Demand full review of Roca Honda's 366-acre, 21-year mine plan
Roca Honda Mine Project
U.S. Forest Service· Cibola National ForestU.S. Forest Service project page ↗
Forest ServiceWe track this on the agency’s own system of record, where most on-the-ground decisions live.
The groups on this fight
4 groups predicted likely to care in New Mexico
Predicted likely to care is a guess from footprint in New Mexico, by the same match the STAND matchmaker runs, with no link to this decision. Give straight to them; nothing routes through us.
- Greater Chaco Coalition
Predicted likely to care · a guess
Works New Mexico: the coalition of Diné and Pueblo communities fighting drilling around Chaco.
- New Mexico Wild
Predicted likely to care · a guess
Works New Mexico: led the community campaign for the 2014 designation and executive director Mark Allison spoke at the June 2025 Las Cruces rally against monument reductions and the Senate public land sell-off provisions.
- San Juan Citizens Alliance
Predicted likely to care · a guess
Works New Mexico: the San Juan Basin watchdog on the ground in greater Chaco.
- WildEarth Guardians
Predicted likely to care · a guess
Works New Mexico: serial litigant over greater Chaco drilling permits.
Every group above is on STAND for Public Lands, with its court record, its filings and who backs it.
The Forest Service is scoping a 21-year underground uranium mine that would disturb about 87 acres of national forest and 279 acres of additional state and private land, with only 30 days for public comment.
What’s at risk
The project would except the Cibola National Forest Plan's protective desired conditions for tribal, cultural, and water resources, but the agency has not yet said which specific protections will be waived. Treated mine wastewater would discharge into a non-perennial segment of the Rio San Jose, and the water treatment plant would keep operating throughout the mine's full life, with reclamation not finished until about six years after mining ends.
If this goes through
A draft EIS is expected in July 2027 and a final EIS in January 2028, setting in motion a mine with roughly 21 years of construction, production, and closure activity. The decision also triggers a Forest Plan amendment and permitting by BLM, EPA, and New Mexico agencies, locking in the project's scope well before most of the substantive analysis, including the plan amendment's specifics and full range of alternatives, has been defined.
Our plain-English read of the official notice ↗. Check it against the agency’s own words below.
By the numbers, from the agency’s own document
- National Forest System land disturbed
- approximately 87 acres
- State and private land disturbed off NFS
- approximately 279 acres
- Total project lifespan vs. years of actual mining
- 21 years total, 11 years production
- Public scoping comment period length
- 30 days
Proposed Activities
Open the document ↗“approximately 87 acres of disturbance for dewatering wells, vent shafts, dewatering influent pipelines, development drilling, utility corridors, access roads”
Proposed Activities
Open the document ↗“resulting in approximately 279 acres of additional disturbance off NFS lands”
Plan of Operations
Open the document ↗“The estimated lifespan of the Project is approximately 21 years, of which 11 years would be mineral production”
SUMMARY
Open the document ↗“This notice announces the beginning of a 30-day comment period to solicit comments and identify issues”
Each figure is checked word for word against the decision document ↗; open a label to read the sentence it comes from and the document it’s in.
The agency’s own analysis
What the notice says, and what it leaves out
The strongest findings read from the agency’s own document, each quoted word for word. Each one is a point a letter can put on the record.
Substantive Provisions of Forest Service 2012 Planning Rule Directly Related to Potential Plan Amendment
The agency says
“except the project from certain desired conditions related to tribal, cultural, and water resources to provide consistency with the Cibola National Forest Land Management Plan”
The Forest Service says the project will need a Forest Plan amendment to exempt the mine from existing protective 'desired conditions' covering tribal, cultural, and water resources, but admits it has not yet decided which specific plan components will be waived.
List of Substantive Issues and Expected Impacts
The agency says
“local air quality, in particular, exposure of the public to radioactive radon gas vented from mine shafts”
The notice lists 'exposure of the public to radioactive radon gas vented from mine shafts' as a substantive issue to be evaluated, but the scoping notice gives no baseline radon data, no monitoring commitment, and no distance-based risk information for the community of San Mateo, located about three miles from the project.
Plan of Operations
The agency says
“Some Section 17 surface facilities, particularly the water treatment plant, would remain operational throughout the life of the mine”
The Plan of Operations states that the water treatment plant on Section 17 'would remain operational throughout the life of the mine,' while full site reclamation is not completed until roughly six years after mining ends.
Proposed Action
The agency says
“which will be discharged into a non-perennial segment of Rio San Jose, in the town of Milan, New Mexico”
The proposed action discharges treated mine wastewater into 'a non-perennial segment of Rio San Jose,' meaning the receiving stream does not flow year-round, yet the notice does not explain how a non-perennial channel will assimilate continuous treated discharge during dry periods or what that means for downstream water users.
Alternatives
The agency says
“Other alternatives to be considered in the EIS are expected to be variations of mine and facility configuration based on resource issues identified through the public comment process”
The notice says other action alternatives are merely 'expected to be variations of mine and facility configuration based on resource issues identified through the public comment process,' with no criteria, no defined range, and no agency-proposed resource-protective alternative.
10 holes in the agency’s own analysis
Make these points, in your own words
- I oppose this action as proposed, and I ask the agency to weigh the specific harms below.
- The Forest Service says the project will need a Forest Plan amendment to exempt the mine from existing protective 'desired conditions' covering tribal, cultural, and water resources, but admits it has not yet decided which specific plan components will be waived. The public is asked to comment on scope now without knowing which tribal, cultural, or water protections the agency intends to override. The agency should identify the specific desired conditions to be excepted before or during scoping so the public can meaningfully weigh in.
- The notice lists 'exposure of the public to radioactive radon gas vented from mine shafts' as a substantive issue to be evaluated, but the scoping notice gives no baseline radon data, no monitoring commitment, and no distance-based risk information for the community of San Mateo, located about three miles from the project. The agency should analyze quantified radon exposure risk to nearby residents and disclose vent shaft locations relative to homes before the draft EIS is finalized.
- The Plan of Operations states that the water treatment plant on Section 17 'would remain operational throughout the life of the mine,' while full site reclamation is not completed until roughly six years after mining ends. That means treated wastewater discharge to the Rio San Jose could continue for well over a decade beyond the 11-year production window, yet the notice gives no total discharge duration or long-term water quality analysis. The agency should quantify the full multi-decade discharge timeline and its cumulative water quality effects.
- The proposed action discharges treated mine wastewater into 'a non-perennial segment of Rio San Jose,' meaning the receiving stream does not flow year-round, yet the notice does not explain how a non-perennial channel will assimilate continuous treated discharge during dry periods or what that means for downstream water users. The agency should directly analyze the effects of continuous discharge into an intermittent stream on downstream water quality, quantity, and aquatic life.
Show every point from the document
- The notice says other action alternatives are merely 'expected to be variations of mine and facility configuration based on resource issues identified through the public comment process,' with no criteria, no defined range, and no agency-proposed resource-protective alternative. This leaves the alternatives analysis undefined and reactive rather than agency-driven. The agency should develop and disclose a genuine range of alternatives, including one that reduces water and surface impacts, rather than waiting on public comments to define the range.
- Ore-bearing material from the mine would be hauled entirely by truck across state lines to the White Mesa Mill in Blanding, Utah, yet the notice gives no truck trip counts, no haul route analysis, and no discussion of radiological or transportation safety risk along that corridor despite listing community health and safety as an issue. The agency should quantify truck trips and analyze transportation and radiological safety impacts along the full haul route to Utah.
- The notice discloses that a draft EIS was already published on this project in 2013, but the current proposal discards that analysis entirely and restarts as a brand-new project without explaining what data, studies, or baseline information from that prior effort will be carried forward. The agency should explain what 2013 analysis and data will be incorporated rather than treating years of prior study as if it never happened.
- Tribal and traditional communities and uses appear only as one bullet in a long list of substantive issues, with no detail on which tribes are affiliated, the status of government-to-government consultation, or how the decision to except tribal-resource desired conditions in the plan amendment was reached. The agency should disclose the status and scope of tribal consultation to date and explain the basis for waiving tribal-resource protections.
- The agency has set only a 30-day scoping comment period for a multi-jurisdictional underground uranium mine spanning National Forest, BLM, state, and private lands with an estimated 21-year lifespan and at least a dozen required permits from multiple state and federal agencies. That window is short for the public to identify the full range of issues on a project of this complexity. The agency should extend the scoping comment period to give the public adequate time to review.
- The notice states the project's administrative objection process 'may be subject to' a revised 36 CFR 218 rule that has not yet been finalized, creating uncertainty for commenters about which review process will ultimately govern their right to object. The agency should clarify definitively which administrative review process applies before the close of the comment period so commenters know how to preserve their objection rights.
- Say something only you can say. The law requires the agency to consider and respond to substantive comments, and specifics are what make a comment substantive.
In the agency’s own words
Proposal submitted by Roca Honda Resources LLC on and near Jesus Mesa to conduct developmental drilling, develop infrastructure and construct access roads on NFS lands. These activities will support the underground uranium mine and water treatment plant proposed on adjacent state and private lands.
On the record for this fight
5 people have filed on this fight through PLAN. The official record is still catching up.
- Al, California36 seals
- Daniel T., Arizona14 seals
- Karen W.49 seals
- and 2 more stewards
Ranked on letters found on the agency’s record, then letters filed. Readers appear as first name and last initial, or as a steward in their state; switch yours off in your record. All boards
Did the agency answer?
10 issues are on this record. The agency has not published its decision document yet, so each one stays pending until the agency answers.
Issues on the record, awaiting the decision
- PendingThe notice states the project's administrative objection process 'may be subject to' a revised 36 CFR 218 rule that has not yet been finalized, creating uncertainty for commenters about which review p
The notice states the project's administrative objection process 'may be subject to' a revised 36 CFR 218 rule that has not yet been finalized, creating uncertainty for commenters about which review process will ultimately govern their right to object. The agency should clarify definitively which administrative review process applies before the close of the comment period so commenters know how to preserve their objection rights.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe notice lists 'exposure of the public to radioactive radon gas vented from mine shafts' as a substantive issue to be evaluated, but the scoping notice gives no baseline radon data, no monitoring co
The notice lists 'exposure of the public to radioactive radon gas vented from mine shafts' as a substantive issue to be evaluated, but the scoping notice gives no baseline radon data, no monitoring commitment, and no distance-based risk information for the community of San Mateo, located about three miles from the project. The agency should analyze quantified radon exposure risk to nearby residents and disclose vent shaft locations relative to homes before the draft EIS is finalized.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe Forest Service says the project will need a Forest Plan amendment to exempt the mine from existing protective 'desired conditions' covering tribal, cultural, and water resources, but admits it has
The Forest Service says the project will need a Forest Plan amendment to exempt the mine from existing protective 'desired conditions' covering tribal, cultural, and water resources, but admits it has not yet decided which specific plan components will be waived. The public is asked to comment on scope now without knowing which tribal, cultural, or water protections the agency intends to override. The agency should identify the specific desired conditions to be excepted before or during scoping so the public can meaningfully weigh in.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe Plan of Operations states that the water treatment plant on Section 17 'would remain operational throughout the life of the mine,' while full site reclamation is not completed until roughly six ye
The Plan of Operations states that the water treatment plant on Section 17 'would remain operational throughout the life of the mine,' while full site reclamation is not completed until roughly six years after mining ends. That means treated wastewater discharge to the Rio San Jose could continue for well over a decade beyond the 11-year production window, yet the notice gives no total discharge duration or long-term water quality analysis. The agency should quantify the full multi-decade discharge timeline and its cumulative water quality effects.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe proposed action discharges treated mine wastewater into 'a non-perennial segment of Rio San Jose,' meaning the receiving stream does not flow year-round, yet the notice does not explain how a non-
The proposed action discharges treated mine wastewater into 'a non-perennial segment of Rio San Jose,' meaning the receiving stream does not flow year-round, yet the notice does not explain how a non-perennial channel will assimilate continuous treated discharge during dry periods or what that means for downstream water users. The agency should directly analyze the effects of continuous discharge into an intermittent stream on downstream water quality, quantity, and aquatic life.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe notice says other action alternatives are merely 'expected to be variations of mine and facility configuration based on resource issues identified through the public comment process,' with no crit
The notice says other action alternatives are merely 'expected to be variations of mine and facility configuration based on resource issues identified through the public comment process,' with no criteria, no defined range, and no agency-proposed resource-protective alternative. This leaves the alternatives analysis undefined and reactive rather than agency-driven. The agency should develop and disclose a genuine range of alternatives, including one that reduces water and surface impacts, rather than waiting on public comments to define the range.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingOre-bearing material from the mine would be hauled entirely by truck across state lines to the White Mesa Mill in Blanding, Utah, yet the notice gives no truck trip counts, no haul route analysis, and
Ore-bearing material from the mine would be hauled entirely by truck across state lines to the White Mesa Mill in Blanding, Utah, yet the notice gives no truck trip counts, no haul route analysis, and no discussion of radiological or transportation safety risk along that corridor despite listing community health and safety as an issue. The agency should quantify truck trips and analyze transportation and radiological safety impacts along the full haul route to Utah.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe notice discloses that a draft EIS was already published on this project in 2013, but the current proposal discards that analysis entirely and restarts as a brand-new project without explaining wha
The notice discloses that a draft EIS was already published on this project in 2013, but the current proposal discards that analysis entirely and restarts as a brand-new project without explaining what data, studies, or baseline information from that prior effort will be carried forward. The agency should explain what 2013 analysis and data will be incorporated rather than treating years of prior study as if it never happened.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingTribal and traditional communities and uses appear only as one bullet in a long list of substantive issues, with no detail on which tribes are affiliated, the status of government-to-government consul
Tribal and traditional communities and uses appear only as one bullet in a long list of substantive issues, with no detail on which tribes are affiliated, the status of government-to-government consultation, or how the decision to except tribal-resource desired conditions in the plan amendment was reached. The agency should disclose the status and scope of tribal consultation to date and explain the basis for waiving tribal-resource protections.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe agency has set only a 30-day scoping comment period for a multi-jurisdictional underground uranium mine spanning National Forest, BLM, state, and private lands with an estimated 21-year lifespan a
The agency has set only a 30-day scoping comment period for a multi-jurisdictional underground uranium mine spanning National Forest, BLM, state, and private lands with an estimated 21-year lifespan and at least a dozen required permits from multiple state and federal agencies. That window is short for the public to identify the full range of issues on a project of this complexity. The agency should extend the scoping comment period to give the public adequate time to review.
A hole PLAN found in the agency’s own analysis, quote verified against the document
The reporting behind this
From More Than Just ParksAnother foreign mining company wants a piece of America’s public lands. This one comes with millions of gallons of groundwater pumping and radioactive radon.
It’s referred to as Unit 346 in the Twin Mountain II Timber Sale. On the ground, it’s some of the most spectacular old growth we’ve ever witnessed, and it’s marked for clearcutting.
To document and do our part to save America’s greatest old growth forest
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