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<br /> of the site for public review prior to the initiation of any drilling activities.
<br /> Rule 5.1.2(d)(vi)requires that legal documentation to enter BLM lands be provided before the Notice of Intent is
<br /> approved.The NOI includes a detailed legal agreement between four corporate entities as evidence of legal
<br /> right of entry. However,the Division should require verification from BLM that the legal agreement is not in
<br /> conflict with their requirements to maintain right of entry and that BLM has approved Highbury's access right
<br /> before any activities are authorized.
<br /> The Slick Rock and Disappointment Valley areas adjacent to the general location of the proposed drilling
<br /> activity are abundant in natural values and provide important habitat for wildlife,and any impacts to wildlife must
<br /> be minimized in accordance with Rule 5.3.2.Activities should be restricted to the non-winter months when
<br /> nesting or brooding species are not present.The Naturita Milkvetch(Astragalus naturitensis)and Gypsum
<br /> Valley Cat Eye(Oreocarya revealii)have been located in the vicinity and are notable rare flora species.The
<br /> Division should require that the specific drill sites be surveyed for these species and measures taken to prevent
<br /> any specimens that are identified. Before any surface disturbances occur, it would be beneficial to survey the
<br /> project area for any cultural, historical or paleontological resources,which are abundant in the area,and take
<br /> measures to halt operations and protect them if any are inadvertently discovered during drilling operations.
<br /> The Slick Rock area is a treasured resource for the residents and visitors of San Miguel County and the
<br /> operator should be required to be especially vigilant in its care for the landscape should exploration be
<br /> approved. However, authorizing exploratory drilling in this location cannot be uncoupled from a consideration of
<br /> the future potential for uranium mining in the same location.That would be an unacceptable outcome and an
<br /> incompatible use of the land. For these reasons as well as the extensive deficiencies in the Notice of Intent
<br /> submitted by Highbury Resources,we respectfully request that the application be denied.
<br /> Respectfully submitted,
<br /> Mason Osgood
<br /> Executive Director
<br /> Sheep Mountain Alliance
<br /> P.O. Box 389
<br /> Telluride, CO 81435
<br /> (970)728-3729
<br /> mason@sheepmountainalliance.org
<br /> Jennifer Thurston
<br /> Executive Director
<br /> Information Network for Responsible Mining
<br /> 2205 W. 136th Ave. Ste. 106-311
<br /> Broomfield, CO 80023
<br /> (303)586-1437
<br /> jennifer@informcolorado.org
<br /> Permit Number*
<br /> Enter valid letter and then numbers,for example M1977999, M1999777UG or C1981201.
<br /> P2023018
<br /> Permitting Action Type
<br /> Select revision type or leave blank if comment pertains to a new permit application or NOI
<br /> Permit Type
<br /> Notice of Intent
<br /> County*
<br /> San Miguel County
<br /> Enter one county only
<br /> Site Name
<br /> Slick Rock Project
<br />
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