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Bill Williams Mountain,
Your Watershed,
Say No
to Drake Cement Open Pit Mine


DATE: Feb 2, 2024
TO: Bill Williams Mtn. area residents
FR: Protect Bill Williams Mtn. Committee
RE: Follow Up on Drake Planned Mining Operations on the east slope of Bill Williams Mountain

As promised, we continue to monitor developments and non-developments pertaining to the Drake Cement  Company proposed mining operations that encompasses and impacts critical watersheds on the east slope of Bill Williams Mountain.

We are pleased to inform you that we were the recipients of an unsolicited invitation to join Nicole Branton, Forest Supervisor of the Kaibab National Forest earlier this week for a meeting that included many Forest Service
managers and representatives of the Save Parks opposition to pozzolan mining plans there. The purpose of the meeting was to keep our community informed of the actions that are now being seriously considered by the U.S.
Forest Service. No new decisions regarding the Bill Williams Mountain Exploratory Plan by Drake are currently being considered nor evaluated.


To clarify, Drake's Bill Williams Mountain claim has, indeed, resulted in a proposal for exploration being submitted to the U.S. Forest Service. But given the new development of which we are about to explain to you, the Bill Williams Mountain analysis of Drakes proposal for exploration has been temporarily suspended.

Nicole Branton explained to us that the Kaibab National Forest under her direction has decided to launch a Mineral Classification Process to determine the quality, rarity or non-rarity of pozzolan so as to gain a better perspective
on their ability to approve or deny current or future mining applications. This is a bit elusive given the odd descriptive words used to describe a mineral's rarity or commonality, so please learn these words and their meanings as we
move forward in opposition to any further development of mining interests on Bill Williams Mountain. These ARE NOT dictionary definitions. These are "common man" or "layman's" definitions according to our understanding:

Locatable Material: Rare materials like Uranium, Gold, Silver, but not necessarily limited to these including most metallic mineral deposits and certain nonmetallic and industrial minerals.

Saleable Material: Not rare at all like sandstone, gravel, stone, clay, and other similar materials. Such mineral materials include deposits which, although they have economic value, are used for agriculture, building, abrasion, landscaping, and similar uses.


Why is this important to us?

1. The General Mining Law of 1872 is the major Federal law governing locatable minerals. The Forest Service may not prohibit locatable mineral operations that otherwise comply with applicable law, nor regulate those operations in a way that amounts to a prohibition. This actually answers a question: "Why can't you just deny them access on Forest Roads?"; Such an interpretation would most likely constitute an unreasonable prohibition.

2. Under the U.S. Forest Service’s mineral regulations, the Forest Service has more discretion in managing saleable, also called common variety, minerals. The Forest Service has the authority to deny a proposal to mine saleable minerals. So, in our evaluation of the statements at this meeting, this mineral classification analysis could lead us to a place where our further advocacy against the mining operation may have more weight.


Drake Cement Company, LLC has already been made aware that the mineral classification analysis is going to be conducted by a U.S. Forest Service Certified Mineral Examiner, who will analyze samples and prepare a Mineral Classification Report. The U.S. Forest Service has yet to assign this mineral examiner to the Kaibab National Forest. Therefore, no dates have been set or estimated for initiation or completion of this analysis. That said, Nicole Branton offered to tell us that she expected this process (that has not begun) will take about a year to complete. The reason it will take so long is that the U.S Forest Service will be evaluating many other sites that contain pozzolan to carefully and thoroughly offer a comprehensive analysis as to pozzolan quality and whether it can be considered rare or not-so-rare in our greater area/region.

Adding to the time needed for the Mineral Classification Process, the U.S. Forest Service is REQUIRED to conduct an environmental review (aka NEPA) on their own sampling activities that will occur during the Mineral Classification Process to identify potential effects to forest resources and identify mitigations. Whenever anyone is disturbing, disrupting or breaking ground on a national forest including the Forest Service itself acquiring mineral samples as is the case here, the NEPA process must be completed including input and comment from the public. As part of this required NEPA process, the forest service will be asking the public to weigh-in on their plans and help them refine them. So, in specific regard to this Mineral Classification Process, you’re likely to receive Forest Service notices like,
“we’re soliciting input on a proposal,” “public scoping period,” and “public comment period.”


We have evaluated the Mineral Classification Process proposal and believe that you should support this much needed analysis. We feel that it is important for you to know that Nicole and her staff did not need our input or approval for this action. She and her staff discussed what needs they had at the Forest Service level to help them make the most informed decisions and actions regarding any and all proposed mining of pozzolan on the Kaibab National Forest.


To be clear, the definition/classification of the pozzolan materials is not a guarantee that any future mining application will be approved or denied. This, however, is a step in the process that Nicole Branton and her staff have initiated in order for them to gain much needed clarity on the role they will be able to play in future mining application approvals or denials.


We believe that the Kaibab is being led by folks who see themselves as protectors/stewards of their and our forests. We see them proactively and comprehensively restoring the Aspen groves and protecting/repairing them constantly to mitigate damage to their regrowth by elk and deer. We see them proactively and comprehensively executing critical, prescribed burns to clear our forest floor(s) of dead/downed wood and other forest floor debris like pine needles to try and prevent wildfires/conflagrations. We see their effective and hard fought battles against forest fires in our area and their management of lightning strike fires to affect future fire mitigation. We see their tedious management of forest thinning operations to restore forest health and the forest floor with its natural fauna and, again, to mitigate or prevent wildfires/conflagrations. So, it is not an absent observation of their behavior that brings us to this conclusion: Nicole and her team are strong advocates for protection of our forests and wildlands.


With that in mind, it is important to note that their stewardship is complicated by mining laws that can, at times, make it so that mining application decisions are out of their control. Mining laws are under the purview and complete control of Congress, not the U.S. Forest Service. To make matters more complex, codified law as in the 1872 General Mining law has had many challenges that have been ruled upon in the judicial process, setting "precedents" that have become virtual addenda to the original codified law. However, it is our opinion that the Mineral Classification Process is one that is to be welcomed by all of us here in the Williams Community as its determinations may provide more opportunity for our opposition to a future mining application.


If at some point in the not too distant future, sometime after the Mineral Classification Process clears its NEPA review, and as you are perusing the foothills of Bill Williams Mountain in or around the survey-staked area of Drake's Cement claim, you may see Forest Service folks along with the Certified Mineral Specialist/Examiner doing in-ground examinations of the pozzolan deposits in the affected area. This is not a sign that commercial excavation has begun. This is not a sign that a mining application has been approved. This is not a sign that Drake has started destroying our mountain. The U.S. Forest Service's Certified Mineral Examiner will need to dig a bit, may need to take core samples, etc. That's all that's happening.

We will keep you advised as this proposal/process develops and evolves. Stay tuned.

Steve Dudley
Mike Benham
for Protect Bill Williams Mountain

Older News





Sept. 4, 2023 Please read this news article

Originally published in High Country News Aug. 1, 2023

An antiquated law rules mining in the West
By Jonathan Thompson
(click link below)

High Country News (HCN)

HCN on Facebook

High Country News. All rights reserved.

Email to: Michael Leveton
Content Syndication | High Country News



August 17, 2023

Just a short note to bring everybody up to speed on Drake mining interests.

Drake has now claimed an additional 1416 acres of Kaibab National Forest land for yet another Pozzolan open pit site. These most recent claims are called the Spring Valley claims and are located in Parks immediately behind Spring Valley Cabin, west of Spring Valley Road (see inserted map). Any development of this site into an open pit mine will result in loss of some very beautiful habitat and result in an immense increase of mining truck traffic down Spring Valley Road, through Parks.

If you have any concerns about this potential future development and you live in and around Parks, now is the time to say something. Once the trucks start rolling, it will be far too late.


Save Parks Website

Parks Point Of Contact: Brian Hughes

To that end the Williams Grand Canyon Newspaper is developing an article on this recent development and would like to hear from and interview interested parties from Parks regarding their feelings about this. Please feel free to share and alert the citizens of Parks to this. We need to hear from you! If you live in the Parks area and would like your voice heard please contact the Williams Newspaper at (928) 635-4426; (928) 699-8874 or write

Time is short for the article,

please respond.

Steve Dudley for

Protect Bill Williams Mountain



April 10, 2023

The Scoping Period for the Drake Exploratory Plan on Bill Williams Mtn, closed  April 10, 2023.


To view comments that were submitted click either link below:

As a citizen action group, it is important to understand this scoping period is just the beginning of our efforts to stop Drake. Please write to your Federal and State elected leaders. Our city and county governments need your support. 

Below are two attached letters dated April 7 sent by the Coconino Board of Supervisors to Drake Cement. Coconino County is against any proposed mine located within the Williams Watershed area.  

Letters from the Coconono County Board of Supervisors opposing the Drake mine

Other published letters opposing the Drake mine

Green dots are Drake locations for exploratory digging


Photos of Cataract Creek 2023 spring runoff.

Drake claim stakes right in the middle of one of the drainages!

Be pro-active and protect your drinking water. Please write to your elected government officials.

About Our Organization
Protect Bill Williams Mountain

Please Join Our Fight To Save This Precious Resource

Started by concerned Williams Arizona and Bill Williams Mountain area residents in March 2022, when Drake Cement LLC starting placing mining claim stakes covering 850 acres on the eastern side of the mountain. The Protect Bill Williams Mountain organization is growing rapidly. We have already received official letters of opposition to mining from The City of Williams, The Coconino County Board of Supervisors, and The Sierra Club just to name a few. We invite you to learn more about how you can make an positive impact and stop this mine.


You can contact us at:

Our goal is to inform everyone of where Drake Mining and Material LLC, is proposing this pozzolan open pit mine, and to convince or persuade Drake that this location should not be considered.

Drake Mine proposed location

Claims outlined in black.

Cataract creek.jpeg
WT and BT claims.jpeg

Southwest 600 acre claim

East slope 850 acre claim

Open pit mines should not be allowed to operate in or near a critical watershed. Drake will say they can "mitigate" any risks or hazards, but why should we accept any risk. This proposed mine would be a direct threat to the Cataract Creek and Dogtown Watersheds that supply drinking water to the residents of Williams. Drake should find another location to mine what is a common material in Arizona

Open pit mines are destructive and would permanently scar the east side of Bill Williams Mountain. 


Where do you want your drinking water to come from?

Cataract Creek April 2023

Naturally functioning watershed

Typical surface mine. Effluent water runs off into a "settling pond" and then into your watershed / drinking water

What is pozzolan and what is it used for?

Basically it is siliceous volcanic ash. Pozzolan is a natural material that can be added to cement to strengthen and increase the density of concrete.

Is pozzolan hazardous?

Acute or short-term:
This product is expected to cause irritation of the eyes, skin and mucous membranes. Product may
cause sneezing and coughing if inhaled. Swallowing this product may produce gastrointestinal
discomfort. Inhalation of this product may produce irritation of the upper respiratory tract and asthmalike responses in some individuals.
Chronic or long-term:
This product contains crystalline silica, which upon long-term exposure to levels above the PEL/TLV
may produce bronchitis, silicosis, a fibrotic (scarring) disease of the lungs and potentially lung cancer.
Studies have shown that smoking increases the risk of these diseases. This product may also increase
the risk of scleroderma for which the causes are unknown, but some reports link over exposure to silica
in combination with other chemicals to this disease.

Conditions to Avoid:
Any condition that may generate excessive dust (certainly a challenge for an open pit mine).


Pozzolan Material Safety Data Sheet


Voice your opposition to this proposed mine.
Write a letter via U.S. Mail. Or send an email or call.

Include your full name and return address to receive a written response.

What should you say in your letter or email? It's up to you. 
Having said that, our organization believes that everyone should demand that our elected officials protect the source of our drinking water. Mining companies should not be allowed to disturb a natural and fully functioning watershed that so many people depend on. Drake Cement is owned by UNACEM, a Peruvian cement, ready-mix, aggregate and energy corporation that also has interests in Peru, Ecuador and Chile. We need our Senators and Representatives to take a stance and help the City of Williams and the Coconino Board of Supervisors say no to Drake (UNACEM). Drake wants to open and operate this proposed mine under The General Mining Law of 1872. This 150 year old law helped build the nation but it also contributed to widespread damage to America’s lands and waters, and it still is. It is past time this law was overhauled. Why should foreign owned mining companies be allowed to exploit and profit off of natural resources on public lands and not pay ANY royalties to our government? Federal and state land managers must be allowed to deny mining permits if they determine that scientific, cultural or environmental resources would suffer “substantial irreparable harm". The mineral Drake wants to mine is commonly found in Arizona, and should be mined in areas that are not as fragile and critically important as the Bill Williams Mountain watershed.

Arizona Senator Mark Kelly

2201 E. Camelback Rd, Suite 115
Phoenix, AZ 85016

Arizona Senator Kyrsten Sinema

3333 E. Camelback Rd, Suite 200
Phoenix, AZ 85018

Representative Eli Crane

1229 Longworth House Office Building

Washington, DC, 20515

Phone: (202) 225-3361



Arizona's 2nd congressional district (includes Williams, AZ)

Representative Raúl M. Grijalva
1511 Longworth House Office Building
Washington, DC, 20515-0303
Phone: (202) 225-2435

Chairman U.S. States House of Representatives Subcommittee 
on Energy and Mineral Resources, and National Parks, Forests, 
and Public Lands.

Arizona's 7th congressional district

Representative Ruben Gallego
1131 Longworth House Office Building
Washington, DC, 20515-0307
Phone: (202) 225-4065

Member U.S. States House of Representatives Subcommittee 
on Energy and Mineral Resources, and National Parks, Forests, 
and Public Lands.

Arizona's 3rd Congressional District

Matt Ryan, District 3

Coconino Board of Supervisors

219 E. Cherry Avenue

Flagstaff, AZ 86046


Don Dent, City of Williams Mayor

113 South 1st Street

Williams, AZ 86046-2549

(928) 635-4451


Tim Demko, Geologist

BLM, Hassayampa Field Office

2020 E. Bell Rd.

Phoenix, AZ 85022

Michiko Martin, Regional Forester, SW Region
333 Broadway SE
Albuquerque, NM 87102

Randy Moore, Chief of Forest Service
1400 Independence Ave., SW
Washington DC 20240



Kaibab National Forest Supervisor’s Office

800 South 6th Street

Williams, AZ 86046


Williams Ranger District

742 South Clover Road

Williams, AZ 86046


Drake Cement, LLC

Enrique Rozas, CEO, President

and Statutory Agent

21803 N. Scottsdale Rd., Ste. 220

Scottsdale, AZ 85255



Managers of Drake Cement, LLC

21803 N. Scottsdale Rd., Ste. 220

Scottsdale, AZ 85255

David Chavez

7G-Compliance, LLC

2345 N. Vista del Sol

Mesa, AZ 85207

City of Williams

Letter Opposing Mine


Coconino County Board of supervisors

Letter Opposing Mine


Sierra Club Grand Canyon Chapter

Statement Opposing Mine


Link to Williams-Grand Canyon News Article on proposed Drake mine:


This 150-Year-Old Mining Law Hurts Taxpayers and the Environment


Drake's current position on their claim

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