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Please find attached a presentation by BLR stating that they intend to mine using <br />Underground Bore Hole Mining (UBHM) and Ablation. HYPERLINK "http:// <br />www.blackrangeminerals. comlcontentlwp- content / uploads /2012/07 /Presentation -Aust- <br />Uranium - Confrence_ 18- 7- 12. pdf' http:// www. blackran eminerals .com/content/wp- content/ <br />uploads/ 2012 /07/Presentation -Aust- Uranium - Confrence 18- 7- 12.pdf <br />There are no current DRMS rules that cover UBHM and Ablation. <br />Having searched DRMS rules for monitoring wells, I find that the current situation most - <br />closely matches that of rule 1.4.3. Therefore, I have submitted these comments under the <br />10 -day deadline stated in that rule —as I believe the In situ Leach (ISL) rules that placed <br />pre - application requirements on monitoring wells is the closest regulation in keeping with <br />the Divisions and the MLRBs' intent to protect groundwater quality. <br />I believe that a solid first step is to determine what type of mining is going to be used. And <br />if UBHM and Ablation do not come under the ISL rules, then rules must be promulgated <br />for this type of mining and all actions must wait until a determination is made as to what <br />rules will be applied. <br />I would also like to make comment that I have no objection to DRMS requiring this type of <br />mining to fall under the ISL rules. <br />Further, I believe there should be the same amount of public scrutiny applied to UBHM <br />and Ablation as was for ISL. ISL requires a confined aquifer, UBHM and Ablation does <br />not. Only by giving proper notification and full public participation will there be proper <br />regulation of this new type of unproven, experimental mining that has never been used <br />commercially. <br />Having been a party to the 2010 Rulemaking process for HB08 -1161, I understood that it <br />was the Mined Land Reclamation Board's (MLRB) intent to protect groundwater quality <br />not only during In -situ Leach operations; but for all Designated Mining Operations <br />(DMO). <br />My foremost comment is that the same public process should be undertaken before any <br />UBHM and Ablation operations are considered —even at the pre - application level. This is <br />the level at which the current rules begin to shape the planning of an ISL process —it <br />should be the same level at which DRMS should choose to shape any plans for UBHM <br />and Ablation. <br />