life 06 Jobs
   Technical Feasibility	02 Financial feasibility
   Transportation and Access	02 Increase in traffic volume 03 Aquifer quantity 04 Surface water 05 Central Arizona Project recharge 06 Contamination/pollution 07 Storm water runoff

    

   Analysts read each submittal completely. Comments contained within each letter were identified and bracketed using a pencil. The analyst then assigned the following:

   1. ascending numbers for each comment;
   2. a resource category code; and
   3. a subcategory code.

   For example, if the first comment raised in a letter expressed concerns about the potential for the Rosemont Copper Project to result in an impact to tourism, the code would be ―1-SOC-03" (Comment Number - Resource Category - Subcategory), as shown in Figure 2.  If the next comment expressed a general concern about wildlife, the code would be "02-WL-01".

   
   Figure 2. Example of comment coding

   Codes were written in the margin next to each comment. Figure 3 is a scan of a comment letter that has been coded. Occasionally, a single comment contained multiple themes. For example, a commenter might express concern about how surface water quality could impact wildlife. This comment would be coded twice— once as a water quality comment, the second time as a wildlife comment.

   Form Letters

   Form letters contained identical information in each submittal, represented by postcards, petitions, and duplicate submittals. Twenty-five different form letters were identified. The content of each form letter was coded once because it contained identical information. However, the contact information for each submittal was retained. In some cases, commenters added comments to the form letter. These additional comments were coded according to the methodology described above.

   
   Figure 3. Example of a coded comment submittal.

   Attachments

   Several comment submittals contained attachments to support a commenter’s interest or position. Often, these attachments were technical papers from a wide variety of sources. In general, attachments were not coded unless they had been prepared in direct response to the Proposed Action. These attachments were noted in the database and were made available to Coronado technical staff.

   Data Entry Process

   Every coded comment was entered into an MS Access database that had been customized for the Rosemont Copper Project. The following data were entered:

   1. Submittal type (e.g., letter, email, hearing, etc.) (Figure 4);
   2. Contact information (see Figure 4);
   3. Comment as written by the respondent (Figure 5); and
   4. Each comment number and corresponding codes (see Figure 5).

   
   Figure 4. Database entry fields.
   
   
   
   Figure 5. Database comment fields.

    

   COMMENT THEMES

   Individual comments were assigned to one of 31 categories (see Table 1) on the basis of the overall theme of the comment. Below is a summary of these themes.

   Air Quality

   Comments coded AQ-01 address concerns about dust or other emissions from the mine degrading air quality in the area, impacts to visibility in the area of the mine, and potential airborne transportation of toxic/infectious materials. Comments coded AQ-02 address concerns about the emissions associated with the additional traffic as a result of the mine.

   Alternatives

   Comments that address any alternative to the Proposed Action were coded ALT. For example, if a commenter made a comment about a different location for the power lines serving the mine or an alternative location for the tailings or waste rock, the comment would be coded ALT-01.

   Climate Change

   Comments coded CC-01 address concerns about greenhouse gas emissions from mine traffic, operation of facilities at the mine, and the potential for mine operations to contribute to global warming.

   Cultural Resources

   Comments that address the disturbance or removal of significant prehistoric or Historic period sites, the loss of cultural practice opportunities for Native Americans, or the change in regional landscape were coded CUL-01. This included comments that address the Rosemont Camp and/or the VR Ranch.

   Environmental Justice

   Comments coded EJ-01 address the theme of disproportionate impacts to low-income and minority populations in the area.

   Fire Management

   Comments that address impacts to the historic fire regime, increased wildfire danger, decreased water levels and its impact for fighting fires in the area, and the costs to guard against fire in the area were coded FIR-01.

   Freedom of Information Act Request

   Comments that request that the Forest Service release documents, such as studies conducted in the area, and the credentials of those working on the project were coded FOI-01.

   Hazardous Waste

   Comments coded HZ-01 address how and where hazardous waste resulting from mine operations would be disposed of, impacts of dumping toxins into the ground, potential health and safety issues resulting from direct or indirect contact with hazardous waste, and potential long-term impacts that contamination may have to the area.

   Land Use

   Comments that address the need to keep the area as public open space, the reasons why the Forest Service is considering this project, and the need for the Forest Service to protect the land for public use were coded LU-01. Comments coded LU-99 address the cumulative impacts of existing mines, mine proposals, and increased development in the area.

   Light Pollution

   Comments that address reduced star visibility for amateur and professional astronomers, reduced functional habitat for light-sensitive wildlife species, and reduced quality of life as a result of the diminished dark skies valued by residents in the area were coded LGT-01.

   Livestock Grazing

   Comments coded GRA-01 address loss of rangeland for livestock grazing, potential increased livestock mortality from vehicle/livestock collisions, potential contamination of livestock that drink from contaminated water or eat contaminated vegetation surrounding the project area, and potential fragmentation of rangeland in the area.

   Locatable Minerals

   Comments that address the need for the copper, the validity of the mineral claims, future expansion of the Rosemont mine, and future use of the Peach-Elgin, Broadtop Butte, and Copper World mine properties were coded MLO-01.

   Noise

   Comments that address blasting, vehicle traffic, heavy equipment use, operation of ore processing equipment associated with the construction, and overall noise levels associated with operation of the mine were coded NO-01.

   Other

   Comments coded OTH-01 address any other theme that could be relevant to the study but that is not represented by the other 30 categories. Comments coded OTH-02 address opposition to the mine. For example, if a commenter wrote, ―I do not want this mine here,‖ the comment would be coded OTH-02. Comments coded OTH-03 express support for the mine. omments coded OTH-04 were requests to receive a copy of the Draft EIS when it is published.

   Out of Scope

   Comments coded OUT-01 include both comments that do not address themes considered relevant to the EIS and those that request actions that are beyond the legal or regulatory authority of the Forest Service.

   Paleontology

   Comments that address the potential impact to paleontological resources in the area are coded PAL-01. This includes comments concerned with Ice Age animals and other fossils found in the area.

   Process and Procedure

   Comments coded PRP-01 address the reasons the Forest Service is considering the proposed project or contained questions about the process of approving the MPO or whether approval of the mine is a foregone conclusion. Comments coded PRP-02 address concerns about the scoping meetings that were held in the area. This includes comments about uninformative scoping meetings, comments that additional meetings that should have been held at other locations, and suggestions about better ways to conduct scoping meetings. Comments coded PRP-03 address the NEPA process and question whether the NEPA process is being followed correctly. Comments coded PRP-04 address cooperating agencies. This includes requests that certain agencies be asked to be included as cooperating agencies and requests from agencies to be included as cooperating agencies. Comments coded PRP-05 address the need for working groups and why they would be beneficial for the process. Comments coded PRP-06 address which regulations the MPO must meet, which regulations would govern the operation of the mine, and concerns that the 1872 mining law is outdated and needs to be revised. Comments coded PRP-07 concern who will monitor the mine site during operation to ensure Rosemont Copper is complying with required mitigation measures, who will monitor the site after operations have ceased to ensure reclamation is taking place, and the need for mitigation measures. Comments coded PRP-08 concern whether Rosemont Copper and the Forest Service are trustworthy. This includes comments that question whether Rosemont Copper can be trusted to follow through with stated commitments. This also includes comments that address whether the Forest Service can be trusted to make an informed decision. Comments coded PRP-09 concern selection of the third-party consultant. This includes comments that question the credentials of SWCA Environmental Consultants (SWCA), comments that take issue with some of the documents SWCA has produced in the past, and comments questioning the trustworthiness of SWCA. Comments coded PRP-10 address the forest plan revision. These comments request that the Forest Service not revise the forest plan to accommodate Rosemont Copper.

   Public Health and Safety

   Comments coded PHS-01 address concerns for the safety of surrounding residents, mine workers, and visitors to the general area of the mine. This includes concerns about airborne disease, traffic safety, and potential long-term health impacts associated with mine operations.

   Reclamation

   Comments addressing reclamation of the mine site once operations have ceased were coded RCL-01. These include comments that address the loss of accessible public land, difficulty of successfully reclaiming the site, and potential long-term safety hazards in the area. Comments coded RCL-02 address the cost and bonding of reclamation. These include comments expressing concern that RCC would not have enough money to successfully reclaim the site, and those questioning how the Forest Service would ensure Rosemont Copper has money set aside for site reclamation after mine operations have ceased.

   Recreation

   Comments that address the potential displacement of recreationists that frequent the area, loss of access to recreational land, loss of recreational opportunities in the area, and reduction in safety for recreationists were coded REC-01.

   Riparian

   Comments concerned with potential impacts to riparian areas and/or potential loss of important riparian habitat were coded RIP-01.

   Socioeconomics

   Comments coded SOC-01 address general socioeconomic concerns associated with the construction and operation of the mine. Comments coded SOC-02 address how the project might impact the local economy, both beneficially and adversely. These include comments requesting that economic studies be conducted and those expressing concern about the impacts additional people in the area may have to the local economy. Comments coded SOC-03 address the impacts the project may have to local tourism. These include comments regarding tourist displacement and the emotional distress this may cause local businesses that rely on tourism. Comments coded SOC-04 address potential impacts to local property values. These include concerns that the mine would directly and significantly reduce property values in the area and that residents may not be able to sell their properties as a result of the operation of the mine. Comments coded SOC-05 address potential change in overall quality of life from the project. These include concerns that the operation of the mine would have negative impacts to quality of life in the area as a result of increased noise, air pollution, water contamination, loss of recreational opportunities, and loss of aesthetic qualities. Comments coded SOC-06 address potential impacts to employment in the area. These include comments that construction-related and mining jobs would be created, along with comments regarding potential impacts as a result of people moving into the area for these jobs.

   Soils and Geology

   Comments coded SOL-01 generally address the loss of topsoil, loss of vegetation and habitat resources, potential soil contamination, and potential increased soil erosion in the area.

   Special-Status Species

   Comments that address the loss of suitable habitat for special-status species, fragmentation of habitat for special-status species, displacement of special-status species, conflicts with existing conservation plans and recovery goals, and population declines trending toward endangered status were coded SSS-01.

   Technical Feasibility

   Comments coded TEC-01 address the validity of Rosemont’s claims and whether Rosemont Copper has sufficient experience to successfully operate this mine. Comments coded TEC-02 address the financial feasibility of the Rosemont Copper Project.

   Transportation and Access

   Comments coded TRA-01 concern potential impacts of traffic to property values, increased air pollution, increased noise and light pollution, and increased wildlife/vehicle collisions. Comments coded TRA-02 address impacts of increased traffic to the area. This includes potential traffic congestion along State Route 83 and other local roads that would be used for mine-related traffic. Comments coded TRA-03 address impacts to the designation of State Route 83 as a scenic highway. This includes the potential reduced scenic quality of the highway as a result of mine operations and the potential jeopardy for the Scenic Byway designation of State Route 83. Comments coded TRA-04 concern deterioration of roads as a result of overall increased traffic and the fact that heavy vehicles would use these roads. Comments include a perceived increase in roadway maintenance requirements, accelerated road deterioration, and potential damage to non-mine-related vehicles that use State Route 83.

   Vegetation

   Comments coded VEG-01 address the general loss of vegetation, loss of old-growth vegetation, loss of wildlife habitat, potential increase in noxious weeds, potential impact to the ―sky island‖ ecosystem, and potential contamination of vegetation through airborne or water transmission of dust and chemicals.

   Visual Resource Management

   Comments that address reduced scenic quality, concerns about a compromised Scenic Byway designation for State Route 83, and the alteration of form, line, and color in the area were coded VRM-01.

   Water Resources

   Comments coded WR-01 address the general impacts to water resources in the area as a result of the mine. Comments coded WR-02 address how the mine may impact aquifer quality. These include contamination from tailings seepage and potential reduction in well-water quality. Comments coded WR-03 address how the mine may impact the aquifer quantity. These include concerns that the mine would reduce the functionality of local wells and accelerate depletion of the aquifer. Comments coded WR-04 address contamination of surface water, depletion of surface water, and related impacts resulting from the contamination and depletion of surface water to livestock, wildlife, and residents in the area. Comments coded WR-05 address use of Central Arizona Project (CAP) water to operate the mine. These include concerns about CAP water being of sufficient quality for use by the mine, impacts related to the delivery of CAP water to the site, and availability of CAP water for use by the mine. It should be noted that the MPO does not propose the use of CAP water; therefore, it is likely that these comments will be deemed out of scope during the identification of alternatives. However, the comments were retained for consideration in the event an alternative is developed that would result in the direct use of CAP water. Comments coded WR-06 address the potential contamination and pollution of the local water supply. These include concerns that contaminants in the tailings may leak into the local water supply, that surface water may be contaminated by airborne toxins, and with the long-term impacts of water pollution. Comments coded WR-07 address impacts proposed stormwater control measures may have to the area. These include the adverse impacts to wildlife, vegetation, and downstream habitat, excessive erosion of operational and reclaimed slopes, and potential that the existing stormwater control plan may lead to saturated areas in the dry-stack tailings.

   Wilderness

   Comments coded WD-01 address displacement of recreational users to other areas, potential increase in visitors to nearby wilderness areas, potential reduction of wilderness-related recreational tourism, and potential disturbance to wilderness area characteristics in the area.

   Wildlife and Habitat

   Comments coded WL-01 generally address loss of habitat, displacement of wildlife to other areas, habitat fragmentation, irreversible loss of habitat quality, loss of game populations, and increased potential for vehicle/wildlife collisions.