| Submitted by Nancy Freeman
188 W. Calle del Ano
Green Valley, AZ 85614
January 31, 2012
The NEPA consultant/contractor—SWCA—chosen for the Rosemont Project has shown itself to be totally unprepared and inadequate to evaluate metal mining projects. All cooperating agencies and concerned owners of the public lands have had to produce reams of corrections, additions and omissions. In Chapter 1, page 1, of the DEIS, it is stated
However, it was a consulting firm that prepared the DEIS on behalf of Augusta Resource/Rosemont Copper. Certainly, it was not accomplished by an objective entity, or (as will be shown below) a scientific one. Why wasn't this fact appropriately stated by the preparers in the DEIS?
Further, an important cooperating agency, Arizona Game and Fish was hampered from obtaining technical reports in a timely manner. Following is one example, an excerpt from the AZ Game and Fish Department's comments to Mr. Upchurch in a letter (page 4), dated January 18, 2012: AZ Game and Fish Comment Letter to Coronado National Forest
Another compelling issue to illustrate that the document was written by a consultant and prepared for the sake of the mining company, not the public interest, was the illegal manner in which the consultant put in a change of the Forest Plan in the DEIS, without any public notice at the time of the release of the DEIS. In fact, in Chapter One, which gives the only Table of Contents, an Amendment to the Forest Plan is not mentioned under the Chapter 2 description:
However, it is pointed out in the Executive Summary that the Forest Plan must be amended and can be done so with the stroke of a pen. In spite of the fact, a public Forest Plan revision procedure has been going on for 5 years and the need for a revision of the Forest Plan to accommodate mining in the Rosemont region has never been brought up by the Coronado Forest Service personnel in those meetings. The plan to amend is first presented toward the end of the Executive Summary.
Another strike against the consultant is the fact that they ignored viable, important comments made during scoping. For example, extensive comments were made on TENORM (Technologically Enhanced Naturally Occurring Radio-Active Material), which is a serious consideration in Arizona. For this reason, when EPA did their environmental study of TENORM, they used Arizona mines as the models. We can assume that this important subject was too technical for the consultants to deal with.
Their lack of technical skills and expertise is illustrated again and again in the DEIS. In the two chapters that summarized the impacts the most common word was “may,” certainly not a technical, scientific term. In the Executive Summary, “may” was used 67 times and “could” was used 11 times. In Chapter 1, “may” was used 60 times and “could” 5 times.
This type of analysis is totally unacceptable for an Environmental Impact Statement; the information must be clear, precise and give exact facts and figures. Metal mining is not that common in the National Forests; therefore, the local overseeing Foresters have no idea about mining, so they are inept in asking and requiring relevant data, so they are totally dependent on the expertise of outsiders. The failure to provide requested documents to AZ Game and Fish Department was the consultant, not the Forest Service.
For these reasons and others that have been documented by informal, unprofessional inter-personal e-mails between the consultant and mining company and the Forest Service personnel, I recommend that this consultant be removed from the list of qualified NEPA consultants for metal mining analysis.
Thank you for your attention to this important matter.