Dear District Ranger Ruggiero and Ms. DeRose:
Thank you for this opportunity to comment on the proposed Hermosa Drilling Project and the request by Arizona Minerals, Inc. (“AMI”) for approval of a Plan of Operations (“PoO”) for this Project. These comments are submitted on behalf of Defenders of Wildlife, the Patagonia Area Resource Alliance (PARA) and Earthworks, and are intended to supplement any prior or related comments from these organizations and or individual members of these organizations. We also incorporate by reference in these comments all of the comments on the Project submitted by Sky Island Alliance.
Patagonia Area Resource Alliance (“PARA”) is a grassroots organization of volunteer community members committed to protecting and preserving the Patagonia, Arizona area. It is a watchdog organization that monitors the activities of industrial developers such as mining corporations, as well as government agencies, to make sure their actions have long-term, sustainable benefits to our public lands, our watershed, and the town of Patagonia.
Defenders of Wildlife is a national, nonprofit membership organization dedicated to the protection of all native animals and plants in their natural communities. Defenders is committed to protecting wild lands and wildlife in Arizona, and its Southwest office is located in Tucson, Arizona.
Earthworks is a nonprofit organization dedicated to protecting communities and the environment from the impacts of irresponsible mineral and energy development while seeking sustainable solutions.
As an initial matter we agree with your preliminary assessment that the Hermosa Drilling Project does not meet any of the criteria for a Forest Service categorical exclusion (“CE”), established under 36 C.F.R. § 220.6, for exclusion from detailed National Environmental Policy Act (“NEPA”) review in an Environmental Assessment (“EA”) or Environmental Impact Statement (“EIS”). Accordingly, our comments are directed toward issues of concern and which we believe should be considered in a forthcoming EA or EIS.