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Black Range Minerals describes its proposed activity in the amended NOI: "New <br />disturbance is proposed for a bulk sample collection via hydraulically jet- cutting a cavern of rock <br />from within a standard bore hole." [Amended NOI, p. 4, question #11.] The proposed <br />disturbance is described as: "Upon completing a bore hole into the target zone (shaft) a bulk <br />sample collection mining tool will be lowered to a target depth. The tool will use a water stream <br />to cut rock away from the bore hole annulus and also pump the cut material to the surface via the <br />drill pipe string." [Ibid, question #12.] This is all the detail provided to describe the actual <br />extraction of mineral resources in the amended NOI application, which falls far short of the <br />information necessary to adequately review and approve the deployment of a new technology, <br />particularly one that is hydraulic in nature and will be used for the extraction of uranium. <br />Despite the lack of detail and the softening of language about this extraction activity in <br />the amended application, there can be no doubt that Black Range Minerals' minimalistic <br />verbiage is actually depicting underground borehole mining, which the company has <br />aggressively promoted for the last several years as an emerging technology to extract uranium in <br />Colorado. In its most recent annual presentation to investors in November 2014, Black Range <br />Minerals repeated its numerous, previous descriptions of UBHM activities at the Hansen Project <br />and announced its intentions to proceed with developing the project in 2015 by "undertaking trial <br />underground borehole mining" with the dual purpose to "streamline the mine permit approval <br />process" and "help refine production plans and operational cost estimates." [See investors' <br />presentation online at http://www.blackrangeminerals.com/content/wp- <br />content/uploads/ 2014 /12/28- Nov - 2014- Investor- Presentation.pdf at slide #7.] Statements of the <br />intent to mine are coupled with reassurances from the company that it has completed the baseline <br />monitoring program it is required to undertake as a last and final obligation to complete before a <br />mining permit can be reviewed by the Division. <br />These are noteworthy statements to investors because they underscore the company's <br />advancing strategy of developing a mining deposit, not simply prospecting to determine whether <br />mining is feasible. Feasibility of the Hansen Deposit has already been demonstrated by Black <br />Range Minerals by its release of a scoping study in March 2012 that demonstrated the economic <br />viability of mining and delineated the mineral resources available, followed by the <br />commencement of a full Preliminary Economic Analysis, which can only be commenced after all <br />necessary data has been acquired from the completion of prospecting. Since that time, Black <br />Range Minerals has been busy at work promoting the viability of the project and attempting to <br />attract investment for mining, not prospecting. [See BRM Quarterly Activities Report, March 31, <br />2012, online at <br />http:// www. blackrangeminerals. com/ pdfs /QuarterlyActivitiesRgportMarch l 2Ouarter30Apr l 2.pd <br />f.] <br />This is an important distinction because, again, what Black Range Minerals is now <br />proposing far exceeds the scope of activities that can be authorized by an amendment to an NOI <br />submitted and approved five years previously. Black Range Minerals is not proposing additional <br />prospecting activities, defined in the Colorado Mined Land Reclamation Act at C.R.S. 34 -32 -103 <br />(12) as "the act of searching for or investigating a mineral deposit." Please note that the state <br />law does not define prospecting as "undertaking trial underground borehole mining" nor is <br />prospecting's legal definition expansive enough to include the ancillary activities of "refining <br />