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I am writing these comments on behalf of Earthworks, a national non-profit organization dedicated to protecting communities and the environment against the adverse impacts of hardrock mining. Earthworks has a long history of advocating for protection of the outstanding resource values in southwest Oregon, and we have members who enjoy hiking, fishing, floating, wildflower viewing and other activities in the region.

We commend the agencies for initiating this process, and we express our strong support for the proposed mineral withdrawal in aid of legislation for 95,806 acres of National Forest System lands on the Rogue River-Siskiyou National Forest and 5,216 acres of Bureau of Land Management lands on the Medford District and Coos Bay Districts. Such legislation is currently pending in the 114th Congress as S. 346 and H.R. 682 and identified as the “Southwestern Oregon Watershed and Salmon Protection Act of 2015.”

A mineral withdrawal is needed to protect the extremely high conservation values offered by the public lands in this this region, including wild rivers, world-class salmon runs, globally significant botanical diversity, and tremendous recreational opportunities.

Protecting these resources is incompatible with hardrock mining, particularly nickel laterite strip mining. Owing to the outdated 1872 Mining Law, federal land management agencies have stated that they have no authority, outside a mineral withdrawal, to prioritize the protection of the outstanding resource values these public lands offer.

We ask that you provide the maximum possible interim protection available while Congress considers legislation to permanently withdraw those areas. At a minimum, the 5-year withdrawal is critical and immediately necessary. However, the Secretary of Interior should implement the full scope of her authority under FLPMA to implement a 20-year withdrawal, which is warranted in this case due to the area’s outstanding values. And, the Forest Service should consent to the mineral withdrawal to provide the maximum protection for these public lands.

A mineral withdrawal is consistent with the considerable public investments in conservation in the region and it has tremendous public support.

Our more detailed comments are outlined below.

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