LETTER to Chaffee County Commissioners Regarding ACA/Holman Gravel Pit

Letter to Chaffee County Planning Commission and County Commissioners Regarding the Holman/ACA Major Impact Review for the Proposed RB Gravel Pit

Submitted by Cynda Green on May 15, 2017


I live in the City of Salida. I began researching this issue from a neutral position, but now have many concerns regarding the approval of the Holman/ACA application for the proposed RB Gravel Pit.

The application and supporting documents are open-ended and offer conflicting information. The Mountain Mail coverage adds to the confusion. For example, the trucks that will haul the gravel are simply referred to as “transport trucks”. What size are the transport trucks? How many trips? Documents estimate anywhere from 1100 annual round-trips to many multiples of that (Marcin Engineering).  There are varied estimates, and no caps in the Major Impact Review documents.

How many tons each year are to be extracted? Documents and media coverage range from 8,250 to 300,000 tons. Are expected hours of operation 8 AM to 5 PM or 7 AM to 8 PM? How many years of extraction are expected? I’ve read anywhere from 5 to 40 years. Frank Holman told me 30 years.

Even though the proposed RB Pit is just .4 miles from State Highway 50, and a portion of the Holman Family’s property is adjacent to Highway 50, CR 140 and CR 250 are the proposed routes to transport gravel. The County will be responsible for maintaining the roads once the pit is in operation. How much will that extra maintenance cost?

Tests have shown that one loaded 15 Ton Short Truck (a typical 10 yard gravel dump truck with dual axle – dual wheel – 4 tires per axle) does the equivalent damage to an asphalt road as 2,100 cars.

This study was based on tests done over many years by various Federal and State agencies and national standards agencies. All kinds of pavements and sections were tested and they noticed that the damage was different between rigid pavement (concrete) and flexible pavement (asphalt). Almost all of the Equivalent Single Axle Loading (ESAL) calculations and results are empirical which means the formulas were developed to match what they were actually finding in the tests.

See ATTACHMENT: Explanation of “Road Damage of One Fully Loaded Gravel Truck = 2100 Cars”.

The Holman/ACA  gravel pit application makes some claims that can not be substantiated. For example:

The change in land use (from grazing to surface mining) shall not cause any impacts to the surrounding area.

Opacity from the pit is limited to 20% so it will not cause any more dust than the current vacant land.

These claims, stated in absolute terms, give me pause as to how credible other aspects of the application and associated documents are.

It’s a fact that surface mining and transport of aggregates is a source of increased dust, silica and noise. That is why surface mining noise levels and dust levels are so heavily regulated. The question is, how much will dust and noise increase, and what distances will be affected? We know how windy it can be. The wind generally blows from the west, which would be toward the CR 140 corridor. Sound travels uphill and is also affected by the wind, according to a San Luis Obispo County (CA) Noise Analysis for a gravel quarry.

The answer is, we don’t know how much dust and noise will be generated by the proposed pit. The applicant has not invested in professional analyses of noise and dust impact in this particular location. It’s easier to make the claim that there would be no impact.

Here’s an example of what 20% opacity looks like, comparatively, in the case of smoke.

According to the Example of ACA Pit Permit with Opacity report in the ACA/Holman Major Impact Review, there are brief periods (6 minutes every 60 minutes) during certain phases of construction that allow for 30% opacity.

The following statements (some paraphrased with emphasis added) were taken from the Major Impact Review documents for the proposed RB gravel pit:

There is no intention to use explosives on this property.

Equipment used on site will include a loader, dozer, blade, excavator and water truck.

Processing equipment will include a generator, jaw crusher, cone crusher, conveyor belting and JCI screen.

There will be no concrete plant and no need for equipment washing. There is also no asphalt plant planned for permitted area.

Crushing activities will take place for approximately one month during the winter… the material that is being crushed has a high plasticity index and will have a high moisture content, therefore, it will only emit minimal dust or particulates…. there will be no water or chemicals used in this processing… (There also is no mention of enclosing the crusher in housing, so we must assume that the crusher will be out in the open, with no water or chemicals to dampen the impending dust.)

Instead of linking to a MSHA (Mine Safety and Health Administration) document, the document “MSHA Guide for Noise Control” links to “Decibel Trivia” and a decibel comparison chart posted by Hearing Education and Risk for Rockers. My hunch is that they are talking Zeppelin and Zappa, not gravel.

Applicant ACA Products did scribble some MSHA noise exposure levels on the Rocker info sheet. Acceptable MSHA levels are less than a piano fortissimo, which is rated at 92-95 decibels. Neither stone crushers nor other surface mining equipment are rated on the Decibel Trivia Chart for Rockers, so what is the point, other than to trivialize the noise nuisance of a gravel pit?

Another major concern is the gentrification of the CR 140 corridor.

Both the State and Chaffee County are aware of the important role of road base aggregate for road building and road maintenance. Conservation and development of significant mineral deposits should be a high priority, and should be balanced with other County general plan goals and policies, and with other natural resources and existing adjacent uses.

As far as I can tell, Chaffee County planning for extraction mining is and has been non-existent. The best example of this is the lack of priority given to Mining Resources in the latest (2000) County Comprehensive Plan. To quote the Purpose of the Plan:

The Chaffee County Comprehensive Plan is a response to issues that have arisen as a result of increased growth and development the County has seen in the past few years. While the primary focus of the plan is land use and the impact growth will have on land use decisions, there are many different areas (such as housing, and community facilities) that are also effected. The plan is comprehensive in that it covers an entire geographic planning area, and all the functions that make a community work including:

Land Use
Community Character
Open Space/Agricultural Land
Natural/Cultural Resources
Affordable Housing
Community Facilities
Economic Development

The plan is a guide for decision-makers, whether they are Chaffee County Commissioners, the County Manager, County Planning Staff, and officials of the various County municipalities. It proposes goals, objectives, and implementation steps that address the issues embedded within each of these planning areas. Given the amount of public participation, the goals, objectives, and action steps are all designed to achieve the desires of County residents. While reflecting social and economic values, it guides the physical development of the County by addressing land use, open space, and density issues.

Mining Resource planning is not on the planning list. The emphasis in this plan appears to be, for example, attracting more and wealthier tourists, passive and active recreation, preserving scenic vistas for both residents and tourists, open space and wildlife habitat preservation, and preserving the “rural and scenic atmosphere”.

Apparently planning for a future road base source (gravel pit) didn’t quite fit in the 2000 Comprehensive Plan.

In fact, the word “extraction” is mentioned just four times in the Comprehensive Plan and supporting documents. The first mention is on page 31:

Review the county’s zone districts to modify the number of commercial uses that are allowed in rural areas through the special permit process. Allow only those uses that have an obvious need to locate in such areas such as certain resorts/dude ranches, commercial rafting, and resource extraction activities.

The second mention is in the Definitions section of the Comprehensive Plan:
Development: Substantial property improvement and, usually, a change of land use within a site. The act of using land for building, extractive, and/or agricultural purposes.

The third mention is a question in the Planning Survey that was used as a guide for the 2000 Comprehensive Plan:

How do you feel about each type of future economic development in your area of Chaffee County?
Resource Extraction (mining and timber) was one of the many activities rated by the survey-taker.

The final time the word “extraction” is used is in the (May 1997) Planning Survey Executive Summary:

Citizens expressed significant support for economic development strategies based on passive recreation (e.g., fishing, hiking, showshoeing) and ranching/agriculture. Heavy industrial growth, real estate development, correctional facilities, and resource extraction were at the bottom of the list.

Compare the Comprehensive Plan’s snubbing of planning for resource extraction to its extensive discussion (page 24-25) of airports and their surroundings. Here’s an excerpt:

Of concern to the county airport commission is the national trend for incompatible residential growth to envelope airports. Residents then predictably mount campaigns to limit operations or close the airports due to noise and safety concerns.

Let’s change “airports” to “surface mining”.

Of concern to the county commission is the national trend for incompatible residential growth to envelope surface mining areas. Residents then predictably mount campaigns to limit operations or close the surface mine due to noise and safety concerns.

Significant mineral resources, because of their importance to our County, should be protected from incompatible land uses that threaten their availability for future mining. Unfortunately, Chaffee County has not protected the proposed RB Gravel Pit from incompatible land uses. So now we have this predictably ugly and divisive scenario:

Chaffee County could certainly use a new source of gravel that works well with our magnesium chloride road maintenance program. The proposed RB Pit apparently fits that description. But there was no County plan to protect the Holman property from nearby land uses that are incompatible with surface mining. A lack of land use planning has, you might say, undermined the RB Pit as a future source of gravel.

The area has, in fact, been gentrified. The upscale Weldon Creek subdivision would be severely impacted by the RB Pit. Eureka Ranch is close as well. The CR 140 corridor and CR 250 would also be affected. Most of these residents, including some long-time ranching families, oppose the RB Pit .

If you travel down CR 140, you will see that there many expensive homes along the CR 140 corridor:

This property is at the corner of CR 140 and CR 250, where the gravel transport trucks would evenly split between the two roads.

If you turn your head and look up into the hills that rise above CR 140, you will notice expensive homes on ridges. If you travel some of the roads off of CR 140, you’ll see more expensive homes. Million dollar properties. Retirement homes. Second homes.

Why are there so many expensive homes along the CR 140 corridor – a corridor that, many years or decades ago – might have been compatible with a gravel pit? It wasn’t by accident, but rather by intent. The valley is beautiful, with a mountainous backdrop, including Mt. Shavano. It’s peaceful, as opposed to living in the city. There are working ranches still. Abundant wildlife. It’s rural.

But ranchers and other property owners of considerable acreage sold or sell either a portion of their property, or their entire property. Frank Holman has sold off property. They make money.

Chances are they sold to a developer. The developer went before the county planning commission and eventually obtained approval from the county commissioners and various county departments to subdivide the property they purchased. After spending a lot of money creating a subdivision, the developer put the newly-created parcels up for sale.

The developer and real estate agents made money selling the parcels. Then, people who could afford the parcels, and who were awestruck by the surrounding beauty and peacefulness of the rural location, bought the parcels and built homes on them. Expensive homes, for the most part.

Architects and all people involved in the construction business made money building the homes. Sales taxes accrued. The county made money throughout this process. The value of the property and therefore the property tax base increased significantly. The new property owner paid for all of this. As new residents of Chaffee County, they spend money here. It’s called economic development, and something that the County has approved of, and benefited from.

More development is on the way. To quote the Marcin Engineering Traffic Study, “It’s anticipated that some buildout will occur. Difficult to determine precisely, but a review of Google Earth indicates that more lots could be developed adding maybe 50% to the peak (traffic) flow.”

The newcomers bought into the fantasy of the 2000 Chaffee County Comprehensive Plan that didn’t discuss the need for a plan for local surface mining. The CR 140 corridor has indeed been gentrified. The RB Pit has fallen victim to the encroachment of adjacent incompatible land uses (residential properties), right before Mr. Holman and Mr. Moltz’s eyes.

The applicants, both community leaders, could have spoken up at any point along the path to gentrification of the CR 140 corridor, but they did not.

The applicants could have advocated for a plan for Resource Mining in the 2000 Comprehensive Plan. They could have advocated for a surrounding land use plan that would be compatible with surface mining, so as to not threaten the possibility of surface mining the RB Pit.

They could have asked, for example, that the following map that depicts the high potential of mineral extraction far beyond the proposed RB Pit be included in the 2000 Comprehensive Plan:

Colorado Mineral Geological Survey, Mineral Commodities Map, showing RB Pit location. Red areas: High Potential; Yellow areas: Medium Potential; Blue areas: Low Potential.

The applicants could have spearheaded a discussion on a compatible land use plan for surface mining areas to be included in the 2000 Comprehensive Plan.

Mr. Holman could have spoken up at the public hearings for the Weldon Creek subdivision – a subdivision that was required by the County to include a 1,000 acre conservation easement to promote open space and wildlife habitat – and notify the commissioners of his intent to apply for a surface mining permit on property adjacent to the proposed Weldon Creek subdivision. That would have been the transparent thing to do.

Of course, if Mr. Holman had publicly expressed his future plans to have a commercial gravel pit on his property, those sellers and investors who were selling and developing and building homes around the CR 140 corridor would not have been as successful as they were. Some would run before investing, fearing that a commercial gravel pit and commercial gravel transport would devalue the area’s residential property and rural quality of life.

The biggest proponents of the RB gravel pit remained silent while incompatible adjacent and nearby land uses – residential homes and property – encroached on their right to mine. That was their choice.


Explanation of “Road Damage of One Fully Loaded Gravel Truck = 2100 Cars”

The number was based on damage to an asphalt road. Below is an explanation of the calculation process.

With clarity in mind, it is not the wheel load but rather the damage to the pavement caused by the wheel load that is of primary concern. The most common historical approach is to convert damage from wheel loads (developed by field data) of various magnitudes and repetitions to damage from an equivalent number of standard loads. The most commonly used equivalent load in the U.S. is the 18,000 lb. equivalent single axle load (normally designated ESAL). The key word here is SINGLE. These are single axle loads with one tire on each end, not multiple axles or multiple tire loads.

The relationship between axle weight and inflicted pavement damage is NOT linear. For example a 4,000 lb. single axle load will cause 16 times the damage of a 2,000 lb. single axle load which is approximately an exponential factor of four and that exponential factor of four holds up fairly closely throughout the calculations of ESALs for the normal range of vehicle load weights. With this in mind, an 18,000 lb. single axle load (the base loading unit of 1 ESAL) causes 3,000 times more damage to a pavement than a 2,000 lb. single axle load. (thus the load equivalency factor for a 2000 lb. single axle load is 0.0003 ESAL)

In Table 1 listed below you will find some typical Load Equivalency Factors and can see that pavement type, tandem axles and dual tire configuration can greatly affect the ESAL rating and thus reduce the damage to the pavement. This is why we see so many dual tire tandem axle configurations on trucks as this configuration is the best configuration for reducing damage to the pavement.

We will only deal with flexible pavement (Asphalt) and not rigid pavement (Concrete) in our analysis for obvious reasons, and most of the emphasis will be on tandem axle dump trucks and semi type trucks that haul gravel rather than two axle garbage trucks, delivery trucks and school buses.

The table below converts some of the information in Table 1 to more relatable vehicles.

Some Typical Load Equivalency Factors:

Some of the numbers don’t seem to match, for example the car. It is listed at 0.0007 ESALs. That is because it has two axles and weighs more closely to 4,000 lbs, thus 0.000333×2 = 0.000666 or 0.0007 rounded off.

A 10 yd dump truck will have a 34,000 lbs tandem axle rating of 1.11 ESALs plus the 14,000 lb. front single axle rating of 0.399 for a total of 1.509 ESALs

With this information, we can take the ESAL loading and do the following calculation 1.509/0.0007 = 2156 which means that one ten yard gravel truck does the same damage to the pavement as 2156 cars.

Hopefully this will answer your questions.

Bob Perry P.E.
Archuleta County Engineer

Cynda Green

Cynda Green is an investigative reporter who enjoys writing about various and sundry topics, least of which is politics. But someone has to do it. Contact: cyndagreen@gmail.com