United States Department of Agriculture

Draft Record of Decision 

and Finding of 

Nonsignificant Forest 

Plan Amendment for the 

Rosemont Copper Project

Forest 

Service 

Southwestern 

Region

MB-R3-05-9

December 2013
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Printed on recycled paper –December 2013 

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Record of Decision and Finding of Nonsignificant Amendment

Contents 

Acronyms and Abbreviations .............................................................................................................. v

Introduction .......................................................................................................................................... 1

Background of the Project ................................................................................................................... 1

Purpose of and Need for Action ....................................................................................................... 2

Issues ................................................................................................................................................ 4

Issue 1: Impact on Land Stability and Soil Productivity ............................................................ 4

Issue 2: Impact on Air Quality ................................................................................................... 4

Issue 3: Impact on Water Resources ........................................................................................... 5

Issue 4: Impact on Springs, Seeps, and Riparian Vegetation ..................................................... 6

Issue 5: Impact on Plants and Animals ....................................................................................... 6

Issue 6: Impact on Cultural Resources ....................................................................................... 7

Issue 7: Impact on Visual Resources .......................................................................................... 8

Issue 8: Impact on Dark Skies and Astronomy .......................................................................... 8

Issue 9: Impact on Recreation .................................................................................................... 8

Issue 10: Impact on Public Health and Safety ............................................................................ 8

Issue 11: Impacts on Social and Economic Resources ............................................................... 8

Issue 12: Impact on Transportation/Access ................................................................................ 9

My Decision ........................................................................................................................................... 9

Responsiveness to the Purpose of and Need for Action ................................................................. 10

Responsiveness to the Issues .......................................................................................................... 10

Decision Rationale .............................................................................................................................. 10

Conclusion – Determination of Selected Action ............................................................................ 25

Description of the Selected Action ..................................................................................................... 25

Connected Actions ......................................................................................................................... 29

Electrical Transmission Line .................................................................................................... 29

Water Supply Pipeline .............................................................................................................. 29

Electrical Distribution Line ...................................................................................................... 29

Arizona National Scenic Trail Reroute..................................................................................... 29

State Route 83 Highway Maintenance and Improvements ....................................................... 29

Mitigation and Monitoring ............................................................................................................. 30

Stipulations, Mitigations, and Monitoring Programs...................................................................... 30

General Stipulations ....................................................................................................................... 30

Mitigation and Monitoring Requirements ...................................................................................... 33

Reporting and Evaluation ......................................................................................................... 33

Geology, Minerals, and Paleontology ...................................................................................... 34

Soils and Revegetation ............................................................................................................. 34

Air Quality and Climate Change .............................................................................................. 34

Groundwater Quantity and Quality .......................................................................................... 34

Surface Water Quantity and Quality......................................................................................... 35

Seeps, Springs, and Riparian Areas .......................................................................................... 36

Biological Resources ................................................................................................................ 36

Landownership and Boundary Management ............................................................................ 38

Dark Skies ................................................................................................................................ 38

Visual Resources ...................................................................................................................... 38

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Recreation and Wilderness ....................................................................................................... 39

Hazardous Materials ................................................................................................................. 39

Transportation/Access .............................................................................................................. 40

Noise ......................................................................................................................................... 42

Public Health and Safety .......................................................................................................... 42

Cultural Resources .................................................................................................................... 42

Power Use ................................................................................................................................. 43

Community Programs ............................................................................................................... 43

Permits, Licenses, and Authorizations Needed to Implement the Decision .................................. 44

Applicable Laws, Regulations, and Policies ..................................................................................... 46

Alternatives Considered ..................................................................................................................... 46

Alternative 1 – No Action (Environmentally Preferable Alternative) ............................................ 46

Alternative 2 – Proposed Action .................................................................................................... 47

Alternative 3 – Phased Tailings ...................................................................................................... 48

Alternative 5 – Barrel Trail Alternative ......................................................................................... 50

Alternative 6 – Scholefield McCleary Alternative ......................................................................... 50

Alternatives Eliminated from Detailed Study .................................................................................. 52

Environmentally Preferable Alternative .......................................................................................... 52

Public Involvement ............................................................................................................................. 52

Scoping .......................................................................................................................................... 52

Public Review of the Draft Environmental Impact Statement ....................................................... 53

Consultation with Tribes and Government Agencies ..................................................................... 54

Tribal Consultation ................................................................................................................... 54

Cooperating Agency Consultation ............................................................................................ 55

Financial Assurance ............................................................................................................................ 56

Findings Required by Other Laws, Executive Orders, and Rules ................................................. 56

National Forest Management Act .................................................................................................. 57

Finding of Nonsignificant Amendment .................................................................................... 57

The Endangered Species Act .......................................................................................................... 59

Regional Forester’s Sensitive Species............................................................................................ 61

The Migratory Bird Treaty Act of 1918 ......................................................................................... 62

Water Pollution Control Act of 1972 (Clean Water Act) ................................................................ 62

The Clean Air Act, as amended in 1990 ......................................................................................... 62

Federal Noxious Weed Act of 1974 ............................................................................................... 63

National Historic Preservation Act................................................................................................. 63

Wetlands (Executive Order 11990) ................................................................................................ 63

Floodplains (Executive Order 11988) ............................................................................................ 63

Environmental Justice (Executive Order 12898) ........................................................................... 63

Tribal Consultation and Coordination (Executive Order 13175) ................................................... 63

Procedures for Change During Implementation ............................................................................. 64

Implementation Date .......................................................................................................................... 64

Contact Person .................................................................................................................................... 65

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Appendix

A. Detailed Description of the Selected Action 

Figures

Figure ROD-1. General project location and footprint of the selected action ........................................ 3

Figure ROD-2. Selected action footprint .............................................................................................. 26

Figure ROD-3. Road changes under the selected action ...................................................................... 27

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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

ACC Arizona Corporation Commission 

ACHP Advisory Council on Historic Preservation 

ADA Arizona Department of Agriculture

ADEQ Arizona Department of Environmental Quality 

ADOT Arizona Department of Transportation 

ADWR Arizona Department of Water Resources

AGFD Arizona Game and Fish Department 

APE area of potential effects

APP Aquifer Protection Permit 

ARS Arizona Revised Statutes

ASLD Arizona State Land Department 

Augusta Resource Augusta Resource Corporation 

AUM animal unit month 

AZPDES Arizona Pollutant Discharge Elimination System

BA biological assessment

BLM Bureau of Land Management 

BMP best management practice

BO biological opinion

CAA Clean Air Act

CEC Certificate of Environmental Compatibility

CEQ Council on Environmental Quality 

CFR Code of Federal Regulations 

CH4 methane 

CO2 carbon dioxide 

CWA Clean Water Act

DEIS draft environmental impact statement

EIS environmental impact statement

EPA U.S. Environmental Protection Agency 

ESA Endangered Species Act

FEIS final environmental impact statement

FLAG Federal Land Managers Air Quality Related Values Working Group 

Forest Service U.S. Forest Service

FSM Forest Service Manual

GIS geographic information system 

HPTP historic properties treatment plan 

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I- interstate

ID team interdisciplinary team

kV kilovolt

LED light emitting diode

MOA memorandum of agreement 

MPO mine plan of operations 

MSHA Mine Safety and Health Administration

NAAQS national ambient air quality standards

NEPA National Environmental Policy Act

NHPA National Historic Preservation Act

NFMA National Forest Management Act

NFS National Forest System

NFSR National Forest System road

N2O nitrous oxide

NOx nitrogen oxides 

no. number 

NRHP National Register of Historic Places

OHV off-highway vehicles

PL Public Law

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

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

QA/QC quality assurance/quality control

ROD record of decision 

Rosemont Copper Rosemont Copper Company 

ROW right-of-way

SHPO State Historic Preservation Office

SR State Route

SWPPP stormwater pollution prevention plan

the Coronado Coronado National Forest (the agency) 

U.S. United States 

USACE U.S. Army Corps of Engineers 

U.S.C. United States Code

USDOT U.S. Department of Transportation 

USFWS U.S. Fish and Wildlife Service 

WUS waters of the United States

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Introduction

This is the record of decision (ROD) for the Coronado National Forest’s (the Coronado’s) response to 

Rosemont Copper Company’s (Rosemont Copper’s) mine plan of operations (MPO) for the 

Rosemont Copper Project. It also includes administrative actions to incorporate amendments to the 

“Coronado National Forest Land and Resource Management Plan” (referred to as the “forest plan”), 

which will create a new forest management area for which specific standards and guidelines will be 

established relative to a large-scale mining operation. 

An environmental impact statement (EIS) was developed to analyze the potential effects of the 

Rosemont Copper Project. Six alternatives were considered and analyzed. The EIS was finalized in 

November 2013 and made available to the public on December 13, 2013. 

This ROD documents my decision, along with the rationale for the decision and alternatives 

considered in reaching the decision. It also includes a discussion of preferences among alternatives 

based on relevant factors and how those factors were considered in reaching the decision. This ROD 

also documents changes and additions to the preliminary MPO submitted by Rosemont Copper 

deemed necessary by the Coronado, an administrative unit of the U.S. Forest Service (Forest 

Service), to meet the requirements of the regulations at 36 Code of Federal Regulations (CFR) 228 

Subpart A and comply with other applicable laws and regulations. 

The decision presented in this document addresses activities proposed on lands administered by the 

Forest Service for which Federal decisions are required. 

Background of the Project

The current preliminary MPO for the Rosemont Copper Project is the latest in an extensive history of 

copper prospecting and development in this area of southern Arizona. Copper production in the Santa 

Rita Mountains began in the 1880s and continued until the 1950s. Previous mining activity on the 

east side of the Santa Rita Mountains supported operation of the Rosemont smelter in the Rosemont 

mining district, which is located in and around the project area. Previous mining activity on the west 

side of the Santa Rita Mountains supported operation of the Columbia smelter at Helvetia in the 

Helvetia mining district. Although several exploration projects have been undertaken, there has been 

no recent production of copper at or near this location. The rising value of copper over the past 

several years has increased the economic viability of mining the Rosemont mineral deposit. 

In July 2007, Rosemont Copper submitted a preliminary MPO to the Coronado requesting approval 

to construct, operate, reclaim, and close an open-pit mine on and adjacent to National Forest System 

(NFS) lands administered by the Coronado for development of the Rosemont mineral deposit. The 

Coronado’s review of the preliminary MPO identified the need for additional information. In 

February 2008, a supplemental preliminary MPO was submitted by Rosemont Copper and accepted 

for environmental review by the Coronado. 

At the request of Rosemont Copper, the U.S. Army Corps of Engineers (USACE) reviewed a 

preliminary delineation for potentially jurisdictional waters of the United States (WUS) submitted in 

accordance with regulatory guidance letter no. 08-02. The USACE has determined that potentially 

jurisdictional WUS are present within the proposed project area. These waters are discussed in the 

Final EIS (FEIS) in the “Surface Water Quality” section of chapter 3.

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The proposed mine is located on private and NFS lands in the Barrel drainage on the Nogales Ranger 

District, Coronado National Forest, approximately 30 air miles southwest of the center of Tucson, 

Arizona (figure ROD-1).There are also associated connected actions to the project, which are located 

as follows: 

Electrical Transmission Line – Primarily located on State, private, and NFS lands. The transmission 

line will run from the Santa Rita South substation, located near Sahuarita, Arizona, to the Rosemont 

substation, to be located at the mine site. 

Water Supply Pipeline – A water supply pipeline and ancillary facilities (four pump stations and 

electrical distribution line) will be co-located with the electrical transmission line.

Electrical Distribution Line – An existing electrical distribution line, located on NFS and private 

lands in the immediate vicinity of the mine site, will be relocated within the same general vicinity.

 Arizona National Scenic Trail Reroute – Approximately 10 miles of the Las Colinas portion of the 

Arizona National Scenic Trail will be relocated from the mine area to a location on the east side of 

State Route (SR) 83 on NFS and private lands. 

State Route 83 Highway Maintenance and Improvements – The Arizona Department of 

Transportation (ADOT) is requiring road maintenance activities on SR 83 from the junction of 

Interstate 10 (I-10) to the junction with the primary access road, consisting of pavement overlay and 

associated actions. This will occur within ADOT right-of-way (ROW) and will cross a variety of land 

ownerships. 

The Rosemont Copper Project will mine copper, silver, and molybdenum from private and NFS

lands, with copper being the primary metal extracted. Copper is used for a variety of commercial 

purposes, including construction, power generation, household plumbing and wiring, 

telecommunications, and components of cars and trucks. The Rosemont mine is expected to produce 

an estimated 5.88 billion pounds of copper, 194 million pounds of molybdenum, and 80 million 

ounces of silver. This represents approximately 11 percent of U.S. copper production and less than 1 

percent of world copper production, based on 2011 statistics (U.S. Geological Survey 2013e). 

The project will consist of an open pit, a processing plant (mill) and associated facilities, transmission 

lines for power and water, and waste rock and tailings facilities. Approval of the final MPO for this 

project will result in total surface disturbance of an estimated 5,888 acres of combined private lands, 

lands administered by Arizona State Land Department (ASLD), and NFS lands. This acreage includes 

all disturbance within the perimeter fence, the primary access road corridor; utility corridor (including 

the electric supply line, water supply line, and utility maintenance road); road construction and 

decommissioning; and the reroute of the Arizona National Scenic Trail. Refer to the description of the 

Barrel Alternative in chapter 2 of the FEIS for further detail. 

Purpose of and Need for Action

The Coronado’s overall purpose and need is to process Rosemont Copper’s MPO. Rosemont Copper 

is entitled to conduct operations that are reasonably incidental to exploration and development of 

mineral deposits on its mining claims pursuant to applicable U.S. laws and regulations and is

asserting its right under the General Mining Law to mine and remove the mineral deposit subject to 

regulatory laws. 

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Figure ROD-1. General project location and footprint of the selected action

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From the perspective of the Forest Service, the need for action is to: 

• Respond to Rosemont Copper’s proposed MPO to develop and mine the Rosemont 

copper, molybdenum, and silver deposit; 

• Ensure that the selected alternative would comply with other applicable Federal and 

State laws and regulations;

• Ensure that the selected alternative, where feasible, would minimize adverse 

environmental impacts on NFS surface resources; and

• Ensure that measures would be included that provide for reclamation of the surface 

disturbance. 

The Coronado is evaluating the proposed action at this time in order to comply with its statutory 

obligations (see below) to respond to Rosemont Copper’s preliminary MPO in a timely manner. 

An amendment to the forest plan is proposed and included in this FEIS (see “Forest Plan Consistency” 

in chapter 2) and addressed in this ROD (see “Finding of Nonsignificant Amendment” on p. 56). 

Issues

Using the comments received during the scoping process (see “Public Involvement” in chapter 1 of 

the FEIS and p. 52 of this ROD) from tribes, agencies, organizations, and the public, the Forest 

Service developed significant issues to address in the Draft EIS (DEIS). These issues were used to 

help formulate alternatives to the proposed action, develop elements or components of the 

alternatives, develop mitigation measures, and analyze environmental effects. A summary of 

significant issues for this project follows.

Issue 1: Impact on Land Stability and Soil Productivity

Ground disturbance from clearing vegetation, grading, and stockpiling soils has the potential to

accelerate erosion and reduce soil productivity. The tailings and waste rock facilities could be 

unstable over time, and reclamation may not adequately result in a stable, revegetated landscape.

The geochemical composition of tailings and waste rock facilities may not support native vegetation. 

Soils are nonrenewable resources. Damage, disturbance, and removal of the soil resource may result 

in a loss of soil productivity, physical structure, and ecological function across the proposed mine site 

and across downgradient lands. The mining area could potentially act as a barrier to sourcing and 

supporting natural downslope transportation of geological material, water, and nutrients through 

alluvial, eolian, and fluvial processes. 

Issue 2: Impact on Air Quality

Changes in air quality that could potentially occur from the mine operation were identified as a 

significant issue. Construction, mining, and reclamation activities at the mine and along 

transportation and utility corridors would increase dust, airborne chemicals, and transportation related 

(mobile) emissions in the affected area. The Clean Air Act (CAA) and other laws, regulations, 

policies, and plans set thresholds for air quality, including Class I airsheds. 

The emission of greenhouse gases has been implicated in global climate change, and the policy of the 

Federal Government is to reduce these emissions when possible (Executive Order 13514). 

Greenhouse gases are those in the atmosphere that retain heat. They are natural and keep the earth 

from becoming too cold. The specific gases known as greenhouse gases are carbon dioxide (CO2), 

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methane (CH4), nitrous oxide (N2O), and fluorocarbons. CH4, N2O, and fluorinated gases would be 

emitted by the project; however, the anticipated level of emissions of these gases is much smaller 

than the level of CO2 emissions associated with the project.

Issue 3: Impact on Water Resources

This group of issues relates to the effects during premining, active mining, final reclamation and 

closure, and postmining phases on the quality and quantity of water for beneficial uses, wells, and 

stock watering. The loss of water available to riparian and other plant and animal habitat is addressed 

in Issues 4 and 5. 

Issue 3A: East Side Groundwater Availability

The proposed open-pit mine may reduce groundwater availability to private and public wells in the 

vicinity of the open pit. Household water availability could potentially be reduced. 

Issue 3B: West Side Groundwater Availability

Water needed to run the mine facility could reduce groundwater availability to private and public 

wells in the Santa Cruz Valley, specifically the communities of Sahuarita and Green Valley, Arizona. 

Household water availability could potentially be reduced. 

Issue 3C: Groundwater Quality

Construction and operation of the mine pit, waste rock, and leach facilities have the potential to 

exceed Arizona Aquifer Water Quality Standards. The mine pit could result in the creation of a 

permanent pit lake, which has the potential to concentrate dissolved metals and toxins and may lower 

pH levels. Likewise, disposal of waste material in surface facilities such as tailings, waste rock, and 

leaching operations could potentially contribute to degradation of the aquifer. 

Issue 3D: Surface Water Availability

Construction and operation of the mine pit, tailings, waste rock, and leach facilities have the potential 

to change surface water discharge to Davidson Canyon and Cienega Creek, portions of which are 

designated an Outstanding Arizona Water by the Arizona Department of Environmental Quality 

(ADEQ). Additionally, the availability of water for stock watering tanks could be reduced. 

Issue 3E: Surface Water Quality

Construction and operation of tailings, waste rock, and leach facilities have the potential to result in 

sediment or other pollutants reaching surface water and degrading water quality, leading to a loss of 

beneficial uses. If sediment enters streams, turbidity will increase, and State water quality standards 

could be exceeded. Downstream segments of Davidson Canyon and Cienega Creek are Outstanding 

Arizona Waters (Tier 3), which are given the highest level of antidegradation protection. As 

outstanding resource waters under the Arizona Revised Statutes (ARS), Tier 3 waters must be 

maintained and protected, with no degradation in water quality allowed. 

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Issue 4: Impact on Springs, Seeps, and Riparian Vegetation

Potential impacts on seeps, springs, and associated riparian vegetation could result from the alteration 

of surface and subsurface hydrology because of the pit and other operations. Potential impacts could 

include reduced or eliminated flow to seeps and springs and loss of, or change in, the function of 

riparian areas. 

Issue 5: Impact on Plants and Animals

This group of issues focuses on the effects on plant and animal populations and habitats. Many 

aspects of the mine operations have the potential to affect individuals, populations, and habitat for 

plants and animals, including special status species. This issue includes the potential for impacts on 

wildlife as a result of landscape alteration and as a result of light, noise, vibration, traffic, and other 

disturbance from the proposed mine operations. 

Issue 5A: Vegetation

The pit, plant, tailings and waste rock facilities, road and utility corridors, and other facilities have the 

potential to permanently change vegetation, and reclamation may not restore vegetation to preproject 

conditions. 

Issue 5B: Habitat Loss

Issue 5C: Nonnative Species

Issue 5D: Wildlife Movement

Issue 5E: Special Status Species 

Issue 5F: Animal Behavior

The mine and ancillary facilities could result in a loss or alteration of habitat for numerous plant and 

animal species. Potential impacts could include loss of riparian habitat and fragmentation of riparian 

habitat and corridors, including Cienega Creek. 

The mine and its operations have the potential to create conditions conducive to the introduction, 

establishment, and/or spread of nonnative species, which may out-compete native plants and animals. 

Forest Service and other Federal, State, and local laws, regulations, policies, and plans contain 

management direction for invasive plants. 

The mine and its operations could potentially modify and/or fragment wildlife habitats and/or reduce 

connectivity between habitats. Increased traffic could correspondingly increase wildlife mortality and 

injury. 

The mine and its operations have the potential to impact habitat for special status species (see the 

“Analysis Methodology, Assumptions, Uncertain and Unknown Information” part of the “Biological 

Resources” section in chapter 3 for a description of special status species). 

Mine construction, closure, and operations, including drilling and blasting, may result in noise and 

vibrations, which could impact animal behavior and result in negative impacts on wildlife. Nocturnal 

and other animals may be adversely affected by the light glow in night skies. 

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Issue 6: Impact on Cultural Resources

This group of issues focuses on the adverse effects of the proposed mine operations on cultural

resources. Mine operations could impact historic properties as well as traditional uses and perceptions 

of the land for the many communities who have used it over the past centuries. Native Americans 

claim the area as part of their ancestral homelands. Tribes consulted as part of the EIS process 

perceive disruption of the physical world as causing spiritual harm to the Earth and to the people 

here. Ancestral human remains and sacred sites are known to exist in the project area, as are 

traditional resource collecting areas. 

Ranching and mining communities also have attachments to the area that began in the late 19th

century and continue through the present. Comments submitted during public scoping identified 

impacts on the historic rural landscape as an issue, as well as impacts on traditional resource 

collecting areas and recreation venues. Historic human burials may yet be found in areas not 

excavated during previous archaeological investigations. 

Issue 6A: Historic Properties

Proposed mine activities, from premining through final reclamation and closure, would bury, remove, 

or damage historic properties, including traditional cultural properties, sacred sites, traditional use 

areas, archaeological sites, historical structures, districts, and landscapes. Vibrations from blasting 

and drilling could damage historical structures in the immediate and adjacent areas. This could also 

result in the loss of or reduction in the future research and public interpretation potential of known 

and yet-to-be-discovered sites, along with the permanent alteration of cultural landscapes important 

to the ongoing cultural practices of Native American tribes and other communities with cultural or 

historic ties to the project area. 

Issue 6B: Disturbance of Human Remains

Human remains have been discovered in previous archaeological excavations of prehistoric and 

historical sites in the Rosemont area. Additional burials are present in previously excavated and 

unexcavated historic properties and may be present in as-yet-undetected historic properties. Proposed 

mine activities, from premining through final reclamation and closure, have the potential to disturb 

human remains. Native American remains on Federal lands fall under the jurisdiction of the Native 

American Graves Protection and Repatriation Act (25 United States Code (U.S.C.) 3001); nonnative 

remains on Federal lands fall under the Advisory Council’s “Policy on Burial Sites, Human Remains 

and Funerary Objects on Federal Lands” (February 23, 2007). Arizona burial laws (ARS 41-844 and 

41-865) protect human remains on State and private lands.

Issue 6C: Sacred Sites

Several Federal laws direct Federal land management agencies, to the extent permitted by law and not 

clearly inconsistent with essential agency functions, to accommodate access to and use of Native 

American sacred sites, to avoid affecting the physical integrity of such sites wherever possible, and to 

temporarily close NFS land for traditional and cultural purposes. Tribal consultation has identified 

springs, high vision points, and many natural resources in the project area as having sacred 

ceremonial functions. Proposed mine activities, from premining through final reclamation and 

closure, could preclude access to or destroy or degrade these types of resources.

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Issue 6D: Traditional Resource Collecting Areas

Native Americans and the ranching, mining, and Mexican American communities use the Rosemont 

area to collect and process natural resources for food, medicines, firewood, and traditional crafts. 

Proposed mine activities, from premining through final reclamation and closure, could preclude 

access to or destroy or degrade these types of resources.

Issue 7: Impact on Visual Resources

This issue focuses on the visual impacts that would result from the proposed mine pit, placement of 

tailings and waste rock facilities, and development and use of other facilities. The proposed mine 

tailings and waste rock facilities would create significant changes to the landscape. The facilities may 

block valued mountain views. The processing plant, roads, and utility corridor could also affect visual 

resources in the area. The character of the SR 83 designated scenic corridor and the views from it 

may change. The ability for the area to meet assigned scenic integrity objectives in the forest plan 

could potentially be reduced. The scenic quality of the landscape may be permanently degraded. 

Issue 8: Impact on Dark Skies and Astronomy

This issue relates to the potential for the mine operation and facilities to reduce night sky visibility. 

Many area residents, recreationists, research and amateur astronomers, and stargazers value the 

current dark skies in the area. Increased light and air particulates from mine related facilities, 

equipment, vehicles, and processes have the potential to diminish dark skies. The increased sky glow 

could reduce the visibility of celestial objects, particularly the faint ones, which are often the subject 

of scientific study. Key observation points and the Smithsonian Institution’s Fred Lawrence Whipple 

Observatory could be adversely affected. 

Issue 9: Impact on Recreation

This issue focuses on the effects of the mine operation on recreation on NFS land, including loss of 

access and recreation opportunities and loss of or reduction in solitude, remoteness, rural setting, and 

quiet. The mine may lead to permanent changes to recreation settings (Recreation Opportunity 

Spectrum) and/or the type of recreation available and may result in increased pressure on public and 

private lands in other places to compensate for lost opportunities. 

Issue 10: Impact on Public Health and Safety

This issue focuses on the hazardous materials that would be transported and the potential increase in 

the risk of a spill or other public safety impact. Furthermore, an increase in traffic could reduce public 

safety by increasing the potential for traffic accidents. Another aspect of this issue is human health 

risks to forest visitors if they inadvertently come into contact with mine operations, tailings facilities, 

or waste rock facilities. Air quality impacts resulting from the operation could potentially be harmful 

to public health. 

Issue 11: Impacts on Social and Economic Resources

Mine operation could have both negative and positive socioeconomic impacts that could change over 

time. The socioeconomic stability of the area could be affected. Residents’, business owners’, and 

visitors’ expectations of national forests and the historic rural landscape may not be met. 

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Issue 11A: Regional Socioeconomics

The mine facilities and operation may result in changes over time to local employment, property 

values, tax base, tourism revenue, and demand and cost for road maintenance and emergency 

services. There may be costs to the alternative elements and mitigation measures that influence the 

present net value of the mine operations and, thus, its economic profile. 

Issue 11B: Rural Landscapes

The mine operation may not conform to the quality of life expectations as expressed by the forest 

plan and Federal, State, and local regulations and ordinances. Commenters expressed concerns about 

modification of rural historic landscapes and local ranching traditions, which are important to local 

residents and visitors. Commenters also expressed a need to assess impacts on quality of life, 

including the economic nature of these rural landscapes. 

Issue 12: Impact on Transportation/Access

This issue focuses on the impact of increased mine related traffic during premining, active mining, 

and final reclamation and closure. Transportation of personnel, equipment, supplies, oversize 

permitted loads, and materials related to the mine operation has the potential to increase traffic. 

The operations also have the potential to permanently obliterate forest roads or temporarily restrict 

access to forest roads and lands.

My Decision

This ROD documents my decision and rationale for the selection of “Alternative 4 – Barrel 

Alternative” (referred to in this ROD as the “selected action”). It also documents my finding that the 

proposed amendments to the forest plan are not significant (see finding on page 56 of this document). 

Alternative 4 (Barrel Alternative or selected action) is described in chapter 2 of the FEIS. It is also 

described in detail in appendix A of this ROD. My decision includes the associated transportation 

system, the design features, mitigation and monitoring measures (appendix B of the FEIS), and forest 

plan amendments (FEIS chapter 2, p. 117), as described in the FEIS. My decision allows 

development of the Rosemont mineral deposit in a manner that is consistent with the selected action. 

The selected action requires changes and additions to the preliminary MPO that are necessary to meet 

the requirements of regulations at 36 Code of Federal Regulations (CFR) 228 Subpart A and comply 

with applicable laws and regulations; these changes will be incorporated into a final MPO to be 

submitted to the Coronado by Rosemont Copper. 

My decision is based on a thorough review of the FEIS, review of public and agency concerns 

received on this project, consultation with cooperating and regulatory agencies, consultation with 

interested tribes, and the project record. I considered relevant scientific information, public concerns 

and opposing viewpoints, scientific uncertainty, and risk, which are discussed in the resource sections 

in chapter 3 of the FEIS. I am aware that there is incomplete or unavailable information for some 

resource analysis (also discussed in the resource sections in chapter 3 of the FEIS). In an effort to 

understand scientific uncertainty and resolve professional disagreement, I have also sought out and 

considered the professional opinion of resource specialists from Federal agencies, private industry, 

and third-party consultants. I have met on numerous occasions with interested members of the public 

to listen to their concerns and issues to help me in formulating this decision. 

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Responsiveness to the Purpose of and Need for Action

The selected action meets the stated purpose of and need to process Rosemont Copper’s MPO in a 

timely manner while complying with applicable laws and regulations, minimizing adverse impacts to 

NFS surface resources and provides for reclamation of surface disturbance. It will protect resources 

to the extent practicable, it addresses the public’s concerns, and it is consistent with applicable 

Federal laws and regulations. The selected action provides practicable environmental safeguards, 

including features designed to avoid or reduce environmental impacts; mitigation measures designed 

to avoid, reduce, or minimize impacts; and a monitoring plan to ensure that resulting impacts comply 

with applicable laws and regulations and are within the range predicted in the FEIS impacts analysis. 

Refer to chapter 2 of the FEIS for a description of the components of the Barrel Alternative (also 

contained in appendix A of this ROD) and to chapter 3 of the FEIS for a complete description of the 

environmental impacts predicted for the Barrel Alternative.

Responsiveness to the Issues

The selected action is responsive to the issues described in chapter 1 of the FEIS and summarized 

earlier in this ROD. The Barrel Alternative was developed to respond to significant issues regarding 

potential impacts on biological resources, cultural resources, and the surface water component of 

water resources. It also responds to the other significant issues through design features and mitigation 

measures that reduce potential environmental and social impacts. The topics presented in the section 

titled “Decision Rationale, Social and Environmental Benefits and Impacts” provide further 

information on how the selected action responds to the significant issues and how those were 

considered in making my decision. 

Decision Rationale

The Coronado National Forest comprises outstanding landscapes, with a diversity of resource values, 

and a rich history of human use and visitation. The Santa Rita Mountains, in which the project area is 

located, provide a spectrum of ecological conditions that support wildlife and plant communities, as 

well as human uses such as livestock grazing. The area also provides opportunities for a variety of 

recreational pursuits, such as hiking the Arizona National Scenic Trail, dispersed camping, or riding 

off-highway vehicles (OHVs). The area represents one of the large expanses of undeveloped public 

land remaining on the Coronado National Forest and is home to many rare plants, animals, and a vast 

array of valuable cultural sites. 

With these factors in mind, I did not take this decision lightly. My decision to approve the proposal is 

guided by Federal law. The primary guidance comes from the General Mining Act of 1872, which 

grants citizens the right to conduct mining activities on public lands that are open to mineral 

exploration. The Multiple-Use Mining Act of 1955 reaffirms the right to conduct mining activities on 

public lands, including mine processing facilities and the placement of mining tailings and waste 

rock. Although a right to conduct mining activities exists, proposals must comply with applicable 

Federal and State environmental protection laws, and the Forest Service can require reasonable 

measures, within their authority, to protect surface resources.

Conducting a mining operation of this type and size will undoubtedly impact the natural, cultural, and 

social resource values found on the Coronado National Forest as well as adjacent lands outside the 

forest. There will also be associated economic and job creation effects, as well as contributing to the 

worldwide demand for copper. This decision incorporates a wide array of mitigation and conservation 

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measures that will be required of the proponent to mitigate and reduce effects of the proposal. In 

addition, a comprehensive monitoring program will be implemented to verify that effects disclosed in 

the FEIS are within predicted ranges and to ensure that mitigation requirements are being met.

In reaching my decision, I have considered the purpose and need for action, the issues, the forest plan 

and associated amendments, current policies and regulations, effects on natural and cultural 

resources, public and cooperating agency comments received, and the full range of alternatives. I 

considered the broad range of concerns expressed throughout this process. Inherent with a project of 

this size and magnitude will be direct and indirect impacts to natural, cultural, and social resources on 

the Coronado National Forest and adjacent lands. My decision allows Rosemont Copper to develop 

its mineral resource while requiring a wide array of mitigation and monitoring steps that will 

minimize or avoid impacts on NFS lands to the extent practicable. Importantly, my decision 

implements an alternative that will allow Rosemont Copper to comply with applicable Federal laws 

and regulations. The following discussion summarizes pertinent aspects of my rationale for selecting 

the Barrel Alternative for implementation.

1. Decision Space. My decision authorizes actions on NFS lands. It will also trigger connected 

actions, some of which are under the jurisdiction of other agencies (i.e., the utility corridor 

located on State land is under the jurisdiction of ASLD; the SR 83 connected action is under 

the jurisdiction of ADOT). Those connected actions that are not on NFS lands will require 

authorization by the jurisdictional agency. See chapter 2 of the FEIS for further detail. 

The role of the Coronado under its primary authorities in the Organic Administration Act, 

Locatable Regulations (36 CFR 228 Subpart A), and Multiple-Use Mining Act is to ensure 

that mining activities minimize adverse environmental effects on NFS lands and comply with 

all applicable environmental laws. 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. Through the Mining and Mineral 

Policy Act, Congress has stated that it is the continuing policy of the Federal Government, in 

the national interest, to foster and encourage private enterprise in:

• The development of economically sound and stable domestic mining, minerals, and metal 

and mineral reclamation industries; and

• The orderly and economic development of domestic mineral resources, reserves, and 

reclamation of metals and minerals to help ensure satisfaction of industrial, security, and 

environmental needs. 

I recognize that each of the action alternatives would result in significant environmental and 

social impacts and that the no action alternative is the environmentally preferable alternative

(see page 46 of this ROD for further detail). However, Federal law provides the right for 

Rosemont Copper to develop the mineral resources it owns and to use the surface of its 

unpatented mining claims for mining and processing operations and reasonably incidental uses 

(see 30 United States Code (U.S.C.) 612). Pursuant to Federal law, the Forest Service may 

reasonably regulate the use of the surface estate to that minimize impacts to Forest Service 

surface resources, but cannot endanger or materially interfere with mining and processing 

operations and reasonably incidental uses (see 30 U.S.C. §612 and 36 CFR §228.1). The 

analysis that is disclosed in the Rosemont Copper Project FEIS concludes that the Barrel 

Alternative is the alternative that best achieves the minimization of impacts to Forest Service 

surface resources while allowing mineral operations and reasonably incidental uses.

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2. Social and Environmental Benefits and Impacts. When reviewing the results of the impact 

analyses disclosed in chapter 3 of the FEIS, I found there to be relatively few significant 

differences in the magnitude of impacts between the alternatives for many issues and 

resources. This is primarily due to the nature of the project, which resulted in practical 

constraints being imposed during development of the alternatives. Rosemont Copper’s 

mineral deposit is located in a fixed location, and the mine facilities are by necessity located 

nearby, and such uses of unpatented mining claims is allowed by Federal law. In addition, I 

find it to be critically important to minimize the amount of NFS land and resources impacted 

by the project, which further constrained the overall footprint of the mining facilities. 

Therefore, the differences between alternatives tend to focus on placement and design of the 

tailings and waste rock facilities, the variations of which have similar impacts.

Rosemont Copper brought forward a preliminary MPO that contained mineral processing 

practices (dry-stack tailings) that would result in a smaller footprint on NFS land than 

traditional processing methods. While an alternative that would include traditional slurry 

processing procedures was considered, I instructed the interdisciplinary team (ID team) to 

eliminate it from detailed study because preliminary assessment and past agency experience 

indicated that it would result in a significantly larger footprint on NFS lands and potentially

greater environmental impacts than would any of the alternatives considered. Therefore, I did 

not consider the inclusion of this alternative to be a good investment of time or resources. 

A number of other alternative themes and components suggested by public and agency 

comments and Forest Service staff were evaluated for detailed consideration in the FEIS.

Many were incorporated into the four alternatives to the proposed action that are considered 

in detail. Others were considered but eliminated from detailed study for variety of reasons. 

These are discussed in chapter 2 of the FEIS as well as in project record documents. 

Because there were relatively few significant differences between the overall impacts of the 

action alternatives, my decision came down to a few substantive differences or factors, as 

described below. 

A. Air Quality – Air quality was in issue identified during public scoping (see Issue 2). 

Legal compliance with air quality standards and regulations is determined by the agency 

with the delegated responsibility for administering the CAA, which in the case of the 

Rosemont Copper Project is the ADEQ. ADEQ has issued an air permit for the Rosemont 

Copper Project, and Rosemont Copper has the responsibility to remain in compliance 

with the permit. For the purposes of evaluating impacts and approving an MPO, I have a 

further responsibility to ensure that the proposed project as planned will minimize

impacts to surface resources on Forest Service land. Those surface resources include, 

among other things, public use of adjoining Forest Service lands for multiple-use 

objectives. To ensure the minimization of impacts to those Forest Service lands and to 

allow the continued use and enjoyment of those lands, I have determined that the selected 

action must have the ability to meet National Ambient Air Quality Standards (NAAQS) 

as specified in the CAA at the perimeter fenceline. NAAQS were adopted by the U.S. 

Environmental Protection Agency (EPA) to protect public health and public welfare. The 

selected action is the only action alternative that demonstrated the ability to meet 

NAAQS at the perimeter fenceline and thus comply with standards established to protect 

human health. 

• The Scholefield-McCleary Alternative would not meet NAAQS at the fenceline for 

particulate matter less than or equal to 2.5 microns in diameter (PM2.5) emissions;

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• The proposed action and Phased Tailings, Barrel Trail, and Scholefield-McCleary 

Alternatives would not meet NAAQs at the perimeter fenceline for particulate matter 

less than or equal to 10 microns in diameter (PM10).

• A number of additional mitigation measures were added for all action alternatives 

after the DEIS air analysis indicated that many alternatives would not meet NAAQS. 

At this time, no additional practicable onsite mitigation measures have been 

identified that would further improve the ability of the alternatives to meet NAAQS. 

The ADEQ issued an air quality permit on January 31, 2013, that provides for 

monitoring, reporting, and response actions. The permit will be updated following 

this decision to address any differences between the original permit application and 

the selected action. 

• With the exception of the selected action, none of the action alternatives are 

acceptable from an air quality perspective. While it may be possible to move the 

perimeter fence location for the these alternatives to a location where NAAQS would 

be met, I do not regard this as an acceptable option due to the increased amount of 

NFS land that would be included within the perimeter fence and therefore 

unavailable for public use. The impacts to many other resources for other action 

alternatives are similar to or greater than the selected action. Therefore, I have 

determined that there are no substantive benefits of selecting these other alternatives 

that would offset the additional reduction of access to NFS lands. 

• Regarding potential impacts to Class I airsheds, all alternatives are predicted to 

degrade views from Class I airsheds, including Saguaro National Park East, Saguaro 

National Park West, and the Galiuro Wilderness Area. This is primarily the result of 

fugitive dust emissions during severe weather events with high winds. The selected 

action has the same predicted impacts as three other action alternatives, while the 

Barrel Trail Alternative is predicted to impact only Saguaro National Park East and 

the Galiuro Wilderness Area. Mitigation measures to control fugitive dust have been 

developed and are required as conditions of the air quality permit, issued by ADEQ. 

While impacts to visibility from Class I airsheds are not desirable, this situation does 

not violate Federal, State, or county air quality laws or regulations. In addition, all 

practicable mitigation measures designed to reduce fugitive dust emissions from the 

project will be required. All alternatives are predicted to also increase nitrogen 

deposition at Saguaro National Park East, Saguaro National Park West, and the 

Galiuro Wilderness Area. Nitrogen deposition has already been estimated to exceed 

critical loads in these areas, and additional nitrogen deposition will contribute to this 

issue. Research indicates that responses to nitrogen deposition include alteration of 

species composition, specifically an increase in biomass of exotic species and 

decreases in native species. This, in turn, can result in management consequences, 

including changes in fire frequency and carrying capacity. While impacts to nitrogen 

deposition are not desirable, this situation does not violate Federal, State, or county 

air quality laws or regulations. In addition, all practicable mitigation measures 

designed to reduce nitrogen emissions from the project will be required. 

• Guidance developed by the Federal Land Managers Air Quality Related Values 

Working Group (FLAG) recommends approaches for Federal land managers for 

protection of air quality related values like visibility and deposition. Federal land 

managers have an “affirmative responsibility” to protect these values, even though 

they have no permitting authority under the CAA. This responsibility includes 

Draft Record of Decision – December 13, 2013

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identifying the potential for adverse effects to occur, which has been done in the 

FEIS, but also includes ensuring that all reasonable mitigation has been applied to the 

project. In coordination with other Federal agencies, I have requested that Rosemont 

Copper explore additional onsite mitigation, and I have determined that all 

reasonable mitigation has been applied to the project onsite. I also have requested 

that Rosemont Copper explore additional emission offsets within the airshed. This 

has resulted in Rosemont Copper developing additional offsite mitigation at the 

request of the Coronado to reduce nitrogen, such as carpooling and busing options 

that will reduce nitrogen emissions in the airshed. See “Air Quality and Climate 

Change” under “Mitigation and Monitoring Measures—Rosemont Copper” in 

appendix B of the FEIS for a description of the carpooling and busing option. 

B. Surface Water Flows – Surface water availability was an issue identified during scoping 

(see Issue 3D). The selected action will retain the greatest amount of downstream surface 

water flow into Barrel and Davidson Canyons. All of the action alternatives would reduce 

the amount of stormwater delivery into downstream drainages. However, as a result of 

design modifications intended to minimize reductions in stormwater downstream of the 

mine site, the selected action will result in the least reduction of any action alternative (17

percent reduction in average annual volume vs. 23 to 46 percent reduction for the other 

action alternatives). While any reduction in downstream flows is not desirable, the 

selected action does a better job of providing future flows into Barrel Canyon and 

Davidson Canyon than any other action alternative. 

C. Water Quality – Both surface water quality and groundwater quality were issues 

identified during public scoping (see Issues 3C and 3E). The selected action is similar to 

the other action alternatives with respect to the groundwater and surface water discharges 

that are planned to occur, specifically tailings seepage and stormwater runoff. For all 

alternatives, the seepage from the tailings facility is expected to meet aquifer water 

quality standards and for all alternatives stormwater runoff from the waste rock facility 

would not exceed applicable surface water quality standards in Barrel Canyon, except for 

some water quality parameters that are already observed in stormwater runoff (silver, 

lead, mercury). The selected action has less risk of unplanned releases due to the removal 

of the heap leach facility (discussed below). I recognize that protection of water quality is 

of great importance and that modeling and predictions have some uncertainty; therefore, I 

have incorporated a wide variety of monitoring measures to ensure that any unexpected 

changes in water quality are identified.

Portions of lower Davidson Canyon and Lower Cienega Creek, located downstream of 

the project, have been designated Outstanding Arizona Waters. Portions of Upper 

Cienega Creek located east of the project have also been designated Outstanding Arizona 

Waters. These waters are afforded the highest level of protection from degradation under 

State law. The State of Arizona has the sole authority to make a determination about 

whether or not the proposed project would violate State water quality regulations by 

degrading Outstanding Arizona Waters. The person seeking authorization for a regulated 

discharge to a tributary to, or upstream of, an Outstanding Arizona Water (in this case 

Rosemont Copper) has the responsibility to demonstrate to the State of Arizona that the 

regulated discharge will not degrade existing water quality in the downstream 

Outstanding Arizona Water. This demonstration by Rosemont Copper, and determination 

by the State of Arizona, has not yet been completed. Independent of this determination, 

the potential for degradation of Outstanding Arizona Waters was raised by the public as 

Draft Record of Decision – December 13, 2013

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an issue of importance and therefore the Forest Service has the responsibility under 

NEPA to take a “hard look” at the potential for degradation. The analysis in the FEIS uses 

criteria developed by the Forest Service to assess this potential using available 

information; however, the State of Arizona will make their own determination using their 

own regulatory criteria and the information available to them at the time, which could 

differ from that used by the Forest Service for the purpose of the NEPA analysis. 

I considered the effects of the project on these Outstanding Arizona Waters that will 

result from changes in both water quality and quantity. I consulted with the ADEQ, who 

has the responsibility to issue the State water quality certification as required under 

Section 401 of the Clean Water Act (CWA). While the water quality certification will be 

issued after my decision, ADEQ indicated to me that when the effects from the project 

were considered in light of mitigation to be applied to lower Davidson Canyon and 

monitoring requirements implemented by the Coronado, the antidegradation criteria 

required for the Outstanding Arizona Waters were likely to be met and the 401 water 

quality certification will be issued. I have included some monitoring requirements on 

lower Davidson Canyon requested by ADEQ. Ultimately, it is Rosemont Copper’s 

responsibility to demonstrate compliance with water quality standards and acquire the 

401 certification from the State prior to my approval of the final MPO. 

D. Sediment Delivery – Sediment delivery is a component of surface water quality (see 

Issue 3E). Apart from the Scholefield-McCleary Alternative, the selected action has the 

smallest reduction in sediment delivery of all action alternatives. Maintaining sediment 

delivery is desirable to minimize changes, such as scour, in the geomorphology of Barrel 

Canyon. The Scholefield-McCleary Alternative would result in more sediment delivery 

into downstream drainages. However the Scholefield-McCleary Alternative does not

meet the NAAQs. Refer to “Surface Water Quality” in chapter 3 of the FEIS for more 

information regarding sediment delivery. 

E. Subsurface Outflow – This is a component of groundwater availability, which was 

identified as an issue during public scoping (see Issues 3A and 3B). The selected action

will result in the smallest potential reduction in subsurface outflow to Cienega Creek.

Reduction in subsurface outflow is a direct result of reductions in stormwater flow 

downstream. While all action alternatives would likely reduce subsurface outflow to 

Cienega Creek over the long term, the selected action will result in the smallest reduction 

of any action alternative (4.4 percent reduction, compared with 11.7 percent reduction for 

the proposed action). This will result in less risk of impacts to springs, seeps, riparian 

vegetation, and related habitat near Cienega Creek than any of the remaining action 

alternatives.

F. Heap Leach Treatment Facility – The heap leach facility is a component of several 

issues that were identified during scoping, including groundwater quality (Issue 3C); 

dark skies and astronomy (Issue 8); and public health and safety (Issue 10). Removal of 

the heap leach from the selected action avoids or reduces a variety of environmental 

impacts. In response to comments received on the DEIS, I directed the ID team and 

Rosemont Copper to consider geomorphic reclamation concepts in the design of the 

selected action. One of the restrictive conditions I placed upon this effort was for no 

expansion of the tailings and waste rock facility footprint. My intent for this specific 

restriction was to avoid impacting additional NFS lands, including nearby areas that 

contain cultural sites (including the prehistoric Ballcourt Site), wildlife and plant habitat 

(including habitat for threatened, endangered, and sensitive species and the biological 

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diversity of McCleary Canyon), and WUS. As a result of these efforts, Rosemont 

Copper redesigned the stormwater facilities in order to route more water into Barrel and 

Davidson Canyons postclosure. During this redesign, Rosemont Copper determined that 

including the heap leach facilities within the existing tailings and waste rock footprint of 

this alternative would not be economical. Rosemont Copper volunteered to remove the 

heap leach facility and process from only the selected action, a modification I approved 

because it reduces or avoids a number of environmental impacts, including the 

following: 

• Avoidance of any risk of groundwater contamination from heap leach seepage. 

• Reduction of impacts to WUS. Although Scholefield-McCleary would have impacted 

19.5 fewer acres of WUS, it does not meet the CAA. Of the remaining alternatives, 

the selected action will impact the fewest acres of WUS (68.4 acres).

• Slightly reduced sky brightness from artificial night lighting. Since the selected 

action eliminates the need for lighting the heap leach and associated facilities during 

night operations, it will have slightly reduced sky brightness, compared with other 

action alternatives (it eliminates approximately 105,500 lumens, for a total estimated 

6.4 million lumens for the selected action). This slightly reduces the observed 

fractional increase in sky brightness at the Whipple Observatory; Jarnac Observatory; 

Corona de Tucson; SR 83; and Empire Ranch. 

• Reduced risk of release of hazardous materials into the environment. Specifically, 

removal of the heap leach process from this alternative eliminates the need for 

sulfuric acid and kerosene, thereby avoiding any risk of accidental release of these 

materials into the environment during transportation, use, or storage. 

• Reduced number of trips of hazardous materials to the mine due to the elimination of 

sulfuric acid and kerosene shipments. The number of trips will decrease from 157 per 

week to 94 per week, a reduction of 63 trips per week, or 40 percent. This will reduce 

potential emergency response to accidents or spills of these materials. 

I chose to remove the heap leach from only the Barrel Alternative. Rosemont Copper’s 

engineering and design team worked with the Coronado and its consultants throughout 

the process described above in order to provide me with recommendations regarding both 

the technical and financial feasibility of refined designs. In June and July 2012, 

Rosemont Copper undertook preparation of detailed stacking and engineering plans. On 

July 10, 2012, Rosemont Copper informed me that the operational sequencing required 

under the Barrel Alternative did not allow them sufficient time to complete the leaching 

process and fully recover the copper from the oxide ore materials. Because the other

action alternatives did not have such a restrictive operational sequencing requirement, 

Rosemont Copper determined that it could complete the leaching process within the 

designs of those alternatives. 

After reviewing the refined design of the Barrel Alternative and public and agency 

comments on the DEIS, Rosemont Copper informed me that both the heap leach and 

underdrains would need to be removed from the refined Barrel Alternative design and 

that doing so for the Barrel Alternative would be: (1) both technically and financially 

feasible, though not optimal; and (2) acceptable to the proponent. In doing so, Rosemont 

Copper proposed to the Coronado that the heap leach processing and associated facilities 

be removed from the Barrel Alternative. Rosemont Copper also had recently updated its

internal mine feasibility studies with additional drilling on its private holdings and 

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determined that the sulfide ore reserves were larger than originally thought. Thus, the 

removal of the oxide heap leaching circuit became a viable option from an economic 

standpoint. 

I reviewed the refined design for the Barrel Alternative in light of Rosemont Copper’s 

suggested removal of the heap leach. It is important to note that I do not have the legal 

authority to impose mitigation that would materially interfere with mineral operations. 

While the National Environmental Policy Act (NEPA) allows the consideration of 

reasonable alternatives that are outside the jurisdiction of the lead agency, such conflicts 

must be considered. I considered whether to apply removal of the heap leach process and 

facilities to any additional alternatives and determined that application to only the Barrel 

Alternative would accomplish several goals. First, I recognized that this as an opportunity 

to reduce impacts, respond to public and agency comments, and reduce the need for longterm maintenance of a heap leach facility that could affect NFS surface resources and 

groundwater quality. Secondly, by applying it only to the Barrel Alternative, it would 

help in more “sharply defining the issues and providing a clear basis for choice among 

options by the decision maker and the public” (40 CFR 1502.14). 

Ultimately, I decided to modify the Barrel Alternative by removing the heap leach 

processing facility as well as the underdrains from the Barrel Alternative and retaining 

the refinements to the Barrel Alternative design that arose out of the Coronado ID team’s 

geomorphic reclamation process (i.e., modified stormwater structures, fewer benches, 

and contouring and shaping of the benches and upper portion of the landform). 

G. Disturbance Acres – Disturbance acres are a component of most of the issues that were 

identified during scoping. Generally speaking, the more acres that are disturbed, the 

greater the likelihood of increased impacts. Disturbance acres apply to Issues 1, 2, 3, 4, 5, 

6, 7, and 9. 

The selected action will disturb fewer acres than the other action alternatives. The 

selected action will result in the smallest amount of acres directly disturbed of all the 

action alternatives. The constrained footprint of the tailings and waste rock facilities 

incorporated into the design of the selected action avoids impacts in a number of ways:

• As previously mentioned, the selected action will result in fewer acres of WUS

directly impacted, compared with other alternatives that comply with applicable law 

and regulation.1

 

• The selected action will directly disturb the fewest acres of riparian acres of any action 

alternative (588 acres, compared with 631 to 686 acres for the other action 

alternatives). In addition, the selected action will directly impact the fewest number of 

springs of any of the action alternatives (5, compared with 7 to 13). Along with riparian 

habitat, these springs provide aquatic habitat and surface water that support wildlife 

and plants, including species that are listed as threatened, endangered, or sensitive.

• The fewest acres of terrestrial vegetation will be lost or modified. The project and 

connected actions under the selected action will directly impact or modify the fewest 

acres of terrestrial vegetation, which provides habitat for a number of plant and animal 

species, including those listed as threatened, endangered, or sensitive (5,431 acres for the 

Barrel Alternative, compared with 5,481 to 6,197 acres for the other action alternatives).

1 As mentioned earlier in this section, neither the Barrel Trail Alternative nor the Scholefield-McCleary Alternative would 

comply with the CAA. 

Draft Record of Decision – December 13, 2013

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• The selected action will result in the smallest amount of disturbed area that will be 

conducive to invasive plants. While the impacts of potential invasive plant 

establishment are expected to be largely mitigated through monitoring and treatment 

requirements, the remaining risk will be reduced with the selected action due to the 

fewer acres that are conducive to invasive plan establishment. 

• The selected action will result in the lowest potential reduction in livestock grazing 

on Federal grazing allotments. The potential reduction in Annual Unit Months 

(AUMs) (a measurement of livestock use consisting of a cow-calf pair using the 

allotment for 1 month) annually over the life of the mine will be lowest with the 

selected action. This is primarily attributable to the location of the perimeter fence, 

within which the livestock grazing analysis assumes grazing will be restricted. Actual 

reduction in AUMs is expected to be lower than those described in the analysis 

because the area between the perimeter and security fences will be evaluated for 

grazing potential once perimeter fence construction is completed and regularly 

during mine operation. The reduced footprint of the waste rock and tailings facilities, 

and thus reduced acreage within the security fence with the selected action, will 

likely allow a higher number of AUMs than will the other action alternatives.

H. Biological Resources – Biological resources were identified as an issue during scoping 

(see Issue 5). I consider the selected action to have the smallest impact of all the action 

alternatives to biological resources, including special status species (federally listed 

threatened, endangered, and sensitive species, as well as some migratory birds and Forest 

Service management indicator species). The overall conclusions of impacts to species 

viability are the same for all action alternatives. However, there are differences between 

the action alternatives in how they respond to the issue indicators chosen to reflect 

impacts. I considered the following in making my decision:

• The selected action will result in the smallest amount of acres of terrestrial vegetation 

permanently lost or modified; 

• The selected action will result in impacts to fewer acres of terrestrial and aquatic 

habitat for most special status species;

• The selected action will result in less overall impact in animal movement corridors 

and connectivity between wildlife habitats. Under the selected action, McCleary 

Canyon will remain largely intact, which is the most physically and biologically 

diverse of the nearby canyons and which harbors the rare plant Coleman’s coral-root 

(Hexalectris colemanii). Due to the protection of McCleary Canyon, I consider the 

selected action to have the smallest impact of the action alternatives in terms of 

impacts to animal movement corridors and connectivity between wildlife habitats.

I. Cultural Resources – Cultural resources were identified as an issue during scoping (see 

Issue 6). I considered impacts to cultural resources carefully in my decision. Each of the 

action alternatives will have significant, permanent adverse impacts to cultural resources.

The action alternatives differ in the number of sites impacted, and some alternatives 

clearly have more impacts than others. Cultural sites are resources that cannot be restored 

once impacted, and this project will impact several sites irrespective of which action 

alternative is chosen for implementation. I recognize that every site is significant, and I 

do not take lightly small differences in the number of sites impacted. 

Draft Record of Decision – December 13, 2013

18 Rosemont Copper Project, Coronado National Forest

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• Considering the overall results of the cultural resource impact analysis, I believe that 

the Barrel Trail and Scholefield-McCleary Alternatives would result in the greatest 

impacts of the action alternatives. 

• Of the remaining three alternatives, the selected action will impact the fewest sacred 

springs (16 for the selected action, compared with 17 for the proposed action and 

Phased Tailings) and will impact the fewest sites that are eligible for the National 

Register of Historic Places (NRHP) (84 for the selected action and Phased Tailings, 

compared with 86 for the proposed action). 

• Of the remaining three alternatives, the selected action (and Barrel Trail) will impact 

the greatest number prehistoric sites known or likely to have human remains (32, 

compared with 31 for the Phased Tailings Alternative); and will impact the greatest 

amount of acres of traditional resource collection areas impacted (6,990 acres, 

compared with 6,073 to 6,176 acres for the other action alternatives). 

• The selected action carefully avoids impacting one of the more significant cultural 

sites (the Ballcourt Site) because of the reduced footprint of the tailings. 

I carefully considered the impacts to the Ce:wi Duag Traditional Cultural Property and 

Huerfano Butte Traditional Cultural Property, located on State land. I also recognize the 

cultural significance and importance of the Santa Rita Mountains to the tribes. All action 

alternatives would have similar impacts to the Santa Rita Mountains. In making my 

decision to implement the selected action, I consulted with a number of tribes, the 

Arizona State Historic Preservation Office (SHPO), and the Advisory Council on Historic 

Preservation (ACHP), which resulted in a signed memorandum of agreement (MOA) that 

was developed in compliance with Section 106 of the National Historic Preservation Act

(NHPA) and the 2003 Region 3 First Amended Programmatic Agreement Regarding 

Historic Property Protection and Responsibilities with the four SHPOs and the ACHP. 

The MOA is incorporated with this ROD (see appendix D of the FEIS). I reviewed the 

sites that would be impacted by the action alternatives, the traditional resource collection 

areas that would be affected, and the sum of other environmental and social impacts that 

would result from each alternative.

I decided to select the selected action for implementation, even though it will impact 

more sites and acres of traditional collection resource areas than some other alternatives, 

for the following reasons:

• The Barrel Trail and Scholefield-McCleary Alternatives would result in substantially 

greater impacts to cultural resources than the other action alternatives, and for that 

reason, along with other environmental and social impacts, these alternatives are 

unacceptable to me.

• The proposed action and Phased Tailings Alternative have greater environmental 

impacts as described elsewhere in this ROD and are therefore unacceptable to me.

J. Paleontological Resources – Paleontological resources were not identified as an issue 

during scoping; however, they were addressed in the analysis that is disclosed in the FEIS 

(see “Geology, Minerals, and Paleontology” in chapter 3). I am aware that paleontological

impacts are predicted to be greater with the selected action than with one or more of the 

other action alternatives. In making my decision, I considered the following:

• Potential impacts to paleontological resources. The selected action will result in more 

acres of disturbance to areas considered to have a moderate to high potential for 

occurrence of paleontological resources, compared with some other action 

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alternatives. While no significant fossil localities were discovered within the 

proposed perimeter fence boundary during the paleontological resources field 

surveys, I have included a mitigation measure that requires ground-disturbing work 

in an area to stop upon discovery of a significant paleontological resource until the 

Forest Service can investigate and determine the appropriate steps prior to 

commencement of operations. Therefore, I do not consider the slight increase in risk 

of impacting potential paleontological resources with the selected action to be great 

enough to outweigh the reduced or avoided impacts previously described. 

K. Springs, Seeps, and Riparian Vegetation – Seeps, springs, and riparian vegetation were 

identified as issues during scoping (see Issue 4). Stock tanks are also addressed here as 

well as under “Livestock Grazing” in the impact analysis that is addressed in chapter 3 of 

the FEIS. 

The analysis of potential impacts to seeps, springs, and riparian areas is complex and 

relies on a number of variables. Including a summary of analysis methodology is 

warranted in order to all an understanding of the potential impacts from the action 

alternatives. A more thorough description is contained in “Seeps, Springs, and Riparian

Areas” in chapter 3 of the FEIS.

Flow from seeps and springs in the analysis areas can be attributed to the following: (1) 

discharge of shallow subsurface fracture flow that is directly dependent on storm and 

runoff events and that may or may not be in direct hydraulic connection with the 

groundwater flow system; (2) discharge of groundwater via fractures that intersect land 

surface and that are in connection with the regional groundwater flow system; (3) 

discharge from the recent stream channel alluvium or other shallow aquifer, where it is 

forced to flow to land surface at bedrock constrictions; and/or (4) discharge of 

groundwater along low-permeability fault zones that force groundwater to flow to the 

land surface. 

For many of the seeps and springs considered for this analysis, the exact source of 

groundwater is unknown. The source of water is important to predicting impacts to 

springs. Springs hydraulically connected to the regional aquifer are likely to be impacted 

by groundwater drawdown associated with the mine pit. Springs that receive water from 

local fractures or that are located in ephemeral stream channels may not be impacted, 

even when they are in close proximity to the pit. Many springs may have a mix of 

regional and local water sources. For springs, seeps, and perennial and intermittent 

stream reaches, the following qualitative thresholds were established to reflect this 

uncertainty and are used in this analysis: 

• High likelihood of impact – The predicted changes in hydrology due to the mine 

would impact resource function, and the source of water can either be estimated with 

high certainty to be connected with the regional aquifer, or impacts would occur no 

matter what the source of water. 

• Possible impact – Reduction in flow could occur, given predicted changes in 

hydrology as a result of the mine, but uncertainty exists regarding the source of the 

water. Springs that have not been physically located in the field are assumed to exist, 

and impacts are considered possible. 

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• Unlikely to be impacted – Predicted changes in hydrology as a result of the mine are 

small enough that they are unlikely to cause a reduction in flow, regardless of the 

source of water, or the source of the water is local and unlikely to be affected by 

aquifer drawdown associated with the pit. Springs that fall beyond the modeled 5-

foot drawdown contour are considered unlikely to be impacted. 

The FEIS analysis made use of available data where the data were deemed sufficient to 

determine the source of water for individual springs. Only field observations over several 

years or seasons have provided this level of evidence. For springs without such evidence, 

springs are assumed to have the potential to be impacted. 

When all springs impacts are considered (directly impacted by surface disturbance, 

highly likely to be indirectly impacted by groundwater drawdown, and possibly 

indirectly impacted by groundwater drawdown), most of the action alternatives are 

identical, each potentially impacting 76 springs or seeps, except for the ScholefieldMcCleary Alternative, which would potentially impact 78 springs or seeps.

I recognize that seeps, springs, and riparian areas are a valuable resource and that once 

impacted, they are unlikely to be restored. However, there is substantial uncertainty 

regarding the ability to predict indirect impacts to springs. For this project, the cause of 

indirect impacts to seeps and springs results from predicted groundwater drawdown. 

Seeps and springs whose water source is not tied to groundwater (refer to the “Seeps, 

Springs, and Riparian Areas” section in chapter 3 of the FEIS for further information) are 

not likely to be affected by groundwater drawdown, and it is not feasible to determine the 

source of water for every spring. While the analysis disclosed in the FEIS has attempted 

to address this situation by considering relevant factors such as the presence of perennial 

water and riparian vegetation, uncertainty remains. Therefore, I consider those springs 

with either direct impacts or highly likely indirect impacts to be the most significant 

factor related to seeps and springs influencing my decision. 

When considering just those springs that are directly impacted by surface disturbance or 

that are highly likely to be indirectly impacted by groundwater drawdown, the selected 

action (and Barrel Trail) impact fewer springs (16 total, with 5 springs directly impacted 

and 11 springs indirectly impacted). The other action alternatives impact 17 to 22 

springs.

However, these impacts will be reduced somewhat through required mitigation and 

monitoring focused on replacing impacted water sources. Under terms and conditions of 

the biological opinion (BO), which are also described in mitigation measure FS-BR-05, 

Rosemont Copper will replace or enhance up to 30 water sources if they are impacted by 

the project. Because of the uncertainty of effects on springs and seeps, FS-SSR-02 is a 

requirement that Rosemont Copper continue to monitor 25 springs with baseline data to 

identify any impacts that may occur due to dewatering of the regional aquifer in the 

vicinity of the mine pit. Additionally, the Cienega Creek Watershed Conservation Fund 

(FS-BR-16) can be used for monitoring of success of replacement or enhanced water 

features. If springs levels decrease, mitigation can come from this fund. I consider the 

impacts of all action alternatives to be similar with mitigation applied. 

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In addition, the selected action and Barrel Trail Alternative would result in the greatest

impact to stock tanks of all the action alternatives (15 tanks directly lost and 5 indirectly 

impacted).

Another factor related to the seeps, springs, and riparian issue includes acres of riparian 

area disturbed. The selected action will impact the fewest acres of riparian area of the 

action alternatives (588 acres for the selected action, compared with 631 to 686 acres for 

the other action alternatives). Other factors analyzed for this issue include change in the 

function of riparian areas; and the ability to meet legal and regulatory requirements for 

riparian areas. There are no differences between the action alternatives for these factors. 

Seven criteria were developed by the Coronado and assessed for impacts to Outstanding 

Arizona Waters. With respect to Lower Davidson Canyon and Lower Cienega Creek, 

analysis suggests that several constituents, including sulfate, molybdenum, arsenic, 

sodium, and mercury, may be elevated in stormwater with all action alternatives. Waste 

rock segregation requirements are likely to reduce this potential. All other criteria will 

likely remain unchanged for Lower Davidson Canyon and Lower Cienega Creek. With 

respect to Upper Cienega Creek, predictions are mixed. Few changes are predicted in the 

near term (up to 50 years after closure). In the long term, some modeling scenarios 

suggest that intermittent or ephemeral flow conditions could occur, as could increases in 

the frequency of low-flow conditions, which could affect water quality. All other criteria 

will likely remain unchanged for Upper Cienega Creek.

With all action alternatives, hydroriparian habitat along Empire Gulch could transition to 

mesoriparian or xeroriparian, although this is highly uncertain. Pockets of mesoriparian 

habitat along Davidson Canyon (Reach 2) could transition to mesoriparian or 

xeroriparian with moderate certainty. Xeroriparian habitat in lower Barrel Canyon is 

highly certain to experience reduced vitality, extensiveness, and health and to transition 

to lesser quality habitat. Along Upper Cienega Creek, there is unlikely to be any 

transition from hydroriparian to xeroriparian habitat, although some changes could occur 

at the margins of the hydroriparian corridor. 

Since there is no difference between the action alternatives for these two factors, they did 

not influence my decision. 

L. Visual Resources – Visual Resources is an issue that was identified during scoping (see 

Issue 7). While there are differences between the action alternatives related to impacts to 

visual resources, I do not consider the differences between the alternatives to be 

substantial. All alternatives would result in permanent, major adverse impacts, although 

the Scholefield-McCleary Alternative ranks as having the greatest impacts because its 

tailings and waste rock facilities would be visible from the west side of the Santa Rita 

Mountains. The selected action generally ranks in the middle of all action alternatives for:

• area that would not meet current forest plan scenic integrity objective designations; 

• change in landscape character over time; 

• miles of project visibility from level 1 and 2 forest roads and trails; 

• miles of SR 83 with direct views of the project; and 

• miles of Arizona National Scenic Trail with views of the project. 

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However, the differences between alternatives are not substantive enough to modify my 

overall conclusion that permanent, major adverse impacts that cannot be avoided or 

mitigated will occur with all action alternatives. With the exception of the ScholefieldMcCleary Alternative, the minor differences between alternatives are not substantive 

enough to sway my decision toward or away from one alternative or another. 

M. Recreation and Wilderness Resources – Recreation and wilderness resources is an 

issue that was identified during scoping (see Issue 9.) Other than the ScholefieldMcCleary Alternative, which would have the greatest impacts to recreation and 

wilderness, there is little difference in the impacts between the action alternatives. The 

minor differences are:

• impacts to Recreation Opportunity Spectrum;

• percentage of hunt unit 34A affected; and 

• National Forest System Roads (NFSRs) lost (i.e., roads currently available for legal 

public motorized use that would not be available with project implementation). 

The differences in these impacts are not substantive enough to sway my decision toward 

or away from any of the alternatives. 

The location for the Arizona National Scenic Trail was a consideration in my decision. 

Based upon the analysis and my personal knowledge of the area, I believe that the 

location on the east side of SR 83 is superior to the location on the west side of SR 83 in 

terms of providing a desired user experience. While the east side location is a component 

of the selected action, Barrel Trail, and Scholefield-McCleary Alternatives only, it is a 

mitigation measure that I can apply to any alternative. My decision includes relocation of 

the Arizona National Scenic Trail on the east side of SR 83; however, it was not a 

significant factor in my decision because I could choose to apply this component to any 

of the action alternatives. 

• Impacts to public access. Scholefield-McCleary has the greatest impact of any of the 

action alternatives, while there is little difference between the remaining alternatives.

The other four action alternatives would decommission and restrict public access on 

17.5 to 18.5 miles of NFSRs that are currently open to public motorized use. This is 

primarily due to excluding public access within the perimeter fence. Other than the 

Scholefield-McCleary Alternative, I did not consider the difference between the 

action alternatives to be substantive enough to influence my decision toward or away 

from any of the alternatives. 

• It is important to note that most action alternatives include new road construction

designed to connect roads that will be cut off by the perimeter fence, provide 

turnarounds, and connect the primary access road to a NFSR network in Sycamore 

Canyon. Because of the geographic aspect of the perimeter fence for ScholefieldMcCleary Alternative, new connector roads are not included. Overall, I consider 

these connector roads to be critical for reducing or compensating for the loss of 

public motorized access. However, other than the Scholefield-McCleary Alternative, 

these actions are similar between the remaining action alternatives and thus were not 

a major factor in my decision.

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N. Socioeconomics and Environmental Justice – Social and economic resources were 

identified as issues during scoping (see Issue 11). Environmental justice was not 

identified as an issue but is addressed in the analysis that is disclosed in chapter 3 of the 

FEIS (see “Socioeconomics and Environmental Justice”). There would be few 

differences between action alternatives in terms of their socioeconomic and 

environmental justice effects. 

• Tourism. The analysis indicated that the selected action could result in a greater 

reduction in tourism and recreation revenue over time than the proposed action or 

Phased Tailings Alternative (the Barrel Trail and Scholefield-McCleary Alternatives 

would result in greater impacts; refer to the “Socioeconomics and Environmental 

Justice” section in chapter 3 of the FEIS for further information). As noted earlier, 

the Phased Tailings Alternative would not attain NAAQS at the perimeter fenceline. 

The analysis of impacts to tourism indicates that the selected action could result in 

direct annual reduction in spending related to nature-based tourism of $100,000 to 

$400,000 greater than the proposed action; and indirect effects in output per year of 

$111,000 to $400,000 greater than the proposed action. While I consider any 

negative impacts to local economies to be important, the difference between the 

selected action and the other action alternatives did not rise to a level that influenced 

my decision toward or away from any specific alternative.

• Amenity-based relocation. The analysis indicates a 0.01 percent difference in net 

migration to Santa Cruz County between the alternatives (impacts range from 0.08 to 

0.09 percent decrease in net migration). I did not regard this difference to be of 

substantial magnitude to influence my decision toward or against any specific 

alternative. The analysis also indicates a potential decrease in the rate of population 

growth in Patagonia Census County Division of between 6 to 33 percent to 6 to 38 

percent. The selected action was projected at 6 to 37 percent decrease in population 

growth. This projection did not influence my decision toward or away from any 

specific action alternative for two reasons: (1) similar to predicting impacts to 

tourism and recreation revenue discussed above, there is considerable uncertainty in 

this analysis; and (2) the analysis of this issues indicates that any decrease in 

amenity-based migration may be offset by an increase in mine staff relocation.

O. Astronomy Industry – This is a component of Issue 8, “Impacts on Dark Skies and 

Astronomy,” which was identified during scoping. All action alternatives could 

potentially result in some impairment to observatories near the project area. However, the 

night lighting mitigation plan that applies to all alternatives except the proposed action 

will substantially reduce potential impacts. Although the mitigation plan is not included 

as a component of the preliminary MPO, which is reflected in the proposed action in the 

FEIS, I could decide to apply it to any of the action alternatives. The selected action has 

somewhat less lighting required than the Phased Tailings, Barrel Trail, and ScholefieldMcCleary Alternatives because of the removal of the heap leach facility and therefore 

will have less impact on sky brightness than the other action alternatives.

P. Other factors – A number of other resources were addressed in the analysis. However, in 

general, there were no or very minor differences between the alternatives in terms of their 

impacts. Therefore, the results of these impact analyses were not a substantial influence 

in my decision. 

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24 Rosemont Copper Project, Coronado National Forest

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Conclusion – Determination of Selected Action

After reviewing the analysis and supporting information contained in the FEIS and project record; 

consulting with cooperating and regulatory agencies; reviewing public comments on the DEIS; and 

considering the factors discussed above, I determined that the selected action is the best balance of 

minimizing impacts to NFS resources as well as other environmental and social values. This 

alternative will allow Rosemont Copper to meet applicable laws and regulations and has reduced 

impacts, compared with other alternatives, while allowing Rosemont Copper to develop its mineral 

resources in a manner that is consistent with applicable laws and regulations, and this decision.

The selected action contains a number of design features that will avoid or reduce environmental 

impacts, as well as a comprehensive mitigation and monitoring plan that will reduce overall impacts 

and ensure that impacts are within the range that are predicted by the analysis that is disclosed in the 

FEIS. There is no one action alternative that completely mitigates or eliminates effects on important 

resource values when the proposal results in the placement of 1.3 billion tons of waste rock and 

tailings on the landscape. The challenge is selecting an alternative that represents the best balance of

mitigating effects and avoiding significant impacts to cultural, social, and resource values while 

allowing mining activities authorized in Federal law. It is my determination that the selected action

best meets these goals. 

Description of the Selected Action 

The selected action is fully described in chapter 2 of the FEIS and in appendix A of this ROD. The 

selected action contains changes and additions to Rosemont Copper’s preliminary MPO (“Alternative 

2 – Proposed Action”) and includes design modifications, operational components, and mitigation 

and monitoring plans intended to minimize the risk of adverse impacts to the environment. A 

summary of the major aspects of the selected action follows. Figure ROD-2 depicts the footprint and 

major components of the selected action. 

The selected action will develop Rosemont Copper’s mineral deposit using open-pit mining 

techniques. The mine will consist of an open pit; plant site and support facilities; waste rock and 

tailings facilities; and ancillary facilities, including access and maintenance roads and electrical 

supply and water supply lines. The pit will require 18 to 24 months to fully develop and will be 

between 6,000 and 6,500 feet in diameter, with a final depth of about 3,050 feet above mean sea 

level. The pit will disturb about 955 acres, of which 590 acres are private lands and 365 acres are 

NFS lands. 

During the 18- to 24-month preconstruction phase, other activities will include construction of a 

security fence that will be located approximately 750 feet from the eventual toe of the tailings and 

waste rock facilities; construction of a perimeter fence to protect public health and safety (see figure 

ROD-2), construction of the primary access road, including its intersection with SR 83; temporary 

improvements of an intersection at SR 83 and NFSR 231; and improvement to NFSR 231 to allow 

access to the mine site while the primary access road is being constructed. The area within the 

perimeter fence will be closed to the public for the premining through reclamation and closure 

periods, totaling up to 30 years. An estimated 35 miles of NFSRs will be decommissioned and 18.5 

miles of NFSRs restricted by mine operations. An estimated 3.2 miles of new roads will be 

constructed to connect cut-off roads, including the 2.3-mile-long Sycamore Connector Road, which 

will connect the primary access road outside the perimeter fence to an existing NFSR in the 

Sycamore Canyon area north of the mine site (figure ROD-3). 

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Figure ROD-2. Selected action footprint

Draft Record of Decision – December 13, 2013

26 Rosemont Copper Project, Coronado National Forest

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Figure ROD-3. Road changes under the selected action

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A utility maintenance road will be located within the utility corridor (see “Connected Actions,” 

below) to serve as access to the power supply line, water supply line, and water booster pump 

stations. The road will consist of two discrete segments: one from the plant site, over Lopez Pass, to a 

major wash on private land; and another from the supply wells near Sahuarita to the other side of the 

major wash, generally following the electrical transmission and water line location (the wash itself 

will not be crossed by the utility maintenance road). Overall, this low-use road will require more than 

11.5 miles of new construction and 4.5 miles of reconstruction or upgrade to an existing road. Other 

connected actions associated with the selected action include construction of a 138-kilovolt (kV) 

electrical transmission line and associated facilities; construction of a water supply line and ancillary 

facilities; relocation of an existing electrical distribution line; and relocation of the Arizona National 

Scenic Trail. See “Connected Actions” below and in chapter 1 of the FEIS for further details. 

Active mining will occur for an estimated 20 to 25 years. Blasting in the pit will typically occur once 

per day during daylight hours. Mineral material will be transported from the pit to a crusher in mine 

haul trucks; following crushing, the mineral material will be transported via conveyors to the grinding 

and flotation unit. Dewatered tailings will be transported using a conveyor system from the 

dewatering plant to the tailings facility for final placement. The conveyors will transfer the tailings to 

a radial stacker, and the tailings will then be spread and compacted by a dozer. The compacted 

tailings will be encapsulated by a perimeter buttress formed of waste rock and a waste rock “cap” that 

will be placed by haul trucks traveling on haul roads. Over the life of the mine, it is estimated that 

707,471,000 tons of sulfide ore will be processed and 1,249,161,000 tons of waste rock produced. 

Reclamation will occur concurrently with active mining. This consists primarily of continuous 

construction of the perimeter buttresses, with revegetation activities and application of appropriate 

best management practices (BMPs) beginning as early as year 1, as portions of the waste rock 

buttress are completed. A large portion of the waste rock perimeter buttresses that surround the 

tailings facility and the waste rock facility itself will be concurrently reclaimed by year 10; these 

areas will begin to discharge water downstream as reclamation is completed. The upper benches and 

tops of the waste rock and tailings facilities will be reclaimed beginning in year 16 but will not be 

completely reclaimed until the mine is fully closed. This will help to limit erosion potential and allow 

noncontact stormwater runoff to discharge to sediment ponds and eventually to washes downstream 

of the mine site. 

Final reclamation and closure is expected to take an additional 3 years, for a total mine life of 24.5 to 

30 years. Reclamation and closure consists of several components, including: 

• Removal of all equipment and buildings; 

• Capping of the top of the tailings facility with waste rock upon closure; 

• Removal of pond liners as deemed appropriate; 

• Regrading and revegetation of the plant and mill site areas upon closure;

• Regrading and revegetation of any access roads requiring closure; 

• Removal of electric supply line, water supply line, and related facilities from NFS 

lands; 

• Revegetation of utility corridors where removal causes soil disturbance;

• Final reclamation and revegetation of the landform that encompasses the waste rock 

and tailings facilities;

• Removal of perimeter and security fencing; 

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• Construction of fencing and/or berms for safety considerations; 

• Identification of postclosure land use; 

• Establishment of postclosure access roads; and

• Reestablishment of downstream drainage and surface water flow.

Connected Actions

The selected action will result in the following connected actions, described below. 

Electrical Transmission Line

A 138-kV electrical transmission line and associated facilities will be constructed from the proposed 

Toro switchyard to the Rosemont substation. 

Water Supply Pipeline

A water supply pipeline and ancillary facilities will be constructed to convey mine supply water from 

supply wells near Sahuarita to the mine site. This pipeline will be co-located with the electrical 

transmission line and buried where possible. Ancillary facilities include four pump stations and an 

electrical distribution line that will run from the Rosemont substation to the pump stations on the 

same towers as the electrical transmission line. 

Electrical Distribution Line

An existing 46-kV electrical distribution line that currently provides electrical power to Rosemont 

Ranch and other private lands is located in an area where tailings and waste rock facilities will be 

constructed. This distribution line will be relocated within the security fence where necessary. 

Arizona National Scenic Trail Reroute

The Las Colinas portion of the Arizona National Scenic Trail currently runs through the project area. 

Approximately 10 miles of existing trail will be relocated to the east side of SR 83 in order to 

accommodate both the Rosemont Copper Project and continued use of the trail (see figure ROD-2). 

This will require constructing an estimated 12.8 miles of new construction, along with ancillary 

facilities such as trailheads and parking areas. Construction of ancillary facilities includes two 

trailheads, parking for cars and trailers, and restroom facilities, as described in chapter 2 of the FEIS.

State Route 83 Highway Maintenance and Improvements

ADOT has determined that a number of road maintenance and improvement actions will be required 

to mitigate increased traffic on SR 83 associated with the combination of mine activities and 

anticipated population growth. These actions include a 3-inch pavement overlay from the intersection 

of the primary access road to the junction with I-10; associated striping, raising of guardrails, and 

resigning; and paving of three existing pullouts to safely accommodate school buses. All actions on 

NFS lands will occur within the ADOT easement. 

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Mitigation and Monitoring

All mitigation and monitoring measures listed as Forest Service measures in appendix B of the FEIS 

are included in my decision, with the following exception:

• FS-GW-05 - Monitoring, Pumping, and Treatment of Heap Leach Drainage. The 

heap leach is not included in the selected action; therefore, this mitigation is not 

applicable.

All mitigation and monitoring in the “Forest Service” and “Other Regulatory Agency” categories in 

appendix B of the FEIS are within the jurisdiction of the Forest Service or other regulatory agency, 

are nondiscretionary, and are required to be implemented. Rosemont Copper has committed to 

implementing the mitigation and monitoring in the Rosemont Copper category; however, these items 

are not within the jurisdiction of the Forest Service or other regulatory agency. See “Stipulations, 

Mitigations, and Monitoring Programs” below for identification of those mitigations that will be 

brought forward into the final MPO and thereby required for implementation. 

Stipulations, Mitigations, and Monitoring Programs

A number of modifications to the preliminary MPO, monitoring requirements, and mitigation 

measures will be incorporated in a revised final MPO (the “final” MPO) as identified in the selected 

action. The Forest Service has determined that these changes and additions are necessary to meet the 

purposes of the applicable regulations, including compliance with the Endangered Species Act (ESA), 

as set forth in the BO prepared by the U.S. Fish and Wildlife Service (USFWS), compliance with 

Sections 401 and 404 of the CWA, and compliance with the NHPA, as set forth in the MOA for 

NHPA Section 106 compliance. 

General Stipulations

1. All requirements and stipulations specified in the FEIS for the selected action and in this 

ROD, including the stipulations and mitigation measures in this section, are binding 

upon Rosemont Copper and its successors, if any. These include all stipulations 

contained in the USFWS BO and MOA for NHPA Section 106 compliance, including 

the historic properties treatment plan (HPTP). Any deviation from these requirements 

must be approved by the Coronado in advance. 

2. Rosemont Copper shall modify and amend the MPO to be consistent with development 

of the Rosemont Copper deposit in accordance with the selected action as described in 

this ROD. 

3. The final MPO shall contain a final reclamation and closure plan that is consistent with 

the preliminary reclamation and closure plan for the Barrel Alternative (CDM Smith

2012a), including changes at the request of and approved by the Forest Service. 

4. Rosemont Copper shall submit a reclamation performance bond, meeting the 

requirements of 36 CFR 228.13, in an amount acceptable to the Forest Service and using 

an instrument acceptable to the Forest Service. The bond will be maintained by 

Rosemont Copper and may be required to be reviewed, increased, and updated as 

deemed necessary by the Forest Service.

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5. Rosemont Copper shall comply with the current USFWS BO, dated October 30, 2013, 

and any revised or supplemental BOs in effect for the project. Rosemont Copper shall 

notify the Coronado of actions that do not comply with requirements of the applicable 

BO. The current BO is contained in appendix F of the FEIS. 

6. Rosemont Copper shall comply with all the current and future permits issues by the 

Arizona Department of Water Resources (ADWR), ADEQ, ASLD, Pima County, and 

other permitting agency; and shall comply with any revised or supplemental permits in 

effect for the project. Rosemont Copper shall notify the permitting agency and the 

Coronado of actions that do not comply with requirements of the applicable permit. 

7. Rosemont Copper shall provide the Coronado with: a copy of the Arizona Pollutant

Discharge Elimination System (AZPDES) multisector general permit authorization from 

the ADEQ, including a copy of the stormwater pollution prevention plan (SWPPP); a 

copy of the AZPDES construction general permit authorization and SWPPP if this 

permit is required by ADEQ in addition to the multisector general permit; the CWA 

Section 401 certification from ADEQ; a copy of the CWA Section 404 permit from 

USACE, including the final version of the habitat mitigation and monitoring plan; 

updates to the aquifer protection permit (APP) and air quality class II synthetic minor 

permit from ADEQ incorporating any necessary changes resulting from the decision to 

implement the selected action and copies of any other air permits required for 

construction activities from either the Pima County Department of Environmental 

Quality or ADEQ.

8. Rosemont Copper will provide a ROW permit from the ASLD indicating permission to 

construct a power line, water pipeline, and utility maintenance road across State 

property to the Rosemont Copper Project plant site; and ROW encroachment permits 

from ADOT to allow construction or improvement of intersections of NFSRs and SR

83. 

9. Rosemont Copper shall prepare a construction schedule that describes the order of 

activities and which activities and mitigation measures are required prior to initiation of 

construction and submit it to the Coronado for approval prior to initiating any activities 

on NFS lands. 

10. Rosemont Copper shall provide an annual report summarizing mining, reclamation, and 

monitoring activities and projecting proposed activities for the coming year. Rosemont 

Copper shall conduct an annual review with the Coronado to determine whether

activities are in accordance with the approved MPO and whether any changes to the 

approved MPO or financial assurance are needed.

11. Rosemont Copper shall notify the Coronado in the event of any action, activity, or 

occurrence that results in deviation from the mine life as described in the final MPO. 

12. At any time during operations the Forest Service may ask Rosemont Copper for a 

proposed modification of the MPO detailing the means of minimizing unforeseen 

significant disturbance of surface resources, as stated in 36 CFR 228.4(e). 

13. The Rosemont Copper final MPO shall describe plans to control public access to mine 

areas such as fencing and posting to prohibit unauthorized entry to hazardous areas. 

14. To accomplish the objective of documenting compliance with permit requirements, a 

system of self-monitoring and quality assurance/quality control (QA/QC) techniques 

will occur. To achieve this objective, Rosemont Copper will provide the Coronado with 

a description of how environmental protection standards contained in approved plans 

Draft Record of Decision – December 13, 2013

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Record of Decision and Finding of Nonsignificant Amendment

and permits will be implemented. Rosemont Copper will specify company and 

consultant personnel who are responsible for performance, inspection, and approval of 

all work that affects the surface resources. Rosemont Copper will designate an 

environmental coordinator as the primary contact with the Coronado on permit 

compliance, monitoring, and mitigation. As directed by the Coronado Forest Supervisor, 

an interagency task group will be formed to assist the Coronado to administer the 

approved MPO. The Coronado, ADEQ, Arizona State Mine Inspector, Arizona Game 

and Fish Department (AGFD) Bureau of Land Management (BLM), and other 

regulatory and permitting agencies will be invited to participate in the task group. See 

“Reporting and Evaluation” below and chapter 2 of the FEIS for further details.

15. Rosemont Copper will be required to compile monitoring results into a monitoring 

report that will be provided to the Coronado on a quarterly basis. Any monitoring result 

that is not in compliance with the effectiveness criteria will be reported to the Coronado 

within 72 hours. After reviewing the results of these reporting requirements, the 

Coronado will notify members of the multiagency monitoring group should conditions 

warrant interim or emergency meetings.

16. In addition to quarterly monitoring reports, Rosemont Copper will submit an annual 

report to the Coronado and the multiagency monitoring group that contains a description 

of all activities conducted during the previous year and a summary of applicable 

information as approved by the Coronado, along with annual results of all monitoring 

plans in a format approved by the Coronado, including a complete data summary and 

any data trends, a mining status plan, and plans for the coming year. 

17. Rosemont Copper has agreed to enter into a voluntary collection agreement with the 

Coronado to fund work performed by Coronado employees, consultants, and/or 

cooperators assigned to administer and monitor the project. This would include a 

minerals administrator; a biological monitor, whose role in overseeing monitoring 

activities is described in the BO (see appendix F of the FEIS); and the time spent by the 

forest archaeologist to oversee the implementation of the HPTP for the construction, 

operation, and reclamation of the project. Details regarding other Coronado positions 

that would be necessary for administering the project and overseeing monitoring are still 

being developed. The collection agreement will be in place at the time the final MPO is 

approved. This measure may be refined with further details once the collection 

agreement is finalized and approved by both parties. 

18. Rosemont Copper has agreed to purchase merchantable large, woody material cleared 

from NFS lands during mine construction after reclamation requirements are met. 

Rosemont Copper will be responsible for disposal of this material, which could occur in 

several ways. For example, the remaining material could be made available to the 

public, including tribal members. In order to allow public access to firewood, previously 

cleared areas on NFS lands outside the perimeter fence may be used for temporarily 

stockpiling firewood if approved in advance by the Coronado. Some material could also 

be sold commercially for other uses, such as for lumber. Some woody material suitable 

for reclamation will likely be stored in temporary stockpiles prior to placement, but no 

large-scale stockpiles of wood will be maintained onsite on NFS lands. Refer to “Fuels 

and Fire Management” in chapter 3 of the FEIS for further detail. 

Draft Record of Decision – December 13, 2013

32 Rosemont Copper Project, Coronado National Forest

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Mitigation and Monitoring Requirements

The description of the selected action in appendix A of this ROD contains descriptions of operational 

requirements, design criteria, mitigation items, monitoring plans, and changes and additions to the 

preliminary MPO. Mitigation measures, design components, and monitoring programs that must be 

incorporated in the final MPO prior to Coronado approval are listed below. Where deemed 

appropriate, I have included clarification or additional details regarding these required mitigation and 

monitoring measures. Mitigation and monitoring measures identified as Forest Service measures in 

appendix B are requirements of this ROD and are therefore required for implementation. 

Mitigation and monitoring measures identified as “Other Agency” measures in appendix B are also 

required; however, these measures are required by permits that are under the authority of ADEQ, 

ADWR, ASLD, Pima County, or other permitting agencies and are not within the authority of the 

Forest Service. While these measures are not specified as a requirement of this ROD, they are 

expected to be implemented under the jurisdiction of a permitting agency and are referenced below. 

Mitigation and monitoring measures identified as Rosemont Copper measures in appendix B are not 

within the authority of the Forest Service or any permitting or regulatory agency; therefore, the 

implementation of these measures is not assured. However, Rosemont Copper has publicly committed 

to implementing these measures and I expect them to follow through with their commitment. Because 

these measures are outside the authority of the Forest Service, they are not considered to be 

requirements of this ROD. I have referenced these Rosemont Copper mitigation and monitoring 

measures below for informational purposes. Additional details for all mitigation and monitoring are

described in appendix B of the FEIS. 

Rosemont Copper and AGFD signed an agreement in principle on October 25, 2013 (AGFD 2013) in 

which Rosemont Copper agrees to provide funding to AGFD and AGFD agrees to implement certain 

mitigation and monitoring items. While this agreement details the relationship between Rosemont 

Copper and AGFD in implementing required mitigation and monitoring, it is important to note that 

nothing in this agreement changes or modifies the requirements of this ROD, including requirements of 

the BO. Rosemont Copper is responsible for implementing the project in a manner that complies with

all applicable laws and regulations and meets the requirements of my decision. I consider the agreement 

in principle to be a working agreement in Rosemont Copper’s efforts to comply with its responsibilities. 

Reporting and Evaluation

The Forest Service has sole authority to approve and administer the MPO. The Forest Service will 

review all final designs and monitoring and mitigation plans, and written approval from the Forest 

Service must be obtained prior to initiation of the work outlined in the final MPO. Prior to beginning 

construction activities on NFS lands, an interagency task group will be formed to provide for 

information sharing for purposes of facilitating multiagency oversight of the Rosemont Copper 

Project. The Coronado will invite county, State, and Federal agencies with permitting or other 

regulatory authority to participate in this task group. This interagency task group will review plans 

and monitoring data and will facilitate information sharing for multiagency oversight of regulatory 

compliance related to the Rosemont Copper Project. Refer to chapter 2 of the FEIS for further detail. 

Draft Record of Decision – December 13, 2013

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Geology, Minerals, and Paleontology

The following mitigation measures associated with geology, minerals, and paleontology are required 

and will be incorporated into the final MPO. Refer to appendix B in the FEIS for details: 

• FS-GMP-01 - Upon discovery of paleontological resources, suspension of operations 

pending Forest Service review

• FS-GMP-02 - Upon discovery of a cave or sinkhole, suspension of operations 

pending Forest Service review

Soils and Revegetation

The following mitigation measures associated with soils and revegetation are required and will be 

incorporated into the final MPO. Refer to appendix B in the FEIS for details: 

• FS-SR-01 - Growth media salvage and application

• FS-SR-02 - Revegetate disturbed areas with native species

• FS-SR-03 - Concurrent placement of perimeter buttress

• FS-SR-04 - Slope stability monitoring

• FS-SR-05 - Sediment transport monitoring 

In addition, the following clarification and requirement will apply to soils and revegetation mitigation

and monitoring: 

1. Rosemont Copper shall update the final reclamation and closure plan for inclusion in the final 

MPO and submit such plan to the Coronado for approval. Rosemont Copper shall conduct 

reclamation in accordance with an approved final reclamation plan. Refer to appendix B of 

the FEIS regarding the mitigation and monitoring measures above for further detail. 

Air Quality and Climate Change 

A number of other regulatory agency mitigation and monitoring measures associated with air quality 

and climate change are described in appendix B of the FEIS. Please see items OA-AQ-01 through 

OA-AQ-11 in appendix B for details. 

In addition, Rosemont Copper has agreed to implement mitigation and monitoring measures

associated with air quality and climate change. Please see RC-AQ-01 in appendix B of the FEIS for 

details.

Groundwater Quantity and Quality 

The following mitigation measures associated with groundwater quantity and quality are required and 

will be incorporated into the final MPO. Refer to appendix B in the FEIS for details: 

• FS-GW-01 - Monitoring of waste rock for seepage

• FS-GW-02 - Water quality monitoring beyond point-of-compliance wells

• FS-GW-03 - Additional operational waste rock and tailings characterization

• FS-GW-04 - Periodic update and rerunning of pit lake geochemistry model 

throughout life of mine 

Draft Record of Decision – December 13, 2013

34 Rosemont Copper Project, Coronado National Forest

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Draft Record of Decision and Finding of Nonsignificant Amendment

In addition, a number of other regulatory agency mitigation and monitoring measures associated with 

groundwater quantity and quality are described in appendix B of the FEIS. Please see items OA-GW01 through OA-GW-08 in appendix B for details. 

Rosemont Copper has committed to implement several mitigation and monitoring measures

associated with groundwater quantity and quality. Please refer to RC-GW-01 through RC-GW-03 in 

appendix B of the FEIS for details. 

The following clarifications and requirements will apply to groundwater quantity and quality 

mitigation and monitoring:

1. Rosemont Copper shall test water quality, waste rock, leachate, and tailings materials 

throughout the life of the mine to evaluate potential for acid generation and metals leaching, 

as specified in appendix B of the FEIS. 

Rosemont Copper shall provide a detailed sampling plan for water quality sampling and 

waste rock/tailings characterization plan for Forest Service review and approval that includes: 

(1) quality assurance protocol, (2) sampling protocol consistent with accepted scientific 

standards, (3) detailed analyte (chemical or contaminant) list including the contaminants of 

concern, (4) sampling frequency no less than monthly (tailings), quarterly (process water), 

every 6 months (humidity cell testing for potentially acid-generating waste rock), annually 

(humidity cell testing for tailings), every 250,000 tons (for potentially acid-generating waste 

rock), and every 5,000,000 tons (for non-potentially acid-generating waste rock), (5) criteria 

for defining baseline or ambient groundwater quality, (6) definition of non-regulatory water 

quality thresholds against which to compare results, (7) no less than annually reporting 

requirements, (8) proposed protocols to be followed in the event that a water quality 

threshold is exceeded (i.e., reporting, increased sampling frequency, other investigative 

approaches, and remedial action), and (9) a proposed procedure with which to review and 

request changes to the level of monitoring.

Surface Water Quantity and Quality

The following mitigation measures associated with surface water quantity and quality are required 

and will be incorporated into the final MPO. Refer to appendix B in the FEIS for details: 

• FS-SW-01 - Location, design, and operation of facilities and structures intended to 

route stormwater around the mine and into downstream drainages 

• FS-SW-02 - Stormwater diversion for Barrel Alternative designed to route more 

stormwater into downstream drainages postclosure 

In addition, a number of other regulatory agency mitigation and monitoring measures associated with 

surface water quantity and quality are described in appendix B of the FEIS. Please see items OA-SW01 and OA-SW-02 in appendix B for details. 

Rosemont Copper has committed to implement a mitigation and monitoring measure associated with 

surface water quantity and quality. Please refer to RC-SW-01 in appendix B of the FEIS for details. 

The following clarifications and requirements will apply to surface water quantity and quality 

mitigation and monitoring:

Draft Record of Decision – December 13, 2013

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Record of Decision and Finding of Nonsignificant Amendment

1. Rosemont Copper shall provide a final engineering design for the tailings and waste rock 

landform that includes:

a. Any necessary modifications to ensure that the ultimate landform complies with this 

decision. The final configuration of the tailings and waste rock landform shall be such 

that no storage of stormwater occurs on the top of these facilities or benches. Design of 

these facilities shall include grading of the tops to discharge stormwater to the lower 

benches, which in turn shall be designed to move stormwater laterally along the benches 

until it reaches several concrete drop structures. The runoff from these drop structures 

shall be discharged into the natural washes (Barrel Canyon or a tributary) or discharged 

into a diversion channel that will carry runoff along the toe of the waste rock and tailings 

facilities and discharge that runoff into the natural washes. 

b. The thickness of waste rock material to be placed as a closure cap over the tailings 

facility. 

2. Rosemont Copper shall provide a site water management plan that includes:

a. Locations and design criteria for all stormwater conveyance or storage facilities. 

b. Engineering final design for conveyance channels, stormwater drop structures, and 

stormwater management and detention/retention basins. 

c. Phasing of stormwater management features over the mine life. 

d. Stormwater management features after reclamation and closure. 

e. Reestablishment of downstream drainage and surface water flow. 

3. Rosemont Copper shall remove and reclaim compliance point dams, unless monitoring and 

maintenance of such structure determine the need to retain them for further monitoring. Such 

determination is the responsibility of the Coronado, in coordination with ADEQ. 

Seeps, Springs, and Riparian Areas

The following mitigation measures associated with seeps, springs, and riparian areas are required and 

will be incorporated into the final MPO. Refer to appendix B in the FEIS for details: 

• FS-SSR-01 - Purchase of water rights, to be used for compensating for impacts in the 

Cienega Creek watershed

• FS-SSR-02 - Spring, seep, and constructed/enhanced waters monitoring

Biological Resources

The following mitigation measures associated with biological resources are required and will be 

incorporated into the final MPO. Refer to appendix B in the FEIS for details: 

• FS-BR-01 - Plant site location and design adjustments to reduce impacts to biological 

resources

• FS-BR-02 - Redesign of the coarse ore stockpile dome and pebble crusher/ball 

loading facility to avoid a subpopulation of sensitive plants 

• FS-BR-03 - Measures to exclude wildlife, livestock, and the public from water ponds 

and other areas

• FS-BR-04 - Salvage, growing, planting, and monitoring of Palmer’s agave

Draft Record of Decision – December 13, 2013

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Draft Record of Decision and Finding of Nonsignificant Amendment

• FS-BR-05 - Construction, management, and maintenance of water features to reduce 

potential impacts to wildlife and livestock from reduced flow in seeps, springs, 

surface water, and groundwater 

• FS-BR-06 - Location of the electrical power line that provides power to the pit area 

so that it avoids talus slopes to the extent practicable

• FS-BR-07 - Recordation of a restrictive easement on the private Helvetia Ranch 

Annex North Parcel to compensate for impacts to species listed as threatened or 

endangered 

• FS-BR-08 - Recordation of a restrictive easement on the private Sonoita Creek 

Ranch Parcel to compensate for impacts to species listed as threatened or endangered 

• FS-BR-09 - Funding to support camera studies for large predators, including jaguar 

and ocelot 

• FS-BR-10 - Measures to reduce and rectify impacts to Pima pineapple cactus

• FS-BR-11 - Monitoring and control of actions to reduce or prevent impacts to 

Chiricahua leopard frog from invasive aquatic species

• FS-BR-12 - Relocation of Chiricahua leopard frogs from areas in the immediate 

vicinity of the project area

• FS-BR-13 - Measures to ensure relocation of lesser long-nosed bat and other bat 

species in the immediate vicinity of the mine

• FS-BR-14 - Measures to reduce impacts to western yellow-billed cuckoo

• FS-BR-15 - Measures to protect two occurrences of Coleman’s coral-root during 

road decommissioning 

• FS-BR-16 - Establishment of the Cienega Creek Watershed Conservation Fund, to be 

used for future mitigation in the Cienega Creek watershed

• FS-BR-17 - Future modification of allotment management plans 

• FS-BR-18 - Predisturbance surveys for Forest Service sensitive species

• FS-BR-19 - Measures to reduce impacts to jaguar 

• FS-BR-20 - Funding of NEPA analysis required for implementation of mitigation 

measures or changes in the MPO that affect NFS surface resources

• FS-BR-21 - Recordation of a restrictive covenant or conservation easement on 

private land parcels in Davidson Canyon to compensate for loss of habitat for listed 

species

• FS-BR-22 - Monitoring to determine impacts from pit dewatering on downstream 

sites in Barrel and Davidson Canyons 

• FS-BR-23 - Monitoring to determine the extent of road-kill near the project area

• FS-BR-24 - Surveying and monitoring for lesser long-nosed bats 

• FS-BR-25 - Surveying for bats in the vicinity of the project area 

• FS-BR-26 - Annual monitoring for Chiricahua leopard frog

• FS-BR-27 - Periodic validation and rerunning of groundwater model throughout life 

of mine 

• FS-BR-28 - Monitoring of water quality in potential Chiricahua leopard frog habitat

Draft Record of Decision – December 13, 2013

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Record of Decision and Finding of Nonsignificant Amendment

In addition, Rosemont Copper has committed to implement a mitigation and monitoring measure 

associated with biological resources. Please refer to RC-BR-01 in appendix B of the FEIS for details. 

The following clarification and requirement will apply to biological resources mitigation and 

monitoring: 

1. Prior to completing construction of the perimeter fence, Rosemont Copper shall coordinate 

with the Coronado regarding livestock grazing levels and restrictions for the permitted area 

between the perimeter and security fences. Grazing may be reintroduced in areas within the 

security fence once reclamation is completed and the land has been determined to be suitable 

for grazing. This could be during the active mining phase in some areas where concurrent 

reclamation has occurred or is occurring and livestock grazing has been determined to be 

suitable for specific areas. It is not known when revegetation will be established enough to 

reinstate grazing. 

Landownership and Boundary Management

The following mitigation measures associated with landownership and boundary management are 

required and will be incorporated into the final MPO. Refer to appendix B in the FEIS for details:

• FS-LO-01 - Resurveying of existing survey monuments and land lines to allow 

reestablishment postmining 

• FS-LO-02 - Reestablishment of survey monuments and surveyed land line upon 

completion of final reclamation

In addition, Rosemont Copper has committed to implement two mitigation and monitoring measures 

associated with landownership and boundary adjustment. Please refer to RC-LO-01 and RC-LO-02 in 

appendix B of the FEIS for details. 

Dark Skies

The following mitigation measure associated with dark skies is required and will be incorporated into 

the final MPO. Refer to appendix B in the FEIS for details: 

• FS-DS-01 - Implementation of an outdoor lighting plan that would reduce potential 

impacts from artificial night lighting

• FS-DS-02 - Funding of additional ground-based sky brightness monitoring 

Visual Resources

The following mitigation measures associated with visual resources are required and will be 

incorporated into the final MPO. Refer to appendix B in the FEIS for details: 

• FS-VR-01 - Color of mine related buildings blends into the natural landscape 

• FS-VR-02 - Removal of unneeded facilities during closure 

• FS-VR-03 - Measures to reduce color contrasts from cuts, fills, and concrete 

structures associated with the mine

• FS-VR-04 - Measures to reduce the visual impact of the mining pit

Draft Record of Decision – December 13, 2013

38 Rosemont Copper Project, Coronado National Forest

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Draft Record of Decision and Finding of Nonsignificant Amendment

The following clarifications and requirements will apply to visual resources mitigation and monitoring:

1. Rosemont Copper shall submit plans and specifications for the final MPO detailing how the 

perimeter and security fence will be constructed, maintained, and removed in a manner that 

minimizes surface disturbance. 

2. All areas will be surveyed for the presence of contaminants, and any contaminated soils, 

reagents, or fuels and any contaminants will be disposed of offsite at licensed facilities.

Recreation and Wilderness

The following mitigation measures associated with recreation and wilderness are required and will be 

incorporated into the final MPO. Refer to appendix B in the FEIS for details: 

• FS-RW-01 - Relocation of a segment of the Arizona National Scenic Trail and 

construction of trailheads 

• FS-RW-02 - Arizona National Scenic Trail: easement to allow the trail to be 

constructed across Rosemont Copper’s private land 

• FS-RW-03 - Mitigate loss of OHV use opportunities 

In addition, the following clarifications and requirements will apply to recreation and wilderness 

mitigation and monitoring:

1. Rosemont Copper shall ensure that the relocated segment of the Arizona National Scenic 

Trail is pioneered and available for public use at the time the existing trail segment is closed 

to public use. With the intent of maintaining the trail in an open condition during the prime 

hiking season of March, April, October, and November, any activity that will restrict the trail 

to public use shall be reported to the Coronado in advance and shall not commence without 

the approval of the Coronado. See FS-RW-01 in appendix B of the FEIS for further detail. 

2. Rosemont Copper has agreed to grant ROWs to the Coronado across its private lands for 

construction of a trailhead and associated facilities for the relocated Arizona National Scenic 

Trail; and to allow the relocated trail to be constructed across Rosemont Copper private land. 

ROWs will be granted prior to commencement of mine construction activities on NFS lands.

See FS-RW-02 in appendix B of the FEIS for further detail.

3. Rosemont Copper has agreed to provide funding for efforts to produce a plan for developing 

facilities and managing OHV use that will be displaced from the project area (see FS-RW-03 

in appendix B of the FEIS for details). Rosemont Copper has agreed to enter into a collection 

agreement to provide funding that will include $100,000 to be used for a NEPA analysis and 

decision process to determine where additional facilities are warranted and appropriate. 

Subsequent to the NEPA decision to implement OHV mitigation, Rosemont Copper has 

committed to contribute $700,000 to the Coronado for additional work, which could include, 

but would not be limited to, construction of OHV facilities; public outreach and education; 

management; and enforcement. 

Hazardous Materials

The following mitigation measures associated with hazardous materials are required and will be 

incorporated into the final MPO. Refer to appendix B in the FEIS for details: 

Draft Record of Decision – December 13, 2013

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Record of Decision and Finding of Nonsignificant Amendment

• FS-HM-01 - Hazardous materials containment and management

• FS-HM-02 - Maintaining of material safety data sheets in accordance with 30 CFR 47 

Transportation/Access

The following mitigation measure associated with transportation and access is required and will be 

incorporated into the final MPO. Refer to appendix B in the FEIS for details: 

• FS-TA-01 - Development of a comprehensive transportation plan 

In addition, Rosemont Copper has committed to implement several mitigation and monitoring 

measures associated with transportation and access. Please refer to RC-TA-01 through RC-TA-03 in 

appendix B of the FEIS for details. 

The following clarifications and requirements will apply to transportation and access mitigation and

monitoring: 

1. NFS Road Stipulations 

a. Rosemont Copper shall prepare a comprehensive transportation plan for inclusion in the 

final MPO. The plan shall address the following for all roads on NFS lands, other than 

temporary haul roads, including all roads to be constructed or reconstructed, or 

maintained, that are used for mining or related purposes. The transportation plan shall 

address for all roads on NFS lands used for mining and related purposes: 

i. A list of all NFSRs that Rosemont Copper intends to use for mining or related 

purposes, including those roads to be constructed. 

ii. Maintenance standards;

iii. Levels of appropriate use; 

iv. Methods to maintain the roadways sufficiently to prevent washboard, rutting, and 

drainage problems; 

v. Commitment to replace surfacing lost to drainage; 

vi. Commitment to repair roads damaged by use; 

vii. Commitment to restore temporary roads to natural preoperation conditions 

during reclamation/closure; 

viii. Installation and maintenance of wildlife crossing structures (e.g., corrugated metal 

pipes) under the primary access road at locations of known wildlife concentration. 

ix. A transportation reduction plan for reducing traffic (i.e., carpooling, busing); and 

x. A delivery schedule plan that will indicate actions to be taken to schedule 

delivery traffic on SR 83 occurs outside peak traffic hours, as well as monitoring 

and reporting stipulations. 

b. The final MPO shall specify the conditions under which Rosemont Copper may use 

NFSRs. The final MPO will address the following:

i. Access road design shall meet Forest Service specifications (to be furnished by the 

Forest Service) for road width, grade, alignment, surfacing, drainage, quality control, 

and signing. Exceptions to these standards may occur only with Coronado approval. 

Rosemont Copper will submit designs for road construction and improvements to the 

Coronado for review and approval prior to initiating construction.

Draft Record of Decision – December 13, 2013

40 Rosemont Copper Project, Coronado National Forest

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Draft Record of Decision and Finding of Nonsignificant Amendment

ii. A requirement that Coronado approval must be obtained for all location or design 

changes for access and utility maintenance roads on NFS lands.

iii. Rosemont Copper shall be responsible for maintaining all signs, fencing, and 

other features deemed necessary to ensure public safety. 

iv. During the construction period, Rosemont Copper shall coordinate all use of 

approved and alternative access routes with the Coronado. 

v. Rosemont Copper shall construct or reconstruct all mine access and utility 

maintenance roads on NFS lands in a manner acceptable to the Coronado and 

will be responsible for providing “as-built” certification of all items by a licensed 

professional engineer. The Forest Service administrator will review the 

Rosemont Copper Project construction to ensure compliance with approved 

plans. Certification and results of tests and inspections will be forwarded to the 

Coronado for review and approval. 

vi. Rosemont Copper and the Coronado will review all access and utility 

maintenance roads on NFS lands, during and after summer monsoon runoff. 

The purpose of this inspection will be to verify that all design features are 

functioning as designed and/or to identify any needed improvements or changes. 

c. Rosemont Copper shall work with authorized grazing permittees to provide access to their 

permits in areas where road access has been cut off by mine related actions. Rosemont 

Copper shall provide permittees access to their adjacent allotments upon request.

d. Rosemont Copper shall construct the Sycamore Connector Road and all other new road 

construction on NFS lands described for the selected action within 1 year of the time that 

public motorized access is restricted on said road by mining or related actions (i.e., 

construction of the perimeter fence). All roads constructed on NFS lands will be 

constructed to standards that are approved in advance by the Coronado. 

e. Rosemont Copper shall be responsible for road decommissioning for all NFSRs 

identified for decommissioning in the selected action. Rosemont Copper shall coordinate 

with the Coronado to determine specifically which segments of road are to be 

decommissioned and specifically what level of decommissioning is required for each 

segment. No active decommissioning shall occur on any NFSR without prior Coronado 

approval. Within 1 year of completion of the perimeter fence, Rosemont Copper shall 

complete decommissioning activities at the direction of the Coronado. Decommissioning 

activities that result in ground disturbance shall not occur until the Coronado has been 

notified and approved the activity. 

f. All new roads on NFS lands, except those roads identified by the Coronado as needed for 

administrative purposes, will be reclaimed at mine closure. 

g. Active road decommissioning will be coordinated with the Coronado archaeologist and 

biological monitor prior to implementation to coordinate areas to avoid due to the 

presence of cultural sites and sensitive plant populations. 

h. Establishment of postclosure access roads will be coordinated with the Coronado prior to 

closure, with work conducted by Rosemont Copper. 

Draft Record of Decision – December 13, 2013

Rosemont Copper Project, Coronado National Forest 41

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Record of Decision and Finding of Nonsignificant Amendment

Noise

The following mitigation measures associated with noise are required and will be incorporated into 

the final MPO. Refer to appendix B in the FEIS for details: 

• FS-N-01 - Management techniques to reduce potential noise impacts from blasting 

• FS-N-02 - Actions to reduce potential noise impacts from vehicles

In addition, the following clarification and requirement will apply to noise mitigation and monitoring: 

1. Rosemont Copper shall submit for the final MPO details of procedures for blasting and 

handling of ammonium nitrate and other explosive materials to minimize loss or spillage.

Public Health and Safety

The following mitigation measure associated with public health and safety is required and will be 

incorporated into the final MPO. Refer to appendix B in the FEIS for details: 

• FS-PHS-01 - Construction of a perimeter fence that would exclude the public 

• FS-PHS-02 - Preparation of emergency response and contingency plans, including a 

fire plan 

In addition, the following clarifications and requirements will apply to public health and safety 

mitigation and monitoring:

1. Rosemont Copper shall prepare an emergency response and contingency plan, including a 

fire plan. Prior to construction, Rosemont Copper shall conduct emergency response and 

contingency planning with appropriate agencies. The emergency response and contingency 

plan shall document the results of this consultation. These plans shall identify emergency 

preparedness and clear protocols for contacting emergency responders. 

The fire plan shall contain requirements for providing and maintaining fire-fighting tools 

onsite; precautionary requirements for blasting and welding; training of employees in fire 

prevention, detection, and suppression; independent actions taken by Rosemont Copper and 

its employees and contractors to suppress fires in the work area or vicinity; requirements for 

mechanized equipment to reduce the risk of fire ignition; and construction of new water 

sources such as a firewater storage tank. 

2. Construction of fencing and/or berms for postclosure safety will be coordinated with the 

Coronado and other applicable regulatory agencies (i.e., Mine Safety and Health 

Administration (MSHA), Arizona State Mine Inspector) and installed by Rosemont Copper. 

Cultural Resources

The following mitigation measures associated with cultural resources are required and will be 

incorporated into the final MPO. Refer to appendix B in the FEIS for details and the HPTP in 

appendix D of the FEIS: 

• FS-CR-01 - Archaeological data recovery on sites that would be adversely affected

• FS-CR-02 - Respectful and appropriate treatment of human remains that would be 

disturbed by the project 

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• FS-CR-03 - Curation of archaeological collections in accordance with 36 CFR 79 

and the HPTP 

• FS-CR-04 - Monitoring and treatment of inadvertent discoveries

• FS-CR-05 - Limiting of ground-disturbing activity between the perimeter fence and 

security fence 

• FS-CR-06 - Cultural resources protection training

• FS-CR-07 - Project proponent would allow tribal members access, upon 5 days’ 

advance request, to the project area for cultural practices

• FS-CR-08 - Project proponent would organize tribal members’ field visits to 

potentially affected springs

• FS-CR-09 - Transplanting of critical plant resources and inclusion of species within 

revegetation mixture

• FS-CR-10 - Interpretation of the results of the cultural resources investigations for 

tribal members, the Hispanic community, and the public 

• FS-CR-11 - Stabilization of previously excavated historic properties between the 

security and perimeter fences

In addition, Rosemont Copper has committed to implement a mitigation and monitoring measure 

associated with cultural resources. Please refer to RC-CR-01 in appendix B of the FEIS for details. 

In addition, the following clarifications and requirements will apply to cultural resources mitigation 

and monitoring: 

1. Rosemont Copper shall provide access to tribal members to springs, vision sites, other sacred

sites and resource-collecting areas within the project area, while remaining in compliance 

with any applicable MSHA or other regulations. The Coronado will coordinate requests with 

Rosemont Copper. 

2. Ground-disturbing activities between the perimeter and security fences shall be approved in 

advance by the Coronado. Areas of disturbance in this area are anticipated to be limited to 

construction of compliance wells, stormwater drainage facilities, access to monitoring 

equipment, the perimeter fence, and active road decommissioning. Approved cultural 

monitors shall be present for all ground-disturbing work in this area. Cultural material 

discovered during monitoring shall be dealt with in accordance with the discovery plan in the 

HPTP. 

Power Use

Rosemont Copper has committed to implement a mitigation and monitoring measure associated with 

power use. Please refer to RC-PU-01 in appendix B of the FEIS for details. 

Community Programs 

Rosemont Copper has committed to implement a mitigation and monitoring measure associated with 

community programs. Please refer to RC-CP-01 in appendix B of the FEIS for details. 

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Permits, Licenses, and Authorizations Needed to Implement the 

Decision

Federal mining laws authorize mineral exploration and development on Federal lands. State and 

Federal environmental laws are intended to ensure that adverse impacts are minimized and that longterm productivity of the surface resources is preserved to the extent feasible. Rosemont Copper may 

not commence mining operations addressed in this ROD until the Forest Supervisor approves a 

resubmitted, final MPO that will set forth the final specific mitigation measures necessary to 

minimize adverse impacts and an approved reclamation bond is posted. 

The Coronado may accept certification and other approvals issued by State or other Federal agencies 

as evidence of compliance with similar or parallel requirements of regulations governing mining 

activities on the national forests. Besides the Forest Service, other agencies that require permits for 

the Rosemont Copper Project are: ADEQ, USACE, U.S. Department of Transportation (USDOT), the 

ADWR, ADOT, ASLD, the Arizona State Mine Inspector, the Arizona Corporation Commission 

(ACC), the Arizona Department of Agriculture (ADA), the Town of Sahuarita, and Pima County. 

The plans and permits submitted to, or to be submitted to, these agencies by Rosemont Copper 

include the following: 

1. A 401 certification must be issued by the State of Arizona. It is important to note that I cannot 

approve a final MPO until the Section 401 certification is issued.

2. An AZPDES multisector general permit was authorized by ADEQ (February 7, 2013). As a 

requirement of this permit, a SWPPP must be developed and submitted to ADEQ for review. 

An AZPDES permit must be obtained prior to the discharge of any pollutant, including 

stormwater from construction areas, to WUS. ADEQ may require a separate AZPDES 

construction general permit and SWPPP for temporary construction activities.

3. USACE project-specific (individual) 404 permit(s) required for the discharge of dredged or 

fill material into WUS. Prior to issuance of the 404 permit, the State of Arizona must 

complete CWA Section 401 certification. 

4. USDOT hazardous materials transportation permit, which governs the transport of hazardous

materials as defined by the USDOT. Requires specific employee training and security and 

contingency planning. 

5. EPA hazardous waste identification number authorizes facilities to generate and transport 

offsite hazardous waste in quantities in excess of 100 kilograms per month (or those that 

generate acute hazardous waste in quantities exceeding 1 kilogram per month). Requires 

specific employee training, inspections, and contingency planning.

6. ACC Certificate of Environmental Compatibility (CEC) regulates the placement of electrical 

transmission lines and ensures compliance with ARS 40-360 (issued June 12, 2012).

7. ADA agriculture land clearing permit authorizes disturbance and clearing of State protected 

native plants, as required under the Arizona Native Plant Law.

8. ADEQ APP regulates the direct or indirect addition of pollutants to groundwater. Specifies 

best available demonstrated control technology (design criteria and/or operation practices) to 

control discharge of pollutants to groundwater and establishes aquifer water quality limits 

enforced at points of compliance specified for the facility. Requires monitoring, reporting, 

contingency planning, and financial assurance. Permit was issued on April 3, 2012, and will 

require updating to reflect the selected action.

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9. Pima County air activity permits may apply to activities (such as earthmoving, trenching, 

road building, blasting, etc.) leading up to mining and well development. 

10. ADEQ air quality class II synthetic minor permit applies to emissions from activities during 

operations. Requires inspection, sampling, monitoring, contingency/emergency planning, 

notification, reporting, and compliance certification. Issued on January 31, 2013, and will 

require updating to reflect the selected action. 

11. ADEQ CWA section 401 water quality certification. The State must certify, waive, or deny an 

application for a USACE permit for discharge of dredged or fill material to WUS. To certify, 

the State must find that the activities proposed under the 404 permit will not result in a 

violation of State surface water quality standards. The 401 certification may specify 

conditions, including reporting requirements. The 401 water quality certification is currently 

under review.

12. ADEQ Hazardous Waste Management Program governs the management of hazardous waste 

(including transport and disposal). Requirements differ somewhat, depending on the volume 

and nature of hazardous waste generated; however, in general, it requires inspection, training, 

and contingency/emergency planning. 

13. ADOT ROW encroachment permit authorizes the construction of the intersections for the 

primary access road in the ROW of SR 83. 

14. ADWR Mineral Extraction and Metallurgical Processing Groundwater Withdrawal Permit 

No. 59-215979.0000 authorizes withdrawal of groundwater. Permit was issued on January 

18, 2008, and is good for 20 years; at that time, Rosemont Copper must reapply.

15. ASLD ROW permit allows water and electrical supply lines to be placed within a ROW.

Permit will be issued after the ACC approves the electrical supply alignment. 

16. ADWR water storage permits. Augusta Resource Corporation (Augusta Resource) currently 

has three water storage permits with ADWR. Note that Rosemont Copper/Augusta Resource 

is not required by ADWR to store water, but they have elected to store water in the Tucson 

Active Management Area. As of December 31, 2010, their long-term storage balance was 

42,593.02 acre-feet of Central Arizona Project credits. 

17. The Town of Sahuarita issued a license for ROW encroachment on June 24, 2013, to allow 

Rosemont Copper to encroach on portions of the Town of Sahuarita’s ROW for the purpose 

of construction, installation, operation, maintenance, and repair of a water delivery pipeline 

and related facilities. 

Rosemont Copper must obtain required plans and permits from the State and Federal agencies 

described above for implementation of the project. Approval of the final MPO is required prior to 

beginning any surface-disturbing activities on NFS lands. Rosemont Copper will be required to 

change its preliminary MPO to incorporate any requirements identified in this ROD. 

Draft Record of Decision – December 13, 2013

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Applicable Laws, Regulations, and Policies

The FEIS was prepared in accordance with regulations implementing the NEPA (40 CFR 1500–

1508). This decision is consistent with the requirement of the National Forest Management Act 

(NFMA) (36 CFR 219), Forest Service locatable mineral regulations (36 CFR 228, Subpart A), the 

1897 Organic Administration Act (30 Stat. 11), the 1970 Mining and Mineral Policy Act (Public Law 

(PL) 91-631), and other applicable State and Federal statutes.

My decision is made in accordance with the requirements of 36 CFR 228 Subpart A, meets the 

requirements of the abovementioned State and Federal laws, and addresses the requirements of the 

1872 Mining Law (30 U.S.C. 21 et seq.), and the 1955 Multiple-Use Mining Act (30 U.S.C. 612). 

Alternatives Considered

The alternatives considered in the FEIS were initially developed to respond to the issues identified 

during public scoping. The alternatives were further modified in response to comments received on 

the DEIS from the public, agencies, and tribes. In addition to the selected action (presented as 

Alternative 4 in the FEIS), five other alternatives were analyzed in detail. They include “Alternative 1

– No Action,” and Alternatives 2 through 6, which feature differing configurations of waste rock, 

tailings, plant site, and associated facilities. Alternatives 2 through 6 (the action alternatives) include 

all the common facilities, processes, and activities described under “General Overview of Mining 

Operations” in chapter 2 of the FEIS (also described in appendix A of this ROD as they apply to the 

selected action). The connected actions described under the selected action on page 29 of this ROD 

are also included in each of the action alternatives.

Additional alternatives include those considered in the FEIS and eliminated from detailed study 

(FEIS chapter 2, pp. 100 to 114). 

Alternative 1 – No Action (Environmentally Preferable Alternative)

The no action alternative was developed to provide an environmental baseline with which to compare 

the action alternatives. The no action alternative does not meet the purpose of and need for action 

because it would not respond to Rosemont Copper’s proposed MPO to develop and mine the 

Rosemont copper, molybdenum, and silver deposit. Other than issues associated with economic 

benefits associated with the project, the no action alternative addresses the issues identified during 

scoping in that it would avoid environmental impacts that are inherent in the action alternatives.

Additionally, while the Forest Service may reasonably regulate mining activities to protect surface 

resources, there are statutory and constitutional limits to its discretion. The Forest Service may reject 

an unreasonable MPO but cannot categorically prohibit mining or deny reasonable and legal mineral 

operations under the mining law. 

If no action is taken, Rosemont Copper would not develop the Rosemont mineral deposit as described 

in the MPO submitted for approval (including modifications to date), and all premining exploration 

and environmental studies on NFS lands would be reclaimed in accordance with laws, regulations, and 

permits. For the most part, the project area of the Rosemont Copper Project proposed action (figure 9 

in chapter 2 of the FEIS) would continue to grow and develop in accordance with generally accepted 

social and environmental trends. Information regarding current uses and trends in the project area are 

described in the “Affected Environment” parts of the resource sections in chapter 3 of the FEIS.

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In the absence of the proposed action, current uses of the proposed project area, including the 

Coronado National Forest, would continue, and new future uses may be proposed. These include all 

forms of recreation; grazing; and minerals exploration. Traditional cultural uses of the project area 

would continue. Access to public land in the area would continue as governed by law, regulation, 

policy, and existing and future landownership constraints, the latter of which may include denial of 

access over private land. 

The environment, population, and economy of southeastern Arizona will continue to evolve over 

time, whether or not the Rosemont Copper Project is implemented. Population growth in Pima 

County is estimated to continue, reaching 1.45 million by 2041. The Town of Sahuarita expects its 

population to increase to 45,597 over a 20-year planning horizon. The population of Santa Cruz 

County is expected to reach 60,080 by 2025, an increase of more than 26 percent from the county’s 

2010 population of 47,420. As populations increase, land and resource uses, including those of the 

Coronado National Forest, would be expected to increase proportionately. Traffic would likely 

increase with population growth. 

Changes in the climate of the southwestern United States are expected to continue, including an 

increase in mean annual temperature, a more frequent drought cycle, a decrease in winter 

precipitation, and an increased frequency of heavy rains and flooding. 

Alternative 2 – Proposed Action

The proposed action includes all the common facilities, processes, and activities described under 

“General Overview of Mining Operations” on p. 30 in chapter 2 of the FEIS (see figure 9 in chapter 2 

of the FEIS). This alternative would meet the purpose of and need for action by processing Rosemont 

Copper’s MPO in a manner that complies with applicable laws and regulations; and it would include 

measures for reclamation of surface resources. While this alternative would contain measures to 

minimize adverse environmental impacts on NFS surface resources, it would not do so as well as the 

selected action.

The proposed action reflects Rosemont Copper’s preliminary MPO. It was not developed to respond 

to the significant issues. Rather, scoping was conducted to gather public comment on the preliminary 

MPO, and the issues were identified from the resulting comments. 

The waste rock facility would be constructed south of the tailings facility. Reclamation of these areas 

would be conducted concurrently with active mining. Starting in the first year, waste rock would be 

placed as a perimeter buttress to partially block the view of the mining area project for travelers on SR 83 

and for viewers in the surrounding area. Throughout the life of the mine, waste rock would be disposed 

of to the west and/or north of (behind) these berms. Waste rock would also be placed to support and 

armor the outer slopes of the dry-stack tailings facility. Construction of the perimeter buttress would be 

complete approximately 5 years after plant startup. The final elevation of the perimeter buttress would be 

about 5,475 feet but would step down on the northeast side to between 5,150 and 5,050 feet to tie in with 

the dry-stack tailings and oxide heap leach facilities. The height of the waste rock facility would vary, 

ranging from 100 to 400 feet above the ground surface, depending on existing topography. 

Waste rock disposal would be restricted to a single surface water drainage basin, the Barrel Canyon 

area, which includes the tributaries of the Wasp and McCleary drainages. The tops of the waste rock 

facility would be sloped to direct stormwater away from the crest of the perimeter buttress. The drystack tailings facility would be divided into two separate units, north and south, which would be 

separated by a stormwater control facility (the central drain). 

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The plant site would be located between the pit and the north end of the tailings facility. The coarse 

ore stockpile would be a rectangular building with the appropriate conveyors going to and from the 

building. 

The central would be a rock chimney drain is designed to route excess stormwater through the 

tailings facility from both upstream and on top of the dry-stack tailings facility to the compliance 

point dam in Barrel Canyon. Stormwater from the waste rock buttresses of the dry-stack tailings 

facility would be combined with stormwater from the waste rock facility for reuse or discharge 

downstream after passing through the final compliance pond (see figure 11 in chapter 2 of the FEIS). 

The central drain design is designed to allow conveyance of the 100-year, 24-hour storm event volume 

through the drain within 30 days. Other diversion channels around the plant site are sized to handle 

runoff from the 100-year, 24-hour storm event (equal to 4.75 inches of rain over a 24-hour period).

The Arizona National Scenic Trail would be realigned just outside the perimeter fence with a 

trailhead that would be located off of the primary access road, as shown in figure 9 in chapter 2 of the 

FEIS. Area roads that are outside the perimeter fence that would either be reconnected or 

decommissioned are shown in figure 12 in chapter 2 of the FEIS. The Sycamore Connector Road 

would be about 3,432 feet long. 

Alternative 3 – Phased Tailings

The Phased Tailings Alternative was developed to respond to significant issues regarding potential 

negative effects of the proposed action on water and visual resources. Alternative 3 (see figure 13 in 

chapter 2 of the FEIS) contains a number of features in common with the proposed action. However, 

several features have been modified and designed to better respond to the issues, including: 

• Reversing the phased placement of the dry-stack tailings to leave the McCleary 

Canyon drainage open for approximately 10 years longer; 

• Refining the plant site, including redesigning the coarse ore stockpile to a dome 

structure and associated conveyor; 

• Realigning the primary access road to avoid Scholefield Canyon; and 

• Redesigning the stormwater management. 

This alternative was developed to respond to the purpose of and need for action. It would meet the 

purpose of and need for action by processing Rosemont Copper’s MPO in a manner that complies 

with applicable laws and regulations; and it would include measures for reclamation of surface 

resources. While this alternative would contain measures to minimize adverse environmental impacts 

on NFS surface resources, it would not do so as well as the selected action.

At the end of mine life, the final waste rock and tailings facilities would occupy the same location as 

the proposed action. This would reduce the short-term impact on surface water flow by allowing the 

McCleary Canyon drainage to remain open for approximately 10 years longer than it would under the 

proposed action. 

The primary access road was redesigned to follow an alignment that both shortens the road and 

reduces its visibility from SR 83. This realignment avoids Scholefield Canyon and would reduce 

impacts to riparian vegetation and cultural resources. The new alignment intersects SR 83 at the same 

location as in the proposed action but is 3.2 miles long (see figure 13 in chapter 2 of the FEIS). 

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While the location of the plant site would be the same as that of the proposed action, the Phased 

Tailings Alternative relocates some facilities to address geotechnical concerns regarding differential 

settlement (see figure 14 in chapter 2 of the FEIS). These modifications provide secondary 

containment opportunities for process solutions, where possible, and add stormwater catchments. 

The Phased Tailings Alternative adds a double liner with a leak collection and removal system to the 

process water temporary storage pond and improves the containment of process water and separation 

of process water from stormwater. In addition, the Phased Tailings Alternative modifies the design of 

the coarse ore stockpile to a geodesic dome structure and associated conveyor systems to avoid 

encroaching on a population of the Forest Service sensitive plant species, Coleman’s coral-root, a 

wild orchid. 

A redesigned process water pond has a double liner with leak collection and removal system over a 

geosynthetic clay liner, and the temporary storage pond has a single liner over a geosynthetic clay 

liner. A settling basin upstream of the process water containment has been included to provide 

containment for tailings settlement, if necessary, and to allow excess water to flow into the process 

water pond. Additionally, the leaching system barren solution pond was relocated upgradient of the 

process water pond to provide containment opportunities. 

This alternative includes a minimum 20-foot-thick final cap of waste rock atop the heap leach rather 

than the 50-foot minimum cap specified by the proposed action. A cap of 20 feet is considered 

sufficient as long as ponding is not occurring above the heap leach. 

A series of flowthrough drains beneath the tailings and waste rock facilities would replace the central 

drain and attenuation pond of the proposed action. These are rock drain structures placed in the 

natural drainage channels designed to pass stormwater beneath the tailings and waste rock facilities. 

The Phased Tailings Alternative redesigns the diversion and stormwater management system to 

incorporate a more conservative design to reduce the potential for failure during unusually high 

precipitation events. During both operations and postclosure, stormwater would be stored on top and 

on the benches of the waste rock and tailings facilities and would not be discharged downstream 

except in extreme events. 

The stormwater storage basins on the top and benches of the waste rock facility are designed to store 

the 500-year, 24-hour storm event. The stormwater storage basins on the top of the closed tailings 

facility are designed to store the 1,000-year, 24-hour storm event. Runoff from the plant site and the 

diversion west of the open pit would also be retained. This alternative would maintain flow from 

above the plant site by diverting it into upper McCleary Canyon both during operations and 

postclosure. 

Because this alternative would not encroach on the McCleary drainage for the tailings facility until 

around year 10, those portions would not begin reclamation until reclamation of other portions of the 

tailings and waste rock facilities have long been underway. Therefore, the entire outer edge of the 

facilities would not be consistent in the reclamation phasing. 

The Arizona National Scenic Trail would be realigned just outside the perimeter fence with a 

trailhead that would be located off of the primary access road, as shown in figure 13 in chapter 2 of 

the FEIS. Area roads that are outside the perimeter fence that would either be reconnected or 

decommissioned are shown in figure 16 in chapter 2 of the FEIS. The Sycamore Connector Road 

would be about 12,184 feet long. 

Draft Record of Decision – December 13, 2013

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Alternative 5 – Barrel Trail Alternative 

The Barrel Trail Alternative (see figure 21 in chapter 2 of the FEIS) was developed to respond to 

significant issues regarding potential impacts on visual resources and the surface water component of 

water resources. This alternative incorporates gentler and more varied slopes. This alternative was 

developed to respond to the purpose of and need for action. It would meet the purpose of and need for 

action by processing Rosemont Copper’s MPO in a manner that complies with applicable laws and 

regulations; and it would include measures for reclamation of surface resources. While this 

alternative would contain measures to minimize adverse environmental impacts on NFS surface 

resources, it would not do so as well as the selected action. 

The Barrel Trail Alternative would place all tailings and waste rock in upper Barrel, Trail, and Wasp 

Canyons. This alternative is similar to the selected action in that it would permanently avoid placing 

mine waste in McCleary Canyon to reduce effects on surface water flows to Barrel Canyon. A more 

varied topography is proposed to more closely replicate a natural landform than the other action 

alternatives. However, this alternative would expand the footprint of the tailings and waste rock

facilities. 

The Barrel Trail Alternative would incorporate a waste rock perimeter buttress that would completely 

surround the dry-stack tailings. The heap leach facility would be located in the same place as for the 

other alternatives. The primary access road from SR 83 would be the same as for the Phased Tailings 

Alternative, except that the tailings conveyor system would require modification to accommodate the 

relocated tailings facility. 

The general style for diversion and stormwater control structures would be similar to that of the 

Phased Tailings Alternative, except that the valley incorporated in the final mine waste landform 

would carry stormwater to Barrel Canyon instead of using the rock drop structures proposed under 

the Phased Tailings Alternative. However, engineering concepts available thus far indicate that rock 

drop structures and hardened channels would be required to manage the facility without incurring 

excess erosion (see figure 22 in chapter 2 of the FEIS). The Barrel Trail Alternative would use 

flowthrough drains, similar to the Phased Tailings Alternative.

With the Barrel Trail Alternative, concurrent reclamation could be delayed because of the need to 

rehandle material in order to form the final topography at closure. Reclamation time frame would be 

similar to that of the Phased Tailings Alternative. 

The Arizona National Scenic Trail alignment for this alternative is located east of SR 83 (see figure 

ROD-2). Area roads that are outside the perimeter fence that would either be reconnected or 

decommissioned are the same as for the selected action (see figure ROD-3). The Sycamore Connector 

Road would be about 12,184 feet long. 

Alternative 6 – Scholefield McCleary Alternative

The Scholefield-McCleary Alternative (see figure 23 in chapter 2 of the FEIS) was developed to 

respond to significant issues regarding potential impacts on cultural resources, riparian habitat

resources, and the surface water component of water resources that would arise from placing the 

tailings and waste rock in the McCleary and/or Barrel Canyon drainages. This alternative was 

developed to respond to the purpose of and need for action. It would meet the purpose of and need for 

action by processing Rosemont Copper’s MPO in a manner that complies with applicable laws and 

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regulations; and it would include measures for reclamation of surface resources. While this 

alternative would contain measures to minimize adverse environmental impacts on NFS surface 

resources, it would not do so as well as the selected action. 

The Scholefield-McCleary Alternative would place all tailings and the majority of waste rock north of 

the McCleary Canyon drainage channel. The dry-stack tailings would occupy Scholefield Canyon and 

an unnamed tributary drainage. Waste rock would be placed on the northern slope of McCleary 

Canyon above the drainage bottom and extend to the north on top of the tailings. Some waste rock 

would be placed in Barrel Canyon on top of and next to the heap leach facility. A series of conveyors 

would be required to carry the dry-stack tailings over the ridge into Scholefield Canyon. As currently 

expected, these conveyors would be elevated and would run through portions of McCleary Canyon 

east, then north around the footprint to the tailings facility (see figure 23 in chapter 2 of the FEIS). 

These conveyors would require lighting and a small one-lane maintenance road. 

Because of the relocation of mine waste to Scholefield Canyon, which is the site of the primary 

access road for the proposed action and other action alternatives, the road would be realigned, as 

shown in figures 23 and 24 in chapter 2 of the FEIS. The primary access road would intersect SR 83 

between mileposts 41 and 42 and would be 2.8 miles long. 

Diversion and stormwater control facilities would be designed to the same criteria used for the 

Phased Tailings Alternative, although there would not be any flowthrough drains. The heap leach 

facility and surrounding waste rock facility would use the same stormwater control design criteria as 

the Phased Tailings Alternative.

In order to maintain concurrent reclamation of final outer slopes, waste rock would initially be placed 

in berms along the outside edge of the waste rock facility near SR 83 and later placed behind the 

berms. Because of the ultimate height and slope of this alternative, it is likely that reclamation efforts 

would require more time to implement, resulting in longer reclamation phasing. It is also likely that 

reclamation efforts for this alternative would focus on slope stability and structural integrity and may 

be delayed or altered for safety reasons during final design. 

The Scholefield-McCleary Alternative is the most problematic with respect to concurrent 

reclamation, with constraints caused by its having greater slopes, greater safety concerns, and less 

soil salvage material. The conveyor system located east of the waste rock and tailings facilities would 

also likely be removed and the area reclaimed during final closure activities. 

The heap leach facility would be located in Barrel Canyon, as it would for the proposed action, the 

Barrel Trail Alternative, and the Phased Tailing Alternative. Reclamation of the heap leach pad would 

be similar to the Phased Tailings Alternative. 

The Arizona National Scenic Trail alignment analyzed as part of this alternative is the same as for the 

Barrel Trail Alternative and is located east of SR 83 (see figure ROD-2). 

Area roads that are outside the perimeter fence that would either be reconnected or decommissioned 

are the same as for the selected action (see figure ROD-3). There is no Sycamore Connector Road in 

this alternative. 

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Alternatives Eliminated from Detailed Study

NEPA, the CWA, Organic Administration Act, and Forest Service regulations (36 CFR 228) 

governing mineral development on NFS lands provide guidance regarding alternatives development. 

Reasonable alternatives include those “that are practical or feasible from technical and economic 

standpoints and using common sense, rather than simply desirable from the standpoint of the 

applicant.” The selection of alternatives under Council on Environmental Quality (CEQ) criteria 

includes consideration of a reasonable range of alternatives that meet the project purpose and need 

and are economically and technically feasible. 

I considered a number of alternatives and alternative themes that were evaluated but eliminated from 

detailed study. These alternatives included mining other locations; using alternate mining methods;

backfilling and partially backfilling the open pit; modifying the life of the mine; changing the 

scheduled hours of operation; suspending operations during high wind events; using alternate water 

supply sources; modifying the transportation of workers, supplies, and shipments; using a natural gas 

pipeline instead of an electrical transmission line; performing a land exchange; downsizing the 

electrical transmission line; and burying the electrical transmission line. A more detailed discussion 

of these alternatives appears in the FEIS (chapter 2, pp. 100 to 114, under “Alternatives Considered 

but Eliminated from Detailed Study”), along with the rationale for dismissal. These potential 

alternatives were identified as a result of public participation as well as agency concerns. The six

alternatives considered in the FEIS present a range of reasonable alternatives designed to address the 

significant issues identified by the Forest Service.

Environmentally Preferable Alternative 

The identification of an environmentally preferred alternative is required by NEPA (40 CFR 

1508.2(b)). The environmentally preferred alternative is the alternative that has the least impact on 

the physical and biological environment and that best protects, preserves, and enhances historic, 

cultural, and natural resources. Economic, social, technical, and agency mission factors are not 

considered in the identification of this alternative. 

After evaluating all alternatives presented in the FEIS, I find that “Alternative 1 – No Action” is the 

most environmentally preferable alternative. This alternative best protects, preserves, and enhances 

historic, cultural, and natural resources. Each of the action alternatives would result in permanent 

adverse impacts to historic, cultural, and natural resources. However, the environmentally preferable 

alternative does not meet the agency need to process Rosemont Copper’s MPO in a timely manner.

Chapter 3 of the FEIS contains a more detailed evaluation of impacts associated with the various 

alternatives, including the no action alternative. 

Public Involvement

Scoping

On March 13, 2008, the Coronado began soliciting comments on the preliminary MPO with 

publication in the Federal Register of a “Notice of Intent to Prepare an Environmental Impact 

Statement” (Federal Register 73(50):13527–13529). The Notice of Intent summarized the proposed 

action and stated that the impacts of the proposed action, including a reclamation plan, amendment to 

the Coronado forest plan, and connected actions, would be evaluated in the EIS. Six open house 

public meetings were held as follows: March 18, 2008 (Tucson, Arizona); March 19, 2008 (Green 

Valley, Arizona); March 20, 2008 (Patagonia, Arizona); April 5, 2008 (Vail, Arizona); April 22, 2008 

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(Sahuarita, Arizona); and April 23, 2008 (Elgin, Arizona). Approximately 1,000 people attended the 

open houses. Oral and written comments were solicited at the meetings and accepted on a toll free 

phone line and by mail, hand delivery, facsimile, and email throughout the initial 30-day scoping 

period. 

On April 29, 2008, a “Corrected Notice of Intent to Prepare an Environmental Impact Statement” was 

published in the Federal Register (73(83):23181). This notice announced a change in the duration of 

the scoping comment period and provided information regarding three public hearings. The scoping 

comment period was extended to July 14, 2008, for a total scoping comment period of 120 days. 

The following public hearings were held: May 12, 2008 (Elgin, Arizona); June 7, 2008 (Sahuarita, 

Arizona); and June 30, 2008 (Tucson, Arizona). Both oral testimony and written comments were 

collected at the public hearings. Oral testimony was professionally audio-recorded and documented 

by a court reporter. A total of 860 people signed in at the public hearings, with 169 people presenting 

formal oral comments. On June 27, 2008, in response to public concerns about constraints limiting 

hearing attendance and participation, the Coronado hosted a toll-free phone hotline for use by the 

public to provide comments. A total of 302 people left recorded comments, which were transcribed 

for the project record.

The Coronado received 11,082 comment submittals during the scoping comment period, 70 percent 

of which were postcards, petitions, and form-letter submittals. Approximately 16,000 discrete 

comments were identified among those received. In addition, submittals received during the scoping 

period from March 13, 2008, through August 1, 2008, were recorded and analyzed. A systematic 

process referred to as content analysis was used to organize the contents of the submittals. 

Twelve significant issues were identified after content analysis of the scoping comments. These issues 

are described in chapter 1 of the FEIS, and summarized on pp. 4 to 9 of this ROD. Consideration of 

these issues led, in part, to the development of alternatives to the proposed action that are considered 

in this FEIS (see chapter 2) and the approach used for impacts analyses reported in chapter 3 of the 

FEIS. Detailed records about this process are contained in the project record. 

Public Review of the Draft Environmental Impact Statement

On October 19, 2011, a “Notice of Availability of Draft Environmental Impact Statement” for the 

Rosemont Copper Project DEIS was published in the Federal Register (76(202):64893–64894). 

The notice of availability began a 90-day public comment period. On January 19, 2012, with the 

publication of a notice in the Federal Register, the Forest Supervisor extended the formal comment 

period for the DEIS through January 31, 2012, because a technical problem with the electronic mail 

inbox for public comments resulted in the rejection of some comments for a brief period of time on 

January 18, 2012. 

Seven open public meetings were held: November 12, 2011 (Tucson, Arizona); November 19, 2011 

(Vail, Arizona); December 1, 2011 (Vail, Arizona); December 7, 2011 (Benson, Arizona); December 

8, 2011 (Green Valley, Arizona); December 10, 2011 (Elgin, Arizona); and January 14, 2012 

(Sahuarita, Arizona). The first six meetings consisted of both an informational and an oral comment 

session. The seventh meeting was an oral comment session. Coronado ID team resource specialists 

staffed the informational sessions to answer questions and provide information pertinent to the DEIS. 

Oral comment sessions allowed the public to provide oral comments directly to the Coronado Forest 

Supervisor, Coronado Deputy Forest Supervisor, and/or Nogales District Ranger. Oral comments 

were professionally audio-recorded and documented by a court reporter. 

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Oral and written comments were also accepted by mail, email, hand delivery, facsimile, and 

telephone recording, as well as through the project Web site, throughout the formal public 

involvement period. Documentation of the formal DEIS comment process is contained in the project 

record. Comments were received from individuals; tribal governments; Federal, State, and local 

agencies; organized interest groups; and businesses. The Coronado received more than 25,000 

submissions during the DEIS comment period. Content analysis was used to categorize the nature of 

comments received by issue and concern. Appendix G of the FEIS contains a summary of Forest 

Service responses to comments received on the DEIS. Detailed records about this process are 

contained in the project record. 

Comments received on the DEIS helped to inform the decision in a number of ways, including but 

not limited to the following: 

• The issues and their measurement factors were refined and clarified;

• Analysis methodologies were modified and improved for a number of resources; 

• Information provided helped to better describe existing conditions; 

• The analysis of the effects of the no action alternative was broadened in response to 

comments;

• Several of the action alternatives were modified in response to comments and 

suggestions; 

• Public comments and input from agencies and tribes contributed to development of a 

number of mitigation and monitoring measures; and

• Information provided helped to identify past, present and reasonably foreseeable 

actions that were incorporated into cumulative impact analysis.

Overall, changes and modifications made in response to comments and information received during 

the DEIS comment process led to improved analysis and disclosure of impacts that I took into 

consideration in making my decision. They also led to development of many mitigation measures that 

will reduce potential environmental impacts and monitoring measures that will be used to ensure that 

the project is implemented in accordance with this decision. 

Consultation with Tribes and Government Agencies

Tribal Consultation

Several regulations require that Federal agencies consult on a government-to-government basis with 

federally recognized Native American tribes having traditional interests in and/or ties to the lands 

potentially affected by a proposed action and alternatives. Federal land management agencies, 

including the Forest Service, are required to consult with American Indian tribes not only under 

mandated law but also under the U.S. Government’s trust responsibility to tribal nations. The 

Coronado commenced official consultation with 12 tribes in March 2006 upon notice of Rosemont 

Copper’s intent to file a preliminary MPO. Another letter was sent in March 2008 giving notice that 

the project was continuing. Details of tribal consultation are summarized in the “Cultural Resources” 

resource section in chapter 3 and in appendix E of this FEIS. 

The Tohono O’odham Nation maintains deep and significant cultural, spiritual, social, physical, and 

holy ties to the Santa Rita Mountains, known in their native language as Ce:wi Duag. Other American 

Indian tribes, including the Ak Chin Indian Community, Fort Sill Apache Tribe, Gila River Indian 

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Community, Hopi Tribe, Mescalero Apache Tribe, Pascua Yaqui Tribe, Salt River Pima-Maricopa 

Indian Community, San Carlos Apache Tribe, White Mountain Apache Tribe, Yavapai-Apache 

Nation, and Pueblo of Zuni, are also recognized as stakeholders with interest in and association to the 

Santa Rita Mountains. Ce:wi Duag has been determined by Arizona SHPO to be eligible for inclusion 

in the NRHP as a traditional cultural property. The Tohono O’odham Nation is often deferred to and 

considered the lead tribal entity with regard to activities and projects associated with the Santa Rita

Mountains. 

Either my staff or I met personally with tribal representatives on more than 25 separate occasions

concerning the Rosemont Copper Project. These meetings consisted of field trips, formal consultation 

meetings, interviews, and presentations to Tribal Councils and other tribal groups. Mitigation 

recommendations and project concerns from the tribes were identified and integrated into the EIS

(see the “Cultural Resources” section in chapter 3 of the FEIS; and mitigation measures FS-CR-01 

through FS-CR-11 in appendix B of the FEIS). The Tohono O’odham Nation and Pascua Yaqui Tribe

have passed formal tribal resolutions opposing the Rosemont Copper Project. Implementation of the 

project will be completed, to the extent feasible, with respect toward the values inherent in Ce:wi 

Duag Traditional Cultural Property and in compliance with applicable laws and regulations. 

Consultation with the Arizona SHPO has been completed, and a finding was made that the project 

would result in adverse effects on historic properties. 

Cooperating Agency Consultation

Consultation with Federal and State agencies occurred throughout the EIS preparation process. This 

included inviting 33 Federal, State, and local agencies to participate as cooperating agencies. Sixteen 

agencies ultimately accepted and participated as official cooperating agencies: Department of 

Defense – Air Force; USACE; Smithsonian Astrophysical Observatory, Fred Lawrence Whipple 

Observatory; BLM, Tucson Field Office; AGFD; Arizona Department of Mines and Mineral 

Resources; ADOT; ADWR; Arizona Geological Survey; Arizona State Mine Inspector; Arizona State 

Parks; City of Tucson; Pima County; and Town of Sahuarita. The Tohono O’odham Nation also 

signed an agreement to participate as a cooperating agency. The Coronado held regular meetings with 

cooperating agencies and solicited their review and comment at key points of the process, including 

prior to release of the DEIS and FEIS. In addition to interaction with cooperating agencies, the 

Coronado consulted with the USFWS regarding compliance with Section 7 of the ESA; and Arizona 

SHPO, ACHP, and others regarding compliance with Section 106 of the NHPA. The Coronado also 

worked closely with the USACE, EPA, and ADEQ regarding permits under their purview. In 

addition, the Coronado worked closely with staff from Saguaro National Park concerning impacts 

that could impact the park. 

Information and suggestions provided by the cooperating agencies was used to clarify aspects of the 

alternatives; modify analysis methods to more accurately predict environmental impacts; develop 

mitigation and monitoring measures; and better understand divergent scientific viewpoints regarding 

a number of environmental issues. Overall, information provided, and changes and modifications 

made in response to cooperating agency contributions led to improved analysis, more thorough 

disclosure of impacts, and a better understanding of scientific viewpoints, which I took into 

consideration in making my decision. 

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Financial Assurance

The Forest Service is authorized to require an operator to furnish a bond or other financial 

assurance for MPOs to ensure reclamation of surface disturbances to prevent or control damage to 

the environment; to control erosion, landslides, water runoff and toxic materials; and to provide for 

rehabilitation of fish and wildlife habitat (36 CFR 228.13). In addition, bonding will include funds 

for mitigation of cultural sites disturbed by project activities if implementation is delayed or not 

completed. The Forest Service has developed guidance for calculating the amount of financial 

assurance required for mining projects. In developing the financial assurance amount for the 

Rosemont Copper Project, the Coronado will follow the 2004 guidance and include costs to remove 

structures, regrade and recontour the surface, replace soil, and revegetate the reclaimed land. 

The financial assurance will also include necessary administrative and overhead costs to complete 

the reclamation if the company were unable or unwilling to do so and costs for long-term 

treatments or monitoring, if such treatment were to be required to meet applicable laws and 

regulations. 

The financial assurance will be required in a readily available bond instrument payable to the 

Coronado. In order to ensure that the bond can be adjusted as needed to reflect actual costs and 

inflation, there will be provisions allowing for periodic adjustment on bonds in the final MPO prior to 

approval. Selection of the bond period may be based on some logical stage of mine development, 

such as construction, certain facilities’ implementation, and/or closure. Initial bond estimates are 

typically based on the engineering plans for construction, and it is likely that the initial bond for this 

project will be calculated to cover the construction period, with the first periodic review planned for 1 

year after construction begins. The Forest Service process does not require calculation of the bond 

prior to publication of the FEIS or completion of the NEPA process. 

Because this project is on both private and Federal lands, both the Forest Service and the Arizona 

State Mine Inspector have financial assurance and/or bonding requirements. The Arizona State Mine 

Inspector has expressed a willingness to work cooperatively with the Coronado to bond for the 

project, covering the private lands as well. 

Mitigation under Section 404 of the CWA also requires financial assurance. ADEQ requires a permit 

and bonding as part of the APP for closure and groundwater protection. Rosemont Copper has 

submitted calculations in section 13 of their APP application that include all reclamation costs, 

including bonds for the Forest Service, Arizona State Mine Inspector, and ADEQ. 

Findings Required by Other Laws, Executive Orders, and Rules

Several Federal laws and regulations apply to the Forest Service decision to approve an MPO as 

proposed, or require changes and additions to the preliminary MPO. As required by NEPA, an EIS 

describing the potential “significant environmental effects” that may result from this decision, and 

several alternatives, has been prepared. The scope of the action, a reasonable range of alternatives, 

and site-specific environmental effects were assessed in the EIS as required. 

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National Forest Management Act

NFMA requires that all permits, contracts, and other instruments for the use and occupancy of NFS 

land be consistent with forest land and resource management plans. My decision includes 

amendments to the 1986 Coronado forest plan to address the inconsistencies of the proposed project 

with current standards and guidelines. The forest plan amendment will create a new management 

area, with new standards and guidelines. The activities associated with the Rosemont Copper Project 

will comply with the Coronado forest plan, as amended.

Finding of Nonsignificant Amendment

Under the NFMA (16 U.S.C. 1604(f)(4)), forest plans may “be amended whatsoever after final 

adoption and after public notice.” Federal regulations at 36 CFR 219.14 allow forests to use the 

provisions of the planning regulations in effect before November 9, 2000, in order to amend forest 

plans. These regulations state that the responsible official shall: (1) determine whether proposed 

changes to a land management plan are significant or not significant in accordance with the 

requirements of sections 1926.51; (2) document the determination of whether the change is 

significant or not significant in a decision document; and (3) provide appropriate public notification 

of the decision prior to implementing the changes. 

The “Forest Service Land and Resource Management Planning Manual” (Forest Service Manual 

(FSM) 1926.51) provides a framework for determining whether a proposed change to a forest plan is 

or is not significant. An amendment is not significant when it involves: 

1. Actions that do not significantly alter the multiple-use goals and objectives for long-term 

land and resource management.

2. Adjustments of management area boundaries or management prescriptions resulting from 

further on-site analysis when the adjustments do not cause significant changes in the 

multiple-use goals and objectives for long-term land and resource management. 

3. Minor changes in standards and guidelines. 

4. Opportunities for additional projects or activities that will contribute to achievement of the 

management prescription. 

An amendment may be significant when it involves: 

1. Changes that would significantly alter the long-term relationship between levels of multipleuse goods and services originally projected (see section 219.10(e) of the planning regulations 

in effect before November 9, 2000 (see 36 CFR parts 200 to 299, revised as of July 1, 2000)). 

2. Changes that may have an important effect on the entire land management plan or affect land 

and resources throughout a large portion of the planning area during the planning period. 

The Coronado proposes to amend its forest plan in order to address the inconsistencies of the 

proposed project with current standards and guidelines. The proposed forest plan amendment would 

create a new management area for which direction specific to copper mining would apply. The 

management area and its standards and guidelines apply only to the Rosemont area and would not 

affect activities outside the Rosemont area. This amendment would be in effect for the life of the 

forest plan. 

Draft Record of Decision – December 13, 2013

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The Forest Supervisor has evaluated the proposed changes to management direction to determine 

whether they constitute a significant amendment to the Coronado forest plan. This evaluation 

addresses the Rosemont Copper proposed action and all action alternatives. The following discussion 

provides the rationale for the determination of significance. 

1. Actions that do not significantly alter the multiple-use goals and objectives for longterm land and resource management.

The proposed amendment to the forest plan does not alter any of the multiple-use goals and 

objectives for long-term land and resource management. The amendment proposes changes 

in management direction to address mining and associated activities to occur in the Rosemont 

area only. Adoption of this amendment will allow activities that are inconsistent with a 

number of forest-wide standards and guidelines. However, these activities are restricted to the 

Rosemont area and will not have wide-ranging effects across the Coronado National Forest.

While environmental effects could extend beyond the Rosemont area, as disclosed in chapter

3 of the FEIS, they are not expected to significantly alter the multiple-use goals and 

objectives of the forest plan as a whole. 

2. Adjustments of management area boundaries or management prescriptions resulting 

from further on-site analysis when the adjustments do not cause significant changes in 

the multiple-use goals and objectives for long-term land and resource management. 

Management areas boundaries will be adjusted for management areas 1, 4, and 7 with this 

amendment. Management prescriptions for these management areas will not change. The 

changes are not expected to cause significant changes in the multiple-use goals and objectives 

for long-term land and resource management. 

3. Minor changes in standards and guidelines.

The proposed amendment to the forest plan adopts new standards and guidelines for 

management area 16, which is a new management area. When compared with the existing 

standards and guidelines for management areas 1, 4, and 7, changes go beyond what could be 

considered minor. However, when considered on a forest-wide basis, changes will be minor 

because they apply to the proposed management area 16 area only, which constitutes only 

0.61 percent of the net acres of the Coronado National Forest (based on net forest acres of 

1,726,514 from forest plan table 2a; and net management area 16 acres of 10,531 derived 

from geographic information system (GIS) data).

4. Opportunities for additional projects or activities that will contribute to achievement of 

the management prescription.

The proposed amendment establishes a new management area and thus a new management 

prescription. It provides opportunities for mining and associated activities that have impacts 

that are both beneficial and detrimental, as described in chapter 3 of the FEIS. 

Evaluation of the four examples of amendments that are not significant does not conclusively 

determine whether the proposed amendment is significant. Therefore, the two examples given in 

FSM 1926.51 as indicative of circumstances that may cause a significant change to a land 

management plan have also been evaluated:

1. Changes that would significantly alter the long-term relationship between levels of 

multiple-use goods and services originally projected (see section 219.10(e) of the 

planning regulations in effect before November 9, 2000 (see 36 CFR parts 200 to 299, 

revised as of July 1, 2000)). 

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The proposed amendment will not significantly alter the long-term relationship between 

levels of multiple-use goods and services originally projected in the Coronado forest plan. As 

described in chapter 3 of the Rosemont Copper Project FEIS, the project could reduce 

grazing capacity and livestock use; dispersed and wildlife recreation use; and water yield. It 

could also reduce the number of acres meeting visual quality objectives, and reduce air and 

water quality. However, these effects will take place only within and adjacent to the 

Rosemont mining area (management area 16). When considered in the context of the 

1,726,514-acre Coronado National Forest planning area, the effects will not be significant.

Refer to chapter 3 of the FEIS for details regarding environmental effects of the proposed 

action and action alternatives.

2. Changes that may have an important effect on the entire land management plan or 

affect land and resources throughout a large portion of the planning area during the 

planning period. 

The proposed amendment affects only a small portion of the Coronado National Forest, 

which is the planning area for the forest plan. While the effects are substantial, they are 

highly localized and will not have a significant effect on the entire land management plan, 

nor will they affect land and resources throughout a large portion of the planning area. 

Finding

On the basis of the information summarized above, it is my determination that this will not constitute 

a significant amendment to the Coronado forest plan. The current forest plan is nearing the end of the 

first planning period and is being revised. The proposed management direction described above will 

be amended to the current forest plan and incorporated into the revised plan. 

The Endangered Species Act 

Section 7(a)(2) of the ESA requires Federal agencies to consult with the USFWS, as appropriate, to 

ensure that their actions do not jeopardize the continued existence of species listed as threatened or 

endangered under ESA, or destroy or adversely modify their critical habitat. A biological assessment 

(BA) was completed and identified potential threats from project actions that could affect federally 

listed threatened or endangered species. The BA was transmitted to USFWS to initiate formal 

consultation on the determination of effects. USFWS issued a BO for impacts to listed species on 

October 30, 2013. The BO included specific conservation measures, reasonable and prudent 

measures, and terms and conditions that apply to approval of the MPO. 

The Forest Service prepared a BA on federally listed terrestrial and aquatic threatened and 

endangered species. The Forest Service found that the selected action MAY AFFECT, AND IS

LIKELY TO ADVERSELY AFFECT the following federally threatened or endangered species:

• Lesser long-nosed bat, listed as endangered. The USFWS found that the selected 

action is not likely to jeopardize the continued existence of the lesser long-nosed bat.

The USFWS issued an incidental take statement for direct and indirect take of lesser 

long-nosed bats. They also included non-discretionary reasonably and prudent 

measures and terms and conditions that will be implemented. The following review 

requirement is specified for the lesser long-nosed bat: 

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Review requirement: The reasonable and prudent measures, with their 

implementing terms and conditions, are designed to minimize incidental take that 

might otherwise result from the selected action. If, during the course of the action, 

the level of incidental take is exceeded, such incidental take will represent new 

information requiring review of the reasonable and prudent measures provided. The 

Coronado must immediately provide an explanation of the causes of the taking and 

review with the USFWS the need for possible modification of the reasonable and 

prudent measures. 

• Jaguar, listed as endangered with proposed critical habitat within the action area. 

The USFWS found that the selected action is not likely to jeopardize the continued 

existence of the jaguar and is not likely to destroy or adversely modify proposed 

critical habitat. The USFWS issued an incidental take statement for indirect take of 

jaguar. They also included non-discretionary reasonably and prudent measures and 

terms and conditions that will be implemented. The following review requirement is 

specified for the jaguar: 

Review requirement: The USFWS believes that no more than one jaguar will be 

incidentally taken (in the form of harassment) as a result of the selected action. The 

reasonable and prudent measures, with their implementing terms and conditions, are 

designed to minimize incidental take that might otherwise result from the selected

action. If, during the course of the action, the level of incidental take is exceeded, such 

incidental take will represent new information requiring review of the reasonable and 

prudent measures provided. The Coronado must immediately provide an explanation of 

the causes of the taking and review with the USFWS the need for possible modification 

of the reasonable and prudent measures.

• Ocelot, listed as endangered. The USFWS found that the selected action is not likely 

to jeopardize the continued existence of the ocelot. Incidental take of ocelots is not 

anticipated. 

• Pima pineapple cactus, listed as endangered. The USFWS found that the selected 

action is not likely to jeopardize the continued existence of the Pima pineapple 

cactus. 

• Chiricahua leopard frog, listed as threatened with designated critical habitat within 

the action area. The USFWS found that the selected action is not likely to jeopardize 

the continued existence of the Chiricahua leopard frog and is not likely to destroy or 

adversely modify designated critical habitat. The USFWS issued an incidental take 

statement for direct and indirect take of Chiricahua leopard frog. They also included 

non-discretionary reasonably and prudent measures and terms and conditions that 

will be implemented.

• Gila chub, listed as endangered with designated critical habitat within the action area. 

The USFWS found that the selected action is not likely to jeopardize the continued 

existence of the Gila chub and is not likely to destroy or adversely modify designated 

critical habitat. The USFWS issued an incidental take statement for indirect take of 

Gila chub. 

• Gila topminnow, listed as endangered. The USFWS found that the selected action is 

not likely to jeopardize the continued existence of the Gila topminnow. The USFWS 

issued an incidental take statement for indirect take of Gila topminnow. 

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• Huachuca water umbel, listed as endangered with designated critical habitat (but not in 

the action area). The USFWS found that the selected action is not likely to jeopardize 

the continued existence of the Huachuca water umbel and is not likely to destroy or 

adversely modify designated critical habitat because critical habitat is not present 

within the action area. Incidental take of Huachuca water umbel is not anticipated.

The Forest Service found that the selected action MAY AFFECT, BUT IS NOT LIKELY TO 

ADVERSELY AFFECT the threatened Mexican spotted owl. The USFWS concurred with this 

determination. 

Regional Forester’s Sensitive Species

As described in FSM 2670.12, the Forest Service will do the following: (1) manage “habitats for all 

existing native and desired nonnative plants, fish, and wildlife species in order to maintain at least 

viable populations of such species;” and (2) avoid actions that “may cause a species to become 

threatened or endangered.”

The Forest Service prepared a biological evaluation on species designated as sensitive by the Region 3

Regional Forester. The Coronado found that the selected action MAY IMPACT INDIVIDUALS BUT 

IS NOT LIKELY TO RESULT IN A DOWNWARD TREND TOWARD FEDERAL LISTING AS 

THREATENED OR ENDANGERED OR A LOSS OF POPULATION VIABILITY for the 

following plant species: Arid throne fleabane, Arizona coralroot, Arizona giant sedge, Arizona manihot, 

Bartram stonecrop, Beardless chinchweed, Broadleaf ground cherry, Chihuahuan sedge, Chiricahua 

Mountain brookweed, Coleman’s coral-root, Huachuca golden aster, Lemmon milkweed, Lemmon’s 

lupine, Lemmon’s stevia, Lemon lily, Metcalfe’s tick-trefoil, Nodding blue-eyed grass, Pima Indian 

mallow, Santa Rita yellowshow, Santa Cruz striped agave, Sonoran noseburn, Southwestern (Box 

Canyon) muhly, Sycamore Canyon (Weeping) muhly, and Tumamoc globeberry.

The Forest Service found that the selected action MAY IMPACT INDIVIDUALS BUT IS NOT 

LIKELY TO RESULT IN A DOWNWARD TREND TOWARD FEDERAL LISTING AS 

THREATENED OR ENDANGERED OR A LOSS OF POPULATION VIABILITY for the 

following amphibian species: Great Plains narrow-mouthed toad, lowland leopard frog, and western 

barking frog. 

The Forest Service found that the selected action MAY IMPACT INDIVIDUALS BUT IS NOT 

LIKELY TO RESULT IN A DOWNWARD TREND TOWARD FEDERAL LISTING AS 

THREATENED OR ENDANGERED OR A LOSS OF POPULATION VIABILITY for the 

following reptile species: Arizona ridge-nosed rattlesnake, giant spotted whiptail, Gila monster, green 

ratsnake, mountain skink, northern Mexican gartersnake, Slevin’s bunchgrass lizard, and Sonoran 

desert tortoise. 

The Forest Service found that the selected action MAY IMPACT INDIVIDUALS BUT IS NOT 

LIKELY TO RESULT IN A DOWNWARD TREND TOWARD FEDERAL LISTING AS 

THREATENED OR ENDANGERED OR A LOSS OF POPULATION VIABILITY for the 

following bird species: Abert’s towhee, American peregrine falcon, Arizona grasshopper sparrow, 

Baird’s sparrow, broad-billed hummingbird, buff-collared nightjar, cactus ferruginous pygmy-owl, 

common blackhawk, elegant trogon, Gould’s turkey, Lucifer hummingbird, northern beardlesstyrannulet, northern goshawk, northern gray hawk, varied bunting, violet-crowned hummingbird, 

western yellow-billed cuckoo, and whiskered screech-owl. 

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Forest Service found that the selected action MAY IMPACT INDIVIDUALS BUT IS NOT 

LIKELY TO RESULT IN A DOWNWARD TREND TOWARD FEDERAL LISTING AS 

THREATENED OR ENDANGERED OR A LOSS OF POPULATION VIABILITY for the 

following fish species: longfin dace. 

Forest Service found that the selected action MAY IMPACT INDIVIDUALS BUT IS NOT 

LIKELY TO RESULT IN A DOWNWARD TREND TOWARD FEDERAL LISTING AS 

THREATENED OR ENDANGERED OR A LOSS OF POPULATION VIABILITY for the 

following invertebrate species: Cestus skipper. 

Forest Service found that the selected action MAY IMPACT INDIVIDUALS BUT IS NOT

LIKELY TO RESULT IN A DOWNWARD TREND TOWARD FEDERAL LISTING AS 

THREATENED OR ENDANGERED OR A LOSS OF POPULATION VIABILITY for the 

following mammal species: Allen’s big-eared bat, Arizona shrew, California leaf-nosed bat, 

Cockrum’s desert shrew, fulvous harvest mouse, greater western mastiff bat, hooded skunk, 

Merriam’s Mouse, Mexican long-tongued bat, northern pygmy mouse, pale Townsend’s big-eared 

bat, Plains harvest mouse, pocketed free-tailed bat, western red bat, western yellow bat, white-nosed 

coati, and yellow-nosed cotton rat. 

The Migratory Bird Treaty Act of 1918

Approval of a final MPO has been determined to be in compliance with requirements of the 

Migratory Bird Treaty Act (see “Biological Resources” in chapter 3 of the FEIS).

Water Pollution Control Act of 1972 (Clean Water Act)

The Federal Water Pollution Control Act of 1972 (PL 92-500) as amended in 1977 (PL 95- 217) and 

1987 (PL 100-4) is also known as the Federal CWA. AZPDES permits for discharges of process 

wastewater and stormwater under Section 402 of the CWA will be required for the approved of a final 

MPO. Section 404 of the CWA regulates discharge of dredged or fill material to wetlands and WUS; a 

404 permit will also be required for the final MPO. The CWA establishes a non-degradation policy 

for all federally proposed projects to be accomplished through planning, application, and monitoring 

of BMPs. Identification of BMPs is mandated by Section 319 of the Water Quality Act of 1987 (also 

referred to as the CWA), which states, “It is national policy that programs for the control of non-point 

sources of pollution be developed and implemented.” Sediment control BMPs are required for road 

construction and maintenance. The stormwater permit(s) will also require BMPs for operational 

control of runoff and sediment.

The Clean Air Act, as amended in 1990

Rosemont Copper will be required to obtain a State of Arizona air quality permit for operation of 

certain equipment. ADEQ issued an air quality permit to Rosemont Copper on January 31, 2013. The 

permit will be revised after this decision is issued to reflect the requirements of the selected action.

Upon receipt of this permit, operations under the final MPO will be in compliance with State and 

Federal CAA requirements.

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Federal Noxious Weed Act of 1974

Rosemont Copper is required as a condition of the final MPO to update their weed management plan 

in coordination with the Coronado. Preparation and implementation of this plan will meet the 

requirements of the Noxious Weed Act. 

National Historic Preservation Act

In a letter dated February 15, 2013, the Arizona SHPO concurred with the Coronado regarding the area 

of potential effects (APE) and that the project would result in adverse effects on historic properties. The 

Forest Service completed a cultural resource survey of the APE of operations under the final MPO in 

compliance with the requirements of Section 106 of the NHPA (16 U.S.C. 470 et seq.). An MOA was 

developed and agreed to by a number of signatories, including the Coronado, Rosemont Copper, 

Arizona SHPO, the ACHP, and others. The MOA is located in appendix D of the FEIS. 

Wetlands (Executive Order 11990)

Section 404 of the CWA authorizes the USACE to issue permits for activities that will result in the 

placement of dredged or fill material in WUS. Before a permit can be issued, Section 404(b)(1) 

guidelines require that projects avoid impacts to the extent possible, minimize impacts that cannot be 

avoided, and provide compensatory mitigation for impacts that occur. The selected action is estimated 

to impact a total of 42.8 acres of WUS. Rosemont Copper will be required by conditions in the final 

MPO to obtain Section 404 approval from the USACE prior to impacting the jurisdictional WUS. 

Floodplains (Executive Order 11988)

Operations under the final MPO will have limited impacts to floodplains, and Coronado approval of 

the Rosemont Copper MPO is in compliance with Executive Order 11988. The only construction 

activities that will occur within a floodplain are associated with the utility corridor. These activities 

are necessary for the project, and no feasible alternative to their implementation was identified in the 

EIS analysis.

Environmental Justice (Executive Order 12898)

The Coronado’s approval of the final MPO will result in disproportionate adverse environmental 

effects on the Tohono O’odham Nation and the other consulting tribes with interests in the project 

area, which qualify as minority or low-income communities. The impacts identified with the project 

include the known presence of ancestral villages, human remains, sacred sites, and traditional 

resource collecting areas, and the understanding that disturbance will cause spiritual harm to the earth 

and to the people present now and in the future. Refer to the “Socioeconomics and Environmental 

Justice” section in chapter 3 of the FEIS for further details.

Tribal Consultation and Coordination (Executive Order 13175)

The Coronado consulted with 12 tribes during the development of the EIS. Ten of these tribes actively 

participated in consultation activities. Primary consultation between the Forest Service and tribal 

entities has included meetings, field visits, conference calls, phone calls, and letters. The tribes were 

consulted prior to and throughout the planning process for this project. Each tribe also received a copy 

of the DEIS. The Coronado received comments from consulting tribes during the scoping process, 

during various meetings and fieldtrips, and in response to the DEIS. Written correspondence is located 

in the project record; a listing of meetings and field trips can be found in appendix E of the FEIS. 

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Procedures for Change During Implementation

Modifications to the MPO may be proposed by Rosemont Copper or requested by the Forest Service 

due to reasons such as unforeseen significant impacts to surface resources. The monitoring plan 

described in appendix B of the FEIS contains monitoring specifically designed to identify whether 

impacts of the project are within those projected in the impact analysis disclosed in the FEIS. The 

Coronado will evaluate the results of project implementation monitoring, including field verification, 

on a regular basis. 

Rosemont Copper is responsible for complying with the requirements of the USFWS BO and the 

Arizona SHPO MOA, and the Forest Service is responsible for monitoring to ensure compliance. 

Should non-compliance of any requirement of the BO or MOA occur, the Forest Service would take 

appropriate action which could include enforcement or consultation with the appropriate agency to 

determine whether further action may be needed. 

Rosemont Copper is responsible for complying with all applicable permit requirements, as well as 

applicable laws and regulations. It is the responsibility of the primary permitting agency to determine 

whether Rosemont Copper’s actions comply its permits and underlying regulations. If Rosemont 

Copper is notified of non-compliance by a permitting agency, it is responsible for notifying the Forest 

Service of the situation in a timely manner. Acting within its authority, the Forest Service will review 

the situation and determine whether and what action may be needed by the Forest Service. 

In determining whether further NEPA action is required, I will first consider whether any major 

federal action subject to NEPA is proposed. If a Federal action subject to NEPA is proposed, then I 

will consider the criteria to supplement an existing environmental impact statement in 40 CFR 

1502.9(c) and Forest Service Handbook 1909.15, section 18, and, in particular, determine whether the 

proposed change is a substantial change to the intent of the selected action as planned and already 

approved, and whether the change is relevant to environmental concerns. Connected or interrelated 

proposed changes regarding particular areas or specific activities will be considered together in 

making this determination. The cumulative impacts of these changes will also be considered. 

Implementation Date

Upon completion of the administrative process and submittal by the Rosemont Copper Project 

proponent of a modified MPO reflecting this decision, posting of a bond, the final MPO will be 

approved. 

Draft Record of Decision – December 13, 2013

64 Rosemont Copper Project, Coronado National Forest

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Contact Person 

For further information on this decision, contact: 

Mindy Sue Vogel

Minerals and Geology Program Manager

Coronado National Forest 

300 W. Congress Street 

Tucson, AZ 85701

Phone: (520) 388-8327 

Email: msvogel@fs.fed.us 

Signature and Date 

_____________________________ _______________ JIM UPCHURCH Date

Forest Supervisor, Coronado National Forest 

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Appendix A 

Detailed Description of the Selected Action

Mine Facilities and Activities

Blasting and drilling activities will occur in the mine pit. The waste rock and tailings will be 

transported from the mine pit and processed within the corresponding facilities (figure A-1). A 

perimeter fence and security fence will be built to encompass the primary mining and processing 

operations and facilities, excluding portions of the access roads and utility lines. Further information 

is provided under the “Perimeter and Security Fences” below. 

Pit

Preproduction stripping of overlying rock will require 18 to 24 months to prepare for full-scale 

mining operations, train work crews, construct access and haul roads, and clear and grub the pit and 

tailings and waste rock facilities that will be disturbed during the initial years of operation. Open-pit 

mining will be used to excavate ore to recover copper, molybdenum, and silver. The roughly circular 

open-pit mine will measure, at end of mine life, between 6,000 and 6,500 feet in diameter, with a 

final depth of up to 3,000 feet (3,050 feet above mean sea level), depending on the elevation of the pit 

rim. Pit slope angles between in-pit roads will be controlled by rock strength and will range between 

33 and 50 degrees. The pit will disturb about 955 acres, of which 590 acres will be on private land 

and 365 acres will be on NFS lands. 

Blasting and Drilling

Explosives storage, transport, and use will adhere to all rules, regulations, and safety standards. Once 

a day on average, an ammonium nitrate and fuel oil explosive will be detonated in the mine pit. This 

will occur during daylight hours only, generally between 9 a.m. and 4 p.m. Dry bulk ammonium 

nitrate will be transported for use from storage silos at the adjacent plant site. Blasting detonators, 

such as caps, delays, cord, and boosters, will be stored in special magazines and transported to the pit 

in separate vehicles. 

If wet-hole blasting is necessary, an emulsion and/or slurry will be transported to the pit from onsite 

storage tanks. Mixed ammonium nitrate and fuel oil will be loaded and transported using special 

trucks designed for that purpose. 

Mineral Processing

The Rosemont deposit is primarily sulfide minerals with a cap of oxide minerals nearer the surface. 

The mineral material will be mined over 20 to 25 years at an average rate of 75,000 tons per day. 

Most of the oxide minerals will be removed in the first 6 to 7 years of the project, while sulfide 

minerals will be produced throughout the mine operation. 

Draft Record of Decision – December 13, 2013

Rosemont Copper Project, Coronado National Forest A-1 

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Record of Decision and Finding of Nonsignificant Amendment

Figure A-1. Selected action footprint

Draft Record of Decision – December 13, 2013

A-2 Rosemont Copper Project, Coronado National Forest

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Draft Record of Decision and Finding of Nonsignificant Amendment

Exploratory drilling by Rosemont Copper has occurred on private and NFS lands, beginning in 2006 

and continuing to 2012. Characterization of the mineral deposit has been updated several times 

during this period. The most recent analysis resulted in mineral resource and updated metallurgical 

test work being completed, with estimated, measured, and indicated mineral resources of 919.3 

million tons of sulfide mineral and 63.4 million tons of oxide minerals. These mineral resources 

consist of proven and probable mineral reserves of nearly 667.2 million tons of sulfide. There were 

inferred resources of 138.6 million tons of sulfide and 1 million tons of oxide ores. Because the latest 

feasibility study completed for the selected action does not incorporate oxide ore processing, a 

portion of the oxide mineralization (65 million tons) is instead categorized as waste rock. The most 

recent feasibility study states that “the ultimate pit is currently under-optimized because of the 

capacity limitations of the tailings storage facility,” meaning that when the pit reaches a depth of 

3,050 feet above mean sea level, removal of additional mineral material will be constrained because 

of the volume limitations of tailings and waste rock facility designs and footprints. 

Sulfide Ore Process

Sulfide ore will be sent through a circuit of crushers, grinding mills, and ball mills to reduce the rock 

size to the consistency of sand. A flotation circuit will separate the copper and molybdenum sulfides 

from the waste material to create a concentrate. The concentrates will then be dewatered, thickened, 

filtered, and loaded for shipment. The waste or tailings from the sulfide ore processing will be 

dewatered using large-capacity pressure filters, which will essentially squeeze the water out of the 

tailings to create a dry cake with a moisture content of 12 to 18 percent. The filtered tailings will then 

be conveyed to and placed in the dry-stack tailings disposal facility, while the water will return to the 

process for recycled use. 

Process Water Temporary Storage Pond

The process water temporary storage pond facility is a component of the sulfide ore process and will

be regulated under the APP. The facility will be divided into two sections (ponds), termed the process 

water and the temporary storage ponds. In general, the reservoir in the process water pond will be 

managed to optimize containment of recirculated water, and the temporary storage pond will be kept 

at low fill levels to optimize room for stormwater runoff. Incline-mounted or barge pumps in each 

pond will pump captured recirculated process water and stormwater to the process circuit. The pumps 

will also allow each pond to be emptied for inspection. 

Process water will be retained in a double-lined surface impoundment with a capacity of 70 million 

gallons, which will store 3 days of water reclaimed from the tailings filters and mixed with fresh 

water from Rosemont Copper’s supply wells near Sahuarita. Three days’ storage will allow for some 

flexibility and emergency storage in case of a service interruption at the plant facilities. Additionally, 

during operations, if ponded stormwater on the top surface of the dry-stack tailings facilities exceeds 

timely evaporation, it will be pumped to the process water pond to limit infiltration to the tailings. 

The temporary storage portion will be a single-lined surface impoundment that will receive 

stormwater runoff from the plant site area, including a small drainage basin located west of the pond. 

As currently designed, the temporary storage portion will provide containment of a 100-year, 24-hour 

storm event. This pond will have a storage capacity of approximately 38 million gallons. Under the 

APP, this pond will need to be emptied of stormwater within 60 days.

Construction details for the process water temporary storage pond liners are discussed in the 

“Groundwater Quality and Geochemistry” resource section of chapter 3 of the FEIS. 

Draft Record of Decision – December 13, 2013

Rosemont Copper Project, Coronado National Forest A-3 

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Record of Decision and Finding of Nonsignificant Amendment

Waste Rock and Tailings Placement

Waste rock will be placed in areas outside the open pit. Dewatered tailings will be sent via conveyor 

belt to the unlined dry-stack tailings disposal area, where they will be deposited, stacked, and 

compacted. Ultimately, the tailings will be encapsulated, or covered completely, by a thick layer of 

waste rock. 

Waste Rock and Tailings Facilities

The selected action will place all of the tailings and waste rock in upper Barrel Canyon and the lower 

portion of Wasp Canyon, prohibiting disposal of mine tailings or waste in McCleary Canyon. This 

change will permanently maintain the contribution of surface water flow from McCleary Canyon to 

the Barrel Canyon drainage system, albeit in a somewhat decreased capacity during operations 

because runoff from the plant site will be required to be retained. It will also increase the drainage 

area that may be diverted through the McCleary Canyon channel, in contrast to the proposed action 

and the Phased Tailings Alternative. 

Like the other action alternatives, the selected action incorporates a waste rock perimeter buttress that 

will completely surround the dry-stack tailings. 

Ore, Waste Rock, and Tailings Transport

Transportation of ore, waste rock, and tailings will occur only in the mine area, which will be closed 

to the public for safety reasons. Ore and waste rock will be moved in large, off-highway haul trucks. 

Roads for the haul trucks will be constructed both within the open pit and between the pit and the 

plant and tailings and waste rock facilities. In accordance with MSHA regulations (30 CFR 1–199), 

haul roads will be approximately 125 feet wide, including safety berms and drainage ditches, and 

from 10 to 12 percent slope or less. Maximum truck speed will be 35 miles per hour. Haul roads will

be temporary and will regularly be moved based on where materials are proposed to be placed. These 

temporary roads will be gradually covered by waste rock as it is placed. Any temporary haul roads 

remaining after all waste rock has been placed will be decommissioned unless the Coronado 

determines that they are desirable for future management.

Sulfide ore will be transported from the pit to a crusher in mine haul trucks; following crushing, the 

sulfide ore will be transported via conveyors to the grinding and flotation unit. Dewatered tailings 

will be transported using a conveyor system from the dewatering plant to the tailings facility for final 

placement. The conveyors will transfer the tailings to a radial stacker, and then the tailings will be 

spread and compacted by a dozer. The compacted tailings will be encapsulated by a perimeter 

buttress formed of waste rock and a waste rock “cap” that will be placed by haul trucks traveling on 

haul roads. In addition to 1 foot of growth media, between 3 to 5 feet of waste rock will be placed on 

the top surface of the tailings facility during closure.

Plant Site and Support Facilities

Facilities necessary to support mining and ore processing operations include buildings and structures, 

such as administration buildings, change house, warehouse with laydown yards, analytical laboratory, 

light vehicle and process maintenance building, mine truck shop, mine truck wash and lube facility, 

powder magazines and ammonium nitrate storage, main guard shack with truck scale, and fuel and 

lubricant storage and dispensing facilities. 

Draft Record of Decision – December 13, 2013

A-4 Rosemont Copper Project, Coronado National Forest

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Draft Record of Decision and Finding of Nonsignificant Amendment

Plant Site

Compared with the proposed action, the selected action eliminates the oxide ore processing buildings 

and instead uses that land for materials laydown yards, as shown in figure A-2. It also relocates some 

facilities to address geotechnical concerns regarding differential settlement. These modifications also 

provide secondary containment opportunities for process solutions, where possible, should there be 

interrupted operations, and add stormwater catchments, where necessary. A double liner with a leak 

collection and removal system is added to the process water temporary storage pond, which improves 

the containment of process water and separation of process water from stormwater. In addition, the 

design of the coarse ore stockpile is modified to a 400-foot covered geodesic dome structure and 

associated conveyor systems, to avoid encroaching on a population of the Forest Service sensitive 

plant species, Coleman’s coral-root, a wild orchid. 

Lighting

The selected action contains an updated lighting mitigation plan that mitigates the lighting system 

that was proposed in the preliminary MPO through its provisions for the following components: 

• Full cut-off, solid-state light-emitting diode (LED) lighting systems;

• High fitted target efficacy lighting systems and optics;

• Specific-purpose lighting systems with optics that match task requirements;

• Adaptive lighting controls to dim or extinguish lighting when not needed and to 

provide immediate “instant on” emergency or operational lighting;

• Where color rendering light is needed, use of color-tuned solid-state light sources for 

superior energy efficiency and optical control with attenuated short wavelengths to 

minimize Rayleigh scattering;

• Where color rendering light is not needed, use of narrow-band solid-state lighting to 

emulate low-pressure sodium but with superior optical and electrical control; and 

• Color-adaptive lighting to shift from narrow-band amber emissions to higher color 

rendering light when color rendering is needed. 

Roadways and parking lot areas will use narrow-band LED lighting fixtures set 123 feet apart on twolane haul roads and 225 feet apart on light-truck roads. The primary access road may use full cut-off 

low-pressure sodium fixtures. 

Elevated hazard areas, such as the mine process area and pit, will mostly require high-pressure 

sodium lighting or solid-state LED lighting fixtures that will be aimed and shielded to minimize light 

pollution. These fixtures will be located around the buildings in the process areas and concentrated 

around areas in the pit where large shovels are actively being operated. With a total of three shovels, 

three drills, and two loaders with various sized lamps, there will numerous beam-shaped LED fixtures 

that will direct more useful light to tasks. The only narrow-band lighting fixtures in this area will be 

used at a refueling site and explosives storage facility. 

According to the detailed site general electrical design that was based on the lighting plan proposed 

by Rosemont Copper before the DEIS, there will be a total of 12 200-watt and 475 90-watt lowpressure sodium fixtures, and there will be 19 200-watt, 86 90-watt, 11 70-watt, 21 50-watt, and 334 

35-watt high-pressure sodium fixtures. Although the mitigation will implement different fixtures, it is 

not expected that the number of fixtures will decrease; instead, there will be a more focused lighting 

pattern.

Draft Record of Decision – December 13, 2013

Rosemont Copper Project, Coronado National Forest A-5 

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Record of Decision and Finding of Nonsignificant Amendment

Figure A-2. Selected action plant site

Draft Record of Decision – December 13, 2013

A-6 Rosemont Copper Project, Coronado National Forest

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Draft Record of Decision and Finding of Nonsignificant Amendment

Further discussion of the updated lighting mitigation plan is included in the following locations in the 

FEIS: appendix B, “Mitigation and Monitoring Plan;” and in the “Dark Skies” resource section in 

chapter 3. Impacts associated with artificial night lighting are described in a variety of resource 

sections in chapter 3.

Solid, Hazardous, and Sanitary Waste

Solid waste will be recycled as appropriate and feasible. Nonrecyclable, nonhazardous waste will be 

disposed of at an onsite landfill located on about 2 acres of Rosemont Copper’s private land. 

Activities at the landfill will be regulated by the ADEQ APP for Rosemont Copper Mine facilities. 

The excavated depth of the landfill will range from 5 to 43 feet, with a minimum excavation elevation 

of approximately 5,190 feet above mean sea level; maximum height of the landfill at closure will be 

no more than 5,280 feet above mean sea level. All putrescent materials or other items that cannot be 

disposed there will be transported offsite for disposal by a commercial vendor. 

Hazardous waste will be handled and disposed of in accordance with Resource Conservation and 

Recovery Act regulations. The Resource Conservation and Recovery Act gives the EPA the authority 

to control hazardous waste from “cradle to grave.” This includes the generation, transportation, 

treatment, storage, and disposal of hazardous waste. The project will produce less than 220 pounds of 

hazardous waste each month and will qualify as a conditionally exempt small quantity generator. No 

hazardous waste will be disposed of onsite. All hazardous waste will be stored and then transported 

by licensed haulers for disposal at regulated facilities. 

Sanitary waste will be treated in onsite septic systems, with leach fields located in the vicinity of each 

building. During the construction phase and where necessary during operations, portable toilets will

be used in various locations throughout the plant and mine sites. The portable toilets will be serviced 

by a commercial sanitation company and the waste removed for disposal offsite.

Perimeter and Security Fences 

A perimeter fence will be built to encompass the primary mining and processing operations and 

facilities, excluding portions of the access roads and utility lines. It will provide a zone restricted 

from public access and locations for environmental compliance monitoring. The fence will be 

standard four-strand barbed wire, although the bottom wire will be bare, in accordance with BLM and 

AGFD fencing standards. Access for fence construction will be by all-terrain vehicle or on horseback 

to avoid the need for a road. There will be signage on the perimeter fence stating that entrance into 

the project area is prohibited. 

A security fence and security patrol road will be located within the perimeter fence, approximately 

750 feet from the toe of the slope of the waste rock and tailings facilities. The road will be a one-lane 

gravel or native surface road used for patrols, fence maintenance, monitoring, and general mine 

related access. 

A guard shack will be located where the primary mine access road intersects the security fence. Near 

the guard shack, the fence will be chain-link and 6 feet high, with barbed wire along the top. Other 

areas farther away from the primary mine access road will be enclosed by a standard four-strand 

barbed wire fence to provide a secondary safety barrier, with signage to help ensure public safety and 

to provide access to APP points of compliance.

Draft Record of Decision – December 13, 2013

Rosemont Copper Project, Coronado National Forest A-7 

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Record of Decision and Finding of Nonsignificant Amendment

Depending on the location of the fencing, the fencing at the mine and facilities will remove NFS land 

from public use during the 24.5- to 30-year mine life. The configuration of the perimeter and security 

fences and security road is depicted in figure A-1. Before project implementation, a legal closure 

order for the area within the perimeter fence will be issued by the Coronado. 

The perimeter and security fences will be removed following closure after considering grazing and 

safety needs. The security road may be partially or completely reclaimed as part of mine closure and 

reclamation, depending on the need for postmine administrative access for maintenance or 

monitoring purposes. Portions of the site, including the mine pit, will likely remain fenced off and 

closed to the public indefinitely for safety reasons, or as required by the Arizona State Mine 

Inspector. 

Ancillary Facilities and Activities

Utility Lines (Electrical and Water Supply) 

On June 12, 2012, the ACC approved a CEC authorizing the construction of a 138-kV electrical 

transmission line and associated facilities from the proposed Toro switchyard (located near Sahuarita) 

to the Rosemont substation (located at the mine). Because the water supply and utility maintenance 

road were intended to be co-located in all action alternatives in order to reduce impacts, the decision 

made by the ACC was instrumental in the final alignment of all three components (figure A-3). 

During mine closure, the power line will be removed from NFS land and disturbed areas reclaimed 

and revegetated with native vegetation. Removal of the power line on private and ASLD land is 

outside the jurisdiction of the Forest Service. However, the CEC states that once service is no longer 

needed, “Applicant shall file a plan for removal of the transmission line.” This decision also states 

that all costs associated with the line removal will be charged to Rosemont Copper, and proof of 

funds for these costs is required. 

Power Supply

The total power requirement for the project is 108 to 112 megawatts, which requires a minimum 

transmission voltage of 138 kV. The transmission line will be an aboveground single-circuit 138-kV 

nonreflective transmission line provided from a link attached to existing transmission lines on the 

South substation loop. The transmission line will extend from the proposed Toro switchyard 13 miles 

to the proposed Rosemont substation, held on double-circuit capable Core 10 standard steel (rustcolored) monopole structures with typical heights of 75 to 150 feet. The route will generally parallel 

the existing South Santa Rita Road before entering private land held by Rosemont Copper (table A1). The alignment will then continue east over the ridge and cross the ridgeline at Lopez Pass (see 

figure A-3). The corridor width for the entire project route will be 500 feet and will include an 

associated 14-foot-wide unpaved maintenance road.

Draft Record of Decision – December 13, 2013

A-8 Rosemont Copper Project, Coronado National Forest

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Draft Record of Decision – December 13, 2013

Rosemont Copper Project, Coronado National Forest A-9

Figure A-3. Approved utility alignment for the Rosemont Copper Project 

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Record of Decision and Finding of Nonsignificant Amendment

Table A-1. Landownership or management of the utility corridor

Forest Service BLM ASLD Private 

Electrical transmission line (feet) 2,787 0 47,881 18,393

Water supply line (feet) 5079 0 65,881 32,849

Utility corridor (acres) 38 3* 574 302

* While the corridor for analysis includes some land within BLM jurisdiction, Rosemont Copper withdrew the BLM MPO, 

and lands administered by the BLM will not be disturbed or otherwise affected by construction, maintenance, or removal of 

utility facilities.

Power needed to operate the water pump stations (described below) will be supplied by an electrical 

line from the Rosemont substation, back over the same poles as the transmission line to the pump 

station buildings. The electrical line spanning pump stations two and three will be an underground 

line, at the request of ASLD. 

In addition to traditional electrical service from TEP, Rosemont Copper plans to use solar 

technologies, such as passive solar installations, to power the administration buildings and potentially 

other areas. 

Power Distribution Line Relocation

A 46-kV electrical distribution line that currently runs north-south through the project area will

require realignment for each action alternative. Relocation will include the establishment of new 

electrical poles (similar to those found in residential areas) along the inside of the security fence 

where needed. The line will be strung on those poles and connected to the existing line. 

No interruptions in service will be expected. Ground disturbance associated with relocation of this 

line will occur within the security fence perimeter, which is an area already considered disturbed for 

the purposes of the effects analysis; therefore, no additional ground disturbance will occur with this 

relocation.

Water Supply Pipeline 

A 20- to 24-inch ductile iron water pipeline will be constructed. The pipeline will require trenching, 

ranging from 30 to 52 inches wide, and will receive a minimum soil cover of 36 inches within the 

State land easement and 24 inches of cover on private property. While it is expected that most 

drainage crossings will only require backfill of the previously removed material, some crossings may 

require nonerosive material, such as concrete, below calculated scour depth where wash composition 

is soil and gravel. Where rock prohibits burial, the pipeline will be placed above the rock and covered 

with soil, as previously specified, depending on slope, topography, and the availability of cover 

material. 

The pipe bedding requirements will follow the manufacturer’s recommendations. Isolation valves 

will be installed in the pipeline at intervals of approximately 3,000 feet and at elevation changes of 

250 feet. Construction of the pipeline will include up to four booster stations that will consist of 

concrete basins, vertical turbine pumps, and a pneumatic tank housed within secured buildings or 

structures and requiring power, as described above. The reservoirs and pump stations will be built 

outside jurisdictional WUS. 

Draft Record of Decision – December 13, 2013

A-10 Rosemont Copper Project, Coronado National Forest

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Draft Record of Decision and Finding of Nonsignificant Amendment

Water Supply 

During construction of the water supply pipeline, water will be drawn from existing wells in and 

around the project site in order to supply construction activities. It is estimated that approximately 

600 to 900 gallons per minute will be necessary to support facility construction. 

The project is permitted by the ADWR to draw up to 6,000 acre-feet2 per year. However, it is 

currently estimated that the project will use between 4,700 and 5,400 acre-feet per year of fresh 

water, for a total use over the mine life of approximately 100,000 acre-feet. Water will be pumped 

from four to six wells located on land owned or leased by Rosemont Copper near the community of 

Sahuarita in the Santa Cruz Valley at a maximum rate of 5,000 gallons per minute (total pumpage). 

Well locations, proposed pipeline route, and pipeline route are shown in figure A-3. Four booster 

stations will be needed to maintain water flow in the line. 

Total fresh water to be used during operation is estimated to be about 4.8 million gallons per day. 

Most of this will be supplied by groundwater wells in the Santa Cruz Valley. Much smaller quantities 

will be obtained from stormwater and pit dewatering on the mine site. Water will primarily be

allocated to ore processing. Other water uses will include dust control, fire protection, drinking water, 

sanitary waste management, and other miscellaneous uses. It is estimated that up to 18,500 acre-feet 

could be obtained from pit dewatering over the life of the mine. Water acquired through pit 

dewatering will either be used in processing or dust control. Because the quality of the water supply 

is expected to approach potable standards, it will not require any additional processing to be used in 

various mining processes. 

Where feasible, an estimated 37 million gallons of water per day will be reclaimed from a variety of 

uses on the mine and returned for use in processing. Water used to process ore (referred to as process 

water) and other water impacted by the project will be controlled as described below. 

Water Control

The primary water control objective will be to reduce the risk of discharging potentially contaminated 

water into the environment. Water control will be applied to: (1) process water, (2) groundwater, and 

(3) stormwater that comes into contact with process facilities or tailings.

Process Water

Figure 6 in chapter 2 of the FEIS is a schematic diagram of the process water control system that 

shows the basic water circuits during processing of sulfide ore. Control of process water will consist 

of containing the process water in engineered structures, such as tanks, pipes, sumps, lined ponds, 

lined ditches and maintaining the water content of the dry-stack tailings at a level that minimizes 

seepage from the dry-stack tailings facility. The engineering design and performance of the various 

process water control facilities, including seepage and leakage monitoring and recovery, will meet or 

exceed the best available demonstrated control technology criteria used by ADEQ and will be 

regulated under the APP that was issued on April 3, 2012. Details of best available demonstrated 

control technologies are discussed in the “Groundwater Quality and Geochemistry” resource section 

in chapter 3 of the FEIS. 

2 Note: 1 acre-foot equals 325,851 gallons.

Draft Record of Decision – December 13, 2013

Rosemont Copper Project, Coronado National Forest A-11

 

DRAFT
Record of Decision and Finding of Nonsignificant Amendment

Groundwater

The groundwater control system will include both activities and facilities designed to protect and 

monitor the quality of the groundwater in the area, as well as the investigation and modeling used to 

predict the response of the groundwater systems to both the withdrawal of groundwater and the 

influence of seepage and leakage from the project facilities. Implementation of groundwater control 

requirements will be monitored as part of the APP that has been issued by the ADEQ, as well as 

additional monitoring required by the Coronado (see appendix B in the FEIS). 

Protection of groundwater quality at the mine site during operations will primarily be achieved by 

using the process water controls described above. Included in these is monitoring of the seepage and 

leakage detection systems that are part of facility design, as required by the APP. 

Of particular importance to long-term groundwater and surface water protection is the acid rock 

drainage protection and monitoring program. Monitoring to ensure that offsite groundwater quality is 

not impacted beyond the level allowed by the APP will be accomplished at specific groundwater 

monitoring wells required by the APP, at additional monitoring wells required by the Coronado, and 

by applying best available demonstrated control technology (i.e., engineering controls and practices). 

Protection of water quality following mine closure will be achieved by closure and reclamation of the 

process facilities, elimination of or reduction in acid rock drainage generation in the tailings and 

waste rock from the design and operation of the facilities, monitoring and testing required by the APP 

following mine closure, and capture of possible impacted mine site groundwater by localized 

groundwater flowing into the pit. 

Stormwater Controls

Stormwater (contact water) from the mine pit, ore processing facilities, and mine maintenance plant 

areas will be prohibited from surface discharge under the stormwater permit during operations. 

Stormwater allowed to be discharged, such as that from the waste rock facility and waste rock 

buttresses around the tailings facility, will be routed to sediment control structures, where any offsite 

overflow discharge point will be monitored for chemical and sediment content in accordance with an 

ADEQ mining stormwater general permit. Runoff from tailings is not prohibited from downstream 

discharge under the stormwater permit, but it will be contained onsite, along with other contact water.

The top surface of the dry-stack tailings will be exposed to precipitation only during operations. 

All tailings will be covered with waste rock at closure. The general design concept for managing 

stormwater from the dry-stack tailings facility is to minimize infiltration of water in the tailings and 

prevent discharge of stormwater that comes in contact with the tailings. This will be accomplished by 

constructing uniform lifts of dry tailings that are buttressed by waste rock. The buttresses will be built 

around the tailings surface for containment and erosion control. The top of the tailings facility will be 

relatively impervious. That is, all precipitation will remain on top of the tailings facility to evaporate. 

If water ponds on top of the tailings facility, it will be pumped to the process water temporary storage 

pond to limit infiltration into the tailings facility. Diversion channels will be constructed to direct 

surface runoff that has not contacted tailings from the outer waste rock shell slopes into either 

sediment ponds or adjacent drainages to a sediment control structure. The selected action permits no 

storage of stormwater on the top or benches of the waste rock/tailings landform postclosure. Instead, 

waste rock and tailings facilities will shed runoff after closure. The tops of the facilities will be 

graded to discharge stormwater to the lower benches, which in turn are designed to move stormwater 

laterally along the benches until it reaches several concrete drop structures. The runoff from these 

Draft Record of Decision – December 13, 2013

A-12 Rosemont Copper Project, Coronado National Forest

DRAFT
Draft Record of Decision and Finding of Nonsignificant Amendment

drop structures will either be discharged into the natural washes (Barrel Canyon or a tributary) or 

discharged into a diversion channel that will carry runoff along the toe of the waste rock and tailings 

facilities and then will discharge that runoff into the natural washes (figure A-4). In this manner, as 

much water as possible will be allowed to flow downstream after reclamation is complete.

Stormwater from above the mine pit will be diverted around the pit and plant site. During operations, 

stormwater that falls within the mine pit and associated disturbed areas, especially stormwater that 

comes into contact with ore, will be contained onsite and used for mining and processing purposes. 

Postclosure, any stormwater that enters the pit will contribute to the pit lake. 

Flowthrough drains beneath the tailings and waste rock facilities are not part of the selected action

because of concerns about intermingling of stormwater and tailings seepage and long-term 

maintenance. The small ridge just east of the plant site will be eliminated postclosure in order to 

enable stormwater from the reclaimed plant site area to be diverted to flow into McCleary Canyon via 

a surface channel. 

Precipitation that comes into contact with waste rock does not need to be retained but can be released 

downstream. Regardless of this, much of the runoff from the waste rock facilities will be retained, 

with the exception of the perimeter waste rock buttresses. For perimeter buttresses, concurrent 

reclamation and appropriate BMPs will progress up the outer slopes as the buttresses are constructed. 

This will limit erosion potential and will allow noncontact runoff to discharge to downgradient 

sediment ponds and eventually to the watershed. 

Active stormwater management will continue after the mine closes, as required by the mining 

stormwater general permit and the erosion control provisions of the mine land reclamation plan, 

administered by the Arizona State Mine Inspector. The Arizona State Mine Inspector has jurisdiction 

for reclamation under 27 ARS Chapter 5; this is the Reclamation Act statute for reclamation of 

hardrock mining, which pertains to private lands with more than 5 acres of mining disturbance. 

Compliance Point Dam

Two compliance point dams will serve as the final onsite location where stormwater can be 

monitored. It is what is referred to in many technical documents as a “sediment control structure.” 

Each dam will be approximately 6 feet tall and approximately 100 to 200 feet wide and will have a 

storage capacity of approximately 2 acre-feet. It will be constructed in year 0 using inert waste rock

as an ADWR nonjurisdictional, unlined embankment. Normally, the area behind the embankment will

be empty. During storm events, water will be temporarily impounded and slowly released through the 

porous rock-fill dam. Large storm events may overtop the dam and proceed downstream. If the dam 

is destroyed by an overtopping event, it will be rebuilt. The compliance point dam will be evaluated 

after closure of the project facilities. The dam will be removed if it is determined that subsequent 

discharges will meet Arizona Surface Water Quality Standards. 

Access to the dam will use Forest Service roads to minimize additional surface disturbance.

Draft Record of Decision – December 13, 2013

Rosemont Copper Project, Coronado National Forest A-13

DRAFT
Record of Decision and Finding of Nonsignificant Amendment

Figure A-4. Selected action stormwater concept 

Draft Record of Decision – December 13, 2013

A-14 Rosemont Copper Project, Coronado National Forest

DRAFT
Draft Record of Decision and Finding of Nonsignificant Amendment

Primary Access Road

A new two-lane paved road, referred to as the “primary access road,” will be constructed to provide 

primary access between SR 83 and the mine. The primary access road will leave SR 83 along a straight 

section of the State highway. At the intersection, SR 83 will be widened, and new lanes will be added. 

Compared to the preliminary MPO, the primary access road was redesigned to follow a revised 

alignment that both shortens the road and reduces its visibility from SR 83. This realignment avoids 

Scholefield Canyon and will reduce impacts to riparian vegetation and cultural resources. The new 

alignment intersects SR 83 at the same location as in the proposed action but is 3.2 miles long, as 

shown in figure A-1. 

Public use will be restricted on portions of the primary access road at the perimeter fenceline during 

construction, operation, and closure of the mine because of safety considerations but will be reopened 

to the public after closure. The primary access road will be subject to periodic short-term restriction 

of public use for maintenance and to protect public safety. Restricted areas will be indicated by 

signage, gates, and/or a security guard shack located near the plant site. Segments of the primary 

access road will be added to the Coronado’s NFSR inventory. 

Utility Maintenance Road

Referred to as the “secondary access road” in the DEIS, a better understanding of this road and its 

function resulted in its being renamed the “utility maintenance road.” This road will be located within 

the utility corridor to serve as access to the power supply line, water supply line, and water booster 

pump stations (see figure A-3). The road will consist of two discrete segments: one from the plant 

site, over Lopez Pass, to a major wash on private land; and another from the supply well area near 

Sahuarita to the other side of the major wash, generally following the electrical transmission and 

water line location. Overall, this road will require more than 11.5 miles of new construction and 4.5 

miles of reconstruction or upgrade to an existing road. Refer to figure A-3 for a map of the utility 

maintenance road. 

A gravel road will be constructed from the plant site to Lopez Pass to serve as a maintenance road for 

the utility supply lines. The existing road over Lopez Pass (NFSR 505) is on NFS land and private land. 

While NFSR 505 is considered a Forest Service system road, the Forest Service does not have legal 

access across private land. There are small portions of the new road construction that overlap existing 

NFSR 505, and those will be reconstructed as part of the utility maintenance road. However, most of the 

alignment will require new construction from the plant site to its western terminus. The rocky, hilly 

portion of the road will be reconstructed, and a new road will be created that will run west across private 

land. The road will intercept a major wash at its western terminus. There are no plans to construct a 

crossing of this wash, which will require an engineered structure. The second segment of the utility 

maintenance road will begin at the area of mine water supply wells near Sahuarita and follow the 

location of the electrical transmission and water lines. This road segment will cross land administered 

by the ASLD and private lands and will generally parallel Country Club and Santa Rita Roads. 

Where the water pipeline to the mine travels under Santa Rita Road, the utility maintenance road 

intersects the public roadway. It will be gated here to prevent unauthorized access. Because there are 

different mine water supply well locations, the utility maintenance road will include spurs that extend 

to these locations as required. The waterline segment to the northernmost well will not require a new 

road and will use the existing adjacent Santa Rita Road for construction and maintenance until it 

intersects with Country Club Road. 

Draft Record of Decision – December 13, 2013

Rosemont Copper Project, Coronado National Forest A-15

DRAFT
Record of Decision and Finding of Nonsignificant Amendment

A ROW permit from ASLD is required for the sections of the utility maintenance road and utility 

corridor on State land. A ROW application has been filed; the ROW permit itself will not be issued 

until approval of the project by the Forest Service. The sections of the road within the ASLD ROW 

will be new construction. ASLD will also decide at a later date whether they intend to require an 

additional fence between the utility maintenance road and the rest of the Santa Rita Experimental 

Range. The Town of Sahuarita also signed an agreement with Rosemont Copper allowing use of a 

portion of its current ROW alongside Santa Rita Road (Town of Sahuarita and Rosemont Copper 

Company 2013). This license agreement provides access to the northernmost well via Santa Rita 

Road. Use of Santa Rita Road for construction, maintenance, or crossing of the water line may 

require additional permitting by Pima County. 

The utility maintenance road will be required to meet MSHA standards by including truck axle-high 

berms (anticipated to be about 3 feet high) on the sides of the section of roadway located on 

Rosemont Copper private lands. Some road reconstruction will be on NFS lands before the road 

intersects private lands, and the Coronado will negotiate with MSHA to accommodate safety while 

minimizing impacts to NFS surface resources. Otherwise, the segments on ASLD and will be a 

standard 14-foot-wide native surface road without any additional MSHA requirements. 

The utility maintenance road will be closed to the public during construction and operation of the 

mine, and portions may be reopened to the public after closure, depending on safety concerns. It is 

the intent of the Coronado to restore public access over Lopez Pass. However, a section of this road 

crosses private land, and there is currently no legal right of public access. While the Coronado will 

work with the landowner to secure a permanent public easement for this segment of road, it is 

unknown at this time whether legal public access will be available postclosure. The portions of this 

road on private lands will remain after the pipeline and booster stations are removed. For sections on 

State land, ASLD will ultimately decide which portions will be retained, removed, or revegetated 

through their ROW permitting process. 

Other Area Roads

Area roads that are outside the perimeter fence that will either be reconnected or decommissioned are 

shown in figure ROD-3. If the mine project is approved, all NFSRs within the perimeter fence not 

used for mining activities will be decommissioned. A short section of new temporary road (about 700 

feet in length, disturbing an estimated 0.2 acre) and use of a segment of NFSR 4064 will be necessary 

for installing and accessing air quality monitoring equipment to be located at the perimeter fence. 

Actual decommissioning activities could range from closing and abandoning the road, to activities 

such as scarifying the road surface to discourage motorized use and promote vegetative recovers, to 

full topographic recontouring. For the sake of analyzing impacts, it is assumed that all miles of 

NFSRs within the perimeter fence will be actively decommissioned, and the acreage of these roads is 

contained in disturbance calculations used for various impact analyses (see table 11 in chapter 2 of 

the FEIS). NFSRs that are cut off by the perimeter fence will either be decommissioned, rerouted to 

connect to another area road, or have a turnaround area constructed exterior to the fenceline. New 

roads will be added as NFSRs, while decommissioned roads will be removed as NFSRs. Within the 

project area, the Forest Service was granted a ROW from ASARCO Corporation in 1993 for NFSRs 

231, 4051, and 4064, for the portions that cross private land. These ROWs remain valid, although title 

of the underlying land is now held by Rosemont Copper. These roads will be decommissioned. 

Draft Record of Decision – December 13, 2013

A-16 Rosemont Copper Project, Coronado National Forest

DRAFT
Draft Record of Decision and Finding of Nonsignificant Amendment

New road segments designed to connect remnant NFSRs include the construction of a new road from 

the primary access road to unauthorized road 4050-0.36R-1 (which intersects NFSR 4050 about 0.3 

mile farther west), in order to continue to provide legal public access to the Sycamore Canyon area 

once the unauthorized road is adopted as an NFSR. The completed pair of road segments are referred 

to as the “Sycamore Connector Road” is about 12,184 feet long and will impact about 26 acres. 

Because some Open-Authorized-Restricted roads, which are only open to motorized use by 

permittees and administrative use, are typically used in the project area for access to grazing 

allotments, these will mostly remain intact to allow administrative and permitted use postclosure. 

Construction of the Sycamore Connector Road will be required to be completed within 1 year of the 

date on which public access to NFSR 4050 is cut off due to mine related activities. During operations, 

Rosemont Copper will be responsible for providing access, in some form, to the grazing lease holders 

for management of their allotments and to the Coronado for permit administration. 

Transportation on State Route 83

The primary mine access road includes a new intersection with SR 83 that requires an ADOT 

encroachment permit. The existing two-lane SR 83 roadway will be reconstructed to include a 

northbound left-turn lane, a southbound right-turn lane, and a merging northbound acceleration lane. 

All intersection improvements will occur between mileposts 46.63 and 47.14. Portland cement 

concrete will form the surface approximately 100 to 200 feet north and south of the intersection and 

the access road turnout. Asphaltic concrete will be used for the remainder of the project alignment. 

To improve drainage from the intersection, Rosemont Copper will upgrade current drainage structures 

in the area in accordance with ADOT requirements. The project will also include a turnout connecting 

to an NFS unpaved roadway and temporary pavement during construction. 

As part of the encroachment permit for the primary access road, Rosemont Copper has agreed to fund 

a lump sum amount to perform or implement the design, construction, and maintenance of road 

improvements to SR 83 elsewhere. These improvements are considered in this EIS as a connected 

action (see “Connected Actions” on page 29 of this ROD), and ADOT has indicated that these 

improvements will consist of a 3-inch asphalt-concrete overlay, guardrail reconstruction, pavement 

markings, and shoulder buildup from the primary access road intersection north to milepost 58.5. 

In addition, three existing bus pullouts on SR 83 at mileposts 47.9, 49.2, and 52 will be paved.

After this ROD is issued, it is expected that ADOT will issue an encroachment permit for 

improvements to the Rosemont Junction intersection serving NFSR 231. Rosemont Junction will

provide temporary access to the mine site during the premining period to the project site while the 

intersection for the primary access road is being constructed. The intersection upgrades for this 

temporary construction route consist of improvements to the turnout for Rosemont Junction (South 

Helvetia Road) at milepost 46.63 on SR 83. The improvements include raising Rosemont Junction to 

match existing pavement. It also includes the installation of new cattle guards and fencing to guide 

traffic to the newly widened, gravel padded Rosemont Junction. Stormwater and sediment controls 

are also designed as part of the overall improvement plans. An estimated 200 feet of NFSR 231 on 

NFS land beyond the ADOT easement will be reconstructed to match the intersection and grade to the 

existing road. This reconstruction will result in an estimated 0.37 acre of disturbance. 

Draft Record of Decision – December 13, 2013

Rosemont Copper Project, Coronado National Forest A-17

DRAFT
Record of Decision and Finding of Nonsignificant Amendment

Mine Life and Alternative Production Schedule

Mining production plans were developed through the end of year 21.3 based on proven and probable 

mineral reserves. Table A-2 provides a crosswalk between the production timing and the mine life 

used for the analysis in the FEIS. 

Table A-2. Mine life and anticipated production schedule for the selected action 

Mine Life 

Phasing 

(expected 

time frame)

Cumulative 

Timing

Description of 

Activities

Detailed Timeline 

for Alternative

Sulfide Ore 

(1,000 tons)

Waste Rock 

(1,000 tons)

Premining

(18 to 24 

months)

1.5 to 2 years Clear vegetation; stockpile 

soil; construct facilities; 

construct primary access 

road; construct electrical 

and water lines and 

segments of utility 

maintenance road; construct 

fences; decommission 

roads; begin construction of 

pit; begin construction of 

perimeter buttress with 

waste rock; construct 

monitor wells

22 months 6,259 98,859

Active mining

(20 to 25 years)

21.5 to 27 

years

Continue pit development; 

continue construction of 

perimeter buttress; conduct 

mineral processing;

construct tailings facility; 

perform concurrent 

reclamation activities 

(includes revegetation); 

haul products; construct 

stormwater drainage 

facilities

Year 1

Year 2

Year 3

Year 4

Year 5

Year 6

Year 7

Years 8 through 10

Years 11 through 15

Years 16 through 19

27,920

35,576

42,628

27,375

32,015

34,348

37,373

96,360

163,520

204,097

88,169

69,944

82,165

95,980

74,569

63,412

62,094

269,243

260,736

83,996

Final 

reclamation 

and closure

(3 years)

24.5 to 30 

years

All mineral processing has 

been completed; remove

plant site facilities; finish 

reclamation; stain pit walls; 

finish drainage structures; 

remove perimeter fence; 

remove electrical lines on 

NFS land

Not Applicable Not Applicable Not Applicable

Total 707,471 1,249,161

Note: Totals for sulfide ore include stockpiled ore. 

Mine related traffic on SR 83 during operation will consist of trucks carrying supplies to the project, 

trucks carrying concentrate and copper cathodes from the project, and employee traffic. Equipment 

and construction material deliveries to the site will be in addition to large-truck trips. Major 

equipment arriving by rail may be received at the Port of Tucson, which is located near Vail, Arizona, 

to the west of the project area. Table A-3 shows Rosemont Copper’s estimate of the large-truck 

shipments for the selected action on a year 1 and year 20 weekday of the operations phase. 

Draft Record of Decision – December 13, 2013

A-18 Rosemont Copper Project, Coronado National Forest

DRAFT
Draft Record of Decision and Finding of Nonsignificant Amendment

Table A-3. Large-truck trip per weekday data (years 1 and 20 of 

operations phase)

Materials Round Trips per Week 

Year 1

Round Trips per Week 

Year 20

Copper concentrate 50 50

Materials (e.g., lime, fuels, etc.) 19 19

Total 69 69

Copper concentrate shipments will form the largest number of routine truck shipments for both the 

selected action and MPO, with approximately 50 to 56 round trips per day 7 days per week, 

respectively. Because the project area will have limited onsite parking during the premining phase, all 

anticipated daily worker commuter trips will be by bus. More specifically, the estimated 1,250 

workers needed during construction will require 37 daily round trips by bus. During operation, 

worker commuter trips will vary from approximately 266 to 311 round trips per day, depending on 

the year and the alternative. Worker commutes for the operations phase are assumed to be one trip per 

worker (assuming no carpooling or busing). The largest concentrated volume of mine traffic during a 

24-hour period will occur during workforce shift change during the operations phase. Shift changes 

will vary between 6 a.m. to 8 a.m. and 4 p.m. to 6 p.m. 

Arizona National Scenic Trail

The Las Colinas portion of the Arizona National Scenic Trail runs through the project area. 

Approximately 10 miles of trail will be relocated to the east side of SR 83 to accommodate the 

project and the demand for use of the trail (figure A-5). It will require construction of about 13 miles 

of new trail. It will be built to the same standard as the current trail: built with a 24-inch tread, and 

cleared from 6 to 8 feet wide and 10 to 12 feet high to accommodate multiple uses, such as hiking, 

biking and horseback riding. These actions include periodic maintenance of the trail and associated 

facilities. Construction of new trail segments will be completed within 1 year of approval of this

ROD. The trail will be pioneered and available to public use prior to closing the existing trail (refer to 

“Mitigation Effectiveness” in the “Recreation and Wilderness” resource section of chapter 3 and 

appendix B in the FEIS for further information). 

This action includes construction of trailheads at Oak Tree Canyon and at the intersection of SR 83 

and Hidden Valley Ranch Road. The trailhead at Oak Tree Canyon, estimated to be up to 3.7 acres, 

will be designed to accommodate 18 passenger vehicles and 12 horse trailers and will include a 

bathroom and water source for pack stock and wildlife. It will also include a gravel parking surface, 

perimeter fence, and gates and signs to deter OHV use. The Hidden Valley Ranch Road trailhead, 

estimated to be up to 2.5 acres, will accommodate eight passenger vehicles and four horse trailers on 

a gravel parking surface, a post and rail fence, and gates and signage to deter OHV use. Metal gates, 

signs, and fencing will be used to deter OHV use on the trail, and gates will be used to accommodate 

equestrian and mountain bike crossing in areas where there are existing fence lines. Fencing will be 

extended from the trail gate near Oak Tree/Davidson Canyons in order to properly protect the 

corridor. Signage consistent with the Arizona National Scenic Trail will be installed, as well as detour 

and construction signage once construction takes place.

Draft Record of Decision – December 13, 2013

Rosemont Copper Project, Coronado National Forest A-19

DRAFT
Record of Decision and Finding of Nonsignificant Amendment

Figure A-5. Arizona National Scenic Trail relocations

Draft Record of Decision – December 13, 2013

A-20 Rosemont Copper Project, Coronado National Forest

DRAFT
Draft Record of Decision and Finding of Nonsignificant Amendment

Reclamation and Closure 

Reclamation of the project will be administered and regulated by the Coronado (36 CFR 228) on NFS 

lands; administered and regulated on private land by the Arizona State Mine Inspector (ARS 27-901 

et seq., as amended); and regulated by the ADEQ (ARS 49-241 through 49-252; and Arizona 

Administrative Code 18-9-101 through 403). 

Reclamation and closure plans have developed as the NEPA process has progressed. The 2007 

preliminary MPO included a conceptual reclamation and closure plan, which was updated in 2010 for 

the other action alternatives. Following publication of the DEIS and in part in response to public 

comments received, the reclamation and closure plan was updated to focus solely on the preferred 

alternative. This latest reclamation and closure plan provides details for the phasing and locations for 

reclamation activities, details of postclosure site water management, and preliminary calculations of 

reclamation and closure costs.

In concept, reclamation and closure consists of several components common to all action alternatives: 

• Removal of all equipment and buildings; building foundations may be broken up and 

buried, or removed; 

• Capping of the top of the tailings facility with waste rock upon closure; 

• Removal of pond liners as deemed appropriate under the APP; 

• Regrading and revegetation of the plant and mill site areas upon closure;

• Regrading and revegetation of any access roads requiring closure;

• Removal of electric supply line, water supply line, and related facilities from NFS 

lands; 

• Revegetation of utility corridors where removal causes soil disturbance;

• Concurrent reclamation and revegetation of the landform that encompasses the waste 

rock and tailings facilities, beginning as early as year 1, as portions of the waste rock 

buttress are completed;

• Salvage of soil resources and selected vegetation for reuse in revegetation activities;

• Removal of perimeter and security fencing;

• Construction of fencing and/or berms for safety considerations; 

• Establishment of postclosure access roads; and

• Reestablishment of downstream drainage and surface water flow.

Several considerations were incorporated into mine design to facilitate later reclamation and closure. 

These include managing operations to minimize environmental impacts, constraining disturbances to 

a minimum number of drainages to minimize downstream hydrologic disturbance, constructing waste 

rock buttresses to allow for concurrent reclamation of outer slopes, and using appropriate technology 

to minimize the generation of impacted water. 

With the exception of most roads within the plant site, access roads into the project area will remain 

after closure. Specifically, the primary access road and portions of the utility maintenance road will

remain, and a road will be maintained through the plant site to access the waste rock/tailings 

landform for monitoring and maintenance. Roads may also remain on top of and around the toe of the 

waste rock/tailings landform to allow for postclosure monitoring activities and use of the land for 

grazing. 

Draft Record of Decision – December 13, 2013

Rosemont Copper Project, Coronado National Forest A-21

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Record of Decision and Finding of Nonsignificant Amendment

Postmine land use of NFS lands will be the same for all action alternatives and will follow the 

direction in the forest plan that is in place at that time. Postmining/closure reclamation objectives for 

Rosemont Copper’s private land could include dispersed recreation, wildlife habitat, and ranching.

At closure, fence construction for the mine pit under all action alternatives will be a minimum of 

three-stranded barbed wire with warning signs. Arizona Administrative Code R11-2-401 specifies 

measures that include fencing and signage. Additionally, Rosemont Copper will construct structures 

to provide additional safety protections if needed, such as berms around the pit, possible “tank traps” 

as necessary to restrict road access, and upgraded fencing (i.e., chain link) if necessary on steeper 

slope areas above the pit or other areas. 

Operating facilities will be demolished and removed, and building foundations will be demolished, 

covered with soil, and graded or removed. All areas will be surveyed for the presence of 

contaminants, and any contaminated soils, reagents, or fuels will be disposed of offsite at licensed 

facilities.

With respect to revegetation of the waste rock and tailings landforms, Rosemont Copper will be 

responsible for designing and implementing revegetation procedures. The Coronado, however, will

define the criteria that must be met for revegetation to be considered a success, and all designs and 

techniques must be approved by the Coronado. Planned revegetation techniques, expected success 

criteria, and details of how concurrent revegetation of these areas will be phased are described in the 

“Soils and Revegetation” resource section of chapter 3 of the FEIS. In order to assess the potential 

success of the revegetation plans, the Coronado has considered the results of greenhouse studies and 

onsite reclamation plots conducted by Rosemont Copper. These results are also summarized in 

chapter 3 of the FEIS. 

Phasing of Concurrent Reclamation

In order to maintain concurrent reclamation of final outer slopes, waste rock will initially be placed in 

buttress along the outside edge of the waste rock facility, followed by waste rock and tailings 

placement behind the buttress. A large portion of the waste rock perimeter buttresses that surround the 

tailings facility and the waste rock facility itself will be concurrently reclaimed by year 10; these 

areas will begin to discharge water downstream as reclamation is completed. The upper benches and 

tops of the waste rock and tailings facilities will be reclaimed beginning in year 16 but will not be 

completely reclaimed until the mine is fully closed. The volume of soil that can be salvaged from the 

site to be used later for cover during reclamation activities is estimated at 2.8 million cubic yards.

Draft Record of Decision – December 13, 2013

A-22 Rosemont Copper Project, Coronado National Forest

DRAFT