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precipitation into exposed bedrock joints during excavation of the top of the ridge. The <br />entire hearing process has been fixated on only the first source while the other two have <br />been completely neglected. From the beginning there has been no logical plan to establish <br />what studies are appropriate, why they are appropriate, how their results will be used in <br />the hearing process, and whether all aspects of the rockfall risk have been addressed. <br />Instead ad hoc studies have been required that have no clear purpose, and whose results <br />have no clear bearing on resolving concerns. In addition, these studies have been <br />conducted without technical oversight and without rigorous standards to assure they <br />satisfy their objectives. Since vibration amplitudes are only relevant to one of the three <br />contributing sources to rockfall risk, the other two major factors have not been addressed. <br />Yet all risk of rockfall has been dismissed with no rational justification provided. After a <br />lengthly hearing process the MLRB has failed to address citizen concerns, the potential <br />risk of rockfall damage to adjacent homes from the three sources is still unknown, and no <br />mitigation of these potential risks has been required in the permit. What was the point of <br />this process? <br />When we initiated the process of filing our concerns with the State and setting up <br />a hearing with the MLRB we fully expected our concerns regarding rockfall risk to be <br />addressed factually and scientifically through a cooperative effort with geotechnical staff <br />of the Division of Minerals and Geology (DMG). We expected that geotechnical studies <br />would be done by the staff, or by an unbiased and qualified consultant, to evaluate the <br />rockfall hazard at the site, and that the MLRB would impose restrictions on the mining <br />permit to mitigate the risk to adjacent homes if they were deemed necessary. What <br />actually ensued was very different from these expectations. The requirement of token <br />studies that were inappropriate to address concerns, the uncritical acceptance of <br />unprofessional work and illogical conclusions, the disregard for expert opinion in the <br />science, and the strong bias shown by the DMG staff all give the strong appearance of <br />corruption. <br />I am requesting that the MLRB and the DMG staff be required to consider all <br />aspects of our concerns, and to resolve these issues legitimately, logically, and <br />scientifically using methodologies accepted by experts within the science. I wish to see a <br />peer review of our concerns by independent geoscientists, who can examine the hearing <br />process and the studies required by the DMG staff to give a judgment regarding the <br />relevance of the studies conducted, the technical merit of the studies, and whether our <br />concerns for rockfall risk from all sources have been adequately addressed. <br />Sincerely, <br />Greg Lazear <br />Geophysicist