United States Department of Agriculture

Forest 

Service 

Southwestern 

Region

MB-R3-05-6d 

December 2013

Final Environmental 

Impact Statement for the 

Rosemont Copper 

Project

A Proposed Mining Operation 

Coronado National Forest 

Pima County, Arizona

Volume 5 - Appendix 
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Printed on recycled paper – December 2013
Environmental Impact Statement for the 

Rosemont Copper Project

Coronado National Forest

Pima County, Arizona

Lead Agency: U.S. Department of Agriculture Forest Service

Cooperating Agencies: Bureau of Land Management, National Park Service, Saguaro 

National Park, Smithsonian Astrophysical Observatory – Fred 

Lawrence Whipple Observatory, U.S. Army Corps of Engineers, 

U.S. Department of the Air Force Davis-Monthan Air Force Base 

162nd Fighter Airwing, Arizona Department of Environmental 

Quality, Arizona Department of Mines and Mineral Resources, 

Arizona Department of Transportation, Arizona Department of Water 

Resources, Arizona Game and Fish Department, Arizona Geological 

Survey, Arizona State Land Department, Arizona State Mine 

Inspector, Arizona State Parks, Pima County, City of Tucson, Town 

of Sahuarita 

Responsible Official: Jim Upchurch, Coronado National Forest, Forest Supervisor

300 W. Congress St.

Tucson, AZ 85701

For Information Contact: Bev Everson, Interdisciplinary Team Leader

300 W. Congress St.

Tucson, AZ 85701

(520) 388-8300

Abstract: This final environmental impact statement (FEIS) documents the analysis of six 

alternatives (including a “no action” alternative) that was developed for the Rosemont Copper 

Project analysis. Alternative 4 – Barrel Alternative is the U.S. Forest Service preferred alternative. 

The Notice of Intent to prepare this document was published in the Federal Register on March 13, 

2008. The public comment period was subsequently extended with a Notice of Intent that was 

published in the Federal Register on April 29, 2008. The draft environmental impact statement 

(DEIS) was released for public comment with a Notice of Availability (NOA) on October 19, 2011. 

The NOA was later revised to update meeting information and published on December 6, 2011. 

Subsequently, the comment period was extended with a Notice of Extension published in the Federal 

Register on January 27, 2012. 

The Rosemont Copper Project proposes to mine copper and associated minerals on the Nogales 

Ranger District of the Coronado National Forest. The proposed activities include an amendment to 

the 1986 “Coronado National Forest Land and Resource Management Plan.”

Final Environmental Impact Statement for the Rosemont Copper Project i 

Acronyms and Abbreviations

Documents

forest plan “Coronado National Forest Land and Resource Management Plan,” 

as amended (U.S. Forest Service 1986)

preliminary MPO preliminary mine plan of operations (WestLand Resources Inc. 2007)

Other abbreviations

°F degrees Fahrenheit

ΔE color difference index

AAC Arizona Administrative Code

ACC Arizona Corporation Commission

ADEQ Arizona Department of Environmental Quality

ADOT Arizona Department of Transportation

ADWR Arizona Department of Water Resources

AGFD Arizona Game and Fish Department

AGS Arizona Geological Survey

ARS Arizona Revised Statutes

ASLD Arizona State Land Department

Augusta Resource Augusta Resource Corporation

AUM animal unit month

BLM Bureau of Land Management

CAA Clean Air Act

CAFÉ corporate average fuel economy

CD compact disc

CaCO3 calcium carbonate

CEC Certificate of Environmental Compatibility

Census U.S. Census

CEQ Council on Environmental Quality

Final Environmental Impact Statement for the Rosemont Copper Project iii
Acronyms and Abbreviations

CFR Code of Federal Regulations

CH4 methane

CO carbon monoxide

CO2 carbon dioxide

CWA Clean Water Act

dB decibel

dBA A-weighted decibel

DEIS draft environmental impact statement

EIS environmental impact statement

EPA U.S. Environmental Protection Agency

ESA Endangered Species Act

FEIS final environmental impact statement

Forest Service U.S. Forest Service

FSH Forest Service Handbook

FSM Forest Service Manual

g the acceleration due to gravity equaling 32 feet per second squared

GIS geographic information system

GPS global positioning system

HPTP historic properties treatment plan

Hz hertz

I- interstate

ID team interdisciplinary team

IMPLAN Impact Analysis for Planning

iv Final Environmental Impact Statement for the Rosemont Copper Project
Acronyms and Abbreviations

kHz kilohertz

kV kilovolt

lb/mile pound per mile

LED light emitting diode

m3

/m2 cubic meter(s) per square meter

mg/L milligram(s) per liter

μg/m3 microgram(s) per cubic meter

MOA memorandum of agreement

MOU memorandum of understanding

mpg mile(s) per gallon

MPO mine plan of operations

MSHA Mine Safety and Health Administration

MW megawatt(s)

NAAQS national ambient air quality standards

NAGPRA Native American Graves Protection and Repatriation Act

NEPA National Environmental Policy Act

NFS National Forest System

NFSR National Forest System road

N2O nitrous oxide

NO2 nitrogen dioxide

NOx nitrogen oxides

NRHP National Register of Historic Places

O3 ozone

Pb lead

PM2.5 particulate matter less than or equal to 2.5 microns in diameter

Final Environmental Impact Statement for the Rosemont Copper Project v
Acronyms and Abbreviations

PM10 particulate matter less than or equal to 10 microns in diameter

REMI Regional Economic Models Incorporated

ROD record of decision

Rosemont Copper Rosemont Copper Company

Rosemont Copper Project EIS Rosemont Copper Project Environmental Impact Statement

ROW right-of-way

SHPO State Historic Preservation Office

SO2 sulfur dioxide

SR State Route

TCP traditional cultural property

TEP Tucson Electric Power Company

the Coronado Coronado National Forest (the agency)

USACE U.S. Army Corps of Engineers

U.S.C. United States Code

USFWS U.S. Fish and Wildlife Service

USGS U.S. Geological Survey

VOC volatile organic compound

WUS waters of the United States

vi Final Environmental Impact Statement for the Rosemont Copper Project
Contents

Appendix

Volume 5

A. U.S. Army Corps of Engineers' Section 404(b)(1) Alternatives Analysis.............................A-1

B. Mitigation and Monitoring Plan (includes U.S. Army Corps of Engineers’ Habitat 

Mitigation Plan).....................................................................................................................B-1

C. Visual Simulations.................................................................................................................C-1

D. Memorandum of Agreement (prepared under Section 106 of the National Historic 

Preservation Act)...................................................................................................................D-1

E. Tribal Consultation ................................................................................................................ E-1

Volume 6

F. U.S. Fish and Wildlife Service Biological Opinion.................................................................. F-1

G. Summary of Response to Comments on the DEIS ...................................................................G-1

We have made every attempt to make these documents accessible to people with disabilities. 

If you cannot fully access the information on a particular page, please call us at (520)388-8300.

USDA Target Center

The USDA TARGET Center converts USDA information and documents into alternative formats, 

including Braille, large print, video description, diskette, and audiotape. For more information, visit 

the TARGET Center's Web site or call the Center at (202) 720-2600 (Voice/TTY).

Final Environmental Impact Statement for the Rosemont Copper Project vii

A. U.S. Army Corps of Engineers' Section 

404(b)(1) Alternatives Analysis

Final Environmental Impact Statement for the Rosemont Copper Project A-1

ROSEMONT COPPER PROJECT ______________________________

CWA SECTION 404(B)(1)

ALTERNATIVES ANALYSIS

(SPL-2008-00816-MB)

Prepared for:

ROSEMONT COPPER COMPANY

2450 West Ruthrauff Road, Suite 180

Tucson, Arizona 85705

Prepared by:

4001 East Paradise Falls Drive

Tucson, Arizona 85712 

September 2013 

Project No. 1049.15
Rosemont Copper Project September 10, 2013

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TABLE OF CONTENTS 

1. INTRODUCTION ........................................................................................................................... 1

1.1. Document Purpose and Organization ....................................................................................... 1

1.2. Project History and Background .............................................................................................. 2

1.3. Purpose and Need for the Project ............................................................................................. 3

1.4. Physical and Natural Environment ........................................................................................... 3

1.5. Jurisdictional Waters of the United States ................................................................................ 4

2. FORMULATION OF ALTERNATIVES......................................................................................... 6

2.1. Criteria for Detailed Analysis of Alternatives........................................................................... 6

2.1.1. Practicability................................................................................................................. 6

2.1.2. Impacts to Aquatic Ecosystem .................................................................................... 10

2.1.3. Other Environmental Impacts...................................................................................... 10

2.2. Offsite Alternatives................................................................................................................ 10

2.2.1. Status of Copper Industry in 2005 ............................................................................... 11

2.2.2. Offsite Alternatives..................................................................................................... 11

2.2.3. Offsite Alternatives Summary ..................................................................................... 23

2.3. Rosemont-Owned Alternative Mineral Deposits..................................................................... 23

2.3.1. Broad Top Butte ......................................................................................................... 24

2.3.2. Copper World ............................................................................................................. 25

2.3.3. Peach-Elgin ................................................................................................................ 26

2.3.4. Rosemont-Owned Alternatives Summary.................................................................... 26

2.4. Onsite Alternatives ................................................................................................................ 27

2.4.1. Onsite Alternatives Development................................................................................ 28

2.4.2. Elements Common to All Onsite Alternatives ............................................................. 30

3. ALTERNATIVES DESCRIPTION, PRACTICABILITY DETERMINATION, AND 

ENVIRONMENTAL ANALYSIS......................................................................................................... 33

3.1. Onsite Configuration Alternatives.......................................................................................... 34

3.1.1. Alternative 1 – Mine Plan of Operations...................................................................... 34

3.1.2. Alternative 2 – Phased Tailings................................................................................... 37

3.1.3. Alternative 3 – Barrel (Proposed Action)..................................................................... 38

3.1.4. Alternative 4 – Barrel Trail ......................................................................................... 38

3.1.5. Alternative 5 – Scholefield-McCleary ......................................................................... 39

3.1.6. Alternative 6 – Modified Pit Configuration ................................................................. 42

3.1.7. Removal of Heap Leach and Associated Facilities....................................................... 44

3.2. Utility Line Alternatives ........................................................................................................ 46

3.2.1. Power ......................................................................................................................... 46

3.2.2. Water.......................................................................................................................... 47

4. SUMMARY AND CONCLUSIONS ............................................................................................. 49

5. REFERENCES.............................................................................................................................. 52

TABLES 

Table 1. Arizona Copper Mine Production, 2005........................................................................ 11 

Table 2. Arizona Copper Projects, 2005 ..................................................................................... 12 

Table 3. Summary of Key Elements of Onsite Alternatives ........................................................ 36 

Table 4. Impacts to Potential Waters of the U.S. from Transmission Line Alternatives ............... 47 

Table 5. Summary of Impacts and Practicability of Onsite Alternatives...................................... 51 
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FIGURES 

(follow text) 

Figure 1. Vicinity Map

Figure 2. Potential Waters of the U.S.

Figure 3. Operating Copper Mines, 2005

Figure 4. Arizona Copper Projects, 2005

Figure 5. Alternative Mineral Sources 

Figure 6. Alternative 1 – Original Mine Plan of Operations

Figure 7. Downstream Dewatering Effects

Figure 8. Alternative 2 – Phased Tailings

Figure 9. Alternative 3 – Barrel

Figure 10. Alternative 4 – Barrel Trail

Figure 11. Alternative 5 – Scholefield-McCleary

Figure 12. Alternative 5 – Scholefield-McCleary Cross-section

Figure 13. Alternative 6 – Modified Pit Configuration with Wasp Canyon Open

Figure 14. Alternative 1A – Mine Plan of Operations without Heap Leach and SX/EW Facilities

Figure 15. Alternative 2A – Phased Tailings without Heap Leach and SX/EW Facilities

Figure 16. Alternative 4A – Barrel Trail without Heap Leach and SX/EW Facilities

Figure 17. Alternative 5A – Scholefield-McCleary without Heap Leach and SX/EW Facilities

Figure 18. Proposed Power Alignment Alternatives

Figure 19. Proposed Water Line

APPENDICES

Appendix A. Rosemont Letters Regarding Nearby Deposits

Appendix B. Pit Backfill Response

Appendix C. Rosemont Technical Memorandum – Avoidance of Wasp Canyon Wash
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1. INTRODUCTION

1.1. DOCUMENT PURPOSE AND ORGANIZATION

Rosemont Copper Company (the Applicant) proposes to develop an open pit copper mine known as the 

Rosemont Copper Project (Project). Because portions of the Project occur on lands managed by the U.S. 

Forest Service, Coronado National Forest (CNF), the Applicant submitted a Mine Plan of Operations 

(MPO) (WestLand, 2007) to the CNF. The CNF deemed the MPO complete for the purpose of initiating 

review under the National Environmental Policy Act (NEPA) and is in the process of developing an 

Environmental Impact Statement (EIS). The U.S. Army Corps of Engineers (Corps) is a cooperating 

agency in the EIS development process due to anticipated impacts to potentially jurisdictional waters of 

the U.S. 

In addition to the development of an EIS by the CNF, an analysis of alternatives to the proposed Project is 

required by the Corps to demonstrate compliance with guidelines established under the Clean Water Act 

(CWA), Section 404(b)(1) (40 C.F.R. §230), for avoidance and minimization of impacts to jurisdictional 

waters of the United States. The alternatives analysis is intended to ensure that no discharge be permitted 

“if there is a practicable alternative to the proposed discharge which would have less adverse impact on 

the aquatic ecosystem, so long as the alternative does not have other significant adverse environmental 

consequences” (40 C.F.R. §230.10(a)). 

This analysis identifies a number of alternatives to accomplish the Project purpose and evaluates the 

practicability of each alternative as well as the expected environmental impacts of each. The formulation 

of alternatives to the proposed Project relies in part on the alternatives developed through the U.S. Forest 

Service review of the Rosemont Project MPO (WestLand, 2007).

This alternatives analysis is presented in three sections:

Section 1: Introduction. This section includes historical information, a description of the purpose and 

need for the Project, and a description of the proposed Project area.

Section 2: Formulation of Alternatives. Section 2 provides a description of the general approach taken in 

formulating alternatives, including the geographic scope of the alternatives, a description of the criteria 

reviewed in the analysis, the preferred alternative, and other onsite and offsite alternatives considered that

could potentially satisfy the Applicant’s overall Project purpose.

Section 3: Alternatives Description. Section 3 provides a description and evaluation of the practicability 

of each of the alternatives considered and the impact of each alternative on the aquatic ecosystem and on 

the overall environment.
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1.2. PROJECT HISTORY AND BACKGROUND

The Rosemont Copper Property (Property) consists of a group of patented mining claims, unpatented 

mining claims, and fee land that covers most of the Rosemont Mining District and the adjacent Helvetia 

Mining District within unincorporated Pima County in southeastern Arizona. Specifically, the Property is 

located approximately 30 miles southeast of Tucson, west of State Route 83 (SR 83), in portions of 

Sections 1, 2, 10–15, 22–25, 35, and 36, Township 18 South, Range 15 East, portions of Sections 1 and 2, 

Township 19 South, Range 15 East, portions of Sections 6–8, 14–23, and 27–33, Township 18 South, 

Range 16 East, and portions of Sections 4, 5, and 6, Township 19 South, Range 16 East (Figure 1). 

Primary access to the Property will be from Interstate 10 (I-10) to SR 83 south, then west on the Project’s 

main access road. There is a secondary access from the west for utility corridor maintenance and 

emergency purposes. The access and utility alignment traverses the Santa Rita Experimental Range and 

private properties that lie northwest of the Project. The utility corridor will contain both a 138 kV 

powerline and a waterline.

As explained more fully below, current estimates are that the Rosemont deposit consists of 667 million 

tons of proven and probable mineral reserves. Additional mineralized material has been identified in 

association with the Broad Top Butte, Copper World, and Peach-Elgin deposits.

The core of the Property consists of 132 patented lode claims1 that in total encompass an area of 

1,969 acres. A contiguous group of 899 unpatented lode claims2 with a total area of approximately 

12,000 acres surrounds the patented claims. There are also 14 parcels of Rosemont-owned fee land 

grouped into six individual areas that total 911 acres on the east side of the Santa Rita Mountains. These 

patented claims, unpatented claims, and fee lands cover approximately 14,880 acres and, together, are 

referred to as the Rosemont Holdings. For the purposes of this 404(b)(1) analysis, the Project “site” is 

comprised of that portion of the aggregated Rosemont Holdings that was considered for onsite 

alternatives. This area comprises the entirety of the Barrel Canyon drainage from the Santa Rita Mountain 

ridgeline on the west, south to the upper Cienega Creek watershed boundary, east to SR 83, and north to 

Scholefield Canyon.

Most of the unpatented claims are located on federal land administered by the CNF, but a limited number 

of claims in the northwest portion of the Property are on federal land administered by the Bureau of Land 

Management (BLM). The Project does not include any activities on BLM land. The area surrounding the 

claims and fee properties is generally state and federal lands and undeveloped rangeland, with limited 

 

1 A “patented lode claim” is a parcel of fee land that was conveyed by the United States government to an individual or company pursuant to 

the Mining Law of 1872. Generically, a “patent” is a deed issued by the United States—it is the evidence of right, title, and/or interest in a 

parcel of land, as first granted by the United States.

2 An “unpatented lode claim” is a parcel of land claimed by an individual or company pursuant to the Mining Law of 1872, but which has not 

been patented. The owner of an unpatented lode claim does not need a patent, or a vested right to issuance of a patent, to possess and 

use the land for legitimate mining or milling purposes. Further, an unpatented lode claim is property in the fullest sense of the word, and the 

owner is not required to secure patent from the United States—so long as the owner complies with all the provisions of the Mining Law of 

1872, his possessory right, for all practical purposes of ownership, is as good as though secured by a patent. See United States v. 

Shumway, 199 F.3d 1093, 1105 (9th Cir. 1999).
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private property. The area in the vicinity of the Project is used primarily for cattle grazing, with 

substantial public use for recreational purposes.

The Property is situated mainly on the east side of the Santa Rita Mountains. The existing large-scale 

mining activities that have been ongoing in the region occur on the west side of the range, along the 

Interstate 19 corridor south of Tucson. Production from mines in the Helvetia District and to a lesser 

extent the Rosemont District occurred from the late 1800s until 1951, producing approximately 227,300 

tons of ore. Ore production in the area ceased in 1951 and has not been resumed as of 2013, although 

exploration of the Rosemont deposit and (to a significantly lesser extent) the Broad Top Butte and 

Peach-Elgin prospects has been carried out over the ensuing years.

1.3. PURPOSE AND NEED FOR THE PROJECT

In accordance with the requirements of the CWA Section 404(b)(1) guidelines, for the purpose of 

determining a project’s water dependency, the basic Project purpose is copper mining.3 For the purpose of 

developing alternatives, the Corps has determined that the overall project purpose is to develop the 

mineral resources associated with an ore deposit in southeastern Arizona (Pima, Pinal, Gila, Graham, 

Greenlee, Cochise, and Santa Cruz counties) using conventional open pit mining and processing of copper 

ores for the purpose of producing copper and/or copper precursors, silver, and molybdenum.4

 

The Applicant’s purpose and need for the Project is to mine and process copper ore from the Rosemont 

ore deposit for the purpose of producing copper and/or copper precursors, as well as recovering byproduct metals such as silver and molybdenum, in a manner that is sensitive to the natural environment 

and in compliance with applicable regulations, with an economic return adequate to justify the 

development costs and risks associated with the construction of the mine site and associated facilities.

1.4. PHYSICAL AND NATURAL ENVIRONMENT

The primary drainage in the Project site is Barrel Canyon, with its main tributaries being Wasp Canyon, 

McCleary Canyon, and Scholefield Canyon. Barrel Canyon drains into Davidson Canyon on the east side 

of SR 83. Several seeps and springs are present within the Project site, including Scholefield Spring 

(which supports a potentially jurisdictional wetland) located in the northern portion and Rosemont Spring 

northwest of Rosemont Camp.

Elevations on the Property range from approximately 6,824 ft above mean sea level (amsl) at Weigles 

Butte on the west edge of the Project site to approximately 4,500 ft at the lower end of Barrel Canyon. 

The ridge on the west edge of the Property constitutes the main crest of the Santa Rita Mountains. 

Topographically, the site consists of mountain front and rolling foothills bisected by ephemeral washes 

 

3 As a general rule, the basic purpose of the project must be known to determine if the project is water dependent. Since the proposed Project 

does not entail discharges to special aquatic sites (see Preliminary Jurisdictional Waters Determination SPL-2008-00816-MB), the 

presumption that a less damaging, practicable offsite alternative exists does not apply [Army Corps of Engineers Standard Operating 

Procedures for the Regulatory Program, Section 12, 2009; 40 CFR part 230.10(a)(3)].

4 See Army Corps of Engineers Standard Operating Procedures (SOP) for the Regulatory Program (2009). The Corps SOP state “the overall 

project purpose is used to evaluate less environmentally damaging practicable alternatives” and “must be specific enough to define the 

applicant’s needs, but not so restrictive as to constrain the range of alternatives that must be considered under the 404(b)(1) guidelines.”
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(with occasional spring flow within short reaches of McCleary Canyon and other drainages) draining 

generally east toward Davidson Canyon, which discharges to Cienega Creek near I-10. Drainages on the 

west side of the Santa Rita Mountains flow generally west and northwest toward the Santa Cruz River. 

Underlying geologic units include metamorphic rocks and limestone on the higher ridges and 

conglomerate and alluvium in the lower hills.

Vegetation cover types within the Project site are consistent with the mapping by Brown and Lowe 

(1980). The two biomes present within the Project site are Madrean evergreen woodland and semidesert 

grassland, as described by Brown (1982). Madrean evergreen woodland covers the higher elevation parts 

of the Project site, generally in the western and southern areas. This community is characterized by open 

woodlands or savanna, with trees interspersed with grasses and forbs. Semidesert grassland covers the 

lower elevation parts of the Project site, primarily in the northern and eastern areas. This community is 

characterized by open grasslands with widely scattered shrubs and cactus. At middle elevations within the 

Project site, the semidesert grassland grades into the Madrean evergreen woodland in a wide transition 

zone. Riparian areas are present along some of the major washes within the Project site and in small 

patches at some of the more reliable springs (WestLand, 2010). Ephemeral flow in Barrel, McCleary, and 

Wasp Canyons (with occasional spring flow in short reaches of McCleary Canyon and other drainages) 

supports areas with tree and shrub species not present on the drier upland ridges. Several springs in the 

Project vicinity, including Rosemont Spring, Scholefield Spring, and Figtree Spring, support a variety of 

trees, shrubs, and herbaceous plants not found elsewhere within the Project site. 

An analysis by WestLand (2010) delineated five different classes of riparian habitat within the Rosemont 

Project area based on Normalized Difference Vegetation Index (NDVI) Display Values developed from 

satellite imagery, with higher NDVI Display Values indicating the presence of increased vegetation. 

Based on this classification system, the highest quality (read “highest vegetation density”) riparian habitat 

was found in a relatively short, moister reach in upper McCleary Canyon and in association with 

Scholefield and Fig Tree Springs. 

1.5. JURISDICTIONAL WATERS OF THE UNITED STATES

Per the provisions of Corps RGL 08-02 (dated June 26, 2008), the Applicant submitted a preliminary 

jurisdictional waters determination (PJD) to the Corps on May 29, 2009. Additional information was 

submitted per Corps request on July 31, 2009. Supplemental information related to Sycamore Canyon and 

the offsite waterline alignment was provided to the Corps on January 5, 2010, and March 1, 2010, 

respectively. Approval of the PJD by the Corps was provided in November 2010. Although an approved 

PJD does not provide a legally binding determination of jurisdiction over particular water bodies or 

wetlands, it is suitable for the purpose of permitting under CWA Section 404 (Corps RGL 08-02). 

The total estimated area of potentially jurisdictional waters within the analyzed portion of the Project site 

is approximately 101.6 acres (Figure 2). Additional potential waters of the U.S. occur along the proposed 

utility alignments west of the Project site. The majority of the onsite potential waters of the U.S. are 

ephemeral, flowing only in response to storm events. Springs located within McCleary Canyon and 
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Rosemont Spring will occasionally discharge for an extended period after storm events, resulting in minor 

surface water flow before the spring water infiltrates back into the ground. 

Two potential special aquatic sites, as defined by the 404(b)(1) guidelines (40 CFR §230.3(q-1)), were 

identified on the Property. The potential special aquatic sites consist of wetlands associated with 

Scholefield and Fig Tree Springs. These wetlands will not be directly impacted by the proposed Project, 

but may be impacted by one or more alternatives.
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2. FORMULATION OF ALTERNATIVES

This section defines the range of the alternatives in this analysis and describes the criteria used to 

determine the practicability of the alternatives for the Rosemont Project. Alternatives are influenced by 

the distribution, function, and value of the jurisdictional waters found at the site, the nature of the project 

purpose, and other environmental factors. Specific criteria are described that are used to identify the least 

environmentally damaging practicable alternative that fulfills the Project’s overall purpose.

2.1. CRITERIA FOR DETAILED ANALYSIS OF ALTERNATIVES

The following criteria have been established to determine whether an alternative is available and capable 

of being done after taking into consideration cost, existing technology, and logistics in light of the overall 

Project purpose, and whether it has the potential to reduce impacts to the aquatic ecosystem without 

causing other significant adverse environmental consequences.

2.1.1. Practicability

The 404(b)(1) guidelines provide that “an alternative is practicable if it is available and capable of being 

done after taking into consideration cost, existing technology, and logistics in light of overall project 

purposes” (40 CFR 230.10). In order to determine whether an alternative to the Rosemont Project could 

be considered practicable, a brief discussion of the geology of copper deposits and the stages of a mine 

project is in order.

Although copper is a relatively common constituent of the earth’s crust, concentrations of copper 

minerals that can be economically recovered are rare. This contrasts markedly with other types of more 

common mineral resources, such as coal, sand and gravel, or limestone deposits, which are considerably 

more abundant and widespread. To justify the substantial investment necessary to develop a copper 

deposit, the deposit must be of sufficient quality (grade), size (tons), and geometric configuration 

(e.g., depth, etc.) to allow for a sufficient financial margin after meeting operating costs to amortize the 

initial investment and provide a reasonable return on investment. Financing of mine development is 

heavily dependent on accurate reporting of the known nature of the mineral deposits, and, as a 

consequence, the terminology used must follow generally accepted industry standards and securities 

regulatory agency requirements. (The letters from Augusta Resource’s Vice President of Exploration, 

provided in Appendix A, explain this in detail.)

Determining the quality, size, and geometric configuration of a deposit is an expensive and 

time-consuming process. A mining project begins with an exploration campaign of a geologically 

favorable region. As the results of more and more exploration and evaluation become available for the 

region, certain areas, called prospects, are targeted as being more favorable, i.e., as having the quality, 

size, and configuration conducive to profitable extraction. Increasingly detailed work will show what the 

relative potential of each targeted area is and typically identify the highest potential target area. Continued 

exploration is then focused on the area with the highest potential for profitable mineral extraction because 

the significant time and expense involved in the exploration process for any one operator make 

simultaneous evaluation of all potential mineralized areas impracticable.
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The advancement of a prospect during mineral exploration may then result in the identification of an 

initial Mineral Resource estimate. Mineral Resources are officially defined as: “A concentration or 

occurrence of diamonds, natural solid inorganic material, or natural solid fossilized organic material 

including base and precious metals, coal, and industrial minerals in or on the Earth’s crust in such form 

and quantity and of such a grade or quality that it has reasonable prospects for economic extraction. The 

location, quantity, grade, geological characteristics and continuity of a Mineral Resource are known, 

estimated or interpreted from specific geological evidence and knowledge.”5 Mineral Resources are 

subdivided in order of increasing geological confidence into inferred, indicated, and measured categories, 

the definitions of which are provided below.

Inferred Mineral Resource – “that part of a Mineral Resource for which quantity and grade or 

quality can be estimated on the basis of geological evidence and limited sampling and reasonably 

assumed, but not verified, geological and grade continuity. The estimate is based on limited 

information and sampling gathered through appropriate techniques from locations such as outcrops, 

trenches, pits, workings and drill holes.” Due to the uncertainty that may be attached to Inferred 

Mineral Resources, it cannot be assumed that all or any part of an Inferred Mineral Resource will be 

upgraded to an Indicated or Measured Mineral Resource (see below) as a result of continued 

exploration.

Indicated Mineral Resource – “that part of a Mineral Resource for which quantity, grade or 

quality, densities, shape and physical characteristics, can be estimated with a level of confidence 

sufficient to allow the appropriate application of technical and economic parameters to support 

mine planning and evaluation of the economic viability of the deposit. The estimate is based on 

detailed and reliable exploration and testing information gathered through appropriate techniques 

from locations such as outcrops, trenches, pits, workings and drill holes that are spaced closely 

enough for geological and grade continuity to be reasonably assumed.” An Indicated Mineral 

Resource estimate is of sufficient quality to support a preliminary feasibility study which can serve 

as the basis for major development decisions.

Measured Mineral Resource – “that part of a Mineral Resource for which quantity, grade or 

quality, densities, shape, and physical characteristics are so well established that they can be 

estimated with confidence sufficient to allow the appropriate application of technical and economic 

parameters, to support production planning and evaluation of the economic viability of the deposit

(i.e., feasibility [see below] can be completed). The estimate is based on detailed and reliable 

exploration, sampling and testing information gathered through appropriate techniques from 

locations such as outcrops, trenches, pits, workings and drill holes that are spaced closely enough to 

confirm both geological and grade continuity.

 

5 The definitions provided in this section were all obtained from CIM DEFINITION STANDARDS – For Mineral Resources and Mineral 

Reserves, prepared by the Canadian Institute of Mining, Metallurgy and Petroleum (CIM) Standing Committee on Reserve Definitions and 

adopted by the CIM Council on December 11, 2005. Augusta Resource Corporation, parent company of Rosemont Copper Company, is 

traded on the Toronto Stock Exchange and is bound by these standards.
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The next major stage of a mineral exploration project is a feasibility analysis, which incorporates mine, 

metallurgical, and environmental engineering to determine what part of the Mineral Resource is 

economically extractable, and that part is referred to as the Mineral Reserve. Mineral Reserves have been 

officially defined as: “The economically mineable part of a Measured or Indicated Mineral Resource 

demonstrated by at least a Preliminary Feasibility Study. This Study must include adequate information 

on mining, processing, metallurgical, economic and other relevant factors that demonstrate, at the time of 

reporting, that economic extraction can be justified. A Mineral Reserve includes diluting materials and 

allowances for losses that may occur when the material is mined.” Material that cannot be considered as 

part of the economic Mineral Reserve must remain as Mineral Resource for reporting purposes. Mineral 

Reserves are subdivided in order of increasing economic confidence into probable and proven categories, 

as defined below.

Probable Mineral Reserve – “the economically mineable part of an Indicated and, in some 

circumstances, a Measured Mineral Resource demonstrated by at least a Preliminary Feasibility 

Study. This Study must include adequate information on mining, processing, metallurgical, 

economic, and other relevant factors that demonstrate, at the time of reporting, that economic 

extraction can be justified.” 

Proven Mineral Reserve – “the economically mineable part of a Measured Mineral Resource 

demonstrated by at least a Preliminary Feasibility Study. This Study must include adequate 

information on mining, processing, metallurgical, economic, and other relevant factors that 

demonstrate, at the time of reporting, that economic extraction is justified.” Application of the 

Proven Mineral Reserve category implies that the person performing the evaluation (the “Qualified 

Person”) has the highest degree of confidence in the estimate with the consequent expectation in the 

minds of the readers of the report.

Once the economic feasibility study has demonstrated a given mineral project to be economically viable

(that is, a Mineral Reserve has been identified), the next steps include detailed engineering, environmental 

impact analysis, and procurement of project financing. The geological Mineral Resource and economic 

Mineral Reserve are largely fixed at this point, but may be updated if additional information becomes 

available. In such circumstances, the additional information is usually incorporated into an economic 

feasibility study update.

It is conceivable, however, that a feasibility study may determine that no part of a Mineral Resource is 

economically extractable (given existing technologies), and in that case no Mineral Reserve would be 

identified. Development of such an ore deposit would therefore not be “practicable” under the 404(b)(1) 

guidelines. 

If an offsite alternative consists solely of Mineral Resources, by definition there is insufficient 

information to determine if extraction is feasible (the industry’s term) or practicable (the 404(b)(1) 

guidelines’ term). It is not until the feasibility study is complete, and the Mineral Reserve identified, that 

it can be determined whether or not a given project is “capable of being done” in light of cost, technology, 

and logistics. As such, offsite projects or properties for which only a Mineral Resource has been identified 
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cannot be considered “practicable” alternatives until a feasibility study has been completed that 

determines them so. It is not simply that these offsite alternatives are not “practicable”; their practicability 

is unknown and unknowable absent a significant (i.e., expensive and time-intensive) exploration 

campaign and subsequent feasibility analysis.

With this as background, we move to discussion of the specific elements of practicability identified in the 

guidelines: availability, cost, and logistics and technology.

2.1.1.1. Availability

In order for development on a particular site to be practicable, the subject property must be under the 

Applicant’s control or ownership, or available for acquisition. The Corps has directed the Applicant to 

evaluate availability as of the date of acquisition of the Rosemont Project, in 2005. 

2.1.1.2. Cost

As a publicly held corporation, the Applicant has a fiduciary duty to stockholders to provide a reasonable 

rate of return on investment, commensurate with the risks associated with achieving those returns. Project 

costs affect the practicability of alternatives, especially with respect to costs that are substantially greater

than the costs normally associated with the particular type of project. The relevance to practicability 

determination rests not in the Applicant’s individual financial standing, but primarily in the characteristics 

of the project and what constitutes a reasonable expense for these types of projects for the industry as a 

whole. The alternatives were reviewed with respect to the effect of the alternative on Project cost when 

compared to other alternatives or the cost of similar projects. 

Offsite alternatives present a particular challenge from the standpoint of cost. In order to determine if a 

particular alternative is feasible, it is necessary to estimate the costs of developing the resource and 

measure those costs against industry standards, which typically means cost per pound of copper produced. 

The challenge with many offsite mineral resources is that the extent and configuration of the resource has 

not been adequately defined and so there is inadequate information on the amount of copper generated or 

the cost to construct the project. 

2.1.1.3. Logistics

Development of an MPO includes several logistical considerations, including mine stability—waste rock 

and tailings piles must be designed so as to be stable and to meet basic safety standards. Similarly, 

development of an open pit is done in an incremental way that ensures that the walls of the pit remain 

stable so as to allow continued mining.

2.1.1.4. Existing Technology

All of the alternatives considered in this analysis were developed based on existing copper mining 

technology. That is, none of the alternatives considered here are dependent on development of new 

technology to be practicable. For example, dry stack tailings disposal was contemplated for all 

alternatives; this technology is more expensive but uses much less water than conventional tailings 
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disposal with slurry pipeline and impoundments. Technological considerations, therefore, were not 

determinative in the evaluation of any of the alternatives.

2.1.2. Impacts to Aquatic Ecosystem

Specific criteria used to determine whether the development of an alternative mineral resource would 

result in less impact to the aquatic ecosystem include estimated impacts to waters of the U.S., including 

wetlands. Because offsite alternatives are effectively eliminated by issues related to Project purpose, 

availability, or cost (see below), analysis of impacts to aquatic ecosystems is not discussed here. In 

general, the Rosemont site itself is located at the top of the watershed and is characterized by ephemeral 

watercourses, with a few isolated springs and occasional spring flow within short reaches in McCleary 

Canyon and others. There are no wetlands within the footprint of the proposed Project. As a general 

matter then, the presumption of available alternative sites found in the 404(b)(1) guidelines is not 

applicable here.

2.1.3. Other Environmental Impacts

Because offsite alternatives are effectively eliminated by issues related to Project purpose, availability, or 

cost (see below), a detailed analysis of other environmental impacts associated with alternative mineral 

resources is not discussed here.

With regard to onsite alternatives, in addition to potential waters of the U.S., the Rosemont Project site 

supports sensitive species and habitats that may be affected by one or more of the evaluated alternatives. 

Sensitive habitats include the five classes of riparian habitats referenced above and described in 

WestLand (2010). The Rosemont Project site also supports habitat features for sensitive species, 

including roost sites for the federally listed lesser long-nosed bat and stock tanks in which the federally 

listed Chiricahua leopard frog has been observed. A number of area springs, including both Scholefield 

and Fig Tree Springs, support the giant sedge, which is listed as “sensitive” by the U.S. Forest Service. 

A complete analysis of a broad suite of environmental resources is provided in the CNF EIS.

2.2. OFFSITE ALTERNATIVES

The 404(b)(1) guidelines provide that “an alternative is practicable if it is available and capable of being 

done after taking into consideration cost, existing technology, and logistics in light of overall project 

purposes. If it is otherwise a practicable alternative, an area not presently owned by the applicant, which 

could reasonably be obtained, utilized, expanded or managed in order to fulfill the basic purpose of the 

proposed activity may be considered” (40 C.F.R. §230.10). 

The following sections provide a discussion regarding the state of the copper mining industry in Arizona 

in 2005, as well as an analysis of the copper mining projects that were either underway or in the planning 

stage at that time.
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2.2.1. Status of Copper Industry in 2005

The copper industry is very important in Arizona, with an estimated direct and indirect contribution to the 

Arizona economy of approximately $12.1 billion in 2010, the most current year for which this 

information is available (Niemuth, 2011). At the time that Augusta bought the Rosemont Property, in 

2005, Arizona produced over 60 percent of the nation’s copper; however, nearly 100 percent of that 

copper came from just 10 large mines owned by four companies (Table 1; Niemuth, 2006). Figure 3

shows these facilities as they occur within the geographic range of the alternatives.

Table 1. Arizona Copper Mine Production, 2005 (Niemuth, 2006)

Mine Ownership % of Arizona 

Production

Morenci Phelps Dodge and Sumitomo (now FreeportMcMoRan and Sumitomo) 51.9 

Ray ASARCO 14.8 

Bagdad Phelps Dodge (now Freeport-McMoRan) 10.5

Sierrita Phelps Dodge (now Freeport-McMoRan) 10.3 

Mission ASARCO 6.1 

Silver Bell ASARCO and Mitsui 3.0

Pinto Valley BHP 1.2 

Miami Phelps Dodge (now Freeport-McMoRan) 1.2 

Mineral Park Mercator 0.6

Tohono Phelps Dodge (now Freeport-McMoRan) 0.3 

In 2005, the price of copper had increased 29.5 percent over the previous year due to increased domestic 

and international demand, and was continuing to rise (Niemuth, 2006). In that environment, the 

companies listed in Table 1 were evaluating opportunities for expanding and rehabilitating their 

operations or otherwise increasing production to take advantage of this significant increase in copper 

price. As such, none of the sites listed in Table 1 were available for sale at the time that Augusta 

purchased the Rosemont Property. None of these sites therefore offered the possibility of being an 

available, practicable alternative within the scope of the Rosemont Project.

2.2.2. Offsite Alternatives

A number of other Arizona copper mining projects and potential projects were in various stages of 

exploration or development in 2005 (Table 2; Niemuth, 2006). The locations of these projects are shown 

in Figure 4, and the projects themselves are described further below. Much of the information regarding 

the status of these projects was derived from their respective filings with the U.S. Securities and 

Exchange Commission and the Canadian Securities Administrators (CSA), all of which are publicly 

available online. In addition to the formal filings, these companies issued news releases marking 

significant milestones, which were also reviewed as part of this alternatives analysis.
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Table 2. Arizona Copper Projects, 2005 (Niemuth, 2006)

Project Ownership Size and 

Confidence Level Status Summary

Safford

(Dos Pobres/San 

Juan)

Phelps Dodge 

(now FreeportMcMoRan)

538 million tons proven and 

probable mineral reserves In production as of December 2007

Lone Star

Phelps Dodge 

(now FreeportMcMoRan)

1,600 million tons inferred

mineral resources

Continuing exploration by FreeportMcMoRan

Johnson Camp Nord 35 million tons proven and 

probable mineral reserves Active leaching, no production

Carlota

Quadra 

(now KGHM 

International 

Ltd.)

105.7 million tons proven and 

probable mineral reserves

13 million tons inferred 

mineral resources

In production as of December 2008. 

Announced mine-for-closure in fall 

2011 due to inefficiencies in leaching 

process.

Dragoon BHP-Billiton Unknown

BHP terminated agreement after 

exploration effort. Sporadic 

exploration in area by others. 

Copper Creek Redhawk Copper 

Not reported in 2005. 

Currently estimated 27.4 

million tons measured and 

indicated mineral resources; 

158.4 million tons inferred

mineral resources

Continuing exploration by Redhawk 

Copper 

Resolution Rio Tinto and 

BHP-Billiton

Not reported in 2005. 

Currently estimated 1.64 

billion tons inferred mineral 

resources

Continuing exploration by Resolution 

Copper Mining

Monitor Teck Cominco/ 

General Minerals Unknown

GMC spun off HDG in 2007. Teck 

dissolved relationship after completion 

of exploration. In 2007 CSA filing, 

HDG identified potential exploration 

targets not hit by Teck. No mention of 

Monitor in 2008 filing.

Markham Wash General Minerals Unknown

GMC spun off HDG in 2007. Teck 

terminated relationship in May 2008 

after completion of exploration. In 

June 2008, HDG dropped its interest in 

this property.

Oracle Ridge Oracle Ridge 

Mining, LLC

8.14 million tons proven and 

probable mineral reserves

16.57 million tons inferred 

mineral resources

Inactive. Exploration drilling initiated 

to investigate potential for mine restart. 

Bear Canyon Arizona Copper 

Corporation Unknown Proposed exploration by Arizona 

Copper Corp.
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2.2.2.1. Safford (formerly Dos Pobres/San Juan)

The Safford Mine, a combination of the previous Dos Pobres and San Juan projects, is an open pit copper 

mine located approximately 6 miles north of Safford, Arizona. The facility is owned by 

Freeport-McMoRan Copper & Gold and is a mine-for-leach project, producing copper cathodes. In 2005, 

the Safford Mine (then owned by Phelps Dodge Corporation, which has since been acquired by 

Freeport-McMoRan) was still in the process of acquiring state operating permits, including the state air 

permit. Phelps Dodge had expended considerable effort in permitting the Safford Mine, having initiated 

permitting in the early 1990s and finally achieving a Record of Decision and completed land exchange 

with the BLM in September 2005.

Availability: As described above, in 2005 Phelps Dodge Corporation had spent over 10 years and 

millions of dollars to complete permitting and a land exchange for the Safford Project, 

the ROD for which was only signed in September 2005. In addition, copper prices were 

rising well above historic norms in 2005, and large mining companies like Phelps Dodge 

were looking for opportunities to expand existing operations and projects, not sell them. 

As such, the Safford Project would not be considered available for purchase by Augusta 

in 2005. 

Cost: Given the efforts of the current owner to develop the mine, this project is assumed to be 

practicable from a cost standpoint.

Logistics and 

Technology:

Given the efforts of the current owner to develop the mine, this project is assumed to be 

practicable from a logistics and technology standpoint.

Summary of 

Practicability:

The Safford Project was not available for purchase by Augusta in 2005 so it could not be 

considered a practicable alternative to the Rosemont Project.

2.2.2.2. Lone Star

The Lone Star deposit is a preliminarily large deposit (1.6 billion tons inferred mineral resources) located 

in the same mining district as the Safford Mine and is likewise owned by Freeport-McMoRan. The public 

lands that may be used for the development of this potential ore body were acquired as part of the same 

BLM land exchange that was completed for the Safford Mine. In 2005, feasibility level analysis had not 

yet been completed on the Lone Star deposit, and exploratory drilling was ongoing.

The Lone Star deposit was considered as an alternative to the Dos Pobres/San Juan (now Safford) project 

in that project’s Section 404 permitting effort. Because exploration and feasibility level analysis had not 

yet been completed at the Lone Star deposit at the time of the Dos Pobres/San Juan alternatives analysis 

(1997), development of the Lone Star deposit was determined to be logistically impracticable.
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Availability: In conjunction with the Safford Mine, Phelps Dodge Corporation had spent over 10 years 

and millions of dollars to complete a land exchange for the Lone Star deposit, the ROD 

for which was only signed in September 2005. In addition, copper prices were rising well 

above historic norms in 2005, and large mining companies like Phelps Dodge were 

looking for opportunities to expand existing operations and projects, not sell them. As 

such, the Lone Star deposit was not available for purchase by Augusta in 2005. 

Cost: Unknown. However, it is reasonable to conclude that the proximity of the Lone Star 

deposit to the existing Safford Mine and its associated infrastructure will allow 

Freeport-McMoRan to mine this deposit (once feasibility is completed) far more 

economically than would a separate entity such as Augusta.

Logistics and 

Technology:

Unknown, although, again, it is anticipated that development of this mineral resource 

(once feasibility is completed) would be considerably more logistically feasible for 

Freeport-McMoRan than for a separate entity such as the Applicant. 

Summary of 

Practicability:

The Lone Star project was not available for purchase by Augusta in 2005 and so it could 

not be considered a practicable alternative to the Rosemont Project. 

2.2.2.3. Johnson Camp

The Johnson Camp Mine is an existing open pit copper mine located approximately 65 miles east of 

Tucson, in Cochise County, Arizona, with an estimated 35 million tons of proven and probable reserves 

(or approximately five percent the size of the Rosemont ore body). The facility represents the principal 

holding of the Nord Resources Corporation (Nord) and was placed into care and maintenance in 2003 due 

to weak market conditions. Despite financial and legal troubles, Nord commissioned several feasibility 

studies between 2000 and 2005 for resuming operations at the Johnson Camp Mine. The results of these 

studies suggested that the initial capital costs for restarting operations were expected to exceed 30 million 

dollars, necessary for the rehabilitation of solution ponds, the construction of new leach pads, the 

purchase and installation of crushing and conveying equipment, and the installation of infrastructure 

required by these modifications. Nord was seeking financing during this period in order to initiate these 

efforts. As of 2005, Nord was the owner of the entirety of the Johnson Camp property and the owner or 

holder of all associated claims. Nord suspended mining new ore at Johnson Camp in July 2010 in an 

effort to restructure its debt, but continues to leach existing ore leach pads.

Availability: As stated above, the mine was the principal asset of the company and there was no 

indication that the mine was for sale in 2005.

Cost: Unknown. Preparation of feasibility studies suggests it is practicable though current 

financial difficulties suggest that cost may not be practicable. 

Logistics and 

Technology:

Unknown.

Summary of 

Practicability:

Given that the Johnson Camp Mine was not available for purchase by Augusta in 2005, it 

could not be considered a practicable alternative to the Rosemont Project.
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2.2.2.4. Carlota

The Carlota Copper project is an open pit copper mine located approximately 6 miles west of Miami, on 

the border of Gila and Pinal Counties, Arizona. Construction on the project had not yet commenced in 

2005. Quadra Mining Ltd. (Quadra) purchased the property from Cambior Inc. (Cambior) in December 

2005 for approximately 39.7 million dollars. Cambior had previously completed a feasibility study for the 

operation in October 2005 and obtained all the permits necessary for the mine’s operation when it opted 

to sell the operation to Quadra. At the time of the sale, two of the previously approved permits for the 

project (the state air permit and the Environmental Protection Agency National Pollutant Discharge 

Elimination System permit) were the subject of litigation that had the potential to affect the construction 

or operation of the Carlota project.

A significant portion of the Carlota ore body lies beneath Pinto Creek, a relatively large intermittent 

drainage on the Tonto National Forest. Development of the project entailed rerouting a portion of Pinto 

Creek around the open pit on an established pit bench. In January 2010 a significant rainfall event resulted 

in the Cactus Pit at the Carlota Mine being inundated with water, preventing any mining in that pit until 

the water could be removed in March 2010.

In the fall of 2011, Quadra announced that it would be ceasing mining operations at the Carlota Mine due 

to inefficiencies in the leaching process resulting from the presence of excess fines in the leach material. 

Carlota is now operating under a mine-for-closure plan and will be initiating reclamation in the relatively 

near future. In February 2012, Quadra entered into an agreement with KGHM, a Polish company, in 

which a subsidiary of KGHM would acquire all outstanding Quadra securities and Quadra would operate 

under the name KGHM International Ltd. 

Availability: The Carlota Project was purchased by Quadra in 2005, though it was encumbered at that 

time by litigation related to two environmental permits. 

Cost: Given the fact that the Carlota project is now in closure, it cannot be a considered a 

practicable alternative to the Rosemont Project.

Logistics and 

Technology:

As with costs, given the fact that the Carlota project is now in closure, it cannot be a 

considered a practicable alternative to the Rosemont Project.

Summary of 

Practicability:

In 2005, the Carlota Copper project was encumbered by litigation related to two 

environmental permits that had the potential to adversely affect the implementation of the

project. In addition, the challenging project design (i.e. developing a mine pit below a 

significant intermittent mountain drainage) has proved difficult to manage in terms of 

stream hydrology. Due to inefficiencies in the leach system, Quadra (now KGHM 

International Ltd.) has announced that it is winding down the mine operation. Given the 

above, the Carlota Project does not provide a practicable alternative to the Rosemont 

Project.
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2.2.2.5. Dragoon

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The Dragoon property is a copper exploration prospect near Benson, in Cochise County, Arizona. 

General Minerals Corporation (GMC) announced the acquisition of the rights to the Dragoon copper 

prospect in November 2002. In that announcement, GMC characterized the property as an exploration 

“prospect” and a “drill target,” and indicated that a certain highly prospective portion of the property had 

“never been drilled.” In a subsequent announcement (dated April 10, 2003) relating to the completion of 

geophysical studies, GMC stated that earlier drilling on the Dragoon property “indicated the presence of 

weak sulphide mineralization” and that its goal was a “further refinement of the target.” About one year 

later, GMC issued a press release (dated March 5, 2004) relating to an update of its world-wide 

exploration activities in which it described itself as an “early stage exploration[ist]” with the ultimate goal 

of “identify[ing] properties with discovery potential.” Interestingly, although GMC provided significant 

information relating to certain of its properties, it only mentioned Dragoon in passing, indicating that the 

property is “attracting interest from potential joint venture partners.” Shortly thereafter (May 2004), GMC 

announced the completion of four technical reports, none of which related to Dragoon. Notwithstanding, 

GMC did strongly indicate at that time its strategy: “wealth creation through mineral exploration 

discovery and success.”

In April 2005, GMC announced that it had entered into an exploration earn-in with BHP Billiton (BHP) 

whereby BHP agreed to make certain exploration expenditures to earn up to a 70 percent joint venture 

interest in the property. In this announcement, GMC continued to characterize the Dragoon property as an 

exploration property with portions that had never been drilled. Subsequent to entering into the earn-in 

joint venture, BHP initiated a drilling program at Dragoon, consisting of three to five holes of between 

1,200 and 2,500 m. Shortly thereafter, BHP withdrew from the joint venture, indicating that the Dragoon 

property drilling program identified only “weakly anomalous copper and molybdenum values,” which 

“provided insufficient incentive for [it] to continue with the project.” (See GMC press release dated April 

21, 2006.)

Consistently over time, GMC characterized the Dragoon property as an exploration property. None of the 

press releases suggested that the weakly mineralized area at Dragoon was a proven or mineable reserve, 

or that the property was ready for development into a mine. Indeed, over a three-and-one-half-year period, 

GMC never once reported a quantified resource for Dragoon (such as the tons and grade of ore). As such, 

it can only be concluded that the information required to make a determination of whether the Dragoon 

property was a viable and/or practicable alternative to the Rosemont Project was simply not known.

Availability: Unknown

Cost: Unknown

Logistics and Unknown

Technology:
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Summary of 

Practicability:

As described above, the Dragoon prospect was still in the early phases of exploration in 

2005 and its owner, GMC, had not identified any potential mineral reserves or even 

mineral resources. As such, the practicability of this project in terms of cost, logistics, 

and technology could not be determined without extensive additional exploration and 

feasibility analysis. Subsequent exploration efforts have consistently failed to identify a 

viable Mineral Reserve or even Mineral Resource. The Dragoon Copper prospect

therefore could not be considered a viable alternative to the Rosemont Project.

2.2.2.6. Copper Creek

The Copper Creek property is the proposed location of an underground copper mine approximately 

75 miles northeast of Tucson, in Pinal County, Arizona. Redhawk Resources, Inc. (Redhawk) purchased 

the 7-mi2 property in August 2005 for a total acquisition cost of approximately 1.8 million dollars. This 

purchase represented the culmination of two years of negotiations between Redhawk and the previous 

owner of the project. Although located at the intersection of known porphyry copper deposits, the Copper 

Creek property required significant further drilling to complete scoping and feasibility studies. As of 

March 2006, Redhawk was still in the process of exploring the Copper Creek mineral body and had not 

identified a Mineral Resource for the project.

Availability: Given Redhawk’s two-year of negotiations with the property owner, it is not reasonable 

to conclude that the Copper Creek property was available for purchase by Augusta in 

2005.

Cost: Unknown

Logistics and 

Technology:

Unknown

Summary of 

Practicability:

Given that the Copper Creek property was not available for purchase by Augusta in 2005, 

it could not be considered a practicable alternative to the Rosemont Project. In addition, 

Redhawk was still in the exploration phase of the project in 2005, having not identified a 

Mineral Resource, so that the practicability (in terms of cost, logistics, and technology) of 

developing the Copper Creek deposit could not be determined. Copper Creek is therefore 

not a viable alternative to the Rosemont Project.

2.2.2.7. Resolution

The Resolution property is the current location of an ongoing program of exploration and pre-feasibility 

studies for a proposed deep underground copper mine near Superior, in Pinal County, Arizona. In 2002, 

Rio Tinto Ltd (Rio Tinto) earned a 55 percent share of the project after spending 25 million dollars on an 

exploratory program, leaving BHP with a 45 percent share. In 2005, the two companies reached an 

agreement to accelerate exploration in the following year. At that time, the joint venture was awaiting 

(and continues to wait for) the passage of a land exchange introduced in the U.S. House and Senate.
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Availability: At the time of Augusta’s purchase of the Rosemont Property, both BHP and Rio Tinto 

were heavily invested in the development of the property and the outcome of the 

proposed federal legislation. It is unreasonable to conclude therefore that the Resolution 

property was available for sale at this time.

Cost: Unknown. Actions of the ownership group in pursuing land exchange and development 

suggest that the project is practical from a cost perspective, but the ongoing exploratory 

drilling program suggests that information regarding known resources is currently 

insufficient to support a feasibility study. In addition, the capital investment requirements 

represented a significant obstacle to Augusta’s participation in the Resolution project 

(see “Logistics and Technology” discussion below).

Logistics and 

Technology:

The Resolution copper deposit is located nearly 1.5 miles below the ground surface and 

will require an enormous investment in infrastructure and technology to extract, making 

the Resolution project one of the most complex and challenging mining projects in North 

America. Only a very few mining companies in the world would have the capability to 

develop the project, and Resolution Copper Mining is comprised of two of the largest and 

most well capitalized of these firms (Rio Tinto and BHP). According to the Financial 

Times Global 500 Rank 2005, BHP was the largest mining company in the world in 

2005, with a market capitalization of $81.1 billion (as of March 31, 2005) and total 

annual revenues of $22.9 billion (year-end June 30, 2004). The second largest mining 

company was Rio Tinto, with a market capitalization of $45.2 billion (as of March 31, 

2005) and total annual revenues of $11.3 billion (year-end December 31, 2004). 

By comparison, during the month of March 2005, Augusta Resource Corporation’s 

market capitalization ranged between $37 and $61 million. During the same period, 

Augusta Resource Corporation’s revenues were essentially nil, as it did not maintain any 

revenue-generating mineral operations.

Given the fact that the two largest mining companies in the world joined together to 

advance the Resolution Copper deposit because of the significant capital required and the 

technological challenges associated with developing such a large and deep resource, it is 

readily apparent that Augusta Resource Corporation, with such limited financial 

capitalization, could not have participated in the Resolution Copper project. 

Summary of 

Practicability:

Given that the Resolution project was not available for purchase by Augusta in 2005, it 

could not be considered a practicable alternative to the Rosemont Project. In addition, the 

Applicant was not in a financial position to address the significant technological and 

logistical challenges associated with advancing the Resolution Copper project. Finally, 

the Resolution Project was still an exploration project in 2005, and had not yet identified 

a Mineral Resource, let alone a Mineral Reserve. As such, it would not have been 

possible to determine the cost, logistics, or technological feasibility of the project at that 

time.
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2.2.2.8. Monitor

The Monitor property is a copper exploration prospect near Hayden, in Pinal County, Arizona. GMC 

announced the acquisition of the rights to the Monitor copper prospect in January 2004. In that 

announcement, GMC indicated that it had “delineated an area of approximately 2 km2 with characteristics 

suggestive of an underlying porphyry copper target.” A few months later, GMC issued a press release 

relating to an update of its world-wide exploration activities, in which it described itself as an “early stage 

exploration[ist]” with the ultimate goal of “identify[ing] properties with discovery potential.” Interestingly, 

although GMC provided significant information relating to certain of its properties, it only mentioned 

Monitor in passing, indicating that the property is “attracting interest from potential joint venture 

partners.” Shortly thereafter, GMC announced the completion of four technical reports, one of which 

related to Monitor. In that announcement, GMC strongly stated its strategy: “wealth creation through 

mineral exploration discovery and success.” GMC concluded in the Monitor technical report that 

additional surface work consisting of detailed mapping and rock chip and soil sampling should be 

conducted, which would aid in the refinement and prioritization of various drill targets. (See Report on 

Monitor property, Pinal County, Arizona, Randall L. Moore, May 19, 2004.) In a June 2004 press release, 

GMC provided an update to the exploration activity at Monitor, indicating that it continued to be 

encouraged by the results and reiterating that the property exhibited characteristics suggestive of an 

underlying porphyry copper occurrence.

In February 2005, GMC announced that it had entered into an exploration earn-in with Teck Cominco 

(Teck) whereby Teck agreed to make certain exploration expenditures to earn up to a 65 percent joint 

venture interest in the property. Subsequent to entering into the earn-in joint venture, Teck initiated a 

drilling program at Monitor, consisting of six holes of varying depths. GMC announced the results of the 

Teck drilling program in June 2006. Not long thereafter, Teck withdrew from the joint venture, indicating 

that the results of the drilling program were “inconclusive.”

In 2007, GMC spun off its North American mining unit into High Desert Gold Corporation (HDG). In 

2007, HDG’s CSA filing indicated that Teck’s drill program “has shown the possibility for high-grade 

structurally controlled mineralization does not exist immediately below the old workings in the Monitor 

area,” but identified other potential exploration targets. There is no further mention of the Monitor 

property in HDG’s subsequent securities filings or currently on its website.

Consistently over time, GMC characterized the Monitor property as an exploration property. None of the 

press releases or technical reports suggested that the mineralized area at Monitor was a proven or 

mineable reserve, or that the property was ready for development into a mine. Indeed, over a nearly 

three-year period, GMC never once reported a quantified resource for Monitor (such as the tons and grade 

of ore). As such, it can only be concluded that the information required to make a determination of 

whether the Monitor property was a viable and/or practicable alternative to the Rosemont Project was 

simply not known.

Availability: There is no indication that the Monitor property was available for sale in 2005.

Cost: Unknown
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Logistics and Unknown

Technology:

Summary of As described above, the Monitor prospect was still in the exploration phase in 2005 when 

Practicability: Augusta purchased the Rosemont Property, and any potential Mineral Reserves, or even 

an estimated Mineral Resource, at Monitor were unknown. As such, the practicability of 

this project in terms of cost, logistics, and technology could not be determined without 

extensive additional exploration and feasibility analysis. As indicated above, the results 

of the exploration program subsequent to 2005 appeared to be mixed with regard to the 

potential for economically extractable ore, and it does not appear to have been pursued 

despite the continuing high price of copper. The Monitor prospect therefore could not be 

considered a viable alternative to the Rosemont Project.

2.2.2.9. Markham Wash

The Markham Wash property is a copper exploration prospect near Safford, Graham County, Arizona. In 

December 2004, GMC announced the acquisition of certain additional rights to the Markham Wash 

copper prospect. In that announcement, GMC indicated that it had “detected three high-priority 

anomalies” within an area of approximately 4 km2 that it “interpreted as representing sulphide 

mineralization related to a porphyry copper system,” which prior drilling did not appear to have tested. 

GMC also stated that its “observations and conclusions further support the target being...a[n 

undiscovered] buried porphyry copper system.”

In March 2006, GMC announced that it had entered into an exploration earn-in with Teck whereby Teck 

agreed to make certain exploration expenditures to earn up to a 65 percent joint venture interest in the 

property. About one year later, GMC announced that it intended to spin off its North American assets to a 

new gold-copper-focused publicly traded company (HDG). The preliminary prospectus for HDG 

characterized the Markham Wash property as an early stage exploration prospect, classifying it as 

non-material “[o]ther [p]roperties” owned by HDG in the United States. Subsequent to the spinoff and 

entering into the earn-in joint venture, Teck initiated a drilling program at Markham Wash, consisting of 

two holes at approximately 600 m depth each. Not long thereafter, Teck withdrew from the joint venture. 

In June 2008, HDG dropped its interest in the property.

Consistently over time, GMC and HDG characterized the Markham Wash property as an exploration

prospect. None of the press releases or the preliminary prospectus suggested that the mineralized area at 

Markham Wash was a proven or mineable reserve, or that the property was ready for development into a 

mine. Indeed, over a nearly three-and-one-half-year period, GMC and HDG never once reported a 

quantified resource for Markham Wash (such as the tons and grade of ore).

Availability: There is no indication that the Markham Wash property was available for sale in 2005.

Cost: Unknown
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Logistics and 

Technology:

Unknown

Summary of 

Practicability:

As described above, the Markham Wash prospect was in the early phase of exploration

in 2005, and any potential Mineral Reserves, or even an estimated Mineral Resource,

were unknown. As such, the practicability of developing this deposit in terms of cost, 

logistics, and technology could not be determined without extensive additional 

exploration and feasibility analysis. Subsequent exploration efforts have consistently 

failed to identify an estimated Mineral Resource or viable Mineral Reserve. The 

Markham Wash prospect therefore could not be considered a viable alternative to the 

Rosemont Project.

2.2.2.10. Oracle Ridge

The Oracle Ridge Copper Mine is a historic underground copper mine near Tucson, in Pima County, 

Arizona. The mine, which began operating in 1991, eventually closed in 1996 after operating difficulties 

and poor copper prices. Although some feasibility studies were completed in 1994, estimates of 

18 million tons of proven copper reserves at the mine still have not been validated.

Pima County records show that in May 2004 the owners of the Oracle Ridge Copper Mine—Oracle Ridge 

Mining Partners—conveyed a group of patented mining claims consisting of approximately 927 acres to 

Marble Mountain Ventures LLC (MMV), an entity presumed to be engaged in a non-mining-related real 

estate investment and development business.

On the same day that MMV acquired the group of patented mining claims, it recorded a Declaration of 

Covenants, Conditions & Restrictions (CCRs) significantly restricting the use of the patented mining 

claims by all subsequent owners. Among other things, the CCRs indicated that although the CCRs did not 

apply to MMV, MMV “shall not engage in any mass industrial mining.” Further, the CCRs indicated that 

none of the owners of the patented mining claim group subject to the CCRs may engage in mass 

industrial mining, which was defined as a mining operation of the scope and magnitude that was 

performed on the property over the last 50 years.

Immediately after recording the CCRs, MMV conveyed an approximately 334-acre portion of the mining 

claim group to LW Holdings, L.L.C. (LWH), and an approximately 167-acre portion of the mining claim 

group to Old Pueblo Associates, LLC (OPA). The mineral interest was reserved to MMV in both these 

conveyances. In August 2004, the 167-acre portion of the mining claim group was conveyed by OPA to 

Stratton Springs Canyon, LLC, which subsequently conveyed the same to Regal Manor Condominiums, 

L.L.C. (RMC), in February 2007.

In March 2005, MMV conveyed an approximately 160-acre portion of the mining claim group to 

Summerland Ventures LLC (Summerland). The mineral interest was reserved to MMV in this 

conveyance.
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Five years later, after the 2008 crash of the housing market, MMV, LWH, RMC, and Summerland, the 

collective owners of the 927-acre group of the Oracle Ridge Copper Mine patented mining claims, 

recorded a termination of the declaration of the CCRs on February 19, 2010, which extinguished, 

terminated, and forever released the restrictions associated with the CCRs. On the same day, MMV 

recorded a memorandum of agreement indicating that it had entered into an agreement to convey certain 

mineral rights associated with the patented mining claim group to Oracle Ridge Mining, LLC (ORM). 

Immediately thereafter, ORM recorded a memorandum of lease indicating that it had entered into an 

industrial lease agreement with MMV regarding certain surface rights associated with a portion of the 

patented mining claim group owned by MMV.

In a series of press releases issued between the months of August and September 2010, Gold Hawk 

Resources, Inc. (GHR), announced the acquisition of ORM, along with all the subsurface mining rights 

and the surface mining rights needed to explore, rebuild, and operate the Oracle Ridge Copper Mine. 

GHR has proposed an exploratory and mapping program to verify resource estimates should the sale be 

approved.

The chronology above indicates that a real estate investor purchased the Oracle Ridge Mining property, 

apparently for non-mining real estate investment or development purposes in May 2004, and by the 

declaration of the CCRs, immediately placed restrictions on future owners of the property from 

conducting any mining-related activities on the property. With the CCRs in place, the original investor 

presumably was able to sell off portions of the group of patented mining claims to other real estate 

investors. It was not until February 2010, after the housing market crash of 2008, that the original 

investor, along with all the subsequent owners/investors of the group of patented mining claims, 

terminated the CCRs, thereby providing the potential opportunity for mining to once again resume on the 

property. Given the fact that the property was severely restricted by the CCRs between May 2004 and 

February 2010, the Oracle Ridge Copper Mine property was not available for sale as a viable mining 

property during that period of time.

Availability: As indicated above, in 2005 the Oracle Ridge property was severely restricted by CCRs 

that prevented any mineral exploration or exploitation. Therefore, the Oracle Ridge 

deposit was not available for purchase as a mine property in 2005.

Cost: Unknown

Logistics and 

Technology: 

Unknown

Summary of 

Practicability:

As indicated above, the current purchaser of this project is proposing an exploratory 

evaluation to confirm the reserve estimates that were calculated back in the 1990s. As 

such, it is difficult to ascertain what the practicability of the project would be. However, 

as stated above, the project was not available for purchase as a mine project in 2005 and 

therefore does not present a viable alternative to the Rosemont Project. 
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2.2.2.11. Bear Canyon

Bear Canyon is a recently recognized porphyry target within the historic Bisbee copper-producing region, 

approximately 28.8 miles west of Bisbee’s Copper Queen Mine in Cochise County. Although 

mineralization within the Bear Canyon area has been known since the 1880s, with minor wartime 

production during World Wars I and II (primarily tungsten and antimony with limited gold and silver), 

the porphyry deposit was not identified until 2007. Arizona Copper Corporation, the owner of the Bear 

Canyon project, is in the process of acquiring permits to initiate an exploratory drilling program at the 

project.

Availability: At the time Augusta purchased the Rosemont Property in 2005, the Bear Canyon project 

was an unknown and unquantified resource and, in fact, had not yet been discovered as a 

potential copper resource. The Bear Canyon project was therefore not available to 

Augusta as an alternative to the Rosemont Project.

Cost: Unknown

Logistics and 

Technology:

Unknown

Summary of 

Practicability:

As described above, because the Bear Canyon project was not identified until 2007, it 

was not available to Rosemont in 2005 and it is therefore not a practicable alternative to 

the Rosemont Project.

2.2.3. Offsite Alternatives Summary

The Applicant has completed an evaluation of a significant number of offsite alternatives over an 

expansive geographic area (more than 33,000 mi2

). None of these alternatives represents a practicable 

alternative to the Rosemont Project due to the alternative 1) not being available or 2) being solely in an 

exploration phase and therefore without an identified Mineral Resource or Mineral Reserve in 2005. As 

such, there are no viable offsite alternatives to the Rosemont Project in southeastern Arizona (Pima, Pinal, 

Gila, Graham, Greenlee, Cochise, and Santa Cruz counties). 

2.3. ROSEMONT-OWNED ALTERNATIVE MINERAL DEPOSITS

Recent and historical exploration has identified three mineral deposits in the vicinity of the Rosemont ore 

body, within the contiguous Rosemont patented claims. These areas are referred to, from east to west, as 

Broad Top Butte, Copper World, and Peach-Elgin (Figure 5). Details related to the history of these 

deposits and their exploration are provided in Appendix A. 

During the earlier exploration period of the Rosemont area from the 1950s to the 1970s, extensive 

exploration of the Rosemont Property started on a regional basis and then progressed to a number of more 

specific deposits, including the Rosemont, Broad Top Butte, Copper World, and Peach-Elgin deposits. By 

about the middle 1970s, the cumulative results of the mineral evaluations from across the Rosemont 

Property had already identified the Rosemont deposit as the site with the best potential for being 

developed into an economic mine, and hence Rosemont became the focus of subsequent exploration 
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efforts. The primary attributes of the Rosemont deposit that made it attractive were its significant size 

(estimated now at over 600 million tons of ore), favorable metal grades, and low stripping ratio, all of 

which contribute to the economic viability of deposit development.

Because of the focus on the Rosemont deposit in the early exploration phases, considerably more 

exploration drilling had been completed at the Rosemont deposit than at the other three nearby deposits at 

the time Augusta purchased the Rosemont Property in 2005 (over 200,000 ft of core for Rosemont and 

just over 30,000 ft for the other three deposits combined). In 1977, then owner Anamax commissioned an 

estimate of the Rosemont deposit that identified a geological resource of about 445 million tons of ore. 

Building on this information, ASARCO, in 1997, commissioned a preliminary feasibility analysis that 

identified a “mineable resource” at the Rosemont deposit of nearly 341 million tons at an average grade 

of 0.64 percent copper. Although neither of these estimates met the current (2005) definition of “Mineral 

Resource” or “Mineral Reserve,” Augusta staff had personal knowledge of the modern (1997) Rosemont 

evaluations by ASARCO, and understood that the extensive core data and analysis that had already been 

completed on the Rosemont deposit would allow Augusta to readily develop a modern Mineral Resource

estimate for the deposit with minor additional drilling and engineering analysis. Proven and probable 

Mineral Reserves for the Rosemont deposit were estimated following the completion of a preliminary 

feasibility study in 2007, and the Reserve estimates were revised following additional feasibility analyses 

in 2009 and 2012. 

By comparison, the minimal evaluation completed to date of the Broad Top Butte, Copper World, and 

Peach-Elgin deposits has provided, at best, only a preliminary estimate of the inferred mineral resource at 

these areas. It must be noted that at the time that Augusta purchased the Rosemont Property in 2005, a 

number of Augusta personnel, who cumulatively had worked in the copper mining industry for decades, 

had personal knowledge of the potential of the Rosemont deposit and knew that, although a formal 

Mineral Resource, per the then just established Canadian standard, had not yet been estimated, the effort 

to develop a Mineral Resource estimate using the hundreds of thousands of feet of drill core would be 

minimal. The fact of this substantial additional drill core data, coupled with the modern (1997) “mineable 

resource” estimated by ASARCO, clearly and distinctly distinguishes the Rosemont deposit from the 

other three nearby mineral deposits (Broad Top Butte, Peach-Elgin and Copper World). 

Details related to these deposits are provided in the following sections, with additional detail provided in 

Appendix A. 

2.3.1. Broad Top Butte

At the Broad Top Butte deposit, Anamax carried out an estimate in 1979 that found a preliminary

estimated mineral resource of 8.8 million tons at an average grade of 0.77 percent copper and 

0.037 percent molybdenum. This estimate must be considered to be historical in nature, is based on 

limited drilling results, and is not necessarily consistent with current industry practices and securities 

reporting requirements. The Applicant estimates it will take at least five years and 12 million dollars to 

conduct the necessary drilling and engineering to advance the property to a possible economic feasibility 

stage, although, as is the nature with any early stage exploration mineral project, there are no guarantees 
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that such a project will eventually be shown to be economic by a feasibility study. Given the lack of 

information for this deposit, it could not yet be considered a viable Mineral Resource under current 

definitions, and could therefore not be considered available. 

Size: Current estimates show 8.8 million tons of preliminary mineral resource.

Availability: Available in the sense that Rosemont owns the deposit.

Cost: Unknown. However, as indicated above, the cost just to complete exploration and 

feasibility analysis for this deposit is estimated at approximately 12 million dollars. 

Logistics and 

Technology:

Largely unknown, although considerations of logistics and technology would presumably 

be similar to those for the Rosemont deposit.

Summary of 

Practicability:

Given the lack of information about this deposit, the feasibility of its extraction cannot be 

determined until a full exploration campaign and feasibility analysis are completed. 

Because of the considerable additional time and expense required to complete such an 

exercise, Broad Top Butte could not be considered to be available, and would therefore 

not be considered a practicable alternative. 

2.3.2. Copper World

The Copper World deposit contains mineralization that was mined by a historical small-scale, high-grade 

mine. Little is known of the remaining mineralization, other than variable results from a few widely 

scattered drill holes. There is not enough information for the Applicant or predecessor companies to have 

estimated a mineral resource. It is most likely that a small deposit of low-grade mineralization may 

remain at Copper World that is only a fraction of what the mineable mineral reserve is for the Rosemont 

deposit.

Like the Broad Top Butte deposit, the considerable lack of information related to the Copper World 

deposit makes it impossible to categorize this deposit as a viable Mineral Resource under the current 

definition. Based on the very limited information that is available, it seems likely that whatever mineral 

resource remains at the Copper World deposit would be far smaller than the Rosemont deposit. As with 

the Broad Top Butte deposit, if the Copper World deposit were to be developed, it could only be as part of 

the development of the larger Rosemont deposit. 

Size: Unknown, although likely substantially smaller than the Rosemont deposit.

Availability: Available in the sense that the Applicant owns the deposit.

Cost: Unknown. 

Logistics and 

Technology:

Largely unknown, although the location of the deposit on the west side of the Santa Rita 

Mountain ridgeline would significantly affect logistical considerations when compared to 

the Rosemont Project.
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Summary of 

Practicability:

Given the lack of information about this deposit, the feasibility of its extraction cannot be 

determined until a full exploration campaign and feasibility analysis are completed. 

Because of the considerable additional time and expense required to complete such an 

exercise, Copper World could not be considered to be available, and would therefore not 

be considered a practicable alternative. 

2.3.3. Peach-Elgin

At the Peach-Elgin deposit, Anaconda carried out an estimate in 1964 that found a preliminary mineral 

resource of 13.7 million tons of sulfide mineralization at an average grade of 0.78 percent copper and 

0.037 percent molybdenum, along with 9.7 million tons of oxide mineralization averaging 0.72 percent 

copper. In producing this estimate, Anaconda drilled a number of additional holes in the 1960s, the 

records for which were permanently lost before the Applicant obtained the property and property 

information. As with the 1979 Broad Top Butte estimate, this mineral resource estimate should be 

considered historical in nature and not necessarily consistent with current industry practices and securities 

reporting requirements. Given the lack of information for this deposit, it could not yet be considered a 

viable Mineral Resource under current definitions, and could therefore not be considered available. 

This deposit is likewise very small, comprising only 4.3 percent of the mineable reserves identified at the 

Rosemont deposit. As with the other two nearby mineral deposits, the Peach-Elgin deposit has potential 

as a satellite area of production, but not as a viable alternative to the Rosemont deposit.

Size: Current estimates show 23.4 million tons of preliminary mineral resource.

Availability: Available in the sense that the Applicant owns the deposit.

Cost: Unknown

Logistics and 

Technology:

Largely unknown, although the location of the deposit on the west side of the Santa Rita 

Mountain ridgeline would significantly affect logistical considerations when compared to 

the Rosemont Project.

Summary of 

Practicability:

Given the lack of information about this deposit, practicability in terms of cost, logistics, 

and technology cannot be determined until a full exploration campaign and feasibility 

analysis are completed. Because of the considerable additional time and expense required 

to complete such an exercise, Peach-Elgin could not be considered to be available, and 

would therefore not be considered a practicable alternative.

2.3.4. Rosemont-Owned Alternatives Summary

The Applicant has evaluated the potential to develop three deposits within the Rosemont Holdings 

boundary. None of these deposits represents a practicable alternative to the Rosemont Project because a 

Mineral Reserve was not identified for any of these deposits in 2005, and a Mineral Resource could not 

be reasonably determined based on the paucity of information related to the deposits. 
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2.4. ONSITE ALTERNATIVES

The formulation of onsite alternatives has been based on information provided by the CNF and the 

Applicant, and is consistent with typical mine planning approaches. In proposing a mill and concentrate 

operation for sulfide ore with an open pit copper mine, the Applicant has already determined that an 

underground mine or in situ leach operation is not practicable and that the mineralogical characteristics of 

the leachable ore deposits make other extraction and processing techniques inappropriate. Alternative 

mining techniques that were considered but dismissed from further evaluation are addressed in the EIS 

completed for the Project.

The formulation of alternative mine development scenarios for an open pit copper mine is tied to the pit 

location, as the location of the deposit and considerations related to the appropriate pit location, depth, 

and configuration are dependent on the location and arrangement of the ore deposit. For the proposed 

Project, a floating cone evaluation of the Rosemont deposit resulted in the pit configuration proposed by 

the Applicant in the 2007 MPO (WestLand, 2007). The floating cone evaluation of potentially economic 

pit limits is based on a variety of criteria, including the nature and extent of the ore body that can be 

economically developed, as influenced by projected future copper prices, projected capital and operating 

expenses, financial risk factors, and pit stability considerations which set the appropriate setbacks, pit 

wall slopes, and benching necessary to achieve stable slopes and appropriate safety standards. The pit 

design was refined in 2009 based on a feasibility analysis. The proposed pit configuration for all 

alternatives considered in the EIS and this alternatives analysis is that with a pit bottom elevation of 

3,050 ft amsl.

Onsite alternatives reflect a variety of configurations, which come primarily from the development and 

location of heap leach pads, dry stack tailings, waste rock storage, plant site facilities, and onsite and 

offsite ancillary facilities. Once the pit size and volumes of waste rock, dry stack tailings, and leachable or 

concentratable ore were defined, the configuration of suitable storage locations for waste rock and dry 

stack tailings and the acceptable locations for leach stockpiles and processing facilities could be 

identified. The placement of waste rock, dry stack tailings, heap leach pads, and processing facilities 

relative to the pit and to each other is not completely independent. There are various technical constraints 

relative to the interrelated aspects of these components that affect the location and configuration of each 

with respect to the others in each alternative. In addition to the configuration alternatives, there is one 

alternative relative to the sequencing of the dry stack tailings.

The development of leachable and concentratable reserves within the Rosemont deposit will result in a 

relatively fixed volume of material that must be accommodated in the various locations proposed for 

alternatives, in a manner that is practicable while achieving the Project’s overall purpose and need.

The area considered suitable for the evaluation of onsite alternatives is bounded by specific topographic 

and geographic features. In general, the analysis area is bounded on the west by the ridgeline of the Santa 

Rita Mountains and on the east by SR 83. The southern boundary of the analysis area was established by 

the watershed boundary of Cienega Creek, a sensitive riparian resource east of the Project site. Where no 

topographic or geographic feature constrains the mine plan area, cost considerations for haulage distance 
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also limit the consideration of appropriate alternatives. The relationship between haulage distance and 

cost creates economic and sometimes logistical constraints that affect the practicability of alternatives.

2.4.1. Onsite Alternatives Development

2.4.1.1. Onsite Alternatives Considered but Dismissed

An expansive suite of alternatives was considered and dismissed as part of the draft EIS development 

process. Some examples include the mechanical conveyance of ore to a rail head, in situ mining in lieu of 

an open pit, and use of desalinated sea water for mining and ore processing. These alternatives and the 

rationale for their dismissal are discussed in detail in the EIS or in the EIS supporting documentation. 

In addition to the EIS alternative development process, the Applicant evaluated a number of other onsite 

alternatives that were quickly dismissed due to obvious and significant adverse environmental effects.

• Expand Pit West Through Ridge: The Rosemont ore body includes economically recoverable 

reserves that would require expansion of the pit west through the Santa Rita Mountain ridgeline, 

including Weigles Butte. However, this larger pit would significantly impact the view of the Santa 

Rita Mountains from the heavily populated Sahuarita and Green Valley areas. This alternative would 

have also resulted in a significant increase in waste rock and tailings to be disposed of. Given these 

factors, the Applicant elected to limit the size of the pit to the current configuration.

• Conventional Tailings Design: The Applicant completed a tailings siting study in 2006 

(Vector 2006) to identify potential locations for the development of a tailings facility. The study 

focused on conventional (slurry) tailings, but also evaluated the potential benefits of the use of dry 

stack tailings. The study concluded that conventional tailings facilities would result in a larger 

footprint than a comparably located dry stack tailings facility, predominantly because development of 

a conventional tailings facility requires the construction of a significant downgradient dam to contain 

the slurried tailings material. The sizes of the conventional tailings facilities evaluated in the siting 

study ranged from approximately 1,300 to 2,700 acres. Under the current alternative designs, the total 

area of dry stack tailings material and surrounding buttress ranges from approximately 870 to just 

over 1,200 acres. Although an analysis of the impacts to potential waters of the U.S. resulting from 

these larger tailings facilities has not been completed, it is assumed that the increase in impacts would 

have been commensurate with the increase in size of the facilities.

The size of the conventional tailings facilities was such that the total volume of an appropriately sized 

tailings facility and the waste rock material from the operations could not be restricted to a single 

drainage basin (i.e., Barrel Canyon). Use of a conventional tailings facility therefore would have 

required development in another drainage basin, such as Sycamore Canyon or east of SR 83 in upper 

Davidson Canyon, with waste rock being deposited in Barrel Canyon, significantly increasing the 

geographic scope of the Rosemont Project. The conventional tailings dam had other significant 

environmental drawbacks as well:

− Requires considerably more water usage than dry stack tailings

− Increased risk of seepage to groundwater
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− Increased risk of windblown tailings

− No opportunity for concurrent reclamation

Given the larger footprint and significant environmental disadvantages of a conventional tailings 

design, the Applicant did not pursue this alternative further.

• Pit Backfill: Rosemont evaluated in depth the potential to backfill, or partially backfill, the pit with 

waste rock material. Implementation of a pit backfill alternative would result in significant additional 

environmental effects and safety considerations when compared with other alternatives. A thorough 

discussion of the legal implications of a pit backfill alternative, as well as technical and cost 

challenges associated with three pit backfill alternatives are provided in a separate memorandum and 

letter, respectively, provided in Appendix B of this document but are summarized below. 

Implementation of a pit backfill alternative would effectively result in extending the mining 

operations for 3 to 22 years, depending on the extent of backfilling. The waste rock material to be 

backfilled into the pit would have to be re-mined, hauled, and deposited back in the pit. 

Environmental effects (continuing and otherwise) resulting from this alternative include:

- Removal of the hydraulic sink within the pit, thereby removing the passive containment 

system contemplated in the Arizona Department of Environmental Quality (ADEQ) Aquifer 

Protection Permit;

- Forestalling of reclamation until backfill activities are complete (i.e. there will not be able to 

be any concurrent reclamation of the majority of the impacted area, though the tailings 

facility may be able to be reclaimed concurrently with operations.);

- Continued dewatering of downstream reaches of Barrel and Davidson canyons until 

reclamation can be accomplished and final post-mining stormwater controls can be put in 

place;

- Continued impacts to air quality resulting from dust generation and truck emissions;

- Continued use of diesel fuel for haul trucks;

- Continued use of water for dust suppression;

- Continued impacts to visual resources as reclamation cannot be accomplished until backfill 

activity is complete.

The backfilling activity would also result in heightened safety concerns, as haul trucks are not 

designed to carry full loads downhill. 

Potential waters of the U.S. and riparian habitat impacted under this alternative would be lost even if 

surface flow paths could be re-established within the former footprint of the waste rock and tailings 

facilities. Downgradient impacts to potential waters of the U.S. and riparian habitat would continue 
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for another 3 to 22 years beyond mine life, until stormwater flows could be restored following the pit 

backfill effort.

Given the above, backfill of the pit does not represent a reasonable alternative for the Rosemont 

Project. 

2.4.1.2. Selected Onsite Alternatives

Various configurations of the largest Project structural elements (i.e., heap leach pads, dry stack tailings, 

and waste rock storage) have been considered. In addition, one alternative is considered that changes the 

configuration of the pit. Six alternatives affecting the configuration of the mine plan elements and other 

items are contemplated in this document. The onsite alternatives will be detailed and analyzed in Chapter 

3, and are identified as follows:

• Alternative 1: Mine Plan of Operations

• Alternative 2: Phased Tailings

• Alternative 3: Barrel (Proposed Action)

• Alternative 4: Barrel Trail

• Alternative 5: Scholefield-McCleary

• Alternative 6: Modified Pit Configuration

2.4.2. Elements Common to All Onsite Alternatives 

Certain elements of the Project planning have not been individually evaluated in the discussion of the 

alternatives provided below. These items are common to all the alternatives and are listed here to provide 

an overall understanding of the Project and the context of the alternatives considered, and to reduce the 

need to describe the common elements within the description of each alternative. These items are 

described below.

Production Rates, Processing Facility Output, and Types of Equipment: Production rates, processing 

facility output, and types of equipment used will be the same for all the onsite alternatives. The 

information provided here is derived from the 2012 feasibility study. The most recent feasibility study for 

the Rosemont Project provides a mineral reserve calculation of 667 million tons of ore, and the Project is 

expected to produce approximately 243 million pounds of copper per year for approximately 21 years for 

each alternative. The average annual production of molybdenum and silver is projected to be 5.4 million 

pounds and 2.9 million ounces, respectively. There is one exception to the expected production: an 

alternative that considers a smaller pit (Alternative 6), which will reduce the total availability of ore for 

production. The major mining equipment on site will include drills, loading units, trucks, and support 

units. The types of equipment will be similar within each alternative, although there may be different 

quantities of equipment required for the various alternatives and throughout the life of each alternative.
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Mineral Processing Operations and Techniques: Mineral processing operations and techniques will 

generally be the same for each of the alternatives. It should be noted that Rosemont's Proposed Action 

(Barrel Alternative) does not include the construction of a heap leach and associated SX/EW processing 

operations. An analysis of the removal of the heap leach and associated facilities from the other 

alternatives is provided in Section 3.1.7, below.

Mining of the ore will be through conventional open-pit mining techniques. Mining operations will be 

carried out in the open pit with benches that are 50 ft in height. The pit will be constructed to meet the 

standards required for stability as identified by the Applicant’s geotechnical engineering analysis and will 

conform to Mine Safety and Health Administration standards.

Waste rock will be blasted and transported by haul truck to the waste rock storage areas. Ore will be 

blasted and either transported by haul truck to the leach pad or crushed and loaded onto a conveyor for 

transport to the mill, depending on the type of ore. Ore will be processed either by conventional sulfide

milling or by oxide leaching. The copper concentrates from the milling operations (sulfide material) will 

be shipped offsite to a smelter. Leach ore (oxide material) will be placed on the leach pad. The heap leach 

facility will be large enough to contain all the oxide material processed on a lined leach pad. Drainage 

around the facility will be provided by the stormwater management facilities. Sufficient pond sizing will 

be available for emergency overflow containment of the 100-year, 24-hour storm event, with pumping 

capacity to manage additional flows. Solutions from the pad will be collected in a solution pond and then 

processed through the SX/EW plant. Copper cathodes generated from the SX/EW plant will be 

transported offsite for further processing.

Waste rock buttresses will be constructed for the dry stack tailings facilities. The tailings will be filtered 

prior to disposal and delivered by conveyor from the filter plant to the tailings disposal location to be 

placed with a radial stacker against the starter buttresses.

General Plant Site Location: The location of the plant site with respect to the pit is similar for all the 

onsite alternatives. The arrangement of facilities within the plant site has been optimized for all but the 

Mine Plan of Operations Alternative (Alternative 1). 

Reclamation and Closure: The overall slopes will be left at 3:1, which will provide appropriate slopes 

for reclamation. Topsoil will be removed, stored, and then replaced on portions of the waste rock storage 

and dry stack tailings facilities as well as the perimeter buttresses. Plants utilized in the reclamation effort 

will include native grasses, shrubs, forbs, and trees, as well as transplanted and propagated agave plants. 

Under Alternatives 1, 2, and 3, reclamation of the outer waste rock buttress will be completed 

concurrently with operations, starting in Year 1. Under Alternatives 4 and 5, concurrent reclamation, to 

the extent that it could occur, would not occur until a much later date in the operations due to constraints 

of slope and logistics, respectively. Additional detail is provided in the sections below.

Primary and Secondary Access and Utility Alignments: Primary access to the Project site will be from 

SR 83 for all the onsite alternatives. The actual location for the turnout and the alignment of the roadway 

vary slightly between the alternatives due to changes in the configuration of the waste rock and tailings, 
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but the primary access is from the east in all alternatives. Secondary access and utility alignments will be 

from the west for all the onsite alternatives. The water supply system and electrical power alignments will 

generally follow the secondary access road alignment.
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3. ALTERNATIVES DESCRIPTION, PRACTICABILITY DETERMINATION, AND 

ENVIRONMENTAL ANALYSIS

Each of the onsite alternatives considered is briefly described below. Following each description is a 

discussion of each alternative’s practicability. Table 3 summarizes a number of key differences between 

each of the alternatives. Minor changes in impacts from previous versions of this document relate to 

refinement of the alternative designs and associated security fencing, and broader assumptions about 

impacts related to the primary access road. 

Avoidance and minimization have been achieved for the onsite alternatives in a number of ways. As 

described above, a guiding principal in the development of alternatives was to limit the project to a single 

drainage (Barrel Canyon) to minimize the impact to potential waters of the U.S. The dry stack tailings 

technology and modern plant design have allowed for a relatively smaller footprint for the alternatives 

considered. Previous project concepts contemplated by ASARCO when they owned the Project area in 

the 1990’s included the use of conventional (slurry) tailings and impacted an area considerably larger than 

any of the alternatives developed for the EIS or this alternatives analysis (see discussion of conventional 

tailings design in Section 2.4.1.1 above). Minimization of impacts to potential waters of the U.S. is 

achieved through best management practices as outlined in ADEQ's Arizona Pollutant Discharge 

Elimination System (AZPDES) Multi-Sector General Permit (MSGP) for stormwater discharges and the 

best available demonstrated control technologies (BADCT) design of the facilities ADEQ Aquifer 

Protection Permit (APP). As noted in Subpart H of the Section 404(b)(1) guidelines (40 CFR §230.72), 

minimization of adverse effects can be achieved by “selecting discharge methods and disposal sites where 

the potential for erosion, slumping or leaching of materials into the surrounding aquatic ecosystem will be 

reduced.” The BMP and BADCT prescriptions of the AZPDES and APP programs, respectively, are 

designed to achieve these goals. These include use of sediment basins, lined containment ponds, capping 

of tailings material post-closure, and minimizing point and non-point pollutant discharges. Additional 

minimization efforts include stormwater control designs that route as much unimpacted water as feasible 

into downstream flow systems.

The discussion of onsite alternatives includes an estimate of impacts as follows:

• Direct and indirect impacts to potentially jurisdictional waters: The estimate of direct impacts to 

potential waters of the U.S. includes that area of potential waters within each alternative that will 

be directly filled by waste rock, native fill, etc. Indirect impacts to potential waters of the U.S. 

were determined by calculating the area of potential waters from the toe of the waste rock and/or 

tailings pile downstream to the confluence with the nearest large drainage. Additional indirect 

downstream impacts to potential waters of the U.S. were determined based on the modeled 

reduction in average annual flow volume within Barrel and Davidson canyons. The modeled flow 

reductions are described in the EIS completed by the CNF. 

• Direct and indirect impacts to riparian habitat: In this analysis, riparian habitat mapping is 

provided by Pima County at the online Pima County MapGuide. Direct impacts include those 
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areas of mapped riparian habitat that occur within the security fence for each alternative. Impact 

results for riparian habitat are described fully in the EIS for the Project. 

It should be noted that impacts to downstream riparian habitat are dependent on the reduction in 

surface water flow and the type of habitat within each stream reach. Impacts to downstream 

riparian habitat will qualitatively be similar under all alternatives (see discussion below), though 

likely greater under alternatives with greater reduction in stormwater flows. Within Barrel 

Canyon, downstream of the operations, effects on the xeroriparian habitat could vary from 

reduced vegetation volume to mortality of individuals, though a complete loss of xeroriparian 

habitat is unlikely. 

Within Davidson Canyon, from the confluence with Barrel Canyon to Davidson Spring, riparian 

habitat is largely xeroriparian, with pockets of mesoriparian habitat. Effects on the pockets of 

mesoriparian habitat may include reduced recruitment, increased mortality rates, decreased 

canopy height and vegetation volume, and potentially a transition to deeper-rooted species 

(e.g. tamarisk). Impacts to xeroriparian within this reach of Davidson Canyon would be expected 

to be similar to, though less than, those described for Barrel Canyon. That is, impacts could range 

from reduced vegetation volume to mortality of individuals, but a complete loss of xeroriparian 

habitat is unlikely.

• Number of springs supporting riparian vegetation that are directly impacted or highly likely to be 

indirectly impacted

• Number of springs supporting riparian vegetation that will possibly be indirectly impacted

3.1. ONSITE CONFIGURATION ALTERNATIVES

3.1.1. Alternative 1 – Mine Plan of Operations 

Alternative 1 is the configuration presented in the July 2007 MPO (WestLand, 2007). The facilities for 

this alternative incorporate McCleary, Barrel, and Wasp Canyons (Figure 6). For this alternative, waste 

rock will be placed in the Barrel Canyon drainage. The dry stack tailings will be stored in two separate 

phases, the North (McCleary Canyon) and the South (Barrel Canyon) Dry Stacks. Tailings will be 

dewatered at the plant site facilities and then conveyed overland to the tailings facilities. Dry stack 

tailings will be placed in the North Dry Stack area (McCleary Canyon) first, for a period of approximately 

14 years. During Year 12, preparation work will begin in the South Dry Stack area to prepare the facility 

for tailings placement. Tailings will be placed in the South Dry Stack facility (Barrel Canyon) by Year 14. 

The heap leach facility will be located in the Barrel Canyon drainage.

The perimeter berms will be located in the Barrel Canyon drainage, while the buttresses will be located in 

both Barrel and McCleary canyons. A large underdrain feature, called the “central drain,” will be located 

along the major McCleary Canyon drainage between the two tailings phases. The primary offsite roadway 

alignment presented in the original MPO is shown in Figure 6. The primary access will follow a roadway 

alignment that crosses both Scholefield and McCleary Canyons and the confluence of Barrel Canyon near 
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the intersection with SR 83 at approximately milepost 46.9. A variety of elements related to the 

construction and impacts of this configuration are presented in Table 3, below.

Environmental Effects: Implementation of Alternative 1 will result in the following impacts: 

• Direct impacts to potential waters of the U.S.: 42.5 acres

• Indirect impacts to potential waters of the U.S.: 36.9 acres

• Direct impacts to riparian habitat: 674.6 acres

• Indirect impacts to riparian habitat: 664.5 acres

• Number of springs directly or highly likely impacted: 14

• Number of springs possibly indirectly impacted: 35 

An evaluation completed by Tetra Tech (2010a) shows that the average annual stormwater flows within 

Barrel Canyon at the SR 83 bridge immediately upgradient of the confluence with Davidson Canyon will 

be reduced by approximately 45.8 percent as a result of this alternative. Graphic representation of the 

reaches of Barrel and Davidson canyons that will be dewatered as a result of all alternatives is shown in 

Figure 7. 

Practicability Determination: This alternative is likely practicable. That is, Alternative 1 is available, 

logistically and technologically feasible, practicable from a cost perspective, and consistent with the 

Applicant’s Project purpose. However, additional engineering and hydrologic evaluation of the central 

drain design indicated that long-term maintenance of the drain could be a concern, along with additional 

contact between stormwater and tailings and increased seepage to groundwater. The development of 

Alternative 2 (below) was accomplished, in part, to address these concerns. 
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Table 3. Summary of Key Elements of Onsite Alternatives

Alternative 1

Mine Plan of 

Operations

Alternative 2 

Phased Tailings 

Alternative 3 

Barrel

Alternative 4 

Barrel Trail

Alternat

Scholefi

McClea

Total area direct impacts (acres) 5,602 5,471 5,421 5,878 

Total exclusion (fenced) area (acres) 6,177 5,471 5,421 5,878 

Pit size (acres) 950 950 950 950 

Waste rock area (acres) 2,000 1,370 1,460 1,820 

Waste rock ultimate elevation (ft amsl) 5,450 5,470 5,435 / 5,700 5,300 / 5,600 

Tailings area (acres) 870 1,135 987 1,040 

Tailings storage ultimate elevation 

(ft amsl) 5,250 5,250 5,300 5,238 

Leach pad area (acres) 230 126 -- 126 

Leach pad ultimate elevation – before 

cover (ft amsl) 5,340 5,380 -- 5,380 

Estimated average haulage distance – 

waste rock (ft) 14,475 14,475 17,515 17,515 2

Estimated average conveyor distance – 

tailings (ft) 12,000 11,105 14,385 14,385 1
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3.1.2. Alternative 2 – Phased Tailings

Alternative 2 consists of a modification to the 2007 MPO (Alternative 1) as a response to issues raised 

during public scoping. This alternative is similar to Alternative 1 in that the waste rock and tailings 

facilities will be confined to McCleary and Barrel Canyons (Figure 8). However, in addition to a number 

of minor design element changes and mitigation concepts, this alternative includes an alternative tailings 

sequence in which the McCleary Canyon drainage will be impacted later in the development of the 

Project. As with Alternative 1, the facilities for this alternative incorporate Wasp, Barrel, and McCleary 

Canyons.

The phasing for this alternative starts in Barrel Canyon and leaves McCleary Canyon open for a period of 

approximately 10 years prior to any tailings deposition activity in this area. This keeps the footprint for 

the first 10 years isolated to an area of Barrel Canyon. As with Alternative 1, the tailings will be stored in 

two separate phases, the North (McCleary Canyon) and the South (Barrel Canyon) Dry Stacks. Tailings 

will be dewatered at the plant site facilities and then conveyed overland to either of the tailings facilities. 

Under Alternative 2, dry stack tailings will be placed in the South Dry Stack first for a period of 

approximately 12 years, leaving McCleary Canyon open. During Year 10, preparation work will begin in 

the North Dry Stack area (McCleary Canyon) to prepare the facility for tailings placement. Tailings will 

be placed in the facility by Year 12.

As under Alternative 1, the waste rock and heap leach facilities will be placed in the Barrel Canyon 

drainage under this alternative. The perimeter berms will be located in the Barrel Canyon drainage, while 

the buttresses will be located in both Barrel and McCleary Canyons. A revised underdrain system will be 

located along the major drainages underlying the facilities. This alternative includes a revised alignment 

for the offsite roadway, as shown in Figure 8. The same elements presented in Alternative 1 relative to 

construction and impacts have been analyzed for Alternative 2 and are presented in Table 3. 

Environmental Effects: Implementation of Alternative 2 will result in the following impacts:

• Direct impacts to potential waters of the U.S.: 41.8 acres

• Indirect impacts to potential waters of the U.S.: 37.2 acres

• Direct impacts to riparian habitat: 629.4 acres

• Indirect impacts to riparian habitat: 664.5 acres

• Number of springs directly or highly likely impacted: 14

• Number of springs possibly indirectly impacted: 35

Average annual stormwater flows in Barrel Canyon at the SR 83 bridge will be reduced by 44.3 percent

under this alternative (Tetra Tech, 2010b).

Practicability Determination: This alternative is practicable.
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3.1.3. Alternative 3 – Barrel (Proposed Action)

It should be noted that, in addition to being the Proposed Action, the Barrel Alternative has also been 

identified as the Preferred Alternative of the CNF in the Draft EIS. Under this alternative, both dry stack 

tailings and waste rock will be confined to Barrel Canyon and an unnamed tributary of Barrel Canyon 

between Barrel Canyon proper and SR 83 (Figure 9), referred to colloquially as “Trail Canyon,” 

presumably for its proximity to the Arizona Trail. The facilities for this alternative incorporate Wasp and 

Barrel Canyons. Waste rock storage is provided in both Barrel Canyon and Trail Canyon. Tailings will be 

dewatered at the plant site facilities and then conveyed overland to the tailings facility. Dry stack tailings 

will be located entirely within Barrel Canyon. The perimeter berms and buttresses will be located in the 

Barrel Canyon drainage as well. 

There will be no underdrains or heap leach facility as part of this alternative. The roadway alignment for 

this alternative is the same as for Alternative 2. The same elements presented in Alternative 1 relative to 

construction and impacts have been analyzed for Alternative 3 and are presented in Table 3. 

Environmental Effects: Implementation of Alternative 3 will result in the following impacts:

• Direct impacts to potential waters of the U.S.: 40.0 acres

• Indirect impacts to potential waters of the U.S.: 28.4 acres

• Direct impacts to riparian habitat: 587.4 acres

• Indirect impacts to riparian habitat: 664.5 acres

• Number of springs directly or highly likely impacted: 13 

• Number of springs possibly indirectly impacted: 36 

The reclamation designs for Alternative 3 have been optimized to maximize downstream flows both 

during operations and post-closure. Under Alternative 3, annual average stormwater flows in Barrel 

Canyon at the SR 83 bridge will be reduced by 17.2 percent after approximately Year 10 

(Tetra Tech, 2012a). Due to the deposition of waste rock in Trail Canyon, this alternative has higher 

impacts to visual resources along SR 83 than either Alternative 1 or 2.

Practicability Determination: This alternative is practicable.

3.1.4. Alternative 4 – Barrel Trail

Similar to Alternative 3, this alternative has been developed to address potential concerns related to visual 

aesthetics and stormwater runoff. Under this alternative, the surface of the waste rock dumps and the 

covered tailings facility and heap leach pad would be modified to affect a more “natural” contour, 

resulting in a considerable expansion of the facility footprint (Figure 10). Alternative 4 is otherwise 

similar to Alternative 3. 
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Environmental Effects: Implementation of Alternative 4 will result in the following impacts:

• Direct impacts to potential waters of the U.S.: 50.0 acres

• Indirect impacts to potential waters of the U.S.: 34.1 acres

• Direct impacts to riparian habitat: 632.6 acres

• Indirect impacts to riparian habitat: 664.5 acres

• Number of springs directly or highly likely impacted: 13

• Number of springs possibly indirectly impacted: 36

Under this alternative, annual average stormwater flows in Barrel Canyon at the SR 83 bridge will be 

reduced by 42.0 percent (Tetra Tech, 2010c). 

Air modeling completed for this alternative indicates that Alternative 4 would not meet National Ambient 

Air Quality Standards (NAAQS) for particulate matter (PM10) (JBR Environmental Consultants, 2012). 

This air modeling effort has been reviewed by the CNF and EPA. Finally, because this alternative will 

require substantial modification of the waste rock and tailings facilities surfaces at the end of mining, 

concurrent reclamation under this alternative, if it could occur, would only be able to be accomplished at 

some later point in the development of the project. The majority of reclamation, therefore, would likely 

occur at closure.

Practicability Determination: This alternative is practicable.

3.1.5. Alternative 5 – Scholefield-McCleary

Alternative 5 (Scholefield-McCleary) was developed in an effort to avoid cultural resources, riparian 

habitat, and recreational opportunities within Barrel Canyon. Under this alternative, the dry stack tailings 

will be located entirely within Scholefield Canyon (Figure 11). Waste rock will be located in two 

locations, both outside the canyon bottoms: 1) adjacent to and immediately south of the dry stack tailings 

within the McCleary Canyon drainage basin, but outside the drainage bottom, and 2) between Wasp and 

Barrel Canyons, overlying the heap leach pad once leaching operations have ceased in Year 6 and the 

heap leach pad has been reclaimed.

Two mechanisms for transporting the tailings to Scholefield Canyon are being considered for this 

alternative: conveyor and slurry pipeline. For the conveyor option, tailings will be dewatered at the plant 

site facilities and then conveyed overland to the tailings facility. For the slurry pipeline option, the tailings 

will be transported to a separate tailings filter plant and dewatered prior to their placement in Scholefield 

Canyon via an additional conveyor. The perimeter berms and buttresses will be located in the Scholefield 

Canyon drainage. The heap leach facility will be located in the Barrel Canyon drainage. This alternative 

includes a primary access roadway alignment that originates farther south on SR 83, as shown in 

Figure 11. The same elements presented in Alternative 1 relative to construction and impacts have been 

analyzed for Alternative 5 and are presented in Table 3. 
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Compared to the other alternatives, the Scholefield-McCleary alternative presents a number of operational

challenges. 

• In order to maximize the volume of material placed in McCleary Canyon, the slopes are necessarily 

long and uninterrupted by stormwater controls to slow sheetflow (Figure 12). Because the waste rock 

material will be stored on the relatively steep natural topography of the slopes of above McCleary 

Canyon (rather than in the canyon bottoms, as with the other alternatives), the risk of slope failure 

under this alternative is greater than under the other alternatives.

• Stormwater management on the long, unbroken slopes will require substantial stormwater controls at 

the toe of the slopes. Sheetflow from the long, unbroken slopes will report to the stormwater controls 

at a greater velocity than with the other alternatives, where intermediate stormwater controls will 

reduce stormwater velocity. Alternatively, implementation of intermediate stormwater controls for the 

Scholefield-McCleary alternative to break up the slopes would require an expanded footprint

(Tetra Tech, 2012b).

• Because of the relatively limited footprint and steep slopes of the waste rock facility under this 

alternative, reclamation of the waste rock slopes will be challenging and will have to occur at some 

later point in the development of the project, with the majority of the reclamation likely occurring at 

closure. 

• If a conveyor is used, slopes for the conveyor will be restricted to less than a 12 percent grade, 

requiring a relatively long conveyor route, crossing multiple potential waters of the U.S, including 

McCleary Canyon, Scholefield Canyon, and small unnamed tributaries of both these drainages and 

Barrel Canyon drainage. 

• If a pipeline is used, additional disturbance will be required for the remote filter plant as well as at 

least one drain pond in the event of a pipeline failure.

• This alternative (either the conveyor or pipeline) has a higher risk for operational interruptions than 

under the other alternatives due to the increased infrastructure associated with the conveyor and 

pipeline.

• The haulage length required for this alternative will require 10 additional haul trucks to be added to 

the fleet to reflect the lengthened haul to the waste rock facility in McCleary Canyon and the buttress 

in Scholefield Canyon. 

Given the technical challenges described above, the Scholefield-McCleary Alternative represents a 

significant increase in cost to construct the Rosemont Project compared to the other alternatives. The cost 

to haul material to construct the waste rock dump and the tailings buttress will require an initial $35 

million compared to the other alternatives, and will cost an additional $237 million over the life of the 

mine. The cost to construct the conveyor system to the distant tailings facility in Scholefield Canyon is 

over $69 million, and will require an additional life-of-mine power cost of approximately $72 million.

The cost for engineering controls to reduce the risk of slope failure on the waste rock pile has not been 

calculated, but would certainly be expected to be greater under this alternative compared to the other 

alternatives.
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Environmental Effects: Implementation of Alternative 5 will result in the following impacts:

• Direct impacts to potential waters of the U.S.: 26.2 acres

• Indirect impacts to potential waters of the U.S.: 22.7 acres

• Direct impacts to riparian habitat: 641.6 acres

• Indirect impacts to riparian habitat: 664.5 acres

• Number of springs directly or highly likely impacted: 19

• Number of springs possibly indirectly impacted: 32

Alternative 5 results in fewer direct impacts to potential waters of the U.S. (26.2 acres) than 

Alternatives 1 through 4 do. However, this alternative results in the second highest impacts to riparian 

habitat (641.6 acres) of all alternatives, and well more than Alternative 3 (Barrel Alternative). Average 

annual flood flows in Barrel Canyon at the SR 83 bridge will be reduced by 18.4 percent as a result of this 

alternative (Tetra Tech, 2010d), which represents a greater reduction in flow than Alternative 3 

(Barrel Alternative). 

However, this alternative would result in a number of other significant environmental effects when 

compared to the other alternatives, including those listed below, which prevented the CNF from 

identifying this alternative as the Preferred Alternative in the Draft EIS: 

• The direct loss of Scholefield Spring, one of the only special aquatic sites (wetlands) identified within 

the Project site and a feature that supports the giant sedge, designated by the U.S. Forest Service as 

“sensitive.” While Scholefield Spring is likely to be impacted over the life of the mine through 

groundwater drawdown, that impact is a projected one based on the assumption that the spring is 

dependent on regional groundwater. If it turns out that there are other localized sources feeding that 

spring, the impacts may not be as adverse as predicted. Moreover, those impacts will occur 

substantially later in time than would occur if the springs were lost through fill activities (they would 

be lost completely early in the mine life). 

• Development of operations within approximately 0.5 mile of a significant lesser long-nosed bat roost 

site (Helena Mine). Although it has been shown that mine operations are compatible with lesser 

long-nosed bat maternity roost sites (notably with the operation of the Cyprus Tohono Corporation 

mine facility near the Old Mammon Mine), an alternative that was developed further away from the 

roost feature would be expected to have less potential to adversely affect the roost site or the 

individuals within it.

• Greater impacts to air quality. Air modeling indicates that the Scholefield Alternative would not meet 

National Ambient Air Quality Standards (NAAQS) for particulate matter (PM10 and PM2.5) (JBR 

Environmental Consultants, 2012). This air modeling effort has been reviewed by the CNF and EPA. As 

described above, implementation of this alternative would require the addition of 10 haul trucks to the 

fleet, with the attendant increase in emissions. Per the October 2011 DEIS, development of the 
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Scholefield-McCleary Alternative will result in 14.1x increase in background levels of PM10 and an 8.4x

increase in nitrogen oxide over background levels, which represents the greatest impacts of all 

alternatives. 

• Significantly greater impact to visual resources. Under the Scholefield-McCleary Alternative, nearly 

22,000 acres of the Coronado National Forest designated with very high or high scenic integrity will 

be impacted, compared to less than 15,000 acres for the Proposed Action (Alternative 3). Portions of 

the waste rock and tailings facilities for this alternative will be visible from areas west of the Santa 

Rita Mountains, the only alternative where this occurs.

• A substantial adverse impact to lands designated by the Pima County Sonoran Desert Conservation 

Plan as being a Biological Core area. The total area of Biological Core affected by Alternative 5 

(1,347.8 acres) is more than five times greater than the next highest impact (250.7 acres under 

Alternative 1), due to the location of the tailings facility, waste rock storage facility, associated haul 

roads, and conveyor system within designated Biological Core areas. 

• As indicated above, reclamation of the waste rock under the Scholefield-McCleary Alternative would 

not occur concurrently with operations as it would under Alternatives 1, 2 and 3, and reclamation 

options in general would be severely limited due to the steepness of the slopes and access challenges 

associated with the waste rock facility in McCleary Canyon. 

Practicability Determination: This alternative suggests a waste rock disposal method (stacked on slopes 

outside of drainages) that is not commonly used in copper mines in Arizona due to cost, stability, and 

stormwater management considerations. 

In addition, the Scholefield-McCleary Alternative presents logistical and cost challenges due to 

significant increases in haulage distance for waste rock and conveyor or pipeline distance for dry stack 

tailings material, as well as an increased haulage distance for deposition of tailings buttress material in 

Scholefield Canyon. A substantial portion of the increased costs represent increased energy requirements, 

which are difficult to predict long term but are expected to increase over the life of the mine. The total 

increased cost would be expected to be even higher given the technological and logistical challenges of 

stacking the waste rock on the side of a hill, coupled with the construction of adequate stormwater 

controls at the toe of the waste rock slopes. 

Given the significant increased logistical challenges and cost of this alternative, it is not considered 

practicable. In addition, the significant adverse environmental effects of this alternative, described above, 

would prevent this alternative from being identified as the least environmentally damaging practicable 

alternative (LEDPA). 

3.1.6. Alternative 6 – Modified Pit Configuration

Alternative 6 consists of a modification to Alternative 2 (Phased Tailings Sequence) in which a portion of 

the proposed pit would remain undeveloped to avoid mining through Wasp Canyon (Figure 13). Under 

this alternative, a portion of the Rosemont ore body would not be recovered, eliminating the seventh 

(and final) mining phase and shortening the life of the mine by four years. The result of this revised pit 
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design is a loss of over 87 million tons of sulfide ore, which represents a 16 percent reduction in 

recoverable sulfide ore. The facilities for this alternative incorporate Barrel, Sycamore, McCleary, and 

portions of Wasp Canyons, although the upper extent of Wasp Canyon would remain largely open. 

Stormwater flows within Wasp Canyon would impound or flow through the waste rock facility. The leach 

stockpiles and waste rock facilities would be constructed similarly to Alternative 2 in terms of slopes and 

methods, but waste rock facilities would contain an estimated 25 percent less waste rock. This reduction 

in waste would reduce the facility height and the facility footprint would remain essentially the same. In 

order to avoid loss of waters in Wasp Canyon, this alternative would not include an upgradient 

stormwater diversion channel around the pit, as is contemplated for all the alternatives with a full-size pit. 

All other items relative to the configuration of the facilities and tailings sequence would be identical to 

those described in Alternative 2. 

Environmental Effects: Implementation of Alternative 2 will result in the following impacts:

• Direct impacts to potential waters of the U.S.: 41.0 acres

• Indirect impacts to potential waters of the U.S.: 40.3 acres

• Direct impacts to riparian habitat: 629.4 acres

• Indirect impacts to riparian habitat: 664.5 acres

• Number of springs directly or highly likely impacted: 14

• Number of springs possibly indirectly impacted: 35

Impacts to potential waters of the U.S. and riparian habitat under this alternative are similar to those under 

Alternatives 1 and 2, with the exception of a portion of Wasp Canyon. Avoidance of impacts to Wasp 

Canyon would result in approximately 0.8 fewer acres of direct impacts to potential waters of the U.S. 

than Alternative 2, for a total direct impact to potential waters of the U.S. of 41.0 acres. Impacts to 

stormwater flows under this alternative would be similar to those under Alternatives 1 and 2, with 

reductions in average annual flows into Davidson Canyon of 44.3 percent. 

This reach of Wasp Canyon would be isolated from downstream receiving waters by the construction of 

the waste rock facility and would be bounded on either side by a waste rock dump and the pit. In addition, 

the haul road from the pit to the waste rock dump would be required to cross the wash in three places 

during successive phases of mine life. As such, the functions and values of the avoided reach of Wasp 

Canyon would be significantly compromised.

Practicability Determination: This alternative is not practicable for several reasons. First, the alternative 

is logistically impracticable. Continued stormwater flows within Wasp Canyon would compromise the 

stability of the pit wall on the south and east portions of the pit, where the relatively low-strength Willow 

Canyon arkose and alluvium occur (Appendix C). This impact to stability represents a threat to the safety 

of mine employees. As such, a stormwater diversion channel and groundwater dewatering system would 

be required to keep this reach of Wasp Canyon dewatered. The construction of the stormwater diversion 
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channel would result in the “loss” of this reach of Wasp Canyon due to the dewatering effects of the 

channel.

As was noted by the Corps Los Angeles District in a recent 404(b)(1) analysis (Newhall Ranch Project; 

Corps File No. 2003-01264-AOA), “the substantial cost increases associated with some alternatives also 

must be viewed in light of the amount of additional avoidance of waters of the United States that they 

provide. A substantial cost increase may be reasonable if impacts also are reduced substantially, while a 

large increase in cost associated with a minimal reduction in impacts may not be reasonable.” As is 

demonstrated here, due to logistical constraints, Alternative 6 results in essentially no avoidance of loss of 

potential waters of the U.S. Given this, Alternative 6 would not be considered a practicable alternative.

3.1.7. Removal of Heap Leach and Associated Facilities

Only the Barrel Alternative (Alternative 3, the Proposed Action) is designed to not include a heap leach 

and associated SX/EW facilities, due to logistical constraints associated with the smaller footprint of this 

alternative. This section provides an evaluation of the effect of removing the heap leach from the other 

action alternatives.

Removal of the heap leach and SX/EW facilities from the other alternatives will not result in reduced 

impacts to potential waters of the U.S. because the heap leach pads are completely encapsulated by waste 

rock (where impacts to potential waters of the U.S. have already been identified) and the SX/EW is 

constructed on a ridge outside of all potential waters of the U.S. in all of the alternatives. Because the total 

volume of material (waste rock, tailings, and heap leach material) will remain largely unchanged (that is, 

the oxide ore that was to be heap leach material will now either be tailings or waste rock), the footprint of 

the facilities will not change with the removal of the heap leach and SX/EW. As such, the elimination of 

the heap leach pads from any of the other alternatives does not affect the determination of the LEDPA.

The elimination of the heap leach pads and SX/EW facilities from any of the alternatives will affect some 

other aspects of the alternative, as outlined below: 

• Electrical usage will be reduced from an estimated 794,000,400 to 738,420,400 kW-hr/year. 

However, the total connected load for the Rosemont Project is estimated to be approximately 

126 megawatts (MW) and will require a transmission voltage of 138 kV. The estimated demand load 

is about 96.5 MW and the estimated operations load is about 92.8 MW, providing for a configuration 

that will still require the use of a 138 kV line to transmit electricity. 

• Although fresh water usage is anticipated to be reduced by approximately 650 acre-ft/year with the 

removal of the heap leach and SX/EW, variability in the requirements for water for dust control in 

order to meet air permit requirements necessitate that estimated total water usage remain at the 

permitted amount of 6000 acre-ft/year. 

• The outdoor lighting necessary to operate the heap leach pads and SX/EW facilities will be 

eliminated, reducing nighttime light pollution by approximately 105,538 lumens. This estimate does 

not include the reduction in lighting from the removal of the SX/EW facilities, tanks, and ponds.
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• The minor risk of spills related to the transportation of sulfuric acid on State Route 83 will be 

eliminated. 

Additional discussion regarding the removal of the heap leach and SX/EW facilities from practicable 

alternatives (Alternatives 1, 2, 4, and 5) is provided in the following sections. As indicated here, the 

elimination of the heap leach and SX/EW facilities does not affect the determination of the LEDPA for 

the Rosemont Project.

3.1.7.1. Alternative 1A - Mine Plan of Operations without Heap Leach and SX/EW Facilities

As shown in Figure 6, under the alternative presented in the Mine Plan of Operations (Alternative 1), the 

entirety of the proposed heap leach pad would ultimately be completely encapsulated within the final 

waste rock area. As discussed above, if the heap leach facility were removed from Alternative 1, the 

majority of the material that would have been leached within the heap leach facility will be treated as 

waste rock, with only a minor portion of this material being processed within the mill. As such, the same 

volume of material (waste rock and tailings) will be incorporated into the final waste rock and tailings 

storage facility, resulting in no change to the facility footprint (Figure 14). Because the removal of the 

heap leach and SX/EW facilities results in no change to the facility footprint, there would be no change to 

the direct and indirect effects to potential waters of the U.S. and riparian habitat under Alternative 1A

compared to Alternative 1 (as described in Section 3.1.1 above). Other environmental effects will be as 

described in Section 3.1.7, above.

3.1.7.2. Alternative 2A - Phased Tailings without Heap Leach and SX/EW Facilities

Similar to the changes described under Alternative 1A above, the removal of the heap leach and SX/EW 

facilities from Alternative 2, the Phased Tailings Alternative (Figure 8), will result in no change to the 

facility footprint (Figure 15). Because no change to the facility footprint or final project configuration 

would result from the removal of the heap leach and SX/EW facilities from the Phased Tailings 

Alternative, direct and indirect impacts to potential waters of the U.S. and riparian habitat will be the 

same under Alternative 2A as they would be under Alternative 2 (as described in Section 3.1.2 above).

Other environmental effects will be as described in Section 3.1.7, above.

3.1.7.3. Alternative 4A - Barrel Trail without Heap Leach and SX/EW Facilities

As with the other alternatives, the design of the Rosemont Project under Alternative 4, the Barrel Trail 

Alternative, results in the heap leach facility being completely encapsulated within the waste rock storage 

facility within the first 10 years of mine operations (Figure 10). As with the other alternatives, therefore, 

the removal of the heap leach facility from the Barrel Trail Alternative will not result in any changes to 

the facility footprint because essentially the same volume of material (waste rock and tailings) will need 

to be stored within the these facilities. Direct and indirect impacts to potential waters of the U.S. and 

riparian habitat, therefore, will be the same under Alternative 4A (Figure 15) as under Alternative 4 

(as described above in Section 3.1.4). Other environmental effects will be as described in Section 3.1.7, 

above. 
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3.1.7.4. Alternative 5A - Scholefield-McCleary without Heap Leach and SX/EW Facilities

As shown in Figure 11, the heap leach facility under the Scholefield-McCleary Alternative is completely

encapsulated by waste rock by Year 10 of mining operations. Under Alternative 5A (Figure 17), the heap 

leach and SX/EW facilities will be removed from the operations, and that material that had been 

designated for leaching will instead be predominately waste rock, with some minor amount of tailings. 

The volume of material to be stored within the waste rock and tailings facility storage areas, therefore, 

will remain essentially unchanged, and no change in the facility footprint will be realized. As such, 

implementation of Alternative 5A would result in identical effects to potential waters of the U.S. and 

riparian habitat as those under Alternative 5 (as described in Section 3.1.5 above). Other environmental 

effects will be as described in Section 3.1.7, above.

3.2. UTILITY LINE ALTERNATIVES

As described above, electrical power and water will be brought to the Project site from the west for all 

onsite alternatives. This section describes alternative alignments and, in the case of the waterline, 

alternative technologies to the proposed action.

3.2.1. Power

Electrical power will be provided by Tucson Electric Power (TEP), which has completed the process for a 

Certificate of Environmental Compatibility (CEC) from the Arizona Corporation Commission. The CEC 

process included review of a number of potential alternative alignments for the power line (Figure 18).

For all alternatives, power was provided from a link attached to transmission lines on the South 

Substation loop. All alternatives include above-ground transmission lines and an associated unpaved 

maintenance road. In general, no transmission line poles, substations, or other structures were to be 

constructed in potential waters of the U.S. Impacts to potential waters of the U.S. would occur almost 

solely from the construction of a 12-ft-wide unpaved access road, and most of these impacts were 

anticipated to be temporary; that is, where feasible, the potential waters of the U.S. would be restored to 

preconstruction contours following construction of the transmission lines and access road. The only 

permanent fill would be at the culverted crossings of waters and at no more than three (3) utility poles in 

the steeper portions of the alignment through the Santa Rita Mountains. Estimated permanent fill is 0.05 

acre with an additional estimated temporary fill of 0.25 acre for temporary construction access.

Impacts to potential waters of the U.S. resulting from the various alternatives are provided in Table 4, 

below. Again, the majority of these impacts would be temporary.
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Table 4. Impacts to Potential Waters of the U.S.

from Transmission Line Alternatives

Alignment Impact to Potential 

Waters of the U.S. (acres)

Preferred Route 0.10 

Alternative 1 0.22

Alternative 2 0.29 

Alternative 3 0.40 

Alternative 4 0.20

The ACC selected the Preferred Route which also resulted in the fewest impacts to potential waters of the 

U.S. The Preferred Route, therefore, represents the least environmentally damaging practicable alternative 

for the power line.

3.2.2. Water

Two waterline alignments have been proposed: the one that was provided in the 2007 MPO (WestLand, 

2007), and a second that largely parallels Santa Rita Road through the Santa Rita Experimental Range and 

an existing unpaved road over the Santa Rita Mountains, through Lopez Pass. In discussions with the 

Arizona State Land Department and the University of Arizona (which are responsible for the Santa Rita 

Experimental Range), the Applicant determined that the preferred alignment for all parties is that which 

parallels Santa Rita Road (Figure 19). This alignment also comports with the Preferred Route for the 

power line, described above.

With either alignment, the pipeline will be constructed with a minimum soil cover of 36 in within State 

Land easements, and 24 in on the mine property. The pipe bedding requirements will follow the 

manufacturer’s recommendations. Isolation valves will be installed in the pipeline at intervals of 

approximately 3,000 ft and at elevation changes of 250 ft. 

Impacts resulting from the installation of the pipeline itself will, for most drainage crossings, be 

temporary, as the pipe trench will just be backfilled with the same soil material that had been removed 

and sidecast to create the trench. In drainages where the stability of the pipe is of concern, 

self-compacting pipe bedding material (e.g., crushed stone) may be placed immediately around the pipe. 

The remainder of the trench would be backfilled with native material. The total width of the trenching and 

sidecast will range from 30 to 52 ft, depending on whether or not power distribution will be included in 

the trenching. There are an estimated 54 crossings of potential WUS resulting from the proposed 

waterline. 

For drainage crossings where the wash material is comprised of soil and gravel, the pipeline will be 

buried below the calculated scour depth. Use of a non-erosive material, such as concrete, is only 

anticipated to be required in areas where the pipeline will be placed in relatively soft bedrock. In these 

instances, a non-erosive material, such as concrete, will be used to backfill the trench over the pipe to the 
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same level as the bedrock. As a result, the bottom elevation of the potential WUS will not change. Some 

minor bank stabilization may also be required in association with these crossings.

Construction of the waterline includes a permanent unpaved access road, which will provide access to the 

powerline as well for most of the respective alignments. Impacts to potential WUS resulting from the 

access road are anticipated to be minimal, as culverts will not be required for the majority of crossings. 

Most wash crossings will be at-grade, or will have minor fill of native material during the construction 

period to facilitate use by light vehicle traffic. These minor fills will be removed following completion of 

the waterline. In other areas, the access road is anticipated to divert back to Santa Rita Road for short 

reaches in order to avoid wash crossings. Culvert crossings will likely only be required where the 

roadway crosses potentially jurisdictional waters on the east end of the alignment, on the slopes of the 

Santa Rita Mountains. It is assumed that no more than five (5) such culverted crossings will be required, 

with a maximum width of 40 ft per crossing. Some minor bank stabilization may also be required in 

association with these culverted road crossings. 

Construction of the pipeline will include four forebay reservoirs and pump stations. The reservoirs and 

pump stations will be built outside potential WUS.

Because the impacts to potential waters of the U.S. from either alignment will be minimal and almost 

exclusively temporary (and therefore comparable), this analysis considers only the preferred alignment 

along Santa Rita Road (Figure 19). The two alternatives to be considered for the construction of the 

waterline relate to the technology to be used: 1) standard trenching and 2) jack-and-bore beneath the 

potential waters of the U.S.

Under the standard trenching alternative, based on refinements to the pipeline construction design, 

impacts to potential waters of the U.S. would total approximately 1.03 acre of temporary impacts and 

0.20 acre of permanent impacts resulting from the construction of road crossings and grade control 

structures. This construction method will cost between $210 and $360 per linear foot, depending on the 

size of pipe that is used.

Under the second waterline alternative, the waterline will be installed beneath potential waters of the U.S. 

using jack-and-bore technology, such that there would be no discharge of fill material to potential waters 

of the U.S. The estimated cost for the jack-and-bore alternative is between $1,100 and $1,800 per linear 

foot, or even more, depending on how large the wash crossing is. For the largest washes within the 

analysis area, additional costs will be incurred by the contractor for the excavation and shoring of the 

jack-and-bore pits. Utilizing jack-and-bore technology for the largest wash crossings within the analysis 

area will cost an estimated $1.5 million compared to $180,000 to $250,000 for the standard trenching 

technology. Jack-and-bore methods also result in substantially more disturbance to native vegetated 

ground than standard trenching techniques. This is due to the fact that the wash crossing itself is generally 

unvegetated (i.e., is located within the ordinary high water mark of the wash) while the staging areas 

located in the adjacent upland areas are generally vegetated. Staging areas are needed on either side of a 

wash being crossed, both for equipment and deposition of excavated material. Thus, avoiding temporary 

impacts within the wash itself results in increased adverse effects to upland areas. On balance then, 

jack-and-bore methods are not less environmentally damaging.
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As demonstrated here, the use of jack-and-bore technology costs between five and eight times that of 

standard trenching technology, results in an impracticable cost increase over the standard trenching 

methodology, and is more environmentally damaging. As such, standard trenching represents the LEDPA 

for the Project waterline.

4. SUMMARY AND CONCLUSIONS

This alternatives analysis has been completed in order to identify the LEDPA for the development of the 

Rosemont Project.

An analysis of potential offsite alternatives that were identified as being in existence in 2005 when 

Augusta Resource Corporation purchased the Rosemont Property was done at the request of the Corps. 

No viable offsite alternatives were identified.

The onsite alternatives that were evaluated as part of this analysis focused on various configurations of 

the dry stack tailings, waste rock dumps, and heap leach pad. The locations of the pit and plant site were 

assumed to remain the same for all alternatives. Other ancillary facilities (minor access roads, etc.) would 

be expected to have relatively minimal impacts to waters of the U.S. Table 5 provides a summary of the 

practicability criteria for the various onsite alternatives, selected environmental effects of each alternative, 

and a determination of practicability. 

As shown in Table 5, Alternatives 1 through 4 have been determined to be practicable alternatives to the 

Rosemont Project. Although Alternative 1 is practicable when evaluating availability, costs, logistics, and 

technology, it presents challenges with regard to long-term management of stormwater flows and would 

therefore not represent an appropriate alternative. 

Alternative 5 (Scholefield-McCleary) is not practicable due to logistical challenges and cost, and has 

other significant environmental effects that would prevent it from being considered the LEDPA, per the 

404(b)(1) guidelines (40 C.F.R. §230.10(a)). These impacts are described in Section 3.1.5 of this

document, and include: direct loss of Scholefield Spring (a potentially jurisdictional wetland), proximity 

to a significant lesser long-nosed bat roost site, greater impacts to air quality (does not meet NAAQS for 

PM10 or PM2.5), overall larger footprint area, significantly greater impact to visual resources, a substantial 

adverse impact to lands designated by the Pima County Sonoran Desert Conservation Plan as being a 

Biological Core area, increased energy and fuel use, and an extremely limited ability to conduct 

reclamation concurrently with operations. 

Of the three remaining alternatives, Alternative 4 (Barrel Trail) has the greatest direct impacts to waters 

of the U.S. (84.1 acres). Of the two remaining alternatives, Alternative 3 has the lowest comparable direct 

and indirect effects to potential waters of the U.S. (68.4 acres). Alternative 3, therefore, is the LEDPA for 

the Rosemont Project.

Of the five alignments considered as part of the Arizona Corporation Commission’s Certificate of 

Environmental Compatibility (CEC) for the Rosemont Project power line, the Preferred Route was 

selected for the CEC. This alternative resulted in the fewest impacts to potential waters of the U.S., the 
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majority of which are anticipated to be temporary. Therefore, the Preferred Route is the LEDPA for the 

Project's power line.

The two alternatives evaluated for the offsite waterline include a standard trench construction 

methodology that would result in 1.03 acre of temporary and 0.20 acre of permanent impacts to potential 

waters of the U.S. and cost an estimated $210 to $360 per linear ft. The other alternative entails using a 

jack-and-bore technique for installing the waterline below the washes that would result in no impacts to 

potential waters of the U.S. but would increase adverse impacts to upland vegetation and cost an 

estimated $1,100 to $1,800 per linear ft, or more, depending on the size of the pipe that is used and the 

width of the wash crossing. Because the jack-and-bore technology results in other environmental 

consequences at a cost five to eight times higher than that for the standard trenching technology, it is not a 

practicable or least environmentally damaging alternative.
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Table 5. Summary of Impacts and Practicability of Onsite Alternatives

Alternative 1

Mine Plan of 

Operations

Alternative 2 

Phased Tailings 

Alternative 3 

Barrel

Alternative 4 

Barrel Trail

Alternat

Scholefield-M

Practicability Criteria

Availability Yes Yes Yes Yes Yes 

Cost Yes Yes Yes Yes Yes 

Project Purpose Yes Yes Yes Yes Yes 

Logistics and Technology Yes Yes Yes Yes Yes 

Impacts to potential waters of the U.S. (acres)

Direct 42.5 41.8 40.0 50.0 26.2 

Indirect 36.9 37.2 28.4 34.1 22.7 

Total 79.4 79.0 68.4 84.1 48.9 

Special aquatic sites No No No No Yes 

Direct impacts to total riparian habitat

(per Pima County mapping) (acres) 686 649 588 633 631 

Area in Sonoran Desert Conservation Plan 

Biological Core (acres) 250.7 217.3 189.4 197.7 1,347.8 

Reduction in average annual stormwater 

flows reporting to Davidson Canyon (%) 45.8 44.3 17.2 42.0 18.4 

Other sensitive resources

Visual resources 

along SR 83

Does not meet 

NAAQS for 

PM10; visual 

resources along 

SR 83

Scholefield Sp

giant sedge; les

long-nosed bat 

does not meet 

for PM10 and 

Practicability

YES – However, 

may be 

technological 

concern regarding 

long-term 

maintenance of 

stormwater 

underdrains. 

YES – Improved 

stormwater 

management 

design

YES – longer 

haulage profile, 

but economically 

viable

YES – longer 

haulage profile 

and significant 

reclamation costs, 

but economically 

viable

NO – significa

increased cost 

proposed actio

Logistically 

impracticable d

need to stack w

rock on slope a

significant hau

distances. Impa

sensitive resou

affected in othe

alternatives. M

options for 

reclamation.
Rosemont Copper Project September 10, 2013

CWA Section 404(b)(1) Alternatives Analysis Page 52

Q:\jobs\1000's\1049.15\404b1\Submittal 9-10-13\Rosemont 404b1 Alternatives Analysis rev 091013.docx WestLand Resources, Inc.

Engineering and Environmental Consultants 

5. REFERENCES

Brown, D. E. (ed.). 1982. “Biotic Communities of the American Southwest–United States and Mexico.” 

Desert Plants (4): 1-4. Boyce-Thompson Arboretum, University of Arizona.

Brown, D. E. and C. H. Lowe. 1980. Biotic Communities of the Southwest (Map). General Technical 

Report RM-78. Rocky Mountain Forest and Range Experimental Station, Forest Service, U.S. 

Department of Agriculture.

JBR Environmental Consultants. 2012. Rosemont Copper Project: AERMOD Modeling Report to Assess 

Ambient Air Quality Impacts. Report prepared for Rosemont Copper Company. December 2012.

Niemuth, N. 2006. Arizona Mining Update – 2005. Publication of the Arizona Department of Mines and 

Mineral Resources. Circular 118. July 2006.

_______. 2011. Minerals and Mining: 2010 Arizona Mining Review. Arizona Geology Magazine website 

(http://azgeology.azgs.az.gov/article/minerals-and-mining/2011/09/2010-arizona-mining-review). 

September 11, 2011. 

Tetra Tech. 2010a. Mine Plan of Operations Stormwater Assessment. Technical Memorandum prepared 

for Rosemont Copper Company, dated March 5, 2010.

_______. 2010b. Barrel and McCleary Alternative Stormwater Assessment. Technical Memorandum 

prepared for Rosemont Copper Company, dated March 5, 2010.

_______. 2010c. Expanded Barrel Only Alternative Stormwater Assessment. Technical Memorandum 

prepared for Rosemont Copper Company, dated September 10, 2010.

_______. 2010d. Scholefield Tailings/Wash Avoidance Alternative Stormwater Assessment. Technical 

Memorandum prepared for Rosemont Copper Company, dated March 31, 2010.

_______. 2012a. Baseline & Post Mine Hydrology and Sediment Delivery at USGS Gage for Barrel 

Alternative. Technical Memorandum prepared for Rosemont Copper Company, dated July 9, 2012. 

_______. 2012b. Rosemont Conceptual Scholefield-McCleary Alternative Stormwater Control Features. 

Technical Memorandum prepared for Rosemont Copper Company, dated January 31, 2012. 

Vector Arizona. 2006. Rosemont Tailings Siting Study. Technical report, May 26, 2006.

WestLand Resources, Inc. 2007. Rosemont Project: Mine Plan of Operations. Report prepared for the 

U.S. Forest Service, Coronado National Forest. July 11, 2007.

_______. 2010. Onsite Riparian Habitat Assessment, Rosemont Project. Report prepared for the U.S. 

Forest Service, Coronado National Forest. April 2010.
 

 

 




















APPENDIX A

ROSEMONT 

LETTERS

REGARDING 

NEARBY

DEPOSITS
 
- 1 -

DENVER OFFICE

4500 Cherry Creek South Drive, Suite 1040

Denver, CO 80246

TEL: (303) 300 0134

FAX: (303) 300 0135

WEB: www.augustaresource.com

Mr. Brian Lindenlaub August 30, 2010

Westland Resources, Inc.

4001 East Paradise Falls Drive

Tucson, AZ 85712

RE: U.S. Army Corp of Engineers – Rosemont Project Alternative 6 – General Deposit 

Evaluation – Report 1/5

Mr. Lindenlaub

I am sending you the following discussion regarding the U.S. Army Corp Of Engineers Alternative 6 

for the Rosemont Project, Pima County, Arizona. This is a follow up on information provided 

previously starting in September 2009. The discussion addresses the vastly higher economic 

potential and more advanced state of evaluation of the Rosemont Deposit, compared with other 

known deposits on the Rosemont Property, along with technical and financial reporting 

requirements that must be adhered to in presenting any public information on these deposits.

General Mining Project Evaluation & Financial Reporting

Introduction

A mining project begins with the exploration of a geologically favorable region. As the results of 

more and more exploration and evaluation become available for the region certain areas are 

targeted as being more favorable. Increasingly detailed work will show what the relative potential 

of each targeted area is, and typically identify the highest potential target area. Exploration is then 

focused on the best potential area. When sufficient geologic data has been collected, mine 

engineering is conducted, culminating in a comprehensive economic feasibility study. A positive 

conclusion from the feasibility study will justify the investment of significant capital used to 

construct the mine facilities and bring the operation into production. Even before the construction 

capital is committed, however, significant expenditures have been incurred on the exploration and 

engineering efforts. 

During this exploration and engineering process, exploration information is advanced to define 

geologic Mineral Resources, which in turn are categorized as economic Mineral Reserves with the 

implementation of the mine engineering and cost considerations, all of which are conducted as part 

of the process of the economic feasibility evaluation. Within a feasibility study, the identification 

and reporting of Mineral Resources and Mineral Reserves is rigorously regulated by various 

security exchange commissions. All work is prepared under the supervision of a “Qualified Person” 

or “Competent Person.” A Qualified Person is officially defined as: “ An individual who is an 

engineer or geoscientist with at least five years of experience in mineral exploration, mine 

development or operation or mineral project assessment, or any combination of these; has experience 
- 2 -

relevant to the subject matter of the mineral project and technical report; and is a member or licensee 

in good standing of a professional organization.” The Qualified Person takes the professional and 

legal responsibility for any publically released project information prepared under their 

supervision.

Financial & Technical Reporting

Any publically traded company has a fiduciary duty to make the best investment decisions for the 

benefit of the stockholders of the company, including any decisions regarding project development, 

while concurrently considering other possible uses of capital funding. Corporate financial 

reporting, including economic feasibility studies, must meet the regulatory and reporting 

requirements of the security commissions in the jurisdiction(s) in which the company reports. 

United States based companies must meet the requirements of the United States Securities And 

Exchange Commission (SEC). If is not unusual for mining companies to have a financial presence in 

more than one country (i.e. Canada, United Kingdom, etc.) which then requires reporting in 

compliance with each of these jurisdictions. A summary of the application of the requirements for 

Mineral Resource and Mineral Reserve reporting is summarized in an independent Pincock 

Perspective bulletin (International Mining Consultants) dated November 2003 (Attachment A).

REPORTING REQUIREMENTS IN THE UNITED STATES

The United States Stock Exchange Commission (SEC) regulates the reporting of Resources and 

Reserves for mineral companies with United States stock exchange listings. The SEC has issued 

Industry Guide 7: Description of Property by Issuers Engaged or to be Engaged in Significant Mining 

Operations (Attachment B) for guidance. In practice, mining companies often also make use of the 

Mineral Resource and Mineral Reserve reporting guideline developed by the United States 

professional group Society of Mining, Metallurgy and Exploration (SME). The SME has developed A 

Guide For Reporting Exploration Information, Mineral Resources, And Mineral Reserves (“SME 

Reporting Guide”) dated 2007 (Attachment C). Industry Guide 7 is generally consistent with the 

SME Reporting Guide, with some differences, including no requirement for a qualified person and 

requiring the term “mineralized material,” rather than mineral resources. SEC practice is that 

mineralized material may only include measured and indicated categories and may not include 

inferred category material, as they consider it too speculative. Also, SEC practice is to have reserves 

defined by a feasibility study for undeveloped properties, with necessary permits reasonably 

pending or having been issued. A mine plan or prefeasiblity study is acceptable for additions to 

operating mines. The SME Reporting Code requires that Mineral Reserves be based on appropriate 

assessments, which may include feasibility studies, carried out to demonstrate that the reserves are 

economically viable. Reserves are to be based on prices at the time of the determination, but can 

consist of a three year historic average to minimize price volatility. 

REPORTING REQUIREMENTS IN CANADA

Canada is a common location for mining companies to have either primary or secondary 

registration. In Canada, the Canadian Securities Administrators (CSA) regulates the reporting of 

resources/reserves for mineral companies with Canadian stock exchange listings. The CSA has 

issued National Instrument 43-101 (NI 43-101), a rule that governs how stock issuers disclose 

technical information about mineral projects, which originally became effective on February 1, 
- 3 -

2001, with the latest update effective on December 30, 2005 (Attachment D). The rule incorporates 

the Mineral Resource and Mineral Reserve reporting guidelines developed by the Canadian 

Institute Of Mining, Metallurgy and Petroleum (CIM) entitled CIM Standards On Mineral Resources 

And Reserves (“CIM Standards”), the latest version dated December 11, 2005. The CIM Standards 

are very similar to those of the SME Reporting Code, as they were developed in collaboration with 

common professional groups. The rule requires that all disclosure be based on work by a “Qualified 

Person” (QP) and requires stock issuers to file Technical Reports for which there is a prescribed 

format. Mineral exploration conducted to delineate a deposit is to follow the Mineral Exploration 

Best Practices guidelines published in June 2000 (Attachment E). Mineral Resource estimation is to 

follow the Estimation of Mineral Resources and Mineral Reserves Best Practices guidelines, dated 

November 23, 2003 (Attachment F).

The CIM Standards do not allow for inferred Mineral Resources to be added with either measured 

and/or indicated resources for presenting a total mineral resource estimate. An issuer should not 

disclose the results of an economic evaluation that used inferred Mineral Resources; however, a 

preliminary assessment or scoping study at an early stage of a project can use inferred Mineral 

Resources in an economic evaluation as long as it is clearly stated as such. The CIM Standards 

requires that reserves be based on at least a Preliminary Feasibility Study or Prefeasibility Study, 

demonstrating that, at the time of reporting, economic extraction can be justified.

Project Advancement 

Exploration and evaluation conducted by a company is the process used to identify projects that 

have the best economic potential for development. A project identified as having economic 

potential for advancement is then advanced consistent with industry standard practices. This 

project advancement can be grouped into general stages including deposit exploration drilling, 

project economic feasibility, and project development. During each stage, financial and technical 

work must be conducted and can only be reported consistent with regulatory requirements.

The first stage of a mineral exploration project is to conduct evaluations of the geologic character 

and mineral distribution sufficient to allow for the identification of a mineral deposit for which an 

initial mineral resource estimate can be conducted. Mineral resources have been officially been 

defined as: “A concentration or occurrence of diamonds, natural solid inorganic material, or natural 

solid fossilized organic material including base and precious metals, coal, and industrial minerals in or 

on the Earth’s crust in such form and quantity and of such a grade or quality that it has reasonable 

prospects for economic extraction. The location, quantity, grade, geological characteristics and 

continuity of a Mineral Resource are known, estimated or interpreted from specific geological evidence 

and knowledge.” Mineral Resources are sub-divided, in order of increasing geological confidence, 

into inferred, indicated, and measured categories.

Stage 1: Deposit Exploration Drilling

The next major stage of a mineral exploration project is to incorporate mine, metallurgical, and 

environmental engineering to determine what part of the mineral resource is economically 

extractable, which then allows for an estimate of the Mineral Reserve (mineable part of the Mineral 

Resource). Mineral Reserves have been officially defined as: “The economically mineable part of a 

Stage 2: Project Economic Feasibility
- 4 -

Measured or Indicated Mineral Resource demonstrated by at least a Preliminary Feasibility Study. 

This Study must include adequate information on mining, processing, metallurgical, economic and

other relevant factors that demonstrate, at the time of reporting, that economic extraction can be 

justified. A Mineral Reserve includes diluting materials and allowances for losses that may occur when 

the material is mined.” Mineral Reserves are sub-divided, in order of increasing economic 

confidence, into proven and probable categories. Material that cannot be considered as part of the 

economic Mineral Reserves must remain as Mineral Resource for reporting purposes.

Once the economic feasibility study has demonstrated the mineral project to be economically 

viable, the next step includes detailed engineering, environmental impact analysis, and 

procurement of project financing. The geological Mineral Resource and economic Mineral Reserve 

are largely fixed at this point but may be updated if additional project information becomes 

available. In such circumstances, the additional information is usually incorporated into an 

economic feasibility study update. 

Stage 3: Project Development

With Regards,

Mark G. Stevens, Professional Geologist

V.P. Exploration
- 1 -

DENVER OFFICE

4500 Cherry Creek South Drive, Suite 1040

Denver, CO 80246

TEL: (303) 300 0134

FAX: (303) 300 0135

WEB: www.augustaresource.com

Mr. Brian Lindenlaub August 30, 2010

Westland Resources, Inc.

4001 East Paradise Falls Drive

Tucson, AZ 85712

RE: U.S. Army Corp of Engineers – Rosemont Project Alternative 6 – Rosemont Deposit 

Evaluation – Report 2/5

Mr. Lindenlaub

I am sending you the following discussion regarding the U.S. Army Corp Of Engineers Alternative 6 

for the Rosemont Project, Pima County, Arizona. This is a follow up on information provided 

previously starting in September 2009. The discussion addresses the vastly higher economic 

potential and more advanced state of evaluation of the Rosemont Deposit, compared with other 

known deposits on the Rosemont Property, along with technical and financial reporting 

requirements that must be adhered to in presenting any public information on these deposits.

Rosemont Copper Project Evaluation

Introduction

The Rosemont Copper Project is the cumulative result of more than 50 years of exploration drilling 

and mine engineering evaluations by several successive mining companies, at a total cost estimated 

to be on the order of $150 million dollars (Rosemont Copper Company does not have the 

accounting records of previous mining companies and these costs can only be estimated). 

Rosemont Copper Company envisions that the Rosemont Project will consist of the mining of the 

Rosemont Deposit in order to extract copper, as well as molybdenum and silver. The Rosemont 

Deposit was identified through extensive mineral exploration carried out on the Rosemont 

Property. Exploration conducted on the property during the period from the 1950s to the 1970s 

initially consisted of work conducted on a more regional property basis, but then progressed to a 

number of more specific deposit areas, as favorable results were obtained in these areas. Deposit 

areas that became more of a focus included Rosemont, Broadtop Butte, Copper World, and PeachElgin; each of which had various degrees of previous mining activity dating back as far as the late 

1800s.

By about the middle 1970s, the cumulative results of the mineral evaluations from across the 

Rosemont property had identified the Rosemont mineral deposit as the site with the best economic 

potential for being developed into an economic mine, and hence Rosemont became the focus of 

subsequent work. The recognition of the potentially larger deposit size and better economic return 

from the Rosemont deposit was not only the conclusion of the mining company owners at that 
- 2 -

time, Anamax, but also was the consistent conclusion of subsequent mining company owners 

ASARCO, and then Rosemont Copper Company. The economic potential of the Rosemont site was 

so clearly demonstrated from exploration drilling, that upon entering into a purchase agreement for 

the property in 2005, Rosemont Copper immediately continued the process of advancing the 

Rosemont Deposit, with very little attention given to the other mineralized areas on the property.

Rosemont Copper Company’s work on the Rosemont Deposit requires corporate financial reporting 

of Rosemont Project information, including economic feasibility study results, consistent with the 

regulatory and reporting requirements of the United States Securities And Exchange Commission 

(for United States securities reporting) and the Canadian Securities Administrators (for Canadian 

securities reporting). The Canadian Securities Administrators requirements are generally accepted 

as being more detailed, but adherence must be made to both systems. As a publically traded 

company, Rosemont Copper Company has a fiduciary duty to make the best investment decisions 

for the benefit of the stockholders of the company, including any decisions regarding project 

development, while concurrently considering other possible uses of capital funding. The Rosemont 

Project has advanced over the last several years by Rosemont Copper Company as being the best 

alternative for corporate investment. Implementing this process, Rosemont Copper Company has 

successively invested approximately $115 million in the Rosemont Copper Project, over the last five 

years. This does not include the investment made by previous mining company owners, estimated 

to be on the order of $35 million (in current dollars) for the previous Rosemont Deposit work. 

Rosemont Project Advancement by Rosemont Copper Company

Since its purchase, Rosemont Copper Company has advanced the Rosemont Project in a manner 

consistent with industry practices. From the work conducted previously, Rosemont Copper 

Company recognized that the Rosemont deposit had the best potential for development, as had the 

previous mining company owners. Rosemont Copper Company has since proceeded to advance the 

Rosemont Deposit from exploration through economic feasibility to the current project 

development stage.

Previous mining company owners of the Rosemont property drilled 179 holes, for a total of 209,999 

feet, in the Rosemont deposit. Subsequently, Rosemont Copper Company has conducted three 

progressive drilling campaigns to further explore the Rosemont deposit, totaling 75 drill holes for 

113,876 feet of drilling. This additional drilling was necessary to better delineate geologic lithology 

and structure in the deposit, as well as to more accurately quantify the grade distribution of the 

mineralization to be consistent with industry standard practices. At the time of this initial work in 

2005 and 2006, it was only appropriate to report on Mineral Resources of the Rosemont Deposit. 

The estimation of the Mineral Resources and assessment of the reasonable prospects for economic 

extraction required the judgment of a consulting engineer to serve as the official Qualified Person. 

In early 2007, the positive results from preliminary assessments of the Rosemont Deposit, allowed 

for the corporate decision to proceed to the next stage.

Stage 1: Deposit Exploration Drilling (2005 – 2008)

Rosemont Copper Company completed an economic feasibility study in August 2007. The study 

demonstrated the positive economic viability of the Rosemont Deposit. With the receipt of 

Stage 2: Project Economic Feasibility (2007 – 2009)
- 3 -

subsequent information with regards to the Mineral Resources, Mineral Reserves, metallurgy, and 

capital and operating costs; an Updated Feasibility Study was finalized in January 2009. Again, the 

feasibility update demonstrated the positive economic viability of the Rosemont Deposit. For each 

of these studies, a Mineral Reserve was reported. The current Rosemont Mineral Reserve is 

estimated to include 1) 546 million tons of sulfide ore averaging 0.45% copper, 0.015% 

molybdenum, and 0.12 ounces per ton silver and 2) 70 million tons of oxide ore averaging 0.17% 

copper. Mineral Reserves of this magnitude demonstrate that the Rosemont Deposit is a large 

deposit. . This Mineral Reserve is capable of supporting a 20 plus year mine life, at a production 

rate of 75,000 tons of ore per day. The estimation of the Mineral Reserves and determination of 

economic feasibility for the project required the expertise of a team of company and consulting 

engineers. The lead engineer for each of the technical disciplines involved in the study served as a 

Qualified Person. The positive economic finding of the feasibility studies allowed for the corporate 

decision to advance the project to the next stage.

Rosemont Copper Company is currently in this stage of activity, which includes detailed 

engineering, environmental impact analysis, and procurement of project financing. The geological 

Mineral Resource and economic Mineral Reserve are largely fixed as of the 2009 feasibility study 

update. 

Stage 3: Rosemont Project Development (2009 – Current)

Rosemont’s focus all along has been entirely on the advancement of the Rosemont Deposit and has 

spent little or no time, effort, or cost on other Rosemont property prospect areas; as it was 

recognized from the initial property purchase, that the best economic potential identified to date on 

the property, was in the Rosemont Deposit. As such, Rosemont Copper Company has spent more 

than $115 million dollars in this effort, including $30 million on land purchases, $22 million on 

exploration drilling, $23 million on project engineering, and $22 million on environmental studies. 

This does not acknowledge the cost of exploration drilling by previous mining company owners, 

who likely spent on the order of $35 million on exploration drilling (in current dollars) and geologic 

evaluation, on the Rosemont Deposit area.

With Regards,

Mark G. Stevens, Professional Geologist

V.P. Exploration
- 1 -

DENVER OFFICE

4500 Cherry Creek South Drive, Suite 1040

Denver, CO 80246

TEL: (303) 300 0134

FAX: (303) 300 0135

WEB: www.augustaresource.com

Mr. Brian Lindenlaub August 30, 2010

Westland Resources, Inc.

4001 East Paradise Falls Drive

Tucson, AZ 85712

RE: U.S. Army Corp of Engineers – Rosemont Project Alternative 6–Broadtop Butte Deposit 

Evaluation – Report 3/5

Mr. Lindenlaub

I am sending you the following discussion regarding the U.S. Army Corp Of Engineers Alternative 6 

for the Rosemont Project, Pima County, Arizona. This is a follow up on information provided 

previously starting in September 2009. The discussion addresses the vastly higher economic 

potential and more advanced state of evaluation of the Rosemont Deposit, compared with other 

known deposits on the Rosemont Property, along with technical and financial reporting 

requirements that must be adhered to in presenting any public information on these deposits.

Broadtop Butte Copper Project Evaluation

Introduction

The Broadtop Butte Deposit is one of several mineralized areas that occur on the Rosemont 

Property. During the earlier exploration period from the 1950s to the 1970s, extensive exploration 

of the Rosemont Property, started on a regional basis and then progressed to a number of more 

specific deposits, one of which was Broadtop Butte. By about the middle 1970s, the cumulative 

results of the mineral evaluations from across the Rosemont property had already identified the 

Rosemont Deposit as the site with the best potential for being developed into an economic mine, 

and hence Rosemont became the focus of subsequent work.

Historical Evaluation

The Broadtop Butte Deposit occurs approximately 6,000 feet to the north of the Rosemont Deposit. 

A total of 18 holes have been drilled at Broadtop Butte, for a total of 10,170 feet. Drilling was 

conducted during the 1960s and 1970s on the deposit. Little work has been conducted since that 

time, because of the focus on the better economic potential at the Rosemont Deposit. It is estimated 

that approximately $2 million (in current dollars) had previously been spent on exploration of the 

Broadtop Butte Deposit.

Detailed exploration information on the Broadtop Butte Deposit does not exist. Drilling results 

deposit obtained during the 1960s and 1970s are widely spaced and are only sufficient for the 

preliminary estimation of a Mineral Resource, but not Mineral Reserves, based on current standard 
- 2 -

industry practices and security exchange reporting requirements. Previously in 1979, Anamax 

carried out an estimate that found a Mineral Resource of 8.8 million tons at an average grade of 

0.77% copper and 0.037% molybdenum. It is noted that this estimate must be considered to be 

historical in nature and is not necessarily consistent with current industry practices and securities 

reporting requirements.

Potential Plan

Rosemont Copper Company has spent very little time and effort evaluating the Broadtop Butte 

Deposit, as earlier exploration results indicated this location had less economic potential than the 

Rosemont Deposit. At some point in the future, Rosemont Copper Company intends to conduct 

further work at Broadtop, to better evaluate the mineral potential. This work can only be 

conducted pending the priority for availability funds to cover the costs of the further work. 

Rosemont Copper Company estimates it will take at least $12 million to conduct the necessary 

drilling and engineering to advance the property to a possible economic feasibility stage. This work 

is likely to take 5 years to carry out. As is the nature with any early stage exploration mineral 

project, there can be no guarantees that such a project will eventually be shown to be economic by a 

feasibility study. Rosemont Copper Company believes from the existing information that the 

Broadtop Butte Deposit has potential as a smaller satellite area of production, but not as a possible 

substitute for the planned Rosemont Deposit production. 

It is noted that United States Securities And Exchange Commission and Canadian Security 

Administrator requirements prohibit the public presentation of any Mineral Reserve without the 

requisite geologic study and corresponding engineering studies. Such a representation can be very 

misleading with the results being very speculative. As such, Rosemont Copper Company would be 

at risk to consider generating such an evaluation.

Conclusion

The geologic Mineral Resource currently known in the Broadtop Butte Deposit is only a fraction 

(1.6%) of what the mineable Mineral Reserve is in for the Rosemont Deposit. As such, the Broadtop 

Butte Deposit is not “available” as a substitute for the Rosemont Deposit. In addition, there is 

insufficient engineering to currently qualify the Broadtop Butte mineralization as a Mineral 

Reserve. Until such time as a comprehensive program of exploration drilling, metallurgical testing, 

mine planning, and economic evaluation have been completed in a definitive feasibility study, the 

Broadtop Butte mineralization cannot be considered “capable of being done”. For Rosemont to 

attempt to do so currently would be speculative and prohibited by financial regulation. The 

Broadtop Butte Deposit is neither “available” nor “capable of being done” and cannot be considered 

as “practicable”.

With Regards,

Mark G. Stevens, Professional Geologist

V.P. Exploration
- 1 -

DENVER OFFICE

4500 Cherry Creek South Drive, Suite 1040

Denver, CO 80246

TEL: (303) 300 0134

FAX: (303) 300 0135

WEB: www.augustaresource.com

Mr. Brian Lindenlaub August 30, 2010

Westland Resources, Inc.

4001 East Paradise Falls Drive

Tucson, AZ 85712

RE: U.S. Army Corp Of Engineers – Rosemont Project Alternative 6 – Copper World Deposit 

Evaluation – Report 4/5

Mr. Lindenlaub

I am sending you the following discussion regarding the U.S. Army Corp Of Engineers Alternative 6 

for the Rosemont Project, Pima County, Arizona. This is a follow up on information provided 

previously starting in September 2009. The discussion addresses the vastly higher economic 

potential and more advanced state of evaluation of the Rosemont Deposit, compared with other 

known deposits on the Rosemont Property, along with technical and financial reporting 

requirements that must be adhered to in presenting any public information on these deposits.

Copper World Project Evaluation

Introduction

The Copper World Deposit is one of several mineralized areas that occur on the Rosemont property. 

During the earlier exploration period from the 1950s to the 1970s, extensive exploration of the 

Rosemont Property, started on a regional basis and then progressed to a number of more specific 

deposits, one of which was Copper World. By about the middle 1970s, the cumulative results of the 

mineral evaluations from across the Rosemont property had already identified the Rosemont 

Deposit as the site with the best potential for being developed into an economic mine, and hence 

Rosemont became the focus of subsequent work.

Historical Evaluation

The Copper World Deposit occurs approximately 10,000 feet to the northwest of the Rosemont 

Deposit. Copper World was a significant part of the Helvetia area production during the late 1800s, 

from selective underground high-grade areas. During the 1960s and 1970s, 28 holes were drilled 

at Copper World, for a total of 11,449 feet. Little exploration work has been conducted since that 

time, because of the focus on the better economic potential at the Rosemont Deposit. A reclamation 

action by ASARCO in the 1990s resulted in part of the surface area being graded and contoured 

where historical turn of the century mining took place. It is estimated that approximately $3 

million (in current dollars) had previously been spent on exploration and another 0.5 million on the 

previous reclamation of the Copper World Deposit.
- 2 -

Detailed exploration information on the Copper World Deposit does not exist. Drill holes in the 

deposit obtained during the 1960s and 1970s are widely spaced and are not sufficient for the 

preliminary estimation of a Mineral Resource and certainly not for a Mineral Reserves, based on 

current standard industry practices and security exchange reporting requirements. Drilling results 

are mixed, some encouraging, some not so encouraging, that together would indicate a smaller, 

geologically complex deposit is more likely present in the area.

Potential Plan

Rosemont Copper Company has spent very little time and effort evaluating the Copper World 

Deposit, as earlier exploration results indicated this location had less economic potential than the 

Rosemont Deposit. At some point in the future, Rosemont Copper Company intends to conduct 

further work at Copper World, to better evaluate the mineral potential. This work can only be 

conducted pending the priority for available funds to cover the costs of the further work. Rosemont 

Copper Company estimates it will take at least $7 million to conduct the necessary drilling and 

engineering to advance the property to an a possible economic feasibility stage. This work is likely 

to take 3 to 5 years to carry out. As is the nature with any early stage exploration mineral project, 

there can be no guarantees that such a project will eventually be shown to be economic by a 

feasibility study. Rosemont Copper Company believes from the existing information that the 

Copper World Deposit has potential as a smaller satellite area of production, but not as a possible 

substitute for the planned Rosemont Deposit production. 

It is noted that United States Securities And Exchange Commission and Canadian Security 

Administrator requirements prohibit the public presentation of any mineral reserve without the 

requisite geologic study and corresponding engineering studies. Such a representation can be very 

misleading with the results being very speculative. As such, Rosemont Copper Company would be 

at risk to consider generating such an evaluation.

Conclusion

The Copper World Deposit contains mineralization that was mined by a historical small-scale, highgrade mine. Little is known of the remaining mineralization, other than variable results from a few 

widely scattered drill holes. There is not enough information for Rosemont Copper Company or 

predecessor companies to have estimated a Mineral Resource. It is most likely that a small deposit 

of low-grade mineralization may remain at Copper World that is only a fraction of what the 

mineable Mineral Reserve is in for the Rosemont Deposit. As such, the Copper World Deposit is not 

“available” as a substitute for the Rosemont Deposit . Since there is no current geologic Mineral 

Resource, there is no mineable Mineral Reserve, as no engineering has been conducted. Until such 

time as a comprehensive program of exploration drilling, metallurgical testing, mine planning, and 

economic evaluation have been completed in a definitive feasibility study, the Copper World

mineralization cannot be considered “capable of being done”. For Rosemont to attempt to do so 

currently would be speculative and prohibited by financial regulation. The Copper World Deposit is 

neither “available” nor “capable of being done” and cannot be considered as “practicable”.

With Regards,

Mark G. Stevens, Professional Geologist

V.P. Exploration
- 1 -

DENVER OFFICE

4500 Cherry Creek South Drive, Suite 1040

Denver, CO 80246

TEL: (303) 300 0134

FAX: (303) 300 0135

WEB: www.augustaresource.com

Mr. Brian Lindenlaub August 30, 2010

Westland Resources, Inc.

4001 East Paradise Falls Drive

Tucson, AZ 85712

RE: U.S. Army Corp of Engineers – Rosemont Project Alternative 6 – Peach-Elgin Deposit 

Evaluation – Report 5/5

Mr. Lindenlaub

I am sending you the following discussion regarding the U.S. Army Corp Of Engineers Alternative 6 

for the Rosemont Project, Pima County, Arizona. This is a follow up on information provided 

previously starting in September 2009. The discussion addresses the vastly higher economic 

potential and more advanced state of evaluation of the Rosemont Deposit, compared with other 

known deposits on the Rosemont Property, along with technical and financial reporting 

requirements that must be adhered to in presenting any public information on these deposits.

Peach-Elgin Project Evaluation

Introduction

The Peach-Elgin Deposit is one of several mineralized areas that occur on the Rosemont property. 

During the earlier exploration period from the 1950s to the 1970s, extensive exploration of the 

Rosemont Property, started on a regional basis and then progressed to a number of more specific 

deposits, one of which was Peach-Elgin. By about the middle 1970s, the cumulative results of the 

mineral evaluations from across the Rosemont property had already identified the Rosemont 

Deposit as the site with the best potential for being developed into an economic mine, and hence 

Rosemont became the focus of subsequent work. 

Historical Evaluation

The Peach-Elgin Deposit occurs approximately 15,000 feet to the northwest of the Rosemont 

Deposit. Peach-Elgin was a significant part of the Helvetia area production during the late 1800s, 

from selective underground high-grade areas; with some surface production in the middle 1900s. 

During the 1960s and 1970s, 21 holes were drilled at Peach-Elgin, for a total of 8,600 feet. Little 

exploration work has been conducted since that time, because of the focus on the better economic 

potential at the Rosemont Deposit. It is estimated that approximately $2.0 million (in current 

dollars) had previously been spent on the drilling and evaluation of these 21 holes at the PeachElgin Deposit.

Detailed exploration information on the Copper World Deposit does not exist. Drilling results from 

the deposit obtained during the 1960s and 1970s are widely spaced are only sufficient for the 
- 2 -

preliminary estimation of Mineral Resource, but not Mineral Reserves, based on current standard 

industry reporting requirements. Previously in 1964, Anaconda carried out an estimate that found 

a Mineral Resource of 13.7 million tons of sulfide mineralization at an average grade of 0.78% 

copper and 0.037% molybdenum, along with 9.7 million tons of oxide mineralization averaging 

0.72% copper. It is noted that this estimate must be considered to be historical in nature and is not 

necessarily consistent with current industry practices and securities reporting requirements. In 

producing this estimate, Anaconda drilled a number of additional holes in the 1960s, the records for 

which were permanently lost before Rosemont Copper Company obtained the property and 

property information. 

Rosemont Copper Company has spent very little time and effort evaluating the Peach-Elgin Deposit, 

as earlier exploration results indicated this location had less economic potential than the Rosemont 

Deposit. At some point in the future, Rosemont Copper Company intends to conduct further work 

at Peach-Elgin, to better evaluate the mineral potential. This work can only be conducted pending 

the priority for available funds to cover the costs of the further work. Rosemont Copper Company 

estimates it will take at least $10 million to conduct the necessary drilling and engineering to 

advance the property to an a possible economic feasibility stage. This work is likely to take 5 years 

to carry out. As is the nature with any early stage exploration mineral project, there can be no 

guarantees that such a project will eventually be shown to be economic by a feasibility study. 

Rosemont Copper Company has no evidence that the Peach-Elgin Deposit would be a possible 

substitute for the planned Rosemont Deposit production. 

It is noted that United States Securities And Exchange Commission and Canadian Security 

Administrator requirements prohibit the public presentation of any mineral reserve without the 

requisite geologic study and corresponding engineering studies. Such a representation can be very 

misleading with the results being very speculative. As such, Rosemont Copper Company would be 

at risk to consider generating such an evaluation.

Conclusion

The geologic Mineral Resource currently known in the Peach-Elgin Deposit is only a fraction (4.3%) 

of what the mineable Mineral Reserve is in for the Rosemont Deposit. As such, the Broadtop Butte 

Deposit is not “available” as a substitute for the Rosemont Deposit. In addition, there is insufficient 

engineering to currently qualify the Broadtop Butte mineralization as a Mineral Reserve. Until such 

time as a comprehensive program of exploration drilling, metallurgical testing, mine planning, and 

economic evaluation have been completed in a definitive feasibility study, the Broadtop Butte 

mineralization cannot be considered “capable of being done”. For Rosemont to attempt to do so 

currently would be speculative and prohibited by financial regulation. The Broadtop Butte Deposit 

is neither “available” or “capable of being done” and cannot be considered as “practicable”.

With Regards,

Mark G. Stevens, Professional Geologist

V.P. Exploration
 
APPENDIX B 

PIT BACKFILL 

RESPONSE 
 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

ROSEMONT COPPER PROJECT
 

AN ANALYSIS OF THE FOREST SERVICE’S AUTHORITY TO
 

REQUIRE PIT BACKFILLING AS POST-MINING RECLAMATION
 

Prepared by Fennemore Craig, P.C. 

February 20, 2012 

I. Introduction 

Rosemont Copper Company (Rosemont) is developing a copper mine along the 

eastern slope of the Santa Rita Mountains, within the historic Helvetia-Rosemont Mining 

District in Pima County, Arizona. The proposed mine and related facilities (the Project) 

will be located on a mixture of private and National Forest System land, and a small 

amount of state land. 

The Project involves the development of an open pit mine with ore processing 

facilities consisting of both milling and copper leaching. Conventional heap leach 

technology will be used at the site along with a “dry stack” tailings storage method 

associated with the milling process. Details of the mine operation are provided in the 

Rosemont Project Mine Plan of Operations (July 2007). The anticipated life of the mine 

is 20 years, following which the areas disturbed by mining activities will be reclaimed. A 

copy of a map depicting the configuration of the Project after 20 years is attached hereto. 

At its rim, the ultimate open pit will be about 6,500 feet across north to south, 

about 6,000 feet across east to west, and will be between 1,800 to 2,900 feet deep. The 

total land surface of the pit (at pre-mine elevation) is about 700 acres. Approximately 80 

percent of the pit is located within Rosemont’s private land, which consists of patented 

lode mining claims with extralateral mineral rights. The remainder of the pit is on 

National Forest System land, on which Rosemont holds unpatented lode mining claims. 

Notably, the central portion of the pit is within Rosemont’s private land, while National 

Forest System land is located primarily along the southern and southeastern pit edges. 

In connection with the Mine Plan of Operations, Rosemont prepared and 

submitted a post-mining reclamation plan to the Forest Service. In addition, Rosemont 

submitted a Mined Land Reclamation Plan to the Division of Mined Land Reclamation in 

the Office of the State Mine Inspector (Mine Inspector) in accordance with Arizona law. 

The Mine Inspector approved the Mined Land Reclamation Plan in 2009. The Forest 

Service’s Draft Environmental Impact Statement for the Project identifies the Mined 

Land Reclamation Plan as one of the major permits required for operation.1 

1 USDA Forest Service, Draft Environmental Impact Statement for the Rosemont Copper Project 

41 (Sept. 2011). The Forest Service explained that the Mined Land Reclamation Plan “[a]pplies 

to reclamation activities at the site” and “[r]equires certification, plan updates, annual reporting, 

and financial assurance.” Id. 

1
 
 

 

 

 

 

 

 

 

 

 

Under Rosemont’s Mined Land Reclamation Plan, the open pit will not be 

backfilled. The pit instead will be secured by a perimeter fence and interior earthen 

berm, which also provides visual mitigation. Groundwater flow modeling completed by 

Montgomery & Associates in 2009 indicates that the open pit will create a hydraulic sink 

and that a pit lake will develop over several decades. This condition is viewed as 

beneficial because it ensures long-term containment of pit water and protection of local 

and regional groundwater aquifers in accordance with Arizona’s aquifer protection 

2

program.

Nevertheless, certain commenters (e.g., Pima County) contend that the Forest 

Service should require, as part of Rosemont’s plan of operations, that the open pit be 

backfilled with waste rock removed from the pit and tailings produced by the 

concentration of ore. Although pit backfilling is rarely required in circumstances 

analogous to this Project due to various technical, economic and environmental 

constraints, apparently backfilling is being seriously considered by the agency. 

As explained below, however, the Forest Service lacks authority to override 

Arizona law and regulate the manner in which Rosemont’s private land is reclaimed. The 

Forest Service’s authority is limited to reasonable regulation of mining activities 

occurring on National Forest System land. The agency has no jurisdiction over private 

land uses. Instead, that authority rests with the Mine Inspector and is governed by 

Arizona law. Consequently, the imposition of a backfilling requirement as a condition in 

Rosemont’s plan of operations would be unlawful. 

Even if such authority existed, the imposition of such a requirement would violate 

the Takings Clause of the Fifth Amendment, which provides that private property shall 

not be taken for public use without just compensation. It is well established that “where 

the government requires an owner to suffer a permanent physical invasion of his property 

– however minor – it must provide just compensation.”3 Here, Rosemont would be 

compelled to use its private property to store waste rock and tailings, directly interfering 

with future mineral development and related uses of the property. This is functionally 

equivalent to the classic taking in which the government directly appropriates private 

property for its own use, and would violate the Constitution. 

For these reasons, pit backfilling is not a viable option. Frankly, we are perplexed 

by the Forest Service’s consideration of pit backfilling given the Forest Service’s limited 

authority and the takings implications of such a requirement. 

II. Applicable Statutes and Regulations 

A. Private and State Land 

Arizona’s Mined Land Reclamation Act, A.R.S. § 27-901 et seq., was enacted in 

1994 and provides a comprehensive program governing the reclamation of private and 

2

 A.R.S. § 49-241- § 49-252. 

3 Lingle v. Chevron U.S.A. Inc., 544 U.S. 528, 538 (2005).
 

2
 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

state land disturbed by mining activities. Under the Act, owners and operators of mining 

units undertaking activities causing a surface disturbance greater than five contiguous 

acres must obtain approval of a reclamation plan and financial assurance mechanism by 

the Mine Inspector.4 Reclamation plans are subject to public notice and comment; any 

person who may be adversely affected by the plan may submit a written objection.

5 A 

public hearing may be held if there is sufficient public interest.6 An applicant is also 

required to submit a financial assurance mechanism within 60 days from plan approval, 

which is also subject to review and approval.7 

In evaluating the sufficiency of a reclamation plan, the Mine Inspector is required 

to consider the “technical and economic practicability of the proposed reclamation 

measures, taking into account the site-specific circumstances at the mine unit and the 

proposed post-mining land use objectives.”8 Notably, backfilling or returning material to 

an open pit is not required where backfilling is “impracticable” and provided that public 

access to the pit is restricted by fencing or other institutional controls.9 In determining 

impracticability, A.R.S. § 27-975(B) requires the Mine Inspector to consider the 

following six factors: 

1. The cost to perform the reclamation; 

2. The topography of the site; 

3. The geology and stability of the site; 

4. The time required to perform the reclamation; 

5. The consumption of resources required to perform the reclamation; and 

6. The impact on future access to mineral resources. 

In circumstances where mine activity occurs on private and adjacent public lands, 

the statutes contemplate coordination between the Mine Inspector and the federal land 

management agency in order to avoid duplication of efforts in inspection and 

enforcement.10 Any reclamation plan or financial assurance mechanism approved by a 

federal land management agency must be “consistent with the requirements of state law” 

and may only supersede a state reclamation plan if a request for such action is expressly 

4 See A.R.S. § 27-921. 

5

 A.R.S. § 27-929. 

6

 A.R.S. § 27-929(D). 

7

 A.R.S. § 27-992; see also A.A.C. R11-2-801- R11-2-822.
 8

 A.R.S. § 27-973(B). 

9

 A.R.S. § 27-975(A). 

10 A.R.S. § 27-932(A).
 

3
 
 

 

 

 

 

 

 

 

 

 

 

 

made by the owner/operator of the project and upon subsequent approval of the Mine 

Inspector.11 

B. National Forest System Land 

The Mining Law of 1872 (Mining Law), codified at 30 U.S.C. §§ 21-42, declares 

that “all valuable mineral deposits in lands belonging to the United States,” as well as 

“the lands in which they are found,” are “free and open” to exploration, occupation and 

purchase. 12 The Mining Law also allows citizens to locate and patent lode and placer 

mining claims and to locate and patent non-mineral lands for mill sites.13 It created a 

system that is self-initiated, i.e., no federal permit or approval is necessary to locate a 

mining claim.14 

Under the Mining Law, a mining claim locator has the right to occupy the claim 

for the exploration and development of minerals, and for uses reasonably related thereto. 

For example, in Shumway, which involved a dispute with the Forest Service over the 

occupancy of unpatented mill site claims, the Ninth Circuit held that the Shumways “had 

a possessory right to their mill sites” and “were not only permitted, but until their right to 

a patent vested, required to use and occupy the mill sites for milling purposes, and were 

entitled to have a residence, equipment, materials, tools, and other property on the site 

incident to milling operations.”15 

The Organic Act of 1897 granted the Forest Service authority to promulgate 

regulations for the protection of National Forests.16 The Act also imposed limits on that 

authority with respect to mining-related activities, requiring that no regulation may 

“prohibit any person from entering upon the national forests for all proper and lawful 

purposes, including that of prospecting, locating and developing the mineral resources 

thereof.”17 Thus, the Forest Service may “adopt reasonable rules and regulations which 

11 A.R.S. § 27-932(B); see also A.A.C. R11-2-204.
 12 30 U.S.C. § 22; see also United States v. Shumway, 199 F.3d 1093, 1098 (9th Cir. 1999). 

13 30 U.S.C. §§ 23, 26, 29, 35, 36, 42. 

14 See, e.g., Union Oil Co. v. Smith, 249 U.S. 337, 346 (1919); Davis v. Nelson, 329 F.2d 840, 845
 

(9th Cir. 1964).
 15 Shumway, 199 F.3d at 1103; see also id. at 1105 (“The owner of a mining or mill site claim
 

does not need a patent, or a vested right to issuance of a patent, to possess and use the property
 

for legitimate mining or milling purposes.”); United States v. Richardson, 599 F.2d 290, 292-93 

(9th Cir. 1979) (The Mining Law “granted a locator broad possessory rights,” which have been
 

“consistently recognized so long as the uses were incident to prospecting and mining.”)
 16 16 U.S.C. § 551; see also Shumway, 199 F.3d at 1106. 

17 16 U.S.C. § 478; see also Siskiyou Regional Educ. Project v. U.S. Forest Serv., 565 F.3d 545, 

558 (9th Cir. 2009); Okanogan Highlands All. v. Williams, 236 F.3d 468, 477-78 (9th Cir. 2000); 

Shumway, 199 F.3d at 1106. 

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do not impermissibly encroach upon the right to the use and enjoyment of [mining] 

claims for mining purposes.”18 

Pursuant to this authority, the Forest Service has adopted regulations, currently 

codified at 36 C.F.R. subpart 228, setting forth “the rules and procedures for the use of 

the surface of National Forest System lands in connection with operations authorized by 

the [Mining Law].”19 These regulations require that miners obtain approval of a plan of 

operations prior to conducting any activities that “might cause significant disturbance of 

surface resources.”20 

A plan of operations describes the type of operations proposed and the manner in 

which they will be conducted.21 Mining operations must be conducted, “where feasible,” 

in a manner that “minimize[s] adverse environmental impacts on National Forest surface 

resources.”22 This regulation sets forth various requirements that must be satisfied for 

environmental protection, including reclamation.23 The plan of operations must describe 

the measures that will be taken to meet these requirements. In approving the plan of 

operations, the Forest Service must “analyze the proposal, considering the economics of 

the operation along with the other factors in determining the reasonableness of the 

requirements for surface resource protection.”24 

With respect to reclamation, the Forest Service’s regulations state that “[u]pon 

exhaustion of the mineral deposit or at the earliest time during operations,” the operator 

shall, “where practicable, reclaim the surface disturbed in operations.”25 Among other 

things, the operator must take measures to “prevent or control onsite and off-site damage 

to the environment and forest surface resources” including the “reshaping and 

revegetation of disturbed areas, where reasonably practicable.”26 The basic goal, 

according to the Forest Service Manual, is to achieve a safe and ecologically stable 

condition and land use consistent with long-term forest land and resource management 

plans and local environmental conditions, including applicable “State air and water 

18 United States v. Weiss, 642 F.2d 296, 299 (9th Cir. 1981); see also Shumway, 199 F.3d at 1107 

(Under Weiss, “the Forest Service may regulate use of National Forest lands by holders of 

unpatented mining claims ... but only to the extent that the regulations are ‘reasonable’ and do not 

impermissibly encroach on legitimate uses incident to mining and mill site claims.”); Okanogan 

Highlands, 236 F.3d at 478 (quoting and following Shumway and Weiss in rejecting challenge to 

Forest Service’s approval of plan of operations for gold mine). 

19 36 C.F.R. § 228.1. 

20 Id. at § 228.4. 

21 Id. 

22 Id. at § 228.8 (emphasis added).
 23 Id. These requirements also include compliance with applicable air quality, water quality, and
 

solid waste standards, as well minimizing impacts to scenic values, fish and wildlife habitat, and
 

roads, again “to the extent practicable.”
 24 Id. at § 228.5(a).
 25 Id. at 228.8(g) (emphasis added).
 26 Id. at 228.8(g)(4) (emphasis added).
 

5
 
 

 

 

 

 

 

 

 

 

 

 

 

quality requirements.” 27 When required, an operator must furnish a bond or other 

financial assurance with to ensure compliance with his reclamation plan.28 

Consistent with Arizona’s Mined Land Reclamation Act, the Forest Service’s 

regulations and manual contain provisions for cooperation in circumstances where there 

are multiple agencies with jurisdiction over mining operations. The Forest Service’s 

policy is to utilize cooperative agreements to eliminate duplicative bonding and 

conflicting reclamation requirements.29 Furthermore, the agency’s regulations provide 

that “certification or other approval issued by State agencies or other Federal agencies of 

compliance with laws and regulations related to mining operations will be accepted as 

compliance with similar or parallel requirements of these regulations.”30 

III. Analysis 

As stated in the Introduction, approximately 80 percent of the open pit is located 

on Rosemont’s private land where the primary ore body is located, including the central 

portion of the pit area. National Forest System land is located primarily along the 

southern and southeastern edges of the pit. The National Forest Land inside the pit 

cannot be backfilled without first requiring Rosemont to backfill its private property. 

Stated another way, if the pit is backfilled, no National Forest System land would be 

included in the area backfilled until the entire pit is nearly full. Furthermore, in the case 

of partial backfilling, no National Forest System land associated with the pit would 

actually be covered – only Rosemont’s private land, including any undeveloped mineral 

resources. 

Under these circumstances, the Forest Service lacks legal authority to require 

Rosemont to backfill the pit, and, moreover, such a requirement would violate the 

Takings Clause of the Fifth Amendment. 

First, the Forest Service cannot override Arizona law and impose its own 

reclamation standards and requirements on mining activities occurring on private land. 

As stated, Arizona has enacted a comprehensive statute, the Mined Land Reclamation 

Act, which governs the reclamation of private and state land disturbed by mining.31 That 

statute governs the reclamation of Rosemont’s private land, including the patented 

mining claims that contain the bulk of the ore body and, consequently, the primary area 

that will be mined. Under Arizona law, backfilling is not required where it is 

impracticable, which is determined on the basis of six specific factors.

32 

27 FSM 2840.3. 

28 36 C.F.R. § 228.13. 

29 FSM 2846. 

30 36 C.F.R. § 228.8(h). 

31 A.R.S. § 27-901 et seq. 32 A.R.S. § 27-975(B). 

6
 
 

 

 

 

 

 

 

 

 

 

The Mine Inspector approved Rosemont’s Mined Land Reclamation Plan for the 

Project in 2009. That plan governs and controls Rosemont’s reclamation of its private 

land. Backfilling of the open pit is not required under this plan. The elements of the plan 

cannot be superseded unless Rosemont requests that such action be taken and it is 

approved by the Mine Inspector.33 And as previously explained, the Forest Service’s 

surface use regulations state that the state reclamation plan will be accepted as 

compliance with any reclamation requirements developed for adjoining National Forest 

System land.34 Having adopted this regulation, the Forest Service must comply with it.35 

Second, the Forest Service has not been delegated authority to regulate mining or, 

for that matter, any other land use activity occurring on private land. As explained, the 

Organic Act grants the Forest Service authority to regulate the occupancy and use of the 

National Forests, subject to the rights of miners to occupy and use National Forest 

System land for mining-related purposes.36 The agency’s regulations likewise apply to 

the “use of the National Forest System lands” under the Mining Laws.37 They provide no 

basis to regulate the use of private land. Consequently, if the Forest Service imposed 

backfilling as a reclamation requirement – regardless of whether full or partial backfilling 

is required – the agency would be ignoring its limited authority under the Organic Act 

and asserting jurisdiction over the manner in which private land is used, creating a square 

conflict with Arizona law (and its own regulations) in the process. 

Finally, requiring Rosemont to backfill all or a portion of the pit would violate the 

Takings Clause of the Fifth Amendment by forcing Rosemont to suffer a permanent 

physical invasion of its private property without compensation. Although the classic 

taking involves the transfer of property to the government by eminent domain, the 

Takings Clause applies to other government actions that effectively achieve the same 

result.

38 Thus, government actions that are functionally equivalent to the classic taking 

are subject to the Takings Clause.39 

The Supreme Court has long held that it is a taking when government regulation 

forces a property owner to submit to a physical invasion or occupation of his property.

40 

33 A.R.S. § 27-932(B); A.A.C. R11-2-204(A).
 34 36 C.F.R. § 228.8(h).
 35 See, e.g., Nat’l Ass’n of Home Builders v. Norton, 340 F.3d 835, 852 (9th Cir. 2003) (holding
 

that the Fish and Wildlife Service must follow its policy establishing the criteria for distinct 

population segments in determining whether the Arizona pygmy-owl population is eligible to be 

listed under the Endangered Species Act). 

36 See, e.g., Okanogan Highlands, 236 F.3d at 478; Shumway, 199 F.3d at 1107; Weiss, 642 F.2d 

at 299. 

37 36 C.F.R. § 228.1.
 38 See, e.g., Stop The Beach Renourishment, Inc. v. Fla. Dep’t of Envt’l Protection, __ U.S. __, 

130 S.Ct. 2592, 2610 (2010) (summarizing Supreme Court takings jurisprudence).
 39 Id. 

40 See, e.g., Lingle, 544 U.S. at 538 (“[W]here government requires an owner to suffer a 

permanent physical invasion of her property – however minor – it must provide just 

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Thus, in Loretto v. Teleprompter Manhattan CATV Corp., for example, the Court held 

that a law requiring landlords to permit cable companies to install cable facilities in 

apartment buildings effected a taking of the landlords’ property, without regard to 

whether the action achieves an important public benefit.41 The Court explained that 

“[p]roperty rights in a physical thing have been described as the rights to possess, use and 

dispose of it. ... To the extent that the government permanently occupies physical 

property, it effectively destroys each of these rights.”42 

Similarly, in Kaiser Aetna v. United States, the Court held that the government's 

assertion of a navigational servitude under the Commerce Clause, which allowed public 

access to an improved pond, was a taking. 43 The Court emphasized that the servitude 

took the landowner’s right to exclude others, “one of the most essential sticks in the 

bundle of rights that are commonly characterized as property.”44 The Court also 

explained: 

This is not a case in which the Government is exercising its 

regulatory power in a manner that will cause an 

insubstantial devaluation of petitioner's private property; 

rather, the imposition of the navigational servitude in this 

context will result in an actual physical invasion of the 

privately owned marina. ... And even if the Government 

physically invades only an easement in property, it must 

nonetheless pay compensation.45 

Here, requiring Rosemont to backfill its pit in order to reclaim National Forest 

System land would result in a permanent physical invasion of Rosemont’s private 

property, on which the pit is centered. The placement of hundreds of millions of tons of 

waste rock and tailings in the pit would directly and substantially diminish Rosemont’s 

property rights by preventing future exploration and development of valuable minerals 

compensation.”); Loretto v. Teleprompter Manhattan CATV Corp., 458 U.S. 419, 426-35 (1982)
 

(analyzing cases addressing takings which involved a physical invasion of property resulting from
 

government action).
 41 Loretto, 458 U.S. at 426 (“We conclude that a permanent physical occupation authorized by
 

government is a taking without regard to the public interests that it may serve. Our constitutional
 

history confirms the rule, recent cases do not question it, and the purposes of the Takings Clause
 

compel its retention.”).
 42 Id. at 435 (quoting United States v. General Motors Corp., 323 U.S. 373, 378 (1945)) (citation
 

and quotation marks omitted).
 43 Kaiser Aetna v. United States, 444 U.S. 164 (1979).
 44 Id. at 176.
 45 Id. at 180; see also United States v. Causby, 328 U.S. 256, 265, n. 10, (1946) (“[A]n owner is
 

entitled to the absolute and undisturbed possession of every part of his premises, including the
 

space above, as much as a mine beneath.”); Pumpelly v. Green Bay Co., 13 Wall. (80 U.S.) 166,
 

181 (1872) (“[W]here real estate is actually invaded by superinduced additions of water, earth,
 

sand, or other material, or by having any artificial structure placed on it, so as to effectually
 

destroy or impair its usefulness, it is a taking, within the meaning of the Constitution.”).
 

8
 
 

 

 

 

 

 

 

 

 

6738586 

that may exist within the boundaries of Rosemont’s patented mining claims, as well as 

the claims’ extralateral rights granted under the Mining Law. 46 

Given that the principal value of Rosemont’s private land within and adjacent to 

the pit area is based on its mineral resources, forcing Rosemont to fill the pit in 

connection with reclaiming adjoining federal land (and despite having a reclamation plan 

approved by the responsible state agency – the Mine Inspector) would directly invade 

Rosemont’s property interests, violating the Takings Clause. To borrow a metaphor used 

by the Supreme Court, the Forest Service not simply take a single “strand” from the 

“bundle” of Rosemont’s property rights: it would chop through the bundle, taking a slice 

of every strand and leaving Rosemont with bare legal title to the pit area, precluding its 

future use for mineral development.47 

IV. Conclusion 

We are perplexed by the Forest Service’s apparent fixation on pit backfilling. 

Putting aside the obvious technical, economic, and environmental problems that 

backfilling would create, the Forest Service lacks legal authority to mandate the 

backfilling (or any other reclamation) of private land under the Organic Act and the 

agency’s surface use regulations. Instead, those regulations plainly provide that the 

Forest Service will accept the Mine Inspector’s approval of Rosemont’s reclamation plan 

under Arizona’s Mined Land Reclamation Act. And even if such authority existed, 

backfilling would effect a taking of Rosemont’s private property by causing Rosemont to 

suffer a physical invasion of its property in violation of the Takings Clause of the Fifth 

Amendment. In light of these serious legal problems, pit backfilling is not an option and 

should not be considered by the agency. 

46 30 U.S.C. § 26; see also, e.g., Del Monte Mining & Milling Co. V. Last Chance Mining & 

Milling Co., 171 U.S. 55 (1898) (dispute over extralateral rights associated with patented lode 

mining claims with overlapping side lines). 

47 Loretto, 458 U.S. at 435. 

9
 
 

 

May 8,	2012

Mr. Jim Upchurch

Forest Supervisor

Coronado	National Forest

30 West Congress

Tucson, Arizona	85701

Re: Response to April 9, 2012 and March 14, 201 Forest Service Letters

Dear Mr. Upchurch:

In response to your letters dated	April 9, 2012	and March 14, 2012,	Rosemont presents the following

information to specifically respond to your	questions enumerated below.

As a preliminary matter, we want to	 again	 emphasize that any backfilling alternative will necessarily

involve the use of Rosemont’s property, given that 80% of the	pit will be	located on Rosemont’s private	

land, including the central portion of	 the pit	area.	 Rosemont has previously explained why the Forest

Service	 lacks legal authority to override Arizona law and regulate the manner in which Rosemont’s

private land	is reclaimed. The Forest Service’s authority is limited	 to	 reasonable regulation	 of mining

activities occurring on National Forest System land. The	 agency has no jurisdiction over private	 land

uses. Instead, that authority rests with the Arizona State Mine Inspector and is governed by Arizona

law.	 Consequently, the imposition of a backfilling requirement in Rosemont’s plan of operations would

be unlawful.

Moreover, the Forest Service’s imposition of a backfilling requirement would violate	the	Takings Clause	

of the Fifth	Amendment, which	provides that private property shall not be taken	for public use without

just compensation.	 Rosemont would	be compelled	to	use its private property to	store waste rock and	

tailings, directly	 interfering with future mineral development and other private land	 uses. This is

functionally equivalent	 to the classic taking in which the government	 directly appropriates private

property for its own	use, and	would	violate the Constitution.

Inherent	 in NEPA and its implementing regulations is a “rule of	 reason,” which ensures that	 the

information developed during the process is useful	to the decision-making process. The CEQ regulations

instruct agencies to use the NEPA process identify “the significant environmental issues	deserving study	

and deemphasizing insignificant issues, narrowing the	 scope	 of the	environmental impact statement.”

40 CFR 1501.1(d). The information the Forest Service has requested on the technical, economic and

environmental aspects of pit backfilling (as well as other recent information	 requests) is inconsistent

with NEPA’s rule of reason and appears intended to generate useless information.

WEB: www.rosemontcopper.com P.O. Box 35130 T E L : (520) 495 3500
 

STOCK SYMBOL: AMX TSX - AZC Tucson, Arizona 85740-5130 F A X : (520) 495 3540
 
Additional questions posed from the April 9, 2012 letter:

Impacts to the economic viability	of mine	operations for both partial and full pit backfill. Please	provide	

this information broken out	in major	work items. The impacts should be described in terms of	specific

costs	such as	operator salary, equipment capacity, and haulage costs,	and costs of additional equipment

and/or equipment depreciation.

Assuming, for the sake of argument, that the Forest	Service has authority to	override Arizona law and	

regulate mining activities on private land, the impacts of backfilling would be very substantial,	 even

under a partial backfill scenario.	

A partial pit backfill	would be accomplished using one shovel, with mining taking place at a rate	of 28 to

29 million tons per year. The total amount of material that	would be rehandled	is about 84 million tons,	

which is a substantial amount of material.	 We expect that such an effort would require 35 months or	

almost three years to complete the backfill,	assuming that operations take place during two work shifts	

covering	24-hours per day,	365 days per year. To accomplish this	Rosemont believes:

•	 A fleet of 16 trucks (219,665 operating hours)	 would be required	 to	 optimize the shovel

productivity.

•	 Other heavy equipment, such as road graders, water	trucks, loaders, and bulldozers,	also will be

required to manage the hauling operations.

•	 The number of operators required for this amount of equipment is 110.

•	 Maintenance personnel for	the heavy equipment would total 37.

•	 Rosemont would	 have to	 maintain a safety department, environmental department, human

resources, accounting,	 payroll,	 accounts payable,	 purchasing,	 warehousing,	 and supervisory

staff. The estimated number of salaried personnel required for the support and supervisory

roles would be approximately 30.

•	 Equipment would be moved	 from the current fleet of shovels, trucks, and support equipment.	

Of the required equipment fleet, four of the trucks and much of the	support equipment will be

nearing the end of	their	useful lives.	 The trucks will require a “rebuild” to equip it	for	downhill

haulage,	which is estimated to cost $1.5	to $2 million per truck, depending upon the operating

hours and	general equipment condition.

•	 While Rosemont considers specific mining cost information proprietary, current (2012 dollar)	

cost updates	for mining, less the cost of drilling and blasting, total approximately $0.80 per	ton.	

Support costs would add an additional $0.20	 to $0.25	 per ton. Thus, total costs for	 backfill

(excluding capital costs)	would be approximately $1.00	to $1.05	per ton.

•	 The estimated total cost	 for	 this effort would be $84 million	 to	 $88 million excluding capital

costs.

A complete waste rock pit backfill would	be accomplished using two shovels, with mining taking place at

a rate	of 56 to 58 million tons per year. The total amount of material that	would be rehandled is 881

million tons (1.8 billion tons of	 material less the material used to cover heap leach facilities and the

tailings buttresses and cover).	 This would require approximately 16 years to complete, again assuming

that	operations take place during two 12-hour work shifts per day,	365 days per year. To accomplish

this we believe:

•	 A fleet of 16 trucks (1,017,000 operating hours) would be required	 to	 optimize the shovel

productivity.

2 | Pag e
•	 Other heavy equipment, such as road graders, water	trucks, loaders, and bulldozers, would be

required to manage the hauling operations.

•	 The number of operators required for this amount of equipment is 125.	

•	 Maintenance personnel for the heavy equipment would total 41.	

•	 Rosemont would	 have to	 maintain a safety department, environmental department, human

resources, accounting, payroll, accounts payable, purchasing, warehousing, and supervisory

staff. The estimated number of salaried personnel required for the support and supervisory

roles is approximately 34.	

•	 Equipment would be moved	 from the current fleet of shovels, trucks, and	support equipment.

Of the required equipment fleet, 11 of the trucks and	much	of the support equipment would be

nearing the end of	 their	 useful lives.	 All but five of the trucks will need to be replaced	at an

estimated cost (in current	dollars)	of	$3.5	million per truck. The five remaining trucks will need

to be rebuilt	at	 cost of $1.5	to $ million per truck.

•	 While Rosemont considers specific mining cost information proprietary, current cost updates	for

mining less the cost of drilling and blasting total approximately $0.80 per ton. Support costs

would add an additional $0.26	to $0.33 per ton. Thus, total costs for	backfill (excluding capital

costs) are $1.06 to $1.13 per ton.

•	 The total cost for complete waste rock pit backfill will be $934	million to $996	million, excluding	

capital costs.

Finally, complete backfill of material using existing equipment would be impossible; large haulage and

loading equipment cannot drive on the tailings. However to provide the Forest Service with an order of

magnitude for scale of the operations required, Rosemont’s mining consultants have prepared an

analysis assuming that loading and haulage	could take	place	on the	tailings stack in a manner similar to

the waste rock.

If this scenario were technically possible, a complete pit backfill would	 be accomplished using three

shovels, mining at a rate of 30 million tons per year. The total amount of material to be rehandled is

1,850	 million tons.	 This would require approximately 22 years to complete, again assuming that

operations take place during two	12-hour work shifts per day,	365 days per year. To accomplish this we

believe:

•	 A fleet of 28 trucks (1,858,000 operating hours) would be required to optimize the shovel

productivity.

•	 Other heavy equipment, such as road graders, water	trucks, loaders, and bulldozers, would be

required to manage the hauling operations.

•	 The number of operators required for this amount of equipment is 190.	

•	 Maintenance personnel for the large equipment would total 64.	

•	 Rosemont would	 have to	 maintain a safety department, environmental department, human

resources, accounting, payroll, accounts payable, purchasing, warehousing, and supervisory

staff. The estimated number of salaried personnel required for the	 support and supervisory

roles is approximately 40.	

• Equipment would be moved from the current fleet of shovels, trucks, and support equipment.	

All but five of the trucks and	much	of the support equipment would	be nearing the end of	their	

3 | Pag e
useful lives.	 The replacement cost	of each truck (in current dollars)	is about $3.5	million,	five of

the trucks will require being rebuilt.

•	 While Rosemont considers specific mining cost information proprietary, current cost updates for

mining less the cost of drilling and blasting total approximately $0.80 per ton. Support costs

would add an additional $0.26 to $0.33 per ton. So total costs for backfill (excluding capital

costs) are $1.06 to $1.13 per ton.

•	 The total cost for a complete	pit backfill this would be $1,961 million to $2,091 million excluding

capital costs.

Impacts to the ability to conduct concurrent reclamation activities. Please be specific as to where in the

project area	 concurrent reclamation	 would	 be affected	 and why and how these effects could	 be

mitigated.

Under a partial backfill scenario, material would be mined between the 5500 foot	 elevation and the

5300 foot elevation on the eastern waste rock dump	 and transported back into	 the pit.	 Thus, the

eastern waste	 rock dump	would	 be reclaimed	after backfilling operations are completed. Concurrent

reclamation could be completed	 as contemplated	 on the northern	 and	 eastern	 edge of the tailings

facilities, the southern waste rock dump and a portion of	 the waste rock dump	 below the 5300 foot

elevation. No	mitigation	is planned for	this additional disturbance.

Under the complete waste rock backfill scenario, concurrent reclamation	activities would	be completed

o the tailings buttress areas not integrated	with	waste rock o the eastern	and	northern	buttress areas.

All other reclamation	 activities would necessarily be postponed until the completion of backfill

operations.	 No mitigation has been planned	for this disturbance and the	cost	of reclaiming the area is

unknown.	

Under the complete backfill scenario, no concurrent reclamation activities would be undertaken, and	

reclamation would necessarily be postponed until the completion of	backfill operations.	 No mitigation

is planned for this additional	disturbance.	

Again, this may have a significant impact on	reclamation bonding requirements and	estimated	 bonds.

As stated, Rosemont’s strategy depends upon concurrent reclamation	to	maintain	bonds at acceptable

levels.	 The Arizona Mine Inspector approved Rosemont’s Mined Land Reclamation Plan for the project	

in 2009.	 The Forest Service’s surface use regulations state that the State	of Arizona reclamation plan

will be accepted as compliance with any reclamation requirements developed for adjoining National

Forest System land. See 36 CFR. 228.8(h). Pit backfilling is not	 consistent	with the state reclamation

plan, and	 it is uncertain	 whether the reclamation	 plan	 approved	 by the Mine Inspector will apply to	

Rosemont’s private land. If the Forest Service takes control of Rosemont’s private land and mandates

pit backfilling, the bonding requirement	may increase to unsustainable levels.

Duration and nature of activities that could result in extended impacts to resources such as air quality,

public health	 and safety, night skies, socioeconomic factors (including quality of life issues), noise and

biological resources (i.e., disturbance from noise, lights, etc.). Provide justification	for duration	of various

activities an examples.

The Rosemont site would remain an active mining area for	 the duration of	 the backfill activities. This

would include traffic for employees for two shifts per day 365 days per year.	 Deliveries of materials and	

supplies necessary for mining activities,	such as fuel, tires, lubricants, parts and	equipment, would occur

4 | Pag e
as well. Mining and	loading activities associated	with	transporting waste rock (and tailings)	would occur

outside of the open	pit and closer to the	edge	of the	facilities. Consequently, environmental impacts

such as	fugitive dust emissions, lights, and noise may be more severe.	 Moreover, impacts from	mining

would continue an additional three to 22 years, depending on which	the backfill scenario is evaluated,	

with nothing being produced, nothing being sold, and generating no positive cash flow.	Consumption of

fuels and generation of noise, dust, light, and traffic would continue throughout the entire period. Thus,

we anticipate that the environmental impacts of backfilling will be very similar to	the impacts resulting

from mining operations but may be more pronounced	due to	the location	of the activities.

What is uncertain is the additional impacts that would result under the complete waste rock backfill and

complete backfill scenarios given the	 placement and subsequent excavation of all or a substantial

portion	 of the waste rock dump and tailings	 facilities. Obviously, these areas	 will be denuded and

severely damaged under either scenario, and whether and how they would be reclaimed is	unknown	

and probably cannot be	determined with any degree	of certainty. It is possible	 that portions of these	

areas may be	permanently impaired and never return to a healthy, functioning ecological condition. The

short-term and long-term impacts of a backfill alternative may therefore be greater than would result

under Rosemont’s concurrent reclamation	program in	the Preferred	Alternative.

Impacts addressing the future possibility to further expand mining operations based on market

conditions	or actual production results	from partial or full pit backfill.

Any material placed	 at the bottom of the pit and	 over the remaining mineralized material would

increase costs, and reduce the value of	 the material left	in the bottom of	 the pit	by restricting access.

Indeed, if the Forest Service imposes a backfilling requirement and orders the	pit filled with waste	rock,

it is unclear whether and how Rosemont’s property could	be used	in	 the future, should	an	increase in	

metals prices, new technological advances or other circumstances make additional resource uses viable.

For this reason, such	an	action by the Forest Service	would result	in a taking of	the future resource value

of Rosemont’s private property.

Questions (with additional specificity) from the March 14, 2012 letter:

1.	 Previous reports, dated in 2010, state that backfill material would be pulled from the side of the

waste rock facility closest to the pit.

a.	 Is that assumption still	 current in light of the most recent plans for the Preferred

Alternative?

No.	 Based on the	configuration required for the	Preferred Alternative, waste	rock could

not be removed	 from the side of the facility closest to	the pit. The material closest to	

the pit	 is actually covered leach facilities or	 tailings, which would not	 be a suitable

materials source area for	backfill material.

b.	 If not, where would the waste rock be pulled	 from now and what is the rationale for

changing this	location? Would you consider backfilling with heap leach material and/or

tailings, and if	not, can you provide your	justification for	not	considering these options?

5 | Pag e
Waste rock would be excavated from the	eastern portion of the	waste	structure. This

material is suitable for backfill and mining-related uses.	 We do not consider heap	leach	

material and/or tailings suitable for backfill for a number of reasons:

•	 Heap leach facilities are facilities that	are engineered and constructed to meet

specific	 stability requirements	 that were vetted and have been permitted

through ADEQ. Additionally, the heap leach facilities are constructed on liners

that	are not	intended to support	future excavation activities.

•	 When a heap leach facility is excavated,	low pH solutions that remain within the

dump	 matrix will be exposed	 to	 the elements, personnel, and environment.

This solution, along with water used	to	control dust during excavation or during

storm events, could cause the amount of solutions	draining through the facility

to increase. When coupled with the unknown effect	 that	 excavation-related

activities could have o the liners, this does not seem to	be prudent risk.

•	 Tailings are not considered suitable for	pit backfill.	 Excavating and rehandling

fine-grained materials placed in a facility that has been engineered to ensure

stability and minimize erosion also increases	 the potential for environmental

impacts.	 Moreover, dust generated	 from excavation	 and	 transportation	

activities can only be	managed through dust suppression techniques that	could

require significant	additional water consumption.

•	 The stability of the tailing management	facility has been engineered using the

buttresses, construction compaction, and water management. Future	

excavation is not part of the	design elements for those	facilities.

•	 The heap leach has been constructed using specific construction requirements

to protect	the liners under	the leach materials. These protective specifications

d not include contingencies for mining the heap	leach	facility.

•	 Finally, heap leach material and tailings are	 considered process materials and

disposal in	 the pit would require detailed	 analysis and	 permitting from ADEQ.

To Rosemont’s knowledge, ADEQ has never permitted	the backfilling heap	leach	

material, tailings or waste rock below local	groundwater levels,	or recognized pit

backfilling as a “Best Available Demonstrated Control Technology.”	 Further, the

use of tailings, waste rock, or	spent	heap leach material as backfill has not been	

contemplated in the establishment of the monitoring plans	or closure concepts	

presented.

c.	 Please specify whether the location of backfilled materials applies to complete and/or

partial backfill.

Based	 on your question,	 this information specifically applies	 to partial pit backfill.	

However, the discussion above is applicable to all pit backfill scenarios.

2.	 Previous calculations, as well as more recent modeling, have made estimates of how much

material would be able to	be backfilled	into	the pit while still maintaining	the hydraulic sink. For

instance the recent modeling by Montgomery & Associates and Engineering Analytics estimates

6 | Pag e
that	from 3.58 to 4.28 billion cubic feet	could be backfilled depending on the backfill elevation,

representing approximately 12 to 14% of	the total stacked material (i.e., waste rock tailings, and

heap	leach).

a.	 Are these the best estimates available for the volume of material that could be backfilled

an still maintain	 hydraulic sink?

The previous estimates of the volume of	 material that	 could be backfilled and still

maintain a hydraulic sink was developed	 by using mine planning software. The

estimates that were	calculated in the	groundwater models are	direct measurements of

open	 space	 in the	 pits and does not include ramps, swell factors, placement

requirements, etc. The specific volume that	was estimated did	not incorporate any of

the factors of	safety that	 would be afforded by incorporating the sensitivity analysis,

Rosemont has calculated the elevation using the sensitivity analysis	 in the hydrologic

studies	to determine lowest water elevations	to maintain the hydrologic sink. Material

elevations were kept below	this lowest water elevation when volumes were calculated.

b.	 Please provide some context with	 this volume, to	 understand	 what this volumetric

change would mean for the Barrel alternative. What height or footprint difference

would removal and backfill of this volume make?

The “footprint	 difference,” if the hydraulic sink is maintained, lowers the elevation of	

the eastern dump by approximately 200 feet. There would be no change to	the overall

operations footprint.

c.	 Please address the safety factor (be specific) that is considered in the modeling analysis

in order to ensure maintenance of a hydraulic sink. For instance, under the modeled

scenarios, how deep would the pit lake be while still maintaining the hydraulic	sink?

Hydrogeologic modeling results for	the anticipated pit lake included	 sensitivity analysis	

that	 showed the variance associated with changes in precipitation, evaporation,

seepage, and other inputs. At the upper end	 of the evaporation range (30% over

“normal”),	the anticipated pit lake is approximately 3945 to	4012 feet	in elevation. To

be conservative and	ensure	that partial backfilling	will not to not	eliminate	the hydraulic

sink, a 3825 foot elevation was	selected for	the partial pit backfill analysis.

3.	 What volume of material would be backfilled in a full pit backfill scenario? How is the volume

calculated	an does it vary by lithology?

The volume does not vary by lithology,	rock density is an average for the deposit.	 The material	

for	the backfill in situ density is 11.85 cubic feet per ton, with a swell	factor of 1.3.	 The full pit

backfill scenario	incorporates 812,489,000 cubic yards of material that would be compacted	into	

the pit. The material would be stacked	 to	 an	elevation	 of 5300 feet with	 an	 ultimate overall

slope above the pit rim of 2:1 or 26 degrees. We note that this 2:1 resulting slope is steeper

than the 3:1 outslopes proposed for	the Rosemont	ridge landform in the original MPO, the 3 or

3.5:1	slopes proposed for the	 phased tailings alternative, and the	 outslopes proposed in the	

preferred	“Barrel Only” alternative.

7 | Pag e
4.	 Previous reports, dated	in	2010, infer that it might only take 3 years in	addition	to	the 20 year

mine life to complete backfill

There appears to be confusion between “backfill,”	 “partial backfill with hydraulic sink	

retention,”	“complete waste rock	backfill,”	and “total backfill including rehandling of waste rock,

tailings, and spent	 leach rock.”	 Because of the volumes of material involved, the cost

implications of any of these scenarios	 are	 substantial and, in Rosemont’s view, represent

unwarranted	 interference with	 the lawful exercise	 of its mining rights and use	 of its private	

property.

a.	 Can you	 confirm how long	 it would	 take to	 complete a partial backfill that would	 still

maintain a hydraulic sink? Please explain the aspects that are considered	in	 this time

calculation	(hours of operation, equipment used, number of haulage trips, etc.).

Again, the estimate	for	partial backfill with retention of	hydraulic sink is approximately

three years, assuming that no unforeseen problems are	encountered. This estimate	is

based	o approximately 219,665	operating hours using 1 trucks, and one	shovel for the	

main mining operation. The mining operation support equipment, administration staff,

maintenance staff, etc., are	not included.

b.	 Can you	specify how long	it would	take to	complete a full pit	backfill? Please explain the

aspects that are considered	in this time calculation.

A complete backfill is estimated	 to	 take 22 years, assuming that operations take	place	

during two	 12-hour work shifts per day,	 365 days per year and no problems are	

encountered. Approximately 30 million tons of material would be excavated and

transported to the pit	each year. Time is calculated on haulage cycles, distances, time,

rates for	 loading and dumping, and the time associated with downhill haulage loaded

into an open pit.	

5.	 In order to complete a full	or partial	pit backfill, logistically, are there operational	changes that

would result in changes to the overall environmental effects? For instance, what changes in

timing of	reclamation activities, additional equipment operation, additional traffic, etc. would	be

expected? Please	 specify	 which operational changes and environmental effects apply	 to each

backfill scenario.

Under a partial backfill scenario, material would be mined between	the 5500 foot elevation and

the 5300 foot	 elevation on the eastern waste rock dump	 and	 moved back into	 the pit.	

Concurrent reclamation	could be completed	as contemplated	on the northern	and	eastern	edge

of the tailings facilities, the southern	 waste rock dump	 and	 a portion of	 the dump below the

5300 foot elevation. There	 would be no significant operational changes other than	 mining

operations shifting from the pit to the waste rock dump	area. Environmental effects would	be

extended by three	 years. In addition, the excavation and transportation activities	 would be

concentrated along the eastern waste rock dump, which may increase certain environmental	

impacts (e.g., dust, light	and noise),	as previously discussed. Under this scenario,	 the ultimate

elevation for partial	pit backfill would be 382 feet.

Under the complete waste rock backfill scenario, concurrent reclamation	 activities would	 be

completed on the tailings	 buttress	 areas	 not integrated with waste rock	 on the eastern and	 

8 | Pag e
northern	 buttress areas. All other reclamation activities	 would be suspended pending the

completion of pit backfill. All impacts would	extend	for approximately 16 years for	the mining

phase. During this period, excavation and transportation activities would be concentrated along

the eastern portions of the mine area and	 away from the pit, which	 may increase certain	

environmental impacts (e.g., dust, light and noise), as previously discussed. Presumably there

would be an additional period	of activity involving reclamation of	 the denuded area while the

area	 that formerly contained the waste rock dump	is recontoured, seeded, and reclaimed. As

stated above, it is	 uncertain whether this	 area will return to a healthy ecological condition.

Under this scenario, the ultimate backfill elevation	in	the pit would	be about 490 feet.

This will have an impact on the bonding requirements and estimated bonds. Rosemont’s

strategy depends	 upon concurrent reclamation to maintain bonds	 at acceptable levels.

Backfilling pushes the bonding requirement to	 unsustainable levels while still requiring

concurrent reclamation expenditures.

Under the complete backfill scenario, no concurrent	reclamation activities would be completed.

All impacts would	 extend	 for 22 years beyond the mining phase and then presumably	 for an

additional period while	 reclamation of the	 now denuded area	 for the	 material that has now

been	removed	is recontoured, seeded, managed, etc. The ultimate backfill elevation	in	the pit

will be 5300 feet,	exceeding the 5050 ground elevation by 250 feet.

Bonding requirements and	 estimated	 bonds under both	 the complete waste rock backfill

scenario and the complete backfill scenario are	 likely to change	 significantly.	 Arizona

Department of Environmental Quality approved the closure concept for the heap	leach	and	set a

bonding amount which	does not include moving the heap	or filling in	the pit. The Arizona Mine

Inspector approved Rosemont’s Mined Land Reclamation Plan for the project	 in 2009. Pit

backfilling is not consistent with	 that reclamation	 plan,	 and it is uncertain whether the

reclamation plan approved by the Mine Inspector	 will apply to Rosemont’s private land.

Rosemont’s strategy depends upon concurrent reclamation	 to	 maintain	 bonds at acceptable

levels.	 Backfilling pushes the bonding requirement to unsustainable	levels while	still requiring	

concurrent reclamation expenditures.

6.	 Please provide the most recent estimate for the economic costs of conducting a partial backfill

that	would still maintain a hydraulic sink.

Assuming that the bonding requirements did	not change, the overall cost is between	$84 and	

$8 million excluding additional capital costs.

7.	 Please provide a recent estimate for the economic costs of conducting a full pit backfill.

The cost for a waste rock backfill will be $933 to $996	 million exclusive of capital costs and

changes	to bonding requirements. The cost for a full pit backfill will be $1,961	million to $2,091	

million exclusive	of capital costs and changes to bonding	requirements.

We hope that the responses along with the attached memo from our	 mine planning consultants’

answers your questions regarding pit backfill.

9 | Pag e
 

Regards,

Katherine	Ann Arnold

Vice President, Environmental and Regulatory Affairs

Cc: Chris Garrett, SWCA

File	

Doc. No.	031/12-15.3.1

6959305 

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Memorandum
 From: Bob Fong, Marc Schulte 

To: Fermin Samorano, Rosemont Copper 

Date: December 10, 2009 

Re: Backfill Pit to 3825 ft Elevation - Revision 

This memorandum is a follow-up to a previous version ‘Memo - Rosemont - Backfill Pit to 3825.docx’, 

issued on November 17, 2009, which summarizes the findings from a scoping level study on an option 

to rehandle some of waste dump to backfill the pit at the end of mine life for mine closure and 

reclamation purposes. The pit is required to be backfilled to the 3825 ft elevation. The pit and waste 

dump designs and layouts are those from the Rosemont Copper 2009 Feasibility (Feasibility) study. 

The top of the waste dump is 5470 ft elevation. 

This memorandum version includes the contents of the previous version, as well as an evaluation of an 

alternate strategy. 

ASSUMPTIONS 

The assumptions for this assessment are provided by Rosemont Copper. Assumptions that are not 

available from Rosemont are developed by MMTS, based on their best knowledge. 

Excavation of the waste dump will be south of the leach pad area. The leach pad design has 

undergone updates since the Feasibility study, and the latest version has not been provided to MMTS. 

The outline of the north pad from the Feasibility study is assumed for this study. 

All waste material from excavated from the dump will be suitable for backfilling the pit. 

One cable shovel from the mine equipment fleet will be used for excavation of the waste dump. The 

existing truck fleet for hauling the material from the dump to the pit will be the 793C trucks. 

Waste material in-situ density is 11.85 ft3

/ton, and the swell factor in the dump is 1.3. 

SUMMARY OF FINDINGS 

The area of the dump that will be excavated is on the west side. The bottom of the cut will be the 5200 

ft elevation. Figure 1 shows the excavated area and the backfill to the 3825 ft elevation in the pit. 

The total material quantity required to backfill the pit to the 3825 ft elevation is calculated to be 46 M-cu. 

yds (loose), equivalent to 80 M-tons. An allowance of 5% is added to the fill quantity to widen areas on 

the in-pit road for runaway ramps. Total material to be re-handled from the waste dump is 84 M-tons. A 

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single shovel mining at a rate of 28 to 29 M-tons per year will require 35 months, or almost 3 years to 

complete the backfill requirement. 

The trucks will excavate the waste dump on 50 ft benches starting on the 5400 bench. This first bench 

will be 70 ft high and may require a dozer to cut it down to the shovel operating bench height. The 

trucks will haul the material from the dump to the pit, following the in-pit ramp to the 3825 ft elevation. 

The material will be end dumped at that location until a pad can be established. The pad will be 

extended out to its entirety at that elevation. 

Figure 1: EXCAVATION AREA AND BACKFILL IN-PIT 

The downhill hauls into the pit will be stressful on the loaded trucks, having to negotiate 3 switchbacks 

and -10% grades. Truck simulations were run on the haulage profiles, and they indicate that maximum 

speed of the trucks on the in-pit ramp will be approximately 13 mph, in 2nd gear. They will be further 

2 
 

 

 

 

 

 

slowed down at each switchback to 7 mph for safety. The haulage routes from the top and bottom 

benches of the waste dump are shown in Figures 2 and 3. 

The haulage productivities are estimated to be 379 t/hr for the top of the waste dump at the 5400 

bench, and 419 t/hr at the bottom, 5200 bench. They are summarized in Table 1, and are used to 

estimate the total required trucks. 

Figure 2: HAULAGE FROM 5400 BENCH TO 3825 ELEV IN-PIT DUMP 

3 
Figure 3: HAULAGE FROM 5200 BENCH TO 3825 ELEV IN-PIT DUMP 

4
 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Table 1: HAUL PRODUCTIVITIES BY BENCH 

Bench 

Elev. 

Quantity 

Cum. 

Quantity 

k-tons k-tons 

Haul Prod. 

t/hr 

5450 

5400 

5350 

5300 

5250 

5200 

8,938 8,938 

18,435 27,373 

18,689 46,062 

16,277 62,338 

12,977 75,315 

8,720 84,036 

379 

387 

395 

403 

411 

419 

The required truck operating hours are summarized by year in Table 2. It is estimated that 16 trucks will 

be required in the first 19 months when the top half of the dump is excavated, and 15 trucks for the 

remainder of the project. 

Table 2: REQUIRED HAULAGE HOURS AND UNITS 

Post Mining 

Year 

Rehandle Quantity 

k-tons 

CAT 793C Truck 

Fleet 

Oper. Hrs Units 

1 

2 

3 

28,774 

28,853 

26,409 

74,740 

72,439 

64,021 

16 

16 

15 

Total 84,036 211,201 16 

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ALTERNATIVE STRATEGY - BACKFILL FROM 4625 ft ELEVATION 

To avoid the downhill haul around the switchbacks and reduce the truck hour requirements, the option 

of backfilling from a higher pit elevation is assessed. More material will be required as a portion will 

hang up on the highwall above the targeted 3825 ft elevation. This alternative study will determine 

whether it is feasible to move more material at higher truck productivities and dozer push the spoil pile 

down to the 3825 ft elevation. 

The plan is to haul from the waste dump to the first switchback from the pit rim at 4750 ft elevation and 

dump a -5% fill access along the pit wall to 4700 ft elevation. From that location, a -5% fill pad is 

extended into middle of the pit to a final dump elevation of 4625 ft. Figure 4 shows the layout of the 

accesses and the backfill almost to the 3825 ft elevation. To entirely fill up to the 3825 ft level will 

require dozer push of over 200 ft vertical elevation. 

Figure 4: DUMP FROM 4625 ft ELEVATION 

The total material mined from the waste dump is estimated to be 96 M-cu. yds (loose), more than twice 

that of the base case where the material is hauled to the 3825 ft elevation. It is estimated that the 

average haulage productivity is 667 t/hr, compared to an average of 400 t/hr for the haulage to the 

3825 ft elevation. This represents approximately 40% less truck hours. 

6 
 

 

 

 

 

 

 

 

 

 

This option does not appear to be feasible as the quantity of material moved eliminates the haulage 

savings. An additional shovel will also be necessary to complete the project over the 3 year period. 

Otherwise it will take 6 years to complete with a single shovel, which will prolong the mine closure 

period and add to the costs. Further closure costs may be incurred if it is necessary to reclaim the 

backfill material above the 3825 ft level in the pit. This alternative will likely be costlier. 

Employing an extended conveyor to dump the waste into the centre of the pit will reduce the amount of 

material hang up on the highwall. This may be another option worth investigating. 

Reference files: 

• Haul Estimates for 3825 Backfill Rev.xlsx 

• Rehandle Cut 5200_Vols Rev.xlsx 

7 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Memorandum
 From: Marc Schulte 

To: Fermin Samorano 

cc: Bob Fong 

Date: May 02, 2012 

Re: Backfill Pit - All Waste Options 

This memorandum is a follow-up to three previous versions: 

- ‘Memo - Rosemont - Backfill Pit to 3825 - Revision.docx’, issued on December 10, 2009 

- ‘Memo - Rosemont - Backfill Pit to 3825.docx’, issued on November 17, 2009 

- 'Memo - Rosemont - Backfill Pit to 3825, MPS Update 120215.docx' issued on February 15, 

2012 

This memo summarizes the findings from a scoping level study on an option to rehandle some of waste 

dump to backfill the pit at the end of mine life for mine closure and reclamation purposes. Two 

scenarios are examined: 

- Backfilling the pit with all material except the leach pads and tailings facilities. 

- Backfilling the pit with all material. 

The pit designs and layouts are those from the Rosemont Copper 2009 Feasibility (Feasibility) study. 

The waste dump designs and layouts are from Tetratech's current 2012 'Barrel Only' waste structure. 

This waste design is not currently finalized, so the designs shown in this memo are in draft form and 

may change. 

ASSUMPTIONS 

The assumptions for this assessment are provided by Rosemont Copper. Assumptions that are not 

available from Rosemont are developed by MMTS, based on their best knowledge. 

Excavation of the waste dump will be from a centroid point in the dump and hauled to the pit entrance. 

For the first case (leaving tails and leach material), the waste will be hauled down to the 4900 elevation 

in the pit. For the second case (all material backfilled), the waste will be hauled to the 5050 pit entrance. 

All waste material from excavated from the dump will be suitable for backfilling the pit. 

Two cable shovels from the mine equipment fleet will be used for excavation of the waste dump. The 

existing truck fleet for hauling the material from the dump to the pit will be the 793D trucks. 

Waste and leach material in-situ density is 11.85 ft3

/ton, and the swell factor in the dump is 1.3. The 

compacted swell factor in the backfilled pit is 1.25. Tailings in-situ density is 18.36 ft3

/ton. It is assumed 

that the backfilled tailings will keep this same density. 

SUMMARY OF FINDINGS, CASE 1, Everything backfilled except leach and tailings 

1 
 

 

 

 

 

 

 

 

 

 

 

All the waste areas will be excavated and placed back into the pit, except for the tails and leach 

structures. 

The quantity of waste removed from the waste structure will be 503,022 kyd3

. This will translate into 

484,260 kyd3 of compacted volume in the pit. 

Total tonnage of material to be re-handled from the waste dump is 881 M-tons. Two shovel mining at a 

rate of 30 M-tons per year will require 15 years to complete the backfill requirement. 

The trucks will excavate the waste dump on 50 ft benches starting on the 5650 bench. The trucks will 

haul the material from the dump to the pit, following the in-pit ramp to the 4900 ft elevation. The material 

will be end dumped at that location until a pad can be established. The pad will be extended out to its 

entirety at that elevation. For safety reasons, it may be necessary to build this dump pad at a lower 

elevation in the pit, below 4900. This circumstance would increase the backhaul cycle times, and add 

costs that haven't been accounted for in the hauler estimates below. 

Figure 1: EXCAVATION AREA AND BACKFILL IN-PIT 

2 
 

 

 

 

Truck simulations were run on a haulage profile from the dump centroid to the 4900 elevation of the pit. 

The haulage route chosen is shown in Figure 2.
 

The haulage productivities are estimated to be 867 t/hr for all waste haul, and are used to estimate the
 

total required trucks.
 

Figure 2: HAULAGE FROM WASTE CENTROID TO 4900 ELEV IN-PIT DUMP 

3 
 

 

 

 

 

The required truck operating hours are summarized by year in Table 1. It is estimated that 16 trucks will 

be required for the entire backfilling project. 

Table 1:	 REQUIRED HAULAGE HOURS AND UNITS

Post Mining

Year

CAT 793C	Truck Fleet

Oper. Hrs Units

1 69,198 16

2 69,198 16

3 69,198 16

4 69,198 16

5 69,198 16

6 69,198 16

7 69,198 16

8 69,198 16

9 69,198 16

10 69,198 16

11 69,198 16

12 69,198 16

13 69,198 16

14 69,198 16

15 47,775 16

16 0 0

Total 1,016,550 16

This option adds ~15 years of costs to the mining activities, thereby delaying the mine closure. It is also 

questionable as to whether the landscape has actually been improved. 

This option also sterilizes any possible economic ore at the bottom of the pit that could potentially be 

mined in the future. 

4 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

SUMMARY OF FINDINGS, CASE 2, Everything Backfilled 

All the waste areas will be excavated and placed back into the pit. 

The quantity of waste removed from the waste, tailings and leach structures will be 1,173,968 kyd3

. Of 

this total, 371,660 kyd3 will be tailings, and 802,308 kyd3 will be waste and leach material. This will 

translate into 812,489 kyd3 of compacted volume in the pit. 

Total tonnage of material to be re-handled from the waste dump is 1,850 M-tons. Three shovel mining 

at a rate of 30 M-tons per year will require 21 years to complete the backfill requirement. 

The trucks will excavate the waste dump on 50 ft benches starting on the 5650 bench. The trucks will 

haul the material from the dump to the pit. The material will be end dumped at the pit rim until a pad can 

be established. The pad will be extended out to its entirety at that elevation. 50ft lifts will be placed 

above the 5050 elevation, up to the 5300 elevation. Overall slope on the waste above the pit rim is 2:1 

or 26 degrees. 

For safety reasons, it may be necessary to build this dump pad at a lower elevation in the pit, below the 

pit rim. This circumstance would increase the backhaul cycle times, and add costs that haven't been 

accounted for in the hauler estimates below. 

Figure 3: EXCAVATION AREA AND BACKFILL IN-PIT 

5 
 

 

 

 

 

 

 

 

 

Truck simulations were run on a haulage profile from the dump centroid to the 5050 elevation of the pit, 

as well as every 50 ft lift above the pit rim. The haulage routes chosen are shown in Figure 4. 

The haulage productivities are estimated to average 996 t/hr for all waste haul, and are used to 

estimate the total required trucks. 

For this scenario it is assumed that the shovels and trucks can work on the tailings material, benching it 

on 50ft. lifts. In the current design criteria, the haul trucks cannot operate on the tailings during the 

construction of this structure, so this criteria would have to change in order to excavate it out by truck 

and shovel. It may be necessary to mine the tailings material by another method, rather than truck and 

shovel. Possibly some sort of continuous mining method. 

Figure 4: HAULAGE FROM WASTE CENTROID TO BACKFILL DUMP 

6 
 

 

 

 

 

 

The required truck operating hours are summarized by year in Table 2. It is estimated that 19 trucks will 

be required for the entire backfilling project. 

Table 2:	 REQUIRED HAULAGE HOURS AND UNITS

Post Mining

Year

CAT 793C	Truck	Fleet

Oper. Hrs Units

1 84,436 19

2 84,436 19

3 84,436 19

4 84,436 19

5 84,436 19

6 84,436 19

7 84,436 19

8 84,436 19

9 84,436 19

10 84,436 19

11 84,436 19

12 84,436 19

13 84,436 19

14 84,436 19

15 84,436 19

16 85,976 19

17 85,994 19

18 85,994 19

19 85,994 19

20 82,399 19

21 82,399 19

22 82,399 19

Total 1,857,696 28

This option adds ~22 years of costs to the mining activities, thereby delaying the mine closure. It is also 

questionable as to whether the landscape has actually been improved. It may be necessary to reclaim 

the slopes on the backfilled material, thereby pushing the mine closure out even further. 

The dust level in re-handling the dry stack tailings would cause environmental issues that may have to 

be dealt with over the long term. 

This option also sterilizes any possible economic ore at the bottom of the pit that could potentially be 

mined in the future. 

7 
 

 

 

 

Reference files: 

• Productivity Estimates for Pit Backfill, no tails or leach.xlsx 

• Productivity Estimates for Pit Backfill, all material.xlsx 

• Rosemont Pit Backfill, no tails or leach 120418.fpc 

• Rosemont Pit Backfill, all materials, 120418 

8 

 
APPENDIX C 

ROSEMONT 

TECHNICAL 

MEMORANDUM 

A VOIDANCE OF 

WASP CANYON 

WASH 
 
ROSEMONT COPPEA 

Rosemont Copper Company 

To: Jamie Sturgess, Kathy .Atnold 

From: Fermin A. Samorano ­ Mine Manager 

CC: 

Date: September 1 , 2010 

Re: .Awoidance ofWasp Canyon Wash 

General Comments: 

During the review of the smaller pit alternative that entailed avoidance of Wasp Canyon, there were 

several mining related issues that had to be addressed. These issues were operational. safety, reserves, 

and logistics. For this evaluation we had Moose Mountain Ted'mical Services develop a Wasp Canyon 

Avoidance Pit and calculate lost mineral resources based on the current Sl. 75 pit shell. In addition, Tetra 

Tech researdl ed the flows into and around the affected area, and Call and Nicholas evaluated the new pit 

geom etrv and assodated stability issues. 

Mining Resources: 

In their evaluation, Moose Mountain Technical Ser\lices identified a loss of 87,295,000 tons of ore at a 

grade of 0.39% copper and 0. 018% molybdenum when oom pared to the Rosemont Copper Updated 

Feasibility study pit. The potential value of the sterilized metaI as approximated by Moose Mountain is 

USD $326,652,000 million (undiscounted), using $1. 75/lb oopper. 

At today' s prices, ranging from USD $3.30 to USD $3. SO, this would represent potential cash flow losses 

(undiscounted) of approximately USD $1.2 billion. 

The potential losses only takes into account the proven and probable reserves and does not indude 

inferred resources atthe USD Sl.75 pit shell or the additional resources available at higher copper prices. 

A detailed study of these resources is beyond the scope of this evaluation, but a lerchs Grossman run at 

different copper prices show the potential gain (Moose Mountain September 1, 2010 Memorandum). 

The loss of over 87 million tons of sulfide ore would result in an increase in the cost of the projed. The 

initial capital investment for amining project is substantial. and Rosemont is no exception with an initial 

capital cost of an estimated $897.2 million. The initial capital investment would be the same even with 

the smaller pit because the first six phases of mine development would be the same under both pit 

scenarios. The estimate of initial capital covers the first three years of mine development, whidl oa:urs 

within the first phase of development. For exam pie, the size ofthemill is dependent on daily throughput 

not total volume of ore, and the number of trud<s would bethe same because the first six phases and 

destinations of the smaller pit are identical to the proposed pit. 

The way that a large project becomes economically viable is to be able to amortize these significant 

capital costs over a commensurately substantial ore tonncge. With a fully-sized pit, the capital costs will 

be spread over the recovery of approximately 546 million tons of sulfide ore (proven and probable). for an 
ROSEMONT COPPEA 

estimated cost of approximately $1.64 per ton of sulfide ore. By redudng the volume of recovered sulfide 

ore by 87 mi Ilion tons, the per ton cost increases to approximately $1.95 per ton of sulfide ore, a 19% 

increase in the cost of production. 

Operations: 

Water m ancg em ent will still be a significant part of the mine operations in order to avoid operational 

delays and address any potential safety issues. Spedfi c:ally, the following projects will need to be 

im piem ented regardless of the size of the pit: 

1. Storm water diversion above the open pit. For this project we have designed two diversions that 

route the surface flows around the upgradient portion of the open pit to avoid flooding the 

operations during significant rain storms throughout the operations. 

2. 	 The development of drainages under the waste rock and dry stack landforms that keep water 

from ponding on the eastern and southern edges of the pit whi dl mav cause a saturation of the 

low-strength Willow Canyon arkose and allu\lium geologicformations. 

3. 	 Dewatering of the low-strength Willow Canyon arkose and alluvium from the 5,100 foot 

elevation to the 4,400 ft elevation along the eastern and southern edges of the pit. We have to 

start dewatering these critical areas before we startto mine in these units for stabilitv and 

safety. 

All three of these water mancg em ent projects are critical for pit slope stabilitv and safety, partiOJ larly on 

the southern and eastern portions of the pit where theWillow Canyon arkose and all u\li urn ocOJr. As 

shown in the attached memorandum by Call and Nicholas, this area of the pit has the I owest strength and 

therefore requires the shallowest slope angles. Of partiOJI ar importance to the stabilitv of this area of the 

pit is that it be dewatered down to the 4,400 ft elevation (Call and Nicholas, 2010). 

Because the dewatering of the Willow Canyon arkose and alluvium is so critical to the stability of that 

portion of the pit, development of the storm water diversion channel around the pit is also necessary. As 

shown in the attadled technical memorandum from Tetra tedl, construction of the designed storm water 

diversion channel will reduce flows in this area by approximately half (from 588 dsto 321 ds in the 100­

year/2~hour storm). resulting in a commensurate reduction in surface water volume (from 82.20to 

40.17 acre-feet in the 100-year /24-hou r storm event). 

In addition to the projects described above, additional infrastructure will need to be established within 

the Wasp Canyon area. During the development of the individual mine phases we will have three separate 

haul road crossings, avercging approximately 150ft in width, across Wasp Canyon to the waste rock 

dumps in Barrel Canyon. In addition, there are pipelines to and from the heap leadl, as well as a main 

power line and mine power line that will be constructed along theWasp Canyon haul road corridor (see 

Attached Figure). 

Summary: 

Avoiding Wasp Canyon significantly reduces the economics of the Rosemont Copper Project by limiting 

the recovery of proven and probable ore reserves. The estimate of the sterilization of the ore in the area 

does not include potential inferred resources. 
ROSEMONT COPPEA 

The avoidance of the wash does not change the operational requirements for the projed. We will still 

have to develop diversions dlannel s for routing water away from the operations, we will have to develop 

drainages for local waters around the pit edge and we will have to keep the Willow Canyon arkose and 

allu\liu m dewatered in this area to protect against high wall failure for the safety of the employees. 
 
N 


® 


SCALE 


1000' 0 1000' 2000' 


L.EGEtm 

EXISTING CONTOURS 

TOWNSHIP/RANGE LINE 

SECTION LINE 

PROPOSED CONTOURS 

PIA A 

1, 	 DESIGN OF THE PLANT SITE AND ASSOCIATED 

DIVERSIONS, PWTS POND, AND ACCESS ROADS 

COIAPLETED BY MJ ENGINEERING eli: TECHNOLOGY_ 

2. 	 DESIGN OF THE DRY STACK TAILINGS AND ASSOCIATED 

DIVERSIONS BY AMEC. 

J. 	 OPEN PIT OUTLINE BY MOOSE MOUNTAIN. 

11 

REVISION 

3031 Waot 1,.Road no.;

~ Tucaon, AriZDna 85741 

(520) 2117-ms (520) 297-772418x 	 01 

' Moose Mountain 

Technical Services · 

MEMORANDUM 


From: Bob Fang (M MTS) 

To: Fermin Samorano, Rosemont Copper 

Date: August 30, 201 0 

Re: Rosemont Copper - Address to Questions on Ultimate/Economic Pit, Updated 

September 1, 2010 

This memorandum addresses the questions in your August 91 h, 2010 email to me with 

respect to ultimate pit reserves, reserves that are restricted by the wasp Canyon, and 

other optimized pit resources. 

1. Development of Optimized Pit and Pit Reserves 

The floating cone, or Lerchs Grossman (LG, also known as Whittle), are open pit 

optimization methodologies that are accepted industry wide as a first approach to 

determining economic pit limits. 

The computer algorithm reads in economic parameters - metal price, metal recoveries, 

mining and process costs, and generates a pit shell on a 30 geology block model. This 

pit shell contains all incremental ore blocks that are economic based on the input 

parameters, and considers the overlying waste blocks that have to be stripped. Model 

blocks immediately outside this pit shell are deemed uneconomic. 

The limits of the potential pit can be restricted for non-economic reasons such as 

encroachment on infrastructure or avoidance areas. For the Rosemount ultimate pit, 

restrictions are applied to the west so that the potential pit wall does not extend beyond 

the top of the mountain ridge. 

An ultimate pit with ramp accesses, smooth pit walls and phase development is 

designed using the economic LG pit shell. A net smelter return value (NSR It) is 

calculated for each block in the 30 block model that is contained in the ultimate pit. This 

value represents the combined net metal value on per ton basis. A cut-off NSR value is 

established as the value of the block that is sufficient to pay for the plant process and G 

& A costs. For this project it was determined to be $3.56 It for sulfide ores and $2.19 It 

for oxide ores. Ore blocks that are equal or above these values are destined to the mill, 

and those below are designated as waste blocks destined to the waste disposal sites. 

The sum of the contained blocks that are above the cut-off NSR determine the ore 

reserves. 

Memo_Wasp Canyon Restricted Pit_Addendum Sept 1, 2010_Updated Page 1 
2. 	 Ultimate Pit Reserves and Comparison with Wasp Canyon 

Restricted Pit 

The reserves for the ultimate pit in the feasibility study and the pit restricted by the Wasp 

Canyon are summarized in Tables 1 and 2. (from Memo_Wasp Canyon Restricted PitRev2.pdf). Fig. 1 shows that the restricted pit is fully contained within the ultimate pit. 

The incremental difference is 87 M-tons of ore from the restricted pit to the ultimate pit, 

with an average NSR value of $12.69 It, well above the cut-off value. 

Table 1 Ultimate Pit Quantities 

IN SITU RUN OF WASTE ROM DILUTED DILUTED DILUTED DILUTED 

ORE MINE TOTAL S/R GRADE GRADE GRADE GRADE 

NSR 

(ktons) (ktons) (ktons) t/t ($/ton) TCU (%) MO(%) AG (oz/ton) 

Wasp Canyon Restricted Ultimate Pit 511,364 529,020 928,913 1.8 12.26 0.43 0.013 0.11 

Feasibility Ultimate Pit 595,302 616,315 1,231,171 2.0 12.32 0.42 0.013 0.11 

Differential 83,938 87,295 302,258 3.5 12.69 0.39 0.018 0.11 

Table 2 Ultimate Pit- Sulphide Ores 

SULPHIDE ORE 

RUN OF 

MINE 

(ktons) 

DILUTED 

GRADE 

NSR 

($/ton) 

DILUTED 

GRADE 

TCU(%) 

DILUTED 

GRADE 

MO(%) 

DILUTED 

GRADE 

AG (oz/ton) 

Wasp Canyon Restricted Ultimate Pit 

Feasibility Ultimate Pit 

459,058 

546,340 

13.54 

13.42 

0.46 

0.45 

0.014 

0.015 

0.12 

0.12 

Differential 87,282 12.75 0.39 0.018 0.11 

Memo_Wasp Canyon Restricted Pit_Addendum Sept 1, 2010_Updated 	 Page 2 
Revised Ultimate Pit with Wasp Canyon Restriction 

I MATE PIT FROM r:EASI81LITY :.TUDY 

3. Potential Pit Resources at Variable Copper Prices 

The feasibility study shows the analyses of the various potential pit limits tested against 

metal prices and costs scenarios (See Rosemont Pit Optimization MS-EP Summary, Oct 

24 08. XLS). Economic reserves will primarily be dependent on metal prices. The bases 

for the economic pit are $1.75 /lb Cu, $15.00 /lb Mo, and $10.00 /oz Ag. If long term 

metal prices do not decline significantly below these assumptions, the current pit design 

and reserves will remain economically viable. 

The potential economic pit is shown to be larger than the feasibility study designed pit if 

the restrictions on the west limits are removed. Therefore, the existing designed pit is 

constrained by physical limits, not necessarily economic limits. 

Additional LG optimized pits are generated with copper prices at $2.00 /lb, $2.50 /lb, and 

$3.00 /lb, to compare against the base case of $1.75 /lb used in the feasibility study. 

Other metal prices remain unchanged. Tables 3 and 4 summarize the total ore and 

sulfides, respectively. 

Also shown is the comparison of the designed ultimate pit compared to base case LG 

pit. The differences are due to pit wall smoothing and adding the in-pit haul road. 

Memo_Wasp Canyon Restricted Pit_Addendum Sept 1, 2010_Updated Page 3 
Table 3 Optimized Pits for Raised Cu Prices- Total Ore, ox and sulph 

RUN OF 

MINE 

(ktons) 

WASTE 

TOTAL 

(ktons) 

ROM 

S/R 

t/t 

DILUTED 

GRADE 

NSR ($/ton) 

DILUTED 

GRADE 

TCU (%) 

DILUTED 

GRADE 

MO(%) 

DILUTED 

GRADE 

AG 

(oz/ton) 

Designed Ultimate Pit 

Base Case LG $1.75/lb Cu 

LG $2.00 /lb Cu 

LG $2.50 /lb Cu 

LG $3.00 /lb Cu 

616,315 

640,405 

669,048 

711,486 

7 56,231 

1,231,171 

1,205,277 

1,229,188 

1,258,515 

1,391,481 

2.0 

1.9 

1.8 

1.8 

1.8 

12.32 

12.28 

13.54 

16.00 

18.41 

0.42 

0.42 

0.41 

0.40 

0.38 

0.013 

0.013 

0.013 

0.013 

0.012 

0.11 

0.11 

0.10 

0.10 

0.10 

Variance from Base Case LG $1.75 /lb Cu 

LG $2.00 /lb Cu 

LG $2.50 /lb Cu 

LG $3.00 /lb Cu 

28,643 

71,081 

115,826 

23,911 

53,238 

186,204 

0.8 

0.7 

1.6 

41.58 

49.53 

52.31 

0.18 

0.16 

0.17 

0.006 

0.006 

0.006 

0.05 

0.05 

0.05 

Table 4 Optimized Pits for Raised Cu Prices - Sulfide Ore Only 

Sulfide Ores 

RUN OF 

MINE 

(ktons) 

DILUTED 

GRADE 

NSR ($/ton) 

DILUTED 

GRADE 

TCU (%) 

DILUTED 

GRADE 

MO(%) 

DILUTED 

GRADE 

AG (oz/ton) 

Designed Ultimate Pit 

Base Case LG $1.7 5 /lb Cu 

LG $2.00 /lb Cu 

LG $2.50 /lb Cu 

LG $3.00 /lb Cu 

546,340 

568,466 

591,418 

622,281 

659,370 

13.42 

13.35 

14.76 

17.60 

20.29 

0.45 

0.45 

0.44 

0.43 

0.42 

0.015 

0.015 

0.014 

0.014 

0.014 

0.12 

0.12 

0.11 

0.11 

0.11 

Variance from Base Case LG $1.7 5 /lb Cu 

LG $2.00 /lb Cu 

LG $2.50 /lb Cu 

LG $3.00 /lb Cu 

22,952 

53,815 

90,904 

49.60 

62.42 

63.70 

0.20 

0.19 

0.19 

0.007 

0.007 

0.007 

0.06 

0.06 

0.05 

4. Economic Pit and Pit Phases 

As previously discussed in Part 1 of this document, the ultimate pit is designed around 

the selected economic pit shell from the pit optimization study. The financial analysis 

provided in the feasibility study document demonstrates that all reserves contained 

within the current ultimate pit design are economic. 

The ultimate pit is divided into pit phases for the purpose of providing an effective mining 

sequence and a balanced material schedule. In general terms, the mining sequence 

follows the order of the mining phases - Phase 1 is mined first, Phase 7 is mined at the 

end of the life of mine (LOM) production schedule. If the cashflow for the latter years of 

the LOM production schedule indicate negative cashflow, then Phase 7 would not be 

Memo_Wasp Canyon Restricted Pit_Addendum Sept 1, 2010_Updated Page 4 
economic. On the contrary, the cashflows are positive, and therefore Phase 7 contribute 

to the economics of the project. 

To further demonstrate the viability of the feasibility study ultimate pit, following is a brief 

economic analysis on the increment ore between it and the Wasp Canyon restricted pit. 

The reserves that would be sterilized by the Wasp Canyon restriction are analyzed in 

isolation, assuming that it is similar to Phase 7 of the ultimate pit as far as the timing of 

when it will be mined. 

A simplified net present value (N PV) calculation indicates a positive value for the 87 Mtons of incremental ore between the Wasp Canyon restricted pit and the ultimate pit. A 

production schedule for the incremental ore and waste is shown in Table 5. It is 

estimated that recovering the ore from this last increment would not commence until 

Year 17, with waste stripping five years in advance. Average costs are estimated from 

the LG inputs, and the revenues are estimated from the average NSR /t values of the 

calculated increment. These are design parameters and may not necessarily represent 

the actual economics that are used for the financial analysis. 

The positive discounted cashflow, both undiscounted ($326,652 k) and discounted 

($29, 166 k), demonstrate the economic viability of the incremental ore. 

Table 5 N PV 0 f 0 re StenT1zed under Wasp can yon 

Yr 12 Yr 13 Yr14 Yr15 Yr16 Yr 17 Yr 18 Yr 19 Yr 20 Yr21 Totals 

Ore, kton s 

Waste, ktons 564 63,361 61,866 51, 486 40,014 

2,296 

34,924 

27,376 

31,434 

27,376 

11714 

27,376 

4,369 

2,870 

2,525 

87,294 

302,258 

Revenue, k$ 

Costs, k$ 

Ore Mining 

Waste Mining 

0 re Process and 

G&A 

12.69 

1.51 

1.12 

3.56 

$/t 

$/t 

$/t 

$/t 

632 70,964 69,290 57,664 44,816 

29,141 

3,467 

39,115 

8,175 

347,400 

41,338 

35,206 

97,458 

347,402 

41,338 

13,120 

97, 459 

347,401 

41,338 

4,893 

97,459 

36,417 

4,333 

2,828 

10,216 

1,107,761 

131,814 

338,528 

310,767 

Cashflow, k$ 

Discount Rate 

NPVUndiscounted, k$ 

10% 

$326,652 

-632 -70,964 -69, 290 -57, 664 -44,816 -21,617 173,398 195,486 203,712 19,039 

NPV- Dtscounted, 

k$ $29,166 

Memo_Wasp Canyon Restricted Pit_Addendum Sept 1, 2010_Updated Page 5 
Reference documents: 

• Memo_ Wasp Canyon Restricted Pit-Rev2.pdf 

• Rosemont Pit Optimization MS-EP Summary, Oct 24 08. XLS 

• Filenote_Potential Ultimate Pit Expansion .PDF 

• LGs Results Aug 16-2010.xlsx 

Memo_Wasp Canyon Restricted Pit_Addendum Sept 1, 2010_Updated Page 6 
1.0 

Tucson Office 

3031 West Ina Road [1t;) Tucson, AZ 85741 TETRA TECH Tel 520.297.7723 Fax 520.297.7724 

W\111\N.Ietratech.com 

Technical Memorandum 

To: Fermin Samorano; Kathy Arnold 	 From: Monica Salguero 

Company: Rosemont Copper Company Date: August 19, 201 0 

Re: Rosemont Wasp Canyon Analysis Doc#: 219/10-320878-5.3 

cc: David Krizek, P.E. (Tetra Tech); Joel 

Carrasco 

Introduction 

This Technical Memorandum summarizes the methods and computations employed to perform 

the hydrological analysis of the wasp Canyon sub-basin at the proposed Rosemont Copper 

Project (Project) in Pima County, Arizona. The objective of this analysis was to assess the 

stormwater run-off response within the basin to a 1 00-year, 24-hour event associated with four 

(4) different scenarios as shown on Figures 1 through 4 in Attachment 1: 

• 	 wasp Canyon sub-basin as natural terrain (Figure 1 ); 

• 	 Wasp Canyon sub-basin with a Modified Pit configuration with the Open Pit Diversion 

Channel (Figure 2); 

• 	 wasp Canyon sub-basin with a Modified Pit configuration without the Open Pit 

Diversion Channel (Figure 3); and 

• 	 wasp Canyon sub-basin with the existing P673 Pit configuration and Open Pit 

Diversion Channel (Figure 4). 

Except for the scenario containing the existing pit configuration, P673 Pit, all scenarios were 

evaluated at a "downstream common point". Figure 1 shows the natural basin conditions without 

any Project development. Figure 2 shows this same elevation point (downstream common 

point) in the wasp Canyon sub-basin with a Modified Pit configuration and with the Open Pit 

Diversion channel. The Open Pit Diversion channel diverts stormwater away from the Open Pit 

and from the Wasp Canyon sub-basin and into Barrel Canyon. Figure 3 shows the Wasp 

Canyon drainage sub-basin without the Open Pit Diversion channel. In this case, more 

stormwater reports to both the Open Pit and to the Wasp Canyon drainage (i.e., the 

"downstream common point"). The "downstream common point" is the point where Wasp 

Canyon is blocked by the Rosemont Ridge Landform (Dry Stack Tailings/Waste Rock). 

Figure 4 shows the current P673 Open Pit outline and its interaction with Wasp Canyon. As 

shown, the final P673 pit configuration cuts through the Wasp Canyon drainage. For reference, 

the "downstream evaluation point" shown on Figures 1 through 3 is also indicated on Figure 4. 

The scenario shown on Figure 4 assumes construction of the Open Pit Diversion channel. Only 
[•11;) TETRA TECH 


a small remaining portion of the watershed remains in the upper portion of the Wasp Canyon 

sub-basin, reporting to the "upper Wasp Canyon point". 

2.0 Methodology and Precipitation 

The Natural Resource Conservation Service (NRCS) method was selected to perform the 

hydrologic calculations. The NRCS method described herein is based on two (2) components, 

the Curve Number procedure (to determine initial losses and excess precipitation) and the unit 

hydrograph method (to derive the hydrograph resulting from excess rainfall). 

HEC-HMS, developed by the U.S. Army Corps of Engineers, incorporates the NRCS method 

and was selected to determine the discharge resulting from the basins considered in this 

analysis. 

The NRCS has developed a widely used curve number procedure for estimating runoff from 

storm events. Rainfall initial losses depend primarily on soil characteristics and land use 

(surface cover). The NRCS method uses a combination of soil conditions and land use to assign 

runoff factors (curve numbers). Curve numbers represent the runoff potential of a soil type (i.e., 

the higher the curve number, the higher the runoff potential). 

A detailed discussion of the NRCS method can be found in the Technical Memorandum titled 

Rosemont Hydrology Method Justification (Tetra Tech, 2010). 

Precipitation data was acquired from the National Oceanic and Atmospheric Association 

(NOAA) Atlas 14 Point Precipitation website (NOAA, 2009). 

3.0 Hydrology 

The NRCS method was selected as the most appropriate for this level of analysis based on the 

information available and on the analysis expectations. 

3.1 Rainfall Excess 


The NRCS method determines rainfall runoff volume using the following relationship: 


Q= (P- 0.2S) 2 

P+0.8S 

Where, 


Q is the accumulated runoff volume in inches; 


P is the accumulated precipitation in inches, ( 1 00-year, 24-hour rainfall depth =4. 75"); 


1000 S is the maximum soil water retention parameter, (S = -10) in inches; and 

CN 

CN is the curve number. 

2 
3.2 

[•11;) TETRA TECH 


Curve Number 

The Curve Number selected for the contributing basin is 85 based on previous study. The initial 

abstraction used was 0.2S = 0.35". 

3.3 Lag Time 

The SCS lag time is defined as: 

T =Los(S+l)o7 

LAG 19005 

Where; TLAG= lag time, in hours; 

S= the maximum soil water retention parameter; 

L= hydraulic length, in feet; and 

Y= watershed slope in%. 

Table 1 summarizes the hydrologic basin parameters for the four (4) Wasp Canyon analysis 

scenarios. 

Table 1 Hydrologic Basin Parameters 

Wasp Canyon Sub-basin A (mi2

) 1 CN s L (ft) y (ftfft) Lag Time 

(min)2 

Natural Terrain 1.251 85 1.765 10228 9.0 34.61 

Modified Pit w/ Open Pit Diversion 

channel 0.240 85 1.765 5726 6.0 26.65 

Modified Pit w/o Open Pit Diversion 

channel 0.491 85 1.765 9732 10.0 31.56 

Current P673 Pit w/Open Pit 

Diversion channel 0.073 85 1.765 2444 6.5 12.96 

:<- £ .• ­

m1 -square miles, m1n- m1nutes 

4.0 Results 

Peak flow and the flow volume produced by the 100-year, 24-hour event was obtained from the 

hydrological analysis using the HEC-HMS and was applied to the four (4) scenarios. A summary 

of the results is shown in Table 2. Except for the current P673 Pit configuration, stormwater 

volumes and peak flows were taken at the "downstream common point" shown on the figures. 

Values for the current P673 Pit configuration were taken at the "upper Wasp Canyon point" as 

shown on Figure 4. 

3 
[•11;) TETRA TECH 

Table 2 Hydrologic Results 

Wasp Canyon Sub-basin Description Peak 

(cfs)3 

Volume 

(ac-ft)4 

Natural Terrain 1184 209.40 

Modified Pit w/Open Pit Diversion channel 321 40.17 

Modified Pit w/o Open Pit Diversion channel 588 82.20 

Current P673 Pit w/Open Pit Diversion channel 146 12.17 ~. ,

cfs-- cub1c feet per second, ac-ft-- acre-feet 

Detailed results from the HEC-HMS model output are provided in Attachment 2. 

4 
[•11;) TETRA TECH 


REFERENCES 

VenTe Chow, D.R. Maidment, L.W. Mays Applied Hydrology. McGraw Hill, 1988. 

National Oceanic and Atmospheric Administration (NOAA), NOAA Atlas 14 - Precipitation 

Frequency Atlas of the United States. Website: http://hdsc.nws.noaa.gov, Visited June 

11,2009 

Tetra Tech Chee, R., and Hemmen, G. (2010). Rosemont Hydrology Method Justification. 

Technical Memorandum to Kathy Arnold (Rosemont Copper Company). Technical 

Memorandum dated January 27, 2010. 

5 
 
ATTACHMENT 1 

 
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! WASP CANYON SUB-BASIN ANALYSIS b
 TETRA TECH NATURAL TERRAIN REWOON 

~ 3031 Wast: Ina Road 

Project: Figure no.: Tucoon, A~....., 85741 

(52D) 

2B7-mS (520)21!7-m4fax ROS EMO NT CO PPER PR

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Issued by : 

~-~ ~ WASP CANYON SUB B 1\ TETRA TECH MODIFIED ,;;/~:~/NALYsls a '- (~ / "11::: ,,::::~,.::;;: ''"'"ct' OPEN PIT DIVERSION CHANNEL "~""' \ V (520)297-mS (520)2117-mHax ROSEMO NT CO PPER PROJECT Figure no.: 

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TETRA TECH 

3031 Wast Ina Rood 

Tucoon, A~....., 85741 

(52D) 297-ms (520) 2117-mHax 

WASP CANYON SUB-BASIN ANALYSIS 

MODIFIED PIT WITHOUT 

OPEN PIT DIVERSION CHANNEL 

Project: 

ROSEMO NT COPPER PROJECT 

Locatfon: 

PIMA COU NTY, ARI20fiA 

Date: 

08/10 

Figure no.: 

3 

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RE\r190N 

ATTACHMENT 2 

 
Project: Was Canyon Analysis 

Simulation Run: Run Natural Terrain Subbasin: Subbasin Natural Terrain 

Start of Run: 13Aug2010, 12:00 Basin Model: Basin Natural Wasp 

End of Run: 15Aug2010, 12:05 Meteorologic Model: Met 1 

Compute Time: 19Aug2010, 10:21:04 Control Specifications: Control 1 

Volume Units: AC-FT 

Computed Results---------------------------.. 

Peak Discharge : 1404.39 (CFS) Date!Time of Peak Discharge : 14Aug2010, 00:30 

Total Precipitation : 316.92 (AC·FT) Total Direct Runoff: 209.53 (AC·FT) 

Total Loss: 107.39 (AC·FT) Total Baseflow: 0.00 (AC·FT) 

Total Excess : 209.53 (AC-FT) Discharge: 209.53 (AC·FT) 
Project: Was Canyon Analysis 

Simulation Run: Run With Pit Channel Subbasin: Subbasin w/ Pit Chnnl 

Start of Run: 13Aug2010, 12:00 Basin Model: Basin Modif Pit with Chn 

End of Run: 15Aug2010, 12:05 Meteorologic Model: Met 1 

Compute Time: 17Aug2010, 11 :08:48 Control Specific at ions: Control 1 

Volume Units: AC-FT 

Computed Results-------------------------­

Peak Discharge : 320.60 (CFS) Date/Time of Peak Discharge : 14Aug2010, 00:20 

Total Precipitation : 60.77 (AC-FT) Total Direct Runoff: 40.17 (AC-FT) 

Total Loss: 20.59 (AC-FT) Total Baseflow : 0.00 (AC·FT) 

Total Excess : 40.17 (AC-FT) Discharge: 40.17 (AC-FT) 
Project: Was Canyon Analysis 

Simulation Run: Run Wasp Without Pit Channel Subbasin: Subbasin w/o Pit Chnnl 

Start of Run: 13Aug2010, 12:00 Basin Model: Basin Moidf Pit NO Chann 

End of Run: 15Aug2010, 12:05 Meteorologic Model: Met 1 

Compute Time: 19Aug2010, 10:20:59 Control Specifications: Control 1 

Volume Units: AC-FT 

Computed Results-------------------------­

Peak Discharge : 587.53 (CFS) Date/Time of Peak Discharge : 14Aug2010, 00:25 

Total Precipitation: 124.33 (AC·FT) Total Direct Runoff: 82.20 (AC-FT) 

Total Loss: 42. 13 (AC·FT) Total Baseflow : 0.00 (AC·FT) 

Total Excess : 82.20 (AC·FT) Discharge: 82.20 (AC·FT) 
Project: Was Canyon Analysis 

Simulation Run: Run Original Pit Subbasin: Subbasin Original Pit 

Start of Run: 13Aug2010, 12:00 Basin Model: Basin Original Pit Position 

End of Run: 15Aug2010, 12:05 Meteorologic Model: Met 1 

Compute Time: 17Aug2010, 11:08:35 Control Specifications: Control 1 

Volume Units: AC-FT 

Computed Results-------------------------­

Peak Discharge : 146.11 (CFS) Dateffime of Peak Discharge : 14Aug2010, 00:05 

Total Precipitation : 18.41 (AC-FT) Total Direct Runoff: 12.17 (AC-FT) 

Total Loss: 6.24 (AC·FT) Total Baseflow : 0.00 (AC·FT) 

Total Excess : 12.17 (AC-FT) Discharge: 12.17 (AC-FT) 
CALL & NICHOLAS, INC. 

2475 N. Coyote Drive 

Tucson, Arizona 85745 U.S.A. 

Tel: 

Fax: 

E-Mail: 

520 .670.9774 

520.670.9251 

cni@cnitucson.com 

MEMORANDUM 

To: 	 Mr. Fermin Samorano I Rosemont Copper Company 

From: 	 Mr. Robert Pratt, P.E. 

Mr. David Nicholas, P.E. 

Date: 23 August 20 10 

Subject: Rosemont Wasp Canyon Restricted Pit Slope Stability 

This memorandum presents results ofCall & Nicholas, Inc.'s (CNI) review of Rosemont 

Copper Company's Wasp Canyon restricted ultimate pit. This pit was constructed with the 

limitation of avoiding disruption to Wasp Canyon, which has resulted in an offset ofthe ultimate 

pit crest on the southeastern side ofthe pit, as shown on Figure 1. The remaining portion ofthe 

pit is unchanged from the original feasibility pit design. CNI reviewed modifications to the pit 

for any potential slope stability issues. 

The geology projected onto the Wasp Canyon restricted pit is similar to that ofthe 

nonrestricted ultimate pit, and therefore slope stability issues will not change from those 

identified as part ofCNI's feasibility study (Feasibility-Level Geotechnical Study for the 

Rosemont Deposit, February 2008). No change is needed to the interramp slope angles 

recommended for the southeast wall as part ofCNI's 2008 feasibility study (28 degrees for the 

alluvium, 33 to 35 degrees for Willow Canyon, and 45 to 48 degrees for Paleozoic rocks in the 

lower portion ofthe slope). These slope angles were determined based on typical mine design 

criteria. 

Due to the easterly dip ofthe Paleozoic rocks and change in pit location, the height ofthe 

upper alluvium and Willow Canyon slope decreases , as shown on Figure 2. This reduction in 

height ofthe upper portion ofthe slope in relatively low-strength materials is expected to 

improve the slope design reliability. It may also be possible to steepen the slope angle while 

maintaining slightly lower, but acceptable slope-design reliability typical for mine slopes. 

Geological Engineering Slope Stability Rock Mechanics 
Rosemont Copper Company I F. Samorano 23 August 20 1 0 

Rosemont Wasp Canyon Restricted Pit Slope Stability Page 2 

The primary issue with respect to slope stability in the southeastern portion ofthe pit will 

be the success of dewatering efforts. To stabilize the upper portion ofthe slope, which consists 

ofrelatively low-strength Willow Canyon arkose and alluvium (Figure 2), dewatering from the 

5,100-foot level to an elevation of approximately 4,400 feet will be required to achieve slope 

angles recommended as part ofCNI's feasibility study. 

CNI recommends future reevaluation of final pit slope angles in the alluvium and Willow 

Canyon slopes after the startup ofmining. Slope angles determined for these materials are based 

on a nominal amount of information obtained from drill cores. With data gathered from mine 

benches, an improved assessment ofslope angles could be performed. CNI also recommends 

pump testing and an evaluation of dewatering feasibility in the southeastern alluvium. 

CALL & NICHOLAS, INC. 

( 1"=800') 

D OVERBURDEN/ ALLUVIUM • ANDESITE 

D EPITAPH DO LOMITE 0 ARKOSE WILLOW CANYON FO RMATIO N 

D CO LI NA LI MESTONE D CON CHA LI MESTONE WASP CANYON CALL & NICHOLAS, INC. D EARP FORMATION D ABRIGO FORMATION RESTRICTED PIT TUCSON, ARJZONA USA D HORQU ILLA LI MESTONE D BOLSA QUARTZITE 

D ESCABROSA LIMESTONE 0 PRECAMBRIAN GRANITE MAP 

D MARTIN FORMATION D GLANCE CONGLOMERATE 

D QTZ MONZONITE PORPHYRY 

1 

5000 E 

1715229 E 

11554409N 

0 OVERBURDEN/ AL LUVIUM D QTZ MONZONITE -- CURRENT TOPOORAPHY 

D COLINA LIMESTONE D GLANCE CONG LOMERATE - - WASP CANYON RESTRICTED PIT CALL & NICHOLAS, INC. 0 D EARP FORMATION -- 2032 ULTI MATE PIT 

TUCSON, ARJWNA USA ~ [:=J HORQUILLA LI MESTONE 

':1 D ESCABROSA LI MESTONE 

• ANDESITE 


D ARKOSE WILLOW CANYctJ FORMATION 
 A
 
B. Mitigation and Monitoring Plan

(includes U.S. Army Corps of Engineers’ 

Habitat Mitigation Plan)

Final Environmental Impact Statement for the Rosemont Copper Project B-1

B. Mitigation and Monitoring Plan

Mitigation and Monitoring Plan

Introduction

This mitigation and monitoring plan has been developed by the Coronado National Forest (the 

Coronado) interdisciplinary team (ID team), using information from a number of sources. Since 

release of the draft environmental impact statement (DEIS), mitigation and monitoring have been 

reviewed and updated to include additional details on: the impacts being mitigated; whether the 

mitigation measure is meant to avoid, minimize, reduce, rectify, or compensate for impacts; 

monitoring actions; effectiveness criteria; timing; responsible party; and to which alternatives the 

items are applicable. In addition, a number of mitigation and monitoring items have been added since 

release of the DEIS.

As stated in chapter 2 of the final environmental impact statement (FEIS), the Council on 

Environmental Quality (CEQ) states that agencies should not commit to mitigation measures absent 

the authority or expectation of resources to ensure the mitigation is performed (Council on 

Environmental Quality 2011). This mitigation and monitoring plan is designed to clearly disclose 

which mitigation and monitoring items are within the authority of the U.S. Forest Service (Forest 

Service) or other regulatory permitting agency (such as the U.S. Army Corps of Engineers (USACE), 

Arizona Department of Environmental Quality (ADEQ), Arizona Department of Water Resources 

(ADWR), etc.). To that end, this mitigation and monitoring plan is organized as follows.

Mitigation and Monitoring – Forest Service – The role of the Coronado under its primary 

authorities in the Organic Administration Act, Locatable Regulations (36 Code of Federal Regulations 

(CFR) 228 Subpart A), and Multiple-Use Mining Act is to ensure that mining activities minimize 

adverse environmental effects on National Forest System (NFS) surface resources. The Coronado 

may impose reasonable conditions to protect surface resources but cannot materially interfere with 

reasonably necessary activities under the General Mining Law that are otherwise lawful. The Forest 

Service authority related to mitigation is limited to protection of surface resources of NFS lands (see 

30 United States Code (U.S.C.) 612, 5 U.S.C. 551, and 36 CFR Part 228.1). In order for the Forest 

Service to require implementation of mitigation, the mitigation must have a direct connection to 

avoiding, mitigating, or minimizing effects on NFS surface resources. The Forest Service has no 

authority, obligation, or expertise to determine or enforce compliance with other agencies’ laws or 

regulations. The Forest Service seeks to coordinate with other agencies to approve a legally compliant 

final mine plan of operations (MPO). However, it is the operator’s responsibility to ensure that its

actions comply with applicable laws. 

Mitigation and monitoring items under this heading are within the authority of the Forest Service,

U.S. Fish and Wildlife Service (USFWS) through the current biological opinion, or Arizona State 

Historic Preservation Office (SHPO) through the current memorandum of agreement (MOA). They 

would be specified as a requirement of the record of decision (ROD) and incorporated into the final 

MPO. This category includes mitigation measures and associated monitoring items that would help to 

minimize impacts to Forest Service surface resources; or are required by the USFWS biological 

opinion, the MOA with the Arizona SHPO and associated historic properties treatment plan (HPTP).

The Forest Service is responsible for overseeing implementation of the mitigation and monitoring in 

this category. It has the regulatory responsibility to do so for those measures that minimize impacts to 

Forest Service surface resources, and it has a legal obligation to ensure that the requirements of the 

biological opinion and MOA/HPTP are implemented. The Forest Service is responsible for 

determining whether the implementation of mitigation and the results of monitoring in this category 

are in compliance with the decision that will be documented in the ROD and in compliance with the 

final MPO.

Final Environmental Impact Statement for the Rosemont Copper Project B-3
B. Mitigation and Monitoring Plan

Mitigation and Monitoring – Other Regulatory and Permitting Agencies – Mitigation and 

monitoring items under this heading are within the authority of other regulatory permitting agencies, 

including the ADEQ and ADWR. The Forest Service has no authority, obligation, or expertise to 

determine or enforce compliance the measures included in this category. They are presented here to 

facilitate disclosure of currently known mitigation and monitoring and their consideration in impacts

analyses. The mitigation and monitoring measures in this category include permit requirements and 

stipulations from legally binding permits and authorizations such as the air quality permit, aquifer 

protection permit, and groundwater withdrawal permit. Many of these permits have already been 

issued. Some of them will be modified following the approval of the ROD. For example, the aquifer 

protection permit was issued in 2012. It will be modified based on the alternative selected in the 

ROD. The mitigation and monitoring related to the aquifer protection permit and other permits that 

are described in this appendix are based on the existing permits as issued and on similar permits for 

those that have yet to be issued. As mentioned, these mitigation and monitoring items may be 

modified post-ROD to more accurately reflect the selected alternative. These regulatory and 

permitting agencies would share monitoring results and any instances of noncompliance with the 

Forest Service. The Forest Service would use the information provided by the regulatory and 

permitting agencies to determine compliance with the decision that would be documented in the ROD 

and compliance with the final MPO.

Mitigation and Monitoring Measures – Rosemont Copper – Rosemont Copper Company 

(Rosemont Copper) has publicly agreed to implement the mitigation and monitoring items under this 

heading. These include contractual, financial, and other agreements over which the Forest Service 

and other regulatory agencies have no jurisdiction. The Forest Service and regulatory agencies have 

no authority, obligation, or expertise to determine or enforce compliance the measures included in 

this category. They are presented here to facilitate disclosure of currently known mitigation and 

monitoring and their consideration in impacts analyses. Since the Forest Service and regulatory 

permitting agencies cannot require implementation of the mitigation and monitoring measures in this 

category, their implementation is not assured. While the effectiveness of these mitigation measures is 

included in chapter 3 of the FEIS, environmental impacts are addressed as measures that may occur, 

as opposed to measures that would occur, unless otherwise noted.

Potential Future Mitigation Measures – The mitigation and monitoring measures listed under this 

heading have been suggested, and Rosemont Copper has expressed interest in implementing these 

items. However, development of these measures has not progressed to the point that adequate details 

are available with which to determine their effectiveness in avoiding, reducing, or compensating for

impacts. While these mitigation and monitoring items may eventually be implemented, they are not 

considered in the determination of mitigation effectiveness disclosed in chapter 3 of the FEIS.

Monitoring measures described in this plan are primarily addressed as either implementation

monitoring or effectiveness monitoring. Implementation monitoring is primarily focused on 

determining whether a mitigation measure or requirement has been implemented in accordance with

the FEIS, ROD, final MPO, or pertinent permit. Effectiveness monitoring is primarily focused on 

determining whether the results of implementing the mitigation measure or requirement achieve the 

results predicted in the FEIS, upon which the ROD and final MPO are based, and whether they 

comply with applicable laws and regulations.

B-4 Final Environmental Impact Statement for the Rosemont Copper Project
B. Mitigation and Monitoring Plan

A number of supporting documents and permits contain detailed information on mitigation or 

monitoring requirements. In order to avoid repetition, the following documents are incorporated by 

reference in their entirety:

• HPTP;

• Habitat mitigation and monitoring plan;

• Aquifer protection permit, issued by ADEQ; 

• Air Quality Class II Synthetic Minor Permit (air quality permit), issued by ADEQ;

• Arizona Pollutant Discharge Elimination System permit (stormwater permit), including 

stormwater pollution prevention plan; authorization issued by ADEQ;

• Mineral Extraction and Metallurgical Processing Groundwater Withdrawal Permit issued by 

ADWR;

• “Rosemont Copper Project Light Pollution Mitigation Recommendation Report” (Monrad 

et al. 2012b);

• USFWS current biological opinion (contained in appendix F of this FEIS);

• USACE Clean Water Act (CWA) habitat mitigation and monitoring plan, based on the 

conceptual habitat mitigation and monitoring plan summary that is presently available 

(included in this appendix), as well as the final habitat mitigation and monitoring plan that is 

not yet available and has not yet been approved by USACE; 

• Arizona Corporation Commission (ACC) Certificate of Environmental Compliance (CEC) 

issued to Tucson Electric Power Company (TEP) for power supply line (Decision No. 73232 

and Amendment 1, dated June 12, 2012);

• MOA (prepared under Section 106 of the National Historic Preservation Act) (contained in 

appendix D of this FEIS);

• Protection Program Master Agreement, dated December 1, 2009, recorded in the Pima 

County Recorder’s Office on January 15, 2012, Recorder’s Sequence No. 20100100153, as 

amended by Amendment No. 1, dated December 17, 2010, recorded in the Pima County 

Recorder’s Office on February 10, 2010, Recorder’s Sequence No. 20110410243; together 

with the individual Rosemont Copper Residential Well Protection Program Well Owner 

Agreements (private, direct contractual agreements with well owners);

Well Protection Program Master Agreement, dated June 19, 2012, originally recorded in the Pima 

County Recorder’s Office on June 20, 2012, Recorder’s Sequence No. 20121720146, and rerecorded 

to correct a clerical error on July 25, 2012, Recorder’s Sequence No. 20122070247; together with the 

individual Rosemont Copper Residential Well Protection Program Well Owner Agreements (private, 

direct contractual agreements with well owners).

It is important to note that there are a number of plans and permits that would contain additional 

details pertaining to mitigation and monitoring that would not be completed until after approval and 

issuance of the ROD. Many of these plans and permits are specific to the alternative selected for 

implementation and therefore cannot be fully developed prior to approval of the ROD. The mitigation 

and monitoring items contained in these plans and permits would be required as a permit requirement 

of a regulatory permitting agency, and their implementation and permit compliance would be the 

responsibility of the applicable regulatory agency.

Reporting and Evaluation – Monitoring would be evaluated annually after reports are reviewed to 

determine whether the level of monitoring and or reporting is appropriate for the current conditions. 

This review may result in a change in the monitoring requirements. Please refer to chapter 2 of this 

FEIS for a discussion of monitoring reporting and evaluation. 

Final Environmental Impact Statement for the Rosemont Copper Project B-5
B. Mitigation and Monitoring Plan

Mitigation and Monitoring – Forest Service

The mitigation and monitoring in this section would be required by the Forest Service and included in 

the ROD and final MPO. These measures are either designed to mitigate impacts to Forest Service 

surface resources or are components of either the USFWS biological opinion or the Arizona SHPO 

MOA. The Coronado has the responsibility to monitor implementation of the terms and conditions of 

the biological opinion and MOA. Note that Rosemont Copper would be required to comply with the 

current USFWS biological opinion dated October 30, 2013, and any revised or supplemental 

biological opinions in effect for the project. The same is true for the MOA with the Arizona SHPO, 

which was signed by the Forest Service on October 22, 2013. Rosemont Copper shall notify the 

Coronado of actions that do not comply with requirements of the applicable biological opinion. 

The current biological opinion is contained in appendix F of the FEIS, and the MOA is contained in 

appendix D. 

Implementation of the mitigation measures in this section is mandatory and required by law or 

regulation. Impacts analyses are disclosed in chapter 3 of the FEIS. The effectiveness of the 

mitigation measures in this section has been evaluated in the impacts analyses and considered in the 

determining of predicted impacts. Refer to the chapter 3 impacts analyses for further detail.

B-6 Final Environmental Impact Statement for the Rosemont Copper Project
Geology, Minerals, and Paleontology

FS-GMP-01 – Upon discovery of paleontological resources, suspension of operations pending Forest Service revie

Element Description

Description Upon discovery of significant paleontological resources, Rosemont Copper would suspend work at that site and t

investigated by the appropriate personnel before work resumes. The designated Forest Service representative wou

the investigation with appropriate Forest Service or other specialist. Significant fossils may be recovered.

Source Coronado ID team.

Impacts Mitigated Compensates for significant impacts to paleontological resources by allowing data to be gathered and evaluated. R

and documentation of significant paleontological resources, should they be found during operations.

Location Includes all areas with surface disturbance on NFS lands.

Monitoring / Reporting 

Action

Implementation: Rosemont Copper would conduct visual inspections when conducting ground-disturbing activi

significant paleontological resources, Rosemont Copper would suspend work at that site and notify the Forest Ser

would be investigated by the Forest Service before work resumes.

Effectiveness: Should paleontological resources be discovered, work suspended, and subsequent investigation co

Service would conduct an “after action review” to determine whether visual inspections, reporting, and data colle

effective in achieving desired results.

Performance Criteria Implementation and Effectiveness: Upon discovery of significant paleontological resources, Rosemont Copper 

that site and contact the designated Forest Service representative to investigate the discovery before work is reinit

Responsible Party Implementation and Effectiveness: Rosemont Copper is responsible for monitoring ground-disturbing activities 

significant paleontological resources and for suspending operations at the site of such discovery and notifying the 

The Forest Service is responsible for investigating in a timely manner any significant paleontological resources th

the Rosemont Copper operational suspension period is minimized.

Timing Implementation and Effectiveness: Premining through active mining phases, when initial ground disturbance w

Applicable Alternatives All action alternatives.

FS-GMP-02 – Upon discovery of a cave or sinkhole, suspension of operations pending Forest Service review

Element Description

Description Upon indication or discovery of a cave or sinkhole, Rosemont Copper would suspend work at that site and contac

Service representative to investigate the discovery before work is reinitiated. The designated Forest Service repre

promptly coordinate the investigation with appropriate agency resource specialists. Any natural void in rock that 

human to enter constitutes a cave. Any collapse feature in or over carbonate rock constitutes a sinkhole.

Source Coronado ID team.

Impacts Mitigated May compensate for impacts to cave by allowing data to be gathered and evaluated. Requires investigation and d

significant cave or sinkhole, should they be found during operations.

Location Includes all areas with surface disturbance on NFS lands.

Final Environmental Impact Statement for the Rosemont Copper Project

B-7
Element Description

Monitoring / Reporting 

Action

Implementation: Visual inspections by Rosemont Copper when conducting ground-disturbing activities to deter

or sinkhole has been discovered. Upon discovery of such resources, Rosemont Copper would suspend work at tha

Forest Service, and the site would be investigated in the same 24-hour period by the Forest Service before work r

Effectiveness: Should a cave or sinkhole be discovered, work suspended, and subsequent investigation conducted

would conduct an “after action review” to determine whether visual inspections, reporting, and data collection/ev

in achieving desired results.

Performance Criteria Implementation: Visual inspections by Rosemont Copper would be conducted when performing ground-disturb

Effectiveness: Upon discovery of cave or sinkhole, Rosemont Copper would suspend work at that site and contac

Service representative to investigate the discovery before work is reinitiated.

Responsible Party Implementation: Rosemont Copper is responsible for conducting monitoring and reporting to the Forest Service

Effectiveness: Rosemont Copper is responsible for suspending operations and notifying the Forest Service, shou

or sinkhole occur. The Forest Service is responsible for conducting investigation that in a timely manner within th

so that the Rosemont Copper operational suspension period is minimized.

Timing Implementation and Effectiveness: Premining through final reclamation and closure phases. 

Applicable Alternatives All action alternatives.

Soils and Revegetation

FS-SR-01 – Growth media salvage and application

Element Description

Description Soil would be salvaged in accordance with the final reclamation and closure plan. This plan would also specify w

growth media would be stored and where and how it would be applied on tailings and waste rock facilities and ot

order to facilitate revegetation of mine related disturbance. Hill slopes would be monitored for erosion. Conserva

terms and conditions related to known lesser long-nosed bat roost protection measures would be followed. 

Source This is a design feature that was contained in the preliminary MPO and further refined in the “Preliminary Soil Sa

Plan: Rosemont Copper Company, July 2012, Rosemont Copper Project, Barrel Alternative” (CDM Smith 2012b

aspects were subsequently required by the Coronado. Final specifications would be developed and included in the 

selected action. The biological opinion specifies that conservation measures to protect lesser long-nosed bat roost

conservation measures and/or terms and conditions for lesser long-nosed bat). Certain erosion control techniques 

under the stormwater pollution prevention plan.

Impacts Mitigated Would provide substrate for improving the success of revegetation efforts; would enhance soil function and stabi

would promote revegetation and reduce impacts to surface water quality from potential erosion; and would reduc

resources.

Location All disturbed areas for salvage; waste rock and tailings facilities for growth media application. Includes linear fea

and pipelines and stormwater diversion structures. 

B-8 Final Environmental Impact Statement for the Rosemont Copper Project
Element Description

Monitoring / Reporting 

Action

Implementation: Weekly visual inspections during soil (growth media) salvage and storage activities to ensure c

specifications in final MPO, with results reported quarterly; visual inspections of recently reclaimed areas after si

(0.5 inch or greater precipitation within 24-hour period) to determine whether there are signs of accelerated erosio

stabilization. Rosemont Copper would determine soil texture soil surface particle size of growth media at the time 

placed on the surface of the waste rock. Quarterly, Rosemont Copper would provide geographic information syst

on the approximate areas where growth media was placed, as well as soil texture, surface particle size, and chemi

media in these areas. A final reclamation and closure plan would be developed by Rosemont Copper and approve

prior to issuance of the final MPO. 

An adaptive management approach (Williams et al. 2009) would be used to set and refine techniques for revegeta

Refinement of techniques would be based on monitoring and evaluation of data collected on revegetated sites, ref

plots under the guidance of a monitoring group composed of Forest Service and other experts. Rosemont Copper 

would use National Resources Conservation Service Ecological Site Descriptions to identify comparable referenc

the vicinity of the mine. Success criteria would be expressed as a percent similarity of revegetated sites, compare

Success criteria would be based on quantitative monitoring results and statistical analyses/comparisons of results 

test plots, and ongoing site monitoring of previously reclaimed areas. Texture of growth media would be defined 

Department of Agriculture soil classification system. Monitoring of growth media, soil stability, and site characte

areas, test plots, and previously revegetated areas would provide quantifiable results and set up a data feedback lo

adjust techniques and objectives by the monitoring group and to determine whether changes are needed in growth 

preparation, soil amendments, soil mycorrhizal inoculation, or other characteristics. 

Effectiveness: Soil stability measurements may include measurements of: soil surface particle size, litter and bas

water flow patterns, pedestals/terracettes, gullies, wind-scoured areas, soil surface loss or degradation, plant comm

relative to infiltration and runoff, soil surface aggregate stability, and soil compaction (Pellant et al. 2005). Recla

results would be statistically compared with reference plot results to determine whether objectives are being met. 

measurements across the reclaimed sites would be required to detect the presence of rills and gullies and to quant

Adaptive management adjustments would be assessed to ensure their compliance with the current National Envir

(NEPA) decision; supported by monitoring data results; and documented in the project monitoring and evaluation 

monitoring of sediment buildup in flow channels and removal of sediment if necessary to maintain adequate flow 

control would be implemented in accordance with the stormwater permit and stormwater pollution prevention pla

Final Environmental Impact Statement for the Rosemont Copper Project

B-9
Element Description

Performance Criteria Implementation: Growth media would be salvaged, stockpiled and placed in accordance with the final MPO in a

mining operations that are stable, isolated from surface water, and gently sloping and well drained. Growth media 

convex in shape and would have slopes no steeper than 3:1. Stockpiles would be revegetated with native species 

growth season following the premining phase. Sediment control structures would be installed and other best man

implemented as needed to protect growth media from loss (wind or rain runoff).

Placement of growth media and revegetation efforts would be implemented concurrently with reclamation efforts

would be contoured, graded, prepared, and seeded and/or planted in accordance with the final reclamation plan. 

Specifications and goals for the salvage, storage, and reuse of growth media from disturbed areas would be devel

providing sufficient cover on all disturbed areas to be reclaimed. Additional treatments to stabilize soils, soil ame

mycorrhizal inoculations may be considered pending monitoring results. Monitoring results would be used to det

additional mitigation measures are needed to enhance plant success on growth medium types or to improve soil s

Revegetated areas would have diverse and permanent vegetative cover composed of species and cover amounts s

vegetation in the area (Forest Service 2008b). Revegetated shrub and tree plantings would be scattered across the 

random/patchy distribution to mimic natural vegetation patterns on adjacent undisturbed areas. 

Available, onsite woody debris from clearing of the mine site would be used on the reclaimed growth medium su

stability, organic matter, and microhabitats for seed germination, invertebrates, and small vertebrate species. Den

would meet guidelines that are portrayed in the draft Coronado forest plan.

Should soil texture, surface particle size, or soil stability not meet revegetation objectives of the final reclamation 

appropriate site-specific measures would be developed by Rosemont Copper in cooperation with the Coronado. M

additional soil being placed onsite, soil amendments, soil stability measures, or other prescribed treatments. Erosi

required to comply with any requirements of the stormwater permit and stormwater pollution prevention plan.

Effectiveness: Slopes with growth media placement would contain a minimum of 1 foot of cover and would be s

results would show no signs of unacceptable soil movement as determined in comparisons with reference sites, ec

descriptions, test plots, and previously revegetated reclamation areas. Growth media would be sufficient to ensure 

planting would be successful in establishing desired plant species and communities in location zones specified in 

plan. Growth media texture, surface particle size, and soil stability measurements would meet interim and final re

revegetation objectives of the final reclamation and closure plan. Sediment channels would maintain design capac

adequate movement of stormwater.

Responsible Party Implementation and Effectiveness: The Forest Service is responsible for monitoring the implementation of any 

mitigation that are specified as requirements of the USFWS biological opinion. Rosemont Copper would be respo

monitoring and reporting to the Forest Service on a quarterly basis. The Forest Service is responsible for establish

determine whether the growth media is sufficient to support revegetation objectives of the final reclamation and c

stability requirements; and to spot check revegetation success and soil stability on NFS lands throughout the year

would conduct annual (at a minimum) site inspections to review monitoring results in cooperation with Rosemon

whether success criteria have been met and the cause for better or worse results than predicted; if data (from refer

and revegetated plots) indicate the need for adjustments to growth medium or soil amendments, seed/plant applic

preparation, determine whether acceptable soil stability has been achieved; and determine the need for additional 

for more successful revegetation and increased soil stability. The Forest Service would evaluate monitoring resul

document compliance with NEPA decision and effectiveness of mitigation.

B-10 Final Environmental Impact Statement for the Rosemont Copper Project
Element Description

Timing Implementation: Monitoring would begin when salvage of soil (growth media) begins and continue until the Fo

that no further reclamation efforts (seeding, planting, site stabilization, etc.) are necessary to meet final objectives 

the Forest Service at the time of the mine closure. Activities near known lesser long-nosed bat roosts would occu

nosed bats are not present, typically during the period from November 1 to July 1 each year.

Effectiveness: Monitoring would begin when salvage of soil (growth media) begins to ensure that storage pile(s) 

contribute large quantities of dust during wind events; continuing through placement of growth media to ensure th

accordance with the final reclamation plan, and does not erode excessively.

Applicable Alternatives All action alternatives; areas having growth media applied differ with some alternatives. Refer to alternative desc

further information. 

FS-SR-02 – Revegetate disturbed areas with native species

Element Description

Description Includes efforts to establish native grasses, forbs, shrubs, and trees on areas disturbed by mining and mine related 

Revegetation would be protected by detection and treatment of invasive weed species. Revegetation efforts would 

species important to Native American cultural uses. Rosemont Copper would include Palmer’s agave in the final 

closure plan. Conservation measures and/or terms and conditions related to known lesser long-nosed bat roost pro

would be followed.

Source This is a design feature that was contained in the preliminary MPO. Further refinements have been made in vario

and efforts to further refine revegetation plans are currently ongoing by the Forest Service. The biological opinion 

vegetation goals for jaguar habitat (see biological opinion conservation measures and terms and conditions for les

Impacts Mitigated Would reduce impacts to surface water quality from potential erosion; would reduce impacts to visual resources; 

enhance soil function and stability. Potentially provides wildlife habitat (including habitat for jaguar, ocelot, and 

suitable livestock grazing conditions; establishment of culturally important plant species; and future recreational 

invasive species establishment and spread.

Location All disturbed areas except the mine pit. Includes linear features such as utilities and pipelines and stormwater div

Final Environmental Impact Statement for the Rosemont Copper Project

B-11
Element Description

Monitoring / Reporting 

Action

Implementation: Visual inspections of recently reclaimed areas would be performed after significant rainfall eve

precipitation within 24-hour period) to determine whether there are signs of accelerated erosion and areas in need 

determine whether there is sufficient growth medium onsite to ensure revegetation success. A revegetation plan w

Rosemont Copper and approved by the Forest Service as part of the final reclamation and closure plan, prior to ap

MPO. The revegetation plan would address how the different plant communities, including woody species, would 

the landscape.

Revegetation efforts, including maps, of approximate areas revegetated and acreage of initial seeding, seed/plant 

application rate, propagation, and transplanting would be reported on an annual basis. The Forest Service would d

success using an adaptive management approach to set and refine techniques based on quantitative monitoring re

analyses/comparisons of results from reference sites, test plots, and ongoing revegetation efforts. Revegetation su

as similarity to comparable reference sites. 

Certified ‘weed free’ sources of plant material and erosion control would be required. Seed and other organic mat

by an independent lab for noxious and invasive species prior to placement on the growth medium. An ‘early dete

species protocol such as the “Multi-Network Exotic Plant Monitoring Protocol and Standard Operating Procedure

among the Southern Plains, Chihuahuan Desert and Sonoran Desert Networks” (Standard Operating Procedure #4

2011), used by the National Park Service Sonoran Desert Inventory and Monitoring Network, or other protocol a

Forest Service, would be implemented. ‘Early detection’ focuses on high-traffic areas such as roads and parking a

invasive seed transport corridors. All other disturbed areas would be monitored twice a year following the rainy s

not always late September and late March). Infestations of invasive species would be treated as soon as they are i

weather conditions are appropriate for treatment. 

The biological opinion includes a conservation measure and/or term and condition for jaguar and ocelot that calls 

percentage of woody vegetation cover consistent with the elements of jaguar critical habitat (note that the relevan

element is from >1 to 50 percent) averaged over the reclamation area, excluding the pit. This shall be established 

obligation of the concurrent reclamation program in appropriate areas as determined in conjunction with the Fore

project development. Additional tree and shrub cover may be required in order to meet similarity requirements to 

Monitoring vegetation and site characteristics on these plots would provide quantifiable results and set up a data f

continually adjust success criteria, objectives, species to be used in seed mix/planting, and site preparation techni

management adjustments would be assessed to ensure their compliance with current NEPA decision; supported b

results; and documented in the project monitoring and evaluation report. Invasive plan control measures comply w

“Environmental Assessment for the Invasive Exotic Plant Management Program: Coronado National Forest; Coc

Pinal, and Santa Cruz Counties in Southeastern Arizona; and Hidalgo County in Southwestern New Mexico” (Fo

GIS data for treatment areas, description of species treated, and the type and amount of herbicides used would be 

Service annually. 

Monitoring / Reporting 

Action, continued

Effectiveness: Annual quantitative monitoring and reporting of revegetation and soil stability would be required. 

measurements may include: species richness, canopy cover, basal cover, density/frequency, and plant community 

plot results would be statistically compared with reference plot results to determine whether objectives are being 

revegetated areas would be surveyed for invasive species twice a year following winter and summer rains; and su

mapped and actions taken to prevent, eliminate, or control invasive plants should they occur, in accordance with t

B-12 Final Environmental Impact Statement for the Rosemont Copper Project
Element Description

Performance Criteria Implementation: Percent similarity to reference sites would be established based on ecological site descriptions, 

plots, and ongoing monitoring of previously revegetated plots. 

Placement of growth media and revegetation efforts would be implemented concurrently with reclamation efforts

revegetated would be contoured, graded, prepared, and seeded and/or planted in accordance with the final reclam

Rosemont Copper and the Forest Service would use Natural Resources Conservation Service Ecological Site Des

comparable reference site replications in the vicinity of the mine. Native species used for revegetation efforts wou

Forest Service in advance and would meet those specified in the final reclamation plan. Species would be determ

Resources Conservation Service Ecological Site Descriptions, reference sites, and test plot results. 

The revegetation plan would include measures to meet the terms and conditions of the biological assessment.

Species composition on revegetated sites would be similar to those found on reference sites, including: grasses, fo

Species considered would be capable of being self-sustaining and would include species with the ability to provid

desired future conditions, and provide wildlife habitat and may include species that are culturally important to trib

Reference site data would be used to calculate native species’ occurrence, density, and cover and to set revegetati

Aspect, elevation, and topographic location would be considered when selecting reference sites and when quantif

between reference and revegetated sites. 

The presence of any noxious or invasive plants species would trigger treatment.

Effectiveness: Growth medium characteristics and soil stability would be sufficient to meet revegetation objectiv

descriptions, test plots, and previously revegetated reclamation areas would be used to establish appropriate plant 

revegetated and to set success criteria. Seeding and planting would be successful in establishing desired plant spe

in location zones specified in the final reclamation plan. Vegetation species and density would be similar to refer

by the adaptive management data feedback loop by the monitoring group.

Visits after invasive plant species treatments would determine the effectiveness of treatments and whether additio

required. 

Responsible Party Implementation and Effectiveness: The Forest Service is responsible for monitoring the implementation of any 

mitigation that are specified as requirements of the USFWS biological opinion. The Forest Service is responsible 

tribes regarding culturally important plant species. 

Rosemont Copper is responsible for conducting monitoring and reporting to the Forest Service. The Forest Servic

establishing success criteria and revegetation objectives based on similarity to reference sites and the adaptive ma

The Forest Service would spot check revegetation success and site stability on NFS lands throughout the year. Th

conduct annual (at a minimum) site inspections to review monitoring results in cooperation with Rosemont Copp

whether success criteria have been met and the cause for better or worse results than predicted; if data (from refer

and revegetated plots) indicate the need for adjustments to seed/plant mix, seed/plant application rates, or site pre

whether acceptable soil stability has been achieved; and determine the need for additional mitigation measures fo

stability. The Forest Service would evaluate monitoring results to determine and document compliance with NEP

effectiveness of mitigation. 

Rosemont Copper is responsible for monitoring, treatment, follow-up treatments, and reporting to the Forest Serv

include: species, maps, population estimates, treatment method(s), and the amount of chemical herbicide used.

Final Environmental Impact Statement for the Rosemont Copper Project

B-13
Element Description

Timing Implementation: Monitoring would begin when salvage of soil (growth media) begins during the premining pha

until the Forest Service determines that no further revegetation efforts (seeding, planting, site stabilization, etc.) a

the revegetation objectives contained in the final reclamation and closure plan. Activities near known lesser long-

occur when lesser long-nosed bats are not present, typically during the period from November 1 to July 1 each ye

Invasive plant monitoring would begin immediately and follow agreed-upon protocols.

Effectiveness: Revegetation effectiveness monitoring would begin with initial seeding or planting during the acti

would continue until the Forest Service determines that final reclamation objectives for revegetation and site stab

during final reclamation and closure or postclosure phases.

Applicable Alternatives All action alternatives.

FS-SR-03 – Concurrent placement of perimeter buttress

Element Description

Description This mitigation involves constructing a buttress formed of waste rock surrounding and encapsulating the compact

Conservation measures and/or terms and conditions related to known lesser long-nosed bat roost protection meas

followed.

Source This is a design feature that was contained in the preliminary MPO and is required by the aquifer protection plan. 

specifies that conservation measures to protect lesser long-nosed bat roosts must be followed (see conservation m

and conditions for lesser long-nosed bat).

Impacts Mitigated Would reduce impacts to surface water due to erosion potential by beginning reclamation and vegetation recovery 

concurrently with mining operations; would reduce impacts to visual quality by eventually blocking the view of m

and structures; and would reduce risk of impacts to groundwater from potential acid generation through proper pl

waste rock materials.

Location Completely surrounding the dry-stack tailings and waste rock/heap leach facilities (heap leach is not included in A

Alternative).

Monitoring / Reporting 

Action

Implementation: Weekly visual inspections and quarterly reporting to ensure that: (1) placement is within the fo

FEIS, ROD, and final MPO; (2) geometry of facility adheres to specifications in the final MPO; (3) waste rock pl

placed in accordance with the aquifer protection permit and stacking plan from the final MPO; and (4) facilities a

be configured to support successful revegetation.

Effectiveness: Weekly visual inspections and quarterly reporting of status and condition of perimeter buttress con

excessive erosion, if any; and results of acid rock drainage monitoring. Annual monitoring of effectiveness of per

blocking the view of the plant site from selected viewpoints. 

B-14 Final Environmental Impact Statement for the Rosemont Copper Project
Element Description

Performance Criteria Implementation: Perimeter buttress would be located within the footprint depicted in the FEIS, ROD, and final M

rock buttresses would be generally no less than 150 feet wide at the crest and would have an overall crest-to-toe s

(horizontal: vertical); slopes would generally be 3:1 between benches; slopes would be stable, with no major failu

deformation, slides, sloughs, and settlement would not affect stability; materials would be placed in accordance w

approved waste rock segregation plan (aquifer protection permit). 

Effectiveness: Monitoring would indicate that acid rock drainage meets predictions in FEIS and ROD and does n

or surface waters; surfaces would be stable and excessive erosion would not occur; the view of the plant site wou

most viewpoints.

Responsible Party Implementation and Effectiveness: The Forest Service is responsible for monitoring the implementation of any 

mitigation that are specified as requirements of the USFWS biological opinion. Rosemont Copper is responsible 

monitoring of perimeter buttress construction, location, and condition and reporting to the Forest Service. Rosem

responsible for conducting water quality monitoring and reporting to the Forest Service and ADEQ. ADEQ is res

determining compliance with the aquifer protection permit. 

The Forest Service is responsible for conducting and reporting monitoring of visual screening.

Timing Implementation and Effectiveness: Would commence when construction of perimeter buttress begins and woul

buttress construction has been completed. Activities near known lesser long-nosed bat roosts would occur when l

are not present, typically during the period from November 1 to July 1 each year.

Applicable Alternatives All action alternatives.

Other Monitoring Items for Soils and Revegetation

FS-SR-04 – Slope stability monitoring

Element Description

Description Rock slopes within the mine pit would be remotely monitored for movement. 

Source Coronado ID team.

Purpose Would determine whether mine pit geometry is within the range specified in the final MPO and would assess the 

high wall and alteration of the Santa Rita ridgeline.

Location Mine pit.

Monitoring / Reporting 

Action

Implementation: Appropriate reflectors or other monitoring methods would be used as pit progresses in depth. 

Effectiveness: Potential movement of the high wall would be monitored remotely using survey equipment, inspe

is typically conducted for safety considerations. Rosemont Copper would provide results on a quarterly basis to e

specifications in the final MPO. 

Performance Criteria Implementation: The monitoring plan and specific monitoring points are sufficient for assessing the potential fo

of high wall.

Effectiveness: Movement would show no potential for collapse of high wall.

Responsible Party Implementation and Effectiveness: Rosemont Copper is responsible for conducting monitoring and reporting to 

a quarterly basis. 

Final Environmental Impact Statement for the Rosemont Copper Project

B-15
Element Description

Timing Implementation: Continuously throughout life of mine as pit deepens.

Effectiveness: Monitoring would begin when pit construction advances to the final wall along the ridgeline. Mon

during operations. Results of the monitoring would be evaluated at closure, and a longer monitoring period would 

time if appropriate.

Applicable Alternatives All action alternatives. 

FS-SR-05 – Sediment transport monitoring

Element Description

Description This monitoring item would monitor the movement of sediment within the channel of Barrel Canyon, including a

scour.

Source Coronado ID team.

Purpose Would determine whether erosion and downstream geomorphological changes are within the range of impacts de

decision.

Location Barrel Canyon from compliance point dam downstream to State Route (SR) 83 bridge. Would include assessmen

at bridge itself.

Monitoring / Reporting 

Action

Implementation and Effectiveness: Baseline conditions would be established prior to mine construction (before 

periodic comparison monitoring would be conducted every 5 years. Baseline condition determination and subseq

use techniques that are sufficient to describe areas along the sandy wash bottom of Barrel Canyon where the surfa

increased from baseline, decreased from baseline, or remained the same.

Performance Criteria Implementation and Effectiveness: Monitoring would be performed and reported to the Coronado every 5 year

include comparison of current conditions with baseline measurement and assessment of trends of any geomorpho

Responsible Party Implementation and Effectiveness: Rosemont Copper is responsible for conducting monitoring and reporting to 

Timing Implementation and Effectiveness: Premining through final reclamation and closure phases.

Applicable Alternatives All action alternatives.

Groundwater Quantity and Quality

FS-GW-01 – Monitoring of waste rock for seepage

Element Description

Description The waste rock facility is not predicted to allow infiltration of precipitation and subsequent seepage. Monitoring e

collection pans or lysimeters) would be encapsulated within the waste rock in order to remotely assess the moistu

rock and allow for collection and analysis of seepage if any is generated.

Source Coronado ID team.

Purpose Would determine whether seepage is occurring, which would be outside the effects predicted in the NEPA analys

B-16 Final Environmental Impact Statement for the Rosemont Copper Project
Element Description

Location Lower lifts of the waste rock facility. Monitoring would include at least two monitoring locations within the wast

surrounding the tailings facility and at least two monitoring locations within the waste rock facility itself.

Monitoring / Reporting 

Action

Implementation: Rosemont Copper would provide detailed locations of seepage monitoring equipment and wou

methodology for monitoring.

Effectiveness: Rosemont Copper would monitor moisture content on a quarterly basis to ensure lack of seepage f

facility. In the event that seepage occurs, leachate would be collected and sampled on a quarterly basis.

Performance Criteria Implementation: Monitoring equipment would be installed in lower lift of waste rock facility.

Effectiveness: Moisture content of waste rock would indicate that seepage is not occurring, and sampling and an

be performed if seepage occurs.

Responsible Party Implementation and Effectiveness: Rosemont Copper is responsible for conducting monitoring and reporting to 

a quarterly basis.

Timing Implementation: Installation would be conducted during the construction of the initial lifts of the waste rock fac

Effectiveness: Monitoring would begin upon installation and would continue throughout the active mining phase

Applicable Alternatives All action alternatives. 

Other Monitoring Items for Groundwater Quality and Quantity 

FS-GW-02 – Water quality monitoring beyond point-of-compliance wells

Element Description

Description Groundwater quality sampling at locations other than required under the Arizona aquifer protection permit.

Source Required by the Coronado.

Purpose Determine in situ changes in the quality of Coronado National Forest groundwater resources, beyond the capture 

potentially triggered by groundwater drawdown.

Location Up to 10 springs and up to 16 wells (15 existing wells, 1 proposed new well [see FS-BR-25]).

Final Environmental Impact Statement for the Rosemont Copper Project

B-17
Element Description

Monitoring / Reporting 

Action

Implementation: The Coronado has provided Rosemont Copper with a potential list of monitoring wells, piezom

that may be able to be sampled. Rosemont Copper would conduct field investigations to determine the ability to c

pertinent water samples from these locations, and based on these results, the Coronado would determine a final m

monitoring list must have appropriate geographic coverage sufficient to monitor changes in the quality of Corona

groundwater resources. The Coronado would coordinate with Rosemont Copper to produce a detailed sampling p

(1) quality assurance protocol, (2) sampling protocol, (3) detailed analyte list, (4) sampling frequency and criteria 

modification of sampling frequency, (5) criteria for defining baseline or ambient groundwater quality, (6) definiti

water quality thresholds with which to compare results, (7) reporting requirements, (8) protocol to be followed in 

quality threshold is exceeded (i.e., increased sampling frequency, other investigative approaches, or remedial acti

determining conclusion of monitoring , and (10) a procedure for reviewing and requesting changes to the level of 

Effectiveness: Rosemont Copper would conduct groundwater sampling at the specified wells and springs. Sampl

required from flowing springs and from wells able to be sampled (i.e., not dry, obstructed, etc.). Frequency would 

detailed sampling plan. A likely scenario would be to require quarterly sampling to establish baseline or ambient 

which would also take into account existing water quality samples already collected by Rosemont Copper, follow

at wells and semiannual sampling at springs, unless major changes in water quality occur associated with observe

drawdown or reduced flow in springs. Specific analytes would be determined in the detailed sampling plan but in 

metals and inorganic analytes. Rosemont Copper would report results of sampling annually to the Coronado as a 

reporting. Report would be submitted electronically in a format acceptable to the Coronado.

Performance Criteria Implementation: Ability to sample wells would be determined, final list of wells is determined, and detailed sam

Effectiveness: Sampling and reporting is conducted in accordance with the detailed sampling plan.

Responsible Party Implementation: The Coronado is responsible for providing a list of potential wells, evaluating Rosemont Copp

data, determining final well locations, and providing this list to Rosemont Copper. Rosemont Copper is responsib

investigations on the final potential list of wells. Rosemont Copper is responsible for preparing a detailed samplin

and approval by the Coronado, as part of the final MPO.

Effectiveness: Rosemont Copper is responsible for sampling and reporting. The Coronado is responsible for revi

sampling results.

Timing Implementation: Selection of wells and detailed sampling plan to be included as part of final MPO.

Effectiveness: Baseline sampling would begin during or before ground disturbance. Sampling would continue th

closure, and the postclosure period (following criteria determined in detailed sampling plan).

Applicable Alternatives All action alternatives. 

Wells and Springs to Be Potentially Monitored in Relation to FS-GW-02

Well or Spring Cadastral Location Well Nam

Well (D-18-16) 20dbc HC-4A and H

Well (D-18-15) 35abc DH-144

Well (D-18-16) 28aba RP-2B and R

B-18 Final Environmental Impact Statement for the Rosemont Copper Project
Well or Spring Cadastral Location Well Nam

Well (D-18-16) 29bbd P-899

Well (D-18-16) 30bab HC-5A and H

Well (D-19-16) 04ddb DH-154

Well (D-19-16) 06cca RP-5

Well (D-19-16) 01bab HC-1A and H

Well (D-18-16) 30bd C-1

Well (D-19-15) 01aac HC-6

Well To be determined Proposed New Well [S

Spring (D-19-15) 1dbd Deering Sp

Spring (D-18-16) 32bbc Rosemont Spring (u

Spring (D-18-16) 9dbb Lower Mulberr

Spring (D-18-16) 9abc Mulberry Sp

Spring (D-18-16) 29bda McCleary D

Spring (D-18-16) 27ddd Questa Spr

Spring (D-18-16) 19ccd MC-2 Spr

Spring (D-18-16) 19abb Fig Tree Sp

Spring (D-18-15) 14dba Helvetia Sp

Spring (D-18-15) 12dba Sycamore S

FS-GW-03 – Additional operational waste rock and tailings characterization

Element Description

Description Waste rock characterization and segregation is required during operations under the aquifer protection permit 

supplementary monitoring measure involves additional waste rock and tailings characterization analysis durin

Source Required by the Coronado.

Purpose The characterization required under the aquifer protection permit, though compliant with ADEQ methodologi

potentially acid-generating material and for providing information on metals reactivity, may not provide detai

composition and potential long-term, postclosure behavior of waste materials with respect to acid generation 

This would better inform the Coronado’s long-term management of the waste rock and tailings facilities, inclu

responsibilities that would continue after release of bonding and after discontinuation of surface and groundw

under the aquifer protection permit.

Location Blast face; waste rock facilities and waste rock perimeter buttress locations; tailings facility.

Monitoring / Reporting Action Implementation: The Coronado would coordinate with Rosemont Copper to produce a detailed waste rock/ta

sampling plan, including: (1) quality assurance protocol, (2) compositing methodology, (3) sampling protocol

list, (5) completion requirements for kinetic testing, and (6) reporting requirements. 

Final Environmental Impact Statement for the Rosemont Copper Project

B-19
Element Description

Monitoring / Reporting Action Effectiveness: Monitoring would consist of five general components: (1) collection of samples, (2) additiona

acid-generating waste rock, (3) additional analysis on non-acid-generating waste rock, (4) analysis of tailings 

(5) reporting. 

Monitoring / Reporting Action Sample Collection

Rosemont Copper would already be collecting composite samples from potentially acid-generating waste rock

samples from all waste rock, as required under the waste rock segregation plan (OA-GW-02). The additional 

FS-GW-05 would make use of the same samples already being collected. 

As described under waste rock segregation plan, “Sample selection will be distributed based on the rock types

encountered during the sampling period/increment.” Rosemont Copper would ensure that the samples provide

analysis are representative of the majority of waste rock excavated during the sampling period.

Monitoring / Reporting Action Additional Analysis of Potentially Acid-Generating Waste Rock

- One sample would be collected for every 250,000 tons of potentially acid-generating waste rock. Th

collected in conjunction with the composite sampling of potentially acid-generating waste rock alre

under the waste rock segregation plan. This sample would be analyzed for:

o Whole rock chemical analysis,

o Detailed visual descriptions of mineralogy present, and

o Quantitative mineralogical analysis.

- One sample would be collected every 6 months for humidity cell testing. Humidity cell testing wou

sample and would continue running until completion criteria are met (as defined in the detailed was

characterization sampling plan). Upon completion, cells would be disassembled using an establishe

clarify the conditions in the cell.

- Petrographic analysis is not required. In the event that a problem is identified that requires such ana

would request that Rosemont Copper investigate the potential of obtaining it from existing cores.

Monitoring / Reporting Action Additional Analysis of Non-Acid-Generating Waste Rock

- One sample would be collected for every 5,000,000 tons of non-acid-generating waste rock. This sa

collected in conjunction with the weekly random sampling of waste rock already being conducted u

segregation plan. This sample would be analyzed for:

o Whole rock chemical analysis,

o Detailed visual descriptions of mineralogy present, and

o Quantitative mineralogical analysis.

B-20 Final Environmental Impact Statement for the Rosemont Copper Project
Element Description

Monitoring / Reporting Action Additional Analysis of Tailings and Process Water

- One grab sample of tailings would be collected monthly, to be collected from a location that does n

operation of the mine. This sample would be analyzed for:

o Whole rock chemical analysis, and

o Quantitative mineralogical analysis.

- One sample would be collected annually for humidity cell testing. Humidity cell testing would be in

and would continue running until completion criteria are met (as defined in the detailed waste rock/

characterization sampling plan). Upon completion, cells would be disassembled using an establishe

clarify the conditions in the cell.

- One sample of process water would be collected quarterly. The intent is to analyze water that is sim

entrained with the tailings; the collection location would be consistent with that intent. Quarterly, pr

analyzed for inorganics and metals (exact analytes would be determined in the detailed waste rock/t

plan). Annually, process water would also be analyzed for organic and radiochemical constituents.

Monitoring / Reporting Action Reporting: Reporting would be conducted annually. Exact reporting requirements would be identified in the 

rock/tailings characterization plan. In general, reporting would summarize the analysis conducted during the p

the most recent results from humidity cells that might still be running and not yet completed and the results fr

disassembled that year. Reporting would also make use of the geological descriptions and mineralogical analy

reference the samples collected during the previous year with waste rock characterization tests conducted dur

those conducted prior to operations. The goal is to develop an ongoing comprehensive data set of the reactivit

units that spans both preoperation and operation time frames.

Performance Criteria Implementation: Detailed waste rock/tailings characterization plan is produced and approved prior to the fin

Effectiveness: Sampling and reporting would be conducted in accordance with a detailed waste rock/tailings 

sampling plan. This plan would include an opportunity to request changes to the level of the sampling and the 

the appropriateness of the request.

Responsible Party Implementation: Rosemont Copper is responsible for preparing a detailed waste rock/tailings characterizatio

review and approval by the Coronado.

Effectiveness: Rosemont Copper is responsible for sampling, reporting, and evaluation. The Coronado is resp

interpretation of sampling results.

Timing Implementation: Active mining phase.

Effectiveness: Active mining phase.

Applicable Alternatives All action alternatives.

FS-GW-04 – Periodic update and rerunning of pit lake geochemistry model throughout life of mine

Element Description

Description Periodic updating of the pit lake geochemistry model to incorporate the most recent and pertinent geochemica

through waste rock characterization efforts. The purpose of this measure is to ensure that the most accurate pr

lake water quality is available at closure. At the time of closure, the results of the model would be assessed an

Final Environmental Impact Statement for the Rosemont Copper Project

B-21
Element Description

management plans for protection of wildlife if possible harm exists from exposure to pit lake water quality.

Source Coronado ID team.

Purpose Predict postmining pit lake water quality in order to develop management plans for protection of wildlife.

Location Mine pit.

Monitoring / Reporting Action Implementation and Effectiveness: Every 5 years, Rosemont Copper would use collected geochemical data 

characterization efforts, and any other pertinent hydrologic, geological, or geochemical data to provide revise

pit lake water quality after closure. The pit lake model would be run for a period of 200 years to match the du

model. At closure, Rosemont Copper would produce a best and final pit lake model and would coordinate wit

develop management plans to protect wildlife, if impacts from pit lake water quality are likely to occur.

Performance Criteria Implementation and Effectiveness: Model update report would be provided every 5 years.

Responsible Party Implementation and Effectiveness: Rosemont Copper is responsible for performing all modeling and provid

documentation to the Forest Service. Forest Service is responsible for review and approval of model. Rosemo

Service are responsible for joint development of management plans for protection of wildlife.

Timing Implementation and Effectiveness: Active mining phase through closure.

Applicable Alternatives All action alternatives.

FS-GW-05 – Monitoring, pumping, and treatment of heap leach drainage

Element Description

Description Monitoring of heap leach draindown after closure and encapsulation of the heap leach pad for the effectivene

and the requirement to pump and treat drainage if passive treatment is ineffective at reducing concentrations b

Aquifer Water Quality Standards.

Source Coronado ID team.

Purpose Ensure that heap leach drainage above aquifer standards is not discharged to aquifer.

Location Heap leach pad.

Monitoring / Reporting Action Implementation: Upon closure of the heap leach pad, Rosemont Copper would install passive treatment adeq

residual heap leach drainage to levels below numeric Arizona Aquifer Water Quality Standards. Rosemont Co

necessary facilities to access and monitor heap leach drainage. 

Effectiveness: Rosemont Copper would continually monitor levels of drainage leaving the treatment system. 

Copper would collect samples of posttreatment drainage and analyze for any constituents with applicable num

Water Quality Standards. If sampling determined that passive treatment is not sufficient to lower concentratio

Arizona Aquifer Water Quality Standards, then Rosemont Copper would install the necessary equipment to p

drainage from the sump, treat drainage, and discharge to an appropriate location, or would provide for additio

that would be effective.

Performance Criteria Implementation: Necessary facilities are installed upon closure and encapsulation of the heap leach pad.

Effectiveness: Posttreatment drainage is below numeric Arizona Aquifer Water Quality Standards. Results of 

reported to Forest Service quarterly.

B-22 Final Environmental Impact Statement for the Rosemont Copper Project
Element Description

Responsible Party Implementation and Effectiveness: Rosemont Copper is responsible for performing all monitoring and treat

Timing Implementation and Effectiveness: Until cessation of drainage from heap leach pad.

Applicable Alternatives All action alternatives except the Barrel Alternative.

Surface Water Quantity and Quality

FS-SW-01 – Location, design, and operation of facilities and structures intended to route stormwater around the m

downstream drainages

Element Description

Description This mitigation involves the design, location, and operation of stormwater diversion facilities in order to main

and avoid contact with processing facilities and ore stockpiles.

Source This is a design feature of the preliminary MPO that has been revised for the various action alternatives. The 

Discharge Elimination System Multi-Sector General Permit does not require but does encourage consideratio

structures.

Impacts Mitigated Would reduce risk of flooding damage to mine facilities; would allow noncontact stormwater to flow into nat

Diversions designed and operated to route stormwater through or around project facilities would reduce loss o

groundwater flows in drainage downstream of mine facility.

Location Pit and permanent diversion channels; flow-through drains and drainage basins (proposed action, Phased Tail

Barrel Trail Alternative only); drop structures, compliance point pond, and dam (sediment control structures)

Monitoring / Reporting Action Implementation: Complete inspection would be performed when these facilities are constructed to ensure co

locations and specifications contained in the final MPO.

Effectiveness: Quarterly visual inspections would be performed to identify physical conditions that could red

facilities and structures to function properly, and appropriate actions would be taken. Quarterly and during/aft

rainfall/surface water flow events, a visual inspection would be performed of all structures to ensure proper ro

identify corrective actions as needed. Permanent facilities may need postclosure monitoring for a period of tim

ensure continued effectiveness. 

Performance Criteria Implementation: Facilities would be constructed in locations and to specifications contained in the final MP

Effectiveness: Structures would be stable and would show no excessive erosion, settling, slumping, or deform

water routing. Water would be routed to desired natural features (washes) in an efficient manner. Permanent f

designed to minimize the need for long-term maintenance postclosure.

Responsible Party Implementation and Effectiveness: Rosemont Copper is responsible for conducting monitoring and reportin

Timing Implementation: During construction (premining phase) to ensure compliance with the final MPO.

Effectiveness: Throughout premining, active mining, and final reclamation and closure phases.

Applicable Alternatives All action alternatives. Note that not all structures apply to all alternatives. Refer to alternative descriptions in 

information. 

Final Environmental Impact Statement for the Rosemont Copper Project

B-23
FS-SW-02 – Stormwater diversion for Barrel Alternative designed to route more stormwater into downstream drain

Element Description

Description This mitigation reflects the results of an effort to apply the concepts of geomorphic reclamation to the Barrel 

is a design that would route more stormwater into downstream drainages postclosure than previous designs.

Source Coronado ID team.

Impacts Mitigated Would reduce impacts to surface flows and groundwater in drainages downstream by allowing more stormwa

drainages (washes). Design grades the tops of facilities to shed water to lower benches, where water would m

reaching concrete drop structure and/or being discharged into a diversion channel and then into a natural drain

built to drain plant site to McCleary Canyon. Postclosure, no water would be stored on waste rock or tailings 

Location Tailings, waste rock, and plant facilities; benches designed to move stormwater laterally; diversion channels; 

structures. 

Monitoring / Reporting Action Implementation: Complete inspection would be performed when these facilities are constructed to ensure co

locations and specifications contained in the final MPO. 

Effectiveness: Quarterly visual inspection would be performed of facility integrity and to ensure that water d

efficiently and that sufficient channel capacity exists; additional inspections would be performed during and a

events (0.5 inch or greater precipitation within 24-hour period).

Performance Criteria Implementation: Monitoring would ensure that construction adheres to the final MPO.

Effectiveness: Facilities would be stable over time without excessive erosion and would effectively deliver st

drainages. 

Responsible Party Implementation and Effectiveness: Rosemont Copper is responsible for conducting monitoring and reportin

Timing Implementation: During construction (premining phase) to ensure compliance with the final MPO. 

Effectiveness: During active mining phase to ensure water delivery is effective and complies with the final M

postclosure for a period of time to be determined would ensure that facilities operate with no or minimal main

Applicable Alternatives “Alternative 4 – Barrel Alternative” only.

B-24 Final Environmental Impact Statement for the Rosemont Copper Project
Seeps, Springs and Riparian

FS-SSR-01 – Purchase of water rights, to be used for mitigating for impacts in the Cienega Creek watershed

Element Description

Description This mitigation would require the following actions in the Cienega Creek Watershed: 

(1) Rosemont Copper would purchase approximately 1,122 acre-feet of surface water rights held by Del Lago 

used to enhance aquatic habitat values in the Cienega Creek watershed for Federal threatened and endangered 

riparian resources. This would include the severance and transfer of portions of surface water rights to approp

in-stream flow rights on lower Cienega Creek and Davidson Canyon within the Cienega Creek Natural Preser

rights on Upper Cienega Creek within the Las Cienegas National Conservation Area. These water rights wou

Pima County, or another entity authorized under Arizona law to hold a surface water right for recreation and w

accordance with the biological opinion.

(2) Rosemont Copper would also acquire and retire a groundwater well on lands associated with Pantano Dam 

impacts to surface water in Cienega Creek from the withdrawal of groundwater.

(3) The remainder of water rights would be conveyed to a USACE-approved in-lieu fee sponsor. Under curre

Rosemont Copper would receive compensatory mitigation credit for conveying these water rights to the USA

fee sponsor, Pima County. The number of credits to be received for the purchase is yet to be determined. Ros

also purchase credits in the in-lieu fee project, as required by the USACE to compensate for impacts to waters 

(WUS).

Refer to the CWA Section 404 habitat mitigation and monitoring plan and conservation measures and/or term

biological opinion for further detail.

Source Rosemont Copper identified this mitigation measure as a component of the CWA Section 404 permitting proc

also put forth by Rosemont Copper as a voluntary conservation measure for consideration under consultation 

the Endangered Species Act (ESA). These conservation measures are no longer considered voluntary for the p

appendix, as implementation of these conservation measures is required under the biological opinion.

Impacts Mitigated Would partially mitigate potential impacts to jaguar, ocelot, Chiricahua leopard frog, Gila chub, Gila topminn

umbel, western yellow-billed cuckoo, and southwestern willow flycatcher, as well as aquatic and riparian veg

Location Cienega Creek watershed. 

Monitoring / Reporting Action Implementation and Effectiveness: In accordance with requirements in the biological opinion and habitat m

monitoring plan.

Performance Criteria Implementation and Effectiveness: In accordance with requirements in the biological opinion and habitat m

monitoring plan.

Responsible Party Implementation: USACE is responsible for determining whether mitigation value under their Section 404 pe

overseeing compliance with that permit. The Forest Service is responsible for monitoring the implementation 

this mitigation that are specified as requirements of the USFWS biological opinion. Rosemont Copper is resp

water rights and assigning them in the manner specified in the biological opinion and habitat mitigation and m

Effectiveness: In accordance with requirements in the biological opinion and habitat mitigation and monitori

Final Environmental Impact Statement for the Rosemont Copper Project

B-25
Element Description

Timing Implementation and Effectiveness: Throughout the life of the project (premining through final reclamation 

for 5 years following mine closure.

Applicable Alternatives All action alternatives.

Other Monitoring Items for Seeps, Springs, and Riparian Areas

FS-SSR-02 – Spring, seep, and constructed/enhanced waters monitoring

Element Description

Description A suite of 25 seeps and springs has been monitored for baseline conditions since 2007 and would continue to 

identify any impacts that may occur due to dewatering of the regional aquifer in the vicinity of the mine pit. R

committed to enhancing or replacing up to 30 water sources to offset potential impacts to surface waters (see 

performance and success of these waters would be monitored, as well. 

The Cienega Creek Watershed Conservation Fund (FS-BR-16) could be used for monitoring of success of rep

water features. If springs levels decrease, mitigation could come from this fund. 

Source Monitoring of constructed waters as required under biological opinion conservation measures and/or terms an

monitoring of seeps and springs was proposed by Rosemont Copper.

Purpose To measure effects of groundwater drawdown and to determine whether decreased water levels are due to min

water level is monitored in a variety of locations. 

Location As specified in the biological opinion. Suite of springs shown in table below. Prior to implementation all avai

prior spring surveys, would be reviewed and sites agreed upon for usefulness for inclusion in the monitoring l

Monitoring / Reporting Action Implementation: Baseline condition of springs would be assessed, including extent of riparian habitat, presen

extent of standing or flowing water, photographs, and flow measurements if possible.

Effectiveness: Measurement of spring condition (presence/absence of water, photographs, flow measurement

year, with results reported to the Forest Service. Up to three springs may be monitored more frequently using 

pending the ability to install such equipment without interfering with spring function or cultural significance o

Spring, Questa Spring, and Deering Spring). Discontinuation of monitoring of individual springs may be cons

indicate the absence of standing water, flowing water, or other indications of subsurface water (damp ground 

Performance Criteria Implementation: Baseline condition of springs and other water resources would be accurately documented.

Effectiveness: Monitoring would accurately record spring condition.

Responsible Party Implementation: The Forest Service is responsible for monitoring the implementation of any components of 

specified as requirements of the USFWS biological opinion. Rosemont Copper is responsible for baseline mo

Forest Service is responsible for determining spring locations and obtaining access for any springs not located 

Effectiveness: Rosemont Copper is responsible for conducting monitoring and reporting to the Forest Service

Timing Implementation: During premining to establish baseline conditions.

Effectiveness: From issuance of the ROD to 5 years postclosure. 

B-26 Final Environmental Impact Statement for the Rosemont Copper Project
Element Description

Applicable Alternatives All action alternatives.

Springs to Be Monitored in Relation to SSR-02

Cadastral Location Spring Name

(D-19-15) 1dbd Deering Spring

(D-19-15) 1bdb Locust Spring

(D-18-16) 32bbc Rosemont Spring

(D-19-15) 1bbb SW

(D-18-16) 9dbb Lower Mulberry Spring

(D-18-16) 9cbd Crucero Spring

(D-18-16) 9abc Mulberry Spring

(D-18-16) 30abc MC-1 Spring

(D-18-16) 29bda McCleary Dam

(D-18-16) 27ddd Questa Spring

(D-18-16) 19ccd MC-2 Spring

(D-18-16) 19abb Fig Tree Spring

(D-18-16) 17acc SC-2 Spring

(D-18-16) 16ccc Scholefield Spring (SC-1)

(D-18-16) 16bba Papago Spring

(D-18-16) 14cab Barrel Spring

(D-18-15) 35bdc Ruelas Spring

(D-18-15) 24dcc Peligro Adit

(D-18-15) 14dba Helvetia Spring

(D-18-15) 13aab SS-2

(D-18-15) 12dba Sycamore Spring

(D-17-17) 6bdd Reach 2 Spring

(D-16-17) 30abd Escondida Spring

(D-18-15) 14bcd Shamrod Spring

(D-18-15) 14ada Zackendorf Spring

Final Environmental Impact Statement for the Rosemont Copper Project B-27
Biological Resources 

FS-BR-01 – Plant site location and design adjustments to reduce impacts to biological resources

Element Description

Description The entire plant site is sited and designed to reduce its size and overall footprint and to use gravity instead of pum

water where possible. Specific plant site details are contained in the preliminary MPO and chapter 2 alternatives 

Source This is a design feature of the preliminary MPO. 

Impacts Mitigated Reduced footprint would avoid some impacts to cultural resources, native plants, and wildlife habitat. Design use

process water where possible, reducing energy needs. Reduced footprint would minimize impact to biological cor

“Sonoran Desert Conservation Plan.”

Location Plant site (see alternative maps in chapter 2).

Monitoring / Reporting 

Action

Implementation and Effectiveness: Initial review of plans and weekly visual inspections would be performed d

plant facilities and during removal of plant facilities. The intent is to inspect the plant site and the building constr

periodically during construction to make sure they are built in accordance with the plans and the final MPO; and 

reclamation, when the plant site is removed and restored, to make sure that areas that were avoided during constru

or directly impacted by building removal and plant site restoration activities. Inspection results that find disturban

depicted in approved plans and the final MPO would be reported to the Coronado within 24 hours. Otherwise, the 

would be summarized and reported in quarterly and annual monitoring reports.

Performance Criteria Implementation and Effectiveness: Facilities would be located and designed in compliance with the final MPO

Responsible Party Implementation and Effectiveness: Rosemont Copper is responsible for conducting monitoring and reporting to 

Timing Implementation and Effectiveness: During premining (construction) and final reclamation and closure (plant fa

to ensure adherence to final MPO decision; periodically during operations if modifications are proposed. 

Applicable Alternatives All action alternatives. 

FS-BR-02 – Redesign of the coarse ore stockpile dome and pebble crusher/ball loading facility to avoid a subpopu

plants

Element Description

Description This facility redesign involves enclosure of the stockpile by a domed structure and reorientation of the crusher/ba

conveyers to avoid a population of Coleman’s coral-root, which is a Forest Service sensitive species. A complete 

land disturbance footprint for Coleman’s coral-root and beardless chinch-weed would be completed prior to grou

Source Rosemont Copper. Also included in the biological evaluation.

Impacts Mitigated Would avoid impact to sensitive orchid subpopulations of Coleman’s coral-root and possibly other sensitive plan

reduction of the originally proposed footprint and angled arrangement of building and conveyers; would reduce im

reducing dust generation; dome would be less visually evident than conventional structure, thereby reducing impa

Location Plant site (see alternative maps in chapter 2).

B-28 Final Environmental Impact Statement for the Rosemont Copper Project
Element Description

Monitoring / Reporting 

Action

Implementation: Same as FS-BR-01.

Effectiveness: Semiannual inspection and reporting would be performed to ensure protections are effective. Vigo

trees would be monitored and reported. Air quality monitoring would be conducted in accordance with air quality 

The Forest Service would assess completed dome from representative viewpoints to determine effectiveness in re

Performance Criteria Implementation and Effectiveness: Facilities would be constructed in accordance with specifications in the fina

populations would not be impacted by plant site and facility construction or operations. Air quality standards wou

Responsible Party Implementation and Effectiveness: Rosemont Copper is responsible for conducting monitoring and reporting to 

See monitoring requirements in “Air Quality and Climate Change” and “Visual Resources” sections for further in

Timing Implementation and Effectiveness: Predominantly during premining (construction of facilities) and final reclam

(removal of facilities) phases. Monitoring during active mining phase to ensure that plants are not indirectly impa

Applicable Alternatives All action alternatives, with the exception of the proposed action.

FS-BR-03 – Measures to exclude wildlife, livestock, and the public from water ponds and other areas

Element Description

Description Specific ponds, basins, and other facilities would be enclosed, fenced, or otherwise managed to exclude wildlife, 

public. Includes construction of barriers to exclude Chiricahua leopard frogs, if needed.

Source This is a design feature from the preliminary MPO. Barriers to exclude Chiricahua leopard frogs are specified in 

(see conservation measures and/or terms and conditions for Chiricahua leopard frogs).

Impacts Mitigated Would avoid or reduce potential impacts to wildlife such as amphibians, birds, and bats; livestock; and public saf

Location Process water temporary storage pond; primary settling basin; raffinate pond, heap leach pad, and pregnant leach 

stormwater pond; primary settling basin; any other location where process water may be ponded; and chemical an

Note that not all of these facilities occur in all action alternatives. 

Monitoring / Reporting 

Action

Implementation: Visual inspection at the time facilities are constructed would be performed to ensure that cover

been installed and facilities have been enclosed or fenced. 

Effectiveness: Daily visual inspection would be performed to ensure enclosures, fences, covers, and/or devices a

to exclude wildlife, livestock, and the public. Inspection results that find measures ineffective at exclusion would 

Coronado and rectified within 72 hours. Otherwise, the results of inspections would be summarized and reported 

monitoring reports.

Performance Criteria Implementation: All accumulations of process water and other noted facilities would be enclosed or would have 

installed that operate to effectively exclude wildlife.

Effectiveness: Enclosures, fences, covers, and/or devices would be effective in protecting wildlife, livestock, and 

Responsible Party Implementation and Effectiveness: The Forest Service is responsible for monitoring the implementation of any 

mitigation that are specified as requirements of the USFWS biological opinion. Rosemont Copper is responsible 

monitoring and reporting to the Forest Service. 

Final Environmental Impact Statement for the Rosemont Copper Project

B-29
Element Description

Timing Implementation: During construction (premining phase) to ensure that enclosures, fences, covers, and devices a

Effectiveness: During active mining to ensure that measures are effective; and at final closure of the facilities to 

water or other facilities do not present hazards to wildlife, livestock, or the public.

Applicable Alternatives All action alternatives, for the listed facilities that apply. 

FS-BR-04 – Salvage, growing, planting, and monitoring of Palmer’s agave

Element Description

Description Revegetation includes biological opinion requirements to plant and monitor agave, study suitability of Palmer’s a

locally for use in reclamation seed mix, and plant native tree species.

Biological opinion requirements for Palmer’s agave would be included in the final reclamation and closure plan. 

would plant (transplanted or nursery-grown stock) at least 35,850 Palmer’s agaves, as specified in the biological 

seed would be included in the seed mix, provided that such seeds are commercially available.

During the life of the project, Rosemont Copper would work with the Forest Service to identify potential restorat

security fence and within 2 miles of the perimeter fence that are suitable for Palmer’s agave. Using the seed mix b

concurrent reclamation, Rosemont Copper would assist the Forest Service with the revegetation of these areas. In 

revegetation efforts would include planting Palmer’s agave transplants or nursery-grown Palmer’s agave. This ef

portions of the segment of the Arizona National Scenic Trail being abandoned under the action alternatives.

Prior to submittal of proposed modification of the allotment management plan (see RC-BR-17), Rosemont Coppe

estimates of Palmer’s agave that would be impacted within the security fence area and conduct studies sufficient 

baseline conditions of pastures that would be proposed in the allotment management plan modification for season

to increase flowering success of agave. In addition, Rosemont Copper would include Palmer’s agave in its concur

Rosemont would investigate the feasibility of agave plantings at ecologically appropriate sites on proposed conse

Sonoita Creek Ranch, Davidson Canyon watershed parcels, and Helvetia Ranch North parcels. Agaves would be 

appropriate densities (as determined by Rosemont Copper, USFWS, and other entities) and follow-up monitoring 

where such plantings are feasible and have a high likelihood of success. 

Biological opinion monitoring requirements regarding Palmer’s agave are also incorporated into the monitoring o

Source Biological opinion and Coronado ID team. See biological opinion conservation measures and/or terms and condit

nosed bat. 

Impacts Mitigated Would rectify impacts to wildlife habitat by rehabilitating and restoring this component of the affected environme

Palmer’s agave would provide habitat for lesser long-nosed bat and would meet the requirements of the biologica

Location All disturbed areas except the mine pit. Includes linear features such as utilities, pipelines, and the abandoned seg

National Scenic Trail. 

B-30 Final Environmental Impact Statement for the Rosemont Copper Project
Element Description

Monitoring / Reporting 

Action

Implementation: Annual monitoring of activities to ensure compliance with specifications in the final MPO and 

requirements of the biological opinion. A final reclamation and closure plan would be developed by Rosemont C

the Forest Service prior to issuance of the final MPO; it would meet all of the stipulations of the biological opinio

conditions and conservation measures of the biological opinion would be addressed in the final revegetation plan

Similar to FS-SR-02, revegetation efforts, including maps, GIS data, and acreage of initial seeding, seed/plant mi

application rate, propagation, and transplanting, would be reported on an annual basis. Specific information woul

and tree species and agaves. Information would be reported as required by the biological opinion. Revegetation w

following an adaptive management process and would ensure compliance with the biological opinion. A record o

and planted from nursery-grown stock during reclamation and the general location and density of transplants wou

reported to the Coronado annually.

Effectiveness: Annual quantitative monitoring of revegetation and site stability would be required, including whe

agave objectives have been met. Vegetation measurements may include: species richness, canopy cover, density/

community structure. Additional surveys would be conducted to track agave planting and survivorship. A record 

transplanted and planted from nursery grown stock during concurrent reclamation efforts and the general location 

transplants would be maintained and reported in accordance with biological opinion requirements. The status and 

would be included in the annual report to USFWS, as outlined in the “Conservation Measures” section of the biol

Performance Criteria Implementation: As part of the USFWS consultation, the biological opinion requires a minimum number of aga

planted and survival criteria to remediate lesser long-nosed bat habitat (the biological opinion proposes an averag

of 10.3 per acre). Revegetation monitoring requirements would be contained in the final reclamation and closure 

monitoring activities would be designed to meet the requirements of the biological opinion. 

Effectiveness: Seeding and planting would be successful in establishing agave and meeting the survival criteria a

established in the biological opinion. 

Responsible Party Implementation and Effectiveness: The Forest Service is responsible for monitoring the implementation of any 

mitigation that are specified as requirements of the USFWS biological opinion. Rosemont Copper is responsible 

from areas prior to disturbance; gathering seed locally; growing agave from gathered seed; transplanting and seed

accordance with the biological opinion; and monitoring both planting/seeding efforts and survival. 

Timing Implementation: Rosemont Copper is currently experimenting with agave salvage and transplanting associated w

and growth plot studies. This effort is expected to continue. Salvage would begin prior to any ground-disturbing a

phase). Activities would end at completion of the final reclamation and closure phase, or at an unknown time dur

depending on the success of agave planting and seeding efforts.

Effectiveness: Effectiveness monitoring would continue until the terms and conditions specified in the biological 

met, either at completion of the final reclamation and closure phase or at an unknown time during postclosure.

Applicable Alternatives All action alternatives.

Final Environmental Impact Statement for the Rosemont Copper Project

B-31
FS-BR-05 – Construction, management, and maintenance of water features to reduce potential impacts to wildlife 

reduced flow in seeps, springs, surface water, and groundwater

Element Description

Description Existing water features, including stock tanks, would be enhanced, and additional water features would be added 

water features would be managed or constructed within Rosemont Copper leased grazing allotments if needed fo

management (persistence) of Chiricahua leopard frog, and to meet the minimum requirements of jaguar propose

habitat primary constituent elements. The water features would generally follow the conceptual designs provide

Resources, Inc. New structures would be intended to enhance metapopulation dynamics, but not at the expense o

colonization between recovery unit populations, dispersal of aquatic species, or spread of chytridiomycosis. The 

construct these additional water features would be based on the findings of ongoing groundwater and seep and s

activities. Includes a requirement that Rosemont Copper establish a long-term management and maintenance fun

features constructed. These include tank/water feature construction or renovation to support Chiricahua leopard 

metapopulations in the Greaterville area. Relocation of Chiricahua leopard frogs, if present, would precede any 

renovation. Restored or replaced springs within jaguar proposed critical habitat would be constructed in accorda

primary constituent elements for surface water. Rosemont Copper would coordinate with the local recovery grou

and location of the seven sites to be specifically dedicated for Chiricahua leopard frog conservation. To protect 

prolonged drought, each of the seven tanks that would be improved for permeability and retention would also ha

source provided, such as a solar groundwater well, to ensure permanence of water at improved sites. Any water 

in addition to these seven sites that may affect the status of Chiricahua leopard frogs in the biological opinion ac

chosen in consultation with the local recovery group to facilitate avoiding incidental adverse effects or creating 

opportunities. Restored or replaced springs within jaguar critical habitat would be constructed in accordance wit

constituent elements for surface water. In addition, Rosemont Copper would establish a long-term management 

to maintain the water features constructed in furtherance of this biological opinion conservation measure and/or 

Source Biological opinion conservation measures and/or terms and conditions. This measure was put forth by Rosemon

conservation measure for consideration under consultation with the USFWS under the ESA. These conservation 

longer considered voluntary for the purposes of this appendix, as implementation of these conservation measure

biological opinion.

Impacts Mitigated Would partially mitigate for potential impacts to Chiricahua leopard frogs, jaguar, and other wildlife and to live

decreased water availability. 

Location As specified in the biological opinion terms and conditions, these sites may or may not include particular sites re

conservation measures of the biological assessment and may or may not be located on grazing allotments manag

Copper, but they would be located on Coronado National Forest lands within the Santa Rita Management Area.

Monitoring / Reporting 

Action

Implementation: Water levels would be monitored annually to determine whether and when artificial waters ne

modified, or constructed to meet the needs of threatened and endangered species. Construction and improvemen

would be conducted in accordance with the biological opinion.

Effectiveness: In accordance with requirements in the biological opinion.

Performance Criteria Implementation and Effectiveness: In accordance with requirements in the biological opinion.

Responsible Party Implementation and Effectiveness: The Forest Service is responsible for monitoring the implementation of an

mitigation that are specified as requirements of the USFWS biological opinion. Rosemont Copper is responsible 

improving the water sources as specified and for all monitoring and reporting. 

B-32 Final Environmental Impact Statement for the Rosemont Copper Project
Element Description

Timing Implementation and Effectiveness: In accordance with the biological opinion. Renovation activities would com

of initiation of construction activities. Water feature enhancements and construction proposed to support a Chiri

metapopulation would be implemented at the start of mining activities. Monitoring of renovated tanks would oc

life of the mine and for 5 years postclosure.

Applicable Alternatives All action alternatives.

FS-BR-06 – Location of the electrical power line that provides power to the pit area so that it avoids talus slopes to 

practicable

Element Description

Description The electrical power line that provides electricity to the pit would be constructed on the west side of pit operatio

disturbance perimeter of the pit and diversion structures.

Source Rosemont Copper. 

Impacts Mitigated Would reduce disturbance to talus slopes and talussnail habitat. Would reduce impacts to visual resources by av

the ridgeline.

Location Powerline from Rosemont substation to the pit and surrounding areas.

Monitoring / Reporting 

Action

Implementation and Effectiveness: Prior to construction, Rosemont Copper would evaluate the potential to fu

disturbance to talus slopes through revised construction techniques or methods. Daily visual inspections would b

construction and removal of this facility to ensure that disturbances to the talus areas are minimized. Inspection 

disturbance in areas not included in approved plans and the final MPO would be reported to the Coronado withi

the results of inspections would be summarized and reported in quarterly monitoring reports until the power line 

completed. A biological monitor or other qualified person would visually inspect areas to identify any unanticip

talussnail habitat.

Performance Criteria Implementation and Effectiveness: Location would avoid talus areas as practicable and would comply with sp

in the final MPO.

Responsible Party Implementation and Effectiveness: Rosemont Copper is responsible for conducting monitoring and reporting 

The Forest Service is responsible for spot-checking monitoring activities and for evaluating monitoring results t

with the final MPO.

Timing Implementation and Effectiveness: During construction of the pit power loop and during removal of these fac

avoidance of talus slopes to the extent practicable. 

Applicable Alternatives All action alternatives.

Final Environmental Impact Statement for the Rosemont Copper Project

B-33
FS-BR-07 – Recordation of a restrictive covenant or conservation easement on the private Helvetia Ranch Annex N

mitigate for impacts to species listed as threatened or endangered

Element Description

Description This mitigation requires the following actions for the Helvetia Ranch Annex North Parcel:

A restrictive covenant or conservation easement that precludes real estate development and similar land uses wo

Rosemont Copper.

This parcel contains about 940 acres of semidesert grassland on the west side of the northern Santa Rita Mounta

Rosemont utility corridor. The property contains Pima pineapple cactus. The property directly links Santa Rita E

Bureau of Land Management (BLM) land, which could benefit habitat and connectivity for ocelot and jaguar. It 

summer foraging habitat for lesser long-nosed bat. Management of the parcel would include modification of gra

grazing pressure on native vegetation.

The Helvetia Ranch Annex North Parcels would be included as available land for the establishment of water fea

listed species and to provide general wildlife benefits.

Source Biological opinion conservation measures and/or terms and conditions. This measure was put forth by Rosemon

conservation measure for consideration under consultation with the USFWS under the ESA. These conservation 

longer considered voluntary for the purposes of this appendix, as implementation of these conservation measure

biological opinion.

Impacts Mitigated Would partially mitigate for impacts to habitat for Chiricahua leopard frog, ocelot, and jaguar. 

Location Helvetia Ranch Annex North Parcel.

Monitoring / Reporting 

Action

Implementation: Recordation of a restrictive covenant in accordance with the biological opinion would be repo

restrictive covenant would be provided to the Forest Service. 

Effectiveness: In accordance with requirements in the biological opinion.

Performance Criteria Implementation: The restrictive covenant would restrict and allow land uses in accordance with requirements s

biological opinion. The restrictive covenant would be recorded in the time frame specified in the biological opin

Effectiveness: In accordance with requirements in the biological opinion.

Responsible Party Implementation: The Forest Service is responsible for monitoring the implementation of any components of th

specified as requirements of the USFWS biological opinion. Rosemont Copper is responsible for crafting and re

covenant that meets the requirements specified in the biological opinion.

Effectiveness: In accordance with requirements in the biological opinion.

Timing Implementation: In accordance with requirements in the biological opinion.

Effectiveness: In accordance with requirements in the biological opinion.

Applicable Alternatives All action alternatives.

B-34 Final Environmental Impact Statement for the Rosemont Copper Project
FS-BR-08 – Recordation of a restrictive easement on the private Sonoita Creek Ranch Parcel to mitigate for impac

threatened or endangered

Element Description

Description This mitigation requires the following actions for the Sonoita Creek Ranch Parcel:

Sonoita Creek Ranch is an approximately 1,200-acre ranch located in and around the historic channel and floodp

a major tributary of the Santa Cruz River, approximately 6 miles south of Sonoita, Arizona, and 2 miles north of 

Santa Cruz County. Approximately 590 acre-feet per annum of water rights is appurtenant to the ranch. The wat

ranch by Monkey Spring, a natural spring less than 1 mile north of the Sonoita Creek Ranch property on an adja

property. Most of the 590 acre-feet of certificated water right appurtenant to the ranch is currently used to season

110 acres of agriculture fields. The foothills of the Canelo Hills are present in the eastern portion of the ranch, a

of the property shares a boundary with the Coronado National Forest. Rosemont Copper would purchase the 1,2

Ranch and an estimated 590 acre-feet per annum of certificated water rights and record a site protection instrum

restrictive covenant.

The parcel contains an estimated 6 acres of open water in two ponds; forested wetland and riparian components

drainages, 337 acres of riparian habitat; 320 acres of upland habitat adjacent to riparian; 5 seasonal ponds; and 7

grassland and Madrean evergreen woodland, including mature Arizona white oaks. The site protection instrume

estate development and similar land use activities, as well as livestock grazing and other agricultural uses. The t

site would be enhanced for management of threatened and endangered aquatic species.

In the event that restoration is required under the habitat mitigation and monitoring plan, Rosemont Copper wou

infrastructure and the naturally occurring water from Monkey Spring (that currently irrigates the agricultural fie

and/or wetland habitat within the 115-acre fields. Otherwise, water available after the needs of the existing pond

onto the floodplain terrace of Sonoita Creek, which is currently an agricultural field, in order to facilitate the pas

riparian habitat.

Small waters would be created on the Sonoita Creek Ranch property and managed as potential source population

leopard frogs for future releases in the affected management areas. This would include renovation to remove har

predators such as bullfrogs, crayfish, and nonnative spiny-rayed fish and the construction and maintenance of fr

necessary, to prevent bullfrogs from recolonizing these waters. Fencing gauge would be chosen that would not e

terrestrial vertebrates such as snakes, lizards, etc., such as 0.25-inch mesh size or smaller. Barrier fencing would 

to allow adequate terrestrial space for foraging or terrestrial habitat enhancements. Management of Chiricahua l

would be coordinated through the local recovery group in the identification and location of the seven sites to be 

to Chiricahua leopard frog conservation. See the biological opinion terms and conditions for Chiricahua leopard 

details.

Source Biological opinion, conservation measures and/or terms and conditions, and habitat mitigation and monitoring p

put forth by Rosemont Copper as a voluntary conservation measure for consideration under consultation with th

ESA. These conservation measures are no longer considered voluntary for the purposes of this appendix, as imp

conservation measures is required under the biological opinion.

Final Environmental Impact Statement for the Rosemont Copper Project

B-35
Element Description

Impacts Mitigated Because of the heavily grazed nature of the property, exclusion of grazing and recordation of a site protection in

in enhancement of the 1,200 acres of wetland, riparian, and upland buffer habitat within the property. This woul

impacts to wildlife habitat and habitat connectivity, including jaguar, ocelot, Mexican spotted owl, lesser long-n

Gila topminnow, Chiricahua leopard frog, western yellow-billed cuckoo, and Huachuca water umbel. Currently

species are absent, and invasive, nonnative species are present. The site is currently managed for agricultural use

are not well suited for wildlife needs. The site would need to be restored to accommodate colonization or transp

and endangered species. 

Location Sonoita Creek Ranch.

Monitoring / Reporting 

Action

Implementation and Effectiveness: Report upon recording of restrictive covenant as described in the biologica

mitigation and monitoring plan; report upon completion of restoration or riparian enhancement activities.

Performance Criteria Implementation and Effectiveness: Riparian restoration and/or enhancement occurs in accordance with requir

opinion and habitat mitigation and monitoring plan.

Responsible Party Implementation and Effectiveness: The Forest Service is responsible for monitoring the implementation of an

mitigation that are specified as requirements of the USFWS biological opinion. Rosemont Copper is responsible 

property and recording a restrictive covenant that complies with the biological opinion and habitat mitigation an

Timing Implementation and Effectiveness: In accordance with biological opinion and habitat mitigation and monitorin

Applicable Alternatives All action alternatives.

FS-BR-09 – Funding to support camera studies for large predators, including jaguar and ocelot

Element Description

Description Rosemont Copper would contribute $50,000 to a suitable entity approved by the Coronado for camera studies fo

Source Biological opinion conservation measures and/or terms and conditions. 

Purpose Would provide information on travel corridors and habitat use of the Santa Rita and Whetstone Mountains, as w

corridors. This is information needed to determine locations where road crossing structures may be warranted in 

Location Santa Rita and Whetstone Mountains and areas in between.

Monitoring / Reporting 

Action

Implementation and Effectiveness: Funding would be provided to a suitable entity approved by the Coronado 

monitoring. 

Performance Criteria Implementation and Effectiveness: Not applicable

Responsible Party Implementation and Effectiveness: The Forest Service is responsible for monitoring the implementation of an

mitigation that are specified as requirements of the USFWS biological opinion. Rosemont Copper is responsible 

contribution. 

Timing Implementation and Effectiveness: Not applicable

Applicable Alternatives All action alternatives. 

B-36 Final Environmental Impact Statement for the Rosemont Copper Project
FS-BR -10 – Measures to reduce and rectify impacts to Pima pineapple cactus

Element Description

Description This measure would mitigate impacts to Pima pineapple cactus by minimizing surface disturbance in the utility 

monitoring; and transplanting those cacti that cannot be avoided. Predisturbance surveys for the cactus would oc

be marked and avoided where possible. Construction practices along the proposed utility corridors would be em

disturbance to the minimum practicable and to avoid Pima pineapple cactus. Known Pima pineapple cactus loca

and to the extent possible would be avoided. Rosemont Copper would protect Pima pineapple cactus that can be 

limit fencing, and construction/reclamation activity in the vicinity of these plants would be monitored during co

Copper would educate construction personnel for the power and water line on how to identify Pima pineapple ca

marking/avoidance methods. Pima pineapple cactus that cannot be avoided by utility construction/reclamation w

within the corridor into suitable habitat. A monitoring and maintenance program would be initiated to facilitate 

would follow similar previous efforts for Pima pineapple cactus transplantation and would involve watering for 

after transplant, followed by regular monitoring.

Source Biological opinion conservation measures and/or terms and conditions. 

Impacts Mitigated Would avoid or reduce impacts to the listed Pima pineapple cactus. See also the Helvetia Ranch Parcel (FS-BR-

species.

Location Utility corridor.

Monitoring / Reporting 

Action

Implementation and Effectiveness: Criteria specified in the biological opinion would be met. 

Performance Criteria Implementation and Effectiveness: Criteria specified in the biological opinion would be met.

Responsible Party Implementation and Effectiveness: The Forest Service is responsible for monitoring the implementation of an

mitigation that are specified as requirements of the USFWS biological opinion. Rosemont Copper is responsible 

identifying, avoiding, and transplanting cactus. Rosemont Copper is further responsible for conducting monitori

results to the Forest Service. 

Timing Implementation: Premining phase (construction of utility facilities) and final reclamation and closure phase (re

facilities). 

Effectiveness: In accordance with biological opinion.

Applicable Alternatives All action alternatives. 

Final Environmental Impact Statement for the Rosemont Copper Project

B-37
FS-BR-11 – Monitoring and control of actions to reduce or prevent impacts to Chiricahua leopard frog from invasiv

Element Description

Description This mitigation includes specific actions to monitor, identify, and remove invasive species (including American 

crayfish, tiger salamanders, and warm-water, spiny-rayed fish species) that could impact the Chiricahua leopard 

Creek Watershed Conservation Fund may be used for fund these activities and to support approved managemen

County to control invasive aquatic species in the Cienega Creek Nature Preserve above and below Pantano Dam 

Rosemont Copper has prepared a preliminary invasive species management plan (Rosemont Copper 2012b). Th

outlines some invasive species and general management plans. It states that the plan “will be updated to address 

species, including bullfrogs and northern crayfish, in wetland and riparian habitats, as well as selected stock tank

consultation is complete.” Methods for implementation of this program would be outlined in the final invasive s

plan.

Precautions would be taken to avoid creating habitat in the active operations area that could become an attractiv

enter the active operations area, specifically focusing on the propensity of stormwater ponds to act as potentially 

Alternatives to traditional stormwater pond construction, operation, etc., would be explored to minimize water h

maximum extent practicable without compromising the primary function of the ponds.

Rosemont Copper would monitor suitable habitat on NFS and Rosemont Copper owned land within habitat with

operations area, including the utility corridor and onsite stormwater ponds, would be monitored by Rosemont C

from July 1 through September 30 while the mine is in operation. If Chiricahua leopard frogs are detected on sit

the active operations area, they would be relocated to suitable habitat within the management area under close c

local recovery group.

Source Biological opinion. See conservation measures and/or terms and conditions for Chiricahua leopard frog.

Impacts Mitigated This would reduce impacts to Chiricahua leopard frog from invasive species such as American bullfrogs, crayfis

species.

Location The tanks renovated as part of the Chiricahua leopard frog biological opinion stipulations; new tanks constructe

stipulations during the life of the project; and at other suitable Chiricahua leopard frog habitats within the perim

biological opinion for further detail. 

Monitoring / Reporting 

Action

Implementation: Commencing in the first year copper is produced, annual monitoring of disturbed areas within 

be conducted to determine occurrence of invasive plant species and implement best management practices to pre

spread. The observed occurrence, or the discovery, of nonnative species would be reported to the USFWS within 

Suitable habitat within 1 mile of the active operations area would be monitored twice monthly from July 1 throu

the mine is in operation. If Chiricahua leopard frogs are detected within 1 mile of the active operations area, the

suitable habitat within the management area. The results of any monitoring efforts conducted and a summary of 

their corrective actions) that occurred during project implementation would be reported. The report would make 

modifying or refining potential future conservation measures for implementation of similar projects that are like

conservation benefit to Chiricahua leopard frogs.

Effectiveness: Monitoring of effectiveness of treatment efforts after invasive species are identified.

Performance Criteria Implementation: Best management practices would be implemented for all equipment. 

Effectiveness: Invasive species would remain at levels similar to or less than those observed prior to constructio

B-38 Final Environmental Impact Statement for the Rosemont Copper Project
Element Description

Responsible Party Implementation and Effectiveness: The Forest Service is responsible for monitoring the implementation of an

mitigation that are specified as requirements of the USFWS biological opinion. Rosemont Copper is responsible 

monitoring, implementing control activities, and reporting to the Forest Service.

Timing Implementation and Effectiveness: Commencing the first year copper is produced and continuing in accordan

opinion.

Applicable Alternatives All action alternatives.

FS-BR-12 – Relocation of Chiricahua leopard frogs from areas in the immediate vicinity of the project area

Element Description

Description Survey, monitor, capture, and relocation of Chiricahua leopard frogs; disinfection methods; testing for chytridio

Predisturbance surveys would follow Arizona Game and Fish Department (AGFD)/USFWS survey protocols. S

latest version of standard disinfection techniques to guard against the spread of disease between the surveyed tan

features. If Chiricahua leopard frogs are located in the survey area, Rosemont Copper would contact the Corona

and relocation or otherwise determine their fate. Prior to relocation, captured frogs would be tested for chytridio

dying frogs would be tested for chytridiomycosis, and periodic testing of live frogs would also be required. The 

approve the vendors where samples would be sent for testing.

Source Biological opinion conservation measures and/or terms and conditions.

Impacts Mitigated Would avoid or minimize impacts to Chiricahua leopard frogs. Methods prevent spread of disease, especially ch

Location Predisturbance surveys would be conducted of suitable habitat within the footprint of proposed construction and 

the security fence prior to construction. Annual surveys would be conducted within the perimeter fence and with

within 1 mile of the perimeter fence. 

Monitoring / Reporting 

Action

Implementation and Effectiveness: In accordance with biological opinion. 

Performance Criteria Implementation and Effectiveness: In accordance with biological opinion.

Responsible Party Implementation and Effectiveness: The Forest Service is responsible for monitoring the implementation of an

mitigation that are specified as requirements of the USFWS biological opinion. Rosemont Copper is responsible 

monitoring, and reporting as specified in the biological opinion. Rosemont Copper is responsible for alerting the 

Chiricahua leopard frogs be found in the survey area to facilitate capture and relocation; and for testing any capt

relocation, or dead or dying frogs; and for periodic testing of up to 10 samples from live healthy appearing frogs 

biological opinion conservation measures and/or terms and conditions for Chiricahua leopard frogs for specific 

would note any American bullfrogs or other nonnative invasive aquatic species encountered during survey.

Timing Implementation and Effectiveness: Predisturbance surveys would be conducted in the survey season prior to i

activities. Annual surveys would occur from premining through final reclamation and closure, commencing the 

construction activities begin.

Applicable Alternatives All action alternatives.

Final Environmental Impact Statement for the Rosemont Copper Project

B-39
FS-BR-13 – Measures to ensure relocation of lesser long-nosed bat and other bat species in the immediate vicinity 

Element Description

Description Rosemont Copper would close 20 abandoned mine features that may be impacted by mine activities, including t

Rosemont Copper would also fence the R2 Mine and Helena Mine complex to exclude unauthorized human acc

the project any new major roost sites (more than 100 lesser long-nosed bats or other cave or mine dwelling bats 

detected within 1 mile of the perimeter fence, it would be fenced or otherwise protected from unauthorized hum

approved by the Forest Service. These are part of predisturbance survey and implementation measures to ensure 

not trapped in abandoned adits or that they do not succumb to mining activities (see the biological opinion for fu

Rosemont Copper would also conduct a monitoring program to evaluate the effectiveness of protection measure

known lesser long-nosed bat roosts. Monitoring would include methods to evaluate: (a) as appropriate, any colli

predation over existing levels, or other sources of lesser long-nosed bat mortality associated with the protective 

term integrity of structures installed as part of the protective measures; (c) any impacts to exit and return behavi

bats that may be caused by the protective measures; and (d) the effectiveness of the protective measures in reduc

other impacts to lesser long-nosed bat roosts. Preinstallation assessment of the disturbance and other impacts mu

changes can be detected.

Rosemont Copper would implement protective measures at a known lesser long-nosed bat roost site within or as 

area as possible. This known roost, as well as the appropriate associated protective measures, would be evaluate

coordination with USFWS, other applicable agencies, and the landowner or manager. 

If the Forest Service or Rosemont Copper or their agents observe a significant decline in the numbers of lesser l

abandonment at either the R-2 or Helena lesser long-nosed bat roosts, protective measures would be applied to a

long-nosed bat roost within or as close to the action area as possible (see the biological opinion for a description 

Also see biological opinion lesser long-nosed bat term and condition 1(b) for specifics regarding significant dec

measures. Measures would comply with conservation measures and/or terms and conditions described in the bio

both the measures and location would be approved and coordinated with USFWS, other applicable agencies, and 

manager. 

Protective measures agreed upon by the Forest Service, USFWS, and other applicable agencies for the selected r

include completion of any environmental compliance requirements and implementation within 1 year of roost si

Rosemont would be required to reclaim the short road segment leading to the R-2 adit roost site, including the u

the Forest Service, Rosemont Copper, USFWS, and other entities determine that site conditions would support t

the likelihood of human intrusion at this roost site. It is anticipated that this would entail closing the road with a 

little resulting ground disturbance.

Any other project activities that would occur in proximity to known lesser long-nosed bat roosts during the time 

long nosed bats are present in the USFWS biological opinion action area would implement conservation measur

conditions related to known lesser long-nosed bat roost protection measures (see biological opinion terms and co

long-nosed bat for further detail). Such activities could typically be carried out from November 1 to July 1 of ea

Source Biological opinion conservation measures and/or terms and conditions; the Coronado. This measure was put for

as a voluntary conservation measure for consideration under consultation with the USFWS under the ESA. Thes

measures are no longer considered voluntary for the purposes of this appendix, as implementation of these conse

required under the biological opinion.

B-40 Final Environmental Impact Statement for the Rosemont Copper Project
Element Description

Impacts Mitigated Would reduce impacts to lesser long-nosed bats and other bat species. This measure would keep bats that are roo

the mine (including the footprint) from onsite mortality by forcing bats to relocate.

Location Chicago Mine; R2 Mine, Helena Mine complex, and other sites as specified in the biological opinion for lesser l

the biological evaluation for other cave and mine dwelling bat species. 

Monitoring / Reporting 

Action

Implementation and Effectiveness: With input from the USFWS and other applicable agencies, Rosemont Cop

monitoring program to evaluate the effectiveness of protective measures implemented at known lesser long-nose

post-implementation monitoring will occur at these roost sites, with an annual report to the USFWS for a period 

pre-implementation monitoring and 3 seasons of post-implementation monitoring). Additional reporting require

the biological opinion terms and conditions for lesser long-nosed bat.

Performance Criteria Implementation and Effectiveness: In accordance with the biological opinion. The Forest Service is responsib

implementation of any components of this mitigation that are specified as requirements of the USFWS biologica

Responsible Party Implementation and Effectiveness: Rosemont Copper is responsible for closure, fencing, monitoring, and repo

biological opinion. 

Timing Implementation and Effectiveness: Prior to project construction. Refer to the biological opinion terms and con

nose bats. Pre- and post-implementation monitoring would occur at these roost sites, with an annual report to the 

of 4 years (refer to the biological opinion conservation measures and/or terms and conditions for lesser long-nos

detail). Monitoring would include a minimum of three visits per season. The Forest Service would report to the 

received from Rosemont Copper related to the monitoring of known lesser long-nosed bat roosts and reconnaiss

within 10 working days of each monitoring or survey effort. The Forest Service would report the intent to close 

supports 30 or more lesser long-nosed bats to the USFWS at least 30 days prior to initiating exclusion and closu

Applicable Alternatives All action alternatives.

FS-BR-14 – Measures to reduce impacts to western yellow-billed cuckoo

Element Description

Description Limitation on vegetation clearing during western yellow-billed cuckoo nesting season. Includes monitoring for n

billed cuckoo and limitation on clearing while nesting is occurring.

Source Biological evaluation and biological opinion conservation measures and/or terms and conditions.

Impacts Mitigated Would reduce or avoid impacts to western yellow-billed cuckoo.

Location Any area where vegetation clearing is proposed within 50 meters of an active western yellow-billed cuckoo nest 

active western yellow-billed cuckoo territory, including disturbance in riparian areas with suitable habitat (ripari

xeroriparian).

Final Environmental Impact Statement for the Rosemont Copper Project

B-41
Element Description

Monitoring / Reporting 

Action

Implementation and Effectiveness: Rosemont Copper would survey for western yellow-billed cuckoo in those 

project area that have potential habitat (e.g., Barrel Canyon, McCleary Canyon) before trees (including large me

perimeter fence boundary are removed, in accordance with current protocol approved by the Forest Service. Veg

not occur within 50 meters of an active western yellow-billed cuckoo nest or the center of an active western yell

territory during yellow-billed cuckoo nesting period. Should vegetation clearing be proposed during the western 

nesting season, Rosemont Copper shall coordinate with the Forest Service and USFWS prior to vegetation clear

yellow-billed cuckoo habitat.

Performance Criteria Implementation and Effectiveness: In accordance with the biological evaluation and biological opinion. The F

responsible for monitoring the implementation of any components of this mitigation that are specified as require

biological opinion.

Responsible Party Implementation and Effectiveness: Rosemont Copper is responsible for predisturbance surveys and for ensuri

activities are appropriately monitored. 

Timing Implementation and Effectiveness: Survey would be conducted during nesting season within suitable habitat w

portions of the perimeter fence area annually for the first 5 years of mine operation, prior to ground-disturbing a

Applicable Alternatives All action alternatives.

FS-BR-15 – Measures to protect two occurrences of Coleman’s coral-root during road decommissioning

Element Description

Description Coleman’s coral-root (Forest Service sensitive) occurs on two locations on National Forest System roads (NFSR

which are scheduled for decommissioning. These locations would be identified on the ground before decommiss

and disturbance would be avoided. 

Source Coronado ID team.

Impacts Mitigated Would avoid direct impacts to specific locations of Forest Service sensitive plants.

Location NFSRs 4051 and 4051A.

Monitoring / Reporting 

Action

Implementation: Pre-activity surveys would occur during blooming season (typically April through May) to id

locate vulnerable populations on the ground (flagging or other method would be used to identify area to be avoi

Effectiveness: Daily inspections would occur while decommissioning activities were taking place in the vicinity 

populations to ensure that they are avoided. Inspection results that identify disturbance to Coleman’s coral-root 

decommissioning would be reported to the Coronado within 24 hours. Otherwise, the results of inspections wou

reported in quarterly and annual monitoring reports.

Performance Criteria Implementation and Effectiveness: Plant populations to be protected would be located on the ground in advan

activities; plants would ultimately be protected by avoiding conducting ground-disturbing activities near their oc

Responsible Party Implementation and Effectiveness: Rosemont Copper is responsible for confirming populations of protected p

impacted by road decommissioning activities and for monitoring implementation of such activities to ensure tha

impacted.

Timing Implementation and Effectiveness: During road decommissioning activities (premining phase).

Applicable Alternatives All action alternatives.

B-42 Final Environmental Impact Statement for the Rosemont Copper Project
FS-BR-16 – Establishment of the Cienega Creek Watershed Conservation Fund, to be used for future mitigation in 

watershed

Element Description

Description Rosemont Copper would establish an endowment, the Cienega Creek Watershed Conservation Fund, and provid

funding. This fund would essentially be established as: (1) a resource to help restore the watershed to a function

(2) a mechanism to promote adaptive management and allow flexibility in mitigation to achieve desired outcom

uncertainties.

Funds would be used to increase water flows and enhance wetlands in the Cienega Creek watershed and to impl

mitigations and management strategies to offset unanticipated effects resulting from groundwater drawdown fro

necessary. Administrative costs for the fund would not be included in the $2,000,000 and would be provided sep

the biological opinion. Monies would be spent for on-the-ground restoration, rather than inventory, monitoring, 

The conservation fund would be managed by a to-be-designated third party. The location and design of projects 

by the BLM, with input from other key stakeholders in the watershed, including the Coronado and USFWS. Pro

designed to preserve and enhance aquatic and riparian ecosystems, protect and maintain habitat for federally list

species, and increase water flows and enhance wetlands in the Cienega Creek watershed. 

Refer to the biological opinion for further details.

Source Biological opinion conservation measures and/or terms and conditions. This measure was put forth by Rosemon

conservation measure for consideration under consultation with the USFWS under the ESA. These conservation 

longer considered voluntary for the purposes of this appendix, as implementation of these conservation measure

biological opinion.

Impacts Mitigated Would potentially mitigate for or offset impacts to Chiricahua leopard frog, Gila chub, Gila topminnow, Huachu

southwestern willow flycatcher, and western yellow-billed cuckoo. 

Location Use of funds from the Cienega Creek Watershed Conservation Fund would be limited to the Cienega Creek wat

Rosemont Copper permitted grazing allotments on NFS lands.

Monitoring / Reporting 

Action

Implementation and Effectiveness: In accordance with the biological opinion.

Performance Criteria Implementation and Effectiveness: In accordance with the biological opinion. The Forest Service is responsib

implementation of any components of this mitigation that are specified as requirements of the USFWS biologica

Responsible Party Implementation and Effectiveness: Rosemont Copper would be responsible for funding the conservation fund 

$200,000/year for 10 years beginning on Apri1 1 of the year following the year in which copper concentrates ar

addition to funding administrative costs as required in the biological opinion. The Forest Service is responsible f

the fund has been established as required by the biological opinion. 

The BLM other stakeholders would be responsible for identifying potential mitigation actions; coordinating tho

Forest Service, USFWS, and other key stakeholders; overseeing expenditures of the fund; and all monitoring an

Timing Implementation and Effectiveness: In accordance with the biological opinion.

Applicable Alternatives All action alternatives.

Final Environmental Impact Statement for the Rosemont Copper Project

B-43
FS-BR-17– Future modification of allotment management plans

Element Description

Description Rosemont Copper would prepare and submit to the Coronado a request to modify the allotment management pla

DeBaud, Greaterville, and Rosemont Forest Service grazing allotments within 1 year of issuance of the ROD. T

be developed in consultation, cooperation, and coordination with the Coronado range staff, with input from othe

and would include the following: 

• To mitigate for the loss of flowering agaves for the lesser long-nosed bat due to the proposed mine, grazing 

restricted during the April 1 to June 15 period through rotation to alternative pastures on approximately 8,0

the Thurber, DeBaud, Greaterville, and Rosemont allotments that currently are permitted to be grazed durin

period. This could increase foraging resources for the lesser long-nosed bat. Prior to submittal of proposed 

allotment management plan, Rosemont Copper would refine existing estimates of Palmer agave that would 

security fence area and conduct studies sufficient to identify and establish baseline conditions of pastures th

for modification for seasonal grazing restrictions to increase flowering success of agave.

• Portions of pastures within these grazing allotments would be put on a winter rotation to limit grazing durin

within riparian areas. This could enhance riparian vegetation. Key pastures would be rested for extended pe

available for grazing when forage production on active pastures is reduced because of drought or other fact

element could enhance overall production within the allotments without the reduction of current cattle stoc

In addition, Rosemont Copper would conduct a scientifically designed study to document the efficacy of season

to enhance agave flowering success. The study would be implemented annually for 5 years following approval o

management plan and implementation of grazing management practices. Also see FS-BR-04 for requirements fo

agave impacted within the security fence.

Rosemont Copper; biological opinion conservation measures and/or terms and conditions. This measure was pu

Copper as a voluntary conservation measure for consideration under consultation with the USFWS under the ES

measures are no longer considered voluntary for the purposes of this appendix, as implementation of these conse

required under the biological opinion.

Impacts Mitigated To be determined, depending on final decision of allotment management plans.

Location Thurber, DeBaud, Greaterville, and Rosemont Forest Service grazing allotments.

Monitoring / Reporting 

Action

Implementation and Effectiveness: To be determined.

Performance Criteria Implementation and Effectiveness: To be determined.

Responsible Party Implementation and Effectiveness: The Forest Service is responsible for monitoring the implementation of an

mitigation that are specified as requirements of the USFWS biological opinion. Rosemont Copper is responsible 

submitting a request to modify allotment management plans. The Forest Service is responsible for determining w

management plans are revised and for making the final decision on plan modifications.

Timing Implementation and Effectiveness: To be determined.

Applicable Alternatives All action alternatives.

B-44 Final Environmental Impact Statement for the Rosemont Copper Project
FS-BR-18 – Predisturbance surveys for Forest Service sensitive species

Element Description

Description This mitigation includes predisturbance survey for a subset of Forest Service sensitive species, and cooperative 

implementation of a survey plan. Rosemont Copper would conduct a complete habitat-specific inventory of the 

footprint within suitable habitat as outlined in an approved plan for the following Forest Service sensitive specie

invertebrate) at least 30 days prior to ground disturbance:

• Plants

o Arizona coral-root*

o Arizona giant sedge*

o Arizona manihot*

o Bartram stonecrop*

o Beardless chinchweed*

o Chiricahua mountain brookweed

o Huachuca golden aster

o Lemon lily

o Santa Rita yellowshow*

o Southwestern muhly*

• Invertebrate

o Cestus skipper

These species were identified by the Coronado as species that need additional mitigation because they are presen

present) within the project and/or analysis area and are imperiled, critically imperiled, and/or proposed for Fede

Rosemont Copper would work cooperatively with the Coronado, USFWS (for species proposed for federal listin

conservation partners to develop a survey plan that would include survey protocols for the 11 species, as well as 

strategy for addressing species that are found in disturbance areas, such as documentation, collection, translocat

The survey plan would address surveys that have already been conducted within the Rosemont project area (pre

species are marked with an asterisk (*) in the list above). Survey would be conducted within suitable habitat and 

season for each species at least 30 days prior to ground disturbance. The written plan would be included with th

Also see FS-BR-02 for preconstruction survey requirements for Coleman’s coral-root.

Source Coronado ID team. Also included in the biological evaluation.

Impacts Mitigated This would avoid or reduce impacts to Forest Service sensitive plant species and one invertebrate species.

Location NFS habitat-specific lands disturbed by project.

Monitoring / Reporting 

Action

Implementation: Rosemont Copper would report results of surveys in post-survey monitoring reports. 

Effectiveness: Rosemont Copper would report any species located in disturbance areas to the biological monito

discovery. Measures or strategies contained for addressing the located species would be carried out in accordanc

developed plan. Should Forest Service sensitive species be translocated, subsequent monitoring would be determ

basis.

Performance Criteria Implementation and Effectiveness: The survey plan would be developed prior to predisturbance survey and w

protocols and survey seasons that are approved by the Coronado, in consultation with other conservation partner

Final Environmental Impact Statement for the Rosemont Copper Project

B-45
Element Description

Responsible Party Implementation and Effectiveness: Rosemont Copper is responsible for coordinating preparation of a plan or 

with located species and for conducting and reporting predisturbance surveys. The Forest Service is responsible 

or strategy and for coordinating with other conservation partners as deemed appropriate.

Timing Implementation and Effectiveness: Predominantly during premining (construction of facilities); also requires 

have been recovered from initial disturbance that would undergo further disturbance during the final reclamation 

of facilities) phases, such as the utility corridor on NFS lands.

Applicable Alternatives All action alternatives.

FS-BR-19 – Measures to reduce impacts to jaguar

Element Description

Description This measure includes limiting speeds on the primary and secondary access roads and the Sycamore Connector 

25 miles per hour and employing the use of wildlife crossing signs. 

In addition, Rosemont Copper would conduct (or provide funding to conduct) jaguar surveys and monitoring for 

proposed mine plus the 5-year postclosure period, in accordance with requirements specified in the jaguar terms 

biological opinion. Jaguar survey and monitoring would be conducted through noninvasive means, including the 

and/or scat-detection dogs. 

Rosemont Copper would monitor the impacts of the project as they relate to jaguar and report these to the USFW

project. Requirements for the monitoring report are specified in the jaguar terms and conditions in the biologica

Additional details on jaguar surveys and monitoring are contained in the USFWS biological opinion terms and c

Source Biological opinion terms and conditions for jaguar.

Impacts Mitigated This would gather data and information that would be used to reduce or avoid impacts to jaguar.

Location As specified in the biological opinion jaguar terms and conditions.

Monitoring / Reporting 

Action

Implementation and Effectiveness: In accordance with the jaguar terms and conditions specified in the USFW

Performance Criteria Implementation and Effectiveness: In accordance with the biological opinion. Speed limit signs are placed in 

Signs cautioning vehicle operators of the presence of wildlife are placed at both ends and the midpoint of the pri

at any other locations determined necessary by the Coronado. Prior to the commencement of any fieldwork: (1) 

final) would be submitted to and approved by the USFWS and other entities; and (2) all necessary permits woul

which must be sent to USFWS and other entities as applicable (see biological opinion terms and conditions for j

detail). All jaguar detections would be reported to USFWS and other applicable agencies within 24 hours. 

Responsible Party Implementation and Effectiveness: The Forest Service is responsible for monitoring the implementation of an

mitigation that are specified as requirements of the USFWS biological opinion. Rosemont Copper is responsible 

the Forest Service is responsible for ensuring that implementation adheres to biological opinion requirements.

Timing Implementation and Effectiveness: In accordance with the biological opinion. Jaguar survey and monitoring m

significant surface disturbance. A monitoring report would be due to the USFWS annually on March 1.

Applicable Alternatives All action alternatives.

B-46 Final Environmental Impact Statement for the Rosemont Copper Project
FS-BR-20 – Funding of NEPA analysis required for implementation of mitigation measures or changes in the MPO 

surface resources

Element Description

Description Most mitigation and monitoring measures are not likely to require additional NEPA analysis; however, some mea

locations or details that would be determined at a later date. Therefore, Rosemont Copper has agreed to enter into 

agreement with the Coronado to fund any additional NEPA analysis required to implement any mitigation measu

MPO. The collection agreement would also include funding any additional NEPA analysis that is determined to b

changes in the final MPO that would affect NFS surface resources. The collection agreement would be in place a

MPO is approved. This measure may be refined with further details once the collection agreement is finalized and 

parties. 

Source Coronado National Forest; Rosemont Copper.

Impacts Mitigated Various; would ensure that all mitigation measures can be implemented and that changes in the final MPO that tr

addressed in a timely manner.

Location Various.

Monitoring / Reporting 

Action

Implementation and Effectiveness: Forest Service would determine necessity for additional NEPA analysis and 

Rosemont Copper would provide adequate funds to accomplish NEPA analysis. This would be applicable only at 

necessary for a categorical exclusion or environmental assessment.

Performance Criteria Implementation and Effectiveness: NEPA analysis is completed as required for any mitigation measures and/or 

MPO that trigger NEPA.

Responsible Party Forest Service: oversight; Rosemont Copper: funding.

Timing All phases.

Applicable Alternatives All action alternatives.

FS-BR21 – Recordation of a restrictive covenant or conservation easement on private land parcels in Davidson Ca

loss of habitat for listed species

Element Description

Description This mitigation would require Rosemont Copper to record restrictive covenants or conservation easements on th

Watershed Parcels. These parcels total 383 acres in Davidson Canyon. The restrictive covenant would preclude r

and similar land use activities and would restrict grazing activities. The parcels include ephemeral wash and ripa

approximately 5,000 feet of Davidson Canyon and approximately 3,000 feet of Barrel Canyon and portions of M

East Fork of Davidson Canyon. Approximately 15.5 acres of ephemeral drainages are included, including three s

riparian habitat, and 190 acres of upland buffer habitat adjacent to riparian. These parcels would be included as a

establishment of water features (see FS-BR-05) beneficial to listed species such as Chiricahua leopard frog, jagu

provide general wildlife benefits. Managed grazing, cultural, and some low-impact public use (hiking, bird watch

hunting, etc.) would be allowed in some locations. None of the conservation actions outlined for the Davidson C

parcels would preclude reasonable access to these parcels by interested Native American groups.

Final Environmental Impact Statement for the Rosemont Copper Project

B-47
Element Description

Source Biological opinion conservation measures and/or terms and conditions. This measure was put forth by Rosemont 

conservation measure for consideration under consultation with the USFWS under the ESA. These conservation 

considered voluntary for the purposes of this appendix, as implementation of these conservation measures is requ

biological opinion.

Impacts Mitigated Would compensate for loss of habitat for listed species (including Chiricahua leopard frog, jaguar, and ocelot); lo

loss of upland buffer habitat; and loss of recreational use. Potentially mitigates for cultural impacts to Native Am

reasonable access to culturally important areas. This mitigation may also be included in the CWA Section 404 pe

WUS. However, that permit has not been issued, and its stipulations are not currently known.

Location Davidson Canyon watershed parcels.

Monitoring / Reporting 

Action

Implementation: Recordation of a restrictive covenant in accordance with the biological opinion would be requ

restrictive covenant would be provided to the Forest Service.

Effectiveness: In accordance with requirements in the biological opinion, if any. 

Performance Criteria Implementation: Restrictive covenant would restrict and allow land uses in accordance with requirements speci

opinion. Such restrictive covenant would be recorded in the time frame specified in the biological opinion.

Effectiveness: In accordance with requirements in the biological opinion, if any.

Responsible Party Implementation: The Forest Service is responsible for monitoring the implementation of any components of thi

specified as requirements of the USFWS biological opinion. Rosemont Copper is responsible for crafting and rec

covenant that meets the requirements specified in the biological opinion.

Effectiveness: In accordance with requirements in the biological opinion, if any.

Timing Implementation: In accordance with requirements in the biological opinion.

Effectiveness: In accordance with requirements in the biological opinion, if any.

Applicable Alternatives All action alternatives.

Other Monitoring Items for Biological Resources 

FS-BR-22 – Monitoring to determine impacts from pit dewatering on downstream sites in Barrel and Davidson Can

Element Description

Description This measure consists of monitoring in Barrel and Davidson Canyons to evaluate impacts from groundwater dra

water features following the conceptual monitoring plans prepared by Rosemont Copper:

• Water and Earth Technologies 2012. “Davidson Canyon Conceptual Surface-Water Monitoring Plan.” 

• Engineering Analytics. 2012. “Davidson Canyon Conceptual Groundwater Monitoring Plan.” March 3

This also includes a biological opinion requirement to monitor geomorphic changes to Davidson Canyon. Four s

established and monitoring conducted using Forest Service protocol or other method approved to by the Forest S

shows Cienega Creek is being impacted, the Cienega Creek Watershed Conservation Fund may be used as a res

mitigation projects.

B-48 Final Environmental Impact Statement for the Rosemont Copper Project
Element Description

Source Biological opinion conservation measures and/or terms and conditions. This measure was put forth by Rosemon

conservation measure for consideration under consultation with the USFWS under the ESA. These conservation 

longer considered voluntary for the purposes of this appendix, as implementation of these conservation measure

biological opinion.

Purpose To determine existence and extent of impacts to groundwater drawdown to surface water features from pit dewa

Location A total of 10 sites is identified in the two conceptual monitoring plans:

- Weather station located on the mine site.

- BC-1. At compliance point dam in Barrel Canyon.

- BC-2. At SR 83 bridge in Barrel Canyon.

- DC-1. In upper Davidson Canyon, below Questa Spring and above confluence with Barrel Canyon.

- DC-2. In Davidson Canyon, below confluence with Barrel Canyon.

- DC-Dike. In Davidson Canyon, near hypothesized intrusive dike.

- DC-3. In Davidson Canyon, above Reach 2 spring, near beginning of Outstanding Arizona Water.

- DC-4. In Davidson Canyon, above confluence with Cienega Creek, near end of Outstanding Arizona W

- CC-1. In Cienega Creek, above confluence with Davidson Canyon.

- CC-2. In Cienega Creek, below confluence with Davidson Canyon.

For pit dewatering monitoring: a minimum of two sites in Barrel and Davidson Canyons identified in the report; 

if authorization to install and access proposed monitoring sites is obtained from the Arizona State Land Departm

authorizations for these sites are obtained, monitoring would commence at these sites. 

For geomorphic changes to Davidson Canyon: four sample sites would be established.

Final Environmental Impact Statement for the Rosemont Copper Project

B-49
Element Description

Monitoring / Reporting 

Action

Implementation and Effectiveness: In accordance with the biological opinion.

In general, the following measurements would be carried out at each monitoring location:

Location Flow Precipitation Water 

Quality

Shallow 

Well*

Deep 

Well*

Water Level 

and 

Temperature

Groundwater 

Quality Isot

BC-1 x x x X x x x 

BC-2 x x x

DC-1 x x x X x x x 

DC-2 x x x X x x x 

DC-Dike X x x x 

DC-3 x x x X x x x 

DC-4 x x x X x x x 

CC-1 x x X x x x 

CC-2 x x X x x x 

* The use of the word “well” does not imply any specific construction detail. These locations may be wells that 

sampling, piezometers accessible for water levels, or other methods suitable to access groundwater.

Performance Criteria Implementation and Effectiveness: In accordance with requirements in the biological opinion. Stormwater mo

during applicable flow events. Water level and temperature measurements would be collected continuously. Gro

would take place every quarter for the first 2 years, with a review after that time for future monitoring requireme

shall use analytical methods with a limit of quantitation that is lower than the lowest surface water standards app

water. For sampling in or immediately upstream of the Outstanding Arizona Water, a method with a detection le

background quality of the Outstanding Arizona Water for the parameter analyzed shall be used. If all methods h

quantitation higher than applicable water quality standard or background quality level, the approved analytical m

limit of quantitation shall be used.

Responsible Party Implementation and Effectiveness: The Forest Service is responsible for monitoring the implementation of an

mitigation that are specified as requirements of the USFWS biological opinion. Rosemont Copper is responsible 

reporting. 

Timing Implementation and Effectiveness: In accordance with biological opinion.

Applicable Alternatives All action alternatives.

FS-BR-23 – Monitoring to determine the extent of road-kill near the project area

Element Description

Description This monitoring involves regular field surveys to determine motor vehicle caused mortality of jaguar or ocelot o

Mortality of any Forest Service or BLM sensitive species would also be reported. In addition, Rosemont Copper 

immediately report all sightings of jaguar and ocelot to the Forest Service.

Source Biological opinion conservation measures and/or terms and conditions.

B-50 Final Environmental Impact Statement for the Rosemont Copper Project
Element Description

Purpose To determine impacts from traffic related mortality to jaguar, ocelot, and the jaguar prey base (white-tailed and 

peccary, and white-nosed coati, in particular) and to any Forest Service or BLM sensitive species.

Location Between the northern extent of currently proposed jaguar critical habitat and Gardner Canyon on SR 83 and Box 

Monitoring / Reporting 

Action

Implementation and Effectiveness: Annual reporting, as specified in the biological opinion. 

Performance Criteria Implementation and Effectiveness: As specified in the biological opinion. 

Responsible Party Implementation and Effectiveness: The Forest Service is responsible for monitoring the implementation of an

mitigation that are specified as requirements of the USFWS biological opinion. Rosemont Copper is responsible 

is carried out. 

Timing Implementation and Effectiveness: This would be conducted weekly for 4 years, commencing with mine cons

through second year of mine operations; it would then be reevaluated to determine whether additional monitorin

conducted. 

Applicable Alternatives All action alternatives. 

FS-BR-24 – Surveying and monitoring for lesser long-nosed bats

Element Description

Description Rosemont Copper would monitor the Helena Mine complex, Adit R2, plus any newly discovered large lesser lon

(>100 bats) within 1 mile of the perimeter fence annually for lesser long-nosed bat following stipulations describ

opinion. Surveys would be conducted by performing evening emergence counts. Infrared tape recordings of the 

during each survey. The number of cameras used to capture emergence on tape would be sufficient to fully docu

emergence events. Digital copies of the recordings would be provided to the Coronado. The exit counts would b

report. Monitored roost sites would not be entered, except as approved by the Coronado in coordination with US

Source Biological opinion conservation measures and/or terms and conditions.

Purpose To determine impacts to lesser long-nosed bats, determine site fidelity during mining activities and ascertain wh

artificial night light emitted by the mine is possible or prudent. 

Location Helena Mine, Adit R2, and any newly discovered large lesser long-nosed bat roost sites within 1 mile of the per

Monitoring / Reporting 

Action

Implementation and Effectiveness: As specified in the biological opinion. 

Performance Criteria Implementation and Effectiveness: As specified in the biological opinion. 

Responsible Party Implementation and Effectiveness: The Forest Service is responsible for monitoring the implementation of an

mitigation that are specified as requirements of the USFWS biological opinion. Rosemont Copper is responsible 

reporting. 

Timing Implementation and Effectiveness: Active life of the mine (premining through final reclamation and closure p

each site would be conducted three times during the late summer lesser long-nosed bat survey period: July, Aug

One of the surveys during the survey season at the Helena Mine would be scheduled to coincide with the region

Monitoring would be conducted annually until 5 years after final mine closure. Monitoring surveys are anticipat

2013.

Final Environmental Impact Statement for the Rosemont Copper Project

B-51
Element Description

Applicable Alternatives All action alternatives. 

FS-BR-25– Surveying for bats in the vicinity of the project area

Element Description

Description Rosemont Copper would conduct reconnaissance-level surveys of other known cave and mine features capable 

within in the perimeter fence and within 1 mile of the perimeter fence for lesser long-nosed bat and other bat spe

stipulations described in the biological opinion. Features known or suspected to have minor numbers of lesser lo

would be monitored by external exit count or other remote sensing method approved by the Coronado. Caves or 

suspected to be occupied by lesser long-nosed bat would not be entered.

Source Biological opinion conservation measures and/or terms and conditions.

Purpose Assessment of impacts to lesser long-nosed bats and Forest Service and BLM sensitive bat species.

Location Known mine and cave features capable of supporting bats within the perimeter fence and within 1 mile of the pe

Monitoring / Reporting 

Action

Implementation and Effectiveness: Monitoring of each site would occur once per year, on an annual basis, dur

lesser long-nosed bat survey period: July, August, and September. Reporting of monitoring results would be ma

days of each monitoring effort. Actions to be taken to protect species, if any, would be determined by the Forest 

based on monitoring results.

Performance Criteria Implementation and Effectiveness: Surveys would be conducted by performing evening emergence counts, fo

provided in the biological opinion. 

Responsible Party Implementation and Effectiveness: The Forest Service is responsible for monitoring the implementation of an

mitigation that are specified as requirements of the USFWS biological opinion. Rosemont Copper is responsible 

reporting. 

Timing Implementation and Effectiveness: Reconnaissance-level surveys shall consist of one visit to each monitored 

summer (July through September). Reconnaissance-level surveys of these other known caves and mine features 

annually for the life of the project and for 5 years following closure.

Applicable Alternatives All action alternatives.

FS-BR-26 – Annual monitoring for Chiricahua leopard frog

Element Description

Description This involves surveying and testing procedures for Chiricahua leopard frog that would provide population inform

Source Biological opinion conservation measures and/or terms and conditions for Chiricahua leopard frog.

Purpose To provide information on the status of Chiricahua leopard frog.

Location In suitable habitat within the perimeter fence area and within suitable habitat within 1 mile of the perimeter fenc

Monitoring / Reporting 

Action

Implementation and Effectiveness: In accordance with requirements in the biological opinion; surveys would 

established survey protocols. 

Performance Criteria Implementation and Effectiveness: In accordance with requirements in the biological opinion.

B-52 Final Environmental Impact Statement for the Rosemont Copper Project
Element Description

Responsible Party Implementation: The Forest Service is responsible for monitoring the implementation of any components of th

specified as requirements of the USFWS biological opinion. Rosemont Copper is responsible for conducting mo

leopard frogs and reporting results to the Forest Service. 

Effectiveness: In accordance with requirements in the biological opinion.

Timing Implementation and Effectiveness: Annually, commencing from the first spring survey period after constructi

through final reclamation and closure.

Applicable Alternatives All action alternatives.

FS-BR-27 – Periodic validation and rerunning of groundwater model throughout life of mine

Element Description

Description Collection of information needed to conduct periodic validation of groundwater model, including collection of b

input to model. In addition to the monitoring actions described below, three contingency areas have been identif

could be required to install additional piezometers if the following criteria were met. Prior to requiring any new 

the Coronado would review with Rosemont Copper the feasibility of access, the logistics and cost involved, and 

for continued water-level measurements in that location based on the entirety of the water-level data collected to 

Sycamore Canyon: HC-5B is no longer functional for water-level measurements;

West of mine pit: DH-1445 is no longer functional for water-level measurements; and

South of mine pit: RP-5 is no longer functional for water-level measurements.

Source Coronado ID team; required by biological opinion terms and conditions for Gila chub and Gila topminnow.

Purpose Monitor groundwater levels and whether there is a decrease of groundwater availability in surface features such 

groundwater model validation. 

Location Mine pit, wellheads of dewatering wells; meteorological stations; existing wells as shown on the following table

well constructed beyond the security fence.

Monitoring / Reporting 

Action

Implementation: Measurement of the volume of dewatering, preferably by installation of flow monitoring devi

wells, but other volumetric or flow measurement procedures may be implemented. Operation of two meteorolog

represent high and low elevations on the site. It is acceptable that the lower meteorological station be associated 

Geological Survey (USGS) gage on Barrel Canyon and that the higher meteorological station be required under 

depending on the final location of that station. Quarterly water-level monitoring on up to 21 existing wells, piez

Drilling, construction, development, and instrumentation of one new monitoring well at a location specified by t

preconstruction and initial development of the pit, water levels in selected locations would be measured daily or 

recording equipment in order to establish baseline measurements required under the biological opinion.

Effectiveness: Rosemont Copper would quarterly report to the Coronado the total amount of water pumped by d

otherwise removed from the pit. Rosemont Copper would collect continual meteorological measurements, condu

maintenance and calibration, and report a summary of meteorological measurements annually. Rosemont Coppe

levels from new and existing wells at least quarterly, if not continually using data loggers, and would report resu

monitoring annually. Every 5 years, Rosemont Copper would use collected data to verify the results of groundw

Final Environmental Impact Statement for the Rosemont Copper Project

B-53
Element Description

revised predictions of groundwater level changes and a comparison of how these changes differ from the same m

impacts in the EIS. Modeling would also be used prior to construction in order to predict water levels in selected 

under the biological opinion.

Performance Criteria Implementation: Monitoring devices would be installed and calibrated. Well construction and installation reco

to the Coronado.

Effectiveness: Hydrologic monitoring data would be reported quarterly. Model validation report would be prov

Responsible Party Implementation: Rosemont Copper is responsible for installation of all equipment and wells; the Coronado is r

well locations and construction details, conducting appropriate NEPA compliance, and spot-checking drilling pe

disagreement regarding the accessibility of a proposed well location, officials from Rosemont Copper would me

personnel in the field to determine whether the problem can be resolved, either by moving the proposed well loc

existing roads.

Effectiveness: Rosemont Copper is responsible for all monitoring and reporting. The Coronado is responsible fo

contingency wells need to be installed and for conducting any necessary NEPA compliance documentation. The 

with Rosemont Copper prior to making any decision regarding contingency wells to ensure that installation is te

logistically feasible.

Timing Implementation and Effectiveness: Premining phase through 5 years after closure. Selected locations may be m

required under the biological opinion.

Applicable Alternatives All action alternatives.

Wells to Be Monitored in Relation to FS-BR-27

Cadastral Location Well Name

(D-18-16) 15aaa RP-7

(D-18-16) 15dbc RP-6

(D-18-16) 20dbc HC-4B

(D-18-15) 35abc DH-1445

(D-18-16) 23dba RP-8

(D-18-16) 27ddc RP-9

(D-18-16) 28aba RP-2C

(D-18-16) 29bbd P-899

(D-18-16) 30bab HC-5B

(D-18-16) 33bbc RP-3B

(D-19-16) 02ccd Oaktree Windmill

(D-19-16) 04ddb DH-1541

(D-19-16) 06cca RP-5

(D-19-16) 18ddb 18ddb

B-54 Final Environmental Impact Statement for the Rosemont Copper Project
Cadastral Location Well Name

(D-19-16) 01bab HC-1B

(D-18-16) 30bd C-1

(D-19-16) 16cbb 16cbb

(D-19-16) 17bdb 17bdb

(D-19-15) 01aac HC-6

(D-19-16) 17ddd Rosemont Ranch

(D-18-15) 22daa 22daa

FS-BR-28 – Monitoring of water quality in potential Chiricahua leopard frog habitat

Element Description

Description Rotational water quality monitoring of potential Chiricahua leopard frog habitat, including stock tanks and new/

FS-BR-05), in order to assess the potential for elevated concentrations of contaminants.

Source Coronado ID team.

Purpose Identify whether potential Chiricahua leopard frog habitat is not exceeding applicable Arizona Surface Water Q

wildlife.

Location Various water sources, to be determined, on NFS lands.

Monitoring / Reporting 

Action

Implementation and Effectiveness: Rosemont Copper would undertake rotational water quality sampling of st

new/enhanced waters. Four water quality samples would be collected per year, at locations determined by the Fo

quality samples would be analyzed for any constituents with applicable numeric Arizona Surface Water Quality 

Results would be reviewed by Forest Service lead for Chiricahua leopard frog and shared with appropriate Chiri

interagency specialists.

Performance Criteria Implementation and Effectiveness: Results of monitoring are provided to the Coronado annually.

Responsible Party Implementation and Effectiveness: Rosemont Copper is responsible for performing all monitoring activities. F

responsible for determining which locations should be sampled each year.

Timing Implementation and Effectiveness: Until mining and processing operations cease.

Applicable Alternatives All action alternatives.

Landownership and Boundary Management

FS-LO-01 – Resurveying of existing survey monuments and land lines to allow reestablishment postmining

Element Description

Description A BLM administered land resurvey and control network has been completed.

Source Coronado ID team.

Impacts Mitigated Would rectify impacts to survey monuments and landownership boundaries from mining and related actions.

Final Environmental Impact Statement for the Rosemont Copper Project

B-55
Element Description

Location Approximately 202 mineral survey corner monuments that control approximately 19.5 miles of property boundar

and private land owned by Rosemont Copper within or very near the footprint of the proposed action on the Coro

Monitoring / Reporting 

Action

Implementation and Effectiveness: Implementation by the BLM has been completed. No further monitoring is 

Performance Criteria Implementation and Effectiveness: BLM criteria have been met.

Responsible Party Implementation and Effectiveness: Rosemont Copper funded dependent resurvey efforts.

Timing Implementation and Effectiveness: Completed.

Applicable Alternatives All action alternatives.

FS-LO-02 – Reestablishment of survey monuments and surveyed land line upon completion of final reclamation

Element Description

Description Upon reclamation, survey monuments would be restored, and landownership boundaries would be properly mark

Source Coronado ID team.

Impacts Mitigated Would rectify impacts to survey monuments and landownership boundaries by restoring survey monuments and l

boundaries.

Location Currently, approximately 19.5 miles of property boundary between NFS lands and private land owned by Rosem

very near the footprint of the proposed action on the Coronado National Forest. (Exact locations are not known at 

Monitoring / Reporting 

Action

Implementation and Effectiveness: Monitoring and reporting protocol would be determined by the Forest Servi

procedures in place at that time for reestablishing survey monuments and land lines. 

Performance Criteria Implementation: Upon reclamation and closure, Rosemont Copper would use the BLM’s “Field Notes of the De

restore survey monuments referring to global positioning system (GPS) control network.

Effectiveness: Closure actions would result in conditions that meet specifications in the final reclamation and clo

Responsible Party Implementation: Rosemont Copper would fund a Forest Service approved Arizona licensed surveyor to oversee 

restoration of survey monuments and boundaries. Rosemont Copper would provide personnel, equipment, and m

physical monuments where needed.

Monitoring: Rosemont Copper is responsible for conducting monitoring and reporting to the Forest Service. 

Timing Implementation: Closure.

Effectiveness: Final closure and postclosure until surveying and boundary management objectives have been me

Applicable Alternatives All action alternatives.

Dark Skies

FS-DS-01 – Implementation of an outdoor lighting plan that would reduce potential impacts from artificial night lig

Element Description

B-56 Final Environmental Impact Statement for the Rosemont Copper Project
Element Description

Description This mitigation involves following Rosemont Copper’s outdoor lighting mitigation plan (Monrad et al. 2012b) du

operation of the mine.

Following construction of the mine and during the initial year of operation, Rosemont Copper would work with th

review the efficacy of light mitigation measures at key resource areas around the mine, such as the Helena Mine. 

could be placed to further reduce lighting effects without adverse consequences to safety and unreasonable operat

Rosemont Copper would implement the additional requested shielding in a manner consistent with safe mining p

Source Rosemont Copper; biological opinion conservation measures and/or terms and conditions.

Impacts Mitigated Compared with the initial MPO, this lighting mitigation plan would reduce potential impacts from artificial night 

and recreational astronomy and to wildlife species, including lesser long-nosed bats and Mexican spotted owls. S

(2012b) “Rosemont Copper Project Light Pollution Mitigation Recommendation Report,” Revision 1, dated June 

as well as the Monrad (2012) “Rosemont Mine–Mitigation Recommendation Report Addendum,” dated August 1

Resources, Inc. (2012i), further analyzed the Monrad et al. (2012b) findings to interpret effects on wildlife. 

Location All areas requiring outside night lighting, including facilities, pit, plant site, and equipment mounted light system

least 12 miles (WestLand Resources Inc. 2012i).

Monitoring / Reporting 

Action

Implementation: Fixtures would be inspected before installation to ensure that lighting equipment complies with 

would incorporate the Monrad et al. (2012b) “Rosemont Copper Project Light Pollution Mitigation Recommenda

1 (June 18, 2012), and Monrad (2012) addendum (August 17, 2012). 

Effectiveness: Baseline data monitoring would occur at a frequency to be determined that represents periods of m

light use during the active mining phase. Monitoring would duplicate the baseline monitoring that is described in 

(2012b) “Rosemont Copper Project Light Pollution Mitigation Recommendation Report,” Revision 1, dated June 

(which would be incorporated into the final MPO), and the “20 Year Monitoring Plan: Light at Night (LAN) Mea

Copper Project,” dated May 20, 2012 (STEM Laboratory Inc.). Includes mobile aerial, mobile ground-based, and 

measurements. If additional shielding could be placed to further reduce lighting effects without adverse impacts t

unreasonable operational expectations, Rosemont Copper would implement that additional shielding in a manner 

mining. 

Performance Criteria Implementation: Lighting used would comply with the final MPO, which would incorporate the Monrad et al. (2

Copper Project Light Pollution Mitigation Recommendation Report,” Revision 1 (June 18, 2012), and Monrad (2

(August 17, 2012), except as personal safety or operational requirements necessitate modifications to this plan (3

Effectiveness: Monitoring would provide for review and comparison of lighting emissions of the Rosemont Copp

developments. The proposed mitigation strategy is to reduce all site lighting lumen emissions, regulated or not, to 

allowed by the Pima County Outdoor Lighting Code lumen per acre table for Zone 1a. Based on the most recent c

2012), the site lighting lumen emissions is 66 percent of the amount allowed by the Pima county Outdoor Lightin

lumen per acre table for Zone 1a. The intent is to fully comply with the Pima County Outdoor Lighting Code; how

be required to comply with Mine Safety and Health Administration (MSHA) regulations. If deviations are require

MSHA regulations, then Rosemont Copper will work to minimize the impact of these deviations.

Responsible Party Implementation and Effectiveness: The Forest Service is responsible for monitoring the implementation of any 

mitigation that are specified as requirements of the USFWS biological opinion. Rosemont Copper is responsible 

monitoring and reporting to the Forest Service. 

Final Environmental Impact Statement for the Rosemont Copper Project

B-57
Element Description

Timing Implementation: During premining phase to ensure compliance with final MPO.

Effectiveness: Annual or semiannual monitoring (in accordance with the “20 Year Monitoring Plan: Light at Nig

Measurements at Rosemont Copper Project,” dated May 20, 2012 (STEM Laboratory Inc.)). Monitoring localized 

quantitative trends in sky-brightness changes due to onsite lighting systems to establish current sources and allow 

Rosemont Copper Mine and all other new developments would determine whether predictions of lumens are accu

direct measurement of sky brightness using overflights and land-based measurements. Monitoring every 5 years d

operations phase (in accordance with the “20 Year Monitoring Plan: Light at Night (LAN) Measurements at Rose

dated May 20, 2012 (STEM Laboratory Inc.)). Review of the efficacy of light mitigation measures would occur f

of the mine.

Applicable Alternatives All action alternatives, with the exception of the proposed action.

FS-DS-02 – Funding of additional ground-based sky brightness monitoring

Element Description

Description Rosemont Copper would fund ground-based sky brightness monitoring, to take place at the Fred Lawrence Whip

Mount Hopkins and participate in a Sky Brightness Monitoring Plan Oversight Committee. This monitoring is d

the aerial-based monitoring being undertaken under measure FS-DS-01. 

Source Rosemont Copper and Smithsonian Astronomical Observatory.

Purpose This monitoring would be to establish premine and postmine baseline measurements of sky brightness as measur

Lawrence Whipple Observatory on Mount Hopkins and to monitor ongoing changes in sky brightness during the 

purpose of the monitoring would be to identify any unanticipated increases in sky brightness that occur as a resu

to identify and propose possible mitigation measures to reduce sky brightness impacts.

Location Fred Lawrence Whipple Observatory, at a single fixed site in the location previously occupied by the IOTA instr

B-58 Final Environmental Impact Statement for the Rosemont Copper Project
Element Description

Monitoring / Reporting 

Action

Implementation: (1) Within 3 months of final ROD issuance, Rosemont Copper would provide $218,069 in fun

Smithsonian Astronomical Observatory for the purchase of equipment and initiation of monitoring activities. (2) 

final ROD issuance, representatives from Rosemont Copper, the Forest Service, and the Smithsonian Astronomi

meet to finalize key components of the monitoring plan. These include the following:

• Identify an appropriate trigger and specific trigger methodology. An increase of 10 percent above the p

been proposed as the trigger; however, details need to be agreed upon for how to prevent a “false trigg

reflect operations at Rosemont Copper. This could include discussion of the number of repeated indivi

the baseline that would have to occur—and over what period of time—in order for it to constitute a tru

than an anomaly.

• Identify how regional increases in sky brightness, not associated with the Rosemont Copper Project, w

when analyzing monitoring results, including the potential for changes in the baseline over time.

• How and where the sensors would be aimed.

• Further identification of the metrics to be used and details of how they would be calculated.

(3) Upon receipt of funding and finalization of the monitoring plan, the Smithsonian Astronomical Observatory w

monitoring using the equipment and methodology as described in the document “Monitoring Program for Assess

Rosemont Copper Mine Sky Brightness as Seen from the F.L. Whipple Observatory on Mt. Hopkins,” dated Sep

(Smithsonian Astrophysical Observatory 2013), subject to changes agreed upon during the process described abo

Monitoring / Reporting 

Action

Effectiveness: (1) Rosemont Copper would provide $100,000 annually to defray costs associated with monitorin

Copper would participate in a Sky Brightness Monitoring Plan Oversight Committee; and (3) Rosemont Copper 

of the additional sky brightness monitoring to be conducted under measure FS-DS-01. 

The Sky Brightness Monitoring Plan Oversight Committee would consist of five members: one each from Fores

Lawrence Whipple Observatory; Rosemont Copper, including any necessary subcontractors; and an independent 

knowledgeable in photometric/spectroscopic measurements. The independent astronomer would be selected by t

consultation with Rosemont Copper and the Fred Lawrence Whipple Observatory. The Sky Brightness Monitori

Committee would meet quarterly and would be responsible for reviewing all pertinent data from mine operations 

conducted under this measure or measure FS-DS-01. Any substantial deviations from operations, or any exceeda

proposed monitoring, would be reviewed and recommendations for action would be developed. These recommen

provided to the Forest Supervisor.

Performance Criteria Implementation: Funding is provided as agreed upon. Monitoring equipment is purchased and monitoring is im

outstanding details of the monitoring plan are agreed upon and the plan finalized.

Effectiveness: Sky brightness associated with Rosemont Copper remains less than the agreed-upon trigger.

Responsible Party Implementation: Rosemont Copper is responsible for providing funding and working to finalize the monitoring 

Astronomical Observatory is responsible for purchasing equipment and implementing monitoring. The Forest Se

establishing and chairing the oversight committee.

Effectiveness: Rosemont Copper is responsible for funding as agreed upon and participation in the oversight com

Service is responsible for chairing the committee and distributing pertinent monitoring data reported to the Fores

Smithsonian Astronomical Observatory is responsible for conducting and reporting all monitoring and for partic

committee.

Final Environmental Impact Statement for the Rosemont Copper Project

B-59
Element Description

Timing Implementation: Active mining phase.

Effectiveness: Active mining phase.

Applicable Alternatives All action alternatives.

Visual Resources

FS-VR-01 – Color of mine related buildings blends into the natural landscape

Element Description

Description Rosemont Copper would submit for approval and the Forest Service would approve colors for mine related buildi

color contrasts. A dark, neutral color is recommended.

Source Coronado ID team.

Impacts Mitigated Would reduce contrast and related visual impact associated with plant buildings.

Location Plant site.

Monitoring / Reporting 

Action

Implementation: Rosemont Copper would receive Forest Service approval of color selection prior to applying fi

ensure that buildings are painted or stained in compliance with the final MPO.

Effectiveness: The Forest Service would reevaluate finished results from representative viewpoints to determine 

Performance Criteria Implementation: Rosemont Copper would use approved colors for buildings. 

Effectiveness: Colors would be effective in reducing contrast of plant site buildings with natural environment. 

Responsible Party Implementation: Rosemont Copper is responsible for obtaining Forest Service approval of color selection before 

to buildings, during construction and maintenance, and during mine life if facilities are added or repainted. 

Effectiveness: The Forest Service is responsible for effectiveness monitoring.

Timing Implementation and Effectiveness: Premining phase when buildings are constructed and during mine life if fac

repainted.

Applicable Alternatives All action alternatives.

FS-VR-02 – Removal of unneeded facilities during closure

Element Description

Description This mitigation involves the removal of mining facilities that would not be needed for future management of the 

include buildings, the plant site, some roads, the perimeter and security fence (if not incorporated into allotment m

power supply line, and piping systems (consistent with Forest Service requirements, as well as requirements spec

ASLD right-of-way (ROW) permit); and water supply pipeline. The plant site would be recontoured and revegeta

vegetation. Building foundations would either be removed or broken up and buried.

Source This is a design feature from the preliminary MPO and a requirement of the Coronado. Requirements regarding th

contained in the ACC CEC and ASLD ROW permit.

Impacts Mitigated Would reduce visual impacts; would reduce potential impacts to surface water from erosion; would restore ability 

B-60 Final Environmental Impact Statement for the Rosemont Copper Project
Element Description

Location Plant site, roads, fences, utility corridor.

Monitoring / Reporting 

Action

Implementation: Weekly inspections during plant site decommissioning to ensure that closure actions comply w

CEC, and ASLD ROW permit. Refer to FS-BR-01for additional details on reporting of plant site decommissionin

Effectiveness: Quarterly inspection and reporting to ensure that closure activities are achieving specifications in 

closure plan, which is contained in the final MPO. Monitor for revegetation progress and success quarterly, inclu

areas of vegetation species, density, and location. Monitor disturbed and revegetated areas for noxious and invasi

map such locations and take action to prevent, eliminate, or control weeds should they occur, in accordance with 

Performance Criteria Implementation: Sites that contain structural improvements would be reclaimed by removing all unneeded ore p

ancillary facilities (including foundations unless the Coronado indicates that breaking and burial are appropriate), 

utility lines on NFS lands, and consistent requirements specified in the CEC and ASLD ROW permit. Growth me

reclaimed areas and revegetated with native grasses, trees, and/or shrubs to meet desired conditions, to be determ

Service.

Effectiveness: Closure actions would result in conditions that meet specifications in final reclamation and closur

revegetation objectives of the final reclamation and closure plan. If foundations are broken and buried, the size of 

depth of burial would comply with the specifications in the final MPO. 

Responsible Party Implementation and Monitoring: Rosemont Copper is responsible for conducting monitoring and reporting to t

Forest Service is responsible for spot-checking monitoring activities and for evaluating monitoring results to dete

the final MPO.

Timing Implementation: During final reclamation and closure.

Effectiveness: During final reclamation and closure and postclosure until revegetation objectives of the final recl

plan have been met.

Applicable Alternatives All action alternatives.

FS-VR-03 – Measures to reduce color contrasts from cuts, fills, and concrete structures associated with the mine

Element Description

Description Rosemont Copper would ensure that concrete drop structures for applicable alternatives are colored to reduce imp

resources. Additionally, light-colored areas resulting from cut and fill of the highly visible southern diversion cha

with growth medium and revegetated (see FS-SR-01 and 02).

Source Coronado ID team. 

Impacts Mitigated Would reduce visual impacts by reducing color contrast.

Location Southern diversion channel and concrete drop structures.

Monitoring / Reporting 

Action

Implementation: Visual inspection and report to ensure that implementation has occurred.

Effectiveness: Visual inspection from selected viewpoints to determine effectiveness.

Performance Criteria Implementation: Color is applied as early in the premining or active mining phase as feasible, in accordance wit

instructions.

Effectiveness: Results would be effective in reducing color contrast.

Final Environmental Impact Statement for the Rosemont Copper Project

B-61
Element Description

Responsible Party Implementation: Rosemont Copper is responsible for implementing this action in accordance with the final MPO

Effectiveness: The Forest Service is responsible for conducting effectiveness monitoring.

Timing Implementation: Premining through early active mining.

Effectiveness: From implementation of coloring through final closure.

Applicable Alternatives All action alternatives; drop structure is unique to Barrel Alternative; all alternatives contain the southern diversio

FS-VR-04 – Measures to reduce the visual impact of the mine pit

Element Description

Description This mitigation involves using commercially available technology to reduce the visual impacts of the mine pit, i

contrast resulting from exposed light-colored rock in the upper mine pit and horizontal lines resulting from benc

portions of the pit. Rosemont Copper would cooperatively work with the Coronado to identify and implement a

of weathering products to reduce color contrast as the pit is developed and would address visual impacts associa

lines as it is technically feasible to do so. 

Source Coronado ID team. 

Impacts Mitigated Could potentially reduce visual impacts by reducing color contrast and linear features.

Location Portions of the mine pit that are visible from concern level 1 and 2 travelways as identified in the “Visual Resou

3 of the FEIS.

Monitoring / Reporting 

Action

Implementation and Effectiveness: To be determined.

Performance Criteria Implementation and Effectiveness: To be determined.

Responsible Party Implementation and Effectiveness: Rosemont Copper and the Coronado are equally responsible for investigat

technologies for reducing the visual impact of the mine pit and for working together to implement appropriate a

Timing Implementation and Effectiveness: Investigation of applicable technologies would occur during premining, an

applied as the pit wall is developed and as soon as mine access onto benches is no longer needed (when access t

safe and mitigation would be most effective). The Coronado would monitor the effectiveness in a manner that w

that time.

Applicable Alternatives All action alternatives.

B-62 Final Environmental Impact Statement for the Rosemont Copper Project
Recreation and Wilderness

FS-RW-01 – Relocation of a segment of the Arizona National Scenic Trail and construction of trailheads

Element Description

Description Rosemont Copper would fund relocation of a section of the Las Colinas portion of the Arizona National Scenic T

Rosemont Copper Mine facilities and trailheads. The trail relocation would result in moving the trail farther away 

complex than its current location. Additionally, the trail easement with the Forest Service would be written in coo

conservation easement to ensure that both easements are in agreement for the use of the overlapping lands.

Source Relocation of the trail is a design feature from the preliminary MPO. The Forest Service has mapped the alternati

the trail farther away from the Helena Mine complex is included in a biological opinion conservation measure an

related to known lesser long-nosed bat roost protection.

Impacts Mitigated Would reduce impacts to recreational users of the Arizona National Scenic Trail. Potential impacts to lesser long-

Helena Mine complex would be reduced by funneling hikers farther away from the adit entrances.

Location Section of Arizona National Scenic Trail that would be relocated. See alternative maps in chapter 2 for locations.

Monitoring / Reporting 

Action

Implementation: Field evaluations during trail construction would indicate that the trail is built to Forest Service 

specifications. 

Effectiveness: User surveys would be conducted periodically to identify user experience.

Performance Criteria Implementation: Trail would be constructed in location and to specifications furnished by the Forest Service. Re

would be pioneered and available for public use at the time the existing trail segment is closed to public use. The 

approve, in advance, any activity that would restrict the trail to public use, with the intent of maintaining the trail 

during the “through hiking” season. All reasonable attempts would be made to avoid closing the trail during the “

seasons of March, April, October, and November. Final construction of the relocated trail and associated facilitie

within 1 year of the time the existing trail is closed to the public. 

Effectiveness: Trail user experience would meet those specified in the FEIS. 

Responsible Party Implementation: Rosemont Copper is responsible for providing funds to the Arizona Trail Association to ensure 

occurs in accordance with Forest Service specifications and is completed before mine related activities close the e

use. Details of the agreement for fund disbursement and trail construction are contained in an agreement between 

the Arizona Trail Association.

Effectiveness: The Forest Service is responsible for maintenance and effectiveness monitoring.

Timing Implementation and Effectiveness: Commences with approval of final MPO; concludes when relocated trail se

facilities are constructed and open for public use. Activities near known lesser long-nosed bat roosts would occur 

nosed bats are not present, typically during the period from November 1 to July 1 each year.

Applicable Alternatives All action alternatives. Location of relocated segments, associated facilities, and level of mitigation differs by alte

Final Environmental Impact Statement for the Rosemont Copper Project

B-63
FS-RW-02 – Arizona National Scenic Trail: easement to allow the trail to be constructed across Rosemont Copper’

Element Description

Description The relocation of the Arizona National Scenic Trail would require locating the trail across two private parcels of 

Rosemont Copper. A trail easement would be required before trail relocation construction could commence. Thes

parcels described in FS-BO-20. Coordination between future land uses allowed under the restrictive covenant dev

and those appropriate for the National Scenic Trail corridor would occur to provide for the nature and purposes an

trail.

Source Coronado ID team. 

Impacts Mitigated Would reduce impacts to recreational users of the Arizona National Scenic Trail. 

Location Davidson Canyon private land parcels (see FS-BO-20).

Monitoring / Reporting 

Action

Implementation and Effectiveness: Recordation of an easement, a copy of which would be provided to the Fore

Performance Criteria Implementation and Effectiveness: An easement would be recorded that allows for construction of a segment o

Scenic Trail and contains provisions deemed sufficient to fulfill the intent of the National Trails System Act and 

and purposes and primary uses of the trail are accommodated. Acquisition of such an easement by the Forest Serv

the National Trail Systems Act (16 U.S.C. 1246(a), Section 7).

Responsible Party Implementation: Rosemont Copper is responsible for providing an easement in perpetuity that remains with the 

change and that allows for national scenic trail construction, use, and management across their private land.

Effectiveness: The Forest Service is responsible for any effectiveness monitoring deemed appropriate.

Timing Implementation and Effectiveness: Prior to relocation construction of the Arizona National Scenic Trail (see FS

Applicable Alternatives All action alternatives. 

FS-RW-03 – Mitigate loss of off-highway-vehicle use opportunities

Element Description

Description Rosemont Copper would provide funding for efforts to produce a plan for developing facilities and managing off

that would be displaced from the project area. Rosemont Copper would enter into a voluntary collection agreeme

up to $800,000 for uses that include the NEPA analysis and decision process to determine where additional facili

appropriate in addition to implementation of the off-highway-vehicle mitigation. Rosemont Copper would contrib

to the Coronado within 6 months of the MPO approval with up to an additional $700,000 for additional work, wh

NEPA analysis, construction of off-highway-vehicle facilities, public outreach and education, and management a

collection agreement would be in place at the time the final MPO is approved. This measure may be refined with 

collection agreement is finalized and approved by both parties.

Source The Coronado, as negotiated with Rosemont Copper.

Impacts Mitigated Once implemented, this would mitigate for the loss of off-highway-vehicle opportunities in the project area by cr

similar facilities and opportunities in other areas of the Coronado National Forest. 

Location Coronado National Forest, primarily on the Nogales Ranger District. 

B-64 Final Environmental Impact Statement for the Rosemont Copper Project
Element Description

Monitoring / Reporting 

Action

Implementation and Effectiveness: To be determined as part of the Forest Service NEPA process.

Performance Criteria Implementation: Rosemont Copper provides the agreed amount of funding to the Coronado. The Coronado com

and implements the decision.

Effectiveness: Off-highway-vehicle opportunities are provided to offset the loss of these opportunities within the 

Responsible Party Implementation and Effectiveness: Rosemont Copper would be responsible for providing funds as agreed. The 

responsible for all planning, implementation, management, and monitoring.

Timing Implementation and Effectiveness: Rosemont Copper would provide $100,000 for NEPA planning to the Coron

of approval of the final MPO. Rosemont Copper would provide the remainder of funding, as needed, for a total c

$800,000. 

Applicable Alternatives All action alternatives.

Hazardous Materials

FS-HM-01 – Hazardous materials containment and management

Element Description

Description This mitigation involves handling, storage, use, and communication information about hazardous materials, in ac

regulations. A variety of agencies have regulations defining what materials are classified as hazardous and how th

transported, handled, and stored. These include the U.S. Environmental Protection Agency (EPA), U.S. Departme

ADEQ, Pima County Department of Environmental Quality, and MSHA. Table 3 in chapter 2 provides a summar

regulations.

Source This is a design feature of the preliminary MPO.

Impacts Mitigated Would reduce potential impacts to human health and environmental risks (such as impacts to surface and groundw

transportation, use, and storage of hazardous materials. Would reduce potential for residue from explosive use.

Location Area within the perimeter fence and any other area where hazardous materials are under the direct control of Ros

employees, or contractors.

Monitoring / Reporting 

Action

Implementation: As required by applicable regulations. An explosives and blasting management procedure wou

implemented to ensure that best management practices are applied.

Effectiveness: As required by applicable regulations.

Performance Criteria Implementation: Inspections during construction to ensure that facility construction adheres to final MPO and co

laws and regulations. Frequency would comply with applicable regulations.

Effectiveness: Inspections during operation and reclamation and closure phases to determine whether operation a

operations is effective and complies with laws and regulations related to transportation, use, and storage of hazard

Frequency would comply with applicable regulations.

Responsible Party Implementation and Effectiveness: Rosemont Copper is responsible for conducting monitoring and reporting to 

Timing Implementation and Effectiveness: Premining through final reclamation and closure phases.

Final Environmental Impact Statement for the Rosemont Copper Project

B-65
Element Description

Applicable Alternatives All action alternatives.

FS-HM-02 – Maintaining material safety data sheets in accordance with 30 CFR 47

Element Description

Description This mitigation involves maintaining material safety data sheets onsite and providing this information to emergen

Regulations require that material safety data sheets be available to workers and that notification of potential hazar

visitors. Access to material data safety sheets would also be provided to appropriate emergency response departm

Source This is a design feature of the preliminary MPO.

Impacts Mitigated Would reduce impacts to worker and public health and safety in the case of exposure by allowing appropriate trea

implemented more rapidly.

Location Project area; emergency response departments and local hospitals.

Monitoring / Reporting 

Action

Implementation and Effectiveness: MSHA would monitor material safety data sheet availability during their sc

Rosemont Copper would report to the Forest Service when material data safety sheets have been provided to eme

departments and hospitals. 

Performance Criteria Implementation: The Rosemont Copper Project is in compliance with regulations specified in 30 CFR 47. 

Effectiveness: Information on hazardous materials would be readily available to employees and visitors to the sit

would furnish copies of all pertinent material data safety sheets provided to emergency response departments and 

Responsible Party Implementation and Effectiveness: Rosemont Copper is responsible for making material data safety sheets avai

site visitors; providing access to emergency response departments and local hospitals; and reporting to the Forest 

responsible for ensuring compliance with 30 CFR 47.

Timing Implementation and Effectiveness: Premining through final reclamation and closure phases.

Applicable Alternatives All action alternatives.

Transportation/Access

FS-TA-01 – Development of a comprehensive transportation plan

Element Description

Description The transportation plan would address maintenance standards; levels of appropriate use; methods to maintain the 

to prevent washboard, rutting, and drainage problems; commitment to replace surfacing lost to drainage; commitm

damaged by use; commitment to restore temporary roads to natural preoperation conditions during reclamation/cl

and maintenance of wildlife crossing structures (e.g., corrugated metal pipes) under the primary access road at loc

wildlife concentration. Details would be contained in the transportation plan.

Source This is a design feature from the preliminary MPO.

Impacts Mitigated Would reduce impacts to surface water from erosion; would reduce impacts to wildlife from vehicle-caused injur

Location All project related roads on NFS lands.

B-66 Final Environmental Impact Statement for the Rosemont Copper Project
Element Description

Monitoring / Reporting 

Action

Implementation and Effectiveness: To be determined in transportation plan, which would be completed and app

Service prior to approval of the final MPO. 

Performance Criteria Implementation and Effectiveness: Completion of a plan approved by the Forest Service and compliance with t

approved plan.

Responsible Party Implementation and Effectiveness: Rosemont Copper is responsible for developing the transportation plan; for 

once it is approved and incorporated into the final MPO; and for monitoring implementation and effectiveness as 

Forest Service. The Forest Service is responsible for reviewing and approving the plan.

Timing Implementation and Effectiveness: The transportation plan would be developed after issuance of the ROD and 

final MPO. Implementation monitoring would occur during the premining phase; effectiveness monitoring would 

premining through the final reclamation and closure phase.

Applicable Alternatives All action alternatives.

Noise

FS-N-01 – Management techniques to reduce potential noise impacts from blasting

Element Description

Description This mitigation is focused on noise management techniques, including generally limiting blasting to once per day

and sequenced blasting using time-delay technology. Explosive usage is limited to 52 tons per day, as consistent 

contained in the air quality permit. 

Source Design feature of the preliminary MPO; aspects required by the air quality permit.

Impacts Mitigated Would reduce impacts from noise to humans and wildlife. 

Location Mine pit.

Monitoring / Reporting 

Action

Implementation and Effectiveness: Daily recording of when blasting occurs. 

Performance Criteria Implementation and Effectiveness: Blasting would be generally limited to once per day, during daylight hours, 

time-delay technology.

Responsible Party Implementation and Effectiveness: Rosemont Copper is responsible for conducting monitoring and reporting to 

Timing Implementation and Effectiveness: Premining through active mining phases.

Applicable Alternatives All action alternatives.

FS-N-02 – Actions to reduce potential noise impacts from vehicles

Element Description

Description This mitigation would reduce potential noise from certain vehicles by requiring backup alarms on vehicles to be a

MSHA standards for backup alarms would be met (56/57.14132(a) and (b), “Horns and Backup Alarms For Surfa

Standard”). It also includes biological opinion requirements to avoid the use of horns and jake brakes to the exten

Final Environmental Impact Statement for the Rosemont Copper Project

B-67
Element Description

Source Coronado ID team.

Impacts Mitigated Would reduce human impacts associated with noise pollution.

Location All mining related vehicles.

Monitoring / Reporting 

Action

Implementation: Inspection of each vehicle equipped with backup alarm at the time of initial use to confirm that 

with the final MPO. Signs would be posted advising vehicle operators to not employ jake brakes at both ends and 

primary access road.

Effectiveness: Quarterly inspections to ensure that backup alarms are attuned to levels that reduce noise as permi

regulations. 

Performance Criteria Implementation: Equipment inspections demonstrate that backup alarms have been attenuated to reduce noise. 

Effectiveness: All backup alarms would be attuned to reduce noise; monitoring would demonstrate that noise lev

those that would occur without attuned backup alarms.

Responsible Party Implementation and Effectiveness: Rosemont Copper is responsible for conducting monitoring and reporting to 

Timing Implementation and Effectiveness: Premining through final reclamation and closure phases.

Applicable Alternatives All action alternatives.

Public Health and Safety

FS-PHS-01 – Construction of a perimeter fence that would exclude the public

Element Description

Description This mitigation involves construction of a perimeter fence to keep the public from coming into contact with minin

potentially hazardous conditions. Construction would use horses and all-terrain vehicles. Existing roads and moto

used to deliver posts and wire to the extent practicable. No road construction or off-road use of vehicles larger tha

would be allowed. 

Source This is a design feature of the preliminary MPO. 

Impacts Mitigated Would avoid or reduce public air impacts; would ensure that the public would not come into contact with operati

reduce the risk of public accident or injury; would use installation methods that would reduce surface disturbance 

sites.

Location Perimeter fence location; differs by alternative. See alternative maps in chapter 2.

Monitoring / Reporting 

Action

Implementation: Daily inspections during installation to ensure that location and construction techniques compl

Effectiveness: Annual inspections the entire length of the fence to ensure that it is effective in restricting public a

Performance Criteria Implementation: Construction would be conducted using techniques that reduce surface disturbance; cultural sit

location and fencing materials would meet specifications in the final MPO.

Effectiveness: Monitoring would indicate that the fence is regularly maintained and is effective in restricting pub

Responsible Party Implementation and Effectiveness: Rosemont Copper is responsible for conducting monitoring and reporting to 

Timing Implementation and Effectiveness: Premining through final reclamation and closure phases.

B-68 Final Environmental Impact Statement for the Rosemont Copper Project
Element Description

Applicable Alternatives All action alternatives.

FS-PHS-02 – Preparation of emergency response and contingency plans, including a fire plan

Element Description

Description This mitigation requires Rosemont Copper to coordinate with Emergency Medical Services providers, local fire d

applicable agencies (i.e., Pima County Office of Emergency Management, Local Emergency Planning Committe

Association, Sheriff’s Department) in development of emergency response and contingency planning. 

Source This is a design feature of the preliminary MPO. The Coronado ID team brought the fire plan forward.

Impacts Mitigated Pre-emergency planning and coordination with Emergency Medical Services providers and local fire districts wo

time and improve services of Emergency Medical Services, reducing impacts of wildfires and potential human inj

Location To be determined in agreement between the Coronado, Rosemont Copper, Emergency Medical Services provider

districts.

Monitoring / Reporting 

Action

Implementation: Confirmation that contingency planning has occurred and has involved the appropriate agencie

incorporated into the final MPO.

Effectiveness: Annual review to ensure that implementation is occurring in accordance with the plan; and annual 

parties to determine effectiveness.

Performance Criteria Implementation: Agreement and plan would be developed and incorporated into the final MPO.

Effectiveness: Annual multiparty review to determine whether the plan is being implemented in accordance with 

whether the results are effective in reducing response time to wildfires and accidents.

Responsible Party Implementation and Effectiveness: Rosemont Copper is responsible for conducting monitoring and reporting to 

applicable fire districts and Emergency Medical Services providers. 

Timing Implementation and Effectiveness: From the time of the final MPO approval through final closure.

Applicable Alternatives All action alternatives.

Cultural Resources

FS-CR-01 – Archaeological data recovery on sites that would be adversely affected

Element Description

Description This involves excavation and recovery at cultural sites that would be directly impacted.

Source HPTP.

Impacts Mitigated Would mitigate for loss of information important to cultural history and archaeology.

Location All archaeological sites within the areas of direct impact.

Monitoring / Reporting 

Action

Implementation and Effectiveness: All testing and data recovery work would conform to the stipulations in the 

HPTP. 

Final Environmental Impact Statement for the Rosemont Copper Project

B-69
Element Description

Performance Criteria Implementation and Effectiveness: Testing and data recovery, including reporting and curation, would be comp

the HPTP.

Responsible Party Implementation and Effectiveness: Forest Service: oversight; Rosemont Copper: funding.

Timing Implementation and Effectiveness: As specified in the HPTP, no testing or data recovery fieldwork would occu

MPO has been approved by the Coronado; however, testing and data recovery fieldwork for any specific archaeo

completed before ground disturbance related to mine construction and operation begins in that specific area.

Applicable Alternatives All action alternatives.

FS-CR-02 – Respectful and appropriate treatment of human remains that would be disturbed by the project

Element Description

Description This involves removal of human remains from sites that would be directly impacted.

Source Burial action plan in the HPTP.

Impacts Mitigated Would partially mitigate for disturbance of human remains.

Location Measure applies to: (1) all known prehistoric and historic sites (some of which are known to have, or likely to hav

and (2) any inadvertent discovery of human remains during project work.

Monitoring / Reporting 

Action

Human remains would be treated in accordance with the protocols in the burial action plan for Federal lands and 

for State and private lands. 

O’odham or Hohokam burials, funerary objects, sacred objects, objects of cultural patrimony, or sacred animal bu

repatriated directly from the field to the Tohono O’odham Nation via the Tohono O’odham Nation Cultural Reso

Any burials, funerary objects, sacred objects, objects of cultural patrimony, or sacred animal burials identified as 

Hohokam would be handled according to the affiliated tribes’ wishes.

Performance Criteria All human remains and associated funerary objects that would be disturbed by the project would be repatriated an

accordance with the burial action plan.

Responsible Party Forest Service: oversight and coordination; representatives of consulting tribes for monitoring and reburial of rec

remains; Rosemont Copper: funding.

Timing The most intensive work related to this mitigation measure is expected to occur during the archaeological testing 

all parties would be prepared to implement the measure at any time during surface-disturbing activities related to 

Applicable Alternatives All action alternatives.

FS-CR-03 – Curation of archaeological collections in accordance with 36 CFR 79 and the HPTP

Element Description

Description This involves storage and interpretation of artifacts that are removed from sites that would be directly impacted 

Source HPTP.

Impacts Mitigated Would partially mitigate for damage to integrity and transmission of O’odham culture that would occur with the d

Duag Traditional Cultural Property and destruction of ancestral sites in the project area.

B-70 Final Environmental Impact Statement for the Rosemont Copper Project
Element Description

Location A curation facility meeting requirements specified in 36 CFR 79 (either Tohono O’odham Nation Cultural Center 

Arizona State Museum).

Monitoring / Reporting 

Action

As detailed in the HPTP.

Performance Criteria All archaeological materials and associated field notes, photographs, etc., generated during surface collection, ma

data recovery on the project would be curated at the designated repository. 

Responsible Party Forest Service: oversight and coordination; Repository: care of collections; Rosemont Copper: funding.

Timing Any required improvements necessary to prepare the museum facility to house the collections would begin concu

approval of the final MPO. The Rosemont exhibit would be developed within 18 months of the completion of the 

Applicable Alternatives All action alternatives.

FS-CR-04 – Monitoring and treatment of inadvertent discoveries

Element Description

Description This involves procedures in the event of discovery during project activities of previously unknown archaeologica

associated grave goods, and ceremonial objects. 

Source HPTP. 

Impacts Mitigated Partial mitigation for inadvertent and unplanned impacts to archaeological sites, should they occur.

Location Within the project area.

Monitoring / Reporting 

Action

The Coronado, in consultation with the SHPO, may identify areas of project construction within the project area t

monitoring by a Coronado-approved archaeologist and tribal monitor designated by the consulting tribes. Work in 

cannot proceed without a monitor in place. 

All work at the site of a discovery would be suspended, and the archaeologist and tribal monitor would examine a

discovery and follow the procedures in the discovery plan included in the HPTP. 

Performance Criteria Appropriate documentation of cultural resources and repatriation of human remains, as described in the HPTP.

Responsible Party The Coronado is responsible for consulting with SHPO and identifying sites requiring monitoring and for approv

monitor. Rosemont Copper is responsible for suspending work and informing the archaeological monitor should 

discovered and for funding and oversight of contractors.

Timing Premining through final reclamation and closure phases. 

Applicable Alternatives All action alternatives.

Final Environmental Impact Statement for the Rosemont Copper Project

B-71
FS-CR-05 – Limiting ground-disturbing activity between the perimeter fence and security fence

Element Description

Description Ground-disturbing activities between the perimeter and security fences would be approved in advance by the For

to be limited to construction of compliance wells, stormwater drainage facilities, the perimeter fence, a road to ac

monitoring site, and active road decommissioning). Monitors would be present for all ground-disturbing work. C

discovered during monitoring would be dealt with in accordance with the discovery plan in the HPTP. Active roa

would be discussed with the Forest Archaeologist prior to implementation to coordinate areas necessary to avoid 

Source HPTP.

Impacts Mitigated Would avoid or minimize ground disturbance and other physical impacts to archaeological sites and cultural depo

Location Area between security fence and perimeter fence.

Monitoring / Reporting 

Action

Rosemont Copper would coordinate any proposed ground disturbance in this area with the Coronado to identify r

properties, which would be avoided. If historic properties cannot be avoided, treatment would comply with the Se

recovery procedures given in the HPTP. Monitoring and reporting ground-disturbing activities would conform to 

HPTP.

Performance Criteria Acceptance of report by the Coronado.

Responsible Party Coronado oversight; professional archaeologist and designated tribal monitors; Rosemont Copper funding. 

Timing Premining through final reclamation and closure phases.

Applicable Alternatives All action alternatives.

FS-CR-06 – Cultural resources protection training

Element Description

Description This requires Rosemont Copper to provide appropriate training to their employees and contractors regarding iden

and protection of cultural sites, and other topics. 

Source HPTP.

Impacts Mitigated Could potentially avoid inadvertent impacts to cultural resources.

Location Rosemont Copper headquarters.

Monitoring / Reporting 

Action

As part of Rosemont Copper’s Environmental Training Program, all personnel (including archaeological contract

instructed, to the degree appropriate to their involvement with the project, by the Rosemont Copper qualified cult

contractor on identification of cultural resources, site avoidance and protection measures, and the procedures to b

discovery plan. Information on the statutes and regulations protecting cultural resources and respectful treatment 

would be provided. Representatives of the consulting tribes would be offered the opportunity to assist in the train

agreements to be developed between the consulting tribes and Rosemont Copper.

Performance Criteria Regular report, as specified in the HPTP. 

Responsible Party Rosemont Copper.

Timing Before project operations begin and throughout premining through final reclamation and closure phases as person

Applicable Alternatives All action alternatives.

B-72 Final Environmental Impact Statement for the Rosemont Copper Project
FS-CR-07 – Project proponent would allow tribal members access, upon 5 days’ advance request, to the project ar

practices

Element Description

Description Requirement to allow reasonable access to the project area for tribal members. 

Source HPTP.

Impacts Mitigated Would partially reduce impacts of loss of access to sacred sites and collection areas.

Location (1) All springs, vision sites, and other sacred sites within project area; (2) resource-collecting areas within project 

Monitoring / Reporting 

Action

Access would be documented in annual report by Rosemont Copper to the Coronado.

Performance Criteria Access would be subject to compliance with all safety requirements.

Responsible Party The Coronado would coordinate requests with Rosemont Copper.

Timing Premining through final reclamation and closure phases of the project.

Applicable Alternatives All action alternatives.

FS-CR-08 – Project proponent would organize tribal members’ field visits to potentially affected springs

Element Description

Description This measure requires knowledge of culturally important spring locations and providing tribal members with acce

ceremonies or plant collections.

Source HPTP.

Impacts Mitigated Would partially reduce impacts of loss of access to sacred sites and collection areas.

Location Springs within the project area and other springs that may be impacted by changes in the surface water or ground

activities.

Monitoring / Reporting 

Action

Once the visits are completed, the Coronado would be notified.

Performance Criteria Tribal access would be organized and provided to requested springs. 

Responsible Party Forest Service: oversight; Rosemont Copper: organization and funding.

Timing To be completed for each spring before ground disturbance occurs in that area.

Applicable Alternatives All action alternatives.

FS-CR-09 – Transplanting of critical plant resources and inclusion of species within revegetation mixture

Element Description

Description This involves incorporating culturally important plants into the revegetation efforts described in the final reclama

Source HPTP.

Final Environmental Impact Statement for the Rosemont Copper Project

B-73
Element Description

Impacts Mitigated Would partially rectify the loss of culturally important plants in the portion of the Ce:wi Duag Traditional Cultura

project area.

Location Rosemont Copper private land with deed restrictions to protect vegetation.

Monitoring / Reporting 

Action

Prior to ground disturbance, Rosemont Copper would coordinate plant removal with consulting tribes. Tribes wou

opportunity to collect plants for removal to their reservations. Other plants would be transplanted to a Rosemont 

and access provided to members of consulting tribes to collect plants used for medicinal, ceremonial, and craft pu

Rosemont Copper would incorporate plant species designated by the consulting tribes in its revegetation mix to th

species exist in the area.

Performance Criteria Successful plant transplantation and propagation as reported in the annual reclamation reporting.

Responsible Party Rosemont Copper with Coronado oversight.

Timing Prior to removal of pit overburden and vegetation and soil in the waste rock and tailings area.

Applicable Alternatives All action alternatives.

FS-CR-10 – Interpretation of the results of the cultural resources investigations for tribal members, the Hispanic c

public

Element Description

Description This involves compiling and interpreting the results of cultural investigations in a manner that is accessible and u

public. 

Source HPTP.

Impacts Mitigated Would partially mitigate for destruction of archaeological sites; damage to traditional cultural properties; and loss 

transmittal of cultural values.

Location Mine Visitor Center; Arizona State Museum; Tribal cultural centers; and online.

Monitoring / Reporting 

Action

Information collected as part of the cultural resource studies undertaken for the Rosemont Copper Project would 

Tribal youth, local school districts, and the public, to dispel stereotypes by providing accurate and culturally awar

history of the project area.

Performance Criteria Public volumes and brochures describing archaeological and historic interpretations available in print and online; perm

Center and online; presentations or exhibits at local venues as requested; and development of curriculum for local scho

Responsible Party Rosemont Copper with oversight by the Coronado.

Timing Visitor Center exhibits within 6 months of the Visitor Center establishment. Public volumes, brochures, and onlin

public within 18 months of the mitigation report finalization.

Applicable Alternatives All action alternatives.

B-74 Final Environmental Impact Statement for the Rosemont Copper Project
FS-CR-11 – Stabilization of previously excavated historic properties between the security and perimeter fences

Element Description

Description This would include bringing in clean material to fill the trenches and other excavations left open at sites excavate

project. All restoration work would be monitored in accordance with the reclamation plan in the HPTP.

Source Reclamation plan in the HPTP.

Impacts Mitigated Would eliminate physical impacts to historic properties currently monitored by the Coronado.

Location In the area between the security and perimeter fences.

Monitoring / Reporting 

Action

Implementation: Stabilization work would be supervised by archaeologists and designated tribal monitors.

Effectiveness: Monitors would be designated by the Coronado to inspect the sites monthly for the first year after 

annually for the remainder of mining operations to ensure that refilled holes have stabilized and that no ancillary 

the sites. If monitoring shows signs of excessive erosion or disturbance, the Forest Archaeologist will be contacte

planning.

Performance Criteria Implementation: Clean fill sediments would be stable and support native vegetation in densities consistent with 

Effectiveness: No signs of excessive erosion or human-caused ground disturbance.

Responsible Party Forest Service: oversight; Rosemont Copper: funding.

Timing Concurrent with data recovery, prior to ground disturbance by project construction.

Applicable Alternatives All action alternatives.

Mitigation and Monitoring – Other Regulatory and Permitting Agencies

The mitigation and monitoring in this section would be required by permits or approvals issued under the jurisdiction of a p

as the ADEQ. As such, implementation would be required. The Forest Service has no authority, obligation, or expertise to d

compliance with the measures included in this category. They are presented here to facilitate disclosure of currently known 

monitoring and their consideration in impacts analyses. Note that the mitigation and monitoring items in this section reflect 

permits and could change as permits are finalized following approval of the ROD, or if permits are amended or modified du

Implementation of the mitigation measures in this section are mandatory and consist of permit requirements. Impacts analy

chapter 3 of the FEIS. The effectiveness of the mitigation measures in this section has been evaluated in the impacts analys

determining of predicted impacts. Refer to chapter 3 impacts analyses for further detail.

Soils and Revegetation 

OA-SR-01 – Power line and water line locations

Element Description

Description Final location is the shortest route of alternatives considered by the ACC and eliminates one water line pump stati

Final Environmental Impact Statement for the Rosemont Copper Project

B-75
Element Description

Source ACC CEC. Specific ROW location is also a requirement of a license agreement executed between Rosemont Cop

Sahuarita for a ROW, enforceable if the ROW is used.

Impacts Mitigated Location selected would reduce acres of surface disturbance, acres of plant and animal habitat impacted, and acre

resources impacted, compared with other alternative locations considered.

Location Utility corridor. See map in chapter 2.

Monitoring / Reporting 

Action

Implementation and Effectiveness: Weekly inspections during construction of power supply line and water supp

that the location complies with the ACC CEC and final MPO.

Performance Criteria Implementation and Effectiveness: Location and acres disturbed would comply with the CEC and final MPO.

Responsible Party Implementation and Effectiveness: Rosemont Copper is responsible for working with TEP to ensure that constr

than NFS land complies with the CEC. Rosemont Copper is responsible for monitoring work on NFS lands to ens

the final MPO. 

Timing Implementation and Effectiveness: During construction of electrical supply line and water supply pipeline (prem

Applicable Alternatives All action alternatives.

Air Quality

OA-AQ-01 – Paving of mine related roads to reduce dust emissions

Element Description

Description All routes used by the shipment and delivery vehicles would be paved, including the entrance road (3.1 miles), plu

light-duty roads within the facility.

Source Air quality permit. 

Impacts Mitigated Would reduce impacts to air quality from fugitive emissions (dust) that would otherwise be produced by vehicle us

were unpaved.

Location Primary access road and other roads that are not used by haul trucks or heavy mine equipment.

Monitoring / Reporting 

Action

Implementation: Weekly inspection during road construction and paving activities, including road maintenance o

applicable MSHA construction requirements and/or Forest Service road specifications are met. Instances where ap

are not met would be reported to the Coronado within 24 hours. Otherwise, inspection results can be summarized i

monitoring reports.

Effectiveness: Effectiveness monitoring related to fugitive dust emissions are specified in the air quality permit. R

including the condition of paved surfaces, would be visually observed monthly and inspected in further detail quar

pavement remains intact and that maintenance is scheduled and implemented in a timely manner. The intent is to i

require maintenance actions in a timely manner. Routine maintenance needs and actions can be summarized and re

reports prepared as specified in the air quality permit and shared with the Coronado. 

Performance Criteria Implementation: Designated roads within the plant site would be constructed and paved to specification followin

completion of the plant site facilities. 

Effectiveness: Specifications stated in air quality permit would be met. 

B-76 Final Environmental Impact Statement for the Rosemont Copper Project
Element Description

Responsible Party Implementation: Rosemont Copper is responsible for conducting monitoring and reporting to the Forest Service a

Effectiveness: Rosemont Copper is responsible for conducting monitoring and reporting to ADEQ and the Forest 

with the air quality permit. ADEQ is responsible for determining compliance with the air quality permit and the Cl

keeping the Forest Service informed of the results of such determinations.

Timing Implementation: Begins with construction of the road system (premining phase) and ends at completion of final r

phase (due to periodic road maintenance).

Effectiveness: Refer to the air quality permit.

Applicable Alternatives All action alternatives.

OA-AQ-02 – Dust control for unpaved roads

Element Description

Description This mitigation contains a number of actions that are designed to control at least 90 percent of particulate matter 10 

from the unpaved road network. These actions include application and reapplication of chemical dust suppressant 

Source This is a design feature for the preliminary MPO. The dust control plan is contained in the air quality permit. Meas

dust are also a requirement of a license agreement executed between Rosemont Copper and the Town of Sahuarita 

enforceable if the ROW is used.

Impacts Mitigated Would reduce impacts to air quality from fugitive dust emissions.

Location The network of unpaved haul roads used to transport ore and waste rock from the open pit mine to the primary cru

area, and waste rock areas, respectively; and any unpaved general roads within and around the perimeter fence surr

used by support vehicles. Primary roads include: (a) haul roads located in the pit, (b) haul roads for transporting co

pit to the primary crusher/run of mine stockpile, (c) haul roads for transporting leaching ore from the pit to the leac

for transporting waste rock from the pit to the waste rock storage area, waste rock buttresses, and other general are

facility roads around the project area for support vehicles. 

Monitoring / Reporting 

Action

Implementation and Effectiveness: Inspections and dust control measures in accordance with specifications cont

plan, which is included in the air quality permit. Inspection results would be reported in semiannual reports prepar

air quality permit and shared with the Coronado. 

Performance Criteria Implementation and Effectiveness: In accordance with the dust control plan, during actual operation, Rosemont 

the haul truck traffic rates at different time periods throughout the life of the mine to correctly identify the applicat

road watering to achieve 90 percent control efficiency on haul roads. Also, Rosemont Copper would evaluate the t

vehicles to determine the water application intensity needed to control the general unpaved facility roads to 90 per

Other requirements contained in the air quality permit, such as opacity limits, also apply. 

Responsible Party Implementation and Effectiveness: Rosemont Copper is responsible for conducting monitoring and reporting to 

Service in accordance with the air quality permit. ADEQ is responsible for determining compliance with the air qu

Clean Air Act and for keeping the Forest Service informed of the results of such determinations.

Timing Implementation and Effectiveness: Premining through final reclamation and closure phases.

Applicable Alternatives All action alternatives.

Final Environmental Impact Statement for the Rosemont Copper Project

B-77
OA-AQ-03 – Dust control for open areas and storage piles

Element Description

Description This mitigation contains a number of actions that are designed to control fugitive dust emissions from open areas a

activities include application and reapplication of chemical dust suppressant and water. Open areas and storage pil

used would be controlled by applying sufficient chemical dust suppressant and/or water to develop and maintain a 

means such as use of an adhesive soil stabilizer, paving covering, landscaping, detouring, or other acceptable mean

be used.

Source The dust control plan contained in the air quality permit.

Impacts Mitigated Reduces impacts to air quality from fugitive dust emissions.

Location Open areas and storage piles include mined areas, overburden storage areas, and waste rock storage facility.

Monitoring / Reporting 

Action

Implementation and Evaluation: Inspections and dust control measures in accordance with specifications contain

which is included in the air quality permit. Inspection results would be reported in semiannual reports prepared as 

quality permit and shared with the Coronado. 

Performance Criteria Implementation and Effectiveness: In accordance with dust control plan, monitoring would demonstrate 90 perc

Responsible Party Implementation and Effectiveness: Rosemont Copper is responsible for conducting monitoring and reporting to 

Service in accordance with the air quality permit. ADEQ is responsible for determining compliance with the air qu

Clean Air Act and for keeping the Forest Service informed of the results of such determinations.

Timing Implementation and Effectiveness: Premining through final reclamation and closure phases.

Applicable Alternatives All action alternatives.

OA-AQ-04 – Control of particulate emissions from lime slaking process

Element Description

Description Refinement of the design of the lime slaking system, including the addition of a lime slaker scrubber. 

Source Air quality permit.

Impacts Mitigated Would reduce impacts to air quality by controlling particulate matter emissions from the lime slaking process.

Location Lime silo at the plant site area.

Monitoring / Reporting 

Action

Implementation: Inspection and reporting at the time of construction of said facilities to ensure that the design me

the air quality permit application and amendment.

Effectiveness: In accordance with air quality permit requirements. Inspection results would be reported in semiann

specified in the air quality permit and shared with the Coronado. 

Performance Criteria Implementation: Equipment used would comply with that specified in the air quality permit application and amen

Effectiveness: Air quality permit processes and specifications would be met.

Responsible Party Implementation and Effectiveness: Rosemont Copper is responsible for conducting monitoring and reporting to 

Service in accordance with the air quality permit. ADEQ is responsible for determining compliance with the air qu

Clean Air Act and for keeping the Forest Service informed of the results of such determinations.

B-78 Final Environmental Impact Statement for the Rosemont Copper Project
Element Description

Timing Implementation and Effectiveness: Beginning with installation of specified equipment and continuing in accorda

in the air quality permit. 

Applicable Alternatives All action alternatives.

OA-AQ-05 – Control of particulate emissions from major metallic mineral processing operations

Element Description

Description Installation, operation, and maintenance of cartridge dust filters and other measures to control particulate matter e

metallic mineral processing operations.

Source Air quality permit.

Impacts Mitigated Would reduce impacts to air quality from particulate matter emissions associated with processing operations.

Location At all locations specified in the air quality permit and in the aquifer protection permit.

Monitoring / Reporting 

Action

Implementation: Inspection and reporting at the time of construction of said facilities to ensure that the design m

the air quality permit application and amendments.

Effectiveness: In accordance with air quality permit requirements. Inspection results would be reported in semian

as specified in the air quality permit and shared with the Coronado. 

Performance Criteria Implementation: Equipment used would comply with that specified in the air quality permit, application, and am

Effectiveness: Air quality permit processes and specifications are met.

Responsible Party Implementation and Effectiveness: Rosemont Copper is responsible for conducting monitoring and reporting to 

Service in accordance with the air quality permit. ADEQ is responsible for determining compliance with the air q

Clean Air Act and for keeping the Forest Service informed of the results of such determinations.

Timing Implementation and Effectiveness: Beginning with installation of specified equipment and continuing in accord

requirements in the air quality permit. 

Applicable Alternatives All action alternatives.

OA-AQ-06 – Use of covers on mix tanks and settlers to reduce emissions of volatile organic chemicals

Element Description

Description This mitigation involves the installation of covers on specific facilities that could otherwise result in volatile orga

Source Air quality permit.

Impacts Mitigated Would reduce impacts to air quality by reducing emissions of volatile organic chemicals and hazardous air pollut

and settlers used in the solvent extraction system.

Location Mix tanks and settlers within the plant site.

Final Environmental Impact Statement for the Rosemont Copper Project

B-79
Element Description

Monitoring / Reporting 

Action

Implementation: Inspection and reporting at the time of construction of said facilities to ensure that the design m

the air quality permit application and amendments.

Effectiveness: In accordance with air quality permit requirements. Inspection results would be reported in semian

as specified in the air quality permit and shared with the Coronado. 

Performance Criteria Implementation: Equipment used would comply with that specified in the air quality permit application and ame

Effectiveness: Air quality permit processes and specifications are met.

Responsible Party Implementation and Effectiveness: Rosemont Copper is responsible for conducting monitoring and reporting to 

Service in accordance with the air quality permit. ADEQ is responsible for determining compliance with the air q

Clean Air Act and for keeping the Forest Service informed of the results of such determinations.

Timing Implementation and Effectiveness: Beginning with installation of specified equipment and continuing in accord

requirements in the air quality permit. 

Applicable Alternatives All action alternatives.

OA-AQ-07 – Use of drip emitters on heap leach pad to reduce emissions

Element Description

Description This mitigation involves the installation and use of drip emitters to apply solution to the heap leach. 

Source This is a design feature from the preliminary MPO. It is also required under the air quality permit.

Impacts Mitigated Would prevent or reduce impacts to air quality from aerosol production and losses to wind, thereby reducing rele

into the air; would reduce evaporative losses of water.

Location Heap leach pad.

Monitoring / Reporting 

Action

Implementation: Visual inspection at time of construction to ensure that drip emitters have been installed. 

Effectiveness: Periodic inspection to ensure that emitters are functioning properly. Inspection results would be re

reports prepared as specified in the air quality permit and shared with the Coronado. 

Performance Criteria Implementation: Inspection and reporting at the time of construction of heap leach facility. Drip emitters would 

accordance with the final MPO.

Effectiveness: Monitoring of emitter operations would indicate that they are effective in preventing aerosol produ

potential release due to wind. Air quality monitoring results would meet requirements specified in the air quality 

Responsible Party Implementation and Effectiveness: Rosemont Copper is responsible for conducting monitoring and reporting to 

Service in accordance with the final MPO and air quality permit. ADEQ is responsible for determining complianc

permit and the Clean Air Act and for keeping the Forest Service informed of the results of such determinations.

Timing Implementation and Effectiveness: Beginning with installation of specified equipment and continuing in accord

requirements in the air quality permit. 

Applicable Alternatives All action alternatives except “Alternative 4 – Barrel Alternative.”

B-80 Final Environmental Impact Statement for the Rosemont Copper Project
OA-AQ-08 – Reduction in air emissions from diesel engines associated with stationary equipment

Element Description

Description This mitigation requires the use of low-sulfur diesel for all stationary equipment.

Source Air quality permit.

Impacts Mitigated Would reduce impacts to air quality from potential air emissions.

Location All stationary equipment equipped with diesel engines.

Monitoring / Reporting 

Action

Implementation and Effectiveness: Inspection as required under the air quality permit. Results would be reporte

reports prepared as specified in the air quality permit and shared with the Coronado. 

Performance Criteria Implementation and Effectiveness: Review of delivery data would show that all diesel fuel delivered to stationa

the mine is low-sulfur diesel.

Responsible Party Implementation and Effectiveness: Rosemont Copper is responsible for conducting monitoring and reporting to 

Service in accordance with the final MPO and air quality permit. ADEQ is responsible for determining complianc

permit and the Clean Air Act and for keeping the Forest Service informed of the results of such determinations.

Timing Implementation and Effectiveness: Premining through final reclamation and closure phases.

Applicable Alternatives All action alternatives.

QA-AQ-9 – Reduction in air emissions from diesel engines associated with mobile sources (haulage equipment, et

Element Description

Description Use of newer engine designs on haulage equipment and on select mobile sources; includes use of Tier 4 EPA com

emission standards on selected nonroad engines (all except haul trucks and the 2,000 horsepower front-end loade

engines for haul trucks; and use of Tier 4 engines for large haulage trucks and support equipment purchased after 

Note: EPA standards have been changing based on what is technologically available and on equipment productio

Copper would purchase equipment that meets EPA standards; the dates may change based on EPA requirements.

Source Air quality permit.

Impacts Mitigated Would reduce impacts to air quality from internal combustion engine emissions. 

Location Specific equipment listed and addressed in air quality permit, application, and amendments.

Monitoring / Reporting 

Action

Implementation: Certification and reporting that specified equipment meets requirements before it is put into us

Effectiveness: In accordance with air quality permit requirements. Inspection results would be reported in semian

as specified in the air quality permit and shared with the Coronado. 

Performance Criteria Implementation: Specified equipment would meet specifications stated in air quality permit application and ame

Effectiveness: Meets criteria specified in the air quality permit.

Responsible Party Implementation and Effectiveness: Rosemont Copper is responsible for conducting monitoring and reporting to 

Service. ADEQ is responsible for determining compliance with the air quality permit and the Clean Air Act and f

Service informed of the results of such determinations.

Timing Implementation and Effectiveness: Commences with purchase of stated equipment, prior to putting that equipm

through closure or as stated in the air quality permit.

Final Environmental Impact Statement for the Rosemont Copper Project

B-81
Element Description

Applicable Alternatives All action alternatives.

OA-AQ-10 – Air pollution control requirements for electrowinning process

Element Description

Description This mitigation requires several actions and methods to control potential emissions in the electrowinning process

and use of scrubbers to control sulfuric acid emissions; dilution of sulfuric acid and use of drip system to minimiz

installation, use, and maintenance of covers to control acid emissions; and use of foam, dispersion/poly balls, sur

effective means of controlling sulfuric acid emissions. Locations where these requirements apply are specified in 

Source Air quality permit.

Impacts Mitigated Would reduce emissions from electrowinning process. 

Location All equipment and locations specified in the air quality permit.

Monitoring / Reporting 

Action

Implementation: In accordance with air quality permit requirements.

Effectiveness: In accordance with air quality permit requirements. Inspection results would be reported in semian

as specified in the air quality permit and shared with the Coronado. 

Performance Criteria Implementation: In accordance with air quality permit requirements.

Effectiveness: In accordance with air quality permit requirements.

Responsible Party Implementation and Effectiveness: Rosemont Copper is responsible for conducting monitoring and reporting in 

air quality permit requirements. ADEQ is responsible for determining compliance with the air quality permit and 

for keeping the Forest Service informed of the results of such determinations.

Timing Implementation and Effectiveness: During electrowinning processing.

Applicable Alternatives All action alternatives except “Alternative 4 – Barrel Alternative.”

Other Monitoring Items for Air Quality

OA-AQ-11 – Opacity monitoring

Element Description

Description This monitoring describes emission limitations and establishes monitoring, reporting, and recordkeeping requirem

Source Air quality permit. 

Purpose To determine whether opacity meets the requirements of the air quality permit.

Location Locations specified in the air quality permit.

Monitoring / Reporting 

Action

Implementation and Effectiveness: In accordance with the air quality permit. Inspection results would be repor

reports prepared as specified in the air quality permit and shared with the Coronado. 

Performance Criteria Implementation and Effectiveness: In accordance with the air quality permit.

B-82 Final Environmental Impact Statement for the Rosemont Copper Project
Element Description

Responsible Party Implementation and Effectiveness: Rosemont Copper is responsible for monitoring and reporting in accordance 

permit. ADEQ is responsible for determining compliance with the air quality permit and the Clean Air Act and fo

Service informed of the results of such determinations.

Timing Implementation and Effectiveness: Premining through final reclamation and closure phases.

Applicable Alternatives All action alternatives.

Groundwater Quantity and Quality

OA-GW-01 – Location and design of the heap leach facility to reduce potential impacts to groundwater and surface 

Element Description

Description The heap leach facility has been designed and located to reduce the risk of potential contamination of groundwate

designed to collect all possible drainage and solution. It would be located on top of a stable rock location; the line

meet the requirements of the aquifer protection permit; and the facility would be encapsulated by waste rock at cl

stormwater infiltration. 

Source This is a design feature that was contained in the preliminary MPO. It is also a requirement of the aquifer protecti

Impacts Mitigated Would avoid impacts to groundwater and surface water quality. 

Location Heap leach pad. 

Monitoring / Reporting 

Action

Implementation: Daily visual inspection at time of construction to ensure that the location and design comply w

aquifer protection permit. 

Effectiveness: Inspections and operational monitoring would occur monthly and quarterly, as specified in the aqu

Performance Criteria Implementation: The heap leach pad would be constructed at the location specified in the final MPO; the design 

would comply with specifications in the final MPO and aquifer protection permit.

Effectiveness: Monitoring would indicate that the heap leach is effective in containing solutions, and monitoring 

seepage that could impact groundwater is not occurring. Also see OA-GW-06, “Groundwater Quality Monitoring

Responsible Party Implementation and Effectiveness: Rosemont Copper is responsible for conducting monitoring and reporting to 

ADEQ. ADEQ is responsible for determining compliance with aquifer protection permit.

Timing Implementation and Effectiveness: Monitoring would be required from the beginning of heap leach pad constru

processing, and until closure of the heap facilities to ensure effectiveness of the facility in avoiding impacts and e

applicable laws, regulations, and permits. 

Applicable Alternatives All action alternatives except “Alternative 4 – Barrel Alternative.”

Final Environmental Impact Statement for the Rosemont Copper Project

B-83
OA-GW-02 – Reduction of the potential for acid generation and metal leaching from tailings and waste rock as req

aquifer protection permit

Element Description

Description This mitigation involves requirements for the segregation and encapsulation of potentially acid-generating waste 

buffering capabilities in order to reduce the risk of potential acid generation.

Source This is a design feature that was in the preliminary MPO. It is also a requirement under the aquifer protection per

Impacts Mitigated Would avoid or reduce impacts to groundwater and surface water quality by reducing the potential of acid produc

the reactivity of the material for drainage from waste rock areas.

Location Waste rock facilities and waste rock perimeter buttress locations.

Monitoring / Reporting 

Action

Implementation: Monthly monitoring to ensure that placement of waste rock, potentially acid-generating, and no

types complies with placement requirements and approved waste rock segregation plan in the aquifer protection p

Effectiveness: In accordance with aquifer protection permit: after significant rainfall events (0.5 inch or greater p

hour period); waste rock managed by monitoring potentially acid-generating and non-acid-generating rock types 

aquifer protection permit (required inspections and operational monitoring) and performing synthetic precipitatio

test work on materials as described in the waste rock segregation plan (also referenced in the aquifer protection p

groundwater quality monitoring (OA-GW-06) and stormwater monitoring (OA-SW-01) in this section.

Performance Criteria Implementation: Placement of potentially acid-generating and non-acid-generating materials would comply with 

waste rock segregation plan and therefore would comply with the final MPO and aquifer protection permit.

Effectiveness: No consistent, long-term indications of elevated metals concentrations or other characteristics of a

would be detected, based on aquifer quality limits to be specified by ADEQ through the aquifer protection permit 

groundwater monitoring). See also groundwater quality monitoring (OA-GW-06) and stormwater monitoring (OA

section.

Responsible Party Implementation and Effectiveness: Rosemont Copper is responsible for conducting monitoring and quarterly re

Service and ADEQ. ADEQ is responsible for evaluating compliance with aquifer protection permit.

Timing Implementation: Beginning when waste rock is segregated and placed and ending when those activities are com

Effectiveness: Until closure of the aquifer protection permit tailings and waste rock facilities.

Applicable Alternatives All action alternatives.

OA-GW-03 – Equipment and methods to keep potentially contaminated water from being released into the environ

Element Description

Description This mitigation measure requires the use of appropriately sized lined ponds; retention of all contact stormwater fo

water; and installation of overflow alarms to alert operators of a potential overflow situation.

Source Pond liners and retention and reuse of contact stormwater as process water were contained in the preliminary MP

under the aquifer protection permit. The requirement for installation and use of overflow alarms originated with t

Impacts Mitigated Would avoid or reduce surface water and groundwater contamination.

Location Process water temporary storage pond, raffinate pond, stormwater pond, primary settling basin, and pregnant leac

B-84 Final Environmental Impact Statement for the Rosemont Copper Project
Element Description

Monitoring / Reporting 

Action

Implementation: Complete inspection at time of construction to ensure consistency with location and specificati

final MPO and aquifer protection permit.

Effectiveness: Quarterly visual inspection of pond integrity; additional inspections for process upset events or sig

(0.5 inch or greater precipitation within 24-hour period), in accordance with the aquifer protection permit.

Performance Criteria Implementation: Liners meet specifications contained in the aquifer protection permit. Containment structures a

comply with the final MPO and aquifer protection permit.

Effectiveness: Compliance with the aquifer protection permit. Fluids accumulated in the stormwater pond would 

days, in accordance with aquifer protection permit specifications.

Responsible Party Implementation and Effectiveness: Rosemont Copper is responsible for conducting monitoring and reporting to 

ADEQ. ADEQ is responsible for determining compliance with the aquifer protection permit.

Timing Implementation: Monitoring during preconstruction phase to ensure compliance with the aquifer protection perm

as well as aquifer protection permit best available demonstrated control technology requirements.

Effectiveness: During active mining to ensure effectiveness and permit compliance; and during final reclamation 

ensure that facilities are adequately reclaimed in accordance with the aquifer protection permit requirements. 

Applicable Alternatives All action alternatives. Several facilities may be absent from “Alternative 4 – Barrel Alternative” due to absence 

OA-GW-04 – Control and recycling of process water

Element Description

Description Overall reduction of fresh water use and avoidance of potentially contaminated discharges by containing all proce

facilities, to be recycled back into the process stream to offset fresh water use; and the installation of overflow ala

to a potential overflow situation. 

Source Pond liners and retention and reuse of process water were a design feature contained in the preliminary MPO and 

the aquifer protection permit. The requirement for installation and use of overflow alarms originated with the Cor

Impacts Mitigated Would avoid impacts to groundwater and surface water from potential contamination and would reduce impacts t

used for processing.

Location Process water temporary storage pond; primary settling basin; raffinate pond, heap leach pad, pregnant leach solu

stormwater pond.

Monitoring / Reporting 

Action

Implementation: Daily visual inspections and quarterly reporting during construction to ensure that facilities and 

constructed in a manner that complies with the final MPO and aquifer protection permit.

Effectiveness: Inspections and operational monitoring occur daily and quarterly, as specified in the aquifer prote

Performance Criteria Implementation: Tailings facilities would be located within the footprint depicted in the FEIS, ROD, and aquife

liners and collection systems would be installed as described in the aquifer protection permit. 

Effectiveness: Pump systems, valves, and structures would be functioning properly; overflow pipes and spillway 

be blocked; flow rates would be less than the maximum specified in aquifer protection permit; liner(s) integrity w

impaired; design capacity would not be exceeded. See aquifer protection permit for further details. 

Final Environmental Impact Statement for the Rosemont Copper Project

B-85
Element Description

Responsible Party Implementation and Effectiveness: Rosemont Copper is responsible for conducting monitoring and reporting to 

ADEQ. ADEQ is responsible for determining compliance with the aquifer protection permit.

Timing Implementation: During premining and active mining phases.

Effectiveness: For the life of the mine, commencing when production begins; and ending at closure of the aquife

Applicable Alternatives All action alternatives. Several facilities may be absent from “Alternative 4 – Barrel Alternative” due to absence 

OA-GW-05 – Processing and placement of tailings to reduce water content and overall footprint

Element Description

Description This mitigation requires the use of dry-stack tailings technology, which would eliminate the need for traditional t

would allow tailings to be placed and compacted in a manner that would reduce the overall footprint of tailings fa

minimize the amount of water entrained in the tailings (water from filtered tailings is reused); and would reduce t

water needed for processing.

Source This is a design feature that was contained in the preliminary MPO. It is also a requirement under the aquifer prot

stack tailings plan would be required by the Forest Service, to be included in the final MPO.

Impacts Mitigated A smaller footprint would avoid impacts to cultural sites, wildlife habitat, soils, WUS, and surface water; would r

to water use; would reduce seepage; would avoid or reduce impacts related to potential groundwater contaminatio

evaporation; and would reduce water use. Reclamation can begin earlier, improving vegetative recovery.

Location Entire tailings facility.

Monitoring / Reporting 

Action

Implementation: Daily inspections and quarterly reporting to ensure that the footprint of the tailings facility is w

in the FEIS/ROD and that those facilities are constructed in accordance with the final MPO.

Effectiveness: Monitoring to determine: (1) the moisture content and compaction of the tailings being placed; (2) 

adheres to the stacking plan to ensure adequate buffering of potential acid-generating materials; and (3) that it com

preparation, grading, and applicable best available demonstrated control technology requirements described in the 

permit. 

Compliance with the aquifer protection permit monitoring requirements, daily monitoring relating to ponding of w

deformation, excessive erosion, and moisture content. 

Monitoring results would be compiled into an annual monitoring report and provided to the Forest Service and A

Performance Criteria Implementation: Tailings facilities would be located within the footprint depicted in the FEIS/ROD and final M

Effectiveness: Moisture content of tailings would be a maximum of 18 percent coming out of the filter plant and 

compliance with final stacking plan, which would be included in the MPO. Excessive ponding of water would no

pumped into process water facility before it can infiltrate; excessive erosion would not occur; dry-stack facility w

substantial deformation, movement, subsidence, or slope sloughing. 

Responsible Party Implementation and Effectiveness: Rosemont Copper is responsible for conducting monitoring and reporting to 

ADEQ. The Forest Service is responsible for spot-checking monitoring activities; and for evaluating monitoring r

compliance with NEPA decision. ADEQ is responsible for determining compliance with aquifer protection perm

B-86 Final Environmental Impact Statement for the Rosemont Copper Project
Element Description

Timing Implementation: During the period that tailings are being placed (primarily active mining phase).

Effectiveness: For the life of the mine, commencing when tailing stacking begins and ending when tailings are n

in the facility.

Applicable Alternatives All action alternatives.

OA-GW-08 – Well abandonment or capping

Element Description

Description This mitigation requires that Rosemont Copper properly abandon or cap all unused wells or open boreholes in acc

well abandonment regulations.

Source ADWR regulations.

Impacts Mitigated Proper abandonment or capping of open boreholes or unused wells ensures that a potential pathway for migration 

not exist between surface and aquifer, or between aquifers.

Location Rosemont Copper private lands.

Monitoring / Reporting 

Action

Implementation: Rosemont Copper would identify all known wells and open boreholes that are not properly aba

would be abandoned, and those that need to remain open and would be properly capped. Rosemont Copper would 

or boreholes that logistically cannot be properly abandoned or capped.

Effectiveness: Copies of abandonment completion forms required by ADWR provided to Forest Service for all id

boreholes.

Performance Criteria Implementation/Effectiveness: All identified wells are properly abandoned or capped.

Responsible Party Implementation and Effectiveness: Rosemont Copper is responsible for identifying wells and performing aband

Timing Implementation/Effectiveness: Premining phase.

Applicable Alternatives All action alternatives.

Other Monitoring Items for Groundwater Quantity and Quality 

OA-GW-06 – Groundwater quality and aquifer-level monitoring required under the aquifer protection permit

Element Description

Description This monitoring requires the construction and operation of point of compliance monitoring wells, groundwater qu

sampling protocols, and reporting as specified in the aquifer protection permit. 

Source Aquifer protection permit; biological opinion conservation measures and/or terms and conditions; and requiremen

Purpose To determine whether measures designed to avoid or reduce risk of groundwater are effective and whether applic

regulations are being met.

Location Point of compliance well locations, as specified in the aquifer protection permit (point of compliance well locatio

locations are expected to be amended in aquifer protection permit to reflect the selected alternative.

Final Environmental Impact Statement for the Rosemont Copper Project

B-87
Element Description

Monitoring / Reporting 

Action

Implementation and Effectiveness: As specified in the aquifer protection permit.

Performance Criteria Implementation and Effectiveness: As specified in the aquifer protection permit. 

Responsible Party Implementation and Effectiveness: The Forest Service is responsible for monitoring the implementation of any 

mitigation that are specified as requirements of the USFWS biological opinion. Rosemont Copper is responsible 

monitoring and reporting to the Forest Service and ADEQ. ADEQ is responsible for determining compliance with 

permit.

Timing Implementation and Effectiveness: As specified in the aquifer protection permit. 

Applicable Alternatives All action alternatives.

OA-GW-07 – Monitoring quantity of supply water removed from the Santa Cruz Basin

Element Description

Description This monitoring item measures the amount of groundwater pumped by the mine water supply wells located near 

Source Requirement under ADWR mineral extraction permit.

Purpose To determine whether reduction of groundwater resources within the Upper Santa Cruz Basin is within the projec

decision. This information is also needed for ADWR for permit compliance.

Location At wellhead for all water supply wells.

Monitoring / Reporting 

Action

Implementation and Effectiveness: As specified by ADWR permit. 

Performance Criteria Implementation and Effectiveness: As specified by ADWR permit. 

Responsible Party Implementation and Effectiveness: Rosemont Copper is responsible for conducting monitoring and reporting to 

ADWR. ADWR is responsible for determining compliance with the mineral extraction permit.

Timing Implementation and Effectiveness: Premining through final reclamation and closure phases.

Applicable Alternatives All action alternatives.

Surface Water Quantity and Quality

OA-SW-01 – Detention and testing of stormwater

Element Description

Description This mitigation measure requires detention and testing of stormwater quality from perimeter waste rock buttress a

testing prior to flowing downstream of the mine site. Should impacts over and above the levels predicted in the E

monitoring efforts, the funding provided by the Cienega Creek Watershed Conservation Fund could be used to im

management strategies to offset unanticipated effects.

Source Arizona Pollutant Discharge Elimination System Multi-Sector General Permit, Specific Rosemont Copper Permit 

biological opinion conservation measures and/or terms and conditions.

B-88 Final Environmental Impact Statement for the Rosemont Copper Project
Element Description

Purpose Would avoid or reduce impacts to surface water quality by reducing the risk of discharging contaminated water; w

load of water released into downstream drainages. Would potentially reduce impacts to Gila chub, Gila topminno

umbel. 

Location Sediment ponds, sediment control structures in “Alternative 4 – Barrel Alternative” only, and compliance point p

alternatives. Specific locations of sampling would be defined in the stormwater pollution prevention plan which i

Arizona Pollutant Discharge Elimination System Multi-Sector General Permit, and would be modified after Fore

alternative in the ROD. Sampling locations typically are tied to “outfalls” and in this case is likely to be the propo

structures and compliance point dam.

Monitoring / Reporting 

Action

Implementation: Complete inspection at the time of construction of these facilities to ensure consistency with lo

specifications contained in the final MPO and stormwater pollution prevention plan.

Effectiveness: Ongoing maintenance inspections would occur and be reported as specified in the final MPO and 

Discharge Elimination System Multi-Sector General Permit.

Performance Criteria Implementation: Facilities would be constructed in locations and to specifications contained in final MPO and A

Discharge Elimination System stormwater pollution prevention plan.

Effectiveness: As specified in the final MPO and Arizona Pollutant Discharge Elimination System Multi-Sector 

Responsible Party Implementation and Effectiveness: The Forest Service is responsible for monitoring the implementation of any 

mitigation that are specified as requirements of the USFWS biological opinion. Rosemont Copper is responsible 

monitoring and reporting to the Forest Service and ADEQ. ADEQ is responsible for determining compliance with 

Timing Implementation: During construction (premining phase) to ensure compliance with final MPO and stormwater p

plan.

Effectiveness: During active mining phase to ensure effectiveness and permit compliance and during final reclam

ensure that facilities are adequately reclaimed.

Applicable Alternatives While the concept applies to all action alternatives, the structures and locations differ by alternative. Refer to the 

in chapter 2 for further information.

OA-SW-02 – Implementation of stormwater pollution prevention plan

Element Description

Description This mitigation involves requirements of the Arizona Pollutant Discharge Elimination System Multi-Sector Gene

Construction General Permit to prepare and implement a stormwater pollution prevention plan. The stormwater p

plan identifies methods to reduce potential pollution of stormwater; this plan is site specific, flexible, and constan

It typically includes a variety of ways to reduce potential pollution, including structural controls (i.e., sediment ba

bales); best management practices (i.e., good housekeeping, spill prevention); and stabilization practices (i.e., wa

tackification). The plan is implemented by following best practices, installing appropriate structural control meas

monitoring those measures and repairing/replacing if needed, and revising or updating the plan to reflect project c

changing conditions. 

Source Arizona Pollutant Discharge Elimination System Multi-Sector General Permit.

Final Environmental Impact Statement for the Rosemont Copper Project

B-89
Element Description

Impacts Mitigated Would reduce impacts to surface quality through potential degradation and loss of soil through erosion, and preve

stormwater with hazardous materials.

Location All construction areas, including utility lines and access roads; all operational mine areas within security fence.

Monitoring / Reporting 

Action

Implementation and Effectiveness: Final monitoring details and locations would be updated in the stormwater p

plan following selection of the preferred alternative in the ROD.

Performance Criteria Implementation and Effectiveness: Results of this monitoring would be used to evaluate the success of the mea

the water resources. Any changes in water exceedances of Multi-Sector General Permit criteria would be evaluate

the changes are related to the reclaimed mining features, and appropriate steps would be taken to address the prob

stormwater pollution prevention plan.

Responsible Party Implementation and Effectiveness: Rosemont Copper is responsible for conducting monitoring and reporting to 

ADEQ. ADEQ is responsible for determining compliance with the Arizona Pollutant Discharge Elimination Syst

Timing Implementation and Effectiveness: Surface water would be monitored as required in the Arizona Pollutant Disc

System program during construction (premining phase), active mining, and following cessation of mining operati

phase). 

Applicable Alternatives All action alternatives.

Transportation/Access

OA-TA-01 – ADOT activities to mitigate impacts of increased traffic on SR 83

Element Description

Description This mitigation consists of Rosemont Copper’s providing funding to the Arizona Department of Transportation (A

activities to reduce impacts resulting from increased traffic on SR 83. ADOT has indicated that the activities it pl

include 3-inch pavement overlay from Interstate (I-) 10 to the intersection of the primary access road; striping; ra

signs to match new pavement height; and paving three existing bus pullouts for school bus use. Rosemont Coppe

currently negotiating the amount of funding that would be provided.

Source ADOT.

Impacts Mitigated Reduction of potential traffic safety hazards.

Location SR 83 from I-10 to intersection with the primary access road.

Monitoring / Reporting 

Action

Implementation and Effectiveness: In accordance with agreement between Rosemont Copper and ADOT.

Performance Criteria Implementation and Effectiveness: In accordance with agreement between Rosemont Copper and ADOT.

Responsible Party Implementation and Effectiveness: ADOT has jurisdiction over these actions and therefore would determine re

monitoring actions.

Timing Implementation and Effectiveness: To be determined.

Applicable Alternatives All action alternatives.

B-90 Final Environmental Impact Statement for the Rosemont Copper Project
Mitigation and Monitoring Measures – Rosemont Copper

Rosemont Copper has publicly agreed to implement the following mitigation and monitoring items. These mitigation and m

beyond the authority of the Forest Service or other regulatory and permitting agency. Since the Forest Service and regulato

cannot require implementation of the mitigation and monitoring items in this category, their implementation is not assured. 

of these mitigation measures is discussed in chapter 3 of the FEIS, they are addressed as measures that may occur, as oppos

would occur, with the following exception. For the purposes of impacts analyses, the Coronado assumed that those mitigati

items with legally binding agreements in place (such as RC-GW-01 below) at the time at which the decision is made (ROD 

implemented; therefore, they are addressed as such in the mitigation effectiveness sections in chapter 3 of the FEIS. 

Air Quality and Climate Change

RC-AQ-01 – Transporting employees in natural gas powered busses to reduce NOx emissions

Element Description

Description Rosemont Copper has agreed to implement a carpooling plan in which the majority of their employees will be tra

the mine site in company owned or leased buses that are powered by natural gas. The estimated offset for this em

approximately 1,200 pounds of NOx per year based on travel along the SR 83 corridor.

Source Rosemont Copper.

Impacts Mitigated Reduces NOx emissions from employee commuting to and from the mine site.

Location SR 83 corridor, from staging areas to be determined to the mine site and back.

Monitoring / Reporting 

Action

Implementation and Effectiveness: To be determined.

Performance Criteria Implementation and Effectiveness: To be determined.

Responsible Party Implementation and Effectiveness: Rosemont Copper.

Timing Implementation and Effectiveness: Premining through final reclamation and closure mining phases.

Applicable Alternatives All action alternatives.

Groundwater Quantity and Quality

RC-GW-01– Providing protection for individual private residential well owners against the risk that mine-associate

drawdown could impact their well

Element Description

Description This mitigation involves implementing a legally binding well owner protection agreement that provides certain pr

to potential impacts to individual well owners.

Source Rosemont Copper. 

Final Environmental Impact Statement for the Rosemont Copper Project

B-91
Element Description

Impacts Mitigated May compensate for potential impacts to domestic wells for homeowners who are eligible for and sign up for the 

level monitoring program, water well pump warranty program, residential well deepening, and an in-lieu cash opt

restrictions apply.

Location Two distinct agreements: one covers Sahuarita Heights neighborhood near Rosemont Copper’s supply wells; the 

of Hilton Ranch, Helvetia, and Singing Valley.

Monitoring / Reporting 

Action

Implementation and Effectiveness: Agreements have been executed and are currently in place. No Forest Servi

monitoring would occur. Involvement of homeowners is voluntary, and the agreement is between the homeowner 

Performance Criteria Implementation and Effectiveness: In accordance with Rosemont Copper Residential Water Well Warranty Ser

Not applicable to the Forest Service or permitting agencies.

Responsible Party Implementation and Effectiveness: Rosemont Copper.

Timing Implementation and Effectiveness: Agreements for the Sahuarita Heights neighborhood are already in place an

for the Hilton Ranch, Helvetia, and Singing Valley areas would become effective when Rosemont Copper receive

approval for the project. 

Applicable Alternatives All action alternatives.

Other Monitoring Items for Groundwater Quantity and Quality 

RC-GW-02– Recharging the aquifer in the Tucson Active Management Area 

to offset pumping of mine supply water

Element Description

Description This involved regional groundwater mitigation within the Tucson Active Management Area, including using Cen

water to recharge within the Tucson Active Management Area. This mitigation is dependent on Central Arizona P

available to Rosemont Copper.

Source Rosemont Copper. Recharge of groundwater is also a requirement of a license agreement executed between Rose

Town of Sahuarita for a ROW, enforceable if the ROW is used.

Impacts Mitigated Would compensate for some or all of the water removed from the aquifer to supply the mine. Some recharge has 

but not in the Sahuarita area. 

Location Tucson Active Management Area.

Monitoring / Reporting 

Action

Implementation and Effectiveness: Annual reporting required to ADWR.

Performance Criteria Implementation and Effectiveness: Recharge would occur as close as possible within the Tucson Active Manag

Rosemont supply well field. Central Arizona Project storage credits would be balanced with water to be pumped 

well field, with the intent to maintain a surplus inventory of storage credits prior to pumping groundwater for min

Water storage and use inventory records would be maintained to show that Central Arizona Project recharge cred

groundwater removed from the Tucson Active Management Area until at least 5 years following completion of th

Responsible Party Implementation and Effectiveness: Rosemont Copper is responsible for monitoring and reporting to ADWR.

B-92 Final Environmental Impact Statement for the Rosemont Copper Project
Element Description

Timing Implementation and Effectiveness: Has occurred; would continue as long as source water is available. Rosemo

committed to recharging 105 percent of the groundwater extracted. If the full amount authorized by the ADWR is 

up to 126,000 acre-feet. 

Applicable Alternatives All action alternatives.

RC-GW-03 – Extension of Central Arizona Project pipeline to Green Valley

Element Description

Description Augusta Resource Corporation (parent company of Rosemont Copper) would partially fund a 7-mile extension of 

Project to deliver Community Water Company of Green Valley’s Central Arizona Project allotment; and would u

that pipeline to recharge in the general vicinity of the mine supply wells.

Source Rosemont Copper.

Impacts Mitigated Would reduce impacts of groundwater use for mine supply. Would provide Community Water Company with acc

Project water; would allow recharge by Rosemont Copper in the vicinity of pumping; and would compensate for 

supply water pumped out of the aquifer.

Location Central Arizona Project pipeline extension location.

Monitoring / Reporting 

Action

Implementation: Not applicable (NA)

Effectiveness: NA

Performance Criteria Implementation: NA

Effectiveness: NA

Responsible Party Implementation: NA

Effectiveness: NA

Timing Implementation: The U.S. Bureau of Reclamation completed environmental documentation needed for construc

construction was initiated in July 2012.

Effectiveness: NA

Applicable Alternatives All action alternatives. 

Surface Water Quantity and Quality

RC-SW-01 – Continued operation and data gathering of USGS flow gage that would provide data for surface water 

the mine site

Element Description

Description Rosemont Copper would annually fund the USGS to operate and maintain the existing flow gage at Barrel Canyo

Source Rosemont Copper. 

Purpose Would allow for continued baseline data collection and monitoring collection of flows in Barrel Canyon. 

Final Environmental Impact Statement for the Rosemont Copper Project

B-93
Element Description

Location Barrel Canyon flow gage at SR 83.

Monitoring / Reporting 

Action

Implementation and Effectiveness: Rosemont Copper would annually report to the Forest Service on the status 

obligation.

Performance Criteria Implementation and Effectiveness: A fully executed agreement and documentation of funds transferred to USG

cutoff dates.

Responsible Party Implementation and Effectiveness: Rosemont Copper would maintain a contract agreement with a government 

USGS to operate and maintain Barrel Canyon flow gage. Potential agencies include the Pima County Flood Cont

and Forest Service. 

Timing Implementation and Effectiveness: Funding would continue for at least 5 years after mining and processing ope

closure of the aquifer protection permit, whichever is longer.

Applicable Alternatives All action alternatives.

Biological Resources

RC-BR-01 – Recordation of a restrictive easement on private land referred to as the Fullerton Parcel to protect wild

Element Description

Description This mitigation would result from Rosemont Copper’s recording a restrictive covenant on the Fullerton Parcel. Th

contains about 1,780 acres of semidesert grasslands in the Sierrita Mountains. Recordation of a restrictive covena

wildlife habitat. Management would exclude grazing to enhance habitat values. 

Source Rosemont Copper.

Impacts Mitigated May partially compensate for losses of habitat for general wildlife species. 

Location Fullerton Parcel. 

Monitoring / Reporting 

Action

Implementation: Recordation of a restrictive covenant would be reported. A copy of the restrictive covenant wo

Forest Service.

Effectiveness: Not applicable (NA)

Performance Criteria Implementation: Recordation of a restrictive covenant.

Effectiveness: NA

Responsible Party Implementation: Rosemont Copper is responsible for crafting and recording a restrictive covenant.

Effectiveness: NA

Timing Implementation and Effectiveness: To be determined.

Applicable Alternatives All action alternatives.

B-94 Final Environmental Impact Statement for the Rosemont Copper Project
RC-BR-02 – Agreement in principle between Rosemont Copper and Arizona Game and Fish Department

Element Description

Description On October 25, 2013, Rosemont Copper and AGFD entered into an agreement in principle in which Rosemont C

conservation measures and AGFD would implement those measures with Rosemont Copper funding until that fun

agreement in principle is anticipated to be embodied in a detailed agreement between Rosemont Copper and AGF

contractual commitments. None of the terms of the agreement in principle, or the anticipated detailed agreement t

would redefine or take precedence over any requirements contained in the USFWS biological opinion, any permi

ROD. The projects addressed in the agreement in principle include:

• Rosemont Copper purchasing the Sonoita Creek Ranch and transfer of ownership to the Arizona Game 

(see FS-BR-08). This includes Rosemont Copper completing demolition and start-up work prior to tran

• Rosemont Copper providing funding to AGFD over 10 years for long-term fencing, operation, and mai

Creek Ranch.

• Rosemont Copper providing funding to AGFD for renovation of two perennial ponds at Sonoita Creek 

• Rosemont Copper purchasing and transferring certified water rights to the Arizona Game and Fish Com

flow rights in upper Cienega Creek. 

• Rosemont Copper funding the Cienega Creek Conservation Fund (see FS-BR-16).

• Rosemont Copper providing funding designated specifically for AGFD to expend to protect and mainta

trust species.

• Rosemont Copper providing funding to AGFD for an integrated study of the impacts to wildlife connec

camera study described in FS-BR-09. This also includes Rosemont Copper providing funding for struct

indicate the need.

• Rosemont Copper providing funding to AGFD to build and maintain constructed waters to benefit Ariz

• Rosemont Copper purchasing and preserving by deed restriction or restrictive covenant the Fullerton R

BR-01).

• Rosemont Copper including the Rosemont Ranch property into AGFD’s conservation landowner relatio

TA-02).

• Rosemont Copper providing funding to AGFD to reestablish Gould’s turkey populations in southern A

• Rosemont Copper and AGFD would conduct non-binding consultation during development of any plan 

Migratory Bird Treaty Act.

• Rosemont Copper purchasing and protecting by deed restriction or conservation easement of the David

(see FS-BR-21).

• Rosemont Copper purchasing and protecting by deed restriction or conservation easement of the Helve

property (see FS-BR-07).

• Rosemont Copper funding a flexible conservation fund for AGFD.

• Rosemont Copper providing funding to AGFD for coordination and reporting on annual performance.

Final Environmental Impact Statement for the Rosemont Copper Project

B-95
Element Description

Source Rosemont Copper and AGFD.

Impacts Mitigated General impacts to wildlife and wildlife habitat.

Location Various; some not specified.

Landownership and Boundary Management

RC-LO-01 – Transferring of ownership of small slivers of land within the mining footprint from the Coronado to Ro

Element Description

Description A number of small mineral survey fractions are located within the footprint of the mine pit and tailings/waste ro

small slivers of land are currently NFS lands that would be difficult to manage as public lands postproject. Rose

expressed an interest in purchasing these mineral survey fractions from the Coronado. The sale would comply w

Act (36 CFR 254.24). The proponent would pay for surveys of the mineral fractions, appraisals, Commitment o

and other administrative costs, as agreed upon with the Forest Service.

Source Coronado ID team.

Impacts Mitigated Would avoid difficulties related to managing slivers NFS lands that are covered by waste rock and tailings facili

Location Seven known mineral survey fractions totaling approximately 5.5 acres are completely surrounded by the patent

owned by Rosemont Copper.

Monitoring / Reporting 

Action

Implementation and Effectiveness: The Forest Service would process the sale following final Forest Service a

the sale must be finalized prior to mine closure. 

Performance Criteria Implementation and Effectiveness: Sale would be processed and finalized prior to mine closure.

Responsible Party Implementation and Effectiveness: Rosemont Copper is responsible for following through on their commitme

fractions; Forest Service is responsible for processing sale.

Timing Implementation and Effectiveness: Prior to closure of mine.

Applicable Alternatives All action alternatives.

RC-LO-02 – Elimination of future development of private lands located on top of waste rock and tailings facilities

Element Description

Description This mitigation would include recording a restrictive easement or other mechanism intended to avoid future dev

lands located on waste rock and tailings facilities that could compromise stability or reclamation results. 

Source Coronado ID team. 

Impacts Mitigated Would avoid future activities that could compromise reclamation of waste rock and tailings facilities over the lo

Location Waste rock and tailings facilities.

Monitoring / Reporting 

Action

Implementation and Effectiveness: The Forest Service would work with Rosemont Copper to implement mec

restrictive covenants to accomplish goals.

B-96 Final Environmental Impact Statement for the Rosemont Copper Project
Element Description

Performance Criteria Implementation and Effectiveness: Restrictive covenants or other legally binding instruments would be develo

to restrict future development of private lands on or within tailings and waste rock facilities.

Responsible Party Implementation and Effectiveness: Rosemont Copper is responsible for developing and implementing approp

accomplish the stated goals.

Timing Implementation and Effectiveness: Restrictive easement or other mechanism would be in place at time of fina

Applicable Alternatives All action alternatives.

Visual Resources

RC-VR-01 – Architectural designs for buildings associated with the water supply line pump stations

Element Description

Description Rosemont Copper has stated that they would follow University of Arizona College of Architecture and Planning 

Architecture design guidance for buildings associated with four pump stations to ensure that they maintain the te

Experimental Range. 

Source Rosemont Copper. 

Impacts Mitigated Would reduce visual contrast and associated visual impacts of buildings associated with water line pump station

Rita Experimental Range.

Location Four pump stations along utility corridor.

Monitoring / Reporting 

Action

Implementation and Effectiveness: Not applicable (NA)

Performance Criteria Implementation and Effectiveness: NA

Responsible Party Implementation and Effectiveness: Rosemont Copper is responsible for obtaining and implementing design gu

Timing Implementation and Effectiveness: Construction of these facilities (premining phase).

Applicable Alternatives All action alternatives.

Transportation/Access

RC-TA-01 – Scheduling deliveries to the mine to take place during nonpeak traffic hours to avoid adding to traffic 

Element Description

Description Deliveries would be scheduled to minimize material delivery on SR 83 during peak traffic hours (6:30 to 7:30 a

traffic; and 5:00 to 6:00 p.m. for southbound traffic).

Source This is a design feature of the preliminary MPO.

Impacts Mitigated Would reduce impacts to the public from mine related traffic on SR 83 during peak traffic hours.

Location SR 83. 

Final Environmental Impact Statement for the Rosemont Copper Project

B-97
Element Description

Monitoring / Reporting 

Action

Implementation: Plan for delivery schedule would be developed and incorporated into the final MPO. 

Effectiveness: Recordkeeping of deliveries would include time of delivery; quarterly reporting of delivery infor

the preponderance of deliveries occur outside of peak traffic hours. The intent of reporting is to determine wheth

effective in reducing truck traffic during peak traffic periods on SR 83.

Performance Criteria Implementation: Delivery schedule plan would be developed and incorporated into the final MPO.

Effectiveness: Review of delivery records would indicate that the preponderance of delivery traffic on SR 83 oc

traffic hours.

Responsible Party Implementation and Effectiveness: Rosemont Copper is responsible for conducting monitoring and reporting 

Timing Implementation and Effectiveness: Premining through final reclamation. 

Applicable Alternatives All action alternatives.

RC-TA-02 – Providing public access to Rosemont Copper private lands not affected by mine operations through a

agencies and programs

Element Description

Description Rosemont Copper would enter into agreements with appropriate State agencies to allow some public access to p

lands. 

Source Rosemont Copper.

Impacts Mitigated Reduction in loss of public access.

Location To be determined.

Monitoring / Reporting 

Action

Implementation and Effectiveness: Appropriate State agencies would work with Rosemont Copper to identify 

of allowable use.

Performance Criteria Implementation and Effectiveness: To be determined by appropriate State agencies and Rosemont Copper.

Responsible Party Implementation and Effectiveness: Rosemont Copper in cooperation with appropriate State agencies.

Timing Implementation and Effectiveness: To be determined by appropriate State agencies and Rosemont Copper.

Applicable Alternatives All action alternatives.

RC-TA-03 – Limiting travel on utility maintenance road

Element Description

Description Rosemont Copper would limit travel on the utility maintenance road to only what is necessary for pipeline or pow

maintenance and would only perform road maintenance when necessary. 

Source Rosemont Copper. 

Purpose Would reduce fugitive dust emissions on the west side of the Santa Rita Mountains.

Location Utility maintenance road, from mine site to Town of Sahuarita.

B-98 Final Environmental Impact Statement for the Rosemont Copper Project
Element Description

Monitoring / Reporting 

Action

Implementation and Effectiveness: Rosemont Copper would put into place management or access restrictions t

necessary travel takes place on the road. Necessary travel would be related to operation, maintenance, or repair o

power line, pump stations, or related infrastructure. Rosemont Copper would put into place management restrictio

grading or road maintenance activities are only conducted when necessary. Rosemont Copper would obtain and c

necessary State or local permits needed to perform maintenance activities.

Performance Criteria Implementation and Effectiveness: Rosemont Copper would provide copies of any management plans or proce

travel on the utility maintenance road and copies of any applicable State or local permits to the Coronado.

Responsible Party Implementation and Effectiveness: Rosemont Copper would be responsible for producing and implementing m

access restrictions.

Timing Implementation and Effectiveness: Until mining and processing activities cease. 

Applicable Alternatives All action alternatives.

Fire and Fuels

RC-FF-01 – Allowing access to a new water source for firefighting efforts

Element Description

Description Rosemont Copper has stated that it would allow ASLD personnel to access the water fill station at the #2 booste

firefighting purposes. The #2 booster pump station is located along the water supply pipeline.

Source Rosemont Copper.

Impacts Mitigated Would potentially reduce impacts from wildfire, particularly on and near the Santa Rita Experimental Range, by 

source to firefighting agencies.

Location Water line booster pump station #2.

Monitoring / Reporting 

Action

Implementation and Effectiveness: ASLD and Rosemont Copper would enter into an agreement to construct a 

accommodates access by firefighter agencies. This is an agreement between ASLD and Rosemont Copper. No F

agency monitoring would occur.

Performance Criteria Implementation and Effectiveness: ASLD and Rosemont Copper.

Responsible Party Implementation and Effectiveness: ASLD and Rosemont Copper.

Timing Implementation and Effectiveness: From the time this facility is constructed through final reclamation.

Applicable Alternatives All action alternatives.

Final Environmental Impact Statement for the Rosemont Copper Project

B-99
Cultural Resources

RC-CR-01 – Conservation lands used for tribal practices

Element Description

Description This involves using the conservation lands required through the Section 7 and 404 (b)(1) permitting processes to 

tribal members.

Source Rosemont Copper.

Impacts Mitigated Partial compensation of loss of public land access for tribal members.

Location Davidson Canyon parcels, Sonoita Creek Ranch, Helvetia Ranch North, and other Rosemont Copper ranch land

7 or 404(b)(1) documents.

Monitoring / Reporting 

Action

Acquisition of land and recordation of conservation easements.

Performance Criteria Access would be subject to compliance with conservation land easements and permit requirements.

Responsible Party Rosemont Copper.

Timing As required under other permitting processes.

Applicable Alternatives All action alternatives.

Power Use

RC-PU-01 – Use of alternative methods of power generation such as solar and wind to augment power at the mine 

building

Element Description

Description Rosemont Copper has stated its intent to use alternative energy sources to augment electrical power for its mine 

building. 

Source This is a design feature from the preliminary MPO. 

Impacts Mitigated Reduction in electric power use from TEP.

Location Administration building.

Monitoring / Reporting 

Action

Implementation: Inspection during construction of administration building to ensure that it includes solar or wi

Effectiveness: Semiannual report to ensure that alternative energy sources are continuing to function.

Performance Criteria Implementation and Effectiveness: Monitoring would focus on ensuring that facilities include alternative ener

compliance with the NEPA decision.

Responsible Party Implementation and Effectiveness: Rosemont Copper is responsible for following through on its commitment 

alternative power generating equipment for administration building. 

Timing Implementation and Effectiveness: Premining, active mining, and final reclamation and closure phases, when 

sources are operational.

Applicable Alternatives All action alternatives.

B-100 Final Environmental Impact Statement for the Rosemont Copper Project
Community Programs

RC-CP-01 – Establishment of the Santa Rita Mountains Community Endowment Trust for the purposes of funding 

projects

Element Description

Description Rosemont Copper intends to establish the Santa Rita Mountains Community Endowment Trust for the purposes 

community projects, including community recreation, cultural, and environmental conservation projects. 

The endowment would consist of assets, commitments, and funding from Rosemont Copper, including conserva

restrictive covenants donated in the first year of production ($6 million), $500,000 contributed from Rosemont C

years ($12.5 million), and up to $25 million in variable contributions from Rosemont Copper, based on the price 

Copper Company 2010). Because the trust would be established as an independent charitable trust, with a Board 

Advisory Council, the projects that the trust would fund would be decided at a later date, upon the board’s speci

Source This is a design feature from the preliminary MPO.

Impacts Mitigated Compensation for cultural, environmental, and recreation impacts.

Location Not applicable (NA)

Monitoring / Reporting 

Action

Implementation and Effectiveness: NA

Performance Criteria Implementation and Effectiveness: NA

Responsible Party Implementation and Effectiveness: Rosemont Copper is responsible for establishing the Endowment Trust and 

Timing Implementation and Effectiveness: Unknown.

Applicable Alternatives All action alternatives.

Final Environmental Impact Statement for the Rosemont Copper Project

B-101
B. Mitigation and Monitoring Plan

Potential Future Mitigation Measures

A brief description of mitigation measures that are not currently finalized and may be applied in the 

future is presented here. While these mitigation measures may be implemented, either they are not 

currently developed to the point that effectiveness can be assessed or implementation ensured, or 

negotiation regarding implementation has not been completed. Therefore, these mitigation measures 

were not considered in impacts analyses as measures that would avoid, reduce, or compensate for 

impacts.

• Contribute funding to Perimeter Bicycle Association for possible for bike path from I-10 

along Houghton Road to Sahuarita. Details on permitting and approval of this proposed 

project are currently unavailable; therefore, this project is not foreseeable and cannot be 

addressed as mitigation at this time.

• Carpooling opportunities for employees would be identified, including establishing a “park 

and ride program” for workers during all phases of the proposed project to distribute peak 

travel operations during the morning and evening commute periods to minimize congestion. 

Manage trucking to reduce impacts to SR 83 and reduce overlap with school traffic to the 

extent possible.

B-102 Final Environmental Impact Statement for the Rosemont Copper Project
September 2013 Page 1 of 4 

ROSEMONT COPPER PROJECT

CONCEPTUAL HABITAT MITIGATION 

AND MONITORING PLAN SUMMARY

CORPS FILE NO. SPL-2008-00816-MB

Rosemont Copper Company (Rosemont) proposes to develop an open pit copper mine known as the 

Rosemont Copper Project (the Project). On October 11, 2011, Rosemont submitted a Clean Water Act 

(CWA) Section 404 permit application to the U.S. Army Corps of Engineers (Corps) requesting a Section 

404 permit to discharge fill materials into potential waters of the United States in connection with 

proposed Project activities (Corps File No. SPL-2008-00816-MB). As part of CWA Section 404 

individual permit requirements for discharge into waters of the United States, a Habitat Mitigation and 

Monitoring Plan (HMMP) must be prepared in accordance with the Corps' and the U.S. Environmental 

Protection Agency’s (EPA) “Final Rule for Compensatory Mitigation for Losses of Aquatic Resources” 

(33 C.F.R. Parts 325 and 332 and 40 C.F.R. Part 320; published in 73 Fed. Reg. 19594-19705), 

hereinafter referred to as the 2008 Mitigation Rule. The fundamental objective of the 2008 Mitigation 

Rule is to establish standardized compensatory mitigation criteria for all mitigation types to offset 

unavoidable impacts to waters of the United States authorized through the issuance of a CWA Section 

404 permit. 

ROSEMONT COPPER PROJECT

The proposed Project impacts to potential waters of the U.S. are primarily the result of the deposit of 

waste rock and filtered tailings, grading for processing facilities, and the construction of stormwater 

controls, roadways, waterlines, a power line, and other appurtenant features associated with the proposed 

Project. An estimated 40.0 acres of potential waters of the U.S. will be directly impacted by the proposed 

Project. Indirect impacts, totaling approximately 28.4 acres, will occur downstream in Barrel and 

Davidson canyons as a result of the reduction in stormwater flows in these areas.

REGULATORY CONTEXT

The 2008 Mitigation Rule includes a specific order in which five general classes of compensatory 

mitigation options must be considered: 1) mitigation banks, 2) in-lieu fee (ILF) programs, 3) permittee 

responsible mitigation under a watershed approach, 4) permittee-responsible mitigation through onsite 

and in-kind mitigation, and 5) permittee-responsible mitigation through offsite and/or out-of-kind 

mitigation. All five of these general classes of compensatory mitigation were considered when developing 

the mitigation approach for the Rosemont Project. 

Per the 2008 Mitigation Rule, mitigation banks are the preferred method of mitigation. However, there are 

currently no approved mitigation banks in Arizona, so this approach is not possible for Rosemont. 

An ILF program includes a sponsoring entity that assumes responsibility for overseeing the mitigation 

site in exchange for a fee. It is the second most preferable form of mitigation. Within the Santa Cruz 

River watershed, two sponsoring entities currently have approved ILF enabling instruments and are in the 

process of developing ILF projects: 1) the Arizona Game and Fish Department (AGFD), and 2) a 
September 2013 Page 2 of 4

partnership between the Tucson Audubon Society (TAS) and the Pima County Regional Flood Control 

District (PCRFCD).

At this time, onsite mitigation is not being evaluated due to the development of an open pit copper mine 

precluding most areas from serving as potential mitigation. Design of the Rosemont Project has 

incorporated stormwater drainage channels and retention basins that will replicate some of the functions 

of waters lost on site (e.g. hydrology, aquifer recharge, storm flows). These designed channels and basins

are not being proposed for a compensatory mitigation credit due to the incompatibility of the typical site 

protection instrument with the need to maintain the channels and basins to serve environmental protection 

requirements.

Absent mitigation banking, ILF mitigation, a watershed plan approach, or onsite mitigation opportunities, 

or in the event that these approaches do not fully meet the compensatory mitigation obligations for the 

Rosemont Project, then offsite in-kind and out-of-kind permittee-responsible compensatory mitigation 

may be used to compensate for unavoidable impacts to potential waters of the U.S. The Pantano Dam and 

Sonoita Creek Ranch projects (see below) provide ILF and/or offsite permittee-responsible mitigation 

opportunities.

MITIGATION SUMMARY

To identify suitable offsite compensatory mitigation opportunities, Rosemont undertook a review of 

available sites with particular emphasis on sites within the watershed that could support restoration, 

enhancement or establishment opportunities. Preservation opportunities were also evaluated for CWA 

mitigation purposes to the extent that they either were associated with restoration, enhancement or 

establishment opportunities or otherwise provided important physical, chemical or biological functions 

for the watershed and would contribute to the ecological sustainability of the watershed. 33 C.F.R. 

§332.3(h). The Project is located in the Middle Gila (HUC-4), the Santa Cruz watershed (HUC-6) and the 

Upper Santa Cruz (HUC-8) and Pantano-Rillito (HUC-8) watersheds. Rosemont’s search for suitable 

compensatory mitigation sites focused on these watersheds.

Rosemont has worked closely with the Corps to identify compensatory mitigation opportunities for the 

Project (Figure 1). This mitigation concept assumes that an ILF project will be available and that 

mitigation credits will be available for purchase by Rosemont. However, in the event that such an ILF 

project cannot be established, or is not able to provide the entirety of the required compensatory 

mitigation, this mitigation concept includes a contingency for meeting the mitigation obligations of the 

Rosemont Project through a permittee-responsible mitigation approach (see below).

The HMMP, when completed, will become part of the permit for the Project. A summary of the proposed 

mitigation elements is described below.

Pantano Dam

Rosemont has acquired the right to purchase approximately 1,122 acre-feet per annum (AFA) of surface 

water rights in Cienega Creek within the Pantano-Rillito watershed, along with an approximately 2-acre 

parcel which includes the Pantano Dam as well as lands up- and downstream of the dam. This parcel 
September 2013 Page 3 of 4

includes open water and riparian vegetation associated with the pooling of water behind the dam. In 

addition to the water rights and private parcel, the purchase agreement includes a groundwater well near 

the dam.

Of the 1,122 AFA to be secured by Rosemont, approximately 150 AFA will be allocated to conservation 

and land management agencies in Upper Cienega Creek as in-stream flow rights to support conservation 

measures. Rosemont is not seeking CWA mitigation credit for these Upper Cienega Creek conservation 

measures. In addition, Rosemont will convey 146 AFA of water rights to PCRFCD (or similarly 

authorized entity) to restore and enhance the aquatic and riparian ecosystems in the Cienega Creek 

Natural Preserve (the Preserve).

The balance of the water right (826 AFA) will be allocated to a Corps-approved ILF sponsor for use in 

the development of an ILF project downstream of the Pantano Dam. It is anticipated that Rosemont will 

receive mitigation credits, to offset the indirect impacts to WUS from reduction in downstream 

stormwater flows, for the transfer of water rights (including the two-acre parcel and the groundwater 

well), as well as for the purchase of ILF credits from the ILF sponsor. The number of credits required to 

be purchased by Rosemont is still to be determined and will consider the final mitigation project the ILF 

sponsor proposes to implement. The total credits required for purchase will be based upon calculation of 

the mitigation ratio using the SPD Mitigation Ratio Checklist.

Sonoita Creek Ranch

In the event that an ILF project is not available for the Rosemont Project, or available mitigation credit 

from an ILF is not adequate to compensate for the impacts resulting from the Project, Sonoita Creek 

Ranch (SCR) affords an additional mitigation opportunity in the Upper Santa Cruz River watershed. SCR 

is an approximately 1,200-acre ranch located in and around the historic channel and floodplain of Sonoita 

Creek, a major tributary of the Santa Cruz River, approximately six miles south of Sonoita, Arizona and 

two miles north of Patagonia, Arizona in Santa Cruz County (Figure 1). Approximately 590 AFA of 

water rights are appurtenant to the ranch. The water is supplied to the ranch by Monkey Spring, a natural 

spring less than a mile north of the SCR property on an adjacent privately-owned property. Most of the 

590 acre-feet of certificated water right appurtenant to the ranch is currently used to seasonally irrigate 

over 110 acres of agriculture fields. The foothills of the Canelo Hills are present in the eastern portion of 

the ranch, and the eastern boundary of the property shares a boundary with the CNF.

The SCR property includes nearly six acres of open water and wetland in two large ponds, which are 

currently managed for storage associated with agricultural irrigation. Habitat in and associated with the 

ponds includes emergent and forested wetland and riparian components, which are all supported by 

perennial flows from Monkey Spring. The ponds are connected by a small earthen-lined channel 

conveying overflow water from the northern pond to the southern pond. Irrigation water for the 

agricultural activities is provided from overflow from the southern pond. This system is not subject to 

flood flows in Sonoita Creek.

Nearly three miles of Sonoita Creek and over a mile of Corral Canyon are included within the boundaries 

of the ranch. Both areas are characterized by mature riparian vegetation, with some reaches of each
September 2013 Page 4 of 4

buffered by wide floodplains of dense native grassland. Sonoita Creek Ranch provides approximately six 

acres of emergent wetland, 14 acres of other potential waters of the U.S., 337 acres of associated riparian 

habitat, and 721 acres of semi-desert grassland and Madrean evergreen woodland upland buffer habitat. 

Under this conceptual mitigation plan, Rosemont will purchase the 1,200-acre Sonoita Creek Ranch and 

the estimated 590 ac-ft per annum of certificated water rights, and record a site protection instrument. The 

site protection instrument would preclude real estate development and similar land use activities, as well 

as livestock grazing and other agricultural uses. Because of the heavily grazed nature of the property, 

exclusion of grazing and recordation of a site protection instrument will result in enhancement of the 

1,200 acres of wetland, riparian. and upland buffer habitat within the property (Figure 2). The two 

existing ponds on site will be enhanced for management of threatened and endangered aquatic species.

In addition, Rosemont would utilize the existing infrastructure and the naturally occurring water from 

Monkey Spring (that currently irrigates the agricultural fields) to create riparian and/or wetland habitat 

within the 115-acre fields. The volume of water provided by Monkey Spring, the established irrigation 

infrastructure, and the acreage of the active agricultural fields afford considerable opportunity for the 

development of aquatic habitat within the floodplain of Sonoita Creek at SCR. There may be the 

opportunity to conduct restoration activities to Sonoita Creek but this will require further investigation.

Mulberry Canyon Parcel

The Mulberry Canyon Parcel is a 160-acre parcel located northeast of the Project (Figure 1). The parcel 

is bordered on the west and south by the Coronado National Forest, and on the north and east by State 

Trust lands managed by the Arizona State Land Department.

In the event that mitigation credits beyond those described above are required for the Rosemont Project, 

additional mitigation may be provided by preservation of the potential waters of the U.S. and associated 

riparian habitat within the Mulberry Parcel. Under this plan, Rosemont would record a site protection 

instrument prohibiting certain land uses on the parcel.
Tucson

§ ̈¦10

Santa

Cruz River

Green Valley

¬«86

Santa Rita 

Mountains

Patagonia

Mountains

Rincon

Mountains

Sierrita

Mountains

Tumacori

Mountains

Rio Rico

Sonoita Creek

Tubac

¬«82

¬«82

Patagonia

Sonoita

¬«83

¬«83

§ ̈¦19

Pima County & Santa Cruz County, Arizona

ESRI World Imagery - November 8, 2010

± Legend

Mitigation Parcel

Rosemont Project

Sonoita Creek Ranch

Rosemont Project

ROSEMONT PROJECT

MITIGATION LANDS

Figure 1

Draft Habitat Mitigation 

and Monitoring Plan Summary 

PERMIT NO. SPL-2008-00816-MB

0 3 6

Miles

Mulberry Canyon

Parcel

Pantano Dam
T21S, R16E, Portion of Sections 9, 16, 2, 21 & 29, 

Santa Cruz County, Arizona,

Mount Hughes USGS 7.5' Quadrangle

Photo Source: Microsoft, November 2010

±

0 1,000 2,000

Feet

ROSEMONT PROJECT

PERMIT NO. SPL-2008-00816-MB

PERMITTEE-RESPONSIBLE PHASE I

SONOITA CREEK RANCH

Figure 2

Draft Habitat Mitigation 

and Monitoring Plan Summary

F

F

F

F

F

F

F

F

F

F Monkey Spring Overflow

Legend

Sonoita Creek Ranch

Waters of the US (Enhancement)

Riparian Buffer (Enhancement)

Upland Buffer (Enhancement)
C. Visual Simulations 

The visual simulations are provided on a compact disc (CD) included with this document.

Final Environmental Impact Statement for the Rosemont Copper Project C-1

D. Memorandum of Agreement

(prepared under Section 106 of the 

National Historic Preservation Act)

Final Environmental Impact Statement for the Rosemont Copper Project D-1

MEMORANDUM OF AGREEMENT

Among the Coronado National Forest, Arizona State Historic Preservation 

Officer, Advisory Council on Historic Preservation, U.S. Army Corps of 

Engineers, And The Rosemont Copper Company, Regarding Resolution of 

Adverse Effects on Historic Properties from The Rosemont Copper Project

WHEREAS, the Rosemont Copper Company (Rosemont) proposes to construct and operate a 

mine to extract locatable minerals, including copper, molybdenum, and silver (Project) pursuant to 

the General Mining Law of 1872, as amended (30 U.S.C. §§ 22–47 [2006]), and has submitted a 

proposed mine plan of operations (MPO) to the Coronado National Forest (Forest), subject to Forest 

approval with appropriate environmental conditions included in a final MPO under 36 CFR § 228.5; 

and 

WHEREAS, the Project consists of the construction, operation, and reclamation of the 

Rosemont Copper Project and associated infrastructure and ancillary facilities, including a water 

pipeline, a138-kilovolt transmission line with an associated maintenance road, relocation of an 

electric distribution line, commissioning and decommissioning of Forest roads, and relocation of a 

portion of the Arizona National Scenic Trail (Arizona Trail); and 

WHEREAS, the Project will be situated on 995 acres of private land owned by Rosemont, 

3,670 acres of land managed by the Forest, and 75 acres of State land managed by the Arizona State 

Land Department (ASLD); and

WHEREAS, Tucson Electric Power Company will supply electrical power to the Project via 

a 138-kilovolt transmission line pursuant to a Certificate of Environmental Compatibility (CEC) from 

the Arizona Corporation Commission (ACC), which was granted on June 12, 2012, by order of the 

ACC following the ACC’s public notice and hearing process; and Rosemont will construct a water 

pipeline to the mine, and both the transmission line and water pipeline will be co-located within a 

utility corridor, and are subject to Arizona laws, and will require rights-of-way from the ASLD; and 

WHEREAS, the U.S. Department of Agriculture Forest Service serves as the lead Federal 

agency for compliance with the National Environmental Policy Act (NEPA) (42 U.S.C. §§ 4321–

4347), the Native American Graves Protection and Repatriation Act (NAGPRA) (25 U.S.C. § 3001), 

and the National Historic Preservation Act (NHPA) as amended (16 U.S.C. § 470f) for the Project; 

and the Forest has considered several Project alternatives in the Environmental Impact Statement for 

the Rosemont Copper Project (EIS); and

WHEREAS, the U.S. Army Corps of Engineers (COE), a Federal cooperating agency in 

preparing the EIS, with authority to issue permits under Section 404 of the Clean Water Act for 

various aspects of the Project, has designated the Forest as the lead agency under 36 CFR § 

800.2(a)(2) to act on its behalf to fulfill its responsibilities under Section 106 and is a signatory to the 

MOA; and 

WHEREAS, the Forest has consulted with the Arizona State Historic Preservation Office 

(SHPO) in its role of advising and assisting Federal agencies in carrying out their responsibilities 

under Sections 101 and 106 of the NHPA; and pursuant to 36 CFR Part 800, regulations 

implementing Section 106, at §§ 800.2 (c) (l) (i) and 800.6 (b); and in accordance with the First 

Final Environmental Impact Statement for the Rosemont Copper Project D-3
D. Memorandum of Agreement 

Amended Programmatic Agreement Regarding Historic Property Protection and Responsibilities 

Among New Mexico State Historic Preservation Officer and Arizona State Historic Preservation 

Officer and Texas State Historic Preservation Officer and Oklahoma State Historic Preservation 

Officer and the Advisory Council on Historic Preservation and United States Department of 

Agriculture Forest Service Region 3, dated December 24, 2003 (Region 3 Programmatic Agreement), 

and the SHPO is a signatory to this Memorandum of Agreement (MOA) under 36 CFR § 800.6(c)(1); 

and

WHEREAS, the Forest, in consultation with the SHPO, as required by 36 CFR § 800.4(a)(1), 

has defined the Project’s Area of Potential Effects (APE) to include the area enclosed within the mine 

perimeter fence, the associated access roads, the re-route of the Arizona Trail, the associated utilities 

corridor, and the area in which historic properties may be visually, audibly, and atmospherically 

affected by the undertaking (see Exhibit A); and 

WHEREAS, under 36 CFR § 800.4(b), the Forest has consulted with SHPO and has 

identified historic properties within the APE through public scoping, archival research, oral history, 

and archaeological surveys, as described in the following reports (for full citations, see Exhibit E): 

Archaeological Survey of Approximately 67.1 Acres in the Coronado National Forest, Pima County, 

Arizona (Petersen 2007); Results of an Archaeological Class I Inventory of Four Alternatives for the 

Proposed Rosemont Copper Mine, Rosemont Junction, Pima County, Arizona (Petersen and Griset 

2010); Archaeological Survey of Alternatives to the Proposed Rosemont Copper Mine, Pima County, 

Arizona (Barr et al. 2010); A Cultural Resources Inventory of Approximately 3.3 Acres Near Santa 

Rita Road and South Country Club Road, East of Sahuarita, Pima County, Arizona (Martin 2011); 

Archaeological Survey for the Proposed Rosemont Copper Mine, Pima County, Arizona: Final 

Report (Ezzo et al. 2011); A Cultural Resources Inventory of Approximately 84 Acres Near Sahuarita, 

Pima County, Arizona (Chamorro 2011); An Ethnohistory of the Rosemont Copper Project Area in the 

Eastern Santa Rita Mountains, Pima County, Arizona (Griset 2011); A Revised Cultural Resources 

Inventory of Approximately 84 Acres Near Sahuarita, Pima County, Arizona (Chamorro and King 

2012); A Cultural Resource Survey of the 46kV Alternative and Additional Areas for the Rosemont 

Project 138kV Line (Swanson et al. 2012); A Cultural Resources Inventory of Two Contiguous 

Arizona Department of Transportation Encroachment Permit Areas Along State Route 83 for 

Rosemont Copper, Pima County, Arizona (Lindley and Buckles 2012); National Register of Historic 

Places Registration Form: Ce:wi Duag (“Long Mountain” in O’odham) (Griset, Gillespie, and 

Farrell 2012); A Cultural Resource Survey for the Rosemont Project Utility Corridor (Sheehan et al 

2013); A Cultural Resource Survey of Additional Areas for the Rosemont Project Utility Corridor, 

Pima County, Arizona (Rayle 2013); Rosemont Copper: A Cultural Resources Inventory Within and 

Around Helvetia, Pima County, Arizona (Deaver 2013); and 

WHEREAS, under 36 CFR § 800.4(c), the Forest evaluated all identified cultural resources 

within the APE for their eligibility under 36 CFR Part 63 for the National Register of Historic Places, 

and, as required by 36 CFR § 800.5(a), in consultation with the SHPO, consulting Indian Tribes 

(Tribes), and other consulting parties, has applied the criteria of adverse effect to historic properties 

within the APE and has determined that the Project will have an adverse effect on multiple historic 

properties within the APE; and 

WHEREAS, the Forest has notified the Advisory Council on Historic Preservation (ACHP) 

of the Project’s adverse effects on historic properties, in accordance with 36 CFR § 800.6(a)(1), and 

the ACHP has chosen to participate in the consultation under 36 CFR § 800.6(a)(1)(iii) and to be a 

signatory to the MOA; and

D-4 Final Environmental Impact Statement for the Rosemont Copper Project
D. Memorandum of Agreement

WHEREAS, Rosemont is entitled to participate in the Section 106 consultation process under 

36 CFR § 800.2(c)(4) and in the development of this MOA, per 36 CFR § 800.6(a)(2), because of its 

obligations and duties to implement the mitigation measures required by the MOA, has been invited 

by the Forest to be a signatory to this MOA under 36 CFR § 800.6(c)(2)(iii); and 

WHEREAS, the Forest has gone through a consultation process to identify, notify, and seek 

consultation with federally recognized Tribes that have religious or cultural ties to the Project area, or 

whose direct ancestors had historic or pre-historic religious and cultural ties to historic properties that 

may be affected by the undertaking; and 

WHEREAS, under 36 CFR § 800.2(c)(2)(ii), the Forest has engaged in or has made a good 

faith effort to engage in government-to-government consultation with the Ak-Chin Indian 

Community, Fort Sill Apache Tribe, Gila River Indian Community, Hopi Tribe, Mescalero Apache 

Tribe, Pascua Yaqui Tribe, Pueblo of Zuni, Salt River Pima-Maricopa Indian Community, San Carlos 

Apache Tribe, Tohono O’odham Nation, White Mountain Apache Tribe, and Yavapai Apache Nation 

and has invited the Tribes to participate in the identification and evaluation of historic properties, 

including traditional cultural properties (TCPs), to provide information about past and ongoing uses 

of the area by Native Americans, to assess the effects the undertaking will have on historic properties, 

and to discuss ways in which to avoid and mitigate effects on historic properties; and 

WHEREAS, the Tribes have apprised the Forest, SHPO, and other consulting parties of their 

opposition to the Project, and the legislative councils of the Tohono O’odham Nation, Salt River 

Pima-Maricopa Indian Community, Pascua Yaqui Tribe, and San Xavier District of the Tohono 

O’odham Nation have set forth resolutions in opposition to the Project because the Project would 

significantly impact, destroy, or alter cultural and archaeological sites containing cultural resources 

and sacred objects of the O’odham, and would permanently and negatively alter the cultural and 

natural landscapes of the area, and would cause adverse effects on TCPs, including Ce:wi Duag, 

which is of particular cultural and religious significance to the Tribes; and

WHEREAS, many Tribes have apprised the Forest, SHPO, and other consulting parties that 

they oppose implementation of the Project until after all presumed litigation on this Project is 

resolved in order to prevent unnecessary permanent and direct effects to historic properties; and, 

WHEREAS, despite their opposition to the Project and strong beliefs that the effects of this 

Project cannot be mitigated, many Tribes have participated in the development of this MOA and the 

Forest has invited them to be concurring parties to this MOA under 36 CFR § 800.6(c)(3); and

WHEREAS, Pima County has apprised the Forest, SHPO, Tribes, and other consulting 

parties of its opposition to the Project, and the Board of Supervisors has set forth a resolution, BOS 

Resolution 2007-15, January 16, 2007, in opposition to the Project.

WHEREAS, the Forest has consulted with the ASLD, Tribes, and other consulting parties 

regarding the potential effects the Project may have on historic properties within the utility corridor 

on State lands under its jurisdiction; and the ASLD is responsible for ensuring that adverse effects to 

historic properties on State lands are appropriately addressed in accordance with its legal obligations 

under State law (A.R.S. § 41-861 et seq.); and the Forest has invited ASLD to be a concurring party 

to this MOA; and

WHEREAS, the ASLD has the authority and responsibility to approve activities related to the 

undertaking on State lands in fulfillment of the terms of the ACC’s order; 

Final Environmental Impact Statement for the Rosemont Copper Project D-5
D. Memorandum of Agreement 

WHEREAS, the Forest has consulted with the Arizona State Museum (ASM), which is 

responsible for issuing permits for archaeological data recovery on State land per A.R.S. § 41-841 

et seq., the Arizona Antiquities Act, and for coordinating responses to the discoveries of human 

remains, funerary objects, sacred ceremonial objects, and objects of national or tribal patrimony on 

State and private land under A.R.S. §§ 41-844 and 41-865, and the Forest has invited the ASM to be a 

concurring party to this MOA; and

WHEREAS, the Forest has consulted with Pima County and the Town of Sahuarita as part of 

the Section 106 process, and each has been invited to be a concurring party to this MOA; and

WHEREAS, the Forest has made diligent efforts to involve the public, property owners, and 

other interested parties early in the Federal decision-making process by notifying them of the Project 

and its impacts through the NEPA process and providing them with information on the Project and 

opportunities to comment on the preparation of the EIS, including at several public meetings, as 

required by the Council on Environmental Quality’s regulations implementing NEPA (40 CFR § 

1506.6), the NHPA’s implementing regulations (36 CFR §§ 800.2(d); 800.6(1)(4)), and the Region 3 

Programmatic Agreement; and 

WHEREAS, per 36 CFR § 228.13, Rosemont is required to post a bond to ensure reclamation 

of surface disturbance to prevent or control damage to forest surface resources, per 36 CFR § 

228.8(g); and

WHEREAS, for purposes of this MOA, all terms are used in accordance with 36 CFR 

§ 800.16, 36 CFR § 79.4, and the Region 3 Programmatic Agreement; 

NOW, THEREFORE, the Forest, SHPO, ACHP, COE (collectively, Signatories), and 

Rosemont or Invited Signatory agree that the Project will be implemented in accordance with the 

following stipulations to take into account the effect of the undertaking on historic properties.

STIPULATIONS

The Forest, and COE, as applicable shall ensure that the following measures are carried out:

I. PROFESSIONAL QUALIFICATIONS

All historic preservation work carried out under the terms of this MOA and under its jurisdiction will 

be overseen by an individual who meets either the Secretary of Interior’s Standards and Guidelines 

for Archaeological and Historic Preservation (48 Federal Register 44,716–44,742, September 23, 

1983) or the qualification requirements in the Region 3 Programmatic Agreement, and takes into 

consideration the National Park Service’s applicable guidance. 

II. FEDERAL HISTORIC PROPERTIES TREATMENT PLAN (FEDERAL HPTP)

A. The Forest shall continue to consult with the consulting parties to finalize, approve, and 

implement the Federal HPTP (Exhibit B) for historic properties adversely affected on federal 

and private lands within the APE. The Federal HPTP describes all historic properties within 

the APE for all alternatives, other than those properties located on State lands, and those 

effects. The Federal HPTP will detail treatments to avoid, minimize, or mitigate adverse 

effects to historic properties caused by the alternative selected by the Forest in its Record of 

Decision (ROD). The Federal HPTP shall comprise:

D-6 Final Environmental Impact Statement for the Rosemont Copper Project
D. Memorandum of Agreement

1. A Data Recovery Plan for those historic properties eligible for their archaeological 

information potential and that cannot be avoided, which will include:

a) the research design encompassing the entire Project including the utility corridor and 

data requirements needed to address the research questions; 

b) the methods and techniques to be used for archival research, field investigations, 

collections processing, curation, data analysis, and reporting; 

c) the means for conveying the public benefit of the mitigation; and 

d) a Project Suspension/Termination Plan that stipulates the procedures to be followed 

if the Project is halted during data recovery for any reason. 

2. A Plan for the Treatment of Human Remains, Funerary Objects, Sacred Objects, and Objects 

of Cultural Patrimony (Burial Plan). The Burial Plan sets forth the procedures for 

identifying, treating, and transferring custody of human remains, funerary objects, and 

sacred objects discovered during Data Recovery or Project work on Federal or private land 

within the APE. The Burial Plan incorporates the provisions of both a Plan of Action 

prepared under NAGPRA, which applies to Federal land, and a burial agreement prepared 

under Arizona statute, which applies to private land; 

3. A Discovery Plan with the procedures for inadvertent discoveries of cultural resources

and/or human remains after data recovery investigations have been completed which will 

require Rosemont to notify the Forest of any such discoveries during the construction or 

operation of the mine and the ASM for discoveries on State and private land;

4. A Monitoring Plan that describes monitoring training and monitoring procedures (both short 

and long term) and which identifies historic properties to be avoided and sensitive sites with 

the potential for human remains; and 

5. Treatments to mitigate impacts to the Ce:wi Duag TCP (see below).

B. The draft Federal HPTP will be revised after the Draft ROD is issued and an alternative 

selected. Only conforming changes to account for final project design and to present 

measures taken to avoid, reduce, or mitigate effects to historic properties subject to effects 

from the selected alternative will be made. The revised Federal HPTP may also include 

proposed staged data recovery schedule that coincides with phased development of the 

Project.

C. Within thirty (30) calendar days of the issuance of the Draft ROD, the Forest will provide 

consulting parties an opportunity to review the Federal HPTP, as revised, to ensure 

consistency of conforming changes such as opportunities for site avoidance rather than data 

recovery in the selected alternative. The consulting parties will have thirty (30) calendar days 

from receipt to provide comments to the Forest on the Federal HPTP. The Forest shall 

consider the comments from these parties, address them in the final Federal HPTP, and 

provide a response these parties explaining why certain comments may not be addressed prior 

to approval of the final Federal HPTP by the Forest. The Forest shall provide all consulting 

parties with the final Federal HPTP. 

D. The Forest shall ensure that the mitigation measures in the approved Federal HPTP are 

implemented. Mitigation measures in the Federal HPTP may begin to be implemented upon 

the Forest’s approval of the final MPO and the issuance of any necessary ARPA permits by 

the Forest and Clean Water Act Section 404 permit by COE. Mitigation treatments in the 

Final Environmental Impact Statement for the Rosemont Copper Project D-7
D. Memorandum of Agreement 

Federal HPTP involving data recovery must be completed prior to the commencement of 

ground-disturbing activities within the affected historic property.

E. Forest’s approval of the final MPO is contingent upon Rosemont’s acceptance and Forest 

approval of the final Federal HPTP.

F. The Forest will distribute preliminary data recovery reports, including recommendations for 

further data recovery at sites, if appropriate, to SHPO and consulting parties for expedited 

(within 15-days) review and comment. Comprehensive, draft data recovery reports for the 

Federal HPTP will be distributed to consulting parties. The consulting parties will have thirty 

(30) days from receipt to provide comments to the Forest on the comprehensive, draft data 

recovery reports. The Forest shall consider the comments from these parties, address them in 

the final data recovery reports, and provide a response to these parties explaining why certain 

comments may not be addressed prior to approval of the final data recovery reports by the 

Forest. The Forest shall provide all consulting parties with the final data discovery reports.

III. BEST MANAGEMENT PRACTICES FOR ADVERSE EFFECTS

Rosemont will:

A. Comply with the conditions and mitigation measures set forth in this MOA and implement 

the Federal HPTP and the Utilities HPTP, including on Rosemont-owned lands, and report 

this compliance to the Forest. 

B. Ensure that driving occurs only on existing roads or roads constructed with approval of the 

Forest, and that any ground-disturbing activity between the boundary fence and the security 

fence will be authorized by the final MPO or by approval of the Forest if not included in the 

final MPO, and will follow the procedures specified in the Federal HPTP, or as required in 

emergency situations. 

C. Coordinate with Tohono O’odham Nation, Mescalero Apache Tribe, Salt River PimaMaricopa Indian Community, and the Forest to develop and implement a cultural sensitivity 

training program and archaeological monitor training program.

D. Ensure that, as appropriate, Project personnel, including employees and contractors, engaged 

in ground-disturbing activities, will receive cultural-sensitivity training and ongoing training 

on site protection measures, including information on the statutes and regulations protecting 

cultural resources. 

E. Assist the Forest and COE in the implementation of the Federal and Utilities HPTPs by 

funding, coordinating, or conducting either directly or through the use of qualified 

consultants, the treatment measures specified in the Federal and Utilities HPTPs.

F. Ensure any information regarding the invitation or execution of a ceremony associated with 

the Project is not publicized. 

IV. TREATMENT AND VOLUNTARY MEASURES FOR ADVERSE EFFECTS TO 

CE:WI DUAG TCP (EXHIBIT B, CHAPTER 6)

A. Plant Resources 

D-8 Final Environmental Impact Statement for the Rosemont Copper Project
D. Memorandum of Agreement

1. On Forest lands, opportunities to collect plants for traditional, medicinal, and ceremonial 

uses will continue with requests for collection coordinated by the Forest Archaeologist.

Requests for collection will also be coordinated with Rosemont to ensure that proper health 

and safety requirements are met.

2. Rosemont will schedule a week during which tribal representatives can visit the mine area 

before construction to collect specimens of agave, sotol, yucca, beargrass, coral bean, and 

medicinal plants. All tribal representatives will undergo necessary safety training before 

entering the APE, and access will be coordinated with Rosemont. Prior to the removal of 

any plants, Tribes may perform ceremonies. 

3. Where appropriate, Rosemont will incorporate culturally important plants in Rosemont’s 

reclamation seed mixture. Species selected for the revegetation mix will be those that can be 

successfully propagated by seed and for which seeds are readily available in quantity.

4. Rosemont will permit collection of plants on conservation lands to the extent allowable 

under conservation requirements. Rosemont will coordinate access to the conservation lands 

by tribal representatives and may require a five (5) day notice of request for access. 

B. Animal Resources

To the extent allowable under conservation requirements, the conservation lands set aside for the 

COE Clean Water Act, Section 404 Permit for the Project will be available to Tribal representatives 

for hunting, providing that the licenses and tags from Arizona Game and Fish Department have been 

obtained for large and small game. Other U.S. Department of Agriculture, National Forest system 

lands and State lands are available for hunting.

C. Springs and Mineral Resources

1. As part of the week-long visit by Tribal representatives to be facilitated by Rosemont before 

land disturbance begins, there will be an opportunity for Tribal representatives to conduct 

blessing ceremonies at the springs and to collect mineral resources associated with them and 

other areas within the APE.

2. Access to Forest lands within the perimeter fence for medicinal, ceremonial, and traditional 

uses will be coordinated by the Forest Archaeologist in compliance with US Department of 

Agriculture, Forest Service regulations and policy and with Rosemont to ensure compliance 

with health and safety requirements.

D. Cultural Landscape

1. Rosemont will provide access to the conservation lands by tribal representatives for 

ceremonial purposes and may require five (5) days advance request.

2. No later than the end of the third production year, Rosemont will create an exhibit at the 

Rosemont Public Visitor Center that describes the 7,000 years of occupation in the project 

area, the importance of Ce:wi Duag, and the new knowledge gained as a result of the data 

recovery conducted for the Project. 

3. Concurrently with Item 2 above, Rosemont will use the information developed for the 

exhibit to create public brochures that will be accessible online via Rosemont and the Forest 

websites. 

4. Any interpretive exhibit, brochure, or other production that presents material about Ce:wi 

Duag or the Native American occupation and use of the area will be made in consultation 

with the Tribes. 

Final Environmental Impact Statement for the Rosemont Copper Project D-9
D. Memorandum of Agreement 

V. UTILITIES HISTORIC PROPERTIES TREATMENT PLAN (UTILITIES HPTP)

A. The Utilities HPTP (Exhibit C) will describe all historic properties within the APE on State, 

private, and Federal land within the utility corridor and the nature of those effects and 

prescribes treatments to avoid, minimize, or mitigate those effects. The Utilities HPTP 

contains a Data Recovery Strategy, procedures for treating human remains, a discovery plan 

for inadvertent discoveries, and a monitoring plan.

B. The draft Utilities HPTP will be revised after the Forest’s Draft ROD is issued and an 

alternative selected. Amendments to the Utilities HPTP will be consistent with the version 

made available at the time the MOA is signed. Only conforming changes to account for final 

project design and to present measures taken to avoid, reduce, or mitigate effects to historic 

properties subject to effects from the selected alternative will be made.

C. Within thirty (30) calendar days of the issuance of the Forest’s Draft ROD, the Forest will 

provide consulting parties an opportunity to review the Utilities HPTP, as revised, to ensure 

consistency of conforming changes, such as opportunities for site avoidance rather than data 

recovery in the selected alternative. The consulting parties will have thirty (30) calendar days 

from receipt to provide comments to the Forest on the Utilities HPTP. The Forest shall 

consider comments from these parties and approve the final Utilities HPTP, but only after 

ASLD, ASM, and SHPO concur that State law requirements and the conditions of the ACC’s 

Certificate of Environmental Compatibility have been fulfilled. The Forest shall provide all 

consulting parties with the final Utilities HPTP.

D. The Forest shall ensure the treatment measures in the approved Utilities HPTP on Federal and 

private lands are implemented. The COE shall ensure the treatment measures in the approved 

Utilities HPTP on State land within its permit area are implemented. The ASLD retains 

responsibility for ensuring compliance with the Utilities HPTP for historic properties located 

on State lands outside the COE’s permit area. Mitigation measures in the Utilities HPTP may 

begin to be implemented upon the Forest’s approval of the final MPO, and after the COE 

issues its Section 404 Permit and the ASLD issues its right-of-way.

E. The Forest will distribute preliminary data recovery reports, including recommendations for 

further data recovery at sites, to SHPO, ASM, and other consulting parties for expedited 

(within 15days) review and comment. Comprehensive, draft data recovery reports for the 

Utilities HPTP will be distributed to consulting parties. The consulting parties will have thirty 

(30) calendar days from receipt to provide comments to the Forest on the comprehensive, 

draft data recovery reports. The Forest shall consider the comments from these parties, 

address them in the final data recovery reports, and provide a response these parties 

explaining why certain comments may not be addressed prior to approval of the final data 

recovery reports by the Forest. The Forest shall provide all consulting parties with the final 

data recovery reports. 

VI. CURATION 

Collections made during the course of the implementation of the Federal HPTP, including material 

remains collected during data recovery and associated records, will be curated in accordance with the 

provisions of the permits issued by the Forest under the ARPA and by the ASM under the Arizona 

Antiquities Act. Collections will be curated at a repository meeting the standards of 36 CFR § 79, 

“Curation of Federally-Owned and Administered Archaeological Collections” and ASM standards, 

D-10 Final Environmental Impact Statement for the Rosemont Copper Project
D. Memorandum of Agreement

with preference given to a tribal curation facility meeting those standards. Rosemont will fund such 

curation of collections.

VII. SYNTHESIS REPORT 

Within one year of the completion of all data recovery reports required in the final Federal HPTP and 

final Utilities HPTP, Rosemont will submit a draft synthesis report to the Forest. The synthesis report 

shall integrate the results of data recovery for both the Federal and Utilities HPTPs, presenting 

summaries of the results of excavations and analyses of artifacts and other materials. The report will 

discuss how the results of data recovery addressed the expectations of the research design and how 

the results contribute to our knowledge of prehistoric and historic life ways and land use. The Forest 

shall provide the draft synthesis report to the consulting parties who may provide comments within 

sixty (60) calendar days of receipt. The Forest shall consider the comments from these parties, 

address them in the final report, and provide a response these parties explaining why certain 

comments may not be addressed prior to Forest’s approval of the final report. The Forest shall 

provide all consulting parties with the final report.

VIII. REPORTING

Each calendar year following the execution of this MOA, within ninety (90) calendar days of the 

anniversary date of signing, the Forest will provide all consulting parties a summary report detailing 

work undertaken pursuant to its terms. Such report will convey a summary of work conducted in 

accordance with the Federal and Utilities HPTPs, proposed scheduling changes, and problems 

encountered and proposed resolutions. The Forest will invite consulting parties to an annual meeting 

to discuss the annual report and the implementation of the MOA and Federal and Utilities HPTPs in 

general. 

IX. CONFIDENTIALITY

To the extent allowed by Federal and State law, information on the location and nature of all cultural 

resources and traditional cultural information shall be held confidential as provided by Section 304 of

the NHPA (16 U.S.C. § 470w-3); 36 CFR § 800.11(c), Section 9 of the ARPA (16 U.S.C. § 470hh; 43 

CFR § 7.3), Region 3 Programmatic Agreement with SHPO, as amended, and other applicable 

Federal laws, and by A.R.S. § 39-125.

X. TERM OF AGREEMENT

This MOA will be effective on the date of the final signature of the Signatories and will continue in 

effect for the duration of the final MPO unless it is terminated earlier in accordance with Article XI 

below. Per 36 CFR § 800.6(c)(2)(iv), the refusal of any party invited to become a signatory will not 

invalidate this MOA.

XI. POINTS OF CONTACT

A. The points of contact designated to speak for the Signatories, Invited Signatory, and 

concurring parties and to make notifications, requests, reports, or other contacts for or to the 

Signatories, Invited Signatory, or concurring parties are listed in Exhibit D.

B. Any Signatory, Invited Signatory, or concurring party may add to or change its designated 

point(s) of contact by providing written notice of the addition or change to any Forest point 

Final Environmental Impact Statement for the Rosemont Copper Project D-11
D. Memorandum of Agreement 

of contact listed in Exhibit D. The written notice must come from either (a) an authorized 

point of contact for the relevant party listed in Exhibit D; (b) the chief executive or governing 

body of the respective Signatory, Invited Signatory, or concurring party; or (c) a person 

designated in writing by such governing body to speak on its behalf.

C. The Forest will notify Signatories, Invited Signatory, and concurring parties whenever a point 

of contact is added or changed as provided herein.

XII. TRANSFER OF PERMITS TO SUCCESSOR

Any transfer or assignment of the final MPO for the Project to another party will require the assignee 

or successor to assume all responsibilities of Rosemont under this MOA for mitigation of adverse 

effects, and any successor or assign of Rosemont is bound to the terms of this MOA. Any transfer or 

assignment of the permits for the Project to another party will require the assignee or successor to 

sign an amendment to this MOA to become an invited signatory at the time of transfer or assignment. 

All consulting parties will be notified if an amendment to reassign the duties of Rosemont is 

proposed. 

XIII. AMENDMENTS

Any Signatory or Invited Signatory may request an amendment to the terms of this MOA. This MOA 

may be amended when such an amendment is agreed to in writing by all Signatories and Invited 

Signatory. The amendment will be effective on the date a copy signed by all of the Signatories is filed 

with the ACHP. Copies of all amendments will be sent to the consulting parties. 

XIV. DISPUTE RESOLUTION

Should any Signatory or Invited Signatory to this MOA object at any time to any actions proposed or 

the manner in which the terms of this MOA are implemented, the Forest shall consult with such party 

to resolve the objection. If the Forest determines that such objection cannot be resolved, it will:

A. Forward all documentation relevant to the dispute, including the Forest’s proposed resolution, 

to the ACHP. The ACHP shall provide the Forest with its advice on the resolution of the 

objection within thirty (30) calendar days of receiving adequate documentation. Prior to 

reaching a final decision on the dispute, the Forest shall prepare a written response that takes 

into account any timely advice or comments regarding the dispute from the ACHP, 

Signatories, and Invited Signatories and provide them with a copy of this written response.

The Forest will then proceed according to its final decision.

B. If the ACHP does not provide its advice regarding the dispute within the thirty (30) calendar 

day time period, the Forest may make a final decision on the dispute and proceed 

accordingly. Prior to reaching such a final decision, the Forest shall prepare a written 

response that takes into account any timely comments regarding the dispute from the 

Signatories and Invited Signatory to the MOA, and provide them and the ACHP with a copy 

of such written response.

C. It is the Forest’s responsibility to carry out all other actions subject to the terms of this MOA 

that are not the subject of the dispute remain unchanged.

D-12 Final Environmental Impact Statement for the Rosemont Copper Project
D. Memorandum of Agreement

D. If a consulting party objects to any actions proposed or the manner in which the terms of this 

MOA are implemented, they may inform any Signatory in writing and any Signatory may, at 

the Signatory’s discretion, choose to pursue the procedures outlined above. 

XV. TERMINATION

A. If any Signatory or Invited Signatory to this MOA determines that its terms will not or cannot 

be carried out, that party shall immediately consult with the Signatories and Invited Signatory 

to attempt to develop an amendment per Stipulation XIV, above. If within thirty (30) days (or 

another time period agreed to by all Signatories and Invited Signatory) an amendment cannot 

be reached, any Signatory may terminate the MOA upon written notification to the other 

Signatories and Invited Signatory.

B. Once the MOA is terminated, the Forest and COE must either (a) execute an MOA pursuant 

to 36 CFR § 800.6 or (b) request, take into account, and respond to the comments of the 

ACHP under 36 CFR § 800.7. The Forest and COE shall each notify the other Signatories 

and Invited Signatory as to the course of action it will pursue. If terminated, all actions by 

Rosemont will continue to be subject to the applicable requirements of other relevant laws 

such as the ARPA, NAGPRA, Clean Water Act, and applicable state laws. If the MOA is 

terminated, the Forest and COE will use available enforcement authorities to prevent or 

minimize adverse effects to historic properties until the reinitiated Section 106 process is 

completed. 

XVI. EXECUTION AND COMPLETION OF SECTION 106

Execution of this MOA by the Forest, COE, SHPO, ACHP, and subsequent implementation of its 

terms evidences that the Forest and COE have taken into account the effects of this undertaking on 

historic properties and afforded the ACHP an opportunity to comment and that the Forest and COE 

have satisfied their responsibilities under Section 106.

XVII. AUTHORIZING SIGNATURES

In witness hereof, the following authorized representatives of the parties have signed their names on 

the dates indicated, thereby executing this agreement. This MOA may be signed by the Signatories 

and Invited Signatory using photocopy, facsimile, or counterpart signature pages. The Forest will 

distribute copies of all signed pages to the Signatories, Invited Signatory, and concurring parties, once 

the MOA is executed.

Final Environmental Impact Statement for the Rosemont Copper Project D-13
D. Memorandum of Agreement 

SIGNATORIES:

ARIZONA STATE HISTORIC PRESERVATION OFFICER

James Garrison, Arizona State Historic Preservation Officer

ADVISORY COUNCIL ON HISTORIC PRESERVATION

__________________________________ Date

John M. Fowler, Executive Director

U.S. ARMY CORPS OF ENGINEERS, LOS ANGELES DISTRICT

INVITED SIGNATORY:

ROSEMONT COPPER COMPANY

Rod Pace, Chief Executive Officer

CONCURRING PARTIES:

AK-CHIN INDIAN COMMUNITY

__________________________________ Date

Louis J. Manuel, Jr., Chairperson

FORT SILL APACHE TRIBE

__________________________________ Date 

Jeff Houser, Chairperson

D-14 Final Environmental Impact Statement for the Rosemont Copper Project
D. Memorandum of Agreement

GILA RIVER INDIAN COMMUNITY

__________________________________ Date 

Gregory Mendoza, Governor

HOPI TRIBE

__________________________________ Date

LeRoy N. Shingoitewa, Chairman

MESCALERO APACHE TRIBE

__________________________________ Date 

Sandra Platero, President

PASCUA YAQUI TRIBE

__________________________________ Date

Peter Yucupicio, Chairman

PUEBLO OF ZUNI

__________________________________ Date 

Arlen Quetawki, Sr., Governor

SALT RIVER PIMA-MARICOPA INDIAN COMMUNITY

__________________________________ Date 

Diane Enos, President

SAN CARLOS APACHE TRIBE

__________________________________ Date 

Terry Rambler, Chairman

TOHONO O’ODHAM NATION

__________________________________ Date

Ned Norris, Jr., Chairman

Final Environmental Impact Statement for the Rosemont Copper Project D-15
D. Memorandum of Agreement 

WHITE MOUNTAIN APACHE TRIBE

__________________________________ Date 

Ronnie Lupe, Chairman

YAVAPAI-APACHE NATION

__________________________________ Date

David Kwail, Chairman

ARIZONA STATE LAND DEPARTMENT

ARIZONA STATE MUSEUM 

PIMA COUNTY

__________________________________ Date 

C. H. Huckleberry, County Administrator 

TOWN OF SAHUARITA

__________________________________ Date 

Duane Blumberg, Mayor

ATTACHMENTS: Exhibit A. Description of the Project and Area of Potential Effects

Exhibit B. Draft Historic Properties Treatment Plan for the Rosemont 

Copper Project, Pima County, Arizona

Exhibit C. Draft Historic Properties Treatment Plan for Rosemont 

Copper Utilities, Pima County, Arizona

Exhibit D. Points of Contact

Exhibit E. References Cited

D-16 Final Environmental Impact Statement for the Rosemont Copper Project
D. Memorandum of Agreement

Exhibit A

Description of the Project and Area of Potential Effects

Augusta Resource Corporation (Augusta Resource), the parent company of Rosemont 

Copper Company (Rosemont Copper), submitted a preliminary mine plan of operations 

(MPO) to the Coronado National Forest (Coronado) for development of the Rosemont ore 

deposit. The proposed mine site is located on the east side of the Santa Rita Mountains in the 

Nogales Ranger District, approximately 30 miles south of Tucson, Arizona (Figure 1).

Mining activity is proposed on approximately 995 acres of private land owned by Rosemont 

Copper, 3,670 acres of National Forest System land, and 75 acres of Arizona State Land 

Department land administered as a State Trust. This includes a proposed utility corridor that 

is needed to provide utility services to the mine operation. 

The Coronado has prepared a Draft Environmental Impact Statement (DEIS), in which 

several different alternatives were developed and analyzed. The specific Area of Potential 

Effect (APE) differs for each of the alternatives. All but the “No Action” alternative are 

expected to have adverse effects on multiple historic properties. A preferred alternative will 

be identified in the Final Environmental Impact Statement (FEIS). The draft Federal HPTP 

for the mine and draft Utilities HPTP for the utility corridor include all historic properties 

that would be adversely affected by any of the alternatives considered in the DEIS. 

All action alternatives include a suite of proposed activities. The mine operation area 

includes an open pit, waste rock facility, tailings facility, heap leach facility, plant site and 

ancillary facilities, mine primary access road, and utility maintenance road. The full timespan of the mine, including construction, operation, reclamation, and closure, is expected to 

be between 24.5 and 30.0 years. The mine pit would be between 6,000 and 6,500 feet in 

diameter, with a final depth of up to 3,000 feet at the end of mine operation, encompassing 

an estimated 955 acres (590 acres of privately held land and 365 acres of Coronado land).

A plant site for ore processing and other activities would be located to the northeast of the 

open pit. Waste rock and tailings would be placed in areas outside the open pit; locations 

vary with the different alternatives.

A new two-lane paved road, referred to as the “primary access road,” would be constructed 

to provide primary access between State Route 83 and the mine. An unpaved “utility 

maintenance road” would be located within the utility corridor to provide access to a 138-kV 

electrical transmission line, a water supply line, and water-booster pump stations. 

Two fences would enclose the mine operation area during its construction and operation.

A 5-strand barbed wire security fence would surround the mine pit, facilities, and waste 

rock/tailings, and would be patrolled along an adjacent dirt road. A guarded entryway would 

be located where the fence intersects the access road. An outer perimeter fence, also 5-strand 

barbed wire, would be established outside of the security fence to restrict public access 

during construction and operation. The outer perimeter fence would effectively define the 

area made inaccessible to the public during the mining project. Portions of existing Forest 

Service roads and the Arizona National Scenic Trail within the fenced area would be 

decommissioned and rerouted to provide public access to areas outside the perimeter fence.

Final Environmental Impact Statement for the Rosemont Copper Project D-17
D. Memorandum of Agreement 

In addition to rerouting the Arizona Trail and Forest Service roads, connected actions include 

the construction of utility corridors, service roads, and access roads for the project, and 

potential rerouting of additional Forest roads and trails, as necessary. 

In 2012 the Arizona Corporation Commission approved a utility corridor that is 500 feet 

wide, but construction would occur within a right-of-way typically less than 60-feet in width 

within much of that corridor; in a few locations, the disturbance corridor is wider to 

accommodate pumping stations or cut-and-fill operations in areas of steep, rugged terrain. 

The 138-kV transmission line would bring power from the Sahuarita substation over the 

Santa Rita ridgeline and into the mine operation area. Monopoles would be between 75 and 

150 feet tall, except at major road or line crossings, where poles would not exceed 199 feet. 

The proposed water pipeline consists of 20-inch diameter piping that will be fitted and 

installed below the existing ground surface. Up to four booster stations would be built along 

the water pipeline and an unpaved service road would be constructed within this corridor 

where needed.

A total of approximately 5,300 to 6,200 acres would be utilized for the mine and connected 

actions, depending on the alternative selected. Upon closure of the mine and completion of 

reclamation, the facilities and utilities would be removed as a condition of the Arizona 

Corporation Commission’s Certificate of Environmental Compatibility (CEC); the open pit, 

waste rock, and tailings would remain.

An APE for direct physical effects to historic properties is expected for each of the proposed 

actions. Archaeological sites in the areas of the mine pit, facilities, and waste rock and 

tailings storage would be effectively removed or buried. Which historic properties would be 

adversely affected depends on the project alternative selected and whether project design can 

be altered to avoid direct impacts. Historic properties between the perimeter and security 

fences should not be adversely affected by direct effects since new ground disturbance would 

be minimized. Effects on archaeological sites in the utility corridor are more limited since 

ground disturbance from both the transmission line and the water line are more restricted in 

scope. 

An APE for indirect visual, atmospheric, and audible effects to historic properties is also 

expected from many of the proposed actions. Indirect effects such as these have a potential to 

diminish the integrity of historic properties, including undisturbed parts of the Ce:wi Duag 

Traditional Cultural Property (TCP). Figure 2 shows the location of Ce:wi Duag TCP with 

respect to the APE for visual effects for the mine, facilities, waste rock/tailings deposits, and 

transmission line. 

The APE for visual effects is defined as those areas where project activities are visible, 

generalized from viewshed analysis. The designated APE for visual effects for the mine and 

waste rock deposits includes areas extends approximately six miles (10 km) from the mine.

The mine would not be visible from all locations within this area since elevated landforms 

block the view from many low-lying areas. The APE for visual effects encompasses the area 

of audible and atmospheric effects that have the potential to alter the qualities of historic 

properties.

Figure 2 also shows the mine visible from most of the northern portion of the Santa Rita 

Mountains, east of the ridge crest of the mountains; it would not be visible from the west side 

D-18 Final Environmental Impact Statement for the Rosemont Copper Project
D. Memorandum of Agreement

of the ridge crest. Mine and waste rock deposits would be visible from much of the northern 

half of the Ce:wi Duag TCP. Two National Register of Historic Places listed historic 

properties are located on the east side of the Santa Rita Mountains (Empire Ranch 

Headquarters and Kentucky Camp). Each is listed on the National Register of Historic Places 

in recognition of their architectural characteristics and importance to history. Mine operations 

would not be visible from either site. 

The APE for visual effects for the monopole transmission line is considered to extend onehalf mile (0.8 km) from the utility corridor centerline, based on consultation with State 

Historic Preservation Office. Although the transmission line may be visible outside this 

corridor, its visual intrusiveness would diminish with distance. CEC conditions stipulate 

visual mitigation for the utility corridor. For the transmission line, non-specular conductor 

and dulled-surface transmission structures will be installed. Also within the utility corridor, 

Rosemont will minimize vegetation disturbance and will perform revegetation to 

preconstruction conditions. The CEC conditions further stipulate that Rosemont will file an 

annual certification that the transmission line is needed, and once service is no longer 

required, that the transmission line will be removed and environmental remediation will be 

performed.

Final Environmental Impact Statement for the Rosemont Copper Project D-19
D. Memorandum of Agreement 

Figure 1. Components of the proposed Rosemont Copper Project and land 

jurisdiction

D-20 Final Environmental Impact Statement for the Rosemont Copper Project
D. Memorandum of Agreement

Figure 2. Map showing Area of Potential Effect for visual impacts of the mine 

operation and transmission line in relation to identified Traditional Cultural Properties

Final Environmental Impact Statement for the Rosemont Copper Project D-21
D. Memorandum of Agreement 

Exhibit B

Draft Historic Properties Treatment Plan

for the Rosemont Copper Project, Pima County, Arizona

Materials that meet criteria of Freedom of Information Act exemptions are not included here.

Refer to http://www.fs.fed.us/im/foia/foiaexemptions.htm for additional information.

Culturally sensitive materials not included here fall under this criteria.

D-22 Final Environmental Impact Statement for the Rosemont Copper Project
D. Memorandum of Agreement

Exhibit C

Draft Historic Properties Treatment Plan for 

Rosemont Copper Utilities, Pima County, Arizona

Materials that meet criteria of Freedom of Information Act exemptions are not included here.

Refer to http://www.fs.fed.us/im/foia/foiaexemptions.htm for additional information.

Culturally sensitive materials not included here fall under this criteria.

Final Environmental Impact Statement for the Rosemont Copper Project D-23
D. Memorandum of Agreement 

Exhibit D

Designated Points of Contact (POC)

Table D1. Tribal Government Designated Points of Contact

Tribal Government

Tribal Chairperson/

President/ or

Governor

Designated POC

Ak-Chin Indian Community Louis J. Manuel, Jr.

Chairperson

42507 West Peters & Nall Road

Maricopa, AZ 85239

(520) 568-2227

Caroline Antone

Cultural Resources Program Manager

42507 W. Peters & Nall Road

Maricopa, AZ 85239

Fort Sill Apache Tribe Jeff Houser

Chairperson

Route 2, Box 121

Apache, Oklahoma 73006

(580) 588-2298

L. Michael Darrow

Secretary-Treasurer/NAGPRA 

Coordinator

Route 2, Box 121

Apache, OK 73006

(580) 588-2298

Gila River Indian Community Gregory Mendoza

Governor

P.O. Box 97

Sacaton, AZ 85247

Barnaby V. Lewis

Tribal Historic Preservation Officer

Cultural Resource Management Program

Dept. of Land and Water Resources

P.O. Box 2140

Sacaton, AZ 85247

(520) 562-7152 

Hopi Tribe LeRoy N. 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 Sandra Platero

President

P.O. Box 227

Mescalero, NM 88340

(575) 464-4494

Holly Houghten

Tribal Historic Preservation Officer

Resource Management and Protection

P.O. Box 227

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

Veronica Darnell

Attorney General Office

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

Community Development Department and 

Cultural and Environmental Services

10005 E. Osborn Road

Scottsdale, AZ 85256

(480) 362-6331

D-24 Final Environmental Impact Statement for the Rosemont Copper Project
D. Memorandum of Agreement

Tribal Government

Tribal Chairperson/

President/ or

Governor

Designated POC

San Carlos Apache Tribe Terry Rambler

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

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

P.O. Box 507

Whiteriver, AZ 85926

(928) 338-3033

(928) 338-6055 fax 

Yavapai-Apache Nation David Kwail

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 Dongowski

Tribal Historic Preservation Officer

Zuni Heritage and Historic Preservation 

Office

P.O. Box 339

Zuni, NM 87327

(505) 782-4814

Final Environmental Impact Statement for the Rosemont Copper Project D-25
D. Memorandum of Agreement 

Table D2. Federal/State or Local Government Designated Points of Contact

Federal/State or Local 

Government Authorized Official Designated POC

Advisory Council on 

Historic Preservation

John M. Fowler

Executive Director

1100 Pennsylvania Ave, NW,

Suite 803

Washington, DC 20004

Katry Harris

Program Analyst

1100 Pennsylvania Ave, NW,

Suite 803

Washington, DC 20004

(202) 606-8520

Arizona State Historic 

Preservation Office

James Garrison

Arizona State Historic Preservation 

Officer

1700 W. Washington St.

Phoenix, AZ 85007

Ann Howard

Deputy Arizona State Historic 

Preservation Officer 

James Cogswell 

Compliance Specialist

1700 W. Washington St.

Phoenix, AZ 85007

(602) 542-7142

Arizona State Land Department Vanessa Hickman

State Land Commissioner

1616 W. Adams St.

Phoenix, AZ 85007

Steve Ross

Cultural Resource Manager

1616 W. Adams St.

Phoenix, AZ 85007

(602) 542-2767

Arizona State Museum Patrick Lyons

Director

1013 E. University Blvd.

Tucson, AZ 85721

Todd Pitezel

Curator of Mandated Programs

1013 E. University Blvd.

Tucson, AZ 85721

(520) 621-4795

Pima County C. H. Huckleberry

County Administrator

Pima County Administrator’s Office

130 W. Congress Ave.

10th Floor

Tucson, AZ 85701 

Linda Mayro

Cultural Resources Manager

Loy Neff

Cultural Resources and Preservation 

Division Manager

Pima County Cultural Resources and 

Historic Preservation Office

201 N. Stone Ave.

Tucson, AZ 85701

(520) 724-8794

Town of Sahuarita Duane Blumberg

Mayor

375 W. Sahuarita Center Way

Sahuarita, AZ 85629

Orlantha Henderson

Planner

375 W. Sahuarita Center Way

Sahuarita, AZ 85629

(520) 822-8800

U.S. Army Corps of Engineers 

Los Angeles District

David J. Castanon

Chief, Regulatory Division

915 Wilshire Blvd

Los Angeles, CA 90017

Sallie Diebolt

Chief AZ Branch Regulatory Division

3636 N Central Ave, Suite 900, Phoenix, 

AZ 85012

(602) 230-6950

Marjorie Blaine

Senior Project Manager

5205 E. Camanche Street

Tucson, AZ 85707

(520) 670-6277

D-26 Final Environmental Impact Statement for the Rosemont Copper Project
D. Memorandum of Agreement

Federal/State or Local 

Government Authorized Official Designated POC

U.S. Department of Agriculture

Forest Service Southwestern 

Region

Calvin N. Joyner

Regional Forester

USDA Forest Service

Southwest Regional Office

333 Broadway SE

Albuquerque, NM 87102

Jim Upchurch

Forest Supervisor 

Jamie Kingsbury

Deputy Forest Supervisor

William Gillespie

Forest Archaeologist

Coronado National Forest 

300 W. Congress St., Ste. 600

Tucson, AZ 85701

(520) 388-8300

(520) 388-8305 fax

Table D3. Project Proponent Designated Point of Contact

Project Proponent Authorized Official Designated POC

Rosemont Copper Company Rod Pace

Chief Executive Officer

PO Box 35130

Tucson, AZ 85740

Kathy Arnold

Vice President

Environmental and Regulatory Affairs

PO Box 35130

Tucson, AZ 85740

(520) 297-7723

Final Environmental Impact Statement for the Rosemont Copper Project D-27
D. Memorandum of Agreement 

Exhibit E

References Cited

Barr, D.M., I.S. Hesse, S.J. Hesse, J.E. Hider, S. Griset, E.S. Peterson, II, and D.B. Tucker. 2010. 

Archaeological Survey of Alternatives to the Proposed Rosemont Copper Mine, Pima 

County, Arizona. Cultural Resources Report No. 10-334. Prepared for the Coronado National 

Forest. Prepared on behalf of Rosemont Copper Company. Tucson, Arizona: SWCA 

Environmental Consultants.

Chamorro, S. 2011. A Cultural Resources Inventory of Approximately 84 Acres Near Sahuarita, Pima 

County, Arizona. Project No. 1049.29 520 520. Tucson, Arizona: WestLand Resources, Inc.

Chamorro, S., and A.M. King. 2012. A Revised Cultural Resources Inventory of Approximately 84 

Acres Near Sahuarita, Pima County, Arizona. Cultural Resources Report 2011-43, Accession 

No. 2011-0429. . Tucson, Arizona: WestLand Resources Inc.

Deaver, W.L. 2013. Rosemont Copper: A Cultural Resources Inventory Within and Around Helvetia, 

Pima County, Arizona. Project No. 1049.32 A 520. Tucson, Arizona: WestLand Resources 

Inc.

Ezzo, J.A., D. Gilpin, S. Griset, E.S. Petersen, II, and S.M. Whittlesey. 2011. Archaeological Survey 

for the Proposed Rosemont Copper Mine, Pima County, Arizona. Cultural Resources Report 

No. 09-35. Prepared on behalf of Rosemont Copper Company. Prepared for Coronado 

National Forest, U.S. Forest Service. Tucson, Arizona: SWCA Environmental Consultants.

Griset, S. 2011. An Ethnohistory of the Rosemont Copper Project Area in the Eastern Santa Rita 

Mountains, Pima County, Arizona. Cultural Resources Report No. 09-238. Prepared for U.S. 

Forest Service, Coronado National Forest. Prepared on behalf of Rosemont Copper 

Company. Tucson, Arizona: SWCA Environmental Consultants.

Griset, S., W. Gillespie, and M. Farrell. 2012. National Register of Historic Places Registration Form: 

Ce:wi Duag ("Long Mountain" in O'odham). National Park Service Form 10-900. Tucson, 

Arizona: SWCA Environmental Consultants, Coronado National Forest, U.S. Forest Service, 

and Trans-Sierran Archaeological Research.

Lindly, J., and A.E. Buckles. 2012. A Cultural Resources Inventory of Two Contiguous Arizona 

Department of Transportation Encroachment Permit Areas Along State Route 83 For 

Rosemont Copper, Pima County, Arizona. Project No. 1049.26 700B 500. Tucson, Arizona: 

WestLand Resources, Inc.

Martin, A.K. 2011. A Cultural Resources Inventory of Approximately 3.3 Acres Near Santa Rita 

Road and South Country Club Road, East of Sahuarita, Pima County, Arizona. Cultural 

Resources Report 2011-3, Tucson, Arizona: WestLand Resources, Inc.

Petersen, E.S., II. 2007. Archaeological Survey of Approximately 67.1 Acres in the Coronado 

National Forest, Pima County, Arizona. Cultural Resources Report No. 07-48. Tucson, 

Arizona: SWCA Environmental Consultants.

D-28 Final Environmental Impact Statement for the Rosemont Copper Project
D. Memorandum of Agreement

Petersen, E.S., II, and S. Griset. 2010. Results of an Archaeological Class I Inventory of Four 

Alternatives for the Proposed Rosemont Copper Mine, Rosemont Junction, Pima County, 

Arizona. Cultural Resources Report No. 10-47. Tucson, Arizona: SWCA Environmental 

Consultants.

Rayle, C.E. 2013. A Cultural Resource Survey of Additional Areas for the Rosemont Project Utility 

Corridor, Pima County, Arizona. EPG Cultural Resource Services Technical Paper No. 

2012-23. Prepared for Rosemont Copper Company. Phoenix, Arizona: Environmental 

Planning Group.

Sheehan, M.S., S. Swanson, and S. Shelley. 2013. A Cultural Resource Survey for the Rosemont 

Project Utility Corridor, Pima County, Arizona. Cultural Resource Services Technical Paper 

No. 2010-001. Phoenix, Arizona: Environmental Planning Group.

Swanson, S., D. Sunderman, B. Snow, and C. Lonardo. 2012. A Cultural Resources Survey of the 

46kV Alternative and Additional Areas for the Rosemont Project 138kV Line, Pima County, 

Arizona. EPG Cultural Resource Services Technical Paper No. 2010-0017. Prepared for 

Rosemont Copper Company. Phoenix, Arizona: Environmental Planning Group.

Final Environmental Impact Statement for the Rosemont Copper Project D-29

E. Tribal Consultation

Final Environmental Impact Statement for the Rosemont Copper Project E-1

E. Tribal Consultation

Tribal Consultation

This appendix is intended to provide a summary of events that occurred as tribal consultation for the 

Rosemont Copper Project. It is not intended to document the Section 106 process, nor does it include 

every individual contact between the Coronado and the consulting tribes. For example, there were 

numerous emails and phone conversations that occurred that are not captured in the following table. 

This appendix also does not include interactions with State Historic Preservation Office, Advisory 

Council on Historic Preservation, and other consulting agencies, as its purpose is to assist in 

understanding the efforts that the Coronado made to consult with area tribes.

E1. Tribes Consulted by the Coronado National Forest Regarding the Proposed Rosemont 

Copper Mine (current points-of-contact, as of September 2013)

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

42507 W. Peters & Nall Road

Maricopa, AZ 85239

Fort Sill Apache Tribe Jeff Houser, Chairperson

Route 2, Box 121

Apache, Oklahoma 73006

(580) 588-2298

Leland Michael Darrow, SecretaryTreasurer/NAGPRA Coordinator

Route 2, Box 121

Apache, OK 73006

(580) 588-2298

Gila River Indian Community Gregory Mendoza, 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 N. 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 Alfred LaPaz, Acting President

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

Veronica Darnell

Attorney General Office

7474 S. Camino De Oeste

Tucson, AZ 85746

(520) 883-5106

Final Environmental Impact Statement for the Rosemont Copper Project E-3
E. Tribal Consultation

Tribe

Tribal Chairperson/

President/ or

Governor

Designated Tribal POC

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

San Carlos Apache Tribe Terry Rambler, Chairman

P.O. Box 0

San Carlos, AZ 85550

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

Terry Rambler Dec 2010 - 2014

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 David Kwail, 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

E-4 Final Environmental Impact Statement for the Rosemont Copper Project
E. Tribal Consultation

E2. Summary of Tribal Consultation Activities 

Date Event/Correspondence Tribes Included

2006

9/26 Coronado sent letter introducing project All consulting parties

10/16 Response to 9/26 letter stating concerns and concerns 

and requesting arch survey copies

Hopi Tribe

10/19 Response to 9/26 letter requesting to keep informed, but 

they defer to the Tohono O’odham Nation as lead

Ak-Chin Indian Community

10/30 Response to 9/26 letter deferring to San Carlos Apache 

Tribe

White Mountain Apache Tribe

2007

2/21 Coronado met with Hopi regarding concerns about 

NAGPRA repatriation & conducting a TCP study

Hopi Tribe

2008

3/14 CNF Letter with Notice of Intent for project All consulting parties

4/1 Response to 3/14 letter concurring with approach in the 

letter and defers to the Tohono O’odham Nation

Ak-Chin Indian Community

4/1 Phone conversation regarding response to 3/14 letter Tohono O’odham Nation

4/4 Response to 3/14 letter requesting repatriation Anamax 

human remains and support selection of No Action

Hopi Tribe

4/25 Site Tour with Tribe Representatives Ak-Chin Indian Community and Tohono

O’odham Nation

6/13 Coronado letter regarding pursuit of ethnohistory All consulting parties

6/17 Coronado presentation to Legislative Council’s Cultural 

Committee

Tohono O’odham Nation

6/24 Coronado presentation to Four Southern Tribes Cultural 

Resources Working Group

Ak-Chin Indian Community, Gila River 

Indian Community, Salt River Pima-Maricopa 

Indian Community, Tohono O'odham Nation

7/1 Response to 6/13 letter reiterating concerns & formal 

claim for repatriation of human remains

Hopi Tribe

8/6 Coronado letter notification of Anamax repatriation 

requests

Salt River Pima-Maricopa Indian Community

8/15 Coronado met with Four Southern Tribes Cultural 

Committee

Ak-Chin Indian Community, Gila River 

Indian Community, Salt River Pima-Maricopa 

Indian Community, Tohono O'odham Nation

8/18 Coronado met with representatives to discuss current 

status of Rosemont.

San Carlos Apache Tribe, White Mountain 

Apache Tribe

8/25 Letter deferring to Tohono O'odham Nation for 

repatriation of Anamax remains

Hopi Tribe

9/12 Coronado presentation to Tribal Council Tohono O'odham Nation

9/16 Site Tour with Tribe Representatives Ak-Chin Indian Community, Salt River PimaMaricopa Indian Community, Tohono 

O'odham Nation

10/16 Site Tour with Tribe Representatives Fort Sill Apache Tribe, Mescalero Apache 

Tribe, Tohono O’odham Nation, White 

Mountain Apache Tribe

11/6 Coronado presentation to San Xavier Cultural 

Committee

Tohono O'odham Nation

11/14 Coronado provides plant information from Anamax 

reports

San Carlos Apache Tribe

12/9 Coronado meet with District Chairpersons Tohono O’odham Nation

12/17 Coronado presentation to Tribal District Chairpersons 

Committee

Tohono O’odham Nation

Final Environmental Impact Statement for the Rosemont Copper Project E-5
E. Tribal Consultation

Date Event/Correspondence Tribes Included

2009

1/28 Site Tour with District Chairpersons Tohono O’odham Nation

3/23-3/24 Site tour by Tribe elders Mescalero Apache Tribe

4/10 Letter reasserting claims to remains from Anamax 

excavation

Hopi Tribe

4/28 Site tour with Tribe Representative San Carlos Apache Tribe

5/1 Site tour with Tribe Representative Gila River Indian Community

6/1 Letter deferring handling of Anamax human remains to 

the Tohono O’odham Nation

Hopi Tribe

6/22 Coronado letter sending Archeological Report & 

Requesting for Project Comments

All consulting parties

6/30 Letter opposing project; will review the Ethnohistory; 

want to meet with CNF to renew their MOU

Hopi Tribe

7/8 Letter recommending monitoring. No additional info 

needed.

White Mountain Apache Tribe

8/25 Coronado met with Legislature Tohono O’odham Nation

9/11 Notification received of interest in being directly 

involved in NEPA and Sec 106 and phone discussion 

regarding project and suggested references for 

ethnohistory

Pueblo of Zuni

2010

2/3 Comments on survey report provided Tohono O’odham Nation

6/29 Coronado Presentation with Four Southern Tribes 

Working Group

Ak-Chin Indian Community, Gila River 

Indian Community, Salt River Pima-Maricopa 

Indian Community, Tohono O'odham Nation

2011

1/20 Discussion re: cultural significance of springs Tohono O’odham Nation

4/1 Coronado letter re: Alternatives Arch Report and 

Ethnohistory 

All consulting parties

4/28 Hard copy of reports sent Hopi Tribe

5/9 Comments on reports and restatement of opposition to 

project

Tohono O’odham Nation

5/23 Restate opposition to project and request continuing 

consultation, including DEIR, HPTP, NAGPRA Plan of 

Action, and MOA.

Hopi Tribe

6/14 Letter requesting the selection of No Action and 

comments on received reports

Ak-Chin Indian Community

10/3 Coronado presentation with San Xavier Elders Tohono O’odham Nation

10/17 Coronado letter requesting meeting with Legislature Tohono O’odham Nation

11/1 Coronado request for MOA subcommittee to meet 

before consultation meeting on 11/13

All Consulting Parties

11/7 Coronado sent DEIS All consulting parties

12/8 Coronado letter requesting feedback on TCP nomination Ak-Chin Indian Community, Gila River 

Indian Community, Salt River Pima-Maricopa 

Indian Community, Tohono O'odham Nation

12/16 Coronado presentation to Four Southern Tribes Cultural 

Committee

Ak-Chin Indian Community, Gila River 

Indian Community, Salt River Pima-Maricopa 

Indian Community, Tohono O’odham Nation

2012

1/18 DEIS comments received Hopi Tribe, Tohono O’odham Nation

1/27 Meeting regarding TCP Tohono O’odham Nation

E-6 Final Environmental Impact Statement for the Rosemont Copper Project
E. Tribal Consultation

Date Event/Correspondence Tribes Included

2/15 Meeting regarding TCP Tohono O’odham Nation

2/28 Coronado sent thank-you letters for DEIS comments Hopi Tribe, Tohono O’odham Nation

3/19 Letter to Coronado reiterating desire to meet to discuss 

issues

Hopi Tribe

4/5 Coronado met with San Xavier Cultural Committee Tohono O’odham Nation

5/15 Coronado letter requesting meeting Tohono O’odham Nation

5/23 Coronado sent revegetation information Tohono O’odham Nation

7/3 Coronado sent letter inviting participation in Section 

106 consultation

All Consulting Tribes

7/16 Section 106 Consultation tour and meeting Ak-Chin Indian Community, Fort Sill Apache 

Tribe, Gila River Indian Community, 

Mescalero Apache Tribe, Pascua Yaqui Tribe, 

Tohono O’odham Nation, White Mountain 

Apache Tribe

7/17 Site tour with Elders Mescalero Apache Tribe

8/13 Coronado provides 8 cultural reports related to 

Rosemont

All Consulting Tribes

8/15 Section 106 consultation meeting and tour Ak-Chin Indian Community, Gila River 

Indian Community, Mescalero Apache Tribe, 

Pascua Yaqui Tribe, Salt River PimaMaricopa Indian Community, San Carlos 

Apache Tribe, Tohono O’odham Nation, 

White Mountain Apache Tribe

8/22 Coronado and Hopi CPO meet in Flagstaff Hopi Tribe

9/4 Letter to Coronado with review of arch reports, 

reaffirms opposition

Hopi Tribe

9/5 Section 106 consultation meeting Ak-Chin Indian Community, Mescalero 

Apache Tribe, Tohono O’odham Nation, 

White Mountain Apache Tribe

9/15 Site tour of Springs with Representatives and Elders Mescalero Apache Tribe, White Mountain 

Apache Tribe

10/2 Section 106 consultation tour and meeting Ak-Chin Indian Community, Mescalero 

Apache Tribe, Salt River Pima-Maricopa 

Indian Community, Tohono O’odham Nation, 

White Mountain Apache Tribe

11/7 Draft MOA sent White Mountain Apache, Tohono O’odham 

Nation

11/13 Section 106 consultation meeting Ak-Chin Indian Community, Fort Sill Apache, 

Gila River Indian Community, Mescalero 

Apache Tribe, Salt River Pima-Maricopa 

Indian Community, Tohono O’odham Indian 

Community, White Mountain Apache Tribe

12/4 Site tour with Legislature Tohono O’odham Nation

12/6 Section 106 consultation meeting Ak-Chin Indian Community, Gila River 

Indian Community, Mescalero Apache Tribe, 

Pascua Yaqui Tribe, Tohono O’odham Nation, 

White Mountain Apache Tribe

2013

1/9 Tribe Draft MOA sent to Coronado Tohono O’odham Nation

1/22 Section 106 consultation meeting Fort Sill Apache Tribe, Gila River Indian 

Community, Mescalero Apache Tribe, Pascua 

Yaqui Tribe, Tohono O’odham Nation, White 

Mountain Apache Tribe

1/31 Coronado Draft MOA sent All Consulting Parties

Final Environmental Impact Statement for the Rosemont Copper Project E-7
E. Tribal Consultation

Date Event/Correspondence Tribes Included

2/15 Sections of draft HPTP sent for discussion during 

webinar

All Consulting Parties

2/20 HPTP Research Design webinar discussion All Consulting Parties

3/1 Coronado sent Draft MOA & HPTP mailed All Consulting Parties

3/12 Coronado sent hard copies of MOA and HPTP Hopi Tribe

3/19 Letter sent to Coronado reiterating opposition to project, 

consultation premature on HPTP

Hopi Tribe

3/28 Section 106 consultation meeting Gila River Indian Community, Hopi Tribe, 

Mescalero Apache Tribe, Tohono O’odham 

Nation, White Mountain Apache Tribe

4/12 Comments to Coronado on Draft MOA Tohono O’odham Nation

4/23 Forest Supervisor met with Tribal Council Pascua Yaqui Tribe

5/9 Coronado led tour of project area for Chairman, Council 

Members and staff

Pascua Yaqui Tribe

5/24 Coronado sent another Draft MOA and Draft HPTP All Consulting Tribes

6/5 Tribe teleconference Gila River Indian Community, Mescalero 

Apache Tribe, Tohono O’odham Nation

6/5 Rosemont distributes draft Utilities HPTP All Consulting Tribes

6/21 Comments to Coronado on MOA Tohono O’odham Nation

6/24 Comments to Coronado on HPTP Tohono O’odham Nation

6/25 Comments to Coronado on HPTP and MOA Hopi Tribe

6/28 Section 106 consultation meeting Ak-Chin Indian Community, Fort Sill Apache 

Tribe, Gila River Indian Community, 

Mescalero Apache Tribe, Pascua Yaqui Tribe, 

Tohono O’odham Nation, White Mountain 

Apache

7/9 Letter to Coronado requesting 60-day extension of draft 

FEIS and MOA review period

Tohono O’odham Nation

7/16 Coronado sent out MOA All Consulting Parties

7/22 Coronado sent letter extending review period to 8/15/13 

and reiterating availability to meet

Tohono O’odham Nation

8/13 Letter to Coronado conveying Resolution opposing the 

project

Pascua Yaqui Tribe

8/14 Final draft HPTP sent All Consulting Parties

8/20 Letter to T. Vilsack regarding expedited project timeline Tohono O’odham Nation

8/22 Comments to Coronado on HPTP Tohono O’odham Nation

E-8 Final Environmental Impact Statement for the Rosemont Copper Project