Dear Editor,

We are residents of Clear Creek Canyon. We only recently became aware of expansion plans for the Frei Quarry in Clear Creek Canyon.

We are strongly opposed to the proposed Frei Quarry expansion, which will nearly double the quarry footprint to approximately 750 acres.

We are neighbors to the Quarry, some living less than a mile away as the crow flies. Many of us reside on the southwest side of Douglas Mountain, directly facing the quarry. Our lives are impacted daily by the Frei Quarry.

It is our understanding that only one objection to the expansion has been registered.

We submit the lack of objections is not due to lack of concern; it is simply the result of inadequate and antiquated public notification requirements. There has been little to no outreach by Frei. Hence, there is a general lack of awareness in the impacted communities.

We fear the Frei location in a remote corner of Clear Creek, Gilpin and bordering Jefferson County hides the project from public awareness and dilutes regulatory oversight. Douglas Mountain, Clear Creek Canyon, and Golden Gate Canyon residents and users have just now become aware of expansion plans and are extremely concerned.

Some observations of past performance are alarming:

Outside Permit Boundary: We understand that the MLRB (Mine Land Reclamation Board) has allowed the Frei Quarry to perform mining activity outside the permit boundary.

Fines Dump Over Limit: The Frei Gilpin Waste Fines Dump may not have been properly regulated over the last 14 years and such lack of regulation has caused poor air quality, stream degradation, visual impact, potential wildlife hazards due to the “angle of repose placement of the fill,” and general mismanagement of the area. Gilpin County placed several stipulations on the use of the site which appear not to have been adhered to. Currently, at approximately 44 acres the Fines Dump far exceeds the allowed 12 acres unreclaimed disturbed area; it has not been managed per MLRB recommendations.

Dust Pollution: Dust from the fill area has been a constant issue for at least 14 years. The SUR clearly states “All fill surfaces left fallow beyond two weeks shall be stabilized.” The canyon acts like a wind tunnel, at times launching a cloud from and over the quarry as it then creeps down the canyon. As the cloud of particulate blows east into the metro area, the health impacts, we suspect, are more widespread.

Waste Plan? How will Frei accommodate future waste? It is estimated that they have produced over 6 million cubic yards of stored waste in the last 14 years. To date they have failed the community and the environment in terms of dust and erosion management.

Environmental Damage: Sediment oozes from the Frei site on all sides and in all directions. Trucks track it onto the highway. Slopes have washed out and failed. Relying on Frei’s own numbers, the Fines Dump has maxed out while it is still eroding, only sporadically covered with weeds. It has previously failed and washed into North Clear Creek.

With every weather event, the un-reclaimed Frei Fines Dump still pours gray silt into lower North Clear Creek (Gilpin County) undetected and unreported, and then into the waters of Clear Creek proper (Jefferson County), thence to Golden, the Front Range, and Denver.

Meaningful Reclamation? The very minimal amount of revegetation activity performed over the last several years does not bring the landforms back to an acceptable visual standard, as evidenced by the views from I-70 and Highway 40, as well as Highway 6 through Clear Creek Canyon.

According to the expansion plan, Frei is asking to increase the slope of the existing highwall. While that may be a benefit to Frei as it will remove the need to revegetate in the future, is this the right thing for the visual impacts, for erosion and pollution of the air and streams?

Future concerns resulting from the expansion of the Frei Quarry are many, including and not limited to:

Safety, environmental and economic impacts to recreational resources. For example, millions are being invested in the Peaks-to-Plains Trail that parallels Clear Creek and Highway 6. This is being negatively impacted by the continual noise down the canyon from the current 300-400 trucks per day. Hikers, fishermen, bicyclists, rafters ,and rock climbers are all impacted.

In our opinion, the Frei Quarry expansion poses additional threat to Clear Creek, a natural wild brown trout fishery that is valued by Front Range anglers, tourists, trout stream conservationists, and Colorado Parks and Wildlife.

The heavy wash from the Frei “fines” dumping slope reached the North Fork of Clear Creek about seven years ago and to the best of our knowledge has never been repaired, addressed, or tested for heavy metals. The murky tailings waste still drains downstream into the main stem of Clear Creek in Jefferson County.

The proposed expansion will create large volumes of waste dump material. Where is this going to be dumped? Who will regulated it?

Does the expansion consider the safety of the many users, human and animal, of the Clear Creek corridor? There is concern regarding the slope stability in the area. For example, the expansion area is designed to have 0.6:1 slopes, which appears to be pushing safety boundaries. The proposed Frei reclamation will not be sustainable for the short term, let alone “forever.”

The existing Frei Quarry is considered to have a very large “disturbed’ area for a single mine. In our opinion as residents, visually this is unacceptable. More importantly, the dust that is generated from this mining method is assuredly a health hazard. The proposed expansion increases the disturbed area and their plan states that they will continue to keep the current mine area open as well as expanding. In total, they will likely more than double the disturbed area.

Frei’s plan states that the near vertical mine walls that they will be creating will be future habitat for Bighorn Sheep. Regardless of any study that they may have performed, isn’t it obvious that Frei simply designed the expansion to maximize the minable quantity? We have 20-plus miles of Clear Creek canyon that is part of the existing Rocky Mountain Bighorn Sheep Habitat. There are ample cliffs and plenty of habitat in its natural form.

The Floyd Hill Trail Master Plan identifies the expansion area as Winter Concentration area for bighorn sheep. To say that Frei is creating additional habitat is seemingly disingenuous and misleading. Instead of creating more habitat in its natural form, the opposite seems to be true: wildlife is pushed out into a narrower canyon habitat, already busy with human activity.

We must ask the question: what benefit are Clear Creek and surrounding counties and their residents deriving from this proposed expansion? How can any amount of tax justify the destruction of an area in such close proximity to a recreational gem such as the already truck-congested Clear Creek corridor? From our layman’s point of view, this plan would appear to be extreme engineering by any measure. Why is it necessary?

Understanding that traffic is not something within the jurisdiction of DRMS regulation, it is nonetheless an issue important to all who use the canyon. Perhaps you can and even should consider that in addition to all the current traffic, including 300 to 400 rock-hauling trucks per day, the canyon is already overwhelmed with traffic and its impact. Trucks have turned a greenway to an industrial zone. This two-lane Highway 6 was never designed for heavy truck volume/heavy load traffic and is already congested with a dangerous mix of trucks, buses, and personal vehicles.

Beyond traffic impact, the Frei Quarry expansion will also:

Increase road damage, requiring more frequent repair. Much of Highway 6 was resurfaced some 3 years ago and it is now under a major repair and improvement effort by CDOT at a cost of over $20 million. We contend that much of the road damage is directly attributable to the volume of heavy rock-hauling trucks from the quarry.

Cause additional pollution. Not only does the canyon act like a wind tunnel, ideal for distributing the dust from the quarry; the canyon also amplifies blasting/echoing noise up the canyon, disturbing both man and beast. The use of jake brakes is common and especially annoying.

In conclusion and in consideration of our testimony, we are vehemently opposed to the expansion of the Frei Quarry. Thank you for your consideration. If additional information or clarification is required, please contact Tim or Mary Preister.

Tim and Mary Preister

Dennis and Martie Fast

Golden