United States 

Department of

Agriculture

Forest 

Service

Southwestern

Region

MB-R3-05-3b

September 2011

Draft Environmental 

Impact Statement for the 

Rosemont Copper 

Project

A Proposed Mining Operation 

Coronado National Forest

Pima County, Arizona

Appendix
The U.S. Department of Agriculture (USDA) prohibits discrimination in all its programs and 

activities on the basis of race, color, national origin, age, disability, and where applicable, sex, marital 

status, familial status, parental status, religion, sexual orientation, genetic information, political 

beliefs, reprisal, or because of all or part of an individual’s income is derived from any public 

assistance program. (Not all prohibited bases apply to all programs.) Persons with disabilities who 

require alternative means of communication of program information (Braille, large print, audiotape, 

etc.) should contact USDA’s TARGET Center at (202) 720-2600 (voice and TTY). To file a complaint 

of discrimination, write to USDA, Director, Office of Civil Rights, 1400 Independence Avenue, SW, 

Washington, DC 20250-9410, or call (800) 795-3272 (voice) or (202) 720-6382 (TTY). USDA is an 

equal opportunity provider and employer.

Printed on recycled paper – September 2011
Draft Environmental Impact Statement for the Rosemont Copper Project 1

A. Executive Summary 

of the Mine Plan of Operations
A. Executive Summary of the Mine Plan of Operations

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A. Executive Summary of the Mine Plan of Operations

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A. Executive Summary of the Mine Plan of Operations

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A. Executive Summary of the Mine Plan of Operations

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A. Executive Summary of the Mine Plan of Operations

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A. Executive Summary of the Mine Plan of Operations

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A. Executive Summary of the Mine Plan of Operations

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A. Executive Summary of the Mine Plan of Operations

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A. Executive Summary of the Mine Plan of Operations

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A. Executive Summary of the Mine Plan of Operations

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A. Executive Summary of the Mine Plan of Operations

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A. Executive Summary of the Mine Plan of Operations

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A. Executive Summary of the Mine Plan of Operations

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A. Executive Summary of the Mine Plan of Operations

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B. U.S. Army Corps of Engineers’ 

Section 404(b)(1) Alternatives Analysis
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C. Draft Monitoring Plan

Introduction

This Monitoring Plan has been developed in conformance with regulatory requirements for the 

Rosemont Copper Project, and to ensure that mitigation for the Rosemont Copper Project is 

implemented effectively. This monitoring plan should be considered to be the framework of a plan 

that specifies monitoring requirements, responsible parties, and funding. It lacks the specificity that is 

necessary for a final monitoring plan. The monitoring plan for the Rosemont Copper Project would 

continue to be refined as permit requirements become known and mitigation measures are more fully 

developed. It is fully expected that a more robust and detailed monitoring plan will be presented in 

the final environmental impact statement (FEIS) and record of decision (ROD).

This Monitoring Plan details the monitoring, reporting, and recordkeeping that will be performed on 

an annual basis. Once the monitoring activities are completed, a Comprehensive Monitoring Report 

summarizing the monitoring efforts for the previous year will be submitted to the 

U.S. Forest Service (Forest Service).

Annually, Rosemont Copper Company (Rosemont Copper) shall facilitate a meeting between the 

Forest Service and the other relevant permitting agencies to review the Comprehensive Monitoring 

Report. The facilitation activities shall include the following: preparing meeting invitations and 

providing a meeting site, administrative support, and supplies as necessary. Rosemont Copper shall 

also be prepared to provide a summary of activities and an overall discussion of compliance.

The Comprehensive Monitoring Report will be reviewed annually for effectiveness and relevance. 

The Comprehensive Monitoring Report shall incorporate this annual review and, if required, any 

proposed changes will be included in the report as well as the rationale for such changes.

A. Geology, Minerals, and Paleontological Resources

Objective: Ensure that paleontological and karst resources are identified and managed, and 

to the extent practical preserved.

Desired Result: To meet the stated objective through survey, reporting, and recovery as deemed 

appropriate. 

Methods: Prior to land-clearing activities, the project area will be inventoried for 

formations that may contain paleontological resources. Identified resources 

of significant value will be appropriately recovered or recorded. During 

construction and operation, these formations, where exposed, will be inspected 

prior to disturbance to ensure that any significant vertebrate paleontological 

resources are recovered. During mining, geologists will monitor wall rock to 

ensure that any significant karst features are identified and appropriately reported 

to the Forest Service.

Responsibility: Rosemont Copper 

Funding: Rosemont Copper
C. Draft Monitoring Plan

126 Draft Environmental Impact Statement for the Rosemont Copper Project

B. Soils

Objective: Ensure the salvage and recovery of reusable soil resources in a manner that 

minimizes sediment delivery to downstream channels from disturbed areas.

Desired Result: Maximize the salvage and reuse of soil resources for reclamation of minedisturbed lands to the extent practicable.

Methods: Soil inventory and salvage data shall be compiled and reported each year for 

acres of disturbance, acres of reclaimed land, and volume or tonnage and location 

of soil resources stored for future use.

Responsibility: Rosemont Copper

Funding: Rosemont Copper

C. Air Quality

Objective: Ensure that air quality standards are met and that air quality is maintained around 

the Rosemont Copper Project.

Desired Result: Air quality meets Clean Air Act standards.

Methods: Methods used to manage and monitor air quality in the area will be identified in 

the final mine plan of operations (MPO) and specified in the Air Quality Permit 

issued by the Pima County Department of Environmental Quality.

Opacity measurements at the property line and emissions from point sources 

must meet standards specified in the Air Quality Permit. The air emissions from 

all point sources will be reviewed regularly as specified by the permit, when 

issued. Dust control plans, which specify controls for fugitive sources, are also 

typically required as part of the Air Quality Permit. If monitoring determines that 

the dust control efforts need to be modified to improve performance, these plans 

will be updated. It is expected that Air Quality Permit conditions will require that 

emissions be observed, measured, and reported on a regular basis. All emissions 

data and operating information that may affect emissions will be stored onsite 

and reported as required by the permit.

Once the Air Quality Permit is issued, this Monitoring Plan will require reporting 

consistent with the specific monitoring requirements of the Air Quality Permit.

Responsibility: Rosemont Copper, Pima County Department of Environmental Quality

Funding: Rosemont Copper
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Draft Environmental Impact Statement for the Rosemont Copper Project 127

D. Groundwater Quantity

Objective: Minimize impacts to groundwater resources. 

Desired Result: Conservation of groundwater resources.

Methods: Groundwater conservation standards are established in management plans for 

each Active Management Area by the Arizona Department of Water Resources 

(ADWR). State ground water permits require that groundwater use be monitored 

and reported to the State annually.

In accordance with these requirements, Rosemont Copper will monitor and 

report on water use to ensure that water use meets or exceeds those conservation 

standards.

Groundwater elevations will be regularly monitored near the operational 

pumping areas, within both the Santa Cruz River valley and the Davidson 

Canyon/Cienega Creek watershed. Groundwater elevations will be measured and 

reported annually. Every 5 years, the results of the groundwater monitoring effort 

will be compared with the groundwater model predictions. The models will then 

be updated and verified to reflect the acquisition of empirical data. Every 5 years, 

Rosemont shall reevaluate sources of water that might be used for operations. 

The information shall be reported in the annual monitoring report for that year. 

Rosemont Copper will report annually to the Forest Service on the voluntary 

commitment to regional groundwater mitigation identified in the final MPO and 

on compliance with contractual commitments regarding localized groundwater 

mitigation as set forth in Rosemont Copper’s agreement with the United 

Sahuarita Well Owners group. 

Responsibility: Rosemont Copper, ADWR

Funding: Rosemont Copper 

E. Groundwater Quality

Objective: The facility will be designed, constructed, and operated so that it ensures the 

greatest degree of discharge reduction achievable through application of the best 

available demonstrated control technology (BADCT), processes, operating 

methods or other alternatives, including, where practicable, 

a technology permitting no discharge of pollutants, including acid rock drainage.

Desired Result: Per the requirements of the Aquifer Protection Permit (APP) program, 

compliance with the facility’s APP is designed to ensure that the discharge of 

pollutants into the groundwater system will not cause or contribute to a violation 

of aquifer quality standards at the point of compliance, or that the discharged 

pollutants do not further degrade aquifer quality for that pollutant if the 

concentration of the subject pollutant was above the standard at the time of 

permit issuance.
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Methods: APP coverage typically requires regular inspections to any facilities thatare 

classified as potentially discharging, and that groundwater quality be monitored 

at the points of compliance throughout the operational and postclosure periods of 

the facility. Groundwater monitoring typically has quarterly and biennial (once 

every second year) constituent lists. The Arizona Department of Environmental 

Quality (ADEQ) may require a different schedule for postclosure monitoring, 

within the closure plan of the APP.

In addition, where a hydrologic sink is anticipated, the APP typically requires 

that the groundwater model for the hydrologic sink (which helps maintain longterm groundwater quality) be updated periodically (typically every 

5 years). Groundwater levels to support this model are expected to be monitored 

on at least an annual basis.

Seepage and leakage monitoring of the various water control facilities will likely 

be included to meet or exceed prescriptive BADCT criteria.

Once the APP is issued, this Monitoring Plan will require reporting on the 

specific monitoring requirements of the permit.

Responsibility: Rosemont Copper, ADEQ 

Funding: Agency data management and inspections are funded through annual registration 

fees paid by permittees (including Rosemont Copper) to ADEQ. Rosemont 

Copper will fund reporting. 

F. Surface Water Quantity

Objective : Minimize impacts to surface water quantity. 

Desired Result: Conservation and/or replacement of surface water resources and identification of 

potential impacts. 

Methods: Develop and implement a Water Source Enhancement and Mitigation Plan; 

Rosemont Copper will develop a water Web site that will be updated no less than 

annually with postings of all water-related data and reports, including surface 

water quantity data and monitoring. The U.S. Geological Survey (USGS) gage at 

Barrel Canyon into Davidson Canyon will be funded by Rosemont Copper. 

Funding will be provided annually by Rosemont Copper for a period that extends 

5 years after the completion of ore extraction.

Spring flow and stream flow will be regularly monitored at sensitive riparian 

locations. Monitoring will be sufficient to identify seasonal variations in flow.

Responsibility: Rosemont Copper, USGS

Funding: Funding for MPO implementation, plan development, Web site, and tank 

replacement and for maintenance of the gage will be provided for on an annual 

basis by Rosemont Copper.
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G. Surface Water Quality

Objective: Minimize the discharge of pollutants in stormwater, in accordance with the 

requirements of the Arizona Pollutant Discharge Elimination System (AZPDES) 

Multi-Sector General Permit (MSGP) and the AZPDES construction general 

permit (CGP); and minimize or mitigate the discharge 

of pollutants into Waters of the United States in accordance with the 

requirements of the Clean Water Act Section 404 individual permit and ADEQ’s 

401 certification of that permit.

Desired Result: Minimize the discharge of pollutants in stormwater through compliance with the 

MSGP, CGP, and 404 permits.

Methods: Application for MSGP or CGP coverage requires the development of a 

stormwater pollution prevention plan (SWPPP), which outlines best management 

practices to minimize the discharge of pollutants in stormwater from the 

construction or industrial site. In addition, the new MSGP requires analytical 

monitoring of stormwater discharges. The SWPPP for the Rosemont Copper 

Project will identify the stormwater outfalls, anticipated stormwater quality, 

monitoring schedule, and analytical parameters that will be monitored as part of 

the project. The MSGP also requires regular visual inspection of stormwater 

discharges and facility inspections to ensure that control measures are 

functioning effectively. All stormwater discharge information will be stored 

onsite and reported as required by the permits and detailed in the SWPPP.

The 404 permit will require the development of habitat mitigation and 

monitoring plan (HMMP) to address compensatory mitigation for impacts to 

waters of the United States. The HMMP will contain reporting requirement 

consistent with U.S. Army Corps of Engineers (USACE) regulations. ADEQ’s 

401 certification of that permit will include conditions to ensure that surface 

water quality standards are not violated. 

Responsibility: Rosemont Copper, ADEQ, USACE

Funding: Agency data management and inspections under the MSGP and CGP program 

will be funded through application and annual registration fees for those permits. 

Rosemont Copper will fund permit compliance and reporting required by the 

MSGP, CGP, and Section 404 permits.

H. Biological Resources (Plants and Animals)

Objectives: (1) Ensure the requirements of Section 7 of the Endangered Species Act are met; 

(2) Ensure that viability of species occurring in the project area are not impacted 

beyond projections disclosed in the FEIS, ROD, and Biological Opinion; (3) 

Ensure success of revegetation efforts; (4) Ensure success of efforts to reduce or 

eliminate invasive and noxious species in disturbed areas; (5) Ensure that process 

water is adequately covered, enclosed or otherwise managed to avoid detrimental 

impacts to wildlife, livestock, and human health; (6) Protect high value riparian 

habitat from livestock grazing.
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Desired Result: (1) Impacts to federally listed and Forest Service sensitive species are reduced or 

avoided; (2) Viability of species are maintained; (3) Revegetation efforts result in 

establishment and distribution of native species that support wildlife habitat, as 

well as reducing erosion potential and provide for livestock grazing; (4) Ensure 

that process water is adequately covered, enclosed, or otherwise managed to 

avoid detrimental impacts to wildlife, livestock, and human health; (5) Protect 

high-value riparian habitat from livestock grazing.

Methods: Portions of the project area contain habitat for three federally listed species 

(Chiricahua leopard frog, lesser long-nosed bat, and Pima pineapple cactus) and 

several other special status or otherwise sensitive species. The Coronado 

National Forest, along with the two federal cooperating agencies (USACE and 

Bureau of Land Management (BLM)), will initiate Endangered Species Act 

Section 7 consultation with the U.S. Fish and Wildlife Service (USFWS) for 

potential impacts to the three federally listed species once a preferred alternative 

is identified, following publication of the DEIS. Once the consultation is 

completed, the USFWS will issue a biological opinion, which will provide an 

analysis of effects on these species, as well as terms and conditions that are 

nondiscretionary requirements of the Biological Opinion. At that time, reporting 

on the implementation and success of these measures will be incorporated into 

this Monitoring Plan. Rosemont Copper anticipates that this Monitoring Plan will 

include activities such as monitoring the nearby lesser long-nosed bat roost for 

use, or monitoring potential habitat for the Chiricahua leopard frog and its use.

In addition, Rosemont Copper intends to develop a conservation program, in 

coordination with USFWS, for both listed species (such as the Chiricahua 

leopard frog) selected sensitive species that are not federally listed. This program 

will include monitoring activities to be completed prior to and during mine 

construction, and through the life of the mine, along with the maintenance and

enhancement of suitable habitat onsite or at appropriate offsite locations. Details 

of the program will be set forth in documents developed in connection with the 

Section 7 consultation. 

Rosemont Copper will also construct and maintain fencing to restrict access to 

sensitive riparian and species breeding areas and to discourage wildlife 

interaction with impacted water resources at the mine. 

Sensitive caves and caverns will also be evaluated for protective measures upon 

discovery through consultation with the Forest Service. 

Rosemont Copper will conduct regular monitoring for noxious weeds and 

invasive species in accordance with the Noxious Weed and Invasive Species 

Management Plan. This plan will be updated as necessary.

Monitoring of revegetation success will be conducted as part of the Reclamation 

Plan.

Rosemont Copper will address potential deleterious exposure of wildlife, 

livestock, and humans to toxic chemicals or hazardous conditions through 

location and construction of facilities, and other measures such as covers, fences, 
C. Draft Monitoring Plan

Draft Environmental Impact Statement for the Rosemont Copper Project 131

or enclosures. The Forest Service will monitor implementation to ensure that the 

requirements contained in the FEIS and ROD are implemented. 

Responsibility: Rosemont Copper, USFWS

Funding: Rosemont Copper

I. Visual Resources

Objective: Verify that the proposed visual mitigation requirements specified in the FEIS and 

ROD are conducted.

Desired Result: Visual impacts of the mine and associated facilities and activities are reduced or 

avoided to levels specified in the ROD. Reclamation reporting will be monitored 

to ensure compliance with commitments therein. 

Methods: Initially, the building colors shall be compared to the proposed and approved 

palette of colors and a report detailing that compliance shall be submitted. For 

any building maintenance activities that involve painting or surface treatment, 

those activities shall be documented and the compliance with the color palette 

reported on for the year. If no maintenance or surface treatment is conducted, this 

shall be noted for the year.

Additionally, Rosemont Reclamation Plan reporting shall include numbers such 

as total disturbance, reclamation activities completed and contemplated, and a 

report on successful reclamation. Other visual mitigation requirements contained 

in the FEIS and ROD will be implemented.

Responsibility: Rosemont Copper

Funding: Rosemont Copper

J. Dark Skies

Objective: Verify that actions and commitments stipulated in the FEIS and ROD to 

minimize effects are implemented and maintained.

Desired Result: Minimization of light pollution to the extent practicable.

Methods: Rosemont Copper will implement their Lighting Plan (M3 Engineering and 

Technology Corporation 2011) and shall monitor light fixtures installed on site to 

ensure the fixtures meet the specifications. If the fixtures do not meet the 

specifications, the reasons shall be documented and the overall increase or 

decrease in light emissions shall be calculated. Options to meet predicted 

specifications will be explored. The calculated changes shall be managed and 

reported in the annual report.

Responsibility: Rosemont Copper

Funding: Rosemont Copper
C. Draft Monitoring Plan

132 Draft Environmental Impact Statement for the Rosemont Copper Project

K. Recreation and Wilderness

Objective: Validate that the mitigation measures required in the FEIS and ROD are 

implemented and maintained.

Desired Result: All trails, access points, recreation, and fencing modifications or enhancements 

identified in the MPO or ROD are constructed or implemented.

Methods: Rosemont Copper, in conjunction with the Forest Service, shall perform an 

annual review of commitments and progress toward completion. The results of 

this review shall be reported to the Forest Service. 

Responsibility: Rosemont Copper, Forest Service 

Funding: Rosemont Copper, Forest Service

L. Hazardous Materials

Objective: Manage hazardous materials as required by Federal, State, and local law.

Desired Result: Ensure that hazardous materials are managed in a manner that reduces potential 

human health and environmental risks.

Methods: The Resource Conservation and Recovery Act (RCRA) specifies how hazardous 

wastes must be managed from cradle to grave. This includes inspection, 

monitoring, planning, and management and reporting procedures if such wastes 

are generated. Rosemont Copper anticipates being a conditionally exempt smallquantity generator and, as a matter of Federal law, Rosemont Copper must 

comply with all applicable requirements of RCRA.

The Toxic Release Inventory (TRI) reporting requirements of the Emergency 

Planning and Community Right to Know section of the Superfund Amendment 

Reauthorization Act requires annual reporting if toxic substances are 

manufactured, processed, or otherwise used onsite. Rosemont Copper must 

comply with applicable monitoring and reporting requirements of TRI.

The Toxic Substances Control Act (TSCA) requires that specific toxic substances 

onsite be monitored and reported on as to their ultimate use and disposition. 

Rosemont Copper must comply with all applicable reporting requirements of 

TSCA.

The Department of Transportation (DOT) has specific requirements for 

packaging, and shipping of hazardous materials. This includes security plans as 

well as the production of shipping papers and specific training for personnel. 

Rosemont Copper must comply with applicable DOT requirements.

The Mine Safety and Health Administration (MSHA) has specific requirements 

for management of hazardous materials onsite. These management procedures 

include specific storage requirements to ensure the materials do not endanger 
C. Draft Monitoring Plan

Draft Environmental Impact Statement for the Rosemont Copper Project 133

human health onsite. Rosemont Copper must meet all applicable MSHA 

requirements.

The Department of Alcohol, Tobacco, Firearms, and Explosives (ATF) has 

specific requirements for the storage and transport of explosive materials, 

including inventories, training, security clearance and storage requirements. 

Rosemont Copper must comply with all applicable requirements from ATF. 

The Oil Pollution Prevention Act has specific requirements for Spill Prevention, 

Control, and Countermeasure (SPCC) Planning. SPCC plans ensure that 

petroleum products are managed with secondary containment and include regular 

inspections. An SPCC plan detailing these controls is required, as is training for 

employees.

Responsibility: Rosemont Copper, U.S. Environmental Protection Agency, MSHA, Pima 

County/ADEQ

Funding: Rosemont Copper must prepare all materials, reports, perform all necessary

Inspections, and take corrective actions required by the terms and conditions of 

the identified permits/plans.

M. Fuels and Fire Management

Objective: Validate that the mitigation measures required in the ROD are implemented and 

maintained.

Desired Result: All specified requirements identified in the ROD are implemented.

Methods: Annual review of facilities or requirements is reported.

Responsibility: Rosemont Copper and Forest Service

Funding: Rosemont Copper

N. Transportation and Access

Objective: Validate that the mitigation measures required in the FEIS and ROD are

implemented and maintained.

Desired Result: All specified requirements identified in the ROD are constructed or otherwise 

implemented.

Methods: Annual review of facilities or requirements is reported.

Responsibility: Rosemont Copper

Funding: Rosemont Copper
C. Draft Monitoring Plan

134 Draft Environmental Impact Statement for the Rosemont Copper Project

O. Noise

Objective: Monitor offsite noise impacts.

Desired Result: Protect workers’ hearing and reduce impacts to local residents and forest 

users.

Methods: Rosemont Copper will install noise/vibration monitors at strategic points 

around the site between the operations and sensitive receptors to check 

operational noise levels.

In addition, MSHA requires that noise levels be monitored to ensure workers’ 

hearing is not affected. Rosemont Copper will conduct periodic monitoring 

of the operations for those levels.

Responsibility: Rosemont Copper, MSHA

Funding: Rosemont Copper

P. Public Health and Safety

Objective: (1) Restrict public access to the project site to ensure public safety; 

(2) develop and maintain a health and safety training plan.

Desired Result: Prevent unauthorized access to the project site; a safe working environment is 

provided.

Methods: MSHA requires that anyone accessing a mine site must have appropriate training 

and safety equipment. Rosemont Copper will restrict access using a combination 

of fencing, gates, berms, and locks to ensure that the public does not access the 

site. A health and safety training plan is required under Federal regulations and 

must be approved by MSHA. 

Responsibility: Rosemont Copper, MSHA

Funding: Rosemont Copper will maintain such structures, prepare appropriate plans, and 

conduct training at their cost.

Q. Cultural Resources

Objective: Appropriate management of cultural resources.

Desired Result: Successful implementation of the approved treatment or testing plan that is 

developed pursuant to the Section 106 consultation process and ensures 

compliance with applicable laws. Implementation of Community Endowment 

mitigation for socioeconomic impacts. 

Methods: Significant survey efforts have identified a variety of archaeological resources 

within the Rosemont Copper Project area. 

Depending on the treatment plans developed through consultation with the State 

Historic Preservation Officer (SHPO) and various tribal representatives, 
C. Draft Monitoring Plan

Draft Environmental Impact Statement for the Rosemont Copper Project 135

archaeological monitoring may be required during the construction and 

operations phase of the mine. At the very least, initial ground-disturbing 

activities near recorded sites will be monitored by a professional archaeologist 

for the presence of additional human remains or archaeological artifacts. 

Rosemont Copper will make a position available for a Tribal representative 

during this period to ensure that the Tribe is informed of cultural findings and 

ground-disturbing activities.

Steps will also be prescribed to mitigate the project’s potential adverse effects on 

National Register of Historic Places eligible historic properties.

Rosemont Copper will create the Santa Rita Mountains Community Endowment 

Trust for purposes of providing a source of funds for community projects to 

preserve open space and meet other needs identified by the community. The Trust 

will seek input from Native American communities relative to recommendations 

for grant recipients from the Trust. 

Responsibility: Rosemont Copper, Forest Service

Funding: Rosemont Copper will be responsible for funding all monitoring and 

implementing the developed treatment plans and will report annually to the 

Forest Service regarding the activities of the Trust.

R. Socioeconomics

Objective: Validate the projected socioeconomic impacts and benefits of the project. 

Desired Result: Measure and validate the effects of the project. 

Methods: Rosemont Copper shall provide annual employment, gross tax, and production 

numbers to the Forest Service to document the overall socioeconomic impact to 

the area as part of the comprehensive monitoring report.

Responsibility: Rosemont Copper

Funding: Rosemont Copper

S. Other

Objective: Mitigate potential damage from mine-related blasting.

Desired Result: Rosemont Copper and any successors in interest or ownership of the mine 

will repair or otherwise pay for all damages to area residential, historical, or 

other structures caused by blasting at the mine.

Methods: Monitoring points will be located between the areas to be blasted and

sensitive receptor sites. Results of blast monitoring will be available to 

agencies and local residents upon request.
C. Draft Monitoring Plan

136 Draft Environmental Impact Statement for the Rosemont Copper Project

Responsibility: Rosemont Copper

Funding: Rosemont Copper

T. Postclosure Monitoring

Objective: Ensure that reclamation methods are successful.

Desired Result: Reclamation measures and activities achieve intended results and conditions.

Methods: All reclaimed sites would be monitored twice a year for a period to be 

determined, in order to evaluate the success of reclamation work. Any areas that 

do not meet the reclamation goals would be analyzed to determine the underlying 

problems, which would be addressed with a modified plan.

Groundwater would be monitored quarterly for a term to be decided by the 

closure requirements specified in the APP.

Surface water would be monitored as required by the AZPDES program. Final 

details and locations will be determined by ADEQ.

Any changes in water quality would be evaluated to determine whether the 

changes are related to the reclaimed mining features, and appropriate steps would 

be taken to address the problem.

Responsibility: Rosemont Copper

Funding: Rosemont Coppe
Draft Environmental Impact Statement for the Rosemont Copper Project 137

D. Visual Simulations (on CD)

Figure 1. Proposed Action (MPO) Viewshed Analysis
D. Visual Simulations (on CD)

138 Draft Environmental Impact Statement for the Rosemont Copper Project

Figure 2. Phased Tailings Viewshed Analysis
D. Visual Simulations (on CD)

Draft Environmental Impact Statement for the Rosemont Copper Project 139

Figure 3. Barrel Viewshed Analysis
D. Visual Simulations (on CD)

140 Draft Environmental Impact Statement for the Rosemont Copper Project

Figure 4. Barrel Trail Viewshed Analysis
D. Visual Simulations (on CD)

Draft Environmental Impact Statement for the Rosemont Copper Project 141

Figure 5. Scholefield-McCleary Viewshed Analysis

Draft Environmental Impact Statement for the Rosemont Copper Project 143

E. U.S. Army Corps of Engineers’ 

Habitat Monitoring Plan
E. U.S. Army Corps of Engineers’ Habitat Monitoring Plan

144 Draft Environmental Impact Statement for the Rosemont Copper Project
E. U.S. Army Corps of Engineers’ Habitat Monitoring Plan

Draft Environmental Impact Statement for the Rosemont Copper Project 145
E. U.S. Army Corps of Engineers’ Habitat Monitoring Plan

146 Draft Environmental Impact Statement for the Rosemont Copper Project
E. U.S. Army Corps of Engineers’ Habitat Monitoring Plan

Draft Environmental Impact Statement for the Rosemont Copper Project 147
E. U.S. Army Corps of Engineers’ Habitat Monitoring Plan

148 Draft Environmental Impact Statement for the Rosemont Copper Project
E. U.S. Army Corps of Engineers’ Habitat Monitoring Plan

Draft Environmental Impact Statement for the Rosemont Copper Project 149
E. U.S. Army Corps of Engineers’ Habitat Monitoring Plan

150 Draft Environmental Impact Statement for the Rosemont Copper Project
E. U.S. Army Corps of Engineers’ Habitat Monitoring Plan

Draft Environmental Impact Statement for the Rosemont Copper Project 151

Draft Environmental Impact Statement for the Rosemont Copper Project 153

F. Tribal Consultation

Table 1. Tribes consulted by the Coronado National Forest regarding the proposed Rosemont 

Copper Mine

Tribe

Tribal Chairperson/

President/ or

Governor

Designated Tribal POC

Ak-Chin Indian Community Louis Manuel, Chairperson

42507 West Peters & Nall Road

Maricopa, AZ 85239

(520) 568-2227

Caroline Antone

Cultural Resources Program Manager

Ak-Chin Him-Dak Eco Museum and 

Archives

47685 N. Eco Museum Road

Maricopa, AZ 85239

Fort Sill Apache Tribe Jeff Houser, Chairperson

Route 2, Box 121

Apache, Oklahoma 73006

(580) 588-2298

Leland Michael Darrow, Historian

Route 2, Box 121

Apache, OK 73006

(580) 588-2298

Bryan Jones, Cultural Coordinator

Fort Sill Apache Tribe

20885 Frontera Road SE

Akela, NM 88030

Gila River Indian Community William R. Rhodes, Governor

P.O. Box 97

Sacaton, AZ 85247

Barnaby Lewis, THPO 

Cultural Resource Management Program

Dept. of Land and Water Resources

P.O. Box 2140

Sacaton, AZ 85247

(520) 562-7152 

Hopi Tribe Leroy Shingoitewa, Chairman 

P.O. Box 123

Kykotsmovi, AZ 86039

(928) 734-3102

Leigh Kuwanwisiwma, Director

Hopi Cultural Preservation Office

P.O. Box 123

Kykotsmovi, AZ 86039

(928) 734-3612; (928) 734-2331 fax

Mescalero Apache Tribe Mark R. Chino, President

MESCALERO APACHE TRIBE

P.O. Box 227

Mescalero, NM 88340

(575) 464-4494

Holly Houghten

Tribal Historic Preservation Officer

Resource Management and Protection

P.O. Box 227/101 Central Avenue

Mescalero, NM 88340

(575) 464-3005; (575) 464-4637 fax

Pascua Yaqui Tribe Peter Yucupicio, Chairman

7474 S. Camino De Oeste

Tucson, AZ 85746

(520) 883-5000; (520) 883-5014 fax

Rolando Flores

Asst. Attorney General

7474 S. Camino De Oeste

Tucson, AZ 85746

(520) 883-5106

Salt River Pima-Maricopa Indian 

Community

Diane Enos, President

10005 E. Osborn

Scottsdale, AZ 85256

(480) 850-8000; (480) 850-7277 fax

Shane Anton

Cultural Programs Supervisor

Angela Garcia-Lewis, NAGPRA & NRHP 

Section 106 Consultation

Community Development Department

Cultural and Environmental Services

10005 E. Osborn Road

Scottsdale, AZ 85256

(480) 362-6331
F. Tribal Consultation

154 Draft Environmental Impact Statement for the Rosemont Copper Project

Tribe

Tribal Chairperson/

President/ or

Governor

Designated Tribal POC

San Carlos Apache Tribe Wendsler Nosie, Sr., Chairman

P.O. Box 0

San Carlos, AZ 85550

(928) 475-2361; (928) 475-2567 fax

Vernelda J. Grant

Tribal Historic Preservation Officer

Historic Preservation and Archaeology 

Department

P.O. Box 0

San Carlos, AZ 85550

(928) 475-5797

Tohono O’odham Nation Ned Norris, Jr. Chairman 

P.O. Box 837

Sells, AZ 85634

(520) 383-2028

Peter Steere

Tribal Historic Preservation Officer

Joseph Joaquin

NAGPRA Coordinator

Natural Resources Dept./Cultural Affairs 

Program 

P.O. Box 837

Sells, AZ 85634

(520) 383-0202

White Mountain Apache Tribe Ronnie Lupe, Chair

P.O. Box 1150

Whiteriver, AZ 85941

(928) 338-4346 x 201

(928) 338-1514 fax

Mark Altaha

Tribal Historic Preservation Officer

Ramon Riley

Cultural Heritage Resources Director

P.O. Box 507

Whiteriver, AZ 85926

(928) 338-3033; (928) 338-6055 fax 

Yavapai-Apache Nation Thomas Beauty, Chairman

2400 W. Datsi Street

Camp Verde, AZ 86322

(928) 567-3649; (928) 567-3994 fax

Vincent Randall

Apache Culture Manager

P.O. Box 21

Clarksdale, AZ 86324

(928) 649-6960

Pueblo of Zuni Arlen Quetawki Sr., Governor

Zuni Tribal Council

P.O. Box 339

Zuni, NM 87327

(505) 782-4481; (505) 782-2700 fax

Kurt E. Dongowski

Tribal Historic Preservation Officer

Kenny Bowekaty

Supervisory Archaeologist

Zuni Heritage and Historic Preservation 

Office

P.O. Box 339

Zuni, NM 87327

(505) 782-4814
Draft Environmental Impact Statement for the Rosemont Copper Project 155

F. Tribal Consultation

Table 2. Summary of tribal consultation activities

Tribe Correspondence Tribe 

Response

Coronado National Forest

Response

Onsite 

Tours of Rosemont 

Copper Project

Additional 

Correspondence

Ak-Chin 

Indian 

Community

9/16/08: Cultural staff 

Duane Antone & Carmen 

Narcia, toured.

CNF Letter 

Introducing Project 

9/26/06

CNF Letter w/ NOI 

3/14/08

4/1/08: Concur with 5 items in CNF 

letter; defer to Tohono O’odham 

(T.O.).

4/25/08: CNF met with Cultural Staff: 

concur with T.O. requests (see T.O. 

below).

6/24/08: CNF presentation to Four 

Southern Tribes Cultural Resources 

Working Group (FSTCRWG).

CNF Letter re: 

Ethnohistory 6/13/08

8/15/08: CNF met with Four So. Tribes 

Cultural Committee and discussed status 

of Rosemont [notes].

Aug/Sept 08: SWCA communications re: 

arrangements for tour.

CNF Letter Archeo 

Report & Request for 

Project Comments

6/22/09

CNF Letter re: 

Alternatives Arch 

Report and 

Ethnohistory 4/01/11

Fort Sill 

Apache 

Tribe

x 10/16/08: Michael Darrow, 

Tribal Historian, toured.

10/17/08: Griset, SWCA, 

interviewed Michael 

Darrow, Tribal Historian.

CNF Letter 

Introducing Project 

9/26/06
156 Draft Environmental Impact Statement for the Rosemont Copper Project

F. Tribal Consultation

Tribe Correspondence Tribe 

Response

Coronado National Forest

Response

Onsite 

Tours of Rosemont 

Copper Project

Additional 

Correspondence

CNF Letter w/ NOI 

3/14/08

CNF Letter re: 

Ethnohistory 6/13/08

Sep/Oct 08: SWCA communications re: 

arrangements for Oct tour.

CNF Letter Archeo 

Report & Request for 

Project Comments

6/22/09

CNF Letter re: 

Alternatives Arch 

Report and 

Ethnohistory 4/01/11

Gila River 

Indian 

Community

x 9/16/09: Barnaby had to 

cancel attendance at tour.

5/1/09: Barnaby Lewis 

toured.

CNF Letter 

Introducing Project 

9/26/06

CNF Letter w/ NOI 

3/14/08

6/24/08: CNF Presentation to 

FSTCRWG.

CNF Letter re: 

Ethnohistory 6/13/08

8/15/08: CNF met with FSTCRWG 

and discussed status of Rosemont 

[notes].

Aug/Sept 08: SWCA communications re: 

arrangements for Sep & Oct tours.

3/17/09: SWCA email to Barnaby Lewis 

to see if interested in Spring tour.

CNF Letter Archeo 

Report & Request for 

Project Comments

6/22/09

CNF Letter re: 

Alternatives Arch 

Report and 

Ethnohistory 4/01/11
Draft Environmental Impact Statement for the Rosemont Copper Project 157

F. Tribal Consultation

Tribe Correspondence Tribe 

Response

Coronado National Forest

Response

Onsite 

Tours of Rosemont Copper Project

Additional 

Correspondence

Hopi Tribe

x

CNF Letter 

Introducing Project 

9/26/06

10/16/06: Letter stating concerns 

and requesting copies of arch 

survey.

2/21/07: CNF met with Hopi @ 

Kykotsmovi re: concerns about 

NAGPRA repatriation & conducting 

a TCP study.

CNF Letter w/ NOI 

3/14/08

4/4/08: Hopi request repatriation of 

75 sets of human remains from 

ANAMAX project; support “No 

Action” alternative in the EIS.

CNF Letter re: 

Ethnohistory 6/13/08

7/1/08: reiterate concerns re: adverse 

effects; desire to be consulted on 

TCPs and ethnohistory, and formal 

claim for repatriation of human 

remains; later defer to T.O. for 

repatriation.

On Site 

Tours of RCP

2/23/09: SWCA left message with 

Terry Morgart inviting Hopi to tour

3/11/09: Terry Morgart returned 

telephone call to say that Hopi will 

not tour, defer to the Four Southern 

Tribes, and stand by Hopi concerns 

in 7/1/08 letter.

CNF Letter Archeo 

Report & Request for 

Project Comments

6/22/09

6/30/09: Letter opposing project and 

disturbance of human remains; will 

review the Ethnohistory; want to 

meet with CNF to renew their MOU.
158 Draft Environmental Impact Statement for the Rosemont Copper Project

F. Tribal Consultation

Tribe Correspondence Tribe 

Response

Coronado National Forest

Response

Onsite 

Tours of Rosemont 

Copper Project

Additional 

Correspondence

CNF Letter re: 

Alternatives Arch 

Report and 

Ethnohistory 4/01/11

5/23/11: Restate opposition to 

project’s destruction of cultural 

resources and request continuing 

consultation, including DEIR, 

HPTP, NAGPRA Plan of Action, 

and MOA.

Mescalero 

Apache 

Tribe

10/16/08: Holly Houghten, 

THPO, toured.

Feb/Mar 09: various 

telephone calls and emails 

re: arrangements for elders 

to visit.

3/23 - 3/24/09: Mescalero 

elders visited project area; 

Zelda Yazza provided plant 

information to Griset, 

SWCA. CNF/SWCA 

accompanied elders on 1st 

day; 2nd day 

unaccompanied

5/13/09: CNF sent 

Houghten copies of video 

of Zelda Yazza 

describing plant uses in 

RCP.

CNF Letter 

Introducing Project 

9/26/06

CNF Letter w/ NOI 

3/14/08

CNF Letter re: 

Ethnohistory 6/13/08

8/28/08: SWCA spoke with Holly 

Houghten re: upcoming tours.

Sep/Oct 08: SWCA communications re:

arrangements for Oct tour.

CNF Letter Archeo 

Report & Request for 

Project Comments

6/22/09
Draft Environmental Impact Statement for the Rosemont Copper Project 159

F. Tribal Consultation

Tribe Correspondence Tribe 

Response

Coronado National Forest

Response

Onsite 

Tours of Rosemont Copper Project

Additional 

Correspondence

CNF Letter re:

Alternatives Arch 

Report and 

Ethnohistory 4/01/11

Pascua 

Yaqui Tribe

3/17/09: Left voice 

message for Rolando 

Flores regarding tour. 

9/15/08: SWCA faxed 

copies of CNF letter to A. 

Reyes.

10/1/08: SWCA resent 

faxes.

CNF Letter 

Introducing Project 

9/26/06

CNF Letter w/ NOI 

3/14/08

CNF Letter Re:

Ethnohistory 6/13/08

Aug/Sep 08: SWCA communications with 

A. Reyes re: Sept and Oct tours; no

response.

2/23/09: Left telephone message with 

secretary for Rolando Flores regarding 

tour; no response.

CNF Letter Archeo 

Report & Request for 

Project Comments

6/22/09

CNF Letter re: 

Alternatives Arch 

Report and 

Ethnohistory

4/01/11
160 Draft Environmental Impact Statement for the Rosemont Copper Project

F. Tribal Consultation

Tribe Correspondence Tribe 

Response

Coronado National Forest

Response

Onsite 

Tours of Rosemont 

Copper Project

Additional 

Correspondence

Salt River 

PimaMaricopa 

Indian 

Community

9/16/08: Cultural Programs 

staff Shane Anton & Jacob 

Butler toured.

CNF Letter 

Introducing Project 

9/26/06

CNF Letter w/NOI 

3/14/08

6/24/08: CNF presentation to 

FSTCRWG.

CNF Letter re: 

Ethnohistory 6/13/08

8/15/08: CNF met with FSTCRWG 

and discussed status of Rosemont 

[notes].

Aug/Sep 08: SWCA communications re: 

arrangements for tour.

CNF Letter Archeo 

Report & Request for 

Project Comments

6/22/09

CNF Letter re: 

Alternatives Arch 

Report and 

Ethnohistory 4/01/11

San Carlos 

Apache 

Tribe

4/28/09: Vernelda unable 

to tour; sent Michael Park 

Hill as her representative.

CNF Letter 

Introducing Project 

9/26/06

CNF Letter w/ NOI 

3/14/08
Draft Environmental Impact Statement for the Rosemont Copper Project 161

F. Tribal Consultation

Tribe Correspondence Tribe 

Response

Coronado National Forest

Response

Onsite 

Tours of Rosemont Copper Project

Additional 

Correspondence

CNF Letter re: 

Ethnohistory 6/13/08

8/18/08: CNF met with San Carlos 

and White Mtn. THPOs and 

discussed current status of 

Rosemont.

11/14/08: Vernelda wants to delay tour 

until Spring.

2/23/09: SWCA left msg for Vern 

inviting to tour; no response.

3/20/09: SWCA sent email asking if 

Vernelda could tour on May 1st.

CNF Letter Archeo 

Report & Request for 

Project Comments

6/22/09

CNF Letter re: 

Alternatives Arch 

Report and 

Ethnohistory 4/01/11

Tohono 

O’odham 

Nation

9/16/08: Tribal Council, 

Legislature’s Cultural & 

Natural Resources 

Committees, & Cultural Staff toured.

10/16/08: San Xavier 

District Cultural 

Committee and Allottee 

Association toured.

1/28/09: District 

Chairpersons and Natural 

Resources Div staff toured.

CNF Letter 

Introducing Project 

9/26/06
162 Draft Environmental Impact Statement for the Rosemont Copper Project

F. Tribal Consultation

Tribe Correspondence Tribe 

Response

Coronado National Forest

Response

Onsite 

Tours of Rosemont Copper Project

Additional 

Correspondence

CNF Letter w/ NOI 

3/14/08

4/1/08: Peter Steere and Mary 

Farrell, CNF, spoke over phone 

about T.O. response to 3/14/08 

letter. Suggested CNF meet with 

T.O. Legislature’s Cultural 

Committee.

4/25/08: CNF met with Cultural Staff; 

they suggested CNF make presentation 

to Tribal Council’s Cultural Committee 

& do onsite tour.

CNF presentation to:

6/17/08: Legislative Council’s Cultural 

Committee;

6/17/08: T.O. Cultural Center & Museum 

Staff; and

6/24/08: FSTCRWG.

CNF Letter re: 

Ethnohistory 6/13/08

8/15/08: CNF met with FSTCRWG 

and discussed status of Rosemont.

Aug/Sept 08: SWCA communications re: 

arrangements for tour.

9/12/08: CNF presentation to Tribal 

Council.

Oct 08: SWCA communications re: 

arrangements for tour.

11/6/08: CNF presentation to San Xavier 

Cultural Committee

12/17/08: CNF presentation to Tribal 

District Chairpersons Committee, at San 

Xavier.

Jan 09: SWCA communications re: 

arrangements for tour.

CNF Letter Archeo 

Report & Request for 

Project Comments

6/22/09

8/13/09: CNF sent copy of 6/22/09 

letter to Cultural Committee.

8/25/09: CNF met with Legislature’s 

Cultural & Natural Resources 

committees & Attorneys at their 

request to update on project.

8/27/09: Letter from Peter Steere

with comments on Alternatives.

10/22/09: Resolution 09-569 

opposing the RCP passed by T.O. 

Legislature

2/3/10: Email from Peter Steere with 

comments on survey report
Draft Environmental Impact Statement for the Rosemont Copper Project 163

F. Tribal Consultation

Tribe Correspondence Tribe 

Response

Coronado National Forest

Response

Onsite 

Tours of Rosemont Copper Project

Additional 

Correspondence

CNF Letter re: 

Alternatives Arch 

Report and 

Ethnohistory 4/01/11

5/9/11: Comments on reports and 

restatement of opposition to project 

and request for continuing tribal 

consultation

White

Mountain 

Apache 

Tribe

10/16/08: Mark Altaha, 

THPO, toured.

CNF Letter 

Introducing Project 

9/26/06

10/30/06: Letter deferring to San 

Carlos Apache.

CNF Letter w/ NOI 

3/14/08

CNF Letter re: 

Ethnohistory 6/13/08

8/18/08: CNF met with San Carlos 

and White Mtn. THPOs and 

discussed current status of 

Rosemont.

11/5/08: CNF telephone 

conversation includes invite for 

elders to tour.

8/28/08: SWCA spoke with Mark Altaha 

re: upcoming tours/

Sept 08: SWCA communications re: 

arrangements for Oct tour.

CNF Letter Archeo 

Report & Request for 

Project Comments

6/22/09

7/8/09 Received email and official 

letter stating no interests in the 

project area.

CNF Letter re: 

Alternatives Arch 

Report and 

Ethnohistory 4/01/11
164 Draft Environmental Impact Statement for the Rosemont Copper Project

F. Tribal Consultation

Tribe Correspondence Tribe 

Response

Coronado National Forest

Response

Onsite 

Tours of Rosemont Copper Project

Additional 

Correspondence

Yavapai-

Apache 

Nation

2/23/09: SWCA left 

message for Vince Randall 

inviting to tour; no 

response.

3/17/09: SWCA spoke with 

Chris Coder, tribal 

archaeologist; they will not 

tour the project area. 

Continue to send them 

correspondence on the 

project.

CNF Letter 

Introducing Project 

9/26/06

CNF Letter w/ NOI 

3/14/08

CNF Letter re: 

Ethnohistory 6/13/08

CNF Letter Archeo 

Report & Request for 

Project Comments

6/22/09

CNF Letter re: 

Alternatives Arch 

Report and 

Ethnohistory 4/01/11
Draft Environmental Impact Statement for the Rosemont Copper Project 165

F. Tribal Consultation

Tribe Correspondence Tribe 

Response

Coronado National Forest

Response

Onsite 

Tours of Rosemont Copper Project

Additional 

Correspondence

Pueblo of 

Zuni

2/24/09: SWCA left 

message for Kurt 

Dongoske inviting to tour; 

no response.

4/15/09: Email from 

Mary Farrell, CNF to 

Dongoske asking if Zuni 

wants to tour or comment 

on project; CNF will send 

Zuni copies of previous 

CNF letters regarding the 

project.

CNF Letter 

Introducing Project 

9/26/06

CNF Letter w/ NOI 

3/14/08

CNF Letter re: 

Ethnohistory 6/13/08

CNF Letter Archeo 

Report & Request for 

Project Comments

6/22/09

9/9/09: Griset, SWCA, interviewed 

Peter Steere.

9/11/09: Telephone conv. between 

Mary Farrell, CNF and Kurt 

Dongoske discussing project; he will 

submit formal comment to CNF; 

suggested references for Zuni 

ethnohistory

9/11/09: Letter from Zuni THPO 

Dongoske to CNF requesting multi-

phase Zuni collaboration on 

identifying TCPs, sacred sites, and 

resources of interest. No comments 

on draft survey report.

11/4/09: Griset, SWCA interviewed 

Kenny Bowekaty, Zuni supervisory 

archaeologist

CNF Letter re: 

Alternatives Arch 

Report and 

Ethnohistory 4/01/11