2015-08-03_REVISION - P2009025 (5)

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In addition to the clear and unambiguous statements of Division staff, TAC asserts that the Mined Land Reclamation Act requires that a pilot test of UBHM, as described in the current NO1 Modification Application, is properly identified as a "development' activity rather than a "prospecting" activity to be conducted under an NO1. Under the Act, Development is defined as: "Development" means 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 ancillaryfacilities, and other related activities. [CRS 34-32-103 Definition (4), (emphasis added)) Black Range has clearly stated that its "exploration"/prospecting of the Hansen orebody is complete. As early as October 24, 2011, BLR announced "Drilling Program Completed at the Hansen Uranium Deposit". The announcement stated: "It is noted that numerous holes drilled during the recently completed program were located primarily to evaluate geotechnical conditions, rather than to evaluate resource grade, thickness and continuity, which has been well defined with the abundance of previous drilling data." On April 24, 2012 BLR announced "Black Range Selects Development Approach for Hansen Uranium Project" The announcement stated: "Scoping study confirms underground borehole mining with ablation as the best approach for development of the Hansen Uranium Deposit; Operating costs from the scoping study are estimated at US$30/Ib U3O8 at a production rate of 2MIb U3O8 per annum." On April 23, 2014, BLR announced "Hansen/Taylor Ranch Uranium Project—JORC Code 2012 Mineral Resource Estimate". This announcement, which confirmed and restated the same results published in July 2011 under the earlier version of the (Australian) JORC Code, specified in great detail, the location, quantity, grade, thickness, cut-off grades, geology, drilling and sampling techniques, etc. On July 31, 2015, BLR announced its June 2015 Quarterly Activities Report. The highlights of the report included: "Hansen/Taylor Ranch Uranium Project — Continued to acquire baseline environmental data and to advance mine permitting activities." Please see: www.blackrangeminerals.com, Investor Relations, ASX Announcements, by date. It should be noted that the second modification to the NO1, which was approved in November of 2012 following the withdrawal of the TAC appeal, authorized additional "exploration" drilling in addition to the construction of the five monitoring wells. No exploration drilling has been done at the Hansen site since 2011. BLR has made numerous announcements over the past two plus years that it is conducting pre -mining baseline environmental data sampling and that it has commenced the "mine permitting process". Black Range Minerals is no longer conducting prospecting activities but rather is now attempting to establish the viability of the unproven underground borehole mining technology by conducting a pilot test. Tallahassee Area Community was disappointed that this NO1 Modification request was not immediately rejected on procedural grounds by DRMS staff. For over two and one-half years TAC and other interested parties have relied on the numerous unambiguous statements of DRMS staff that any application for utilization of the UBHM process at Hansen would be by an "appropriate mining permit" thereby making the clear implication that BLR would be subject to the Hard Rock/Metal Mining Rules governing a