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In fact, the proposed amendment is intentionally designed to be an end run around extensive <br />public involvement by Black Range Minerals. By filing a Notice of Intent, Black Range Minerals <br />is allowed to begin developing its mining project without the burden of actually applying for a <br />mining permit, which would require a much more complete picture of what will actually occur at <br />the site to be disclosed publicly. Under a Notice of Intent, public comments must be submitted <br />within 10 days and do not have to be considered nor answered by either the Division or the <br />applicant. Neither is the public provided with a final rationale from the Division about how the <br />proposal meets the requirements of the law. The Division should require a full mining permit in <br />this case in order to guarantee that the public has the right of participation in a complete and <br />extensive review process. <br />Respectfully submitted, <br />Jennifer Thurston <br />Director <br />Information Network for Responsible Mining <br />