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Delete subsection (c)(a), (B) and (c). Subsection
to rely on the location on the ground.
flicting locations? This provision needs additional
thought and/or clarification. (h) Boundaries of mining class will not neet at center of
earth if they are vertical unless bill repeals lavs of solid geometry elsewhere. Suggest consideration of language contained in Townsite Act with regard to valid existing rights. Also, an exception to protect valid
existing extralateral rights should be added. Section 104 - chal kalatenango Reguirements. General Comment It is not clear when diligence paynents vill
cease. Diligence payments shouid continue only until orebody is in production. Provision should be made for clain relin
Need to be able to rely on deferral of development.
fee would be consistent with existing practice for federal oil and gas. A $5.00 fee is excessive prior to reaching the production stage and is also excessive when considering the number of acres involved in devel
opnent of a hardrock mineral deposit.
fees and other operating costs. List of diligent
shouid be a defined tern.
(c) (2) (A) After word "survey" add words "including aerial sur
(c) (2) (B) Delete word "Bulk."
(C) (2) (C) Add "and drill pads."
Suggest expenditures as follows (should be maximums and
All expenditures should have a carry forward position. (c) (4) Affidavit neod show only that claim holder complied
with requirements set forth in bill. The list of diligent development expenditures in bill should be only basis for Secretarial challenge. The meaning of
the term "beneficial nature" is questioned. (c) (5) five years is too long to keep records. (a) (2) Payment in lieu of diligent development is acceptable
only if allowed in certain years. Amounts should be identical to those specified in diligent development expenditure section. Lower amounts make it more condu
cive to speculate. (a) (3) Making an election to pay in lieu of work binding for
five years is anti-development and pro-speculation.
concept, but, there is no reason for a limitation.
horrible waste of taxpayer's money. A notation of the
master title plat shoulă be sufficient.
Page 16, line 13 change word "procedures" to "regula-
(h) Need time limitation, tied to record retention require
ment, on Secretary's authority to conduct audits.
Bection 105 - Popeltid.
Penalties are totally out of proportion to listed
tion. Perjury is already a felony. Beation 106 - use of on-kining chain Lande.
Inadequate for intended purpose. Secretary has total
Beation_108_- hinitation on Patant Iosyang.
(a) claim holder should have right to perfect existing
clain, receive patent and mine it under present system
nating rights to vegetation woulā be a good model.
(b) Same comment as for Section 108(a). Bestion 110 xineral materials
The term "mineral material" needs to be defined.
Section 201 - surfigo kunagement Requirmentle
(a) Meaning of "minimize adverse environmental
impacts" unclear. Suggest Federal Land Policy and
dation be adopted (section 302(b)).
overwhelmed. (b) (2) (A) and (B) Change word "may" to "shall." Too much Sec
(b)(3) Secretary must be given time certain in which to ap
prove plans of operations. Current regulations mandate
partial release of "financial guarantees."
ing. Mining will be banned on all lands that have not been subject to land use planning. Prohibi
tion of mining is unsatisfactory.
because of a single violation.
high standards for reclamation with an enormous amount
to clarify intent.
be allowed to proceed on basis of an approved plan of
leat192 292 - Inspection and Encorcerent,
(based on 1.2 million recorded mining claims). Is this
really necessary? Sone limitation is needed. (b), (c), and (a) Objectionable, but innocuous when viewed in
perspective of citizen suit provision. (e) citizen suits are completely objectionable and unneces
sary. will add unnecessary expense to mining operations.
gestion 203 - Lindore Plan
These provisions strike at the very heart of self-
and unalterably unacceptable.
section 201 (b) (4) rather than 201(b) (5).
plete. This language should be reinserted. section 204 - Lande Hot open to locatione
The amount of land removed from mining claim location by this provision is staggering. Thrust is to prohibit nining: not encourage. Closing lands which "may here
after be withdrawn" amounts to 100% of public land. section 205 Berings Classe
Non-preemption of state environmental laws will allow State and local governments to zone land uses on public lands. States should not have authority regulate mining claims. Pervasive reclamation requirements of bill leave no room for state discretion and such laws should be preempted. Should also exempt mines from Resource conservation and Recovery Act requirements to avoid duplication and inconsistency.
seation_col- Jurisdictione pollos functionne
Definition of Secretary should be transferred to Section 101. Opens the door to establishment of conflicting mining law policy: one by the Secretary of Agriculture, one by the Secretary of Interior,
sogtlon 402 - Osor teele
Fees are open ended.
This is objectionable.