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PPTU Quarry Objection Letter, December 17, 2017

December 17, 2017


Ms. Amy Eschberger

Colorado Division of Mining and Safety

1313 Sherman St. Room 215

Denver, CO 80203


Dear Ms. Eschberger;

I am writing on behalf of the more than one thousand members of the Pikes Peak Chapter of Trout Unlimited and as the result of a unanimous vote of the Board of Directors to object to the application by Transit Mix Concrete Co.’s (TM) application (M2017-049) to establish a quarry on Hitch Rack Ranch.

The Pikes Peak Chapter of Trout Unlimited has a mission to Conserve, Protect and Restore the cold water fisheries and their environs in the Pikes Peak Region.

This application (M2017-049) fails to protect the cold waters of Little Turkey Creek and their environs in so very many ways and we will set out many of those failures in this objection letter.

The first failure of this application is simple, it fails to even mention the trout that exist currently in Little Turkey Creek as a form of wildlife present in the application area. Nor does in mention any of the other aquatic forms of wildlife. The trout and all of these aquatic life forms will require cold clean water at all times. This application discusses ground water but fails to adequately address the surface water and its quality. When it does discuss ground water, the solution of ground water entering the mine area is to simple dump it into the stream. No consideration is provided for water quality, changes in pH, temperature, chemistry and/or sediment. There is not data provided as to the presence or absence of heavy metals in the mine application area.  Based on the drawing contained within the application showing the horizontal mine boundary being proposed to be well below the current ground water level, the quantity of groundwater that will be required to be pumped will be far greater than  de minimis.

The topographical maps contained in the application clearly shows a steep incline from the proposed mine area to the stream. Just normal rainfall will result in materials disturbed by the proposed mining operation will easily wash to the stream at a much greater rate that currently occurs. The many acres of denuded ground will provide a ready source of sediment materials to wash into the stream. Water studies performed in the area show sediment to be the greatest threat to stream populations of wildlife.  What studies are contained with in the application that support the idea that sediment from the  mine will be prevented from entering the stream with only a 100 foot margin between the edge of the proposed mine area and the stream? This application continually downplays the possibility of an increase in surface flow of water due to the mining operations however, no data from any study is included within this application so support such a conclusion.

The proposal also contains plans to build an access road close to the stream. This access road is planned to be heavily used by the TM trucks and this will add additional sediment to the stream. It also appears that the plan is to stock pile “Top Soil” in areas topographically above the stream again providing a source for additional sedimentation to enter the stream.

This proposal also includes the placement of fines in a stockpile located in a currently existing ravine. A ravine created by moving surface water down a slope. The placement of this fines stockpile in this location guarantees these fines washing into the stream even under normal rainfall conditions.

In addition to our concerns about the surface water and the maintenance of its quality and quantity we have a geologist on our board of directors who has reviewed the application.

Michele White, V.P. Government Affairs, Pikes Peak Trout Unlimited and Certified Professional Geologist with American Institute of Professional Geologists, #11252, and author on multiple NI 43-101 compliant technical mining reports for the Canadian and United States Stock Exchange Commissions expressed the following:

In consideration of proposing to create a high wall mine in the vicinity of multiple regional faults – the intersection of which are within the pit – their geotechnical study is seriously inadequate. The drill hole data is included, however no analysis of the results are included within the application.

The “geotechnical study in exhibit 6.5” solely addresses overburden and soil. The report includes two geotechnical maps, none of which show geology. The geotechnical study was conducted by a mining engineer and did not utilize a certified professional geologist. They did not present a study of the bedrock or the geologic structures. One map shows that a geophysical survey was performed but there is no summary of what the data means.

The slope stability model and mine design is 100% reliant on assuming that the bedrock is stable. Yet, no bedrock stability analysis was conducted. The presence of multiple faults that intersect with regional fault zones within the area of interest should provide reason to believe that the bedrock stability is highly suspect. The geotechnical study is inadequate for addressing very real geological hazards in this area.”

Where the application discusses a drilling program in 2015 and 2017, Michele writes:

“Details or summary of the drilling program are not provided, details such as how deep did they drill? What was the cohesiveness of the bedrock? Was there a geotechnical study of the bedrock in core? Did they collect rock:fractures ratio?”

The geotechnical report contained in the application states that the engineered design is based on the assumption that the bedrock is stable (static).

The soils stability model is based solely on the soil properties not the underlying bedrock. In addition it is 100% reliant on assuming that the bedrock is stable (static).

Michele White writes: The summary in the geotechnical report states that the model is not competent under changing conditions of ground water or material strengths (of bedrock).

It is my opinion that it is really irresponsible to design an open pit mine and overlook the bedrock and regional structures in evaluation of hazards.

In summary, this proposal overlooks the adverse affects of geologic hazards, which are probably imminent in consideration that they will be excavating and blasting proximal to structural intersections of regional faults. In this light, I have included my analysis of the core data included within the application and accompanies this letter. (Exhibit: Geotechnical Study M2017-049. It is my conclusion that the degree of intense fracturing, brecciation, and faulting of rock observed in core indicates that the area of interest is highly likely to experience significant failure of the high wall over time if the area is mined by open pit.

In general, PPCTU is greatly concerned this application only pays minimal attention to the issues around surface water, the increase in flow due to the mining operations and makes no plan to address surface water other than to dump it along with its sediment  into the stream. We have concerns about the lack of geological study and have included our own.  Further, we have a concern that the maps and drawings provided in this application appear to be inconsistent with the words of the application in many areas, including but not limited to the boundary for the pit relative to the stream. In addition a great number of claims and assumptions are not supported by credible data.

For the above reasons the Pikes Peak Chapter of Trout Unlimited opposes the granting of this mining application. (M2017-049)


Allyn J. Kratz