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Scoping Comments for the Resolution Copper Mine DEIS

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Scoping Comments for the Resolution Copper Mine DEIS Arizona Mining Reform Coalition t Access Fund t Center for Biological Diversity t Concerned Citizens and Retired Miners Coalition t Concerned Climbers of Arizona t Earthworks t Maricopa Audubon Society t Patagonia Area Resource Alliance t Save the Scenic Santa Ritas t Save Tonto National Forest t Sierra Club – Grand Canyon Chapter t Sky Island Alliance t Tucson Audubon Society t Valley Unitarian Universalist Congregation – Green Sanctuary t WildEarth Guardians Alida Q. Montiel and Cyndi Tuell as individuals July 18, 2016 Neil Bosworth, Tonto National Forest Supervisor 2324 East McDowell Road Phoenix, AZ 85006 Sent by email to: [email protected] [email protected] [email protected] [email protected] RE: Scoping Comments for the Resolution Copper Mine DEIS Dear Supervisor Bosworth: Per the U.S. Forest Service’s (“USFS”) March 18, 2016 Forest User public scoping notice letter, this letter (and attachments), following are our comments to be considered for scoping of the Draft Environmental Impact Statement (“DEIS”) covering the Resolution Copper Mining (“RCM”) General Plan of Operations (“GPO”), Initial Submittal: November 15, 2013, Revised: September 23, 2014, Revised: 01/12/2016, and the related Land Exchange. These comments are submitted on behalf of Arizona Mining Reform Coalition (“AMRC”), Access Fund, Center for Biological Diversity, Concerned Citizens and Retired Miners Coalition, Concerned Climbers of Arizona, Earthworks, Maricopa Audubon Society, Patagonia Area Resource Alliance, Save Tonto National Forest, Save the Scenic Santa Ritas, Sierra Club – Grand Canyon Chapter, Sky Island Alliance, Tucson Audubon Society, Valley Unitarian Universalist Congregation – Green Sanctuary, WildEarth Guardians, and Alida Montiel and Cyndi Tuell as individuals. Any or all of these organizations may also submit additional comments apart from these comments that are also incorporated into these comments. Organizations Arizona Mining Reform Coalition works in Arizona to improve state and federal laws, rules, and regulations governing hard rock mining to protect communities and the environment. AMRC works to hold mining operations to the highest environmental and social standards to provide for the long term environmental, cultural, and economic health of Arizona. Members of the Page 1 Coalition include: Apache – Stronghold, Center for Biological Diversity, Concerned Citizens and Retired Miners Coalition, Concerned Climbers of Arizona, Dragoon Conservation Alliance, EARTHWORKS, Empire Fagan Coalition, Environment Arizona, Groundwater Awareness League, Maricopa Audubon Society, Save the Scenic Santa Ritas, Grand Canyon Chapter of the Sierra Club, Sky Island Alliance, Spirit of the Mountain Runners, Tucson Audubon Society, and the Valley Unitarian Universalist Congregation. The Access Fund is the national advocacy organization that keeps U.S. climbing areas open and conserves the climbing environment. Founded in 1990, the Access Fund works with nearly 100 local climbing organizations in supporting and representing some 2.3 million climbers nationwide in all forms of climbing: rock, ice, mountaineering, and bouldering. The Center for Biological Diversity is a non-profit public interest organization with headquarters located in Tucson, Arizona, representing more than 1 million members and supporters nationwide dedicated to the conservation and recovery of threatened and endangered species and their habitats. The Center has long-standing interest in projects of ecological significance undertaken in the National Forests of the Southwest, including mining projects. The Concerned Citizens and Retired Miners Coalition is a group of citizens who: 1) reside in Superior, Arizona, or do not reside in Superior, Arizona, but are affiliated with relatives who are residents; 2) are retired hard-rock miners who previously worked in the now non-operational mine in Superior, Arizona, and were displaced due to mine closure or personal disability; or 3) are individuals who are concerned that important U.S. public recreational land will be conveyed to a foreign mining company for private use. The Concerned Climbers of Arizona was organized in 2010 for the purpose of preserving climbing access and the climbing environment. The group advocates for continued recreational access to climbing areas that are threatened by development or other forms of encroachment. Based in Phoenix, Arizona, the Concerned Climbers of Arizona is the primary group representing the interests of rock climbers in central Arizona. Earthworks is a nonprofit organization dedicated to protecting communities and the environment from the adverse impacts of mineral and energy development while promoting sustainable solutions. Earthworks stands for clean air, water and land, healthy communities, and corporate accountability. We work for solutions that protect both the Earth’s resources and our communities. The Maricopa Audubon Society's Mission is to protect the natural world through public education and advocacy for the wiser use and preservation of our land, water, air and other irreplaceable resources. Maricopa Audubon Society members have led the Superior Christmas Bird Count in and around Oak Flat and Tonto National Forest for years. Our members bird, hike, camp and enjoy other activities in the natural areas which this project proposes to convert to a mine and tailings pile. Patagonia Area Resource Alliance is a non-profit community watchdog organization that monitors the activities of mining companies, as well as ensures government agencies’ due Page 2 diligence, to make sure their actions have long-term, sustainable benefits to public lands and water resources in Patagonia and the State of Arizona. Save the Scenic Santa Ritas is a non-profit organization that is working to protect the Santa Rita and Patagonia Mountains from environmental degradation caused by mining and mineral exploration activities. Save Tonto National Forest works to protect our National Forest and promote safe and responsible use by all groups of outdoor enthusiasts. We are based in Queen Valley, Arizona and have around 260 members concerned about the direction the Tonto National Forest is going. Sierra Club is one of the nation’s oldest and most influential grassroots organizations whose mission is “to explore, enjoy, and protect the wild places of the earth; to practice and promote the responsible use of the earth’s ecosystems and resources; and to educate and enlist humanity to protect and restore the quality of the natural and human environments.” Sierra Club has more than 2.4 million members and supporters with 40,000 in Arizona as part of the Grand Canyon (Arizona) Chapter. Our members have long been committed to protecting and enjoying the Tonto National Forest and have a significant interest in the proposed Resolution Copper Mine and related activities. Sky Island Alliance works to protect and restore the biodiversity and natural heritage of the Sky Islands in the Sky Island region of the southwestern United States and northwestern Mexico. We work with volunteers, scientists, landowners, and government agencies to establish protected areas, restore healthy landscapes, and promote public appreciation of the region’s unique biological diversity. Tucson Audubon Society was established in 1949. The Tucson Audubon Society (Tucson Audubon) is a 501(c)(3) non-profit conservation organization, and is the third largest local Audubon chapter in the nation. Tucson Audubon inspires people to enjoy and protect birds through recreation, education, conservation and restoration of the environment upon which we all depend. Tucson Audubon advocates statewide for the sustainability, resilience, preservation, restoration and connectivity of habitats utilized by birds and other wildlife. Valley Unitarian Universalist Congregation – Green Sanctuary of Chandler Arizona is an environmental advocacy group, accredited by the national Unitarian Universalist Association. The Work of our team focuses on projects that (1) worship and celebrate nature and the Earth; (2) sustain and conserve our natural resources; (3) promote environmental justice; and (4) educate members of the community on environmental issues. WildEarth Guardians is a nonprofit conservation organization with offices in seven states. they have more than 160,000 members and activists across the United States and the world. WildEarth Guardians protects and restores wildlife, wild places, wild rivers, and the health of the American West. Toward this end, Guardians and its members work to protect the natural and cultural features of landscapes within national forests and other public lands, including their wildlife. Page 3 Alida Q. Montiel is Yolloincuauhtli and a teacher of indigenous traditional dance. She has a strong concern for the preservation of Oak Flat, a sacred and special place of the Apache people. Table of Contents 1. Organizations 1 Table of Contents 4 Project Background 8 General Observations 8 Summary of Alternatives to be Considered 12 GPO Deficiencies 12 Accuracy of Data in the GPO 12 Incomplete Plan 13 Impact Analysis Criteria (Analysis of Past, Present, and Foreseeable Actions) 13 2. Equal Value and Appraisal Comments 16 I. Introduction 16 II. FLPMA and NEPA 16 III. The Meaning of Equal Value 17 a. Historic, Cultural and Scenic Values 19 b. Wildlife and Wilderness Values 19 c. Recreation Values 19 d. Mineral Values 20 e. Other Environmental Values 20 IV. Oak Flat in the Context of Other Federal Public Land Exchanges 21 V. Appraisal
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