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<br />with expertise in seismology, and should take place throughout the mining operation to detect <br />changes as the active mining location moves within the site. <br />In addition to vibration, removal of the top of the ridge creates a bare rock surface with all <br />the joints exposed. This presents an opportunity for precipitation to enter the fractures without a <br />clay seal from the soil cover. Some fractures will retain the water which could have considerable <br />head due to the height of the ridge. Water pressure in the joints can reduce the force of friction <br />holding fractured rock slabs in place and further enhance the likelihood of rock fall. <br />In summary, the natural fracturing of the Rollins sandstone has created a very unstable <br />cliff face that could be disturbed by vibrations from a rods crusher, heavy equipment, or the <br />mining operation, and poses a direct threat to life and property for residences below the cliff. 1 am <br />requesting that the Division of Minerals and Geology protect local residents from undue risk from <br />off-site impacts by denying the State Reclamation Permit for the Benson Brothers Red Shale <br />Mine in Coalby Valley. <br />Due to misleading descriptions and documents filed with the application, it may be <br />difficult for Division of Minerals and Geology personnel to recognize the proximity of homes to the <br />cliff as described above. The applicant has attempted to portray the surrounding land use as old <br />coal mines and a few ranches, but the facts are there are no coal mines in operation, and there <br />are 21 residences within %. mile of the proposed Benson Quarry boundary. This is a rural <br />residential area that has grown up since the coal mines closed 20 years ago. The maps <br />submitted with the application are so outdated they do not show most of the residences in the <br />area. Thus I request that Division of Minerals and Geology personnel require that up to date <br />information be supplied with the application, and that the misleading description of surrounding <br />land use from 20 years ago be updated to define current usage. This will aid in evaluation of the <br />claims made in this letter. <br />If Division of Minerals and Geology personnel would like to visit the site with me 1 would <br />be happy to show them the hazards I see, the joint sets described in this letter, and the property <br />at risk from this proposed mining operation in the middle of a rural residential neighborhood. <br />Sincerely, <br />~~ ~ <br />Gregory D. Lazear <br />Figure 1 <br />Down <br />Figure 2 <br />Distribution of Fracture Trends <br />