Proposed AZPDES Permit No. AZ0026387 for January Mine Hermosa Project

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Comment From: Annemarie Avanti

1/10/24 @ 4:35 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: Mary Doll

1/10/24 @ 4:28 PM

As a concerned citizen I am profoundly concerned about the water supply for Tucson and SW Arizona. My daughter is already looking for a place to move to when she retires, believing that the water supply will continue to be a serious problem here, on...↓

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Comment From: BARBARA MESHANKO

1/10/24 @ 4:13 PM

PLEASE, PLEASE, PLEASE!!!! DO NOT DESTROY THE BEAUTY AND ENVIORNMENT OF OUR BEAUTIFUL SANTA RITA MOUNTAINS!!! THIS MINING INITIATIVE IS NOTHING BUT A MONEY GRAB AND WILL DO SO MUCH DAMAGE TO OUR WONDERFUL WILDLIFE. HAVE YOU NO HEART AT ALL???!!!

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Comment From: Greg Kesselring

1/10/24 @ 4:12 PM

South32 seeks to develop a new underground mine known as the Hermosa project. But to operate, the area first has to be pumped dry. This would lower groundwater levels around the mine by an estimated 1,900 feet and harm HUNDREDS of springs fed by that...↓

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Comment From: peg kazda

1/10/24 @ 4:09 PM

i firmly oppose the azpdes permit # AZ0026387 for the january mine hermosa project. the extreme lowering of groundwater would wreak havoc on the the hundreds of springs that nourish the land and animals in the region and beyond. the depletion of t...↓

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Comment From: mary ellen kazda

1/10/24 @ 4:03 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.

I don't live in Patagonia however during my lifetime in Ariz...↓

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Comment From: Roger Baron

1/10/24 @ 3:54 PM

I urge all new or continuing mining to cease in this fragile environment.

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Comment From: David Wright

1/10/24 @ 3:53 PM

When I read that ADEQ is considering granting permits for foreign mining companies to squander millions and millions of gallons of AZ groundwater I had to check the calendar. No it's not April 1 already, it's still January.

You would actually all...↓

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Comment From: JAMES MADSON

1/10/24 @ 3:51 PM

To whom it may concern,

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 fo...↓

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Comment From: Dan Horton

1/10/24 @ 3:40 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: Deanna Horton

1/10/24 @ 3:40 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: James Notestine

1/10/24 @ 3:30 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. I lived in this area and know it and the history of mining th...↓

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Comment From: Andrea Ruygrok

1/10/24 @ 3:30 PM

I am very concerned about water tables and nature habitats. Doesn't make sense to allow foreign companies to do this in our backyard.

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Comment From: Diane Nowak

1/10/24 @ 3:29 PM

I urge you to oppose proposed AZPDES Permit No. AZ0026387. Our ground water is extremely precious here in AZ. This particular project requires that the well/aquifer be emptied to do this project. THIS IS INSANITY! Given our scare resources (esp water...↓

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Comment From: Olivia Fehlberg

1/10/24 @ 3:27 PM

South32 is actively pursuing the development of the Hermosa project, an ambitious underground mine. However, the commencement of operations hinges on the initial step of pumping the area dry, a move that could have severe consequences. The estimated ...↓

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Comment From: Chris Mason

1/10/24 @ 3:24 PM

I disagree strongly with the plan to allow South32 to develop a new underground mine known as the Hermosa project. The area first has to be pumped dry. This would lower groundwater levels around the mine by an estimated 1,900 feet and potentially har...↓

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Comment From: Michael Marek

1/10/24 @ 3:17 PM

Let's be smart and protect our state for future generations. You only get one bite of the apple on this one. Choose wisely.

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Comment From: Mark Coryell

1/10/24 @ 3:13 PM

I very, very strongly urge you to DENY THIS PERMIT.During a critical drought it is immoral and irresponsible to remove groundwater to satisfy a greedy corporate mining interest.We need to protect Arizona's groundwater for not only our residents but a...↓

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Comment From: Terri Engel

1/10/24 @ 3:12 PM

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Comment From: Ernie Edwards

1/10/24 @ 3:05 PM

Do you know that area expert, Floyd Gray, recently retired of USGS, recently completed a Sonoita Creek soil pollution analysis which was a part of a 2012 University Of Arizona thesis on metal accumulation in plants, showing that those metals originat...↓

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Comment From: Karen Lopez

1/10/24 @ 2:36 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: Terri Engel

1/10/24 @ 2:35 PM

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Comment From: Terri Engel

1/10/24 @ 2:27 PM

Please do not approve a permit for the Hermosa Project AZ0026387 I am very concerned about the environmental damage from this mine.

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Comment From: Beth Pirl

1/10/24 @ 1:36 PM

ADEQ has ample information showing that Outfall 002 is constructed in Upper Harshaw creek, NOT lower. Upper Harshaw is listed as impaired under the clean water act 303(d) list. Accordingly ADEQ must revise its TMDL before renewing the permit. Additio...↓

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Comment From: Julie Ruddy

1/10/24 @ 1:24 PM

I object to the proposed permit and request that AZPDES not approve it. My concerns are as follows:

1. I have visited the Patagonia area on a number of occasions. It is a unique and largely untouched desert landscape of immense beauty. It is un...↓

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Comment From: Daniel Tarmer

1/10/24 @ 12:58 PM

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Comment From: Jane Cox

1/10/24 @ 12:36 PM

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Comment From: Jeffrey kenney

1/10/24 @ 12:06 PM

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Comment From: Andrew Means

1/10/24 @ 10:55 AM

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Comment From: Keith Moheban

1/10/24 @ 10:07 AM

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Comment From: Jonathan White

1/10/24 @ 10:00 AM

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Comment From: Ryan Civic

1/10/24 @ 9:57 AM

I am Including Para's comments as part of my comments and pdf upload was created for me by paras legal team

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Comment From: Sharon Calvert

1/10/24 @ 9:55 AM

I have lived in Patagonia since 1995 and have worked as a Psychologist in Santa Cruz County for most of that time. In 1998 I purchased the one-acre property on which I reside, and which is located 500 yards from the Audubon Center on the Patagonia-S...↓

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Comment From: Michael Stabile

1/10/24 @ 9:25 AM

Once again AZDEQ is not looking at the effects this discharge might have on the environment and possibly on the Town of Patagonia. You are taking a natural stream and turning it into a man-made river. The system passes through highly mineralized rock...↓

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Comment From: Murphy Musick

1/10/24 @ 8:37 AM

I have copied the comments from a local group. These comments represent my understanding and concerns about the proposed Hermosa Mine project. Without proper State oversite this project poses a threat to a very large area of Santa Cruz County, Arizon...↓

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Comment From: Gary Townsend

1/10/24 @ 8:27 AM

Summary of Proposed Comments to ADEQ On Proposed Renewal of AZPDES

Discharge Permit No. AZ0026387 to South32 Hermosa, Inc.

The Patagonia Area Resource Alliance (PARA) objects to the proposal from Arizona
Department of Environmental Quality (ADEQ) t...↓

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Comment From: Cholla Rose Duir

1/10/24 @ 8:25 AM

As a concerned local home owner I request that the attached comments be addressed. Patagonia is a small town and does not have the resources to fix mistakes made by large industrial operations. You can hardly get a contractor to fix a broken pipe let...↓

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Comment From: Charles Conner

1/10/24 @ 7:52 AM

All mining in the proposed area should not be allowed, especially by foreign companies. The value of this area's natural environment far outweighs destructive extractive activities that will forever scar the landscape. Thank you for doing the right ...↓

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Comment From: Carl Schmidlapp

1/10/24 @ 7:44 AM

Don't you realize There is no water to spare here, water levels dropping every year, more drought every year.
6 million gallons a year for the mine
FORGET IT. REFUSE TO ISSUE PERMIT future operations.

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Comment From: Terri Williams

1/10/24 @ 6:12 AM

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Comment From: Anastasia Rabin

1/10/24 @ 5:37 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 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.

The beauty and ecological importance of Arizona’s remaining intact natural areas is far more valuable and important than anything this mine will produce, be it jobs, mineral wealth, or revenue. It is time for our state to adopt sane water policies that will protect what remains of this critical and very strained resource. Arizona needs to change the way that water is valued and used or we will simply squander what is left and permanently destroy what remains of our iconic landscapes and enviable quality of life.

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

Sincerely,

Anastasia Rabin

Elfrida, AZ

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Comment From: Margaret Wilch

1/09/24 @ 10:43 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. I moved to Arizona nearly 40 years ago, drawn here by the incredible biod...↓iversity and wild beauty of the Sonoran desert and the sky islands. I spent my career as a biology and environmental science educator. My life’s passion has been to explore, appreciate and understand our natural environment and to share that passion with future generations. As such, I strongly oppose the mining operation proposed by South32.

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,

Margaret Wilch

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Comment From: Barbara Taylor

1/09/24 @ 4:01 PM

Dear Arizona Department of Environmental Quality,

This matter is extremely important to the future of our state. I’m writing to urge you to deny South32’s Hermosa permit (#AZ0026387) for discharge of mine water into Harshaw and Alum creeks. The propos...↓ed 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. We should not be altering and / or displacing water in this era of drought and water shortages!

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.

Please stop to consider the many harmful impacts that this project would bring upon our beautiful state. 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: Donna Hutchinson-Muri

1/09/24 @ 3:33 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.

Having spent much time hiking and investigating on my own these areas I am certain without any doubt or hesitation, that the Hermosa Project will continue to rape the ecology of the Patagonia mountains and surrounding life in all forms. The destruction of plant life due to grading new and existing roadways, the abundant use of water to control dust and supply the "projects" so called exploratory mining goals will not only contaminate the underground waters, it will also inevitably result in extreme loss of needed habitat springs and seeps. WATER is precious in our deserts, it is more precious than what potentially could be mined. The Patagonia area is a haven for wildlife due to the existence of water. People come from all over the world to view over 200 species of birds alone! It is past time that mankind take into account greedy actions that impact other creatures survival. The Hermosa Project is an example of such greed. I sincerely hope that AZ Dept of Environmental quality will live up to the name and reject this permit and any others that may follow. Use your conscience when making decisions.

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

Sincerely,

Donna Hutchinson-Muri

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Comment From: Elizabeth Bruckheimer

1/09/24 @ 12:12 PM

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Comment From: Philip Clevinger

1/09/24 @ 12:01 PM

Dear Arizona Department of Environmental Quality,

My name is Phil Clevinger, and I’m writing to urge you to deny South32’s Hermosa permit (#AZ0026387) for discharge of mine water into Harshaw and Alum creeks. I visit the region frequently and it canno...↓t recover from any of the activities that would be brought to pass for this mine. 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,

Phil Clevinger

Biologist, WSP Environmental

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Comment From: Cynthia Krakowski

1/09/24 @ 11:05 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. My husband and I spend time birding and recreating in the Patagonia area...↓ weekly. We enjoy viewing the plant and animals that inhabit this region and do not want to see the destruction of the natural ecosystem. 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: Sharon Segal

1/09/24 @ 9:50 AM

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Comment From: Peter Segal

1/09/24 @ 9:47 AM

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Comment From: Susan Silverman

1/09/24 @ 9:45 AM

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Comment From: Karen Martin

1/09/24 @ 8:41 AM

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Comment From: Nicholas LaBelle

1/09/24 @ 6:45 AM

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Comment From: Jessica Lackey

1/09/24 @ 5:15 AM

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Comment From: Christine Jimenez

1/09/24 @ 2:12 AM

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Comment From: Rachel DeLozier

1/08/24 @ 10:11 PM

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Comment From: Kenneth Bader

1/08/24 @ 9:41 PM

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Comment From: Victor Ong

1/08/24 @ 9:31 PM

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Comment From: Beth Johannessen

1/08/24 @ 8:38 PM

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Comment From: Marcia Lincoln

1/08/24 @ 8:33 PM

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Comment From: Skylar Benedict

1/08/24 @ 7:40 PM

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Comment From: Jeff vinosky

1/08/24 @ 6:38 PM

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Comment From: Katerina Sacoman

1/08/24 @ 6:32 PM

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Comment From: Ellen Bledsoe

1/08/24 @ 5:16 PM

Dear Arizona Department of Environmental Quality,

As an ecologist with the University of Arizona"s School of Natural Resources and the Environment, 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: Suvi Birch

1/08/24 @ 4:12 PM

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Comment From: Jaemin Wilson

1/08/24 @ 3:43 PM

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Comment From: William McDowell

1/08/24 @ 3:29 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 lower Harshaw and Alum Gulch. The proposed impacts are ecologically and socially unacceptable and ...↓fall into three 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, and 3) potential contamination of downstream water bodies.

First, pumping to drop the groundwater level to facilitate mining will change the ecology of these watersheds. In a semi-arid woodland watershed area this would be highly destructive. Drying out the shallow aquifers in these watersheds will alter the natural vegetation as native plants, including large trees, experience long-term drying of their deep root zones, potentially causing significant die-off of the native woodland tree species. This has occurred in the Tucson area over the past five decades (my lifetime).

Second, the large quantities of continuous discharge of groundwater into these two streams will alter the sediment balance of these streams, causing damaging increased sedimentation of the lower areas of these two watersheds. This will be particularly true during rainstorm runoff, since the mine discharge water will fill the absorption capacity of the stream channels, propelling much higher stormwater flows further down the watershed towards Sonoita Creek, potentially downcutting the stream channel and eventually increasing sedimentation of the lower Harshaw Creek watershed.

Third, the high levels of mine discharge water (up to 6 million gallons of water per day in lower Harshaw Creek and up to 172,000 gallons per day down Alum (Gulch) Creek) will transform lower Harshaw Creek into a perennial stream, with storm flows entering Sonoita Creek, just 5 miles away, much more frequently. As these periodic combined mine discharge/ stormflows will have higher metals concentrations than existing, water quality damage downstream could be severe. Copper is exceedingly toxic to fish, and several rare and endangered fish species exist in Sonoita Creek, a treasured local resource which feeds Patagonia Lake State Park and Natural Area. Cadmium, lead, and zinc have toxic properties for mammals, including humans. These discharges and increased sediment loads also will damage seven rheocrene seeps and springs known in Harshaw Creek and the nine rheocrene seeps and springs known in Alum Creek.

Water quality results of proposed groundwater pumping, hardrock mining, and mine waste water treatment systems are difficult to accurately predict. If actual results of water treatment do not meet the whole effluent toxicity (WET) tests or other effluent standards, it is typically quite difficult to remedy this situation by developing new treatment methods once mine operation is underway. Once money is invested and new employees are hired for new mine operation, social and political pressures on State agencies make it difficult to force modification of proposed treatment systems to meet the real world situation.

Finally, the Patagonia Mountains/Sonoita Creek area is very important to Arizona for both recreation and ecological reasons. Tens of thousands of people come to this area every year to enjoy the natural environment, wildlife, state parks, and other natural features. Opening a huge new mine in the middle of this area is highly risky to existing economy and ecology of the area.

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

Sincerely,

William McDowell

8150 East Broadway Unit H108

Tucson, AZ 85710

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Comment From: Tom Warhol

1/08/24 @ 3:26 PM

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Comment From: Larissa Villeburn

1/08/24 @ 2:40 PM

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Comment From: Victoria Infante

1/08/24 @ 2:18 PM

Dear Arizona Department of Environmental Quality,

This letter details extremely important concerns regarding the proposed mine permit and allowing it would result in irreversible damage to the surrounding environment. I urge you to deny South32’s Herm...↓osa 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: Matthew Wood

1/08/24 @ 2:06 PM

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Comment From: Veronica Vasquez

1/08/24 @ 2:02 PM

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Comment From: Jacob Thompson

1/08/24 @ 1:59 PM

Dear Arizona Department of Environmental Quality,

Sponsoring the destruction of delicate, unique, and protected areas is a foolish and short sided choice. The town of Patagonia is a flourishing center that doesn’t need “boosts in the economy” or at le...↓ast not the one provided by this mining operation. In the long term the continued success of the natural ecosystem will determine OUR success. Additionally, continued access to clean water should be regarded as a human right, and no company or corporation should be tended to before the general public. I understand the demand for precious metals and minerals but possibly we can make advancements in repurposing/recycling older materials, maybe electronic buy back programs, or other lass consumptive methods of resource extraction can be invested in rather than tearing this entire mountain down and destroying the Harshaw creek drainage.

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: Luke Thompson

1/08/24 @ 1:55 PM

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Comment From: Mark Thompson

1/08/24 @ 1:49 PM

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Comment From: Kendyl Thompson

1/08/24 @ 1:43 PM

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Comment From: Patricia Isaacson

1/08/24 @ 1:22 PM

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Comment From: Chris Parsons

1/08/24 @ 1:10 PM

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Comment From: Geoff Wyszynski

1/08/24 @ 1:10 PM

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Comment From: Brian Jones

1/08/24 @ 1:09 PM

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Comment From: Sky Jacobs

1/08/24 @ 1:07 PM

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Comment From: Alina Martin

1/08/24 @ 12:55 PM

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Comment From: Sheri Williamson

1/08/24 @ 12:53 PM

Dear Arizona Department of Environmental Quality,

I am 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 such as cottonwoods and sycamores, changing the vegetation structure on which many wildlife species depend. 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: Caleb Strand

1/08/24 @ 12:36 PM

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Comment From: Cassidy Lee

1/08/24 @ 12:29 PM

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Comment From: Eric Hough

1/08/24 @ 12:19 PM

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Comment From: David Sarich

1/08/24 @ 12:15 PM

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Comment From: Aleesa Palmer

1/08/24 @ 11:51 AM

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Comment From: troy mckaskle

1/08/24 @ 8:50 AM

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Comment From: Joan Patch

1/08/24 @ 8:34 AM

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Comment From: Dani Hawle

1/08/24 @ 8:30 AM

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Comment From: Pamela Pelletier

1/08/24 @ 7:47 AM

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Comment From: Belinda Norby

1/08/24 @ 7:40 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 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.

In addition to the scientific reasons, the Patagonia mountains are one of the places I recreate. I want to be able to hike and gravel ride in a scenic area.

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

Sincerely,

Belinda Norby

Tucson, AZ

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Comment From: Rhianyon Larson

1/08/24 @ 7:29 AM

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Comment From: Joan Hall

1/08/24 @ 7:23 AM

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Comment From: Logan Miller

1/08/24 @ 7:22 AM

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Comment From: Koren Sherrick

1/08/24 @ 7:15 AM

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Comment From: Dana Orozco

1/08/24 @ 7:08 AM

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Comment From: Regina Gillis

1/08/24 @ 7:01 AM

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Comment From: Jennifer MacMilhol

1/08/24 @ 12:00 AM

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Comment From: Anthony Avila

1/07/24 @ 4:32 PM

Dear Arizona Department of Environmental Quality,

I, a Pima County lifelong resident, am 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,

Anthony Avila

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