Comments on Resolution Copper Mining Pre-Feasibility Project with Forest Service Comments from Sierra Club: Re: Resolution Copper Mining Plan of Operations Pre-Feasibility Proposal Comments from a local citizen: To: U.S. Forest Service 7/18/08 RE: Proposed Resolution Copper Mining Pre-Feasibility Project As a former Superiorite who still has family residing in Superior and who still uses Oak Flat Campground I have several questions and statements regarding this matter. 1. Why do they need more drilling sites? I have been told that there are over 85 wells & drill sites in & around this area dating back several years. They (RCC) should have enough information with these 85+ sites to answer many of their questions so that there in no need to further ruin the terrain. They have a lot of money and a lot of knowledge. It is very unbecoming of a large corporation such as this, to pretend they don’t have enough answers on this project. 2. Although RCC may feel there is a statutory right to explore and develop that is recognized by “General Mining Law of 1872”…we must also remember that this land is part of Public Land Order 1229 which specifically deems this land inviolate to mining. 3. Pre-feasibility studies have already been done and RCC has information on water, subsidence and the size of the ore body so there is no need for further evaluation. Shouldn’t the course of action be “No Action Alternative” until NEPA studies are undertaken? Once NEPA studies are completed and IF the land swap goes through, then you can drill to your hearts content and do it anywhere you like. 4. Who previously approved exploration operations? The answer…USDA Forest Service 5. If QC-04 & MB-03 is on previously disturbed land…who and how was it disturbed? 6. What important structure is QC-04 & MB-03 intersecting at 1100 and 1300 meters? 7. OF-1, OF-2 & Of-3 are being drilled for mineral exploration. 8. DHTW-01, DHTW-02 & DHTW-03 are for deep hydrogeologic testing & monitoring wells. 9. 9 boreholes along 2 potential tunnel alignments for planned conveyor or tunnel alignment… 10. I feel the public has every right to enter “public lands” and there should be no road closures and keeping the public out. By using dozers, hammer-hoes or track hoes to modify constrictions the land will be scarred and changed. Then when the land swap does not go their way, the public will have to look at the destruction that is left behind. 11. Where is the permitted landfill for the “excess mud” going to be? 12. What is “silt fencing”? What is a “water bar”? 13. If a fire, caused by the drilling or the drill operator, gets out of control…who puts it out and who pays to have it put out? 14. If 39.2 acres is a conservative estimate of area required…Who would RCC contact and how would they get more land? 15. RE: Service Vehicles adjusting their speed to avoid creating a dust trail 16. RE: Scenic Values 17. I will let someone with more knowledge tackle the fish & wildlife & Native American cultural resources questions…but I do have one question… In my opinion, they are counting their chickens before they are hatched. There is yet NO LAND SWAP and there is the possibility that they may not get the land swap so shouldn’t this project be put on hold until more is known about what is going to happen with this land? Thank you for your time Sylvia Barrett Comments from Groundwater Awareness League: To: Tonto National Forest Scoping Committee From: Nancy Freeman, Executive Director Date: July 17, 2008 Subject: Comments on exploration drilling by Resolution Copper on public land
Recently (week of July 7, 2008), I phoned the Globe Ranger station to ascertain the fire danger levels at Oak Flat Campground because some of us wanted to build a campfire and have prayers for the protection of the land. The amiable Ranger told me that there had been recent rains, so we could build a campfire in the campground. However, he went on to inform me that we had to bring our own firewood, we could not cut the trees or disturb them in any way. Please note the irony of protecting trees that the Forest Service, Bureau of Interior, and a Congressman are considering turning over to a mining company to destroy. Perhaps, the statute to protect the trees from cutting could be invoked to protect the trees from dewatering by mining. After all, how many oak groves do we have in Arizona?
Why does this company need to turn the public land into private land? Do they want to turn the public land into a waste dump—which would be regulated—on public lands? Or do they want to avoid the public outcry will be when the trees start dying on National Forest land? The mining operations will have to pump water out of tunnels and pits underneath Oak Flat. The destruction of the water table down to 7,000 feet will obviously dewater the majority of the 100 plus oak trees at Oak Flat region. Therefore, the mining company is insisting that they have to have control of the surface. The water level at Shaft 9 during the Magma mining era used to be at some 3,600 ft. Resolution Copper plans to dewater the shaft down, which could also draw water from the general region.
The situation:
1) The land in question in the Oak Flat region was protected from mining by executive order for over 50 years. PLO 1229 is still in force and is as valid today as it was in 1955. This Order should be respected and protect Oak Flat region from exploration activities.
2) The mining company, Resolution Copper has never done any mining at all. Further, the mining company is a partnership of two mining companies with the worst possible environmental records worldwide, including in U.S. See: www.mining-law-reform.info/RioTinto.htm See EPA report on Kennecott, another Rio Tinto Company: www.mining-law-reform.info/CleanUp.htm
3) Resolution Copper has already demonstrated that it has no interest and/or knowledge of Arizona water laws. They were planning to dump nearly two billion gallons of toxic water out of the old Magma Mine “shaft 9” in 2007. They planned to discharge the water into a stream that flows behind Boyce Thompson Arboretum State Park. The Arboretum management found out about the potential damage to their property and appealed to the Department of Environmental Quality. To avoid the required permits to discharge water, Resolution Copper now plans to pipe the toxic water to the town of Queen Creek, dilute it with water from the CAP canal, and have the area farmers use it. However, this irrigation district does not appear to have any viable contact.
4) Resolution Copper has stated many times publicly that they will not mine without control of the surface, which includes Oak Flat campground, and the numerous Oak trees in the surrounding area. The Land Exchange bill has only received a short reading and hearing in both the House and Senate with no further sponsors or action scheduled.
5) Resolution Copper currently has a total of 89 wells in the vicinity: 29 mineral exploration wells, 52 monitor/piezometer wells, 2 geotechnical wells, 4 exempt wells, and 2 non-exempt wells. This amount of wells would surely give them the information that they need without further disturbance of the land. See Attachment One: Resolution Wells (Excel file from ADWR GIS well inventory database.) 6) On 29 May 2008, Rio Tinto has stated in a media release [www.riotinto.com/media/5157_7821.asp] that they know how much copper is in the deposit as “Resolution Copper Mining LLC has completed sufficient drilling …. to report an Inferred Resource of 1.34 billion tonnes” of ore.
7) Animals and humans frequent the area. The boreholes would cause a danger of tripping and/or falling. There are statutes in Arizona limiting the amount of disturbed land on potential mining sites, including exploration operations.
8) There is ambiguity over water availability for a heavy water user, such as mining. Resolution Copper plans to mine for 66 years x 30,000 acre feet per year, which equals 1,980,000— nearly 2 million acre feet of water—enough to sustain the population of Tucson for 10 years! It is doubtful that continued Excess Contract CAP water will be available. That would mean that the company would have to pump groundwater from the old Magma well field north of Florence, within the Phoenix Active Management Area. Recommendations: Any exploration that will disturb public land should be postponed until the following events have been achieved: 1) The PLO 1229 that protects the region from mining has been withdrawn. 2) The land exchange has been accomplished in the U.S. Congress. 3) The proposed dewatering of shaft #9 has been successfully accomplished and hydrological affects on the region have been determined. |