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sEP-07-2006 05:15PL1 FROlMDIV RECLAlM'~nN t71NING & SAPETY 3038328102 7-108 P.003/D05 P-2B5 <br />Having summarized my perspective on the proposed monitoring program, I would <br />also like to take this opportwrity to express concems that I have regarding, Mr. Revey, <br />and the role of the DMG staff. <br />When we attended the pre-hearing conference in Cedaredge, Colorado to arganize <br />the agenda for the formal hearing on May 10,2006 in Denver, we were told by Assistant <br />Attorney General Tyson Powell that the purpose of the formal hearing was to "get to the <br />truth" regarding our concerns. One of the major concerns brought forth was Ure potential <br />for increased rockfall risk to properties south of the proposed quarry due to vibrations and <br />ground disturbance from the mining operation. In the next paragraph I examine the <br />"truth" that was provided at the hearing. <br />Prior to the hearing the DMG staffreviewed the Revey study, and information <br />and comments I submitted, and wrote their recommendation for approval of the permit <br />In their letter of recommendation, the only rational for their decision was based upon the <br />level of vibrations required to crack plaster lathe wnstruction. No analysis of the site, <br />analysis of fracturing of the cliff face, or analysis of impacts from exposing bedrock <br />fractures to direct infiltration by precipitation was provided or even mentioned. When I <br />raised these important factors at the hearing, the staff suddenly claimed they had all been <br />studied, but could provide no data, ao analysis, and ao evidence to support their <br />conclusions that these factors did not increase the risk of rockfall. Furthermore, I <br />personally studied the Rollins sandstone cliff, measured fractures, and submitted the data <br />to the staff of the DMG. In that letter I stated that I would be glad to take any interested <br />parties to the site and show them my concems, and the evidence for rockfall risk that I <br />found. No one accepted this invitation! Since the cliffs are on private land, and no staff <br />from the DMG requested permission to visit them, I must assume the staff has never <br />personally examined the situation. Details of the fracturing cannot be evaluated from <br />Ward Creek Road, or from Sherman Street in Denver. So the "tntth" provided to the <br />MI.RB consisted of the Revey Associates study of an unrelated site in unrelated geologic <br />formations, and alleged "qualitative" analysis of rockfall risk due to fracturing and water <br />filled joints by the DMG staff that was never made public, and was conducted without <br />ever personally examining the cliff face. I am left to wonder why the staff had no interest <br />in visiting the site with me to see first hand the concems that I have ? As a scientist, I am <br />not accustomed to conclusions being drawn without examination of the evidence. The <br />MLRB hearing left me with fire very strong impression that we were simply going <br />through the motions in order to pacify some NIMBY's, and the actual tick of damage to <br />property from rockfall was not taken seriously. I am very thankful, however, that at the <br />last minute, the staff saw fit to require at least some form of vibration monitoring at the <br />actual quarry site. My concern now is that this monitoring proposal has not been designed <br />to answer important questions, and may rum into another token study with no meaningful <br />and objective assessment of increased rockfall risk induced by the mining operation. <br />'ribs brings me to my concern regarding the involvement of Mr. Gordon Revey in <br />this monitoring proposal. My concems originated with the initial report by Revey and <br />Associates in which numerous technical errors were found, and in which the study of <br />vibrations at an unrelated site in Mancos shale was claimed to repzesent the seismic <br />