2015-01-20_REVISION - P2009025 (5)

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Coloradoans Against Resource Destruction P.O. Box 1142 Wellington, Colorado 80549 www.nunn(floNN.cone SENT VIA EMAIL ATTACHMENT January 20, 2015 Mr. Tim Cazier, P.E. Environmental Protection Specialist Division of Reclamation, Mining and Safety Colorado Department of Natural Resources 1313 Sherman Street, Room 215 Denver, Colorado 80203 Phone: (303) 866 -3567 SUBJECT: Hansen Uranium Project, NOI File No. P- 2009 -025, Form 2 Modification received December 22, 2014 Dear Mr. Cazier: Pursuant to Rule 5.1.3 of the Mineral Rules and Regulations of the Colorado Mined Land Reclamation Board for Hard Rock, Metal, and Designated Mining Operations ( "the Rules "), Coloradoans Against Resource Destruction ( "CARD ") hereby submits the following comments on the above - referenced Form 2 Notice of Intent to Conduct Prospecting Operations ( "NOI ") submitted to the Division by Black Range Minerals. CARD is a grassroots organization formed in 2007 in northern Colorado for the purpose of protecting the area's natural resources, with a particular focus on groundwater. CARD was instrumental in the passage of House Bill 08 -1161 which amended the Mined Land Reclamation Act ( "the Act "). CARD and its members fit the definition of "party" in the Rules due to the fact that the proposed activity in the NOI modification is a pilot test of underground borehole mining ( "UBHM "), an experimental uranium mining method that is expected to be proposed for the Centennial uranium project in northern Colorado. The Centennial project is owned by Powertech (USA) Inc., a South Dakota corporation that is wholly -owned by Canadian firm Azarga Uranium Corp. Azarga Uranium Corp.'s wholly -owned subsidiary, British Virgin Islands firm Azarga Resources Limited, is the largest shareholder of Black Range Minerals Limited which controls the Hansen uranium project.