Comment on FR Doc # 2012-18352

1. What is the BLM's authority to impose any claim maintenance fees on pre-August 10, 1993 lode, mill site or tunnel site claims? Public Law 112-74 is very clear in that it refers only to such claims located "...on or after August 10, 1993,...". 2. If there is now no authority for the BLM to collect claim maintenance fees for pre-August 10, 1993 lode claims, how then does one hold these claims? By assessment work? By filing Notices of Intent to Hold? How does the BLM plan to refund maintenance fees for the pre-August 10, 1996 paid on or after December 23, 2011, the date of Public Law 112-74? 3. If the locator (or owner) doesn't qualify for a small miners waiver, again, how does one hold the pre-August 10, 1993 claims if there is no statutory provision for payment of annual maintenance fees for pre-August 10, 1993 claims? 4. Will locators (or owners) be entitled to refunds for payments made prior to December 23, 2011 pertaining to the 2012-2013 assessment year (i.e. payments made on or before September 1, 2011)? or any other prior assessment years? 5. Will the BLM withdraw or suspend the "...interim final rule..." including both Subsections (a) and (b) until it can adequately address it's authority particularly with respect to pre-August 10, 1993 lode, mill site and tunnel site claims? 6. This "...interim final rule..." with respect to pre-August 10, 1993 lode, mill site and tunnel site claims appears to fly in the face of the APA with respect to the BLM's statutory authority. The is much confusion among citizens who are vaild owners of unpatented mining claims (including those who own unpatented association placer claims) about the implementation of the both subsections (a) and (b) of Section 3830.21. There are many claimants who are affected by the new "...interim final rule..." It should be withdrawn, rewritten and put out for meaningful public comment before adoption by the agency (i.e., the BLM).