Submitted by:

Nancy Freeman
Groundwater Awareness League, Inc
P. O. Box 934
Green Valley, AZ 85622
520-207-6506
www.g-a-l.info

 

Comments on mining and its impact in general

Since the hearing on February 24, 2007, I have put the comments made at that time and all the enclosures online, which should make them easier to access and use. Also, I was able to add a few relevant comments to the enclosures, which I was not able to do on hard copies. Feb 24 Hearing Report

In an attempt to inform the Securities and Exchange Commission of the inequities of the upcoming buyout of Phelps Dodge Corporation by Freeport-McMoran Corporation, I filed a lengthy report with SEC. The first complaint of that report details the environmental responsibilities that Phelps Dodge currently has in Arizona and New Mexico—and there are others. Complaint One of that report deals specifically with that problem.

The Introduction to the SEC Report gives some general problems in dealing with mining corporations:

Mining Law Reform

In considering mining law reform, I caution you not to capitulate to the usual cry of vested interests: We need more studies. There have been many incredible and extensive studies done already. I refer you to the extensive report: Hardrock Mining on Federal Lands. This report responds to a request by Congress that the National Research Council assess the adequacy of the regulatory framework for hardrock mining on federal lands in 1999.

It is necessary at this time is to take the advice of the experts and act on their advice. The timing is imperative because the price of metals is rising to record highs. The Environmental Working Group has collected a database of all the recent mining claims.

Another reason for action in the near future is the mining of uranium on Native American land, which is “managed” by the Department of the Interior. The devastation by uranium mining has caused the Navajo Nation to vote to exclude uranium mining from their reservation. Similar situations exist in the Black Hills. I am working on a report on the subject that will be released by the end of the month. The Western Mining Action Network is the most proactive in helping the Native American cause. Further relevant information can be found on the Defenders of the Black Hills website.

Impacts on Water

Maintaining supplies of clean water and protecting watersheds were major reasons why public domain forests and rangelands were reserved. As regions have become more populated and States have failed to protect the valuable resource of water, the imperative for the Federal Government through the Forest Service and other agencies to protect these watersheds for their original intended use. The public can no longer dole out large quantities of water to industry, especially heavy water users such as mining and electro-power plants. If we are going to save our watersheds and the many species of plants and animals that Federal Government has to take on this project to protect the water in the national forests, wildlife refuges, and designated conservation areas.

There is not doubt that the quantity and quality of our water is diminishing year by year. U. S. Geological Survey continues to do extensive measuring and reporting on the water issue. However, they have no authority to do anything about what they conclude, neither are they able to express their opinions in any public forum or called on to testify in Government hearing. One report will suffice for your present understanding:

Ground-Water Depletion Across the Nation: U.S Geological Survey Fact Sheet 103-03, November 2003

As you have already been advised, the important reports recently compiled by Ann Maest and Jim Kuipers show that the Environment Impact Statements of mining corporations consistently underestimate the ultimate impact on water by mining operations. Predicted and Actual Water Quality at Hardrock Mines

Recent Federal Cases:

There have been several Federal cases in recent years concerning impacts of mining, especially on water, in both Forest Service and BLM lands.

In 2006, Hells Canyon Preservation Council, Earthworks, and Northwest Environmental Defense Center were Plaintiffs against the Defendants, Richard J. Haines, Steve Ellis and United States Forest Service.

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF OREGON
OPINION AND ORDER CV. 05-1057-PK

CONCLUSION

For the reasons set forth above, plaintiffs' motion for summary judgment (# 35) is granted as to the claims under the Clean Water Act, the Organic Act, and the National Forest Management Act. Defendant's motion for summary judgment (# 50) is granted as to the claims under the National Environmental Policy Act. The Forest Service is enjoined from allowing mining or mineral operations in the North Fork Burnt River pursuant to the NFBR Record of Decision and Final Environmental Impact Statement issued in April 2004 for any action that this court has found violates the CWA, the Organic Act, NFMA and the implementing laws and regulations of those acts.

Dated this 4th day of August, 2006
Complete document

In 2003, Plaintiffs, Mineral Policy Center, Great Basin Mine Watch, and Guardians of the Rural Environment bring this action to challenge the revision of federal mining regulations promulgated by defendant, Bureau of Land Management ("BLM"), United States Department of the Interior ("Interior"), on October 30, 2001.2 According to plaintiffs, the regulations, codified at 43 C.F.R. § 3809 (2003) ("2001 Regulations") "substantially weaken, and, in many instances, eliminate BLM's authority to protect the public's lands, waters, cultural and religious sites, and other resources threatened by industrial mining operations in the West."

Civil Action 01-00073 (HHK)

IV. CONCLUSION

In sum, it is clear that mining operations often have highly significant–and sometimes devastating–environmental consequences. It is also clear that the 2001 Regulations, in many cases, prioritize the interests of miners, who seek to conduct these mining operations, over the interests of persons such as plaintiffs, who seek to conserve and protect the public lands. While such prioritization may well constitute unwise and unsustainable policy, with one exception, the court cannot find that the 2001 Regulations unreaso

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

nably implement the FLPMA, in violation of the Administrative Procedures Act, nor can the court conclude that the Secretary acted arbitrarily or capriciously in promulgating the 2001 Regulations, such that this court may intervene.

Accordingly, with one exception, plaintiffs' facial challenge must fail.

For the foregoing reasons, plaintiffs' motion for summary judgment must be granted in part and denied in part, and Interior and NMA's motions for summary judgment must similarly be granted in part and denied in part. The 2001 Regulations shall be remanded to Interior for evaluation, in light of Congress's expressed policy goal for the United States to "receive fair market value of the use of public lands and their resources," 43 U.S.C. § 1701(a)(9). The 2001 Regulations are otherwise affirmed. An appropriate order accompanies this memorandum opinion.

Henry H. Kennedy, Jr.
United States District Judge
Dated: November 18, 2003
Complete document

Several Government Agencies, including the Forest Service, have produced many relevant reports on impacts of hardrock mining on the environment and watersheds that are essential to the understanding of the importance of protecting our forests from degradation.
Government reports on mining impacts

Job Theme:

A continual plea by proposals for mining permits is the mine will provide more job. There are plenty of jobs for miners in existing mines across U.S. and in Arizona too. Further, according to all the sources I could find, the wages for labor is lower in U.S than in Canada. Another incentive for Canadians to do business in U.S.

Info on jobs and wages

Traditionally mining companies have displayed no interest in providing good wages and conditions for their laborers. In fact, the Arizona company, Phelps Dodge Corporation, has been instrumental in breaking the unions throughout U.S. After two trips to the Supreme Court., they initiated a well-planned strike-breaking in the Morenci and Ajo operations in Arizona. Union workers in every sector have suffered cut-backs in benefits as well as a slowed-down increase in wages. When you read the quote of the Phelps Dodge President below, you will understand why this has occurred.

Details of PD's labor history

Following is an excerpt from that report:

The Final Blow to Labor

Since the 1915 strike in Bisbee, Phelps Dodge had managed labor by granting some wage increases to the local unions with the agreement that the miners would forego national union affiliation. In 1967, the national manufacturing wage was $3 an hour, the average national mining wage $3.10 an hour, but the average Arizona mining wage was about $2 an hour. From mid-1968 when the pattern agreement was finally met, the company would be required to sit down with a powerful Steelworkers coalition to negotiate a contract—every three years. For the next 15 years, things went well for copper miners. The unions demanded and won cost of living adjustments and higher wages from Phelps Dodge, although usually only after a walk-out by employees.

But Phelps Dodge had an ally. As in the case of using an Arizona Governor—if they couldn’t control the system, they would find other ways to manage it. A cantankerous Wharton School of Business professor took it upon himself to start a program to reverse “union power buildup.” Professor Herbert Northrup wrote a series of books on formulas for weakening unions. A founding partner in the project: Phelps Dodge. He had the brains; PD had the dollars. It appears the company would bear any cost to cut labor costs.

We can begin to see a trend here—Phelps Dodge had deep pockets for expenditures to curtail labor demands even though labor's demand were always small and reasonable. PD had money to hire attorneys to argue right up to the Supreme Court to avoid paying back wages to the 35 employees who they had fired for being union members. This trend was also true in the historic 1983 strike, when the workers had agreed to a wage freeze and were only asking for the continuation of their cost of living raises—which would have been minimal since cost of living was not increasing significantly in the early 1980's. Recognizing this fact, all other mining companies had already signed the pattern contract. Phelps Dodge had bigger plans. Break the union once and for all.

With the 1983 strike, they succeeded. Phelps Dodge broke the strike with assistance of Arizona Governor Babbitt, National Guard and State Troopers. But it was all worth it to them, within two years PD had wiped out thirty union locals made up of 2,000 workers. They were used to having their way—money was the bottom line.

For a brief description, I defer to Barbara Kingsolver—who was there—and who wrote a book about the strike, Holding the Line.

In a place a few hours' drive from where I live [ Tucson], the government, the police and a mining company formed a conspicuous partnership to break the lives of people standing together for what they thought was right. That ironclad, steel-toed partnership arrested hundreds of citizens on charges so ludicrous that the state, after having perfectly executed its plan of intimidating the leadership and turning public sympathy against the strikers, quietly dropped every case. [ New York Times review of Holding the Line]

In the aftermath of the strike, Phelps Dodge officials celebrated, while loyal miners whose families had worked in PD mines for generations sorted out new lives for themselves. The cost in human dignity has reverberated through the decades and still touches the ex-miners lives. The wound still has not healed, there are families in Clifton-Morenci who still do not speak to each other. Of course, the permanent replacement workers they had recruited during the strike voted against a union!

And Arizona was not the only place the tactics were used. Former Phelps-Dodge head caught 'selling' union-busting plan to Oregon Steel.

In 1995, Jonathan D. Rosenblum, union attorney and author of Copper Crucible published a report on previously uncovered documents and interviews that revealed facts there were unknown during the strike. The Arizona taxpayers had no idea that they were paying for a covert Tucson-based intelligence agency, the CIA of Arizona state government that was acting against the Union. During the copper strike:

• Undercover agents with the Arizona State Criminal Intelligence Systems Agency (ACISA) infiltrated every union in the Clifton-Morenci mining district early in the strike, bugging nearly one out of every two meetings and monitoring the rest with informers. "We were using about five (informants) at any given moment and as many as eight or nine others moved on and off assignments," said ACISA's former supervising undercover agent.

• A sophisticated supercomputer in Tucson enabled ACISA to compile intelligence files on hundreds of union members and supporters.

• ACISA, in tandem with the Arizona Department of Public Safety, set up an elaborate sting operation to entrap alleged arms dealers during the strike. But the Department of Public Safety botched the operation by critically wounding one of the suspects in an accidental shooting. Meanwhile Phelps Dodge was smuggling arms into the copper mine with impunity.

• ACISA shared some intelligence reports directly with the plant manager and security officers at Phelps Dodge. [Complete report by Rosenblum]

By 1985 Phelps Dodge was making record profits again in copper. Earlier Phelps Dodge had diversified, so not all of its financial problems in the early 1980's were due to copper prices. Phelps Dodge emerged as a model for other American Corporations, for its "ruthless" labor relations. Phelps Dodge president gloated, "We created a new approach to labor. It was followed all over. Suddenly people realized, hell, you can beat a union. Time was big unions were considered invincible. We demonstrated that nobody was invincible."

Several analysts have calculated that it would have cost them less money if they had satisfied the small demands of labor. The strike cost them plenty. There were continual expenses: attorneys, lobbyists, full-page newspaper ads, travel and accommodations for management, alleged gratuities to Arizona politicians and labor officials—getting their way in Arizona was doable, but it could not have come cheaply.

Issues Specific to Augusta's Operations at Rosemont Ranch

Thank you for this opportunity to give you some information that I feel is relevant to your assessments of the projected Rosemont mining operation. I am not against mining per se. However, I know it impacts the whole eco-system in ways that we cannot imagine until you have seen it. I thought those big dams in Green Valley were reservoirs for water conservation. I would have never guessed that they were full of toxic waste.

Mining needs to be done where there is plenty of water and no population of humans, animals or plants. I once teased the manager of Phelps Dodge—you guys should have bought the whole state of Arizona, put up fences and stated: “This is the nation’s metal supply—do not approach, we are going to turn it into a toxic, devastated wasteland.” But here we all are, and so they have to deal with this reality. Pit mining is a very dirty business—I refer you to photos taken from the ADEQ files for Sierrita.

Not to realize and act according to this reality is to continue to degrade our land and water in such a way it will never be available for human or animal use. Of course, in the southwest, we are more concerned about water.

This brings us to the relevant issue: Why are foreign companies coming to U.S. to do their mining? There are a number of them―Rio Tinto, BHP, Kennecott, Grupo Mexico, Kinross, Barrick Gold―and they are all leaving behind an incredible legacy for the American taxpayers to clean up. The companies hold mineral rights on a large portion of public land. The truth is they get free water, virtually free land. Further, they can get free public water with no hydrologic evaluations at all in Arizona.

Further, all reports claim that miners receive lower wages here in U.S. It looks like a win-win for Canadian companies. How many U. S. companies are going to Canada to mine??

Six of the top 10 claimants of public lands in the U. S. are foreign-owned companies

Rank	Company	Address	Number of Claims	Estimated Acreage Claimed
1	Newmont Mining Corp	Denver , CO	17,643	347,458
2	Placer Dome Inc	Vancouver , British Columbia, Canada	13,766	268,758
3	Rio Tinto Limited	Melbourne , Australia	10,097	191,928
4	Barrick Gold Corporation	Toronto , Ontario, Canada	5,768	125,956
5	Phelps Dodge Mining Co	Phoenix , AZ	7,105	124,297
6	Kinross	Toronto , Ontario, Canada	4,306	98,853
7	Cameco Corp	Saskatoon , Saskatchewan, Canada	3,209	66,204
8	ASARCO, a subsidiary of Grupo Mexico	Colonia Roma Sur, Mexico	3,187	61,801
9	Dr Gordon Reynolds	Price, UT	300	48,000
10	Carl Pescio	Elko , NV	2,277	46,996

Source: Environmental Working Group analysis of government land transaction data (BLM LR2000 database) and public records of corporate structures and mergers.

Augusta Resource Corporation

Although the mining law need to be reformed and our water needs to be protected from all large mining operations, Augusta Resource Corporation, gives us a prime example why we need these changes. This Canadian Corporation was formed for the sole and explicit purpose of exploiting Public Land in southwest U. S. according to their current website. [Correction: now it states in "southern Arizona."

They claim that they will pay to put CAP water back in the Tuscon basin—the recharge will be in Marana and they have no guarantee how long they will have the allocation. If they don’t understand that putting water in the basin 30 miles downstream will not help the over-pumping in our National Forest—if they don't understand that pumping water out of a National Forest where dead trees are already showing up won’t harm the plants and critters, then they shouldn’t be doing mining anywhere. And just why aren’t they mining in Canada?

They claim that they will mix tailings and crushed waste rock in a “state-of-the-art” method for planting soil for native plants. If they haven’t seen the 30-year old waste rock piles at Twin Buttes where hardly a weed grows, then they shouldn’t be mining in Arizona.

There is “no-state-of-the-art” dry tailings—there is no example anywhere. There is one mention of the technique in a report from Washington State Department of Ecology. However, I spoke with one of the authors* he assured me it is only in the planning stages. No one has tried it in U.S.. We do not want experiments with over 1 billion tons of waste rock and tailings in our forest. I did the math—spread over the 3,000 acres of Forest Land they propose to appropriate for piles that will reach some 17 stories high.

*Robert L. Raforth
Washington Department of Ecology
Central Region Water Quality Program
15 W. Yakima Ave., Yakima, WA 98902-3387
rraf461@ecy.wa.gov

If they don’t understand that tailings put over washes cause acid mine drainage problems as occurred in Bagdad when Jamie Sturgess worked for Cyprus when there was fish kill in the local creeks because of tailings placed over a wash—then they shouldn’t doing any mining.

In fact, while Mr. Sturgess worked for Cyprus Minerals before it sold out to Phelps Dodge, two of their four mines in Arizona obtained superfund status and the one mentioned above was in violation of EPA rules; the fourth one is now undergoing further assessment for superfund status.

If they don’t understand that these washes are an essential component of our Tucson Basin Watershed. They will be pumping water, obstructing natural watershed recharge, and dewatering the pit—all will bring down groundwater levels, which are already shown to be down 25 feet on the recently released Tucson AMA modeling report. Further, how much water will it take to attempt to grow vegetation on dry tailings, which are nothing but cement, and combined with crushed waste rock. They shouldn’t be doing mining at all.

Destroying the Coronado National Forest for the sake of copper content less than 1% does not make sense. We have the same potential situation in the Tonto National Forest in Payson and Superior. We need to direct our energies toward the real problem—the 1872 mining law that sets no limits on the size of the operations AND the Arizona Groundwater Code that exempts mining—a heavy water user (25,000 acre feet per year at Sierrita in Green Valley.)

The Environmental Protection Agency estimates that billions of dollars are needed to protect Western drinking water supplies from mine waste, and that cleaning up the estimated half a million abandoned mines across the country may cost $35 billion or more (EPA 2000).

Therefore, the sites for mines have to be selected very carefully—with an objective, scientific study.

Augusta Resource Corporate Information

Augusta Corporation History  

 
Augusta Resource Corporation is on the official Canadian Corporation website with the earliest date of 6/28/1999. At the hearing in Tucson conducted by Rep. Raul Grijalva, Jamie Sturgess, Augusta Resources, mentioned that Augusta had been in existance for some decades. Perhaps we get a clue of this discrepancy from another reference to Augusta Resource(s) in 1999 on a Canadian mining directory website.

Information from the Web on Augusta Resources Corporation
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Information from Canadian Corporation Website 

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January 27, 2000  

FOR: AUGUSTA RESOURCE CORPORATION
NEWS RELEASE TRANSMITTED BY CCNMatthews

Vancouver , BC : Augusta Resource Corporation (the "Corporation") announces an arms length private placement of 500,000 units at $0.40 per unit, subject to regulatory approval. Each unit consists of one common share and one non-transferrable share purchase warrant ("Warrant"). Each Warrant can be exercised to purchase one common share at a price of $0.40 during the first year and at a price of $0.50 during the second year. The proceeds will be used for exploration expenditures on the Corporation’s mineral properties and for working capital.  

The Corporation will commence a seven hole, 951 meter drill program on the Guadalupe y Calvo gold-silver property located in Chihuahua State, Mexico in the next several days. The objective of the program is to confirm the results obtained from previous trenching and jackleg drilling programs.  

The Corporation announces the granting of director incentive stock options to purchase up to 50,000 shares at a price of $0.47 per share for a period of five years ending January 26, 2005.   Currently there are 10,349,043 shares issued and outstanding.   The Corporation is a mineral exploration and development company with an interest in the Blue Moon base metal property in California, USA as well as the Guadalupe y Calvo property.   On behalf of the Board of Directors.  
s/Richard W. Warke, President

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March 13, 2002

Augusta Forms Alliance with Ashton
FOR: AUGUSTA RESOURCE CORPORATION NEWS RELEASE TRANSMITTED BY CCNMatthews   Augusta Resource Corporation (“Augusta”} is pleased to announce that it has entered into an option and joint venture agreement with Ashton Mining (Northwest Territories) Ltd., a wholly owned subsidiary of Ashton Mining of Canada Inc. ("Ashton"), on the 138,000 acre BH property in Nunavut.

As announced on March 7, 2002, Augusta holds an option to earn a 100% interest in this property.   Under terms of the agreement, Augusta will fund a Phase 1 exploration program that Ashton will conduct during the 2002 exploration season. Upon completion of Phase I, Ashton will have the option to earn a 60% working interest in the property by spending up to $1,112,000 not later than April 30, 2006. Upon earning this interest Ashton will carry Augusta for a further $268,000 of exploration expenditures under the terms of a joint venture agreement. The option and joint venture agreement is subject to the approval of the Canadian Venture Exchange.  

The BH property is located in the Coronation Diamond District. As shown on the attached map, the property is situated approximately 15 km west of Rockinghorse property of Kennecott Canada Exploration Inc. and Tahera Corporation which hosts the Anuri and Qamutiik kimberlites, and approximately 60 km south west of the Kim property of Ashton and Pure Gold Minerals Inc. which hosts the Artemesia kimberlite.   In light of Ashton's expertise, experience and resources in the Coronation Diamond District, Augusta is pleased to have formed this association and looks forward to an active exploration season.   Augusta has acquired one of the largest land positions in the Coronation Diamond District, aggregating approximately 1.6 million acres. Augusta and Ashton are currently negotiating the extension of their alliance to other properties in which Augusta holds the right to earn a 100% interest.


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December 2, 2004

“Acquisition of Advanced Gold Project in Nevada”

Vancouver , B.C. - Augusta Resource Corporation (the “Company”) is pleased to announce that it has signed an agreement to acquire a 100% interest in the Mount Hamilton Gold Project, located in White Pine County, Nevada. Mount Hamilton has multiple exploration targets including surface bulk mineralization as well as high grade vein style mineralization. Six separate high priority areas have been identified. An extensive amount of exploration and drilling information on these areas is included in the acquisition.

The Company has hired Roscoe Postle Associates Inc. to verify the existing, historical resource estimates and complete an up to date NI 43-101 report.

The Project is located approximately 45 miles east of Eureka, Nevada and 50 miles west of Ely, Nevada and is accessible from Highway 50 over good all-weather gravel roads. The White Pine Mining District has a long history of silver and gold mining, dating back to the first gold discovery in 1865.

The terms of the acquisition are $3.6 million USD payable in a combination of cash and shares and an underlying royalty. A Finder’s Fee is payable.

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September 27, 2005

Augusta Resources announces appointment of Roth Investor Relations

"The Company [Augusta Resource Corp.] announced that it has appointed Roth Investor Relations to conduct its investor relations activities in North America. The New Jersey based Investor Relations firm is headed by Michelle Roth, who has specialized at working within the mining industry for over 20 years. Their impressive contact list throughout the United States and Canada will aid management in raising Augusta's profile amongst the investment community. In exchange for the services provided by Roth Investor Relations, Augusta Resource has agreed to a monthly retainer fee of US$8000."

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September 29, 2005

 Augusta Resource Corporation Appoints V.P. Projects and Environment
Capitol Reports Press Release

VANCOUVER (09/29/05) -- Augusta Resource Corporation ("the Company"), is pleased to announce the appointment of Mr. James (Jamie) Sturgess to the position of Vice President Projects and Environment. Mr. Sturgess will be responsible for management of all environmental permitting and oversight of project development activities. . . .

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November 18, 2005

ABOUT AUGUSTA RESOURCE CORPORATION

Augusta Resource Corp. is a mineral exploration and development company responsibly advancing copper and other base metal assets in the U.S. southwest. The Company's Rosemont Property is located in Pima County, approximately 50 km southeast of Tucson, Arizona, and contains three known potentially open-pit copper/molybdenum ("Cu/Mo") deposits. The Rosemont deposit contain 6.4 billion lbs of Cu equivalent (442,000,000 tons at 0.73% Cu equivalent) in measured and indicated resources and 1.9 billion lbs of Cu equivalent (145,000,000 tons at 0.67% Cu equivalent) in inferred resources. Please refer to the Company's news release dated January 24, 2006 for further details. Augusta has additional exploration properties in Nevada. The Company is traded on the Canadian TSX Venture Exchange under the symbol ARS.

ON BEHALF OF THE BOARD OF DIRECTORS
Gil Clausen, President and CEO

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March 17, 2006

An Augusta Corporation Release on its Website

About the Company:
Augusta is a mineral exploration and development company responsibly advancing copper and other base metal assets in the U.S. southwest. The Company’s Rosemont Property is located in Pima County, approximately 50 km southeast of Tucson, Arizona, and contains three known potentially open-pit copper/molybdenum (“Cu/Mo”) deposits. The Rosemont deposit contain 6.4 billion lbs of Cu equivalent (442,000,000 tons at 0.73% Cu equivalent) in measured and indicated resources and 1.9 billion lbs of Cu equivalent (145,000,000 tons at 0.67% Cu equivalent) in inferred resources. Please refer to the Company’s news release dated January 24, 2006 for further details. Augusta has additional exploration properties in Nevada and New Mexico. The Company is traded on the Canadian TSX Venture Exchange under the symbol ARS.

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February 5, 2007

Augusta Corporations Listings on U.S. Securities and Exchange Commission

New Listing on SEC Edgar Database

Amendment to Statement of Beneficial Ownership

 

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