Proposed AZPDES Permit No. AZ0026387 for January Mine Hermosa Project

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Comment From: Scott Warren

1/07/24 @ 12:46 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, scott warren

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Comment From: James Nolan

1/07/24 @ 9:17 AM

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Comment From: Jon Prochera

1/06/24 @ 11:46 AM

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Comment From: Jonathan Prochera

1/06/24 @ 11:45 AM

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Comment From: Pamela Pesqueira

1/06/24 @ 8:39 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. We already have problems with water from Santa Cruz River! This will only exacerbate the current water issues if this is not correctly monitored!

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: Heather Raftery

1/06/24 @ 8:33 AM

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Comment From: Anthony Ford

1/05/24 @ 5:03 AM

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Comment From: Jimmy Gribbin

1/04/24 @ 4:16 PM

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Comment From: RICHARD B. JR. ENSIGN

1/04/24 @ 2:59 AM

Allowing the mine to release 6,000,000 gallons per day of waste water into the Sonoita Creek water-
shed would seriously threaten the amount and quality of the water supply for the Town of Patagonia.
I own 42 Town lots and 39 acres of land in the P...↓

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Comment From: peter Bodnaruk

1/03/24 @ 2:05 PM

Dear Arizona Department of Environmental Quality,

By now you've heard the following to which I also wish to say we agree with. Please deny the Hermosa mine permit which would harm Patagonia. Such mining practices have done irreparable harm & everyon...↓e living in or near Patagonia would suffer the consequences while a foreign owned company does the damages.

I'm writing to urge you to deny South32's Hermosa permit renewal (#AZ0026387) for discharging pumped aquifer "waste" water into Harshaw and Alum creeks. The possible impacts are unacceptable and fall under two main categories:

1. dewatering due to aquifer pumping, and

2. chemical and physical disturbances due to increased flow rates in Harshaw and Alum creeks.

First, reducing the water table level in these mountains will deny numerous seeps, springs, and livestock tanks of their water supply. The change in hydraulic gradients around the mine will very likely change the "paths of least resistance," where current springs emerge, permanently drying natural water sources. Such sources of water that provide rare and essential habitat for various imperiled species, including the Mexican Jaguar, are irreplaceable and already threatened by a changing climate. Furthermore, tens of thousands of acres of livestock rangeland will very likely be severely impacted as groundwater fed livestock tanks are dried.

Expected harms from water discharges are also deeply concerning. Up to 6.5 million gallons of water per day will be dumped into Harshaw Creek and up to 172,000 gallons per day into Alum Creek. Such large volumes will far exceed the usual intermittent, and base flows in these creeks, and will even surpass Sonoita Creek's flow rate by over three times. This could result in significant consequences, including severe upstream erosion, excessive downstream sedimentation, and the potential burial of vital water sources. Including notably, seven rheocrene seeps/springs in Harshaw Creek and nine in Alum Creek. The concern is heightened due to the unique and biodiverse nature of the areas immediately surrounding springs. Estimates propose that these refuge-like areas may harbor more than 20% of endangered and threatened species in the area, a remarkable statistic given their relatively small land surface area, as indicated by the Springs Stewardship Institute. Such large volumes of water introduced into these creeks will lead to reduced tree recruitment for riparian species like cottonwoods and sycamores � over time, significantly changing both the landscape, and its species composition.

Further, Because the water discharges are continuous, the affected landscape will become water-logged, meaning a reduced capacity for soils and sediments in arroyos to absorb high volumes of water in heavy rain events, making downstream flash flooding more intense and less predictable; significantly increasing the danger to residents, property, and public infrastructure during storms.

Additionally, high rates of flow could liberate and transport high volumes of numerous toxic heavy metals extant within the sediments of both Lower Harshaw and Alum creek, a remnant of legacy acid mine drainage resulting from two generations of under-regulated mining practices. It has been well documented that both creeks are severely impaired as demonstrated in the 2012 University of Arizona thesis "Bioaccumulation of Heavy Metals from Soils to Plants in Watersheds Contaminated by Acid Mine Drainage in SE Arizona, Katherine Eddleman" wherein for example, soil samples from Lower Harshaw creek were determined to be "anomalously high

in arsenic (97.2 ppm) and lead (919.5 ppm)" (Eddleman, 2012). These numbers are alarming, especially when taken with the very real probability of such contaminants being transported by south32 Hermosa discharge into the groundwater basin from which Patagonia wells pull for residential use. Not to mention the introduction of this contaminated water into the federally recognized impaired surface waterway that is Sonoita creek. The Arizona Department of Environmental Quality seems to be either unaware or unconcerned with these threats, as past versions of both the National Pollutant Discharge Elimination System and Aquifer Protection Permits only name a single actual point of compliance 200 feet downstream of the outfall. I argue that South32 aims to use Harshaw creek and Alum creek as natural pipes to discharge their water, and that the true point of discharge is not where they release it from their plant, but where it comes into contact with the vital waters of Sonoita creek and Patagonia municipal sources.

At the very least, ADEQ must create additional points of compliance and require South32 to fund continual remediation of these contaminated creek beds if they seek to pump water into them, which endangers not only the health of the delicate riparian ecosystem, but also the residents of Patagonia, and visitors to the area who enjoy the drinking water, recreation, and fish that would be made hazardous if you choose to do nothing.

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

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Comment From: Deborah Ensign

1/03/24 @ 2:01 PM

Dear Arizona Department of Environmental Quality,

I'm writing to urge you to deny South32's Hermosa permit renewal (#AZ0026387) for discharging pumped aquifer "waste" water into Harshaw and Alum creeks. The possible impacts are unacceptable and fall...↓ under two main categories:

1. dewatering due to aquifer pumping, and
2. chemical and physical disturbances due to increased flow rates in Harshaw and Alum creeks.

First, reducing the water table level in these mountains will deny numerous seeps, springs, and livestock tanks of their water supply. The change in hydraulic gradients around the mine will very likely change the "paths of least resistance," where current springs emerge, permanently drying natural water sources. Such sources of water that provide rare and essential habitat for various imperiled species, including the Mexican Jaguar, are irreplaceable and already threatened by a changing climate. Furthermore, tens of thousands of acres of livestock rangeland will very likely be severely impacted as groundwater fed livestock tanks are dried.

Expected harms from water discharges are also deeply concerning. Up to 6.5 million gallons of water per day will be dumped into Harshaw Creek and up to 172,000 gallons per day into Alum Creek. Such large volumes will far exceed the usual intermittent, and base flows in these creeks, and will even surpass Sonoita Creek's flow rate by over three times. This could result in significant consequences, including severe upstream erosion, excessive downstream sedimentation, and the potential burial of vital water sources. Including notably, seven rheocrene seeps/springs in Harshaw Creek and nine in Alum Creek. The concern is heightened due to the unique and biodiverse nature of the areas immediately surrounding springs. Estimates propose that these refuge-like areas may harbor more than 20% of endangered and threatened species in the area, a remarkable statistic given their relatively small land surface area, as indicated by the Springs Stewardship Institute. Such large volumes of water introduced into these creeks will lead to reduced tree recruitment for riparian species like cottonwoods and sycamores � over time, significantly changing both the landscape, and its species composition.

Further, Because the water discharges are continuous, the affected landscape will become water-logged, meaning a reduced capacity for soils and sediments in arroyos to absorb high volumes of water in heavy rain events, making downstream flash flooding more intense and less predictable; significantly increasing the danger to residents, property, and public infrastructure during storms.

Additionally, high rates of flow could liberate and transport high volumes of numerous toxic heavy metals extant within the sediments of both Lower Harshaw and Alum creek, a remnant of legacy acid mine drainage resulting from two generations of under-regulated mining practices. It has been well documented that both creeks are severely impaired as demonstrated in the 2012 University of Arizona thesis "Bioaccumulation of Heavy Metals from Soils to Plants in Watersheds Contaminated by Acid Mine Drainage in SE Arizona, Katherine Eddleman" wherein for example, soil samples from Lower Harshaw creek were determined to be "anomalously high in arsenic (97.2 ppm) and lead (919.5 ppm)" (Eddleman, 2012). These numbers are alarming, especially when taken with the very real probability of such contaminants being transported by south32 Hermosa discharge into the groundwater basin from which Patagonia wells pull for residential use. Not to mention the introduction of this contaminated water into the federally recognized impaired surface waterway that is Sonoita creek. The Arizona Department of Environmental Quality seems to be either unaware or unconcerned with these threats, as past versions of both the National Pollutant Discharge Elimination System and Aquifer Protection Permits only name a single actual point of compliance 200 feet downstream of the outfall. I argue that South32 aims to use Harshaw creek and Alum creek as natural pipes to discharge their water, and that the true point of discharge is not where they release it from their plant, but where it comes into contact with the vital waters of Sonoita creek and Patagonia municipal sources.

At the very least, ADEQ must create additional points of compliance and require South32 to fund continual remediation of these contaminated creek beds if they seek to pump water into them, which endangers not only the health of the delicate riparian ecosystem, but also the residents of Patagonia, and visitors to the area who enjoy the drinking water, recreation, and fish that would be made hazardous if you choose to do nothing.

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

Sincerely, Deborah Ensign

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Comment From: Diane Ensign

1/03/24 @ 1:30 PM

Our family owns property in Patagonia & we know it's critical to deny the Mine Hermosa Permit No. AZ0026387. It would absolutely harm the Patagonia area as 1 of Az. sky island regions that is 1 of the most biodiverse on our planet. Within our Patagon...↓

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Comment From: Carolyn Bergkuist

1/03/24 @ 12:54 PM

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Comment From: Michelle Ceballos

1/03/24 @ 11:24 AM

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Comment From: Martha McKee

1/03/24 @ 10:51 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 proposal will destroy the ecosystem

as huge amounts of water cascade ...↓down these streambeds.

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. 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. Their destruction will affect endemic species to an unknown degree because the sites haven’t yet been adequately surveyed. Some estimates suggest thatareas 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: Derek Drabicki

1/03/24 @ 9:23 AM

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Comment From: Thomas prim

1/03/24 @ 2:36 AM

Dear Arizona Department of Environmental Quality,

If you don’t deny this, I will go out there with sophisticated technology and take readings on how there is proof. It’s ruining the environment that technology I have is really going to make the govern...↓ment really upset. It’s something I invented and I’m currently working on making a presentation about Its technology that can depict things without blood tests and pick up on the DNA of things, and even detect smells and tune into the subjectivity of things like as if a dam when it’s built affects the surrounding area, we can even learn how certain species of plants are entangled in and expressing themselves differently, and that

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: Ramon Manriquez

1/03/24 @ 12:18 AM

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Comment From: Stanley KEITH Cliver

1/02/24 @ 8:27 PM

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Comment From: Jeff Derickson

1/02/24 @ 7:46 PM

Please reject the mining permit due to the environmental damage that will be associated with it.

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Comment From: Emily Moddelmog

1/02/24 @ 6:42 PM

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Comment From: Matthew Mayer

1/02/24 @ 6:42 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.

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 current permit for this project.

Sincerely,

Matt Mayer

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Comment From: Ella Anderson

1/02/24 @ 5:18 PM

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Comment From: claire Anderson

1/02/24 @ 5:17 PM

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Comment From: Sarah Truebe

1/02/24 @ 4:16 PM

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Comment From: Donna Estridge

1/02/24 @ 12:09 PM

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Comment From: John Goraj

1/02/24 @ 11:24 AM

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Comment From: Beth Pirl

1/02/24 @ 10:05 AM

Dear Arizona Department of Environmental Quality,

I'm writing to request that you deny South32's Hermosa permit renewal (#AZ0026387) for discharging pumped aquifer "waste" water into Harshaw and Alum creeks. The possible impacts have potentially ser...↓

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Comment From: Jeanne Emmerson

1/02/24 @ 9:43 AM

Dear Arizona Department of Environmental Quality,

I'm writing to urge you to deny South32's Hermosa permit renewal (#AZ0026387) for discharging pumped aquifer "waste" water into Harshaw and Alum creeks. The possible impacts are unacceptable and fall...↓ under two main categories:

dewatering due to aquifer pumping, and
chemical and physical disturbances due to increased flow rates in Harshaw and Alum creeks.

First, reducing the water table level in these mountains will deny numerous seeps, springs, and livestock tanks of their water supply. The change in hydraulic gradients around the mine will very likely change the "paths of least resistance," where current springs emerge, permanently drying natural water sources. Such sources of water that provide rare and essential habitat for various imperiled species, including the Mexican Jaguar, are irreplaceable and already threatened by a changing climate. Furthermore, tens of thousands of acres of livestock rangeland will very likely be severely impacted as groundwater fed livestock tanks are dried.

Expected harms from water discharges are also deeply concerning. Up to 6.5 million gallons of water per day will be dumped into Harshaw Creek and up to 172,000 gallons per day into Alum Creek. Such large volumes will far exceed the usual intermittent, and base flows in these creeks, and will even surpass Sonoita Creek's flow rate by over three times. This could result in significant consequences, including severe upstream erosion, excessive downstream sedimentation, and the potential burial of vital water sources. Including notably, seven rheocrene seeps/springs in Harshaw Creek and nine in Alum Creek. The concern is heightened due to the unique and biodiverse nature of the areas immediately surrounding springs. Estimates propose that these refuge-like areas may harbor more than 20% of endangered and threatened species in the area, a remarkable statistic given their relatively small land surface area, as indicated by the Springs Stewardship Institute. Such large volumes of water introduced into these creeks will lead to reduced tree recruitment for riparian species like cottonwoods and sycamores � over time, significantly changing both the landscape, and its species composition.

Further, Because the water discharges are continuous, the affected landscape will become water-logged, meaning a reduced capacity for soils and sediments in arroyos to absorb high volumes of water in heavy rain events, making downstream flash flooding more intense and less predictable; significantly increasing the danger to residents, property, and public infrastructure during storms.

Additionally, high rates of flow could liberate and transport high volumes of numerous toxic heavy metals extant within the sediments of both Lower Harshaw and Alum creek, a remnant of legacy acid mine drainage resulting from two generations of under-regulated mining practices. It has been well documented that both creeks are severely impaired as demonstrated in the 2012 University of Arizona thesis "Bioaccumulation of Heavy Metals from Soils to Plants in Watersheds Contaminated by Acid Mine Drainage in SE Arizona, Katherine Eddleman" wherein for example, soil samples from Lower Harshaw creek were determined to be "anomalously high in arsenic (97.2 ppm) and lead (919.5 ppm)" (Eddleman, 2012). These numbers are alarming, especially when taken with the very real probability of such contaminants being transported by south32 Hermosa discharge into the groundwater basin from which Patagonia wells pull for residential use. Not to mention the introduction of this contaminated water into the federally recognized impaired surface waterway that is Sonoita creek. The Arizona Department of Environmental Quality seems to be either unaware or unconcerned with these threats, as past versions of both the National Pollutant Discharge Elimination System and Aquifer Protection Permits only name a single actual point of compliance 200 feet downstream of the outfall. I argue that South32 aims to use Harshaw creek and Alum creek as natural pipes to discharge their water, and that the true point of discharge is not where they release it from their plant, but where it comes into contact with the vital waters of Sonoita creek and Patagonia municipal sources.

At the very least, ADEQ must create additional points of compliance and require South32 to fund continual remediation of these contaminated creek beds if they seek to pump water into them, which endangers not only the health of the delicate riparian ecosystem, but also the residents of Patagonia, and visitors to the area who enjoy the drinking water, recreation, and fish that would be made hazardous if you choose to do nothing.

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

Sincerely,
Jeanne Emmerson
skylark827@gmail.com

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Comment From: Colin Guiley

1/02/24 @ 8:47 AM

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Comment From: Sarah Vance

1/02/24 @ 12:00 AM

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Comment From: Sandra Kight

1/01/24 @ 9:17 PM

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Comment From: Anna Welch

1/01/24 @ 6:17 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.

In the Kansas salt mines, the mined areas areas are accessed through the water level via elevator shafts so that the water stays where it belongs and is NOT pumped to the surface.

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

Sincerely,

Anna Welch

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Comment From: Joe Carr

1/01/24 @ 3:58 PM

Please turn down the mining permit. Thanks joe Carr visitor to you're state

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Comment From: Catherine Lipscomb

1/01/24 @ 3:13 PM

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Comment From: Daryl Ragan

1/01/24 @ 2:36 PM

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Comment From: Mary Sky Schoolcraft

1/01/24 @ 1:49 PM

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Comment From: Terri Engel

12/31/23 @ 5:36 PM

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Comment From: Pam Case

12/31/23 @ 3:16 PM

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Comment From: Susan Faubion

12/31/23 @ 2:53 PM

Dear Arizona Department of Environmental Quality,

I’m writing to beg you to deny South32’s Hermosa permit (#AZ0026387) for discharge of mine water into Harshaw and Alum creeks. The proposed impacts are devastating 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. This area is unique and pristine, it will be destroyed.

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: Christine Hogan

12/31/23 @ 2:17 PM

Dear Arizona Department of Environmental Quality,

This area is TEEMING with irreplaceable plants, birds, insects, reptiles, mamals and more. This area is necessary for wildlife to roam and have enough terrain to raise offspring and find food and wate...↓r. Water being our most precious resource! Please.

We are begging you to please stop the destruction of the beautiful and precious area.

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: Barbara Jones

12/31/23 @ 1:51 PM

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Comment From: Susen G. Sharkey

12/31/23 @ 1:46 PM

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Comment From: Sherrie Nixon

12/31/23 @ 1:42 PM

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Comment From: Lyvier Gonzales

12/31/23 @ 1:37 PM

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Comment From: Elsa Suarez

12/31/23 @ 1:35 PM

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Comment From: Efrain Leal

12/31/23 @ 1:34 PM

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Comment From: Ramón Manriquez

12/31/23 @ 1:33 PM

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Comment From: Efraín Leal

12/31/23 @ 1:31 PM

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Comment From: Carmen Suarez

12/31/23 @ 1:30 PM

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Comment From: Catherine Itule

12/31/23 @ 1:26 PM

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Comment From: Michael Ross

12/31/23 @ 9:46 AM

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Comment From: Steve DuBay

12/31/23 @ 8:16 AM

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Comment From: David Rossetter

12/31/23 @ 7:00 AM

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Comment From: Molly Molloy

12/30/23 @ 6:24 PM

Dear Arizona Department of Environmental Quality,

I was appalled to read that you are considering polluting the Harshaw and Alum creeks with mine water.

I am a birder, and have enjoyed hiking around there and watching birds, and enjoying the peaceful a...↓tmosphere. This special place must be protected - for the birds snd environment, and for people!

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.

Water is scarce and bird specie are dying every day!

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

Please do the right thing and deny this permit! Thank you.

Sincerely,

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Comment From: Mark Wentley

12/30/23 @ 2:13 PM

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Comment From: JM Waterman

12/30/23 @ 11:53 AM

Dear Arizona Department of Environmental Quality,

I lived in Southern AZ for over 40 years. Now retired, I still visit frequently, always hiking the canyons and riparian areas I came to treasure so much while I lived there.

I’m writing to urge you to d...↓eny 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: David Levene

12/30/23 @ 10:22 AM

Letters against issuing the mining permit. Grisel Levene. David Levene

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Comment From: Michael Ross

12/30/23 @ 9:18 AM

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Comment From: Jonathan Bailey

12/30/23 @ 8:51 AM

Dear Arizona Department of Environmental Quality,

I am writing as a concerned naturalist regarding the South32 Hermosa permit renewal (#AZ0026387) and think such a permit should be denied.

Groundwater is critical for the unique habitats of the Pat...↓agonia Mountains. As a once tropic-like environment warmed, many species isolated in sky islands like the Patagonias, creating a "tide pool" of diversity. In some instances, these plants and animals have been isolated long enough to evolve into genetically distinct species found nowhere else on earth, such as Vaejovis patagonia. In addition, these refugium will prove necessary once again as human-caused climate change encourages migration into higher elevations.

Extant species in the region could be extirpated if the water table is reduced. This includes the Mexican jaguar and Mexican spotted owl as well as species from personal observations such as the rare Amsonia grandiflora—found in but a sliver of southern Arizona—or the critically imperiled Metastelma mexicanum and Cynanchum ligulatum or the federally listed Graptopetalum bartramii. We also identified the first population of Gaga arizonica in the Patagonia Mountains, found very rarely in just three sky islands (the Rincons, Huachucas, and now the Patagonia Mountains). This was the most robust population of G. arizonica documented by myself or my colleagues. Due to its close proximity to the mine, this remarkable and still poorly explored habitat would likely see significant impacts as a result of aquifer pumping.

In addition, changes in landscape, such as a loss of native species and/or an influx of invasives in consequence of disturbed habitat constitute a real and significant harm to local archaeological sites, which are reliant on context for proper interpretation, care, and management. These sites, eligible for inclusion under the National Register of Historic Places under Criterion C "[a historic property] that embodies the distinctive characteristics of a
type, period, or method of construction, or that represent the work of a master, or that possess high artistic values, or that represent a significant and distinguishable entity whose components may lack individual distinction" and/or Criterion D "[historic resources] that have yielded or
may be likely to yield, information important in history or prehistory" are often correlated with plants used for food, medicine, or ceremony. This, in addition to their placement on high, overlooking exposures associated with perennial water sources, makes them especially vulnerable to changes in ground water and viewshed degradation. It is worth noting that NRHP calls for the protection not just of archaeological and historical sites that are listed but those eligible for inclusion.

As a result, I think it would be appropriate to swiftly and decisively reject the permit.

Sincerely,

Jonathan Bailey

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Comment From: Natasha Watson

12/30/23 @ 8:43 AM

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Comment From: Martha McKee

12/30/23 @ 8:26 AM

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Comment From: Circle Z Ranch (Diana Nash)

12/30/23 @ 7:28 AM

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Comment From: Julie Gustafson

12/29/23 @ 7:00 PM

Dear Arizona Department of Environmental Quality,

Please deny South32’s Hermosa permit (#AZ0026387) for discharge of mine water into Harshaw and Alum creeks. The impacts are unacceptable amid the already unprecedented challenges to local wildlife as ...↓

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Comment From: Richard Krueger

12/29/23 @ 6:41 PM

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Comment From: Paulo Quadri

12/29/23 @ 6:36 PM

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Comment From: Michael Ross

12/29/23 @ 6:04 PM

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Comment From: Michael Ross

12/29/23 @ 4:53 PM

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Comment From: Sandy Zelasko

12/29/23 @ 3:14 PM

Dear Arizona Department of Environmental Quality,

Protect Patagonia Springs and Creeks From Mining

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: Mel Preston

12/29/23 @ 12:54 PM

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Comment From: Verlyn Flieger

12/29/23 @ 11:48 AM

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Comment From: Paul Estridge

12/29/23 @ 10:06 AM

Dear Arizona Department of Environmental Quality,

As a person who visits Arizona multiple times each year and spends a lot of time in the area of concern on Sonoita Creek, I'm writing to urge you to deny South32's Hermosa permit renewal (#AZ0026387)...↓ for discharging pumped aquifer "waste" water into Harshaw and Alum creeks. The possible impacts are unacceptable and fall under two main categories:

dewatering due to aquifer pumping, and
chemical and physical disturbances due to increased flow rates in Harshaw and Alum creeks.

First, reducing the water table level in these mountains will deny numerous seeps, springs, and livestock tanks of their water supply. The change in hydraulic gradients around the mine will very likely change the "paths of least resistance," where current springs emerge, permanently drying natural water sources. Such sources of water that provide rare and essential habitat for various imperiled species, including the Mexican Jaguar, are irreplaceable and already threatened by a changing climate. Furthermore, tens of thousands of acres of livestock rangeland will very likely be severely impacted as groundwater fed livestock tanks are dried.

Expected harms from water discharges are also deeply concerning. Up to 6.5 million gallons of water per day will be dumped into Harshaw Creek and up to 172,000 gallons per day into Alum Creek. Such large volumes will far exceed the usual intermittent, and base flows in these creeks, and will even surpass Sonoita Creek's flow rate by over three times. This could result in significant consequences, including severe upstream erosion, excessive downstream sedimentation, and the potential burial of vital water sources. Including notably, seven rheocrene seeps/springs in Harshaw Creek and nine in Alum Creek. The concern is heightened due to the unique and biodiverse nature of the areas immediately surrounding springs. Estimates propose that these refuge-like areas may harbor more than 20% of endangered and threatened species in the area, a remarkable statistic given their relatively small land surface area, as indicated by the Springs Stewardship Institute. Such large volumes of water introduced into these creeks will lead to reduced tree recruitment for riparian species like cottonwoods and sycamores � over time, significantly changing both the landscape, and its species composition.

Further, Because the water discharges are continuous, the affected landscape will become water-logged, meaning a reduced capacity for soils and sediments in arroyos to absorb high volumes of water in heavy rain events, making downstream flash flooding more intense and less predictable; significantly increasing the danger to residents, property, and public infrastructure during storms.

Additionally, high rates of flow could liberate and transport high volumes of numerous toxic heavy metals extant within the sediments of both Lower Harshaw and Alum creek, a remnant of legacy acid mine drainage resulting from two generations of under-regulated mining practices. It has been well documented that both creeks are severely impaired as demonstrated in the 2012 University of Arizona thesis "Bioaccumulation of Heavy Metals from Soils to Plants in Watersheds Contaminated by Acid Mine Drainage in SE Arizona, Katherine Eddleman" wherein for example, soil samples from Lower Harshaw creek were determined to be "anomalously high in arsenic (97.2 ppm) and lead (919.5 ppm)" (Eddleman, 2012). These numbers are alarming, especially when taken with the very real probability of such contaminants being transported by south32 Hermosa discharge into the groundwater basin from which Patagonia wells pull for residential use. Not to mention the introduction of this contaminated water into the federally recognized impaired surface waterway that is Sonoita creek. The Arizona Department of Environmental Quality seems to be either unaware or unconcerned with these threats, as past versions of both the National Pollutant Discharge Elimination System and Aquifer Protection Permits only name a single actual point of compliance 200 feet downstream of the outfall. I argue that South32 aims to use Harshaw creek and Alum creek as natural pipes to discharge their water, and that the true point of discharge is not where they release it from their plant, but where it comes into contact with the vital waters of Sonoita creek and Patagonia municipal sources.

At the very least, ADEQ must create additional points of compliance and require South32 to fund continual remediation of these contaminated creek beds if they seek to pump water into them, which endangers not only the health of the delicate riparian ecosystem, but also the residents of Patagonia, and visitors to the area who enjoy the drinking water, recreation, and fish that would be made hazardous if you choose to do nothing.

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

Sincerely,

Paul Estridge

406 Highland Avenue
Roseville, CA 95678

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Comment From: James Graeter

12/29/23 @ 9:29 AM

I am opposed to approval of the Mining Permit for the Hermosa Project

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Comment From: Richard Spotts

12/29/23 @ 8:00 AM

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Comment From: Deborah Milillo

12/29/23 @ 7:31 AM

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Comment From: Michael Milillo

12/29/23 @ 7:30 AM

I respectfully request that AZDEQ reject the requested permit No. AZOO26387 for the January Hermosa Mine Project. The subject area is documented to contain multiple freshwater springs that help sustain wildlife. We are in a severe drought and can't...↓

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Comment From: Janet Rothers

12/29/23 @ 6:50 AM

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Comment From: Mike Baker

12/29/23 @ 6:43 AM

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Comment From: Linda Williams

12/29/23 @ 5:57 AM

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Comment From: John Moss

12/28/23 @ 7:12 PM

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Comment From: Frank Stieber

12/28/23 @ 4:10 PM

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Comment From: Dave Buckert

12/27/23 @ 2:04 PM

Dear Arizona Department of Environmental Quality,

My wife and I are residents of Rio Rico in Santa Cruz County and are very concerned about the negative environmental impacts of the Water Permit sought by South 32"s Hermosa Project.

I’m writing to urg...↓e 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,

David Buckert

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Comment From: Judy Buckert

12/27/23 @ 1:52 PM

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Comment From: Brian Howard

12/26/23 @ 4:59 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. It has the potential to create sink holes, crack foundations on homes, damage roadways, seriously affect wells and real estate values, and affect the livelihoods of those who rely on real estate for a living.

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,

Brian K. Howard

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Comment From: Tina Brubaker

12/26/23 @ 11:22 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.

We urge you and the Arizona Department of Environmental Quality to deny the permit for this project.

Sincerely,

Tina M Brubaker

and Carl M Decker

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Comment From: Sherrieaww Nixon

12/26/23 @ 10:35 AM

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Comment From: Jeff Smith

12/26/23 @ 10:17 AM

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Comment From: Cheyene Garcia

12/26/23 @ 9:35 AM

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Comment From: Fritz Sawyer

12/26/23 @ 6:39 AM

Please see attachment.

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Comment From: Charmeine Wait

12/25/23 @ 3:13 PM

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Comment From: Jeffrey Richardson

12/25/23 @ 12:07 PM

Dear Arizona Department of Environmental Quality,

As a frequent visitor to federal public lands in the Patagonia Mountains, I am shocked at the proposed groundwater pumping and related activities connected to the South32/Hermosa project. The notion th...↓

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Comment From: Karen Wiley

12/25/23 @ 8:25 AM

Dear Arizona Department of Environmental Quality,

As a frequent visitor to southern Arizona over the last 15 years, I have long had deep appreciation for the beauty and special nature of the Sky Islands including the area around Patagonia. From what I...↓’ve read, this project would permanently alter the landscape in that area. I think proceeding with this project would be very ill advised and irresponsible.

So, 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: Wolfgang Golser

12/25/23 @ 8:21 AM

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Comment From: Ozlem Erol

12/25/23 @ 7:28 AM

Hi,
Climate change and drought already cause water scarcity in Arizona. Arizona's nature is already struggling due the human caused climate change.
We are concerned the mining project by South32 will further harm the environment and the precious Pato...↓

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Comment From: Ceanne Alvine

12/24/23 @ 10:17 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.

The natural beauty of southern Arizona should be preserved for generations to come. Disruptive mining threatens all biodiversity in the area.

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

Sincerely,

Dr. Ceanne Alvine

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Comment From: John Schoen

12/24/23 @ 5:32 PM

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Comment From: Scott Olmstead

12/24/23 @ 2:34 PM

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Comment From: Roma Lamor

12/24/23 @ 2:00 PM

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Comment From: Reta Rutledge

12/24/23 @ 12:54 PM

Dear Arizona Department of Environmental Quality,

There are details below my comments if you need more convincing. We live in an arid landscape and all water is precious. Springs are a valuable source of water for people and wildlife. They must be pro...↓

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Comment From: Janey McLean

12/24/23 @ 12:20 PM

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