PAGE 1 OF 16

Proposed Rosemont Copper Project 

Environmental Impact Statement

USDA Forest Service

Coronado National Forest

Arizona

February 18, 2014

Process Memorandum to File

Errata 

Rosemont Copper Project Final Environmental Impact Statement
PAGE 2 OF 16

ROSEMONT COPPER PROJECT FINAL ENVIRONMENTAL 

IMPACT STATEMENT

Errata Sheet

February 2014

The Rosemont Copper Project Final Environmental Impact Statement (FEIS) was released in December 

2013. This errata sheet documents corrections to the text of the published FEIS. These corrections reflect 

minor errors and omissions discovered after the release of the FEIS, and as such this document should be 

reviewed along with the FEIS. We have utilized “tracked changes” (underlined additions and crossed-out 

deletions) for some of the changes where we felt it would assist the reader in more easily following the 

corrections. There are no changes to the project or significant new circumstances or information identified 

in this Errata Sheet that affect the analysis and conclusions in the Rosemont Copper Project FEIS. 

This errata sheet is intended to be a “living document” that will be continually updated during the 

ongoing objection period for the draft Record of Decision. During this time period the most recent 

version of this document will be maintained on the project website: www.rosemonteis.us

The errata contained in this memo are presented in the order they appear in the Final EIS. In addition, the 

following table summarizes the errata presented.

Summary of Errata

Errata 

Number

Location in FEIS Change Made

1 Appendix G Missing public comment letter

2 Appendix D Missing signature from Memorandum of Agreement

3 Literature Cited, page 1360 Revision to citation for Chee 2010

4 Front matter Incorrect contact name

5 Literature cited, page 1377 Revision to citation for Liedy 2013

6 Appendix B Incorrect mitigation reference

7 Soils and Revegetation, page 180 Revision to description of analysis area

8 Biologic Resources, page 576, 

footnote 15

Replaced with more explanatory footnote

9 Biologic Resources,

page 674, table 123

Incorrect numbers in table for bat species

10 Surface Water Quantity, page 411, 

figure 62

The stock tank reference numbers were inadvertently 

left off of this map

11 Seeps, Springs, and Riparian Areas, 

page 513, figure 69

The locations of several springs were slightly modified, 

but the old map was not properly replaced in the 

document.

12 Appendix G, electronic file 

“424.pdf”

The response to several comments was imprecise, and 

requires clarification. 

13 Appendix G, electronic file 

“01_Rosemont Commenter 

Index.pdf”

A name is misspelled on page 115.
PAGE 3 OF 16

Errata 

Number

Location in FEIS Change Made

14 Appendix B An inconsistency in mitigation measure FS-RW-01 

requires clarification.

15 Appendix B Correction to mitigation measure OA-AQ-06

16 Appendix B Correction to mitigation measure RC-BR-02

17 Executive Summary Incorrect statement

18 Appendix B Correction to mitigation measure FS-SR-01

19 Appendix B Correction to mitigation measure FS-SR-03

20 Appendix B Correction to mitigation measure FS-GW-01

CHANGES TO THE TEXT OF THE FEIS

Front Matter, All Volumes

Errata #4. 

The contact for information was mistakenly given as Bev Everson, Interdisciplinary Team 

Leader. The correct contact for information is Mindy Vogel, Project Manager.

Executive Summary

Errata #17.

The Executive Summary incorrectly states on page xxx, “As modeled, mine pit lake water quality 

would potentially exceed the aquifer quality standard for thallium and ammonia and...” This is 

incorrect and does not match the analysis in Chapter 3. This should be changed as follows: “As 

modeled, mine pit lake water quality would potentially exceed the aquifer quality standard for 

thallium and ammonia, the surface water quality standard for ammonia, and...”

Chapter 3, Soils and Revegetation

Errata #7. Page 180, paragraph 1. 

The area of analysis for soil resources was improperly described. The following text should be 

replaced:

“The reroute of the Arizona National Scenic Trail was not included in the analysis area 

for soils; the level of ground disturbance expected from use of the trail is similar to that 

experienced from the casual recreational use that already occurs in the area. Further, any 

vegetation clearing activities for either the trail or the trailheads is likely to affect no 

more than 10 to 20 acres, which represents less than one hundredth of 1 percent of the 
PAGE 4 OF 16

watershed area for Upper Cienega Creek, which receives most of the runoff from the area 

in which the trail reroute is located.”

With this revised text:

“The reroute of the Arizona National Scenic Trail was included in the analysis area for 

soils.”

Chapter 3, Biological Resources

Errata #8. Page 576, Footnote 15. 

This footnote currently states:

“The Regional Forester’s Sensitive Species List was recently updated (September 2013); 

however, this FEIS is considered an ongoing action, so it does not need to consider 

impacts to applicable sensitive species on this list.”

This footnote should be replaced with the following, which better describes the process followed 

with respect to the updated species list:

“The Regional Forester’s Sensitive Species List was recently updated (September 2013).

Regional direction states that “projects which have been through the scoping process and 

where issues have already been identified are not required to utilize the updated RFSS 

list.” Direction also states the biologist should examine the proposed project and 2013 

RFSS list for any major issues or if the project could cause a trend toward federal listing 

for species on the 2013 list that were not on the 2007 list. Therefore, the Coronado 

National Forest has included this review as an addendum to the Biological Evaluation.”

Errata #9, page 674, table 12. 

This table currently states the following acres of bat habitat lost or altered:

Special 

Status 

Species

Proposed 

Action

Phased 

Tailings

Barrel Barrel Trail ScholefieldMcCleary

Bats

Cave myotis 5,612 5,481 5,431 5,888 6,197

Pocketed 

free-tailed 

bat

5,612 5,481 5,431 5,888 6,197

The table should instead present the following figures. These correct figures were used to support 

the analysis and to draw conclusions in the FEIS:

Special 

Status 

Species

Proposed 

Action

Phased 

Tailings

Barrel Barrel Trail ScholefieldMcCleary
PAGE 5 OF 16

Bats

Cave myotis 5,599 5,469 5,410 5,871 6,155

Pocketed 

free-tailed 

bat

5,599 5,469 5,410 5,871 6,155

Literature Cited

Errata #3. 

The data on the following reference should be revised to be September 10:

Chee, R. 2010. Technical Memorandum: Expanded Barrel Only Alternative Stormwater 

Assessment. Document No. 0/10-320878-5.3. Prepared for Rosemont Copper Company. 

Tucson, AZ: Tetra Tech. September 15.

Errata #5. 

The date on the following reference was inadvertently left off. It should be October 25, 2013.

Leidy, R. 2013. Rosemont Mine: trends, weight of evidence and ecological risk. Email 

communication to Jim Upchurch, Forest Supervisor, Coronado National Forest, from 

Robert Leidy, U.S. Environmental Protection Agency, Wetlands Office.

Appendix B. Mitigation and Monitoring Plan

Errata #6. 

Mitigation Measure FS-RW-02 (page B-64) inadvertently references mitigation measure FS-BO20 in two places. There is no such measure FS-BO-20. The correct measure to be referenced is 

FS-BR-21, “Recordation of a restrictive covenant or conservation easement on private land 

parcels in Davidson Canyon to mitigate for loss of habitat for listed species”.

Errata #14.

Mitigation Measure FS-RW-01 (page B-63) inconsistently states the timing for implementation of 

the mitigation measure. The description contained in the “Performance Criteria” section of the 

mitigation measure, where the reader first encounters this information, is correctly stated. The 

description contained in the “Responsible Party” section of the mitigation measure is not 

consistent with the previous description and should be changed as follows:

“Rosemont Copper is responsible for providing funds to the Arizona Trail Association to ensure 

that trail relocation occurs in accordance with Forest Service specifications and is pioneered 

completed before mine related activities close the existing trail to public use, and that final 

construction of the relocated trail and associated facilities is completed within 1 year of the time 

the existing trail is closed to the public.”
PAGE 6 OF 16

Errata #15.

Mitigation Measure OA-AQ-06 (page B-80) incorrectly identifies that this mitigation measure 

applies to all alternatives. Because this mitigation measure refers only to facilities that would be 

needed with a heap leach pad, it does not apply to the Barrel Alternative from which the heap 

leach facility has been removed. The description under the “Applicable Alternatives” should be 

changed as follows: “All action alternatives except Alternative 4 – Barrel Alternative.”

Errata #16.

Mitigation Measure RC-BR-02 (page B-95) incorrectly refers the reader to measure “FS-TA-02”. 

This measure does not exist. The correct reference should be measure “RC-TA-02”.

Errata #18.

Mitigation Measure FS-SR-01 (page B-10) incorrectly states under “Performance Criteria” that: 

“Sediment channels would maintain design capacity needed for adequate movement of 

stormwater.” This should be changed as follows: “Sediment Stormwater channels would 

maintain design capacity needed for adequate movement of stormwater.”

Errata #19.

Mitigation Measure FS-SR-03 (page B-14) incorrectly states under “Source” that: “This is a 

design feature that was contained in the preliminary MPO and is required by the aquifer 

protection plan.” This should be changed as follows: “This is a design feature that was contained 

in the preliminary MPO and is required by the aquifer protection plan permit.” 

Errata #20.

Mitigation Measure FS-GW-01 (page B-17) incorrectly states under “Monitoring/Reporting 

Action” that: “Rosemont Copper would monitor moisture content on a quarterly basis to ensure 

lack of seepage from water rock facility.” This should be changed as follows: “Rosemont 

Copper would monitor moisture content on a quarterly basis to ensure lack of seepage from water 

waste rock facility.”

Appendix D. Memorandum of Agreement

Errata #2. 

The signature for the Advisory Council on Historic Preservation (ACHP) was inadvertently left 

out of the published FEIS. ACHP signed the Memorandum of Agreement on 11/6/2013; this 

signature page is attached to this Errata memorandum (see attachment 1).
PAGE 7 OF 16

Appendix G. Summary of Response to Comments on the 

DEIS 

Errata #1.

Soon after posting of the FEIS on the project webpage for public review prior to the beginning of 

the objection process, it was discovered that a letter providing comments on the DEIS was 

inadvertently omitted from Appendix G of the FEIS. The letter dated January 8, 2012 was 

submitted by the Arizona Trail Association (ATA) on or about January 9, 2012 which was during 

the official DEIS comment period. The ID Team has conducted the same process for this letter as 

all others that are addressed in Appendix B of the FEIS, including content analysis to identify 

discrete comments contained in the letter; determination of Public Concern Statements that best 

represent the comment; and preparation of additional responses where warranted. The results are 

provided below, and should be considered to be an addition to the CD provided in Appendix G of 

the FEIS.
PAGE 8 OF 16

ATA Comment Public Concern Statement Public Concern Statement 

Response

Additional Response

The ATA supports the no action 

alternative, as the mine will result

in significant negative impacts to 

the Arizona Trail (AZT).

PCS 350: The Coronado 

National Forest should not 

allow the Rosemont Copper 

Company project to move 

forward. Because of impacts to 

the Arizona National Scenic 

Trail.

Further work with the Arizona 

Trail Association has occurred 

since the DEIS was released. 

A revised location on the east 

side of Highway 83 has been 

identified. Details about this 

location, its characteristics and 

its environmental impacts are 

contained in the Visual Quality 

and Recreation and 

Wilderness sections of 

Chapter 3 in the FEIS. Under 

mining laws, the Forest 

Service may reasonably 

regulate mining activities to 

protect surface resources, 

there are statutory and 

constitutional limits to its 

discretion. The Forest Service 

may reject an unreasonable 

Mine Plan of Operation but 

cannot categorically prohibit 

mining or deny reasonable and 

legal mineral operations under 

the mining laws. The Forest 

Service can require 

reasonable changes and 

mitigation measures, but does 

not have the authority to deny 

the project because it will 

impact the Arizona Trail.

None

Should the mine be 

constructed under any of the 

other alternatives, the Arizona 

Trail must be relocated.

The relocation route proposed 

by the Forest Service in the 

DEIS is not acceptable. An 

alternative route is proposed 

by the ATA.

PCS 350: The Coronado 

National Forest should not 

allow the Rosemont Copper 

Company project to move 

forward. Because of impacts to 

the Arizona National Scenic 

Trail.

Further work with the Arizona 

Trail Association has occurred 

since the DEIS was released. 

A revised location on the east 

side of Highway 83 has been 

identified. Details about this 

location, its characteristics and 

its environmental impacts are 

contained in the Visual Quality 

and Recreation and 

Wilderness sections of 

Chapter 3 in the FEIS. Under 

mining laws, the Forest 

Service may reasonably 

regulate mining activities to 

protect surface resources, 

there are statutory and 

constitutional limits to its 

discretion. The Forest Service 

may reject an unreasonable 

Mine Plan of Operation but 

cannot categorically prohibit 

mining or deny reasonable and 

legal mineral operations under 

the mining laws. The Forest 

Service can require 

reasonable changes and 

mitigation measures, but does 

not have the authority to deny 

the project because it will 

impact the Arizona Trail.

None
PAGE 9 OF 16

ATA Comment Public Concern Statement Public Concern Statement 

Response

Additional Response

As a reroute cannot 

adequately mitigate the 

damage to the trail experience, 

additional mitigations 

concerning traffic, water and 

trailheads will be required as 

identified in this letter. 

All costs associated with 

mitigation efforts must be paid 

by Rosemont Mine.

Mitigation costs: It is our 

expectation that as part of the 

mitigation plan Rosemont 

Copper Company, or its 

successors in interest, will pay 

all costs associated with the 

requested mitigation 

measures. These include 

relocation of the AZT, 

construction of water and 

trailhead improvements and 

such necessary expenses as 

cultural and legal surveys, 

permitting, right-of-way 

acquisition, trail and trail head 

construction, and travel and 

staff costs incurred by the 

Arizona Trail Association and 

the Forest Service in 

connection with the 

development and 

implementation of the Arizona 

Trail mitigation measures.

PCS 351: The Coronado 

National Forest should not 

allow the Rosemont Copper 

Company project to move 

forward. Because of impacts to 

the Arizona National Scenic 

Trail.

Further work with the Arizona 

Trail Association has occurred 

since the DEIS was released. 

A revised location on the east 

side of Highway 83 has been 

identified. Details about this 

location, its characteristics and 

its environmental impacts are 

contained in the Visual Quality 

and Recreation and 

Wilderness sections of 

Chapter 3 in the FEIS. Under 

mining laws, the Forest 

Service may reasonably 

regulate mining activities to 

protect surface resources, 

there are statutory and 

constitutional limits to its 

discretion. The Forest Service 

may reject an unreasonable 

Mine Plan of Operation but 

cannot categorically prohibit 

mining or deny reasonable and 

legal mineral operations under 

the mining laws. The Forest 

Service can require 

reasonable changes and

mitigation measures, but does 

not have the authority to deny 

the project because it will 

impact the Arizona Trail.

Impacts to users of the Arizona 

National Scenic Trail have 

been addressed and are 

disclosed in “Recreation and 

Wilderness” section in chapter 

3 of the FEIS.

All costs of relocating the trail 

would be paid by Rosemont 

Copper. Refer to Appendix B 

of the FEIS for details of 

mitigation associated with 

relocating the trail.

ATA’s Preferred Alternative: 

The ATA’s position is that the 

interests of the Arizona 

National Scenic Trail are best 

served by the no-action 

alternative. Clearly, 

destruction of the existing trail 

and locating a new trail is a 

drastic measure. The current 

route was selected with 

thorough involvement and 

cooperation between the

Forest Service, Pima County, 

and the ATA. The route was 

selected only after full 

consideration of the desirable 

scenic and other 

characteristics exhibited by 

several potential routes. The 

trail in this area was then built 

primarily by volunteers, 

demonstrating the strong 

connection between the trail, 

its users and supporters.

The trail was placed in its 

present location because of 

the outstanding scenic 

qualities of the immediate area 

PCS 350: The Coronado 

National Forest should not 

allow the Rosemont Copper 

Company project to move 

forward. Because of impacts to 

the Arizona National Scenic 

Trail.

Further work with the Arizona 

Trail Association has occurred 

since the DEIS was released. 

A revised location on the east 

side of Highway 83 has been 

identified. Details about this 

location, its characteristics and 

its environmental impacts are 

contained in the Visual Quality 

and Recreation and 

Wilderness sections of 

Chapter 3 in the FEIS. Under 

mining laws, the Forest 

Service may reasonably 

regulate mining activities to 

protect surface resources, 

there are statutory and 

constitutional limits to its 

discretion. The Forest Service 

may reject an unreasonable 

Mine Plan of Operation but 

cannot categorically prohibit 

mining or deny reasonable and 

legal mineral operations under 

the mining laws. The Forest 

Service can require 

reasonable changes and 

mitigation measures, but does 

None
PAGE 10 OF 16

ATA Comment Public Concern Statement Public Concern Statement 

Response

Additional Response

and the views of the natural 

landscape for miles around. 

The mine infrastructure, pit 

scar and dumps will forever 

destroy these scenic 

resources. All the alternatives 

except the no-action 

alternative allow construction 

of the mine and placement of 

huge mine dumps upon and in 

the immediate vicinity of the 

trail, with devastating effects 

on the trail, its scenic 

characteristics and the trail 

experience. There is no 

conceivable compensating 

mitigation action for this 

impact. For these reasons, the 

ATA’s firmly held position is 

that the interests of the 

Arizona National Scenic Trail 

are best served by the noaction alternative.

not have the authority to deny 

the project because it will 

impact the Arizona Trail.

Trail Route: ATA personnel 

have examined the trail routes 

proposed by the Forest 

Service in the DEIS for each of 

the alternatives and find that 

they are all too close to the 

mine dumps and Highway 83 

and traverse areas of extreme 

terrain. Placement of the trail 

in these areas would require 

extensive engineering and 

construction of retaining walls, 

steps and drainages that 

would destroy the natural 

aspects of the trail and the trail 

experience. Even then, the 

trail would be so close to the 

highway, mine and mine 

dumps that all scenic qualities 

would be destroyed.

Accordingly, and consistent 

with the discussion on pages 

462, 481, 482 and elsewhere 

in the DEIS, the Arizona Trail 

Association’s position is that 

under all but the no-action 

alternative the trail should be 

relocated to Forest Servicemanaged public land and 

Rosemont-owned private land, 

located for the most part east 

of Highway 83. Additional rerouting west of Highway 83 will 

also be necessary, as 

discussed below. A discussion 

of this route and a map is 

provided as Attachments.

PCS 350: The Coronado 

National Forest should not 

allow the Rosemont Copper 

Company project to move 

forward. Because of impacts to 

the Arizona National Scenic 

Trail.

Further work with the Arizona 

Trail Association has occurred 

since the DEIS was released. 

A revised location on the east 

side of Highway 83 has been 

identified. Details about this 

location, its characteristics and 

its environmental impacts are 

contained in the Visual Quality 

and Recreation and 

Wilderness sections of 

Chapter 3 in the FEIS. Under 

mining laws, the Forest 

Service may reasonably 

regulate mining activities to 

protect surface resources, 

there are statutory and 

constitutional limits to its 

discretion. The Forest Service 

may reject an unreasonable 

Mine Plan of Operation but 

cannot categorically prohibit 

mining or deny reasonable and 

legal mineral operations under 

the mining laws. The Forest 

Service can require 

reasonable changes and 

mitigation measures, but does 

not have the authority to deny 

the project because it will 

impact the Arizona Trail.

None
PAGE 11 OF 16

ATA Comment Public Concern Statement Public Concern Statement 

Response

Additional Response

Additional required mitigation: 

Quoting from the DEIS, page 

62, “mitigation measures” 

include “compensating for an 

impact by replacing or providing 

substitute resources or 

environments.” Because there 

are no mitigation measures that 

compensate for the devastating 

effects of the mine on the scenic 

and natural characteristics of the 

trail corridor, providing substitute 

resources that improve the 

recreational value of Arizona 

National Scenic Trail experience 

are required. The ATA believes 

that the following measures 

would best mitigate the loss of

high quality trail experience 

stemming from construction of 

the mine. The details of these 

mitigation measures are also 

discussed further in the 

Attachment.

Develop adequate trailheads: 

With increased traffic resulting 

from mine activity, and 

increased use of the Arizona 

Trail as a result of reduced trail 

user options, appropriate 

mitigation is the development of 

adequate trailheads. The ATA 

recommends three improved 

access points: Oak Tree 

Canyon, the intersection of 

Highway 83 and Hidden Valley 

Ranch Road, and the junction of 

Sahuarita Road and Highway 

83.

Provide replacement water 

sources: The existing trail has 

available water source 

opportunities. Rosemont Mine 

officials had previously agreed 

to work with the ATA to utilize 

the water from one of their 

purchased ranches. Two 

potential water sources on the 

ATA-proposed route should be 

improved to provide dependable 

equestrian water along the new 

route.

Take the Arizona Trail off roads 

in the area: The mine project 

will close approximately 37 

miles of roads (DEIS, pages 

596, 598) that support 

significant motorized and nonmotorized recreation use. 

Should the mine be constructed 

it is reasonable to assume that 

PCS 351: The Coronado 

National Forest should not 

allow the Rosemont Copper 

Company project to move 

forward. Because of impacts to 

the Arizona National Scenic 

Trail.

Further work with the Arizona 

Trail Association has 

occurred since the DEIS was 

released. A revised location 

on the east side of Highway 

83 has been identified. 

Details about this location, its 

characteristics and its 

environmental impacts are 

contained in the Visual 

Quality and Recreation and 

Wilderness sections of 

Chapter 3 in the FEIS. Under 

mining laws, the Forest 

Service may reasonably 

regulate mining activities to 

protect surface resources, 

there are statutory and 

constitutional limits to its 

discretion. The Forest Service 

may reject an unreasonable 

Mine Plan of Operation but 

cannot categorically prohibit 

mining or deny reasonable 

and legal mineral operations 

under the mining laws. The 

Forest Service can require 

reasonable changes and 

mitigation measures, but does 

not have the authority to deny 

the project because it will 

impact the Arizona Trail.

Trailheads are contained in the 

mitigation measures regarding 

trail relocation. Refer to 

Appendix B and the Recreation 

and Wilderness section in 

chapter 3 of the FEIS for 

further details. 

Development of water sources 

is not currently included in trail 

relocation plans. This can be 

considered once a final 

location of the trail is 

determined. 

Two different locations for 

relocating the Arizona National 

Scenic Trail are addressed in 

the FEIS. The location on the 

east side of SR 83 would not 

locate the trail on any existing 

roads.

A biking route around Mt. 

Wrightson is beyond the scope 

of this decision.
PAGE 12 OF 16

this recreational road use will be 

pushed to other roads in the 

area, some of which are now 

shared with the Arizona Trail. 

This increased road use will 

create safety hazards as well as 

degrade the trail and trail 

experience. To mitigate this 

degradation, new trail must be 

constructed to replace those 

routes now shared with roads, 

and OHV barriers placed at 

potential OHV access points 

along the trail. Non-motorized 

uses in the trail corridor should 

be emphasized in future 

management. The roads of 

concern lie south of the 

proposed mine area and are 

described in the attachment.

Bike route around Mt. Wrightson 

Wilderness: To enhance the 

trail experience for a burgeoning 

segment of the trail user 

population, a bike route is 

necessary around the 

Wilderness area south of the 

proposed mine. This would be a 

newly constructed segment lying 

east of the existing trail, 

departing the existing trail north 

of Patagonia and running to the 

Gardner Canyon area.

Additionally, since Rosemont 

owns the above-described 

private land over which the trail 

would pass, it is expected that 

Rosemont will transfer a 

permanent easement for this 

portion of the trail to Pima 

County or the Forest Service. 

Alternatively, if a suitable route 

can be located, Rosemont could 

construct an additional 

underpass on Forest Servicemanaged public land south of 

the existing underpass in Barrel 

Canyon.

PCS 351: The Coronado 

National Forest should not 

allow the Rosemont Copper 

Company project to move 

forward. Because of impacts to 

the Arizona National Scenic 

Trail.

Further work with the Arizona 

Trail Association has 

occurred since the DEIS was 

released. A revised location 

on the east side of Highway 

83 has been identified. 

Details about this location, its 

characteristics and its 

environmental impacts are 

contained in the Visual 

Quality and Recreation and 

Wilderness sections of 

Chapter 3 in the FEIS. Under 

mining laws, the Forest 

Service may reasonably 

regulate mining activities to 

protect surface resources, 

there are statutory and 

constitutional limits to its 

discretion. The Forest Service 

may reject an unreasonable 

Mine Plan of Operation but 

cannot categorically prohibit 

mining or deny reasonable 

and legal mineral operations 

under the mining laws. The 

Forest Service can require 

reasonable changes and 

mitigation measures, but does 

not have the authority to deny 

the project because it will 

impact the Arizona Trail.

Rosemont Copper has agreed 

to record an easement to allow 

the National Scenic Trail to be 

constructed across their private 

land. Refer to the Recreation 

and Wilderness section in 

chapter 2, and Appendix B of 

the FEIS for further 

information. 
PAGE 13 OF 16

ATA Comment Public Concern Statement Public Concern Statement 

Response

Additional Response

Timing: The timing of these 

mitigation measures is a critical 

concern. The scenic 

degradation has already begun 

with vegetative test plots on the 

mountainside. Permitting and 

construction of the trail re-routes 

can easily encounter delays, so 

to ensure that the trail remains 

intact and a quality recreational 

experience open for use, ATA 

requests that these mitigation 

measures be completed and in 

place before construction of the 

mine begins.

PCS 351: The Coronado 

National Forest should not 

allow the Rosemont Copper 

Company project to move 

forward. Because of impacts to 

the Arizona National Scenic 

Trail.

Further work with the Arizona 

Trail Association has 

occurred since the DEIS was 

released. A revised location 

on the east side of Highway 

83 has been identified. 

Details about this location, its 

characteristics and its 

environmental impacts are 

contained in the Visual 

Quality and Recreation and 

Wilderness sections of 

Chapter 3 in the FEIS. Under 

mining laws, the Forest 

Service may reasonably 

regulate mining activities to 

protect surface resources, 

there are statutory and 

constitutional limits to its 

discretion. The Forest Service 

may reject an unreasonable 

Mine Plan of Operation but 

cannot categorically prohibit 

mining or deny reasonable 

and legal mineral operations 

under the mining laws. The 

Forest Service can require 

reasonable changes and 

mitigation measures, but does 

not have the authority to deny 

the project because it will 

impact the Arizona Trail.

Mitigation timing is discussed in 

the Recreation and Wilderness 

section in chapter 2, and 

Appendix B of the FEIS.

Errata #12.

Electronic file “424.pdf” includes an imprecise measurement for the distance between the mine 

pit and Empire Ranch. The “Additional Response” for letters #12324, #12411, #14293, and 

#24482 on pages 2 and 3 of this file currently states: “The Empire Ranch headquarters is more 

than 8 miles distant from the mine operations area.” 

This should more accurately be stated as: “The Empire Ranch headquarters is more than 6 miles 

from the easternmost edge of the proposed mine pit, which is where blasting vibrations would 

originate.”

Errata #13.

Electronic file “01_Rosemont Commenter Index.pdf” contains a misspelled name on page 115. 

“Burting, Wade” should actually be “Bunting, Wade”.
PAGE 14 OF 16

Mapping Errors

Errata #10. The correct version of figure 62 is provided here. Stock tank numbers were 

inadvertently left off the published figure.
PAGE 15 OF 16

Errata #11. The correct version of figure 69 is provided here with the most current spring location 

data, as used in the analysis.
PAGE 16 OF 16

ATTACHMENT 1 – SIGNATURE PAGE FOR ADVISORY COUNCIL ON 

HISTORIC PRESERVATION