2015-01-22_REVISION - P2009025 - Laserfiche WebLink

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production plans," which is how Black Range Minerals describes its intentions. In fact, in its publicly available investment materials and securities filings in addition to the NOI amendment application, Black Range Minerals has clearly and repeatedly stated its intent to initiate mining at the Hansen Project by the end of 2015. It is helpful to further review the definitions of these various activities in the MLRA. The law at C.R.S. 34 -32 -103 (8) defines mining as "the development or extraction of a mineral from its natural occurrences on affected land." [Emphasis added.] The law further specifies what "development" is by defining it as "the work performed in relation to a deposit, following the prospecting required to prove minerals are in existence in commercial quantities but prior to production activities, aimed at, but not limited to, preparing the site for mining, defining further the ore deposit by drilling or other means, conducting pilot plant operations, constructing roads or ancillary features, and other related activities." [C.R.S. 34 -32 -103 (4).] The fact that the Division is being asked to review an amended NOI is simply a duplicitous attempt to circumvent the public's right to review in great detail and with a complete set of facts and studies a controversial proposal to mine uranium in the Tallahassee Creek area. The amendment application provides scant details about how the experimental UBHM technology will be deployed at the Hansen Project. Black Range Minerals could have included in the amendment application the helpful and detailed video it produced in 2012 discussing how UBHM would be utilized at the Hansen site, including renderings and animations of the experimental technology. [Video available online at https: / /www.youtube.com/ watch ?v= EptNdp8NLcs &feature = youtu.be ] In the video, UBHM is described as the act of lowering a "fixed shrouded jet miner" [at 2:16] into a bore hole in order to excavate a cavern with high - pressure water flows in order to create a "mineralized slurry" [at 3:00] that is then ready for ablation processing. The video further describes how previous ablation testing of material from Hansen resulted in 90 percent recovery of uranium separated from the ore body that resulted in an "ablated concentrate" [at 3:32]. The remaining cavern and bore holes are filled once work is completed. Thus, once again, Black Range Minerals has asserted publicly in investment materials that it has definitively explored and defined the Hansen deposit and has repeatedly stated its viability as a mining project. Prospecting is done. In fact, the Division's staff may recall that prospecting at the Hansen site was conducted in August 2007, without proper county permits, under the cover of darkness, when Black Range Minerals thought that it could circumvent the law by drilling, literally, at night time, thinking that nobody would notice. Unfortunately for the company, many people actually do live in the Tallahassee Creek area and have a right to understand exactly what is being proposed by their mining corporation neighbor. The public is not fully informed about what Black Range Minerals is proposing at the Hansen Project by the information in the amended NOI application, but they could be better informed and offered a greater opportunity to comment and participate in the review with a full mining permit application, complete with an Environmental Protection Plan that will ensure the Tallahassee Creek area is adequately protected from the impacts of hydraulic -based uranium extraction. The Division's Hard Rock/Metal Mining Rule 1.1 (14) identifies Designated Mining Operations as including mining operations that will expose or disturb toxic or acid - forming materials; or where the potential to create acid mine drainage occurs; or where uranium is extracted, either by in situ leach mining or by conventional or open