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Our comments in response to Hudbay’s Aquifer Protection Permit to ADEQ are submitted!

Our comments in response to Hudbay’s Aquifer Protection Permit to ADEQ are submitted!

We are excited to finally be able to share our comments with you, which we hope will help you make informed comments in response to Hudbay’s Aquifer Protection Permit to ADEQ.


You’ll see in our cover letter at the top of the comment document that 13 other organizations signed our comments!


As we’ve mentioned in prior newsletters, SSSR has hired three experts in hydrology and mining to produce our organizational comments. This document includes the comments that SSSR will file with the Arizona Department of Environmental Quality concerning the Copper World draft Aquifer Protection Permit (APP).  


Our comments reflect in-depth review and analysis of the APP by four PhD scientists and engineers: Ann Maest (hydrogeochemistry), Laurel Lacher (hydrogeology and groundwater modeling), David Chambers (mining engineering and geophysics), and Stan Hart (geochemist). You will see that we also attached to our comments the excellent comments previously submitted to ADEQ by Pima County because they covered some points in ways that we did not.


The document is organized as:

  1. Brief biographical sketches of the four experts

  2. an executive summary

  3. the experts’ four reports.

  4. Pima County’s previously-submitted comments


The Executive Summary presents key findings, which are subsequently detailed in the following four reports provided by the four experts. Note that each paragraph in the Executive Summary refers to a particular expert’s report for substantiation and additional detail.


Thank you to everyone who has submitted comments. If you haven't already, or want to submit additional comments, we hope that sharing our comments will be helpful for you.


Read our comments here.


Learn more about the ADEQ permit here and submit your own comments by April 10.

If you have not yet submitted your comments or would like to submit additional comments, you might emphasize.

  • Need for liners on all tailings piles

  • ADEQ should require current best practices, not those in a 20-year out-of-date BADCT manual.

  • Require a geochemical analysis of waste from the newly-proposed Albion process.

For additional ideas, refer to the Executive Summary in our comment letter.

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