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for an exploration program of this size. The only maps made available are those included in the <br /> appendix of an enclosed natural resources survey (at page 67 of the NOI document) and those area <br /> maps indicate a much larger project spread over dozens of acres, crossing over a state highway and <br /> surrounding a number of potential drill sites. All of this permit area is affected land as defined in Rule <br /> 1.1(4). The Notice of Intent is deficient because it does not accurately describe all affected lands that <br /> the operator will be impacting. <br /> Highbury Resources is subject to San Miguel County land use requirements and must obtain <br /> a county special use permit in order to conduct the exploratory uranium drilling but has not done so. <br /> The county permit must be in place before the NOI can be approved, according to Rule 5.3.6. The <br /> construction of new roads or the upgrading of existing roads would conflict with longstanding San <br /> Miguel County policy to prevent the construction of roads and to limit their maintenance in order to <br /> preserve the historic character of the landscape. A number of historic drill roads in the Slick Rock <br /> area have been previously reclaimed and should not be considered access routes now. The Bureau <br /> of Land Management should also be consulted to determine whether use of the access routes <br /> proposed by the operator are in compliance with the Tres Rios Field Office's travel plan. <br /> The operator must prevent any drill cuttings or fluids from entering the watershed as required <br /> by Rule 5.3.1(d) but information about how this will be guaranteed is not indicated in the Notice. The <br /> operator should be required to use protective lining in the mud pits in order to prevent releases of <br /> toxic and radioactive wastes. Drill cutting and any other toxic or waste materials should not remain at <br /> the site and be disposed of in a facility off-site in order to protect the surrounding area. <br /> The NOI does not identify a source of water to be used during the project. It also states that <br /> three or four of the final drill holes will be converted into monitoring wells, but does not precisely <br /> indicate which ones or identify their locations. Rule 5.4.5(1)(a) requires that monitoring well permits <br /> be approved by the Colorado Division of Water Resources prior to approval of the Notice of Intent. <br /> Highbury also states in the NOI that drilling is expected to penetrate an unconfined aquifer. <br /> Rule 3.1.6(1) requires that impacts to the site's hydrological balance be minimized. The NOI should <br /> include information about how drilling into uranium ore bodies while intercepting unconfined aquifers <br /> will not result in contamination of ground water supplies or the Dolores River. The Division should <br /> require Highbury to submit a hydrological study of the site for public review prior to the initiation of <br /> any drilling activities. <br /> Rule 5.1.2(d)(vi) requires that legal documentation to enter BLM lands be provided before <br /> the Notice of Intent is approved. The NOI includes a detailed legal agreement between four <br /> corporate entities as evidence of legal right of entry. However, the Division should require verification <br /> from BLM that the legal agreement is not in conflict with their requirements to maintain right of entry <br /> and that BLM has approved Highbury's access right before any activities are authorized. <br /> The Slick Rock and Disappointment Valley areas adjacent to the general location of the <br /> proposed drilling activity are abundant in natural values and provide important habitat for wildlife, <br /> and any impacts to wildlife must be minimized in accordance with Rule 5.3.2. Activities should be <br /> restricted to the non-winter months when nesting or brooding species are not present. The Naturita <br /> Milkvetch (Astragalus naturitensis) and Gypsum Valley Cat Eye (Oreocarya revealii) have been <br /> located in the vicinity and are notable rare flora species. The Division should require that the specific <br /> drill sites be surveyed for these species and measures taken to prevent any specimens that are <br /> identified. Before any surface disturbances occur, it would be beneficial to survey the project area for <br /> any cultural, historical or paleontological resources, which are abundant in the area, and take <br />