Jim Briscoe Comment Submission to DOI Review of the Ironwood Forest National Monument

Below is Jim Briscoe’s comment submission to the Department of the Interior to urge Secretary of the Interior Zinke to repeal the needless protective designation for the Ironwood Forest National Monument. Along with his letter, Mr. Briscoe  submitted his recent presentation to the AMIGOS Friends of Mining Group in Tucson on June 9th. You can click on the image to view the 20 page presentation about the work stopped at the East Silverbell Porphyry Copper Project just as discoveries were being made to make way for the hastily and poorly conceived Ironwood Forest National Monument.

We urge LBSR shareholders and interested citizens to make public comment as well. We have provided instructions on how to contact the DOI and White House to exercise your democratic freedom to make your voice heard by the government. Click here: “WE NEED YOUR HELP: Exploration of East & West Silverbell…” for instructions and a sample letter. Act soon: the public comment period ends July 10th.

June 20, 2017

Secretary of the Interior Ryan Zinke

RE: April 26, 2017 Executive Order instructing Interior Secretary Ryan Zinke to review any national monument created since Jan. 1, 1996, specifically The Ironwood Forest National Monument, Arizona

Dear Secretary Zinke:

My name is James A. Briscoe. I am a voter, taxpayer and the CEO/Chief Geologist of an emerging mineral exploration company based in Tucson, Arizona. I, like the majority of Americans, want to see our national economy grow by fostering domestic industries. I would like to offer my support to the rescinding of the National Monument designation conferred on the Ironwood Forest National Monument in southeast Arizona.

Let me phrase the issue as a question; what if there was no Ironwood Forest National Monument? So, what? What would change if the protective national monument designation was removed from that area? The answer: nothing.

  1. The preservation of the endangered ferruginous dessert pygmy owl that started the whole thing, the outcry for a protected area in the late 1990’s, is a non-issue now. Even when the monument was founded, the little owls’ status as endangered was based on a pillar of false and bad science. But today, and for several years now, the pygmy owl is not endangered, and never was. The two species under protection of the Endangered Species Act were declared no longer Endangered by the 9th Circuit court of Appeals in 2006. Without the National Monument designation that population is fine.
  2. The preservation of the endangered lesser long-nosed bat: of which one specimen was found some time ago and are regarded as migratory and not settled to the area. Without the national Monument designation, that situation doesn’t change.
  3. Bighorn sheep. What would change without the national Monument designation? A small herd has thrived in the North Silverbell mountains for about 60 years of my personal experience and they interact with humans and their habitat is enhanced by the active mines: once they thrived all over Pinal and Pima County but with hunting pressure they declined and have been absent from most of the area for decades. The national Monument designation didn’t change things. Recently, hunting organizations and the State Game and Fish have tried to introduce new herds around the Tucson foothills and mountains without much success but around the mines the Bighorn sheep have thrived.
  4. Another endangered species: the Nichols Turk’s Head cactus. Those don’t naturally persist near ironwoods in the 1st place, only living on Silurian limestones (I learned about these cacti while out on a field visit with science contractors from the Arizona – Sonora Desert Museum).  There are minimal Silurian limestone rocks in the Ironwood Forest National Monument, ergo few Turk’s Head cacti.  It is generally regarded that there may be more on the Silurian limestone on the Tohono O’odham lands outside but adjacent to the Ironwood Monument. They grow elsewhere where there is a rock friendly environment for them.

What would happen then if the protective designation ended for the endangered flora and fauna just mentioned?  They will be fine. For southern Arizonans? What changes is the ability for local vendors and workers to work at copper mines. Because of scientific exploration methods costing millions, we have defined 10 to 12 porphyry copper and multi -metal mineral deposits and partially defined one of these by drilling. There are 10 or more targets in the area, in addition to the 4-mine operation currently running under ASARCO.



This is the 21st Century and my company and other exploration and mining companies aim to bring the technological advances in our industry to the area currently banned from exploration and development.

My ideas, presented to the Nuclear Regulatory Commission in Denver [2008] envision modern mines that will not emit sound, dust, light, or contaminated water.  Slopes will be revegetated immediately on construction of perimeter berms within which all mining will be contained.  Slopes will be revegetated immediately; all mining facilities will be concentrated interior to the berm and all evidence of the mine will disappear.  All mine overburden, if any, will be placed inside the exterior walls as will the crushed, cleaned, rock -CCR (previously referred to as dry stack tailings) will be consolidated as back fill or sold as a valuable byproduct.  On exhaustion of economic mineral reserves, all mining equipment will be removed, perhaps to another location, nearby or far far away, and any remaining industrial facilities will be conserved and/or repurposed for future use. These practices are coming off the drawing boards and some are in use at the newest mines.

The above described operation(s) will have a very small footprint.  Animal life and typical vegetation will be enhanced and the terrain will go back to the way it was, and multiple uses such as cattle grazing, hunting, outdoor recreation will continue as before, with no evidence of mining except for connecting road work which will be concealed by natural vegetation and colorization.

The communities of Arizona and greater Tucson, Pima County, Maricopa County, and Pinal County will benefit from tax revenue, jobs, and other economic benefits from these mines which could last 100 years or more in total.

For our company, the exploration would be a continuation of the work halted in 2000 when the Ironwood Forest National Monument was declared. Before the termination of exploration, JABA Inc., a Canadian public company, under the leadership of myself and Dr. John Guilbert, a Mining Hall of Fame inductee, had discovered an enriched copper blanket typical of porphyry copper deposits and particularly the Silverbell porphyry, verified by drilling of rotary drill holes.  We were stopped dead in our tracks before we could get an accurate measure of the true grade of the copper mineralization and rock alteration by the enactment of the Ironwood Forest National Monument.

Our project, the East Silverbell Porphyry Copper Project, has a complete record of exploration data, including soil geochemistry, geophysics, high resolution color aerial photography, and drill logs. We will release the data soon and we invite inspection of it as evidence that withholding this land from development is a chokehold on the local economy for reasons that are no longer, or never were, compelling.

The stated reason for the reviewing of 27 national monuments, mostly in the western states, is to roll back unnecessary and unfair withdrawals of public lands from becoming productive. Reconsidering and abolishing the national monument status of the so-called Ironwood Forest with this reason in mind, to give land back to the people so they can make it productive, should make for a quick and easy decision to repeal. Yet, there are loud cries from preservationist calling for the retention of the protected status for biological imperatives that simply do not exist.

Because of a long string of victories based on specious science and emotional appeals in previous administrations, I worry about the repeal of the Ironwood Forest National Monument not happening. Local and national environmental groups are very good at getting their loyal cadres in front of politicians. We in the mining industry have not performed as effectively, but I believe that a clear-eyed analysis of this terrain by competent personnel could only yield one decision: repeal. There is no need to specially designate this area as hands off to the mining industry, an enduring cornerstone of Arizona’s economy.

As a result of the imposition of the mineral exploration ban caused by the declaration of the Ironwood Forest National Monument, our investors, mainly Canadian citizens, lost all of their investment and vowed never to invest in anything in Arizona again.  That vow may fade with the years, but it still leaves a stigma on the State of Arizona, as the development ban was promoted by the Pima County Board of Supervisors, several of whom are still in office, including the County Administrator.


James A. Briscoe
James A. Briscoe| CEO/Chief Geologist
Liberty Star Uranium & Metals Corp.

      Click Image to view slide show

“Ironwood Forest National Monument under review by the Department of the Interior” presentation and comment document submitted to DOI June 20, 2017


 Link to Regulations.gov submission https://www.regulations.gov/document?D=DOI-2017-0002-175945


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Liberty Star Uranium & Metals Corp.
Tracy Myers
Investor Relations

One Response to Jim Briscoe Comment Submission to DOI Review of the Ironwood Forest National Monument

  • Wayne Trenkelbach says:

    Hi Tracy,

    Below is my comment submitted this morning July 10th. I wish you, Mr. Briscoe and the whole team all the best. Wish I could do more to help. You have all shown remarkable perseverance. God Bless You All.

    Wayne Trenkelbach

    Secretary of the Interior Ryan Zinke

    RE: April 26, 2017 Executive Order instructing Interior Secretary Ryan Zinke to review any national monument created since Jan. 1, 1996, specifically The Ironwood Forest National Monument, Arizona

    Dear Secretary Zinke:

    My name is Wayne Trenkelbach. I am a voting, tax paying citizen and an active investor. I firmly believe that we as a country need to put our resources into industries that produce real jobs and real wealth if we are to “Make America Great Again”. I am writing in support of removing the National Monument status of the Ironwood Forest in Arizona.

    It is my understanding that this designation was created under questionable and maybe even false information. Specifically for the preservation of the ferruginous dessert pygmy owl which has been proven to be false and not endangered. If this is true, the federal protection should be dropped and responsible mining allowed.

    Our country’s economy has been languishing, basically treading water for years. I believe that it has been propped up in many different ways. One example is a stock market that has been inflated by entities that produce cheap money which is used to purchase stocks giving the illusion of prosperity and growth. This is a false economy which is at some point doomed to fail. It is my firm belief that one component that will be needed to “Make America Great Again” will be to free up our industries and natural resources, really our national treasures allowing them to become productive once again. I believe this would generate real value and real jobs for many Americans.

    I love nature. I enjoy hunting and fishing and love to spend time in God’s creation. I respect the environment and teach my children to do the same. I want responsible mining to take place and would expect mining companies to be held to the high environmental standards that have been established.

    In conclusion I urge you to be pragmatic in making your decision and remove the National Monument status of the Ironwood Forest in Arizona. I also strongly encourage you in your task to carefully consider each of the other 26 National Monuments rescinding each one if you find they were unjustly created and are hindering our country’s future growth. Please do your part to “Make America Great Again”.


    Wayne A. Trenkelbach

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