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• The experimental site is not analogous to the site of the proposed quarry with regazd <br />to geology, lithology, or topography. <br />• Data analysis procedures are questionable, producing regression curves that do not fit <br />measured data, and no statistical analysis of expected error, confidence levels, or <br />significance of fit are provided. <br />• No descriptions of field procedures, instrumentation, sensor calibration, or sensor <br />spectral response are provided. <br />• There is no discussion regarding the type of waves (compressional, shear, and <br />Rayleigh) produced by various equipment and their relative amplitudes and decay <br />rates. <br />• The analysis of simple harmonic motion in the Revey report does not account for <br />mechanisms that produce the highest amplitude ground motions such as wave guides <br />and natural resonance. <br />• There is no technical analysis using principles of rock mechanics or engineering, to <br />assess the risk that vibrations from heavy equipment could destabilize fractured <br />blocks in the Rollins sandstone cliff, and thereby threaten nearby outbuildings and <br />homes. <br />A more detailed explanation of these concerns is given in the following section. <br />ANALYSIS OF CONCERNS <br />1) The eaperimental site is not analogous to the site of the proposed quarry with <br />regard to geology, lithology, or topography. <br />The Austin site used for field testing is located in either unconsolidated <br />Quaternary deposits of sand and gravel, or in weathered Mancos shale which is fiiable <br />clay-rich marine shale that forms the "badlands" in the azea. Photographs in Attachment I <br />show the sensor and equipment in unconsolidated material. Yet the proposed quarry site <br />is about 10 miles north of the site of the experiment and consists of lithified sandstone <br />and shale of the Cretaceous Mesaverde formation. The "red shale" was formed by <br />burning coal seams that baked the neazby sandstone and shale beds and oxidized iron. <br />Layers of quartz cemented sandstone and baked shale aze interbeded, and the cemented <br />sandstone forms an overburden in portions of the site. In order to justify the choice of <br />experimental site, and its relevance to the proposed quarry location, the report should <br />provide data that shows materials from the two sites have similaz intrinsic and in-situ <br />elastic properties. This has not been provided, and in fact, the materials have very <br />different characteristics. Ripping of lithified bedrock at the proposed quarry site will not <br />produce the same seismic energy spectrum as pushing unconsolidated dirt with a dozer. <br />Considering the very different nature of the sedimentary rock, topography, and <br />