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Keene planning board continues hearing on G2 Holdings gravel-pit expansion after approving several waivers
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Summary
The Keene Planning Board on Monday approved three local waivers for a proposed expansion of an existing gravel operation on Route 9 but continued final action on the excavation permit until Sept. 29 so the applicant and staff can provide additional traffic and monitoring documentation.
The Keene Planning Board on Monday approved three local waivers for G2 Holdings LLC’s proposed expansion of an existing gravel operation on land accessed from Route 9 but postponed formal approval of the excavation permit and related hillside conditional-use permit until the board’s Sept. 29 meeting.
The board granted the developer and its engineers relief from three provisions of the Keene Land Development Code (LDC) that the applicant said would otherwise prohibit the proposed work: the required 250-foot surface-water setback, a clause barring excavation of bedrock that “contains toxic or acid-forming elements or compounds,” and a 5-acre maximum excavation-area limit. Staff and the city’s independent consultants also described a long list of monitoring and reporting conditions the applicant must meet before and during operations.
Why it matters: The project would expand a gravel operation across two Keene parcels and adjoining property in Sullivan and Roxbury, covering roughly 300 acres of ownership with about 31 acres proposed to be disturbed through eight phased permit periods. Opponents raised concerns about visual impacts, dust and traffic on Route 9, and the risk of “acid mine drainage” from pyrite-bearing bedrock. Supporters and the applicant’s experts said monitoring, engineered controls and a staged work plan would mitigate those risks.
The applicant’s presentation and independent review
Ariane Ice, speaking for the applicant team, recapped the application and the review history and said the Keene regulations “meet or exceed” the state earth-excavation standards in RSA 155‑E. She noted the city had hired outside reviewers and said the applicant had revised plans to respond to those reviews. The application team included Granite Engineering and its project engineers, hydrogeologist Joel Banzak of Frontier Geo Services and other specialists on wildlife, noise and real estate.
Brent Cole of Granite Engineering explained the phased plan: eight excavation periods staged so the operation disturbs no more land than necessary at any one time; each period requires a compliance hearing and a performance security before moving to the next period. Cole said the operation would use a processing area near Route 9, and that most work would occur away from mapped city viewsheds.
Joel Banzak, a professional geologist who prepared the acid‑mine‑drainage (AMD) assessment, said laboratory tests showed the rock contains minerals (including pyrite) that could form acidic drainage if exposed to air and water in the right conditions. He added that the crystalline bedrock commonly found in the area is not porous, and that three components (sulfide minerals, air and water) are required to generate AMD. He said the applicant prepared a monitoring program, proactive mitigation (lining stormwater conveyances and ponds with alkaline limestone) and an initial response-action plan in case low pH or dissolved metals are detected.
Third‑party review and staff recommendations
Megan Fortson, the city planner leading staff review, told the board the city had retained Sanborn Head and Fieldstone Land Consultants as third‑party reviewers. After successive plan revisions and a staff‑led meeting among the consultants and the applicant, Fieldstone and Sanborn Head had no outstanding objections that would block moving forward. Sanborn Head’s hydrogeologist, Russ Abel, participated remotely and recommended conditions to confirm seasonal high water levels in permit period 1 and again before period 8 and to require semiannual groundwater-quality monitoring for at least two years after the site is reclaimed.
Fortson summarized staff’s recommended conditions, to be met before final approval and during the permit life. Those included: owner signature on final plans; full‑size paper and digital plan submittals; performance security for erosion, stormwater and reclamation for the first permit period; payment of outstanding consultant review fees; and submittal and approval of all required state and federal permits with permit numbers added to the plan cover sheet. Ongoing conditions would include monthly erosion and pH/stormwater inspections by a licensed third‑party professional, monthly groundwater- and surface‑water level monitoring to detect adverse impacts and immediate notification to the city if adverse impacts are discovered. Staff also proposed that the applicant install a monitoring well in the period‑1 area in spring 2026 to capture seasonal high water-table conditions.
Board discussion and votes
Board members extensively questioned the applicant and the consultants about the AMD analysis, groundwater monitoring and what would happen if low pH or dissolved metals appeared in monitoring results. Banzak described the applicant’s “belt and suspenders” approach: robust monitoring (monthly and quarterly), alkaline lining of conveyances and ponds, and a response plan that would include delineation, additional monitoring wells, domestic well sampling and, in a worst-case scenario, impoundment and treatment. Sanborn Head’s Russ Abel said that, based on the submitted data and the applicant’s proposed monitoring and mitigation, he felt comfortable the plan would detect and address problems if they occur.
After the public-comment period and deliberations, the board voted to approve the three requested waivers (surface‑water setback reduction to 75 feet; a waiver related to excavation in bedrock that contains acid‑forming elements; and increasing the site’s allowable unreclaimed excavation area beyond 5 acres up to 12 acres). The applicant had withdrawn an earlier waiver request that sought to allow excavation below the water table.
Board action on the full permit application was not completed Monday. The board debated whether to act and then moved to a full set of conditions and an approval motion with a lengthy list of the staff‑recommended requirements. That motion was tied in the first recorded final vote and therefore was defeated. After additional procedural steps and discussion, the board ultimately set a continuation of the public hearing and deliberation on the overall application for 6:30 p.m. on Sept. 29, 2025, and asked staff and the applicant to provide additional documentation in advance.
What the board asked for next
Staff and several members requested clearer or updated traffic information and confirmation or clarifications of the applicant’s earlier traffic estimates. The board also asked the applicant to confirm whether any regional complaints about past blasting or related operations in adjacent municipalities had associated monitoring data (for example, any domestic‑well testing results) that could be shared for context. Staff confirmed that the applicant must submit, and the city must receive, approved state and federal permits and that the monitoring data would be reported to the city. The board reiterated that each permit period must return to the board for a permit renewal and performance security prior to starting the next phase; code enforcement and staff would perform monthly and periodic inspections during the work.
Where things stand
The city’s third‑party hydrogeology and engineering consultants told the board they were satisfied with the technical mitigation and monitoring proposed, subject to the conditions summarized by staff. The board granted the three LDC waivers requested but did not approve the full permit application Monday; the public hearing remains open and the application is continued to the planning board meeting on Sept. 29, 2025, at 6:30 p.m. in Keene City Hall’s council chambers. The applicant may proceed with no ground‑disturbing work in Keene until the board issues a final decision that meets the LDC and the cited conditions.
Ending note
The project will also require separate approvals from the other municipalities that own or abut the applicant’s parcels in Sullivan and Roxbury. The board noted those jurisdictions will review the portions of the project in their towns at their hearings and that different municipalities may impose different conditions or limits.
Speakers quoted or paraphrased above are those who spoke at the planning board meeting or appear in the staff or consultant reports and are listed in the article’s speaker section.

