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Wr <br />ENERGYFUELS <br />Energy Fuels Resources (USA) Inc, <br />225 Union Blvd. Suite 600 <br />Lakewood, CO, US, 80228 <br />303-974-2140 <br />www.energyfuels.com <br />All of these initiatives and activities at or involving the Whirlwind Mine, and the <br />significant financial outlays that they require, are indicators of a company that is intent on <br />operating an active, productive and profitable mining project. They are not indicators of a <br />company that is simply looking to do the minimum work required to maintain its mining permits <br />in order to skirt its reclamation obligations. Energy Fuels is going above and beyond the <br />minimum requirements to maintain the readiness of its assets, including the Mine, to respond in a <br />timely fashion to improved uranium and vanadium prices. <br />As discussed in Energy Fuels' Notice (at p. 2, para. (b)), mid- to long-term market <br />indicators for uranium are positive enough to support the very real possibility of resuming <br />mining operations at the Mine within the next five years. This possibility is further supported by <br />recent increases in the price of vanadium, which is produced as a co -product with uranium at the <br />Mine. <br />Given the encouraging mid- and long-term price forecasts for uranium and the current <br />high level of the price of vanadium, Energy Fuels is anticipating that, with recent work and <br />expected future work, a reclassification of the Mine's operations to intermittent status may be <br />warranted. Energy Fuels plans to work with the Division in the coming months to determine <br />whether and when such a change in status would be appropriate based on the nature and degree <br />of operations Energy Fuels has recently undertaken and expects to undertake in 2018 and <br />beyond. <br />Mine Status Chronology <br />INFORM's October 20 letter (at p. 2) incorrectly asserts that, "the Whirlwind Mine has <br />been in temporary cessation since Nov. 24, 2008," and, therefore, "the ten-year statutory limit <br />[for temporary cessation] should have begun on May 19, 2009, after the initial 180 -day period of <br />non -production ran out, pursuant to Rule 1.13.5(a)." INFORM made the same assertion in 2013 <br />when it opposed Energy Fuels' first notice of temporary cessation (see Letter from INFORM to <br />Board and Division, dated Feb. 12, 2013). Then, as now, the error of INFORM's assertion is <br />readily apparent from the actual timeline of events beginning with the issuance of the Mine's <br />reclamation permit on September 10, 2008: <br />• September 10, 2008: Permit No. M-2007-044 is issued. <br />• November 20, 2008: Mining operations are halted at the Mine. Energy Fuels submits a <br />notice of temporary cessation to the Division. <br />• December 2, 2008: Rather than taking specific action to process Energy Fuels' notice of <br />temporary cessation, the Division sends a letter to Energy Fuels informing the company <br />