Forest Service failed to adequately analyze Rosemont’s major impacts to Arizona Trail, OHV and other recreational uses

The proposed Rosemont copper mine will have major negative impacts on popular recreational activities in the Santa Rita Mountains located on the Coronado National Forest (CNF), including off-highway-vehicle (OHV) use and the relocation of 13 miles of the Arizona National Scenic Trail.

Despite the anticipated recreation-related problems, the CNF did not adequately analyze the severity of the impacts or propose suitable mitigation measures to compensate for the damage, according to comprehensive written objections to the CNF’s Final Environmental Impact Statement (FEIS) for the proposed massive open pit mine.

The objections were prepared by a citizen’s coalition opposed to the mine and were filed with the U.S. Forest Service Regional Forester, who must respond in writing by the end of April.

If the objections are not adequately addressed with substantive changes to mining plans, the issues could be used in potential litigation against the Forest Service that could block construction of the mile-wide, half-mile deep open pit mine.

The Forest Service’s FEIS describes the CNF as a “recreation forest” because  recreation is such a high priority for visitors. The agency, however,  did not include a “Recreation Specialist’s Report” in the FEIS that would have provided a comprehensive analysis of the mine’s serious impacts on recreational activities in the Santa Rita Mountains, the objections state.

The CNF’s decision not to include the recreation report comes after a 2008 assessment by the Arizona Game & Fish Department that the mine would “render the northern portion of the Santa Rita Mountains…worthless for wildlife recreation.”

The objections state that CNF has not analyzed what the impact of destroying the Santa Rita Mountains will have on other public lands that the Forest Service predicts will see dramatic increases in recreational use.

Mine opponents asked the Regional Forester to withdraw December’s preliminary decision to approve the mine in a draft Record of Decision and, instead, prepare the Recreation Specialist’s Report to be included in a new Draft Environmental Impact Statement (DEIS) that would be subject to public review and comment.

The objections also cited additional shortcomings in the FEIS including:

• Failure to provide a full analysis of the Arizona Trail relocation alternatives.

The mine will dump waste rock and potentially toxic mine tailings across more than 3,000 acres of the CNF, severing the popular Arizona trail and requiring construction of a new 13-mile segment.

The Forest Service, the objections state, provided conflicting information in its FEIS about when and where the new trail would be constructed and whether the existing trail would be closed prior to completion of an alternative route.

Objectors also state that the Forest Service did not provide adequate disclosure of the cost of constructing the new trail or a detailed accounting of Rosemont Copper Company’s commitment to pay for construction of the new trail segment.

The objectors requested: “The USFS should conduct a comprehensive, site-specific field evaluation of the alternative trail locations, as well as a similarly comprehensive site-specific evaluation of potential construction-related issues, mine-related impacts on trail users, and impacts on wildlife, vegetation and other resources, and include those assessments in a revised DEIS that is made available for public review and comment.”

• The FEIS did not include adequate analysis of the impacts of displaced OHV use on other public lands and fails to require adequate mitigation for these impacts.

In its DEIS, the Forest Service described the Rosemont area as “one of the more popular and traveled off-highway vehicle riding areas, the loss of which would be more intense than the loss of roads in other portions of the Santa Rita Back Country Touring Area.”

The Rosemont mine would likely shift OHV to fragile grasslands that will have a dramatic, negative effect on other parts of the CNF and the Las Cienegas National Conservation Area, the objections state.

The Forest Service states in the FEIS that it will assemble a team to assess the potential damage from OHV displaced by the Rosemont project in a future analysis under the National Environmental Policy Act (NEPA). The objections state the Forest Service is required to do the analysis before it can approve the mine.

Similarly, the Forest Service’s reliance on Rosemont Copper’s promise to provide funding to develop facilities and manage OHV impacts in new areas that are already deemed “less suitable” for off road activities is inadequate, according to the objections.

“It is not acceptable – nor does it constitute mitigation – for the USFS to simply kick the can down the road by agreeing to analyze the impacts of displaced OHV recreation on other areas through a future NEPA process that would be initiated at an unspecified time…through a yet-to-be signed funding agreement with Rosemont,” the recreation objections state.

Mine opponents recommended that the CNF provide a full analysis of the significant environmental and economic impacts of displaced OHV use on other areas of the CNF and adjacent public lands; and develop enforceable mitigation measures that will address the OHV impacts.

The analysis and mitigation should be provided in a revised DEIS that is made available for public review and comment, the objection requests.

* The FEIS provides an inadequate analysis of the Rosemont Mine’s impacts on millions of dollars of  prior investments in recreation and tourism.

The objections state the DEIS failed to analyze the millions of dollars that have been spent in the Rosemont project area to develop and maintain the back country touring area and whether the loss of this investment can reasonably be expected to be duplicated elsewhere.

The objectors requested the CNF to conduct a detailed analysis of the impacts of the Rosemont mine on the public investment and the availability of public funding to develop new recreation areas. The analysis, the objections state, should be included in a revised DEIS that is made available for public review and comment.