Copper World, Inc. - Air Permit

Comment From: Saba Bennett

7/25/24 @ 2:39 PM

Hudbay's air quality permit must be rejected because it fails to address a planned 500-acre toxic tailings pile that will blow dangerous clouds of lead and mercury directly at a school less than one mile away. The monitoring stations are too far apa...↓

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Comment From: Monica Fabre

7/25/24 @ 2:23 PM

My family and I are opposed to any permits the ADEQ could grant Copper World (Hudbay) to conduct mining activities so close to our community. There is no benefit associated with it to our community. We, the people in the surrounding area will only ...↓

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Comment From: Joshua Buell

7/25/24 @ 1:57 PM

I vehemently OPPOSE the current state of the air permit for Copper World. I live no more than 3 miles from where the proposed tailing pile will be placed. In the last year I have had an average of 7MPH winds with highs of 49MPH and gusts as high as 7...↓

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Comment From: Camille Gonzalez

7/25/24 @ 12:42 PM

Considering the amount of air pollution that would be created by the mine, I believe ADEQ should require a Class I permit for Hudbay, with stricter regulations that would help protect people and the environment from air pollution. The Santa Ritas, as...↓

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Comment From: Mary Barg

7/25/24 @ 3:27 AM

I believe Arizona Department of Environmental Quality should require a Class I permit for Hudbay, with stricter regulations that would help protect people and the environment from air pollution.

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Comment From: Francesca Ziemba

7/24/24 @ 1:03 PM

Please require Copper World to get a more stringent Class I Air Quality Permit.

Hudbay's current plan will produce significant, toxic air pollution that will negatively impact human health and the environment for its entire 44-year lifespan and lo...↓ng after. Here are a few facts for consideration as ADEQ adjudicates the permit:

1. Copper World, by its own admission, will produce miniscule toxic particulates less than 2.5 micrometers in diameter. In its own proposal, Hudbay says it will monitor and suppress these toxic particulates that might drift into Green Valley and Corona de Tucson. The area of consideration includes, for example, Copper Ridge Elementary (400 students and 50 staff), which is only 1 ¼ miles from the proposed tailings piles.

Recent scientific studies show that there is no safe threshold for humans breathing in these particulates. Smaller, more difficult to control particles may actually be more dangerous because they can be inhaled more deeply into the lungs. Adverse health effects include:

●Toxic effects from absorption of lead particulates into blood
●Toxic effects from absorption of zinc and other heavy metals
●Harmful respiratory effects, including aggravation of asthma. Risks are highest for the elderly and young children.

Source: "Economic Impact of the Copper World Economic Impact of the Copper World/Rosemont Mine Complex," June 2024, by Power Consulting. Available on the Save the Scenic Santa Ritas website at https://www/copperworldeconomics.com

2. The proposed mine and its related air pollution will destroy sensitive habitat in the northern Santa Rita Mountains, effectively eliminating the well-documented, periodic appearances of jaguars, an extremely rare and endangered species. The mine will also adversely affect mountain lion, bobcat, black bear, coati, ringtail, and other unique wildlife populations due to toxic dust, emissions, noise, blasting, and nighttime light. These animals' sense of smell is documented at hundreds or even thousands of times more powerful than a human's.

Sources: "Lack of a biological assessment as required in the governing legislation" in formal comments on the Draft Aquifer Protection Permit No. P-513690 (APP) for the Copper World Project in Arizona (ADEQ, 2024) and the APP application submitted by Save the Scenic Santa Ritas (SSSR) and the 13 other organizations and Tribal Nations on April 10, 2024: referencing material submitted by Chambers, Lacher, Maest, Hart, Headley, and Pima County.

Please, PLEASE impose common sense air quality requirements on Copper World. Please take into consideration the need to prevent lasting harm to the human beings living around the proposed mine and the fragility of our irreplaceable Santa Rita mountain environment. Thank you.

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Comment From: Wanda Poindexter

7/24/24 @ 11:46 AM

I and my family believe Arizona Department of Environmental Quality (ADEQ) should require a Class I permit for Hudbay's Copper World Air permit, with stricter regulations that would help protect people and the environment from air pollution.

Hudbay...↓

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Comment From: Nancy Phillips

7/24/24 @ 11:12 AM

I believe Arizona Department of Environmental Quality (ADEQ) should require a Class I permit for Hudbay, with stricter regulations that would help protect people and the environment from air pollution. Our local area and those surrounding will be aff...↓

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Comment From: Adele Youmans

7/24/24 @ 11:05 AM

Hudbay is requesting a Class II permit, which is not sufficient for protecting human health, considering the high level of air pollution that would be created by the mine. I believe Arizona Department of Environmental Quality (ADEQ) should require a ...↓

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Comment From: Marie-Christine Moody

7/24/24 @ 10:02 AM

I oppose the Hudbay Mineral Class II Air Permit. All permits should be paused to allow for full evaluation of use of In-situ extraction instead of destructive open-pit mining. In situ extraction, is where a leaching solution is injected underground...↓

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Comment From: J Lynette Libdan

7/24/24 @ 9:53 AM

I am opposed to any permits allowing mining activities and increased pollution that is near or will
affect the people and wildlife in the Santa Rita Mountains and their environs. Hudbay is requesting a Class II permit, which is not sufficient for pro...↓

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Comment From: Carol Boquard

7/24/24 @ 9:46 AM

I am very frustrated with AZDEQ! How can you say a new copper mine in Saurita will not impact residents? So many people are moving to AZ and the growth is phenomenal. It is imperative that you protect citizens from air pollution. The Copper mine need...↓

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Comment From: Aaron Carranza

7/24/24 @ 9:46 AM

I am opposed to any permits allowing mining activities and increased pollution that is near or will affect corona de tucson.

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Comment From: Anne Ryan

7/24/24 @ 9:21 AM

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Comment From: Jonathan Lutz

7/24/24 @ 9:02 AM

I am a bicycle commuter, hiker, and birder, which means I enjoy a significant outdoors in southern Arizona. The Santa Rita Mountains are one of my go-to destinations for outdoor recreation. I believe the Arizona Department of Environmental Quality (A...↓

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Comment From: Brandon Lloyd

7/24/24 @ 8:46 AM

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Comment From: Diane Marr

7/24/24 @ 8:40 AM

I strongly object to this Class 2 Air Pollution Permit being issued due to inadequate meteorological monitoring around the most affected populated areas, as well as the risk of introducing airborne contaminants to the air that almost 9,000 residents ...↓and surrounding communities breathe.

More research is needed to determine the potential for air contamination to the community due to the close proximity of the to the proposed mine site.

Specifically, there are two factors that could contribute to airborne contamination and require further study:

The nighttime inversion of the Sonoran desert consists of a layer of cooler air is trapped near the ground by a layer of warm air above the surface. This is visible from higher elevations and essentially traps dust and pollen in the air, triggering sensitive groups such as those with reactive airways, i.e. asthma or COPD patients. If airborne contaminants were introduced, they will effectively stay in the air and become a potential health threat to our community. It should be given special consideration that an elementary (Copper Ridge Elementary) is in close proximity to the mine site, and over 350 children will be breathing in contaminants from the copper mining process if this permit is approved.

The area surrounding the mine site exhibits notoriously strong gusts of wind, especially during Spring and monsoon seasons. I ask that ADEQ study a meteorological report for a more complete understanding of the winds affecting the Vail/Corona de Tucson area. Airborne contaminants from the proposed mine could easily be carried through thousands of homes, and most importantly thousands of students in the two elementary schools (Copper Ridge, Sycamore) and one middle school (Corona Foothills).

If approved without further scientific study, this Class 2 Air pollution Permit is a threat to the health and safety of our community. As a resident, I ask that ADEQ pay special attention to the current air quality concerns that residents of Patagonia AZ are facing with the South32 Hermosa mine, as well as the air quality hazards caused by the Freeport Sierrita Mine. The 2018 ADEQ violations against Freeport, resulting in $450,000 in penalties for Asarco $100,000 in fines and $350,000 in contributions toward county environmental projects should serve as a warning for us all.

Mining such as this should be carried out in less densely populated areas, certainly not where thousands of residents, many of whom are children, will be exposed to the contamination resulting from the mining process.

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Comment From: Pamela Duncan

7/24/24 @ 7:19 AM

Hudbay is requesting a Class II permit, which I believe is not sufficient for protecting human health, considering the high level of air pollution that would be created by the mine. I request that ADEQ require a Class I permit for Hudbay, with strict...↓

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Comment From: Michael Collins

7/24/24 @ 5:58 AM

I support this class II air permit application. This is appropriate for the project activities.

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Comment From: LINDA LANGER

7/24/24 @ 5:16 AM

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Comment From: Stephen Vaughan

7/24/24 @ 5:15 AM

Hudbay is requesting a Class II permit, which is not sufficient for protecting human health, considering the high level of air pollution that would be created by the mine. We believe Arizona Department of Environmental Quality (ADEQ) should require a...↓

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Comment From: Lynne Firestone

7/24/24 @ 3:53 AM

The Copper World permit must be rejected. We need clean air!

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Comment From: Deborah Drew

7/24/24 @ 1:31 AM

For the sake of our children, our elderly are immunocompromised please do not grant Copper World the permits needed to mine our Santa Rita mountains.

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Comment From: Tim Sautter

7/23/24 @ 8:48 PM

I strongly object to this Class 2 Air Pollution Permit being issued due to inadequate meteorological monitoring around the most affected populated areas, as well as the risk of introducing airborne contaminants to the air that almost 9,000 residents ...↓and surrounding communities breathe. More research is needed to determine the potential for air contamination to the community due to the close proximity of the to the proposed mine site. Specifically, there are two factors that could contribute to airborne contamination and require further study:

The nighttime inversion of the Sonoran desert consists of a layer of cooler air is trapped near the ground by a layer of warm air above the surface. This is visible from higher elevations and essentially traps dust and pollen in the air, triggering sensitive groups such as those with reactive airways, i.e. asthma or COPD patients. If airborne contaminants were introduced, they will effectively stay in the air and become a potential health threat to our community. It should be given special consideration that an elementary (Copper Ridge Elementary) is in close proximity to the mine site, and over 350 children will be breathing in contaminants from the copper mining process if this permit is approved.

The area surrounding the mine site exhibits notoriously strong gusts of wind, especially during Spring and monsoon seasons. I ask that ADEQ study a meteorological report for a more complete understanding of the winds affecting the Vail/Corona de Tucson area. Airborne contaminants from the proposed mine could easily be carried through thousands of homes, and most importantly thousands of students in the two elementary schools (Copper Ridge, Sycamore) and one middle school (Corona Foothills).

If approved without further scientific study, this Class 2 Air pollution Permit is a threat to the health and safety of our community. As a resident, I ask that ADEQ pay special attention to the current air quality concerns that residents of Patagonia AZ are facing with the South32 Hermosa mine, as well as the air quality hazards caused by the Freeport Sierrita Mine. The 2018 ADEQ violations against Freeport, resulting in $450,000 in penalties for Asarco $100,000 in fines and $350,000 in contributions toward county environmental projects should serve as a warning for us all.

Mining such as this should be carried out in less densely populated areas, certainly not where thousands of residents, many of whom are children, will be exposed to the contamination resulting from the mining process.

As a resident of Corona de Tucson, I object to this permit in its entirety.

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Comment From: Emilio Dash

7/23/24 @ 4:44 PM

As a member of this area amd community. I do not want or support Copper World's operations. The air quality emissions is underestimated.

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Comment From: Lewis Nagler

7/23/24 @ 10:06 AM

Copper World Air Permit
1. It is not clear what type if any copper processing such as smelting will be done onsite. I understand an analysis might be required if primary copper smelting, and or secondary copper smelting is done on site.. If onsite ...↓

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Comment From: eleanor kohloss

7/23/24 @ 9:55 AM

"For the sake of our children, our elderly, and everyone else, please require Copper World to get a more stringent Class I Permit." You can cut and paste all the comments below and enter them into the Arizona record. They are factual and generated f...↓rom an in-depth analysis of air quality risks by SSSR.
Talking Points:
• The proposed mine will create mounds of tailings dust hundreds of feet high near schools and residences. Studies worldwide show that such tailings often contain toxins like lead and arsenic and typically blow 20 to 30 miles in dry and windy conditions like those near Tucson. Prevailing winds are from the west, but daily wind changes will blow toxics from east to west toward Green Valley, Sahuarita, Corona de Tucson, and all the housing developments southeast of Sahuarita. An example of dust in the air can be seen almost every morning from Green Valley when vehicles on Santa Rita Road raise dust clouds that drift across the Santa Rita Experimental Range.
Source: "Economic Impact of the Copper World Economic Impact of the Copper World/Rosemont Mine Complex," June 2024, by Power Consulting. Available on the Save the Scenic Santa Ritas website at https://www/copperworldeconomics.com
● Students at one school in particular, Copper Ridge Elementary (400 students and 50 staff), will be at risk from particulates that will drift into their area from the Copper World tailings piles 1 ¼ miles from the school grounds. Recent studies of tiny particulates from mines (dust and haze) show that there is virtually no safe level of exposure for young children – the smaller the particulates, the more likely children will inhale them deeply into their lungs. At the very least, Copper Ridge School (and other schools in Corona de Tucson and Vail) will need to constantly monitor air quality, plan to protect students during emergency alerts, cancel outdoor activities when necessary, train school nurses to deal with respiratory ailments, and possibly cancel classes when risks are high.
Source: "There's a spike in respiratory illness among children — and it's not just COVID," Oct. 11, 2025, by Manuela Restrepo, National Public Radio
● Copper World Mine will produce minuscule particulate matter less than 2.5 micrometers in diameter. This will be perceived as dust, inhalable particles, or haze between the mountains and Sahuarita. No one disputes this. In its plans, Copper World says it will monitor and suppress minuscule toxic particulates that might drift into Green Valley and Corona de Tucson homes and schools. However, recent scientific studies show no safe "threshold" for such particulates. Adverse health effects will include:
● toxic effects from absorption of lead particulates into blood
● toxic effects from absorption of zinc and other heavy metals
● increasing respiratory symptoms, including the aggravation of asthma. Risks are highest for the elderly and young children.
Smaller, difficult-to-control particles may be more dangerous because they can be inhaled deeply into the lungs. The lifespan of the Copper World mine may last 40 years or longer. For people who live in the mine area, this will increase the likelihood of serious physical problems. Source: Australian Government's National Pollutant Inventory, 2023, online at
https://www.npi.gov.au/.../Particulate.../destination/ALL
● When the Copper World mine operation is established, heavy haul trucks loaded with harmful copper concentrates and possibly purified copper cathodes will almost certainly run constantly on the shortest route between the mine and the town of Sahuarita. Despite claims by Copper World that suppressed vehicle speeds and constant watering will keep down dust clouds on dirt roads, it is not realistic to think that particulates will be fully contained in the boxes of the trucks or that spillage will be prevented. Heavy metals can contaminate land for hundreds of years.
Source: "Economic Impact of the Copper World Economic Impact of the Copper World/Rosemont Mine Complex," June 2024, by Power Consulting. Available on the Save the Scenic Santa Ritas website at https://www/copperworldeconomics.com
● The proposed mine will drive away unique large animals in the northern Santa Rita Mountains – jaguar, mountain lion, bobcat, black bear, coati, ringtail, and more – because of toxic dust, emissions, noise, blasting, and nighttime light. These animals' sense of smell is documented as hundreds or even thousands of times more powerful than a human's. This part of the Sky Island mountain range has been their home for thousands of years, and in a relatively few years their habitat will be gone because of the haze of toxic particulates that will drift across their home range.
Sources: "Lack of a biological assessment as required in the governing legislation" in formal comments on the Draft Aquifer Protection Permit No. P-513690 (APP) for the Copper World Project in Arizona (ADEQ, 2024) and the APP application submitted by Save the Scenic Santa Ritas (SSSR) and the 13 other organizations and Tribal Nations on April 10, 2024: referencing material submitted by Chambers, Lacher, Maest, Hart, Headley, and Pima County.
● Residents of Pima County need to be aware of the enormous piles of leftover material in the proposed Copper World Mine's tailings. This waste material - perched on the mountains above Corona de Tucson and Vail - should not be considered "gravel" or "crushed rock." Much of it will be sand and dust particles that could escape the tailings piles or pipes and then spread toxins into the landscape between the Santa Rita Mountains and communities to the west, northwest, and north.
In any open-pit mine operation, tailings must have safeguards, such as dams and liners, to keep them in check. The Copper World Mine owners have already demonstrated a willingness to cut corners with necessary protections. Downstream residents, however, deserve state-of-the-art safeguards for tailings piles that will be hundreds of feet deep.
Traces of metals such as lead, cadmium, and zinc are especially dangerous when they become airborne or flushed out of tailings, working their way down washes during storms.
Green Valley, Sahuarita, and Vail are all about 20 miles from the proposed mine site.
Sources: Topics related to "Tailings Storage Facilities," in formal comments on the Draft Aquifer Protection Permit No. P-513690 (APP) for the Copper World Project in Arizona (ADEQ, 2024) and the APP application submitted by Save the Scenic Santa Ritas (SSSR) and the 13 other organizations and Tribal Nations on April 10, 2024: referencing material submitted by Chambers, Lacher, Maest, Hart, Headley, and Pima County. 1

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Comment From: Mark Johnson

7/23/24 @ 4:42 AM

I support the comments made in the 4/11/24 comment letter (attached) by the Center of Biological Diversity and the Coalition For Sonoran Desert Protection. The emissions from the World Copper-Santa Rita Mountain mine have been significantly underest...↓

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Comment From: Justina Cotter

7/22/24 @ 10:35 AM

There are many issues with regard to air quality for the proposed Copper World Project.

According to "Economic Impact of the Copper World Economic Impact of the Copper World/Rosemont Mine Complex," June 2024, by Power Consulting, the mounds of taili...↓ngs dust -- hundreds of feet high near schools and residences -- likely will contain toxics like lead and arsenic. This type of toxic dust typically blows 20-30 miles in the dry and windy conditions that we have in the Tucson area. Although prevailing winds are from the west, daily wind changes would blow toxics from east to west, toward Green Valley, Sahuarita, Corona de Tucson, and all the housing developments southeast of Sahuarita. As an example, dust in the air can be seen almost every morning from Green Valley, when vehicles on Santa Rita Road raise dust clouds that drift across the Santa Rita Experimental Range. Additionally, toxins can also be flushed out of tailings and start to work their way down washes during storms.

Copper World Mine would produce minuscule particulate matter less than 2.5 micrometers in diameter, indisputably resulting in dust, inhalable particles, and haze between the mountains and Sahuarita. In its plans, Copper World says it will monitor and suppress toxic particulates that might drift into Green Valley, and Corona de Tucson homes and schools. But recent scientific studies show that is no safe "threshold" at which humans who encounter this dust will be safe. Adverse health effects will include toxic effects from absorption of lead particulates, zinc, and other heavy metals into blood and increasing respiratory symptoms, including the aggravation of asthma. Risks are highest for the elderly and young children.
Smaller, more difficult to control particles may actually be more dangerous because they can be inhaled more deeply into the lungs. The lifespan of the Copper World mine may be 44 years or longer. For people who live in the mine area, this will increase the likelihood of serious physical problems.

Students at Copper Ridge Elementary (400 students and 50 staff), would particularly be at risk from particulates that will drift into their area from the Copper World tailings piles -- situated a mere 1 ¼ miles from the school grounds. The mine's presence would require Copper Ridge School (and other schools in Corona de Tucson and Vail) to maintain contingency plans for days with poor air quality; requiring ongoing monitoring of air quality and plans to protect students during emergency alerts, such as canceling outdoor activities, training school nurses to deal with respiratory ailments, and even canceling classes when risks are high.

Heavy haul trucks loaded with harmful copper concentrates and possibly purified copper cathodes will almost certainly run constantly on the shortest route between the mine and the town of Sahuarita. Despite claims by Copper World that suppressed vehicle speeds and constant watering will keep down dust clouds on the dirt roads, it is not realistic to think that particulates will be fully contained in the boxes of the trucks, that spillages will be fully prevented, and that adequate watering of dirt roads can eliminate airborne dust during an Arizona summer. Heavy meals can contaminate land for hundreds of years.

Pima County residents need to beware of the huge piles of leftover material in the proposed Copper World Mine's tailings. This waste material - perched on the mountains above Corona de Tucson and Vail - should not be considered "gravel" or even "crushed rock." Much of it will be sand and dust particles that could escape the tailings piles or pipes and then spread toxins into the landscape between the Santa Rita Mountains and communities to the west, northwest, and north.
In any open pit mine operation, tailings must have safeguards to hold them in check, such as dams and liners. The Copper World Mine owners have already demonstrated a willingness to cut corners with regard to necessary protections. Downstream residents, however, deserve current, even state-of-the-art safeguards for tailings piles that will be hundreds of feet deep.

Lastly, the proposed mine will drive away unique large animals in the northern Santa Rita Mountains – jaguar, mountain lion, bobcat, black bear, coati, ringtail, and more – because of toxic dust, emissions, noise, blasting, and nighttime light. These animals' sense of smell is documented at hundreds or even thousands of times more powerful than a human's. This part of the Sky Island mountain range has been their home for thousands of years, and in a relatively few yeas their habitat will be gone because of the haze of toxic particulates that will drift across their home range.

Thank you for your attention. Please do the right thing for Arizona communities and deny the air permit for the proposed Copper World Mine.

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Comment From: Tim Kosse

7/22/24 @ 10:16 AM

If this mine is to go through, it must be as a Class 1 Air permit. Arizonans already suffer from the smallest particles which are yet the most adverse to human health. Please don't let this private company externalize their costs, any more than a man...↓

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Comment From: Betty King

7/21/24 @ 4:19 PM

Please require Copper World to get a more stringent Class 1 Permit.

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Comment From: Clarence Chaplin

7/21/24 @ 10:38 AM

I am opposed to the Copper World mine in the Santa Ritas for many reasons, but my primary reasons for opposing the mine are the threats it will pose to our groundwater supply and the resulting air pollution that will effect neighboring communities an...↓

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Comment From: Emily Ravits

7/21/24 @ 10:37 AM

I am a resident of Tucson Arizona and am deeply opposed to the Copper World mine in the Santa Ritas . I appreciate that I have this opportunity to have my opinion valued.This mine will have long reaching impacts on air and water quality. It will wrec...↓

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Comment From: Laura Barnett

7/21/24 @ 10:19 AM

As an individual with breathing problems. I do NOT want nor approve of Copper World Inc polluting the air near my home where I should Feel safe

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Comment From: Holly Finstrom

7/21/24 @ 8:58 AM

NO AIR PERMIT SHOULD BE ISSUED FOR ANY POLLUTING INDUSTRY.

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Comment From: Aaron Flesch

7/20/24 @ 2:43 PM

Please require Copper World to get a more stringent Class I Permit.

1) This mine will create a great volume of tailings and dust hundreds of feet high near schools and residences. Tailings often contain toxins like lead and arsenic and typically...↓ blow 5-30 miles in dry and windy conditions like those near the mine. Winds are from the west, but daily wind changes will blow toxics from east to west toward Green Valley, Sahuarita, Corona de Tucson, and housing developments southeast of Sahuarita. An example of dust in the air can be seen almost every morning from Green Valley when vehicles on Santa Rita Road raise dust clouds that drift across the Santa Rita Experimental Range.

2) Students at Copper Ridge Elementary will be at risk from particulates that will drift into their area from the Copper World tailings piles just ~1 mile from the school grounds. Recent studies of tiny particulates from mines (dust and haze) show that there is virtually no safe level of exposure for young children – the smaller the particulates, the more likely children will inhale them deeply into their lungs. At the very least, Copper Ridge School (and other schools in Corona de Tucson and Vail) will need to constantly monitor air quality, plan to protect students during emergency alerts, cancel outdoor activities when necessary, train school nurses to deal with respiratory ailments, and possibly cancel classes when risks are high.

3) Copper World Mine will produce minuscule particulate matter less than 2.5 micrometers in diameter. This will be perceived as dust, inhalable particles, or haze between the mountains and Sahuarita. No one disputes this. In its plans, Copper World says it will monitor and suppress minuscule toxic particulates that might drift into Green Valley and Corona de Tucson homes and schools. However, recent scientific studies show no safe "threshold" for such particulates. Adverse health effects will include toxic effects from absorption of lead particulates into blood, toxic effects from absorption of zinc and other heavy metals, increasing respiratory symptoms, including the aggravation of asthma. Risks are highest for the elderly and young children. Smaller, difficult-to-control particles may be more dangerous because they can be inhaled deeply into the lungs. The lifespan of the Copper World mine may last 40 years or longer. For people who live in the mine area, this will increase the likelihood of serious physical problems.

4) When the Copper World mine operation is established, heavy haul trucks loaded with harmful copper concentrates and possibly purified copper cathodes will almost certainly run constantly on the shortest route between the mine and the town of Sahuarita. Despite claims by Copper World that suppressed vehicle speeds and constant watering will keep down dust clouds on dirt roads, it is not realistic to think that particulates will be fully contained in the boxes of the trucks or that spillage will be prevented. Heavy metals can contaminate land for hundreds of years.

5) The proposed mine will drive away unique large animals in the northern Santa Rita Mountains – jaguar, mountain lion, bobcat, black bear, coati, ringtail, and more – because of toxic dust, emissions, noise, blasting, and nighttime light. These animals' sense of smell is documented as hundreds or even thousands of times more powerful than a human's. This part of the Sky Island mountain range has been their home for thousands of years, and in a relatively few years their habitat will be gone because of the haze of toxic particulates that will drift across their home range.

6) Residents of Pima County need to be aware of the enormous piles of leftover material in the proposed Copper World Mine's tailings. This waste material - perched on the mountains above Corona de Tucson and Vail - should not be considered "gravel" or "crushed rock." Much of it will be sand and dust particles that could escape the tailings piles or pipes and then spread toxins into the landscape between the Santa Rita Mountains and communities to the west, northwest, and north.
In any open-pit mine operation, tailings must have safeguards, such as dams and liners, to keep them in check. The Copper World Mine owners have already demonstrated a willingness to cut corners with necessary protections. Downstream residents, however, deserve state-of-the-art safeguards for tailings piles that will be hundreds of feet deep. metals such as lead, cadmium, and zinc are especially dangerous when they become airborne or flushed out of tailings, working their way down washes during storms.

There is no way to make this mine safe for the local air quality of citizens and therefore a permit should not be issued

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Comment From: Erin Cline

7/20/24 @ 1:56 PM

I vehemently object to the Class 2 Air Pollution Permit being issued due to a lack of comprehensive meteorological monitoring around the populated areas that will be most affected. In addition, there is a high risk of polluting the air with contamina...↓nts that over 9,000 residents breathe. More studies are needed to determine the risk the proposed mines pose to the surrounding communities that are most closely positioned to the proposed work site. There are two specific factors that have the potential to contribute to air contamination, and therefore demand further study:
1. The nighttime inversion of the Sonoran Desert is made up of a layer of cooler air that is trapped near the ground by a layer of warmer air above. This acts as a trap for dust and pollen, and has the potential to trap air contaminants as well, retaining them in the air. This poses a serious health risk for everyone, but especially those who suffer from reactive asthma and COPD. It should be further noted that the mine site is in very close proximity to Copper Ridge Elementary School, which, as of today, hosts 350 students daily, and serves a rapidly growing community. Approval of this permit will expose these children, as well as teachers, administrators, and support staff, to air toxins from the copper mining process.
2. The area surrounding the mine site is well-known for strong wind gusts, especially during the spring and monsoon season. Locals colloquially refer to these wind gusts as the "Vail Gale." These winds have the potential to carry contaminants from the mine site to thousands of surrounding homes, as well as the three schools that exist in close proximity (Copper Ridge Elementary, Sycamore Elementary, and Corona Foothills Middle School). I request that ADEQ study a meteorological report to gain a more complete understanding of the winds affecting the Vail/Corona de Tucson area to ensure that our residents and students are kept safe from contaminated air. As a current resident of the community, I request that ADEQ pay special attention to air quality concerns that the residents of Patagonia Arizona are currently contending with as a result of the South32 Hermosa Mine, as well as the air quality hazards that have been caused by the Freeport Sierrita Mine. The 2018 ADEQ violations against Asarco and Freeport, resulting in thousands of dollars in fines, should serve as a cautionary tale for us all.

Mining operations such as these should not be carried out in populated areas where residents, many of whom are children, will be exposed to the resulting contaminants. As a resident of Corona de Tucson, I oppose this permit in its entirety.

Erin Cline

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Comment From: Leslie A Epperson

7/20/24 @ 1:04 PM

I am gravely concerned about the implementation of the Copper World open pit mines near Tucson, AZ. Here are but a few of my concerns:

The proposed mine will create mounds of tailings dust hundreds of feet high near
schools and residences. Studies a...↓

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Comment From: Christi Moody

7/20/24 @ 8:59 AM

I oppose Hudbay Minerals Inc., Class II Air Permit based on additional concerns. Pima County constantly receives air quality alerts asking citizens to avoid various activities and to stay indoors if you have pulmonary challenges.

Heavy clouds of du...↓st form during mining operations. Blasting alone in the mining process is an enormous piece of the problem. The explosives used in blasting release fumes rich in smog and acid rain-producing gases like highly toxic nitrogen dioxide. Furthermore, respirable particulate matters and suspended particulate matters are pollutant products through open-pit mining.

Hudbay advertises concerns for communities and the environment using industry best practices. The permit as written does not reflect current industry best practices, for example, the company should use Battery-electric haul trucks to reduce their carbon footprint.

Habitats of diverse species in the environment are destroyed as a result of the processes involved in open pit mining. Open-pit mines are excavated directly into mountain tops and as a result vegetation in that region is lost, the topsoil rocks are gone and the habitat is destroyed. Most of the mining sites are densely populated areas for biological diverse species. This poses a serious threat to the existence and the sustainability of the species. While mining is vital for our economy, the effects of open-pit mining still raise questions about environmental conservation. In mining activities, species go extinct as a result of huge land degradation and alteration. The pollutants produced during the process cause suffocation to the organisms present in that landmass.

Open pit mines use very expensive machinery to excavate mineral ores. To make the most out of these machines, Hudbay plans to operate 24/7 year round. The machines used for mining produce so much noise, causing untold noise pollution to the people and wildlife living near the mine sites. In addition, since the mining process produces huge clouds of dust that inhibit a clear view, it leads to light pollution in the areas.

Mining activities are unsustainable not only because they exploit non-renewable resources, but also because they leave behind their destruction of the environment and society. In closing I am providing additional maps to show the proximity of the mine to Corona de Tucson since Hudbay cuts theirs off just before the community boundary.

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Comment From: Stacie Stebbins

7/19/24 @ 10:21 PM

Good evening. I am a concerned parent who will have young children in the area effected by this project. It is very concerning to me that the CDC states that 'breathing in copper dusts, sprays, or crystals can irritate your nose and throat, and caus...↓

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Comment From: Suzanne Anderson

7/19/24 @ 1:32 PM

I am a resident of Corona de Tucson, one of the closest communities to the proposed Copper World mine, and I have worked in the mining industry since 2014. Currently, I am employed at a mineral resource-related school at the University of Arizona, wh...↓

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Comment From: Debra Acker

7/19/24 @ 1:27 PM

I'm am opposed to this because I moved out here for the clean non polluted air quality, and I feel we will be losing this. Anyone with breathing issues will be affected by this operation. I am completely opposed to the opening of this mine.

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Comment From: Kenneth Bierman

7/19/24 @ 12:45 PM

I am concerned that Hudley's request for a Class II air quality permit is not sufficient to protect public health. I urge the ADEQ to require a Class I permit to protect us from increased air pollution.

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Comment From: Pam Shimek

7/19/24 @ 10:19 AM

This foreign company has applied for a Class 2 air permit, clearly they should have applied for a Class 1 air permit. I believe any request for a permit should be denied.

Allowing this mine to open and operate in this area, so close to an elementary...↓

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Comment From: Eve Shapiro

7/19/24 @ 9:34 AM

Copper World's proposed mine poses serious risks to air quality, public health,
and the environment. To this end, it is critical that ADEQ ensure that the Copper World
Project is subject to appropriate scrutiny and permitting under the Arizona SIP ...↓

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Comment From: Christopher Pederson

7/19/24 @ 9:00 AM

Tailings should not be disposed of 1.7 miles away from an elementary school. There are too many residents is close proximity that would be negatively affected by the addition of a mine so close to our cherished community. I and my family strongly app...↓

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Comment From: Catherine Kelly

7/19/24 @ 8:44 AM

Allowing open tailings in this area would not only impact the children that go to CopperRidge elementary school but also all the communities around it. We have a lot of wind here all year round and it blows hard. Unless they plan on covering it, I do...↓

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Comment From: Paul Huddy

7/19/24 @ 8:36 AM

This mine is located in a valley where over half a million people live. We already have serious air pollution problems as it is. The dominant winds blow north from the mine right toward Tucson, which has a high percentage of respiratory inflicted peo...↓

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Comment From: Michaele Chapman

7/19/24 @ 7:44 AM

Thinking of anything that is even remotely good, healthy, holy, fair, and just, how could you even consider tailings within half a mile of an elementary school! Is your profit that critical? Is it more important than human life, especially lives of y...↓

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Comment From: Julie Buell

7/18/24 @ 6:20 PM

Why was this permit dropped before all of the details are in order? Hudbay shows three Tailings Storage Facilities. This permit only covers two. Is this not a for the life of the mine permit which is far from being established what will actually be d...↓

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Comment From: Indiana Rogers

7/18/24 @ 6:03 PM

We desperately need more environmental protections, not the repetition of past mistakes. Open-pit mines are disastrous and hideous. Stop this nonsense.

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Comment From: Thomas Elliott

7/18/24 @ 5:13 PM

The proposal of this vastly destructive mining project, essentially in the heart of a major metropolitan area, is absurd on many accounts. The water usage alone makes the project unthinkable in this area and this epoch of decreasing water supplies. T...↓

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Comment From: Christi Moody

7/18/24 @ 5:07 PM

I oppose Hudbay's request for a Class II permit based on the following reasons.

This should be a Class I permit in accordance with Arizona Administrative Code (A.A.C.) Title 18, Chapter 2, Article 302(B)(1) Any Major Source - A "major" source as de...↓fined by the A.A.C. Title 18, Chapter 2, Article 101(64) is any source that has the potential to emit 100 tons per year of any criteria air pollutant.

Hudbay Class II permit was initially written in 2022 prior to February 2024 when the EPA strengthened the National Ambient Air Quality Standards for Particulate Matter (PM NAAQS) to protect millions of Americans from harmful and costly health impacts, such as heart attacks and premature death. EPA is setting the level of the primary (health-based) annual PM2.5 standard at 9.0 micrograms per cubic meter to provide increased public health protection, consistent with the available health science. I expect ADEQ to abide by the newly set standards.

Hudbay intends to drill 24x7, 365 with the potential to emit TSP, PM, PM10 and PM 2.5 emissions. PM 2.5  is so small they go into the lungs all the way to the air sacs called alveoli. Once there, they can irritate and corrode the alveoli wall, damaging the lungs and causing lung disease. Particulate matter found in the air can make existing lung diseases, like asthma and COPD worse, as well as cause pneumonia, heart disease, stroke and lung cancer. I do not believe Hudbay has adequately considered this in their permit. The close proximity of the Copper Ridge Elementary School, estimated at 5.9 miles (estimated due to fencing preventing further advancement), Sycamore Canyon, Ocotillo Preserve, Corona de Tucson and other surrounding rural areas will be impacted based on daily winds that occur in the area. These small toxic particles will also damage vegetation, destroy local wildlife making it devoid of life based on the life of this mine.

Meteorological monitoring must occur at locations throughout Corona de Tucson and Quail Creek not just surrounding the mine. The nighttime inversion of the Sonoran desert consists of a layer of cooler air trapped near the ground by a layer of warm air above the surface. This is visible from higher elevations and essentially traps dust and pollen in the air and becomes a potential health threat to our community.

ADEQ, I know you are aware of the current air quality concerns that residents of Patagonia AZ are experiencing as well as the air quality hazards caused by the Freeport Sierrita Mine in Green Valley. (Phoenix, Ariz. – June 21, 2004 The Arizona Department of Environmental Quality and the Attorney General's Office have settled a joint lawsuit against Phelps Dodge Corporation for environmental violations committed at its Sierrita mine, located near Tucson. The U.S. The Environmental Protection Agency joined the lawsuit, and will share the $1.4 million penalty assessed for allegedly violating the Clean Air Act.) A great win for the state but 1.4 million will not, does not alter damage residents have endured.

I believe Hudbay's efforts to control 90+ percent of the pollutants produced by open pit mining is usually high coming from a company that looks to cut operational costs regularly, evident when you read Hudbay De-risks Copper World Phase I with Enhanced Pre-Feasibility Study dated Sept 2023.

Water is not an option for dust control. Water droplets can only capture dust particles that are roughly similar in size. This inefficiency means that the smallest particle matter such as PM 2.5 stays in the air longest, travels the furthest, and goes deeper into the lungs. Using water is wasteful especially in the aid desert.

I want to see clear and concise maps of the Copper World Complex, Tailing piles included, in proximity to Corona de Tucson. It is misleading to continually chop the maps to exclude the community that will most likely be affected by their air pollution.

In closing, Appendix F is missing from all posted documents yet it is continually referred to. I am unable to continue comments as a result.

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Comment From: Cathy McGrath

7/18/24 @ 4:55 PM

Hudbay acknowledges their current plan is not optimal and not their first choice. In fact, it is plan C. Plan A was the original Rosemont layout. Plan B was to move to the west side and move to private land. Then, after exploratory drilling exposed m...↓ore deposits, Plan C emerged, increasing the number of pits from 2 to 6.
The Permit includes TSF-1 and TSF-2 and addresses dust mitigation from those two tailings piles (to the top of the "F")
Yet, there is a third tailings area, TSF-N, which will be necessary to store tailings generated over the proposed life of the mine. TSF-N is listed in their 2022 PEA and their 2023 PSF. It is not included in the Permit, as Hudbay has not acquired the state land needed to connect them to TSF-N on their private land north of the two current storage areas.

This Permit should not be granted for the life of the mine, as it fails to contain enough storage for the amount of tailings that will be excavated from the 6 pits over the life of the mine.
If Hudbay is ever successful in acquiring the 160 acre state parcel, a significant amendment to the Permit will be required in order to add in TSF-N. This storage area is by far the most devastating to the community 1/2 mile north of its location. There are many ephemeral washes in the area, high wind and rain events are prevalent during monsoon season. Monitoring stations will need to be relocated, public comment will need to be re-initiated and there is no guarantee that TSF-N will be added into the Permit. Therefore, it is premature to grant a Permit for the proposed life of this mine, without all necessary facilities included in the current Permit.

The addition of TSF-N could change the Permit and require a Class One instead of a Class Two, which could further complicate things.

This Permit includes on-site cathode processing facilities which were removed from their initial start up operations in their 2023 PSF. They will consider adding those facilities back in as an add-on component in year four, to be paid for out of operating revenue. There is no guarantee this will happen at this time, and by year four, cost restraints could change those plans significantly, causing another significant amendment and public comment period.
This Permit should only be granted for the period of time where there are no variables. That would be year one through four, when they are simply exporting copper concentrate and selling it overseas.
It would be irresponsible to issue a Class 2 Permit for a longer period. Hudbay has not decided, or stated definitively how they will proceed beyond that.
Attached: Hudbay 2022 PEA showing TSF's, Map showing what's just north of TSF-N

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Comment From: Golda Velez

7/18/24 @ 1:16 PM

please REJECT this permit. i grew up going to the Santa Ritas, i think of them as a second home, and the key thing about them was the fresh air. Any decrease in air quality, even just "cosmetic" is a huge loss. Do NOT grant a permit that will degra...↓

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Comment From: Aster Schaefer

7/18/24 @ 12:33 PM

I am concerned that the impact on air quality proposed by Hudbay is a drastic under-expectation of the reality of the project. While I and hundreds of others would much prefer the Copper World Mine not exist at all, if it is to move forward, then it ...↓

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Comment From: Aileen Sluka

7/18/24 @ 12:16 PM

I didn't work my whole life to see my dream home ruined by Copper world in many ways! Forestry,precious Az.water issues, majestic views & air pollution. Your facilities emit the following air contaminates:(PM10),(PM25)(VDCs),(NOx),(SO2),(CO)(H2SO4)&...↓

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Comment From: Susan Screven

7/18/24 @ 5:41 AM

Please urge that Copper World must obtain a Class 1 Air Permit. It must be sufficient to protect people and our environment. Thank you.

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Comment From: Samuel Kalter

7/17/24 @ 7:51 PM

While I believe mineral extraction to be an inevitable practice here in AZ,the location of the proposed Copper World mine is a problem in several respects, but we are dealing with only air quality here.It is entirely too close to thousands of residen...↓

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Comment From: Frank Pitts

7/17/24 @ 4:43 PM

Tucson has a large population. Santa Rita Copper World would have a negative impact on the scenery, negative health implications with reduced air quality, extra water consumption near a large population and ground water contamination. We need the cop...↓

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Comment From: Sheryl Hester

7/17/24 @ 4:33 PM

If this project continues all permits should be required. I am not in favor of this project.

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Comment From: Richard Spotts

7/17/24 @ 3:55 PM

Please strongly support and require a Class 1 permit for this proposed mining operation. This mining could significantly contribute to adverse air quality and public health impacts. I have visited this area and I care about maintaining and enhancing...↓

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Comment From: Stephanie Bell

7/17/24 @ 3:41 PM

I am terribly concerned! Hudbay is requesting a Class II permit, which is not sufficient for protecting human health, considering the high level of air pollution that would be created by the mine. We believe ADEQ should require a Class I permit for H...↓

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Comment From: Peter Kadrich

7/17/24 @ 3:38 PM

From experience with the older mines west of I 19 it should be self evident that nothing less than a Class 1 permit should be allowed. Human life must be more valuable than ethereal profits.

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Comment From: Dana Smith

7/17/24 @ 3:32 PM

We believe ADEQ should require a Class I permit for Hudbay, with stricter regulations that would help protect people and the environment from air pollution.

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Comment From: Charles Spilman

7/17/24 @ 3:14 PM

A class Ii permit is insufficient for protecting human health considering the high levels of pollution that will be generated by this mine. Reject this application. Reject this destructive mine.

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Comment From: Kelsey Yule

7/17/24 @ 3:10 PM

To Whom it May Concern,

In response to the Hudbay ADEQ air quality permit application dated April 11, 2024, concerned parties, including environmental organizations and advocates, have raised substantial objections. The application pertains to Coppe...↓r World Inc.'s proposal for a Class II air pollution permit for their Copper World Project in Pima County's Santa Rita Mountains. I and others believe that Hudbay should require a Class I permit due to potential emissions that may exceed Class II thresholds.

The primary concern centers on the classification of emissions as fugitive versus non-fugitive. Under Arizona's State Implementation Plan (SIP), a Class I permit is required for sources projecting 100 tons per year or more of any air pollutant, while Class II permits are for lower emissions. I and others would argue that Copper World's classification of emissions as fugitive is inaccurate. They contend that emissions from activities like rock breakers and material transfer points could feasibly be collected through standard technologies like dust collectors, thus making them non-fugitive. This misclassification could result in underestimating emissions and circumventing more stringent regulatory scrutiny.

Additionally, I am skeptical regarding Copper World's projections of achieving 99% control efficiency for all pollutants using fogging sprays, scrubbers, and dust collectors. Such high efficiencies are impractical over the operational lifespan of the mine and may lead to underestimated emissions of particulate matter, including PM10 and PM2.5. This discrepancy could pose significant risks to local air quality, public health, and the environment, especially considering the proximity of the Santa Rita Mountains to residential and protected areas.

I am urging ADEQ to reevaluate the permit classification and ensure that Copper World adheres to more stringent Class I permit requirements. There is a need for accurate emission assessments and robust control measures to mitigate potential adverse impacts. The outcome of this permitting decision will likely hinge on ADEQ's interpretation of fugitive emissions and the adequacy of proposed control technologies in safeguarding air quality and public health in the region.

There are broad implications of regulatory oversight in balancing industrial development with environmental protection, particularly in sensitive ecological areas like the Santa Rita Mountains. As stakeholders await ADEQ's decision, the scrutiny over Copper World's permit application reflects ongoing debates over responsible resource extraction and environmental stewardship in Arizona.

Thank you for your time -
Kelsey Yule, PhD
Tucson, AZ

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Comment From: Anne Clock

7/17/24 @ 3:09 PM

Open air pits are never good for the environment and this one is a polluting action taking by a company that is aware of this. Once on the air this pollution force will end up also on our water and in our bodies. When i saw you had already made roads...↓

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Comment From: Deron Beal

7/17/24 @ 3:01 PM

Hudbay is requesting a Class II permit, which is not sufficient for protecting human health, considering the high level of air pollution that would be created by the mine. I believe ADEQ should require a Class I permit for Hudbay, with stricter regul...↓

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Comment From: Darlene Rudolph

7/17/24 @ 1:18 PM

We are long time residents of Corona de Tucson and have been living and breathing the clean air that comes naturally when you live outside large city environments. Therefore, we object to this Class 2 Air Pollutants in excess permit being issued as w...↓

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Comment From: Dennis Winsten

7/17/24 @ 12:42 PM

The Trinity Report appears thorough in regard to monitoring air quality and environmental standards.

However, if agreed upon standards are NOT met and timely corrective actions are NOT taken, what recourse does ADEQ have? Fines? Suspension of opera...↓

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Comment From: Allan Rudolph

7/17/24 @ 11:52 AM

I am objecting to this class 2 Air Pollutants in excess permit being issued as written due to inadequate meteorological monitoring around the most affected populated areas. We reside in Corona de Tucson and our area has very frequent high winds. Also...↓

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Comment From: DAVID DEGROOT

7/16/24 @ 6:41 PM

I am against issuing an Air Quality Permit for the Copper World Mine operation. I fear that Copper World Mine does not understand our windstorms and will not monitor and prevent dangerous airborne particulates (lead, cadmium and zinc, for example) fr...↓

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Comment From: Angela devesty

7/16/24 @ 5:54 PM

I strongly object to this Class 2 Air Pollution Permit being issued due to inadequate meteorological monitoring around the most affected populated areas, as well as the risk of introducing airborne contaminants to the air that almost 9,000 residents ...↓and surrounding communities breathe. More research is needed to determine the potential for air contamination to the community due to the close proximity of the to the proposed mine site. Specifically, there are two factors that could contribute to airborne contamination and require further study:
1) The nighttime inversion of the Sonoran desert consists of a layer of cooler air is trapped near the ground by a layer of warm air above the surface. This is visible from higher elevations and essentially traps dust and pollen in the air, triggering sensitive groups such as those with reactive airways, i.e. asthma or COPD patients. If airborne contaminants were introduced, they will effectively stay in the air and become a potential health threat to our community. It should be given special consideration that an elementary (Copper Ridge Elementary) is in close proximity to the mine site, and over 350 children will be breathing in contaminants from the copper mining process if this permit is approved.
2) The area surrounding the mine site exhibits notoriously strong gusts of wind, especially during Spring and monsoon seasons. I ask that ADEQ study a meteorological report for a more complete understanding of the winds affecting the Vail/Corona de Tucson area. Airborne contaminants from the proposed mine could easily be carried through thousands of homes, and most importantly thousands of students in the two elementary schools (Copper Ridge, Sycamore) and one middle school (Corona Foothills).

If approved without further scientific study, this Class 2 Air pollution Permit is a threat to the health and safety of our community. As a resident, I ask that ADEQ pay special attention to the current air quality concerns that residents of Patagonia AZ are facing with the South32 Hermosa mine, as well as the air quality hazards caused by the Freeport Sierrita Mine. The 2018 ADEQ violations against Freeport, resulting in $450,000 in penalties for Asarco —$100,000 in fines and $350,000 in contributions toward county environmental projects should serve as a warning for us all.

Mining such as this should be carried out in less densely populated areas, certainly not where thousands of residents, many of whom are children, will be exposed to the contamination of the mining process. As a resident of Corona de Tucson, I object to this permit in its entirety.

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Comment From: Elaine Wolter

7/16/24 @ 2:50 PM

Many more air quality monitors will need to be installed to protect the large population. Will Hudbay pay for these?

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Comment From: Jean Vickers

7/16/24 @ 11:06 AM

My name is Jean Vickers. I am 75 years old and a lifelong asthmatic. We moved to Corona de Tucson in 2008. Within a few years, my asthma, which was controlled by medication, was getting worse from particulates in the air. I discovered from a Mayo Cli...↓

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