Proposed AZPDES Permit No. AZ0026387 for January Mine Hermosa Project

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Comment From: Wendy Islas

1/12/24 @ 10:02 PM

Arizona Department of Environmental Quality -

I am submitting my objection to the proposal from the Arizona Department of Environmental Quality (ADEQ) to renew the Arizona Pollutant Discharge Elimination Permit (AZPDES) No. AZ0026387 for South32's ...↓

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Comment From: Tina Brubaker

1/12/24 @ 9:55 PM

I am a resident of Patagonia and STRONGLY oppose the renewal the AZDPES for the South 32 Hermosa Mine. Water is our most precious resource and it needs to be protected and valued for all its benefits. I am referencing, full support and I am including...↓

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Comment From: Sean Manion

1/12/24 @ 9:12 PM

The South 32 Hermosa mining project, with its and surface water discharge of up to 6.48 million gallons per day, and its pollutant load, constitutes an ecological ransacking of the natural resources and the economy of Southern Arizona. The ecologica...↓

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Comment From: Julie Holding

1/12/24 @ 8:55 PM

I request that ADEQ deny the application for an Arizona Pollutant Discharge Elimination Permit, No. AZ0026387, for the South 32 Hermosa Project mine in the Patagonia Mountains.

The proposed permit would allow mine waste water to be discharged into H...↓arshaw Creek, Alum Gulch, and Sonoita Creek. As a resident of the Town of Patagonia who drinks water provided by Town municipal wells, I am concerned to learn that the surface waters of Sonoita Creek are already impaired by zinc pollution. I am concerned that requirements of the Clean Water Act to meet existing surface water quality standards in Sonoita Creek have not been met, specifically, that ADEQ is required to prepare Total Maximum Daily Load (TMDL) studies for Sonoita Creek and has not done so.

I am concerned about reports that ADEQ has allowed mine waste water to be discharged into Harshaw Creek, for months, even though the last permit for surface pollutant discharge expired months ago. I am concerned that this mine waste water currently being discharged, and proposed future mine waste water, may contain manganese, sulfates, arsenic, cyanide, cadmium, lead, mercury, and uranium. I am concerned that these pollutants discharged into Harshaw Creek may make their way into Sonoita Creek, and may infiltrate the Town of Patagonia's water wells and the water that my neighbors and I drink.

I am also concerned that ADEQ plans to issue a permit that would not require monthly, or more frequent, water monitoring for elevated contaminants such as manganese, sulfates, arsenic, cyanide, cadmium, lead, mercury, and uranium.

Finally, I do not understand why the historic Trench Camp mine tailings would be allowed to discharge into Alum Gulch—up to 172,000 gallons of mine waste water per day. I do not understand why surface water pollution from a historic mine is not being fully abated to improve water quality. And I do not understand why a permit is proposed to be issued for a new mine to pollute surface waters of Harshaw Creek and Sonoita Creek with up to 6.48 million gallons of mine waste water per day.

Patagonia Area Resource Alliance's comments about this application are attached and included as part of my comments. Thank you for this opportunity to submit my comments.

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Comment From: Miriam Gilbert

1/12/24 @ 8:43 PM

I strongly urge AZDEQ to deny the AZPDES Permit no. AZ0026387 January Mine Hermosa Project. I have lived in Patagonia since 1988. The health and prosperity of Patagonia are tied to the well-being of two areas of interest: the Patagonia Mountains an...↓

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Comment From: James Wolfe

1/12/24 @ 8:30 PM

I moved to this area for the incredible, rich, and diverse natural environment that has persevered here
in spite of the harms perpetrated against it for well over a century by mineral extraction.
We all know the General Mining act of 1872, written...↓

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Comment From: Alberto Bennett

1/12/24 @ 8:13 PM

January 12, 2024

Arizona Department of Environmental Quality
Water Quality Division, Surface Water Protection
Attn: Rachel Heinz
1110 W. Washington St.
Phoenix, AZ 85007

Re: Draft AZPDES renewal permit for South32 Hermosa Project (AZ0026...↓

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Comment From: Jeanette Joy

1/12/24 @ 7:51 PM

I am extremely concerned about the detrimental effect the South 32 mine will have on the health of the surrounding community and the environment. The area is an extremely biodiverse area with many threatened and endangered species present. I am inclu...↓

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Comment From: Ecotone Biodiversity LLC (Caleb Weaver)

1/12/24 @ 7:46 PM

As a business owner in Patagonia, Arizona, I am concerned about the impact that South32's Hermosa Mine will have on my ability to do business in the region. The location of the South32 Hermosa Mine lies within a biological community that has been int...↓

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Comment From: Joe Harding

1/12/24 @ 6:08 PM

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Comment From: Patty Willis

1/12/24 @ 5:52 PM

I am asking you not to go ahead with the mining project. It will severely diminish a beautiful area that needs to be with us for the next generations. Please look at the long view of keeping the beauty of this Earth. The wonderful town of Patagonia w...↓

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Comment From: Rebecka Meyers

1/12/24 @ 5:48 PM

In reading the proposed Arizona DEQ permitting process for Hermosa South 32 water treatment and discharge, it appears there are no transparent plans for monitoring and/or remediation of high sulfate levels in the water released into Harshaw Creek and...↓

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Comment From: Mark Berg

1/12/24 @ 5:14 PM

I object to the Arizona Department of Environmental Quality's proposal to renew the Arizona Pollutant Discharge Elimination Permit for the South 32's Hermosa Project mine until the following issues are resolved:

1. The discharge location is not in L...↓

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Comment From: Martha Fisher

1/12/24 @ 5:12 PM

As a property owner in Patagonia I object to the ADEQ proposal to renew the Arizona Pollutant Discharge Elimination Permit No. AZ0026387 for South32's Hermosa Project mines.

I was a Hydrologist with USGS for 10 years performing water quality and q...↓uantity studies. Our well is 40 feet deep in coarse sands and gravels. It is within 100 ft of the Sonoita Creek bed. This is true for many of the wells providing drinking water to the citizens of Patagonia. Please protect our drinking water from further impairment and pollution from these historic and proposed new mines as is your mandate through the Clean Water Act.

The increased flows of ~ 6 million gallons per day in a creek bed that is largely dry and already impaired will further release pollutants embedded in the upstream impaired tributary creeks Harshaw and Alum. Also as our climate is rapidly changing, we can anticipate even further flooding and dispersion of historic and proposed mine polluting wastes. Please work to reduce our community's drinking water exposure to fewer pollutants rather increased pollutant loads.

Access to our home and that of all of our neighbors is across the Sonoita Creek bed. There is no bridge for access during flooding. With daily flows of 6 million gallons per day for decades, how will we access our homes? What will happen to our property values? Who will be responsible to reimburse us for our loss of healthy drinking water, our health, and the value offer homes?

As a former hydrogeologist from USGS trained in groundwater modeling from University of Waterloo I am horrified that mining companies are exempted from all groundwater regulations. Santa Cruz County has been determined to be an area of Extreme Drought Conditions by the U.Z. Drought Monitor. How can ADEQ allow 6 million gallons per day and more to be dewatered from a huge area of our watershed for 60 years by South32? That is unconscionable. What will happen to our long stored aquifer resources? What will happen to our drinking water supplies? What will happen to all the native flora and fauna living within our watershed?

The Sky Islands in the Coronado National Forest have received national and international recognition for it's conservation value. The World Wildlife Fund recognized the Chihuahuan Desert Region as globally outstanding in its biological distinctiveness and named the ecoregion a top continent-level conservation target. Conservation International has recognized the sky islands as a conservation hotspot. How many acres of our pristine sky islands ecotone will be destroyed by this massive dewatering for decades?

I concur with all of the legal statutory objections as noted in the attached PARA response to the Proposed AZDES Discharge Permit.

I beg you to fulfill your statutory duties to "Act to protect the environment", promote "protection and enhancement of the quality of water resources", provide for the "prevention and abatement of all water and air pollution", and"ensure the preservation of natural beauty" in our state. A.R. S. 49-204(A)(1),(7),(9), and (10)

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Comment From: MagiCa Castillo

1/12/24 @ 5:01 PM

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Comment From: Robert Gay

1/12/24 @ 5:00 PM

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Comment From: Robin Lucky

1/12/24 @ 4:46 PM

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Comment From: Louis Dombroski

1/12/24 @ 4:45 PM

I am writing to urge you to DENY the proposed AZPDES Permit No. AZ0026387 for the January Hermosa Mine Project.
I spent the last four years (through October 2023) living in Patagonia while I worked at Tucson Audubon's Paton Center for Hummingbirds. ...↓

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Comment From: Reformed Catholic Church (Rev. Andrew Barreras OPR)

1/12/24 @ 4:41 PM

You are not doing your job to enforce the discharge provisions of the Clean Water Act to protect
human health and the environment as required by law.
You cannot issue the permit until ADEQ complies with Total Maximum Daily Load (TMDL)
rules required ...↓

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Comment From: Leslie Schupp

1/12/24 @ 4:39 PM

Please fo not issue an antiquated permit for the S 32 mine. I live 3 miles below the mine on Alum Gulch which is my water supply. Arizona should not be issuing permits that will dry ip our waters and pois p n water and air. I agree eith PARA.

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Comment From: Celinas Ruth

1/12/24 @ 4:25 PM

I am a Human Rights Minister with the Temple Community in Rio Rico, AZ where I live. I also practice law with the nonprofit Global Family Legal Services.

The proposed renewal of the DISCHARGE PERMIT TO South32 Hermosa, Inc. must be taken very seri...↓

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Comment From: Lori Bryant

1/12/24 @ 4:13 PM

Water is life. A foreign mining company making a profit by sucking up the groundwater and disrupting springs supply and upsetting the delicate balance of water patterns in the SONORAN DESERT is not a good idea. We already are experiencing unprecede...↓

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Comment From: Town of Patagonia (Andrea Wood)

1/12/24 @ 4:13 PM

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Comment From: Paula Hartgraves

1/12/24 @ 4:09 PM

I object to Arizona Department of Environmental Quality's (ADEQ) plan to renew the Arizona
Pollutant Discharge Elimination Permit (AZPDES) No. AZ0026387 for South32's Hermosa
Project mine.

The proposed Permit would allow for dangerous discharges of ...↓

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Comment From: Laura S Monti

1/12/24 @ 3:59 PM

I express My vehement opposition to the Proposed Renewal of AZPDES Discharge Permit No. AZ0026387 to South32 Hermosa, Inc. for all the the reasons presented in the attached document of objections by the Patagonia Area Resource Alliance. As a nurse...↓

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Comment From: Cornelia OCONNOR

1/12/24 @ 3:54 PM

My home is about 600 feet from Hawshaw Creek and I am concerned about the heath to this creek and all creeks receiving discharge from the Hermosa South 32 mine. I also get my water from a well. Therefore I want ADEQ to :

1. Do more frequent testin...↓

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Comment From: edward pirl

1/12/24 @ 3:54 PM

Ed Pirl, Board Memebr Calabasas Allianza, Rio Rico
Hello. I want to take this opportunity to share my opposition to the renewal of the Arizona Pollutant Discharge elimination Permit for the South32 Hermosa project.
The permit, which would allow di...↓scharges of mine water into Harshaw creek, Alum gulch and Sonoita Creek poses a threat to both the health of the public and the environment . Prior to renewing this permit the ADEQ must prepare a TMDL study and necessary waste load allocations as required by the Clean Water Act as well as a Planning process for achieving water quality standards So that the waters of Harshaw creek, Alum Gulch and Sonoita creek can be returned to good health.
The significant discharges of mine water into the tributaries leading to Sonoita Creek creates a significant issue given that Sonoita creek is impaired for zinc. ADEQ must complete a TMDL for zinc for Sonoita creek prior to renewing the permit The clean water act also requires a waste load allocation to be performed for the discharges to Sonoita creek so that south 32's discharges will not further contaminate surface waters downstream. ADEQ must take measures to uphold its duty to "act to protect the environment".
ADEQ must recognize the Hermosa project to be a new mine and a new source of discharge. As such it is subject to all modern performance standads and requirements of the Clean Water Act. There is ample evidence to support this claim. The current project is in no way similar to the much smaller project of decades past.
Finally, to protect the quality of drinking water,public health, the environment and the ecosystems in the region, Manganese and sulfate must be monitored along with the monitoring for other toxins like lead, arsenic, mercury, cyanide, and uranium on a monthly basis. At present the monitoring is far too infrequent, It is essential that monitoring take place MONTHLY if not more often. It is imperative that ADEQ revise the draft permit to require more frequent testing.
ADEQ exists to protect and improve the environment of Arizona, to provide for the prevention and abatement of ALL water and air pollution. You must step up and safeguard the water of this county and the environment of all who live here, humans, domestic, wild and endangered creatures. As Arizonans we deserve clean air and water and we expect our state agencies to remain true to their mandate and protect the environment.

I also reference and agree to all of PARA's comments in the document submitted by them

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Comment From: Vanessa Register

1/12/24 @ 3:46 PM

January 11th 2024
ADEQ #AZ 0026387
Hermosa 32 Pollutant Discharge Permit
Good evening and Thank you for being here to listen to my concerns.
My name is Vanessa Register I live at Lake Patagonia, mailing address 105 Lado de Loma Nogales, AZ 85621
My ...↓

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Comment From: Cameron Falconer

1/12/24 @ 3:44 PM

Hello, I am not a resident of Arizona however I spend quite a bit of time in the Patagonia area as my partner lives there. I will not repeat the information that PARA and other organizations and individuals have provided the AZDEQ regarding the South...↓

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Comment From: South32 Hermosa, Inc (Brent Musslewhite)

1/12/24 @ 3:29 PM

Please see attached.

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Comment From: Gerald Rodman

1/12/24 @ 3:26 PM

COMMENT: ADEQ claims erroneously that the discharge location (Outfall 002 ) is in Lower Harshaw Creek, whereas extensive evidence and documentation showz that Outfall 002 is actually constructed in Upper Harshaw Creek which is listed as impair...↓ed for various pollutants under Arizona's Clean Water Act 303(d) list. Accordingly, ADEQ must revise its grossly outdated TMDL for Upper Harshaw Creek before issuing this renewed Permit.
COMMENT: ADEQ must acknowledge the impairments in Lower Harshaw Creek and prepare a TMDL for Lower Harshaw Creek before it can issue the proposed AZPDES permit.
COMMENT: ADEQ must acknowledge the true extent of the ongoing discharge to Harshaw and revise this Permit accordingly to include this discharge data in calculating permit limits – before issuing this renewed permit.
COMMENT: The outdated TMDL must be updated and a new TMDL study must be completed on the new lead impairment in Alum Gulch before ADEQ issues the renewed Permit.
COMMENT: ADEQ's workaround proposal to only allow discharge from "historic tailings" into Alum Gulch is contrary to documented facts about how South32 has operated this mine site for years. It also disregards the fact documented by both South32 and ADEQ that the tailings pile and mine seepage from this pile includes dangerous new sources of pollutants. This tailings pile has, for years, been used by South32 to hold many tons of new waste rock, exploration rock, treatment plant waste, and potentially acid-generating material. ADEQ's tortured analysis and conclusion that the only mine seepage that will be discharged to Alum Gulch from the tailings pile will come from historic tailings is wildly inaccurate and misleading to the public. ADEQ must revise this provision before issuing this renewed Permit.
COMMENT: ADEQ must complete a TMDL for the zinc impairment in Sonoita Creek before issuing this renewed Permit.
COMMENT: ADEQ must perform a waste load allocation for the discharges to Sonoita Creek. This is required by the Clean Water Act so that South32's discharges will not further contaminate or degrade these downstream surface waters but rather can support the future restoration of water quality in the Creek.
COMMENT: ADEQ must determine these new facilities to be legal "new sources" of discharge – before issuing this renewed Permit.
COMMENT: ADEQ must revise the Permit to acknowledge that this mine is expected to go into production during the life of this Permit.
COMMENT: As a new source, the mine is subject to all modern performance standards and requirements of the Clean Water Act.
COMMENT: ADEQ must revise the Draft Permit to require monitoring for manganese and sulfate in order to protect human health and the drinking water. systems and infrastructure of the Town of Patagonia and residents of the area – before issuing this renewed Permit.
COMMENT: ADEQ must revise the Draft Permit to require that full monitoring be done at least monthly.
I also incorporate all comments in the attached uploaded file into my comments

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Comment From: TerraSol Center LLC (Mary Tolena)

1/12/24 @ 3:14 PM

I live on Harshaw Avenue in Patagonia, and operate TerraSol Center, a campground that serves hikers, cyclists, and van/RV travelers. My property is approximately 300 yards from Harshaw Creek, and my well taps into the creek aquifer. Not only is ongoi...↓

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Comment From: brett tanner

1/12/24 @ 3:01 PM

Arizona Department of Environmental Quality
Water Quality Division, Surface Water Protection
Attn: Rachel Heinz
1110 W. Washington St.
Phoenix, AZ 85007

Re: Draft AZPDES renewal permit for South32 Hermosa Project (AZ0026387); LTF No. 95353
Dear...↓

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Comment From: Leanna Goose

1/12/24 @ 2:47 PM

We cannot move from one heavily polluting industry to another. Mining to fix the climate crisis will be a grave mistake that we cannot afford to make. We all need clean water to survive, and the amount of water wasted to get all these minerals from t...↓

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Comment From: Southern Arizona Business Coal... (Rick Grinnell)

1/12/24 @ 2:41 PM

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Comment From: Blue Evening Star

1/12/24 @ 2:31 PM

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Comment From: Mary Normandia

1/12/24 @ 2:18 PM

Please vote to deny the water rights permit. I moved to AZ to be part of this great naturally beautiful area. Don't kill me now!

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Comment From: Katya Peterson & Pierre Landau

1/12/24 @ 2:00 PM

As a family who has owned property off of Harshaw Road for a decades, with the idea of eventually building a house on it, we object strenuously to the current rush to permitting for the Hermosa Mine project. Please note the mine is located only a sto...↓

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Comment From: Ann Gosline

1/12/24 @ 1:50 PM

COMMENT: ADEQ claims erroneously that the discharge location (Outfall 002 ) is in Lower Harshaw Creek, whereas extensive evidence and documentation showz that Outfall 002 is actually constructed in Upper Harshaw Creek which is listed as impair...↓ed for various pollutants under Arizona's Clean Water Act 303(d) list. Accordingly, ADEQ must revise its grossly outdated TMDL for Upper Harshaw Creek before issuing this renewed Permit.
COMMENT: ADEQ must acknowledge the impairments in Lower Harshaw Creek and prepare a TMDL for Lower Harshaw Creek before it can issue the proposed AZPDES permit.
COMMENT: ADEQ must acknowledge the true extent of the ongoing discharge to Harshaw and revise this Permit accordingly to include this discharge data in calculating permit limits before issuing this renewed permit.
COMMENT: The outdated TMDL must be updated and a new TMDL study must be completed on the new lead impairment in Alum Gulch before ADEQ issues the renewed Permit.
COMMENT: ADEQ's workaround proposal to only allow discharge from "historic tailings" into Alum Gulch is contrary to documented facts about how South32 has operated this mine site for years. It also disregards the fact documented by both South32 and ADEQ that the tailings pile and mine seepage from this pile includes dangerous new sources of pollutants. This tailings pile has, for years, been used by South32 to hold many tons of new waste rock, exploration rock, treatment plant waste, and potentially acid-generating material. ADEQ's tortured analysis and conclusion that the only mine seepage that will be discharged to Alum Gulch from the tailings pile will come from historic tailings is wildly inaccurate and misleading to the public. ADEQ must revise this provision before issuing this renewed Permit.
COMMENT: ADEQ must complete a TMDL for the zinc impairment in Sonoita Creek before issuing this renewed Permit.
COMMENT: ADEQ must perform a waste load allocation for the discharges to Sonoita Creek. This is required by the Clean Water Act so that South32's discharges will not further contaminate or degrade these downstream surface waters but rather can support the future restoration of water quality in the Creek.
COMMENT: ADEQ must determine these new facilities to be legal "new sources" of discharge – before issuing this renewed Permit.
COMMENT: ADEQ must revise the Permit to acknowledge that this mine is expected to go into production during the life of this Permit.
COMMENT: As a new source, the mine is subject to all modern performance standards and requirements of the Clean Water Act.
COMMENT: ADEQ must revise the Draft Permit to require monitoring for manganese and sulfate in order to protect human health and the drinking water. systems and infrastructure of the Town of Patagonia and residents of the area – before issuing this renewed Permit.
COMMENT: ADEQ must revise the Draft Permit to require that full monitoring be done at least monthly.

I also incorporate all comments in the attached uploaded comments as my comments.

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Comment From: Arizona Trail Association (Matthew Nelson)

1/12/24 @ 1:46 PM

As the organization responsible for the protection and maintenance of the Arizona National Scenic Trail, we object to the Arizona Department of Environmental Quality's (ADEQ) plan to renew the Arizona Pollutant Discharge Elimination Permit (AZPDES) N...↓o. AZ0026387 for South32's Hermosa Project mine. Our primary concerns are impacts to groundwater health on the Coronado National Forest, and within the Town of Patagonia – both of which are vital resources supporting the Arizona Trail.

The proposed permit would allow for dangerous discharges of water into Harshaw Creek, Alum Gulch, and Sonoita Creek, potentially compromising the health of local residents and public lands nearby. This may be in violation of the Federal Clean Water Act and Arizona's surface water quality laws. The issuance of the permit is also contrary to ADEQ's own rules which require ADEQ to:
- act to protect the environment
- promote the protection and enhancement of the quality of water resources
- provide for the prevention and abatement of all water and air pollution
- ensure the preservation and enhancement of natural beauty in our state

The Arizona Trail Association recognizes the importance of the mining industry to maintain a diversified economy within rural communities. In addition, we are supportive of mining projects that are socially and environmentally responsible – especially when the project proponent can offset their negative impacts through proper mitigation measures. We also understand the Biden Administration has prioritized this particular project to support the harvesting of critical minerals. However, the negative impacts to water resources on public lands and within the local community are alarming and require further hydrological analyses and sufficient monitoring protocols before the AZPDES is issued.

Impacts to springs and ephemeral streams in the Patagonia Mountains increase the risk of uncharacteristic wildfires, compromising forest health, wildlife, and Arizona's outdoor recreation industry, which contributes over $18 billion to our state's economy each year. Additionally, if groundwater levels continue to drop or contain harmful contaminants, the Town of Patagonia's very sustainability may be threatened. As one of the most important gateway communities along the Arizona Trail, our organization is very invested in preserving the quality of life within the Town for locals and visitors alike.

We trust ADEQ to enforce the discharge provisions of the Clean Water Act to protect human health and the environment as required by law. Please comply with Total Maximum Daily Load (TMDL) rules required by the Clean Water Act so that the contaminated waters of Harshaw Creek, Alum Gulch, and Sonoita Creek can be returned to good health.

The Arizona Trail Association (ATA) is an Arizona nonprofit organization whose mission is to protect, maintain, enhance, promote and sustain the Arizona Trail as a unique encounter with the natural environment. The 800-mile trail spans the length of the state from Mexico to Utah, connecting deserts, mountains, canyons, forests, communities and diverse peoples. It was designated a State Scenic Trail in 2006 and a National Scenic Trail in 2009. Patagonia is one of 19 designated Arizona Trail Gateway Communities. The ATA works in collaboration with county, state and federal land management agencies, municipalities, volunteers, industry partners, elected representatives, private property owners, and many others to ensure the protection and sustainability of the Arizona Trail for the benefit of all.

Thank you for considering our objection, and please keep me informed throughout the permitting process.

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Comment From: Mark Willaman

1/12/24 @ 1:40 PM

As a property owner in Patagonia, AZ, I am strongly opposed to the renewal of the Arizona Pollutant Discharge Elimination Permit (AZPDES) No. AZ0026387 for South32 Hermosa, Inc.'s Hermosa Project mine. It seems that this permit violates both the Fede...↓

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Comment From: Brett Thompson

1/12/24 @ 1:24 PM

Dear Arizona Department of Environmental Quality,

I’m writing to urge you to deny South32’s Hermosa permit (#AZ0026387) for discharge of mine water into Harshaw and Alum creeks. The proposed impacts are unacceptable and fall into two main categories: ...↓1) dewatering due to the “cone of depression” that would be created around the mine and 2) disturbances that would come from dramatically increased flow rates in nearby creeks.

First, dropping the groundwater level in an area like this would be highly destructive. The change in hydraulic gradients around the mine would change the “paths of least resistance,” where current springs emerge, permanently drying natural springs. It would also lead to significant loss of upland trees. The death of surrounding trees will decrease the landscape’s overall resilience and could lead to the present ecosystem’s radical transformation and potential collapse.

Expected harms from the water discharges are also deeply concerning. Up to 6 million gallons of water per day could be forced down Harshaw Creek and up to 172,000 gallons per day down Alum Creek. These volumes are significantly higher than current, intermittent, base flows. This will lead to severe erosion upstream, excessive sediment loads downstream, and the burial of several important water sources such as the seven rheocrene seeps and springs known in Harshaw Creek and the nine rheocrene seeps and springs known in Alum Creek. These harms are particularly concerning because springs are such unique ecosystems with high biodiversity. Their destruction will affect endemic species to an unknown degree because the sites haven’t yet been adequately surveyed. Some estimates suggest that refugia like these support more than 20% of endangered and threatened species, despite making up a much smaller proportion of the land surface area (Springs Stewardship Institute).

What’s more, such intense flooding will lead to reduced tree recruitment for riparian species like cottonwoods and sycamores — over time, altering the landscape. Because the water discharges would be ongoing, the surrounding landscape will be more water-logged. This means a reduced capacity to absorb water during rains, and potential downstream flash flooding. And finally, the quality of the water being discharged in such high quantities is a concern. Its source will be deep underground in the Hermosa project, and although the mine has promised to treat the water before release, its quality could change unexpectedly over time.

Although water in the desert is a rarity, and one would think that increased flow would help our streams, because of the sensitive ecological balance of these riparian ecosystems, a change in flow regime this drastic could permanently alter the character and species composition of these areas.

For all these reasons, I urge you and the Arizona Department of Environmental Quality to deny the permit for this project.

Sincerely,

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Comment From: Rabbi Nina Perlmutter

1/12/24 @ 1:21 PM

As a rabbi, college instructor in Environmental Ethics and "Eco-theology", I am extremely disappointed about Arizona Department of Environmental Quality's (ADEQ) plan to renew the Arizona Pollutant Discharge Elimination Permit (AZPDES) No. AZ0026387 ...↓

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Comment From: Amee Beck-Jones

1/12/24 @ 1:14 PM

I object to Arizona Department of Environmental Quality's (ADEQ) plan to renew the Arizona
Pollutant Discharge Elimination Permit (AZPDES) No. AZ0026387 for South32's Hermosa
Project mine.
The proposed Permit allows for discharges of mine water to Ha...↓

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Comment From: Patagonia Area Resource Allian... (Carolyn Shafer)

1/12/24 @ 12:47 PM

Comments attached in PDF.

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Comment From: Nasrin Mazuji

1/12/24 @ 12:30 PM

I object to Arizona Department of Environmental Quality's (ADEQ) plan to renew the Arizona Pollutant Discharge Elimination Permit (AZPDES) No. AZ0026387 for South32's Hermosa Project mine.
The proposed Permit would allow for dangerous discharges of m...↓

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Comment From: Bret Halley

1/12/24 @ 12:14 PM

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Comment From: Sandra Porter

1/12/24 @ 11:55 AM

Your agency has let South32 discharge mine water since about August 2023 into Harshaw Creek under an EXPIRED AZPDES surface water permit.
I strongly object to a renewal of this old permit to S32. Your agency must revise and includes all of the fo...↓

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Comment From: Brooke Wolterstorff

1/12/24 @ 11:37 AM

Leave our wetlands alone! We have few and far between wet areas in the southwest as it is. The wildlife needs that area to survive. These are places that cannot be easily or ever be replaced. Look at what was done to the area around the Panama Can...↓

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Comment From: Andrew Gould

1/12/24 @ 11:36 AM

My wife and I have lived in Lake Patagonia Ranch Estates for over 10 years. The town of Patagonia and Sonoita Creek have been the foci of our lives. We have been active members of the Friends of Sonoita Creek for 10 years and have been very involved ...↓

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Comment From: Yuri Hauswald

1/12/24 @ 11:35 AM

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Comment From: Sydney Hay

1/12/24 @ 11:33 AM

January 12, 2024
Arizona Department of Environmental Quality
Water Quality Division, Surface Water Protection
Attn: Rachel Heinz
1110 W. Washington St.
Phoenix, AZ 85007

Re: Comment in support of renewal of AZPDES Permit No. AZ0026387 for January M...↓ine Hermosa Project; LTF No. 95353

Dear Ms. Heinz:

This comment is provided in support of the proposal by the Arizona Department of Environmental Quality to renew the AZPDES permit for the January Mine Hermosa Project owned by South32 Hermosa Inc.

I am President of the mining industry trade association, Arizona Mining and Industry Get Our Support (AMIGOS.) We are over 300 Arizona businesses that provide goods and services to the mining industry. Our members collectively employ thousands of Arizonans in good, high-paying jobs. The mine proposed by South32 Hermosa is important to our membership.

The project will provide significant economic benefits to the local and regional economy in the form of hundreds of jobs during construction and operation, local/regional/state direct spending, and tax revenue. These benefits are critically important for Santa Cruz County, which has a very high unemployment rate. South32 Hermosa has displayed its commitment to the local community by already making significant investments in local infrastructure and education. The company has also acted transparently by sharing information with and seeking input from community members and its community advisory panel which includes several environmental organizations.

The mine will be a source of two critical minerals, manganese, and zinc, that will aid in the country's transition to clean energy sources. Partly for this reason, we understand that the project is the first mining project to be accepted into the federal FAST-41 program that attempts to streamline permitting without sacrificing environmental protection or opportunities for public input.

As explained by ADEQ, this would be a renewal of an existing permit. As we understand it, the treatment plants at the mine have been designed to meet all applicable federal and state legal requirements. The discharges are regulated not only by the permit currently under consideration but also by another permit issued by ADEQ (a groundwater protection permit). Moreover, based on the ADEQ fact sheet, it appears that the changes being proposed to the existing permit would serve to make the renewal permit even more stringent and environmentally protective.

For these reasons, we support ADEQ's proposal to issue the renewal permit. Thank you for the opportunity to comment.

Sydney Hay, AMIGOS President

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Comment From: D Sohocki

1/12/24 @ 11:31 AM

We oppose the permitting of January Mine Hermosa project. The groundwater pumping associated with this project is both excessive and destructive. When will ADEQ stand up and protect our dwindling groundwater resources? When will ADEQ stop being a ...↓

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Comment From: Lisa Redpath

1/12/24 @ 11:18 AM

Dear ADEQ,

I write to you to ask that you refrain from issuing any and all permits to the Australian mine company, South32 and its Hermosa Project. In particular, I object to the renewal of the Arizona Pollutant Discharge Elimination Permit No AZ002...↓

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Comment From: mary steenhoek

1/12/24 @ 10:51 AM

I ask that you do not issue a Permit to AZDPES for the Hermosa Project for underground discharge. Water is one of the most important and valued resources of our state to be preserved for vital uses. Do not approve this discharge. It is a waste of ...↓

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Comment From: Scherry Duncan

1/12/24 @ 10:36 AM

I object to Arizona Department of Environmental Quality's (ADEQ) plan to renew the Arizona Pollutant Discharge Elimination Permit (AZPDES) No. AZ0026387 for South32's Hermosa Project mine.

The proposed Permit would allow for dangerous discharges of ...↓

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Comment From: Emilio Falco

1/12/24 @ 10:25 AM

From the PARA newsletter:
"Despite assurances of safety and sustainability, South 32 has a truly horrific record of environmental devastation poisoning people and places around the planet, as our partners with Calabasas Alliance have shared below. " ...↓

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Comment From: Mindy RUBIN

1/12/24 @ 10:22 AM

The Hermosa mine project to pump ground water will harm our environment and the lives of people in Az. Please do not continue.

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Comment From: Leah Gilbert

1/12/24 @ 10:05 AM

I am opposed to the proposed mining project in the Patagonia area that will degrade conditions in the area and waste our precious water resources. I ask that you do not issue any permits for this project.

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Comment From: Andrea Bernkrant

1/12/24 @ 10:05 AM

I will be brief. There is no project worth wasting precious water sources in AZ and permanently damaging the natural landsape. None. We already have communities in the valley that have literally run out of water. To allow this project, especially...↓

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Comment From: Kelley Gallaher

1/12/24 @ 9:55 AM

South32's Hermosa Mine should: Be identified as a brand new mine; Have its treated wastewater monitored independently for heavy metal contaminants, including manganese, on a monthly basis.

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Comment From: Suzanne Solvet

1/12/24 @ 9:49 AM

Do not waste our precious water. Think of the big Picture, for a change, of our environment and of future generations instead of greed for today.

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Comment From: Susan Schanerman

1/12/24 @ 9:42 AM

Please reconsider this action and protect the environment of this region.

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Comment From: Timothy Ernster

1/12/24 @ 9:39 AM

I am opposed to the issuance of permit for the Hermosa Mine in that it would adversely affect the biodiversity of the area and threaten ground water supplies that would have a lasting detrimental affect on the area.

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Comment From: Emily Dukes

1/12/24 @ 9:20 AM

There needs to be environmental impact studies done from an independent source before moving forward. The fast tracking of any action is the first issue. The new discovery of the endangered jaguar officially in the area should be reason enough. A...↓

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Comment From: Chris Gardner

1/12/24 @ 9:18 AM

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Comment From: Kelvin Murray

1/12/24 @ 8:20 AM

As a Professional Ecologist certified by the Ecological Society of America, I object to ADEQ's plan to renew the AZPDES No. AZ0026387 for South32's Hermosa Project mine. My reading of the project description suggests that the project would require dr...↓

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Comment From: Christine Sbragia

1/12/24 @ 7:36 AM

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Comment From: Eric Findeis

1/12/24 @ 7:11 AM

I am property owner in Patagonia and this topic is literally the deciding factor in whether we will build and move to the beautiful Patagonia area. Patagonia is a special place for many reasons, but its priceless position as a protected migratory pa...↓

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Comment From: Sandy Cordova

1/12/24 @ 7:02 AM

I object to Arizona Department of Environmental Quality's (ADEQ) plan to renew the Arizona Pollutant Discharge Elimination Permit (AZPDES) No. AZ0026387 for South32's Hermosa Project mine.
The proposed Permit would allow for dangerous discharges of m...↓

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Comment From: Jay Thompson

1/12/24 @ 6:36 AM

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Comment From: Sumita Khanna

1/12/24 @ 12:55 AM

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Comment From: Brian Whitlock

1/12/24 @ 12:00 AM

Dear Arizona Department of Environmental Quality, I’m writing to urge you to deny South32’s Hermosa permit (#AZ0026387) for discharge of mine water into Harshaw and Alum creeks. The proposed impacts are unacceptable and fall into two main categories:...↓ 1) dewatering due to aquifer pumping and 2) chemical and physical disturbances due to increased flow rates in Harshaw and Alum. First, dropping the groundwater level in an area like this would be highly destructive. The change in hydraulic gradients around the mine would change the “paths of least resistance,” where current springs emerge, permanently drying natural springs. It would also lead to significant loss of upland trees. The death of surrounding trees will decrease the landscape’s overall resilience and could lead to the present ecosystem’s radical transformation and potential collapse. Expected harms from the water discharges are also deeply concerning. Up to 6 million gallons of water per day could be forced down Harshaw Creek and up to 172,000 gallons per day down Alum Creek. These volumes are significantly higher than current, intermittent, base flows. This will lead to severe erosion upstream, excessive sediment loads downstream, and the burial of several important water sources such as the seven rheocrene seeps and springs known in Harshaw Creek and the nine rheocrene seeps and springs known in Alum Creek. These harms are particularly concerning because springs are such unique ecosystems with high biodiversity. Their destruction will affect endemic species to an unknown degree because the sites haven’t yet been adequately surveyed. Some estimates suggest that refugia like these support more than 20% of endangered and threatened species, despite making up a much smaller proportion of the land surface area (Springs Stewardship Institute). What’s more, such intense flooding will lead to reduced tree recruitment for riparian species like cottonwoods and sycamores — over time, altering the landscape. Because the water discharges would be ongoing, the surrounding landscape will be more water-logged. This means a reduced capacity to absorb water during rains, and potential downstream flash flooding. And finally, the quality of the water being discharged in such high quantities is a concern. Its source will be deep underground in the Hermosa project, and although the mine has promised to treat the water before release, its quality could change unexpectedly over time. Although water in the desert is a rarity, and one would think that increased flow would help our streams, because of the sensitive ecological balance of these riparian ecosystems, a change in flow regime this drastic could permanently alter the character and species composition of these areas. For all these reasons, I urge you and the Arizona Department of Environmental Quality to deny the permit for this project.

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Comment From: Deborah M. Gates

1/12/24 @ 12:00 AM

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Comment From: Gary Levine

1/12/24 @ 12:00 AM

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Comment From: N/A Hadden

1/12/24 @ 12:00 AM

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Comment From: Jerry Harris

1/12/24 @ 12:00 AM

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Comment From: Leon Punt

1/12/24 @ 12:00 AM

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Comment From: Mark Davis

1/12/24 @ 12:00 AM

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Comment From: Melissa Crider Andrea

1/12/24 @ 12:00 AM

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Comment From: Nicki Stanton

1/12/24 @ 12:00 AM

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Comment From: Peter Gates

1/12/24 @ 12:00 AM

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Comment From: Stephen and Barbara Talmage

1/12/24 @ 12:00 AM

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Comment From: Susan Pennacchini

1/12/24 @ 12:00 AM

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Comment From: Michael Guymon

1/12/24 @ 12:00 AM

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Comment From: Peggy Dierking

1/11/24 @ 11:26 PM

I have some questions: 1) What does "historic tailings" refer to? 2) Why is South32 maintaining a "Tailing Storage Facility"? Is this a requirement by ADEQ? What is a geomembrane covering?
Also, can you provide copies of the petitions for review tha...↓

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Comment From: Katerina Sacoman

1/11/24 @ 10:16 PM

The January Mine is a direct threat to the health of the headwaters of The Santa Cruz River. These headwaters affect the water in the rest of the watershed and those who's water is supplied by The Santa Cruz River. The mine should not receive a renew...↓

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Comment From: KATHRYN SCHRAG

1/11/24 @ 10:14 PM

I am writing to address AZPDES Permit No. AZ0026387. I have lived in Patagonia for over 20 years, and have watched with growing concern as foreign mining interests have made plans to extract minerals from the surrounding mountains. This is one of the...↓

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Comment From: Anita Conner

1/11/24 @ 9:47 PM

Good evening. My name is Dr. Anita Conner. I am the Chief Medical Advisor of the Calabasas Alliance and I live in Rio Rico. Our organization is a relatively new but active grassroots advocacy group with the mission of preserving and protecting the ...↓natural environment of biodiverse flora and fauna, water resources, air quality, and the health and safety of all residents of Santa Cruz county. Through active advocacy, in cooperation with like minded groups and legal counsel, the Alliance seeks to mitigate the negative effects of major industrial development, especially mining, ore processing and accompanying transport in Santa Cruz county.

First and foremost, speaking for myself and the Calabasas Alliance, I want to express my strongest possible support for the Patagonia Area Resource Alliance's (PARA's) legal team's document of their specific comments on the proposed renewal of the Arizona Pollutant Discharge Elimination Permit for South32 Hermosa. I am including that document as an addendum to my comments which I will be submitting to you online. Each one of their points is critically important but I personally want to emphasize the need to revise the Draft Permit to require monitoring for manganese.

The health risks associated with too much exposure to manganese are well documented and would be of greatest risk to our very young and our older populations. Imagine the possibility of a young family unknowingly using contaminated well water to make their baby's formula, unaware that they could be contributing to permanent neurotoxic effects for their child. Or an elderly family member potentially developing manganism which may look like Parkinson's disease, but for which anti Parkinson's disease medications do not help, and no other treatments are currently available to effectively treat the symptoms. I also fully support the recommendations to increase the frequency of monitoring.

All the comments relating to the needed Total Maximum Daily Load studies in PARA's document must be carefully and consciously incorporated into any revised or new permit that might be approved for South32 Hermosa. Furthermore, the need to identify this as a new mine is well described in the same document. The consequences of not taking all these points seriously are far-reaching and potentially devastating to our county. The classification of Santa Cruz county as being in an extreme drought state (in the 5% worst category for the state) as per the Arizona Department of Water Resources at their meeting yesterday makes the situation all the more dire. Your role with the Arizona Department of Environmental Quality is one which will shape the destiny of this area for many years to come. Thank you for your time.

addendum from PARA:

https://drive.google.com/file/d/1IORWyXodessLAM42cUYuJwkkIpn-V_xY/view?mc_cid=b110432405

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Comment From: Tiffany Bertelsen

1/11/24 @ 9:42 PM

We need less development in these key corridors for wildlife in this beautiful yet harsh environment THEY call home!!!!

Please do not allow this to proceed. We can find another way.

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Comment From: Julie Arma

1/11/24 @ 9:41 PM

I object to the proposal from Arizona Department of Environmental Quality (ADEQ) to renew the Arizona Pollutant Discharge Elimination Permit (AZPDES) No. AZ0026387 for South32's Hermosa Project mine.

The renewal of this permit could allow dangerous ...↓

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Comment From: emma simonson

1/11/24 @ 9:39 PM

I STRONGLY oppose the renewal of the AZDPES for the South 32 Hermosa Mine. This cannot happen. Water is Life for absolutely everything and everyone on Earth. Patagonia is a precious place with a precious community of humans, plants, birds, wild game ...↓

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Comment From: Z S

1/11/24 @ 9:33 PM

AZEQ - Public Comment

I am a resident of Patagonia and STRONGLY oppose the renewal the AZDPES for the South 32 Hermosa Mine. Water is our most precious resource and it needs to be protected and valued for all its benefits. I am referencing, full su...↓

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Comment From: Robin Kolwicz

1/11/24 @ 9:32 PM

The ADEQ's posted mission statement is to protect and enhance public health and environment in Arizona. In order to fulfill that mission, the ADEQ must be extremely conservative in considering mining permits such as the proposed renewal of Pollutant...↓

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Comment From: Orion Niles

1/11/24 @ 9:22 PM

Orion Niles
Human Rights Advocate & Minister with GCCA
2074 Pendleton drive
Rio Rico
Parent of 2
Lived here 16 years

Please incorporate PARA's comments into my comment.

I object to the renewal of the South 32 Hermosa pollutant discharge permit, AZ0...↓

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Comment From: Gary Kiser

1/11/24 @ 9:15 PM

Water in Arizona is a precious resource. We do not need this mine as it will reduce ground water in the Patagonia area. Patagonia is such a beautiful area. Don't let mining ruin the area.

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Comment From: Onur Azeri

1/11/24 @ 9:14 PM

Hello: My name is Onur Azeri and I am a resident of this incredible town we get to call home. Patagonia, AZ.

I moved here from the dense, polluted, crowded, loud and awful concrete jungle of NY to escape all of that and come to a small town I coul...↓d call home: With clean water, beautiful skies and incredible natural beauty, wildlife, and flora.

I strongly oppose the renewal of the AZDPES for the South 32 Hermosa Mine. Water is our most precious resource in this fragile biosphere in the desert and it needs to be protected and valued for all its benefits. I am referencing, full support and I am including PARAs comments as part of my comments.

The proposed discharge permit will allow dangerous discharge into our waterways, drain our life giving aquifer which the town of Patagonia relies on for drinking water. It threatens the health of the community, residents and greater environmental area.

Fact 1 - South 32 Hermosa is a CLEARLY A NEW MINE. The old mine in the similar site was CLOSED DOWN. And all legal steps need to take the NEW mine into consideration. No permits should be given without that consideration. ADAQ needs to live up to the standards set out in the ADEQ mission statement.

Fact 2 - the proposed monitoring are insufficient! Monitoring need to account for manganese and sulfate, among other minerals baselines need to be set and monitoring need to random ad well as conducted at much more frequent intervals Additionally, monitoring need to be done by an independent monitoring agency, NOT by the polluter South 32.

TMDL analysis needs to be completed for the Zinc in Sonoita Creek before issuing the permit. Additionally, waste load allocation for the discharge into Sonoita Creek must be preformed. This is mandated by the Clean Water Act.

Fact 3 - Santa Cruz County is in a multi year extreme drought! The use of 6.5 million gallons of water being polluted and discharged is absolutely unacceptable.

Fact 4 - ADEQ discharge location is in reality in Upper Harshaw Creek, not Lower Harshaw as falsely claimed. The permit MUST take the impairments of Lower Harshaw Creek into consideration. The true ongoing discharge MUST be calculated in the proposed permit.

We EXPECT our State agencies to be true to their mandate - "To protect and enhance public health and the environment in Arizona. Through consistent, science-based environmental regulation..."

Thank you much.
Onur Azeri
845.303.4070

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Comment From: Lucas Neves

1/11/24 @ 9:08 PM

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Comment From: Angela Murphy

1/11/24 @ 8:56 PM

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Comment From: Bill Gilchrist

1/11/24 @ 8:38 PM

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