Rosemont’s commitment to implement our identified conservation mitigation measures—which are part of the proposed action for NEPA and Section 7 consultation purposes—is not dependent on whether the Corps regards them as appropriate mitigation. As you are aware, the standards for mitigation under the Corps’ regulations are intended to address impacts to waters of the United States caused by the discharge of dredged or fill material. Rosemont has committed to implement additional conservation measures to reduce and offset project impacts that in no way depend on what the Corps may decide. All of these commitments are of course contingent on issuance of the Record of Decision and approval of the Mine Plan of Operation.
Hudbay Minerals. 2016c. Clarification of Conservation Property Commitments. In Letter from Katherine Ann Arnold, Director, Environment, Hudbay Minerals, to Kerwin Dewberry, Forest Supervisor, Coronado National Forest. Tucson, Arizona: Hudbay Minerals. March 18.