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WESTERN MINING ACTION PROJECT <br />Roger Flynn, Esq., <br />Jeffrey C Parsons, Esq. <br />P.O. Box 349 <br />440 Main Street, Suite 2 <br />Lyons, CO 80540 <br />(303) 823-5738 <br />Fax (303) 823-5732 <br />wrngp @ipc.org <br />via email, hardcopy to follow via U.S. Mail <br />Mr. Berhan Keffelew <br />Colorado Division of Reclamation Mining and Safety <br />1313 Sherman Street, Room 215 <br />Denver, CO 80203 <br />August 17, 2009 <br />RE: Black Range Minerals, Ltd. Prospecting Application, File No. P-2009-025 <br />Dear Mr. Keffelew: <br />These comments are submitted on behalf of Tallahassee Area Community, Inc. (TAC) <br />and pertain to the uranium prospecting operation recently proposed by Black Range Minerals, <br />Ltd. in Fremont County, Colorado (File No. P-2009-025). TAC is a non-profit organization <br />made up of landowners and concerned citizens directly affected by the uranium prospecting <br />activities proposed by Black Range Minerals. TAC is focused on protecting communities and <br />natural resources from the impacts of proposed uranium mining in Fremont County, Colorado. <br />TAC understands that the Division is currently conducting its expert review of the application, <br />and will issue an adequacy determination on the application in the near future. We sincerely <br />hope these comments aid in that technical review and also further a productive regulatory <br />process aimed at ensuring protection for public health and the affected natural resources. <br />At the outset, it appears that complete information in the application is missing. For <br />instance, the public Notice failed to provide appropriate surface location information, listing only <br />Fremont County as the location. However, the Notice also indicates that portions of the surface <br />properties that will be impacted by the prospecting activities are federal public.lands managed by <br />the U.S. Bureau of Land Management. The BLM requires disclosure of specific surface location <br />information prior to authorizing any exploration work. Fremont County has also requires <br />specific location disclosure as part of the applicant's local conditional use permit. Thus, this <br />information should not be hidden from the public in the state permitting process. This lack of <br />critical, but non-confidential information serves only to confuse the process, frustrate a full <br />understanding of the project, and raise barriers to meaningful public participation. The Division <br />should request that Black Range Minerals provide the Division all location information, <br />including maps and descriptions that are not legitimate confidential business information.