Drake Cement Proposed Pozzolan Exploration at Bill Williams Mountain

Drake Cement, LLC is proposing to conduct exploration activities for pozzolan (a cement additive) south of the City of Williams at the eastern base of Bill Williams Mountain near Perkinsville Road. The Forest Service is conducting an environmental review of the proposed activities, as described by the National Environmental Policy Act (NEPA). 

This is not a proposal to mine.  The exploration proposal consists of eight trenches from which Drake would collect samples to determine the quality of pozzolan in the area. Pozzolan is an alternative to fly ash, a product of burning coal for power generation. It is used in cement and mortars to enhance density, strength, durability, and chemical resistance. With recent decreases in coal-fired power plants, the availability of fly ash is diminishing. 

Current Status

The Forest Service is beginning NEPA analysis in an environmental assessment. Updates about this process, including timelines and comment periods, will be provided here.

Documents and Links

Map with dots representing general location of proposed trenchesMap of local area with dots and lines depicting proposed trenches and access routes

General Timeline

July 29, 2022 – Drake Cement, LLC submitted initial documentation for a proposal to explore pozzolan claims at the eastern base of Bill Williams Mountain. 

  • Based on that documentation, the Kaibab National Forest determined that, due to the ground-disturbing activities proposed, a Plan of Operations would be required, which would be developed based on an environmental analysis, as set forth by the National Environmental Policy Act (NEPA).

August 15, 2022 – the Kaibab NF issued a letter to Drake stating this determination and that additional information will be needed for the Forest Service to consider the proposal.

September - December 2022 – the Kaibab NF informed Drake of the types of information the draft Plan of Operations would need to include (such as proposed access, equipment, timing, etc.).

January 20, 2023 – Drake submitted a draft Plan of Operations for their proposed pozzolan exploration.

January 26, 2023 – The Kaibab issued a letter to Drake notifying them the Forest Service accepted thevdraft plan for review and will be moving forward into the environmental review phase of the project. Accepting the draft plan does not mean the Forest Service has approved exploration activities. It means the plan contains sufficient information for the Forest Service to begin analyzing the proposed activities, which occurs through a public process as described by the National Environmental Policy Act (NEPA). An Interdisciplinary Team (IDT) will be assigned to analyze and disclose environmental impacts from the proposed activity. 

Scoping Period February 24 - April 10, 2023 – The first step in the review process was a 45-day scoping period during which the Forest Service collected public comments about the project. This helped the Forest Service understand concerns people had about the potential effects the proposed activities could have on natural and cultural resources. The comments received during scoping informed the Forest Service’s determination that an environmental assessment would be the appropriate level of analysis.

Preparation of a draft environmental assessment – The environmental assessment for this proposal will identify the potential impacts to forest resources and identify any mitigations and reclamation activities that would be incorporated into Drake’s Plan of Operations. The draft environmental assessment will be made available for public review and comment in late 2023 or early 2024.

After the public comment period for the draft environmental assessment, the Forest Service will begin finalizing the document. The entire NEPA analysis process for the exploration proposal is expected to take at least a year. The final Plan of Operations would incorporate any necessary adjustments and mitigations identified in the engironmental assessment.

 

Questions and Answers:

Q: Can I see the proposed plan of operations that Drake submitted to the Forest Service?

A:  Yes. Drake’s proposal – the draft Plan of Operations submitted January 20, 2023 – is available here.

 

Q: We heard the Forest Service as already approved the plan. Is this true?

A: No. The Kaibab National Forest has accepted the draft Plan of Operations (PoO) for review, but accepting the draft plan does not mean exploration activities have been approved. Approval of the plan would not occur until entire review process is complete, which could take anywhere from months to years depending on the level of analysis. The final Plan of Operations would incorporate any adjustments and mitigations identified during the review and would then be presented to the Forest Service for approval.

 

Q: How do I provide my comments?

A: While we are happy to listen and discuss anytime you contact us, formal public comment periods are included in the review process, starting with the scoping period February 24 - April 10, 2023.  

 

Q: Will tribal concerns be considered? How will Tribes be involved in the process?

A:  Yes. The Kaibab National Forest will consult Indian Tribes on issues and concerns throughout the proposal and application review process. The Kaibab National Forest is committed to maintaining constant and open communications with our Tribal partners, including seeking to engage in fair, timely, and meaningful consultation.

 

Q: We’ve heard that Bill Williams Mountain is a Traditional Cultural Property. What does this mean?

A: A Traditional Cultural Property (TCP) is a place that is eligible for inclusion on the National Register of Historic Places because of its association with cultural practices or beliefs of a living community that are rooted in the community’s history and are important in maintaining the continuing cultural identity of the community. Bill Williams Mountain has been identified as a TCP by tribes. As a result, the Kaibab National Forest has managed Bill Williams Mountain as a TCP for decades and is currently working on a formal determination of eligibility of the mountain as a TCP. The Kaibab National Forest will consider the exploration proposal’s effects on the TCP as a part of the environmental analysis.

 

Q: How long will this process take?

A: The timeline will be dependent on the level of NEPA analysis and needs for consultation with various agencies and Tribes, and could take anywhere from months to years. We will have a better idea of the timeline after the public scoping period.

 

Q: What level of analysis will this be? 

A: The level of analysis will be determined after the public scoping period.

 

Q: If the proposal is approved, would Drake be able to start mining?

A: No. Drake has not proposed to mine the area at this time, only to perform exploratory trenching. Any proposal for mining would be subject to a separate review process and environmental analysis.

 

Q: Can the Forest Service deny Drake's exploration proposal?

A: The Forest Service cannot deny someone’s right to explore for and discover valuable mineral deposits on federal lands that are open to mineral entry. National Forest lands are open to entry unless the area is withdrawn by the Secretary of the Interior or excluded by an act of Congress. The area where Drake is proposing to conduct pozzolan exploration activities is open to locatable mineral entry.

It is the Forest Service’s responsibility to identify potential adverse environmental impacts on surface resources and any mitigation and reclamation measures, which is done through the environmental analysis process. Afterward, the Plan of Operations would be updated to incorporate those measures, then finalized and presented to the Forest Service for approval. The Forest Service must consider all reasonable proposals for mineral operations on areas that are open to entry.

 

Q: We heard Drake is already starting to mine. Is this true?  

A: Drake has begun operations at a separate location – their Williams Pozzolan Mine located about 9 miles east of Williams at an area locally referred to as Frenchy Pit. That mine was approved in early 2022. No exploration operations have taken place at the Perkinsville Road site. Furthermore, should the plan be approved, mining would still not take place at the Perkinsville Road site, as the proposed activities are strictly for exploration. Any proposal to mine at the Perkinsville Road site would be subject to a separate environmental review and approval process.