2023-12-11_PERMIT FILE - P2023018

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December 8, 2023 Lucas West Environmental Protection Specialist Colorado Division of Reclamation, Mining & Safety 1313 Sherman Street Denver, Colorado 80203 Via email to Iucas.west@state.co.us Re: Comments on Highbury Resources Slick Rock Project Notice of Intent, Permit No. P-2023-018 Dear Mr. West, Thank you for the opportunity to comment on Notice of Intent P-2023-018 submitted by Highbury Resources. These comments are submitted on behalf of Sheep Mountain Alliance and Information Network for Responsible Mining (INFORM). Sheep Mountain Alliance is a citizens' conservation organization that works to protect the greater Telluride region of southwestern Colorado. INFORM is a statewide conservation organization that addresses the impacts of hardrock mining in Colorado. Sheep Mountain Alliance and INFORM are opposed to inappropriate mining development in the Dolores River Basin when it conflicts with regional conservation goals. Those values are embedded within the Dolores River National Conservation Area and Special Management Area Act, federal legislation sponsored by Sens. Michael Bennet and John Hickenlooper and Rep. Lauren Boebert. Although detailed maps are not provided with the publicly available NOI files, it appears that at least one of the drilling sites is located within the boundary of the proposed National Conservation Area and that the entire project area occupies the buffer area immediately adjacent. It is the intent of the federal legislation to protect the Dolores River canyon in order to "conserve, protect, and enhance the native fish, whitewater boating, recreational and scenic, cultural, archeological, natural, geological, historical, ecological, watershed, wildlife, educational and scientific resources" of the Dolores River landscape. Our organizations strongly believe that the natural, scenic and recreational values of the Slick Rock area enhance and support the regional recreation economy and far outweigh the limited benefits of uranium mining. The Notice of Intent does not identify where additional access roads must be constructed or where existing roads must be improved in order to access the drilling locations, even though "off- road access trails" are acknowledged on page 18 of the NOI document as necessary to conduct drilling. However, these roads are not identified in the NOI nor are they"identifiable" without the required accompanying maps, as required by Rule 5.1.2(d)(A) and (B); nor are the lengths of any new road segments identified or described elsewhere in the NOI, as required by Rule 5.3.1(c). The creation of the access roads is also not considered in the NOI's stated disturbed acreage of 0.46 acres in the Notice of Intent, as required by Rule 5.1.2(d)(iv). New roads must be considered in the acreage in order to determine an adequate financial guarantee as well as to ensure that final reclamation will be completed. It is also incorrect for the operator to limit the disturbed acreage to only the pad areas for 20 drill holes when 27 are proposed. Regardless of whether the operator's intent is to drill only 20 holes, the NOI must consider all 27 in the final calculations because all 27 will be authorized to proceed. Furthermore, the roads to the drill sites must be included in the project's reclamation plans and the operator must commit to reclaiming them. Because the project maps have not been made available for public review before the comment deadline, it is impossible to know whether the stated disturbance of 0.46 acres is accurate