Groundwater Awareness League
P. O. Box 934
Green Valley, AZ  85622

Environmental impact of proposed mining project at Apache Leap and Oak Flats, Superior, Arizona

To:  All Arizona Congressional Persons and Natural Resource Committee

Submitted by:
Nancy Freeman,
Groundwater Awareness League,
Executive Director
Date:  July 24, 2007

A foreign company Resolution Copper, a joint venture corporation formed by a British and Australian Company, is attempting to get an Act of Congress to undo the protection that President Eisenhower gave to certain public lands in Public Land Order 1229 in 1955, including Oak Flat in Tonto National Forest in Arizona. Oak Flat is just as unique today as it was then. Further the mining operations would more than likely impact a traditional Indian historical site, Apache Leap.

Map of proposed Resolution Copper mining site

Although this region is not on designated Native American reservation land, it has historical, traditional significance for the Native Americans who have lived in the region for generations. It is a historical site of Apache heroes, rather like Custer’s “last stand”—which has been made a National Monument.

The proposed exchange lands do not in any way equal the sacrifice of Oak Flat, Apache Leap, and Queen Creek, which abound with unique flora and fauna. The proposed sites are principally over-grazed abandoned ranches that offer no uniqueness of bird, animal or plant.

For details, see Attachment One: Land Exchange Properties

The exchange will limit the environmental oversight and the public process that proceeds with mining projects on public lands. One can not help but conjecture the motives of a mining company that is trying to convert public land into private land—when in fact public land is readily available for mining.

Profits made from mining on public lands

Top Mining Companies on BLM land in the U.S.―Ranked by Acres Affected



US m$ (2005)

Acres of

1) Phelps Dodge




2) Barrick Gold Corp.




3) Newmont Mining




4) Kinross


23.8 (2003)


5) Rio Tinto





* Information not available to separate earning in U.S.

Tribal Coalition: The tribes of the region of formed a coalition to preserve the sanctity of the region. They have sent a letter of President Bush requesting that he continue to protect the region, which has been protected by former President Eisenhower. As you can ascertain by the above map, the mining site is to occur on the backside of the formation.

See Attachment Two: Tribal Coalition Letter to President Bush

An online petition has been posted this week so that others can express their support the efforts of the Tribal Coalition to save their traditional sacred site of Apache Leap. People across the U.S. are rallying to the cause.


Impacts of mining: There are certain considerations that a person not familiar with mining practices would need to know before making any decisions concerning facilitating mining operations on or near these two sites.

1)  Mining is not a sustainable operation. The impact on the area where the waste is dumped is more than considerable. Using the figures of Resolution Copper, they will mill some one billion tons, which have only some 3% copper. The other 97% has to be dumped somewhere. If the tailings are stacked, they will cover 2,389 acres at a height of a 20 story building.

For details, see Attachment Three: Volume of Tailings

2)  Water impact. This region has two streams that flow seasonally, but with some permanent pools—a rarity in Arizona. To construct any project that could drawdown the water table—thus emptying the creeks and streamlets—would be devastating to the birds and other wildlife, as well as the trees and other plant life. Even with the National Environmental Policy requirements and oversight, it has been shown by recent research that the Environmental Impact Statements underestimated the impact on water in 76% of the cases studied.

For details, see Attachment Four: Predicting Water Quality Problems at Hard Rock Mines

Another issue is that Resolution Copper will need to pump nearly two billion gallons of toxic water out of the old Magma Mine “shaft 9” before they start new operations. They planned to discharge the water into a stream that flows behind Boyce Thompson Arboretum State Park. After objections over sulfate levels by the Arboretum management, Resolution now plans to pipe the toxic water to Queen Creek, dilute it with water from the CAP canal, and have the area farmers use it. At this time, the residents of that region do not want the contaminated water to get into their groundwater table. Department of Environmental Quality as notified and is requiring Resolution Copper to obtain a discharge permit.

3)  Probability of subsidence: The company asserts that there will be no subsidence with a tunnels running to though terrain 4,000 to 7,000 feet deep and sq feet long and wide. Nevertheless, they would not give a guarantee to Access Fund of no impact to the Oak Flat climbing area and they plan to close the region for recreational use. The bottom line on subsidence: It's totally non-predictable.

Madan Singh, Director of the Arizona Department of Mines and Mineral Resources reports, “Subsidence is an inevitable consequence of underground mining – it may be small and localized or extend over large areas, it may be immediate or delayed for many years” (SME, 1992). In Mining publication, 1997, Fejes calls subsidence “a natural result of underground mining,” and goes on to state that, “When a void is created nature will eventually seek the most stable geologic configuration, which is a collapse of the void and consolidation of the overburden material.” Central to all these opinions is the underlying fact that subsidence will occur and will result in impacts to the overlying strata. There is no way to predict the rifts and faults in a cliff-type area such as Oak Flat and Apache Leap.

For details, see Attachment Five: Subsidence and Hydrological Environmental Impacts

3)  Environmental impact of processing. There are two methods for rendering the 3% copper (predicted grade ore at Resolution mine) from the general ore:

            1)  Electro-winning is a method of dissolving copper ore with sulfuric acid, then electroplating it to 99% pure copper. The positive aspect is that it creates less waste than the second method; however, only certain better grades of oxide ores can be processed with Electro-winning. The drawback is the sulfuric acid is stored in open ponds where any animal or bird unfamiliar with the territory would be dissolved instantly.

Further, although these ponds are lined, human and machine errors do occur. In 2002 at the ASARCO Silver Bell operations outside of Tucson, 242,000 gallons of sulfuric acid were released to the environment when a pond was inadvertently overfilled. Further, the caustic nature of sulfuric acid makes the pipes and equipment subject to breaks and leaks.

For details, see Attachment Six: Environmental Impact of Sulfuric Acid Leaching

            2)  Flotation is the method used for lower grade, or sulfide ore. Toxic chemicals are used in the Flotation Process to separate the copper and molybdenum out of the milled powder. This Flotation process is the major extraction method at Duval/Sierrita mine because of the poor quality of the copper at this site. Some chemicals produce bubbles that that the copper adheres to and the "bad stuff" falls to the bottom. At this point, the unwanted minerals, salts and processing chemical residues are piped over to a tailing impoundment.

The concentrate is then smelted in order to separate the various metals and purify them. The smelting process also potentially introduces contaminants into the environment. It is noteworthy that at the historical mining sites in Arizona, the smelter was placed near the Latin town.

For details, see Attachment Seven: Environmental Impact of Flotation

There is particular concern because Resolution Copper was formed by BHP Billiton and Rio Tinto Mining Companies. Both of these companies vie as the worst polluter of the environment—world wide.

For details, see Attachment Eight:  Rio Tinto Environmental Record

For details, see Attachment Nine: BHP Billiton Environmental Record

Further, Rio Tinto is the parent company of Kennecott, a company that has created the largest toxic plume in the U. S.

For details, see Attachment Ten: Kennecott Clean-up

In closing, I would like to share with you an open letter from a resident of Superior and a former miner at the Magma mine.

See Attachment Eleven: Open Letter