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<br />The steps which objectors would have American Soda take-i.e., five quarters of <br />testing prior to permit issuance~an only be accomplished by drilling wells through the <br />same aquifers through which they will be drilling pursuant to the Groundwater and <br />Surface Water Monitoring Plan. The only benefit which might be obtained by following the <br />suggestion of General Chemical is that the American Soda Mining Operation would be <br />delayed for 15 months which would serve the objectors' financial interest, no one else's. <br />DMG's Staff Report is clear, that is-it is not necessary to collect five quarters of ground <br />water baseline information prior to permit issuance. It is Staff's opinion such a delay would <br />not improve in any way DMG's ability to develop permit conditions protective of the <br />ground water resource. <br />CONCLUSION <br />The fma l Groundwater and Surface Water Monitoring Plan as prepared by American <br />Soda and approved by DMG, BLM, the County Commissioners of Rio Blanco County, and, <br />informally EPA, will be implemented immediately upon issuance of the requested <br />Reclamation Permit. It will provide the best possible water quality data for the Mine. <br />American Soda's application complies in all respects with the statutes of the State of <br />Colorado and applicable Colorado Regulations. Issuance of the Reclamation Permit as <br />requested by American Soda serves not only American Soda's interest but the interest of the <br />citizens of the Western Slope of Colorado and the general public as well. <br />k <br />Respectfully submitted this ~~ay of June, 1999. <br />& GREEN, P.C. <br />B (~.~ l 2 ~ <br />Y <br />Christopher oyle #2966 <br />Attorneys for American Soda, L. <br />P.O. Drawer 790 <br />818 Colorado Avenue <br />Glenwood Springs, CO 81602 <br />Telephone: (970) 945-6546 <br />Facsimile: (970) 945-8902 <br />AMERICAN SODA -6- BRIEFING PAPER <br />