SR 83 Issues to presented to Congressional staff by James Kramp:

1. SR 83 Description:

a. On Sept 20, 1985 Highway 83 became the second highway in Arizona designated a scenic byway by the ADOT.  It is a winding two-lane road with sub standard guardrails, sub standard shoulders, narrow lanes, and limited sight distance. Travelers along 83 can see the numerous skid marks, and damaged guardrails that are prevalent throughout the journey and are indicative of the number of incidents that occur. The typical traffic consists of tourists, nature buffs, motorcyclists, bicyclists, recreation vehicles, and trucks with horse trailers. It is also used daily by residents, and school buses

b. In a report by The Federal Highway Administration identifying the most dangerous roadway segments in Arizona they describe SR 83 as a fairly curvilinear route, which winds its way through some of the most scenic, high-country vistas throughout the entire southern Arizona Coronado National Forest region. Nevertheless, the highway segment from MP 44 to MP 44.9 also ranks first among roadways locations experiencing motorcycle-related collisions, and eighth highest for run-off-road accidents in the state of Arizona.

2. Rosemont plans to use SR83 for its primary route during the construction phase and the operational phases of the proposed mine existence.

a. 900 construction employees and 73 delivery trucks will travel SR 83 each weekday during the construction year (MPO claims 1 year to construct the mine)

b. 495 operations employees and 88 delivery/haul trucks will travel SR 83 during the operational years each weekday. Trucks will contain cargo's including copper concentrate, copper cathodes, sulfuric acid, pebble lime, ammonium nitrate, diesel fuel, and SAG balls.

3. Some concerns with the NEPA process relating to SR 83.

a. Lack of immediate ADOT involvement as a cooperating Agency.

• i. ADOT and our state representatives did not seem to understand their role in identifying SR 83 improvements that would be required if the mine were permitted. A timeline defining correspondence between the various parties is included. ADOT was first invited to participate as a cooperating agency in July of 2008, the MOU was prepared and completed in late 2009, Due to improper contact information between the Forest Service and ADOT the first meeting attended by representatives from the ADOT was March of 2010, 20 months after being invited.

• ii. Proper decisions could not be made on suggested alternatives without identifying the improvements needed to use SR 83, their costs, and who is responsible for paying for them.

• iii. Several technical reports have been completed for Rosemont concerning subjects like SR 83 traffic volumes and roadway surface assessment.

1. In the traffic volume analysis report, during the construction phase, a 100% employee participation in car-pooling by bus to the mine site was assumed. The report suggests 900 construction employees will travel to the site each day by bus. They did not consider weekend traffic since construction is not planned for the weekends. During the operational phase two scenarios were suggested, 100% car-pooling, or 75% car-pooling in company owned vans, 5 people to a van. Worst-case scenarios were not considered.

2. In the AZ-83 roadway assessment report completed for Rosemont, several sub-standard roadway elements were identified, including tight reverse horizontal curves, improper guardrail placement, insufficient shoulder widths, insufficient sight distance, lack of school bus stops, and lack of oversize load pull-off's. The only improvements the report suggests include two oversize truck pull-offs and seven school bus stop pull off areas be constructed to improve traffic flow. The recommended bus stop at Hilton Ranch Rd. directly follows a substandard curve with limited sight distance. The bus will be susceptible to rear end collisions if NB traffic travels into the pull off area for any reason, or even worse the NB traffic avoids the school bus and runs into the arriving or departing children. Very little thought was put into the suggested improvements for safety.

3  The Interchange from I-10 to SR-83 has not been studied. Neither have the cumulative effects of future projects such as the Passages of Tucson. The Passages of Tucson will consist of retail stores, business offices, medical offices and residences. It will lie directly Northwest of the I-10 SR-83 interchange. According to ADOT, the Federal Highway administration would need to be involved in any needed improvements of this interchange, however they declined the invitation to act as a cooperating agency.

4. Traffic impacts from proposed car-pooling scenarios, and shipping the copper products have not been studied. Where will car-pooling parking lots be constructed to handle 900 construction employees? What if employees choose not to participate in car-pooling? If the port of Tucson at Kolb and I-10 is used for copper shipments, what impacts will the traffic have in this area? What agencies will need to be involved, and what improvements will be required?

4. Current and future projects and their impact on SR-83

a. Marsh Station Railroad crossing with Interstate-10 widening is already approved and funded. Work has begun. This will reduce the oversized loads that are currently routed down SR 83 to avoid the low railroad bridge.

b. SR-83 at MP 44.1-44.3 is being straightened, shoulders are being widened, and guardrails are being brought up to standard. These improvements are being paid for by the taxpayers as part of the HES (hazard elimination system) federal funds.

c. According to the Pima Association of Governments 2040 Regional Transportation plan no additional improvements to SR-83 are currently being considered through 2040. State Senator Frank Antenori in an e-mail dated 3/24/2010 to a constituent wrote, ADOT has been involved with the scoping process in SR83.  They have an ongoing Memorandum of Understanding (MOU) with the Forrest Service to ensure the impacts related to an increase in the number and size of vehicles as a result of the proposed mine are taken into consideration.  ADOT has done a preliminary study on the impact of the mine on SR83 that they have provided to the U.S. Forrest Service.  If the Forrest Service approves the MPO for Rosemont, they will have to incur the costs of fixing the safety issues with SR83 as well as widening and straightening of the road before they can begin using it.  The state will not pay for these potentially very costly improvements.

Further comments:

From a business perspective I would have expected Rosemont to work closely with the Arizona Department of Transportation concerning its use as a primary access route to its proposed mine site. It would seem to have been in their best interest to have identified SR 83 improvement requirements and the related costs long before developing their initial Mine Plan of Operation suggesting its use. These requirements should have been identified so the costs could have been considered in Rosemont's economic feasibility studies, and also for comparison purposes for suggested alternative ideas. Many suggested alternatives were shelved due to economic feasibility. How can that decision be made when they have not even considered the economic feasibility of their initial MPO? The Forest service should have done a better job of communicating with the ADOT on the importance of their participation as a cooperating agency and they should have been involved early on.

Summary of correspondence:

•  July 18 th 2008 Forest service sent ADOT invitation to be a cooperating agency on the Rosemont project.

•  June 9 th 2009 Hilton Ranch Community sent a letter to ADOT director concerning Cooperating agency participation on the Rosemont project.

•  June 15 th 2009 Sent E-mail to State Reps Frank Antenori, Jon Paton, and David Gowan outlining their constituents concerns that ADOT has not signed on as a cooperating agency.

•  June 16 th 2009 received an E-mail response from Todd Williams of the ADOT informing us that the MOU between ADOT and CNFS was in progress. He told me I could contact Greg Gentsch of the ADOT Tucson sector for future correspondence.

•  July 8 th 2009 Sent Greg Gentsch our comments on the AZ-83 traffic analysis report prepared for Rosemont by Tetra Tech.

•  July 11 th 2009 received a reply from Greg Gentsch. He informed me to send future concerns to Dan Williams or Linda Ritter

•  July 13 th 2009 sent additional concerns from AZ-83 commuters to Dan Williams

•  July 21 st 2009 sent Linda Ritter from the ADOT an e-mail suggesting a meeting between MEAA members and ADOT staff to discuss our concerns about Rosemont using AZ-83 as their access road.

•  Sept 15 th 2009 meeting place, date, and time established

•  Sept 29 th 2009 meeting between MEAA members and ADOT held.

•  Jan 19 th 2010 E-mail to Linda Ritter concerning the completion of the MOU between ADOT and the Forest Service

•  Jan 20 th 2010 E-mail to Linda Ritter concerning the participation by ADOT in the cooperating agency meetings. No documentation of any attendance can be found.

•  Jan 21 2010 E-mail from Linda Ritter informing of MOU completion

•  Jan 21 2010 E-mail from Linda Ritter informing us that the proper ADOT personnel were not aware of the meetings, that they were correcting things so they will attend future meetings

•  Feb 25 2010 E-mail reply from Linda Ritter concerning Todd Emery not being up to date on our communities concerns.

•  March 18 2010 Todd Emery, ADOT Tucson sector engineer attends the cooperating agency meeting. ADOT's first meeting after being invited 20 months prior. The Draft EIS is due out in April 2010.


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