Answer: No, we recognize the need for environmentally and culturally appropriate mining to support industry, especially for the transition to green energy. However, we oppose mining in the Santa Rita Mountains because the resources that mining would destroy are essential for our community. In particular, Hudbay's Copper World project would require 4 billion gallons of ground water per year, enough to sustain 41,000 families. There are other places where water would be less of an issue.

Answer: We take them from Hudbay’s published documents. We assume they want to put the best spin on things they can, so if they release numbers that indicate the mine would be an environmental, economic, and health disaster, we can take that as a best-case scenario.

Answer: We need money to pay for legal fees, professional reports on water and economics, website development, newsletter production, travel to public meetings, and staff support. As what is essentially a group of neighbors, most of our support comes from ourselves in the form of donations by board and other members.

Answer: Heavy truck traffic could cause accidents and spill toxic chemicals. A spill near the community of Sahuarita Highlands could cut off access to Sahuarita and Highway 19.

Context: More than one hundred trucks per day will pound along the dirt road through the Santa Rita Experimental Range, carrying copper concentrate and, eventually, dangerous sulfuric acid past Sahuarita Highlands and through the town of Sahuarita itself. And accidents do happen. The economic summary of the Power Consulting report contains a photo of a truck carrying copper concentrate overturned on a road near a Hudbay mine in Peru. In 2023, Interstate 10 was closed for days near Tucson because a tanker truck spilled nitric acid.

Sahuarita Highlands has two entrances off of Sahuarita Road. A single accident could sever this connection between Sahuarita Highlands and Sahuarita.

Answer: People living in the community can expect to fill some unknown fraction of the projected 430 mining jobs, plus secondary jobs needed to support the miners. It’s possible that many of the mining would be filled by experienced miners now living outside the community. Because of increasing computerization and use of robots in the mining industry, some of these mining and secondary jobs are likely to disappear over time. Jobs in other industries, like tourism and recreation, are likely to be lost.

Context: Hudbay does not have figures on the number of jobs that locals can anticipate. Hudbay claims it will create 430 direct mining jobs and 3,000 secondary jobs, but there is no specification on how many will be local.

Because many of these mining jobs are specialized, whether in administration, engineering, or operating heavy equipment, it seems likely that many will be filled from outside the county to save on training time. For the Mine Safety and Health Administration to consider someone an “experienced miner” under 30 CFR Part 48, this individual must have 40 hours of training and have previously worked for 12 months as an above-ground miner.[1] New miners must take new miner training approved by MSHA and given by an MSHA-approved instructor. This requires 24 hours of class time plus significantly more time in Task Training for every tool or machine a miner will use.[2]

Because computerized systems and robotics are increasingly taking over mining jobs, it’s not clear whether the number of jobs existing when the mine opens will continue to be required over time. A report about automation in the mining industry focused on Australia states, “The fear of job losses is backed up by data. A 2020 paper estimated that automation could see around 10,000 coal mining jobs in Queensland, Australia being replaced – approximately 40% of Queensland’s coal mining workforce.”[3], [4]

Hudbay’s 430 direct jobs would be less than one-tenth of one percent of jobs in Pima County. And these jobs will come with great economic, health, and safety risks. Yes, some additional, secondary jobs will be created to support the miners, but Power Consulting, commissioned by SSSR, provides compelling evidence that Hudbay exaggerates the number of secondary jobs the mine would create. Hubay used a multiplier of nearly 7 secondary jobs for each of the 430 mining jobs, while multiple studies cited by Power Consulting suggest that a more reasonable multiplier might be 3 to 5. The Power Consulting report cites a study by Fleming in Australia that found that mines actually caused loss of jobs in industries like “arts and recreation services.”[5]

It’s logical that if mine jobs are filled by local people, then relatively few secondary jobs would be created for these miners because they already live in the community and depend on services already in place. If jobs are filled by outsiders, then these people would increase demand for secondary services.

[1]Compliance Guide for MSHA's Modified Regulations on Training and Retraining of Miners. https://arlweb.msha.gov/regs/complian/guides/train/cmpguid2.htm

[2]MSHA. Guidelines for Effective Task Training. https://www.msha.gov/safety-and-health/safety-and-health-materials/guidelines-effective-task-training

[3]Kit Million Ross. 2023. Mine Issue 132, September 2023. https://mine.nridigital.com/mine_sep23/robotics-jobs-automation-mining-employment

[4]Fleming-Muñoz, D.A., L. Poruschi, T. Measham, J. Meyers, M. 2020. Economic vulnerability and regional implications of a low carbon emissions future. Australian Journal of Agricultural and Resource Economics: 64(3). Mogliahttps://onlinelibrary.wiley.com/doi/10.1111/1467-8489.12356

[5]Fleming, D., and Measham, T. Local job multipliers of Mining. Resources Policy. 2014.

Answer: Toxic chemicals that are typically present in tailings piles include copper compounds, lead and lead compounds, arsenic compounds, zinc, mercury, sulfuric acid, cadmium, chromium, and sulfate. Lead, for example, is a powerful neurotoxin that has severe effects on children and that the U.S. Centers for Disease Control considers unsafe at any level.[1]Any of these chemicals escaping from the tailings piles into the groundwater will enter the same aquifer used for drinking water by nearby communities, including Corona de Tucson, Sahuarita, Vail, and Green Valley.

Context: In August 2024, ADEQ gave the Copper World project an aquifer protection permit (APP) that it says will protect the groundwater adequately. However, analysis by expert hydrologists contracted by SSSR reviewed this APP and concluded that the measures it contains may not be adequate to prevent groundwater contamination. Measures the SSSR experts consider inadequate include failure to require plastic liners underneath tailings piles to contain contaminated water so that it does not penetrate the ground. Instead of liners, ADEQ has permitted a system of collection pipes that will be slightly less effective at capturing escaping water (98% for pipes versus 99% for liners, according to Hudbay’s reported results).

We know from other mines that tailings piles do contaminate groundwater. For example, the Freeport-MaMoRan’s Sierrita Mine has a long history of contaminating the groundwater near Green Valley, where high concentrations of sulfates from the mine lead to the closure of wells supplying the Community Water Company. One of the solutions to this problem has been installation of numerous interceptor wells downstream from the tailings pile designed to pump contaminated water to the surface for disposal before it can reach the part of the aquifer used for drinking-water wells.[2], [3]

Concerns are that a) even at a 98% capture rate, the proposed pipe collection system for tailings piles will let some contamination percolate into the ground water, and b) any collection system is unlikely to function in perpetuity after the mine has shut down. We note that it is common for hard-rock mines to declare bankruptcy to escape from environmental obligations once the ore has played out.[4]

[1]CDC. 2024. “About Childhood Lead Poisoning Prevention.” Childhood Lead Poisoning Prevention. May 23, 2024. https://www.cdc.gov/lead-prevention/about/index.html.

[2]Fact Sheet: Phelps-Dodge. 2007. Aquifer Protection Permit P101779, Phelps-Dodge Sierrita, Inc. (PDSI) Mine.  https://legacy.azdeq.gov/function/news/2007/download/sierritafact.pdf.

[3]Freeport-McMoRan. 2024. Reporting Year 2023 Mitigation Performance Review Report. https://www.fcx.com/sites/fcx/files/documents/sierrita/2024/042224.pdf

[4]Government Accounting Office. 2006. Environmental Liabilities: Hardrock Mining Cleanup Obligations. https://www.govinfo.gov/content/pkg/GAOREPORTS-GAO-06-884T/pdf/GAOREPORTS-GAO-06-884T.pdf

Answer: Copper World will pump between 2 and 4 billion gallons per year from the aquifer shared by neighboring ranches, farms, and communities. The epicenter of the draw-down area would be eastern Sahuarita surrounding the water production wells Copper World has already drilled.

Context: The West is experiencing a mega-drought. From 2000 to 2021 Colorado River flows dropped by about 10%, equal to the storage of Lake Mead, the largest water reservoir in the U.S. Water shortages will continue to worsen in the western U.S. because the world is locked into at least another 1.5 degrees C. of warming [excerpted from Power Consulting report]. 

It’s difficult to determine precisely how much water Copper World would consume because Hudbay's publicly released mining plans continue to change. Nonetheless, we know the amount would be huge. In its June 2022 plan, Hudbay proposed to consume an annual average of 4.6 billion gallons of groundwater pumped from wells next to the Santa Cruz River for 44 years. This is enough water to supply the annual needs of 41,000 households (108,000 residents). But in September 2023, the company revised its plans and, unlike in 2022, provided no information about projected water consumption other than stating it has a permit from the State Department of Water Resources to use up to 2 billion gallons per year[1], enough for some 54,000 residents.

Hudbay is expected to eventually amend its state permit to use far more than the now-permitted 2 billion gallons annually. If, as planned, Hudbay begins refining copper concentrate to pure copper on site, this would likely raise water consumption to approximately the 4.6 billion gallons projected in the 2022 plan.

Although no modelling has been publicly released by Hudbay that predicts how much the Copper World project would draw down water levels in the aquifer, such predictions were made for the 2013 Rosemont Mine environmental impact statement (EIS). The EIS predicted that the much smaller Rosemont Mine would decrease water levels in a roughly circular area approximately 5 miles in diameter surrounding the water production wells on the east side of Sahuarita. Because Copper World will most likely pump more than twice the water that was modeled in 2013 for the Rosemont Mine, it’s reasonable to predict that the effects on neighboring users will be considerably greater. Eventually the draw-down will also affect Corona de Tucson, which is upstream of the production wells.

The Sahuarita Water Company, which supplies water to 14,000 residents in Pima County, uses “groundwater drawn from the aquifer” directly west of the proposed mine.[2] Since Hudbay currently has a permit to pump 6,000 acre-feet of water annually (their permit runs out 2028)[3], it is likely that the municipal wells around the proposed mine will have less water available. This is substantiated by the 2013 FEIS for the previously planned Rosemont Mine, which predicted that surrounding wells would produce less water for 140 years after the mine stopped pumping, based on use of only 4,700-5,400 acre-feet per year by the mine, compared to the 6,000 to 13,000 expected for Copper World.

“Groundwater levels would decrease up to an additional 90 feet from the pumping, declining at a rate of 1.5 to 3.5 feet per year above and beyond existing groundwater declines. The geographic extent of the drawdown would be 3 to 4 miles from the Rosemont production wells during the first 20 years of pumping; the geographic extent of impacts would continue to expand an additional 1 to 2 miles for up to an estimated 140 years after completion of pumping. An estimated 500 to 550 registered wells are located within this area of drawdown; specific impacts to individual wells, if any, cannot be identified.”[4]

If the proposed mine were to pump significantly more than what was modeled for the FEIS, as seems likely, the drawdown of groundwater would be significantly increased. Without groundwater modeling for the current project analogous to that done for the FEIS, it’s difficult to know for certain how much ground water would no longer be available for local municipalities, but there would conceivably be almost three times the water volume pumped out of the proposed mine’s wells when compared to the 2013 FEIS. If the time scale is linear with respect to the recharge of the groundwater, then it will take almost 400 years to recharge the local area’s groundwater after the mine has stopped pumping, and it is likely that many more local wells will be affected.[5]

[1] Hudbay. NI 43-101 Technical Report Phase I Pre-Feasibility Study and Updated Miner Resource Estimates. Copper World Project Pima County, Arizona, USA. 7.1.2023. Page 18-2.

[2] Sahuarita Water Company. About us. Accessed 9.5.2023. https://sahuaritawater.com/about-us/#:~:text=The%20source%20of%20SWC%20water,aquifer%20system%20below%20the%20development.

[3]The proposed mine is inside of the Tucson Active Management Area for water in Arizona. Because of this Hudbay had to get a permit for the water that they can pump. Hudbay. Preliminary Economic Assessment. Copper World Complex, Pima County, Arizona USA. 5.1.2022. Page 20-172.

[4] Forest Service. FEIS for the Rosemont Copper Project. 2017. Page xxix.

[5]Power Consulting. 2024. The Economic Impact of the Proposed Copper World/

Rosemont Mine Complex on the Greater Tucson Area Economy

Answer: No. Although copper is needed for the green energy transition, it is not currently in short supply in the U.S. nor likely to be so in the near future. Despite requests by Senator Sinema and others, USGS has declined to list copper as a critical mineral because the U.S. has secure, sufficient supplies. Even were more copper needed, there are other places where mining could be done without such catastrophic effects on the environment, human health, and the local economy.

Context: Hudbay uses the green-washing argument that the green energy revolution requires copper from Copper World. Not so. First, the U.S. Geographical Survey has declined to list copper as a critical mineral because there’s plenty of it. When Senator Sinema and others wrote a letter to the head of the USGS asking that copper be listed, he declined (see attached letter). According to USGS, with recycling, copper from existing mines, and copper from friendly trading partners, there’s enough now and there will be enough for the near future. Second, even if new mines are needed, the Santa Rita Mountains aren’t the right place. No one needs a mine in the Santa Ritas except Hudbay. Some places are just too precious to mine.

There’s confusion because the Department of Energy listed copper as a critical material. However, in the DOE report listing copper as a critical material there’s a figure that shows DOE does not consider copper critical in the short or medium term. And DOE makes no projections for the long term.

Regardless, the strongest argument is the one above: “Even if the US needs more copper in the future, it has adequate supplies at the moment, and there are many other places to get copper that wouldn’t destroy such a special place.

Another helpful fact might be that there aren’t any other copper mines in the U.S. that are so close to a major metropolitan area where a multitude of people could be affected by health risks, loss of potable water, and economic harm.

Answer: The harm to key Pima County economic sectors, notably tourism, outdoor recreation, and the housing market will be much greater than economic benefit from the mine. Tourism and outdoor recreation throughout the region is likely to be depressed by the combined effects of proposed open-pit mines in both the Santa Ritas and the Patagonias.

Context: The Power Consulting report[1], commissioned by SSSR, identifies several sectors where economic losses are likely to be significant, including tourism, outdoor recreation, and home values. Collectively the losses are likely to far outweigh the benefits of the predicted direct mining and indirect jobs (secondary jobs), plus the property taxes projected by Hudbay[2]. In 2022, Pima County passed a resolution opposing Copper World because it saw clearly that replacing precious “natural and cultural resources” with gigantic open pits and piles of toxic waste is a bad idea.

Power Consulting’s review shows that U.S. counties across the country that depend on mining fare worse than those that don’t. This is because mining is boom and bust and because it hurts truly sustainable economic sectors, like tourism and outdoor recreation.

Power Consulting also concluded, based on studies of communities where mines moved in, that just decreases in home values could more than offset economic benefits from mining jobs. Although predicting future values based on other mines in other places is tricky, Power Consulting notes that one thing is certain, namely that Hudbay’s assumption that there will be no negative effects on home values is clearly wrong. Common sense would ask, “Who wants to buy a house next door to a toxic waste dump?” A partial answer is that some homeowners afraid of the mine have already moved away.

In considering how the Copper World project could harm the local economy, it’s important to consider cumulative effects of this mine and others, notably the proposed mines in the Patagonia Mountains. The Sky Islands of southern Arizona, which include the Santa Ritas and the Patagonias, are world-class centers of biological diversity and attract birders and other tourists who support a Pima County tourist economy worth $2.75 billion in 2022.[3]If the natural ecosystems of both the Santa Ritas and the Patagonias are replaced with open pit mines and giant piles of toxic waste this is bound to have a substantial depressive effect on tourism.

The clearest picture of economic harm comes from basic facts. More than 6,000 people, many retirees, move to Pima County every year with savings and investments. Such “non-labor” sources make up nearly half the income in Pima County. Why do these people come to Pima County when they could choose to live anywhere? They come for quality of life, including scenic views of the mountains, access to nature, and opportunities for outdoor recreation. Will they still come to live next to monstrous mountains of toxic waste?

[1]www.copperworldeconomics.com

[2]Hudbay’s Pre-Feasibility Study projects property taxes of $12 million per year.

[3]KVOA, News 4 Tucson. 2023. Record-breaking year in tourism for Pima County. https://www.kvoa.com/news/record-breaking-year-in-tourism-for-pima-county/article_00154946-57cd-11ee-8b60-3f025143384f.html

Answer: Dust contaminated with toxic heavy metals like lead and arsenic is likely to blow into nearby communities, with possible health consequences, particularly for children.

Context: In its 2023 Pre-Feasibility Study (PFS), Hudbay proposed to place hundreds of millions of tons (60,000 tons per day) of tailings (waste left after ore is processed) in piles near residential communities in Pima County where contaminated dust blowing from the piles could pose a risk to human health.[1]These piles will be some 500 feet high and as much as 3 miles long. The PFS proposes to put tailing piles near Copper Ridge Elementary School and approximately 500 feet from the nearest home and one-and-a-half miles from the Copper Ridge Elementary School in Corona de Tucson.

Data presented by Hudbay in its application to ADEQ for an air permit identifies lead as one of the contaminants that will occur in its tailing piles. Other toxic elements may include arsenic, antimony, cadmium, and molybdenum, as have been found in other copper mine tailings around the world.[2],[3] Lead is a neurotoxin that causes permanent damage to children’s nervous systems. As one of the ADEQ staff acknowledged at the air permit public meeting in August, 2024, the US Center for Disease Control states that “There are no safe levels of lead in the blood.”[4]

Even when mines use dust suppression measures, like spraying tailings with water, wind blowing across tailings piles can transport dust particles substantial distances. Although most dust is deposited within a mile or so from the tailings piles, detectable levels of toxics carried by smaller dust particles have been found up to 30 miles from the source.[5],[6] A 2020 story in the Arizona Daily Star[7]reported that:

Year in and out, tailings are typically the largest single source of releases from mines… Owners of both Tucson-area copper mines [Freeport-McMoRan’s Sierrita Mine and Asarco’s Mission Mine complex in Sahuarita] have paid fines and other settlements to Pima County after tailings blew onto neighboring homes and driveways, coating buildings, furniture and vehicles with thick sheens of white.

ADEQ proposes to give Hudbay a Class 2 air permit based on what SSSR believes are faulty assumptions about the quantity of pollutants that would be released. SSSR believes that a more restrictive Class 1 permit is appropriate. A Class one permit also invokes closer oversight by EPA to make sure that the state is following the Clean Air Act guidelines.

ADEQ assumes that distribution of toxics by blowing dust would be minimal if Hudbay follows guidelines for dust suppression. However, as in the above example of the Sierrita and Mission mines, it is unlikely that dust suppression will be absolute

A 2019 study, using mice as the laboratory animals, found that exposing young mice to fine dust from tailings in Arizona caused significant deleterious changes in lung structure and function, and that effects were even observed in utero when the mother breathed tailings dust.[8]The tailings had been produced by mining copper and other metals at the Iron King and Humboldt Smelter Superfund (IKMSS) site in Dewey-Humboldt, Arizona. The authors observed that:

The incidence of high dust storms in the Southwestern US has been increasing in recent years and this is especially a serious concern in arid and semi-arid regions due to the increased susceptibility to windborne transport of metal-laden dust particles. This issue can be particularly acute just downwind from mining sites where dusts can contain high levels of metal(oid)s (Csavina et al., 2011).

[1]PFS p. 18-4.

[2]2022. Zanetta-Colombo et al., “Impact of Mining on the Metal Content of Dust in Indigenous Villages of Northern Chile.” Environment International v. 169: 107490.

[3]2012. Koz, Cevik, and Akbulut, “Heavy Metal Analysis around Murgul (Artvin) Copper Mining Area of Turkey Using Moss and Soil.” Ecological Indicators v. 20: 17-23.

[4]CDC. About Childhood Lead Poisoning Prevention. https://www.cdc.gov/lead-prevention/about/index.html

[5]See in James B. Molloy et al. 2020. “Citizen Science Campaign Reveals Widespread Fallout of Contaminated Dust from Mining Activities in the Central Peruvian Andes,” Geology 48, no. 7 (July 1, 2020): 678–82, https://doi.org/10.1130/G47096.1.

[6]2022. Zanetta-Colombo et al., “Impact of Mining on the Metal Content of Dust in Indigenous Villages of Northern Chile.” Environment International v. 169: 107490.

[7]Tony Davis, 2020. “Arizona Toxic Releases Soar, Led by Copper Mines, Smelter, EPA Says,” July 29, 2020, https://tucson.com/news/local/arizona-toxic-releases-soar-led-by-copper-mines-smelter-epa-says/article_001e92bf-2b27-56a7-83a1-bdb2c2c13133.html. Accessed 12.31.2023

[8]Mark L. Witten et al., 2019. “Early Life Inhalation Exposure to Mine Tailings Dust Affects Lung Development,” Toxicology and Applied Pharmacology 365 (February 15, 2019): 124–32, https://doi.org/10.1016/j.taap.2019.01.009.