July 18, 2026
GENERAL COMMENTS:
The Roca Honda PoO-MORP is significantly lacking the information and analysis as plan that is necessary to justify a permit for the development of a mine. At this time, critical information and analysis is missing on surface and groundwater quality, and on the characterization of the waste rock that will come from any underground workings.
At the present level of analysis, the PoO-MORP can only be used to justify further exploration drilling from the surface, which will be needed both to properly define the economic viability of the mineral resource, as well as to provide information necessary to plan the layout of the underground mine workings needed to remove the uranium ore.
There have been a number of changes to the project plans since a Draft EIS was developed in 2013. Since the Draft EIS, the only technical update appears to be an update to the groundwater modeling by INTERA (2017), which was included in the 2018 Baseline Data update. This groundwater modeling update did not resolve a basic critic by the USEPA on groundwater modeling (see comments under the heading of Groundwater Pumping in the comments on Section 6.3.10 below), it only restated RHR’s original position on the issue.
In addition to failing to respond directly to the EPA criticisms from 2013, the PoO-MORP applications do not provide the additional documentation and justification requested in the New Mexico Agency comments from 2010 through 2013. …
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