| RecID | Submission_Metadata | Commentator name | Comment Text in DB | Attachment PDF | Scanned PDF |
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Comment#:
1
Category:
WR
Code:
01
Type:
Form Letter 17 Master
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Comment in Form Letter 17 Master
| COMMENT 1: ADVERSE IMPACTS OF THE MINE ON THE REGION’S FRAGILE WATERSHEDS AND INCREASINGLY STRESSED GROUNDWATER RESOURCES ARE CERTAIN, ARE UNDERESTIMATED BY AUGUSTA, AND MUST BE FURTHER AND INDEPENDENTLY STUDIED TO BE SUFFICIENTLY UNDERSTOOD AND AVOIDED OR FULLY MITIGATED.
Independent hydrological studies estimate that the Mine will intercept substantial surface water that flows to the Davidson Canyon Wash. |
View Attachment PDF
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Comment#:
2
Category:
WR
Code:
03
Type:
Form Letter 17 Master
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Comment in Form Letter 17 Master
| The same studies warn that dewatering of the Mine’s pit could significantly lower the groundwater levels south and north of the Mine in the region east of the Santa Rita Mountains. The Mine’s water production wells near Sahuarita in the Santa Cruz basin west of the Santa Rita Mountains will affect the basin’s ground water levels and nearby existing wells. |
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Comment#:
3
Category:
WR
Code:
01
Type:
Form Letter 17 Master
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Comment in Form Letter 17 Master
| There are substantial remaining uncertainties pertaining to water runoff, recharge, evapotranspiration, and storage properties in the region east of the Santa Rita Mountains. |
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Comment#:
4
Category:
SSS
Code:
01
Type:
Form Letter 17 Master
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Comment in Form Letter 17 Master
| The disruption of the water runoff and lowering of the local groundwater table by the Mine further may threaten the surface water of the Cienega Creek, classified by the U.S. Fish and Wildlife Service as a critical habitat for the Gila Chub (Gila Intermedia) which is designated as endangered with critical habitat under the Endangered Species Act of 1973. |
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Comment#:
5
Category:
WR
Code:
06
Type:
Form Letter 17 Master
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Comment in Form Letter 17 Master
| There is also a potential for the Cienega Creek to be polluted from the Mine operations during heavy rains. |
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Comment#:
6
Category:
WR
Code:
03
Type:
Form Letter 17 Master
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Comment in Form Letter 17 Master
| Independent original studies must be undertaken to produce for the Forest Service valid and reliable empirical data concerning the Mine’s impact on the quantity of regional surface water and groundwater sufficient and necessary for developing the Environmental Impact Statement (hereinafter “EIS”) and demonstrating compliance with the Regional National Forest Service Policy on Groundwater. |
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Comment#:
7
Category:
WR
Code:
02
Type:
Form Letter 17 Master
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Comment in Form Letter 17 Master
| Independent original studies must be undertaken to produce for the Forest Service valid and reliable empirical data concerning the Mine’s impact on the quality of regional surface water and groundwater sufficient and necessary for developing the Environmental Impact Statement (hereinafter “EIS”) and demonstrating compliance with the Regional National Forest Service Policy on Groundwater. |
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Comment#:
8
Category:
WR
Code:
01
Type:
Form Letter 17 Master
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Comment in Form Letter 17 Master
| COMMENT 1A: THE EXTENT THAT THE MINE’S WASTE ROCK, TAILINGS, AND ACID LEACH FIELDS DEPOSITED BEHIND CONTAINMENT BUTTRESSES IN BARREL AND OTHER NEARBY CANYONS WILL DISRUPT SURFACE WATER CHANNELS FLOWING INTO THE DAVIDSON CANYON WASH REMAINS UNDETERMINED.
Discussion: The Coronado National Forest Land and Resource Management Plan states the following:
“Much of the water used in Southern Arizona and New Mexico originates on the mountain Watersheds of the Coronado. Competition for available water is rapidly increasing, and concern is growing about quantity, and quality. The issue can be stated as follows:
Management of forest resources to protect or enhance watershed condition from both a hydrologic function and soil productivity standpoint.”
An independent hydrological study commissioned by Pima County (see Attachment A which is incorporated herein by reference) estimates that the Mine will intercept approximately 650 acre-feet per year of water flow to the Davidson Canyon Wash which in turn flows to the Cienega Creek- and important contributor to greater Tucson’s water supply. The amount that will be intercepted is approximately the same as the current flow that reaches the lower Cienega Creek from Davidson Canyon. The nearly 3,000 acres of waste rock, tailings, and acid leach fields will forever alter the Davidson Canyon Watershed and Cienega Creek. |
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Comment#:
9
Category:
WR
Code:
01
Type:
Form Letter 17 Master
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Comment in Form Letter 17 Master
| Mitigation:
Explicit Performance Standards must be established and continuously monitored by an independent entity at the ongoing expense of Augusta to ensure that the existing water quantity and quality is met during and following reclamation and closure. Such monitoring shall continue indefinitely until an independent entity can scientifically confirm that no long-term adverse effects exist.
The proposed “Central Drain” does not address the adverse impacts of “upstream” surface runoff containing toxic materials entering the Davidson Canyon Watershed, Cienega Creek, and Pantano Creek. Mitigation of such adverse impacts must be provided and conclusively demonstrated via stringent performance standards and on-going monitoring (see above). A National Pollutant Discharge Elimination System (NPDES) permit will be required under the federal Clean Water Act (CWA). This will apply to liquid waste applied to land or released into waters of the nation, and to runoff from the site. In fact a permit would be required to re-inject the waste water into the groundwater basin. |
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Comment#:
10
Category:
WR
Code:
03
Type:
Form Letter 17 Master
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Comment in Form Letter 17 Master
| COMMENT 1B: THE EXTENT THAT DEWATERING OF THE MINE’S PIT WILL ALTER THE LOCATIONS, LEVELS, AND/OR QUALITY OF GROUNDWATER IN THE REGION REMAINS UNDETERMINED. |
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