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prom aarnaei ~.. oemro io. nv. man .wc+a.,, <br />LJ <br />Mr. Larty Shults <br />Bureau of Land Management <br />White River Resourcz Area <br />73544 Highway 64 <br />Meeker, CO <br />Dear Mr. Shults: <br /> <br />Michsel C. Ireland P.C. <br />225 N. Mill #203 <br />Aspen CO 81611 <br />A~ick(akofnet <br />April 15, 1999 <br />As one of the people who submitted comments on the Draft EIS for 1he.American <br />Soda Yankee Gulch project I am writing to express my continuing concern about two <br />issues that plague this project (1) the lack of baseline data and other important <br />information in the EIS; and (Z} the atteanpts to shroud critical formation under the rubric <br />as "proprielary.° <br />Baseline Data <br />In my Mazch 8, 1999 ]erier I noted the inadequacy of baseline ground •water data <br />in the EIS. This is a fatal flaw in the EIS; it cannot and will not stand as written. <br />Without competent baseline data, you simply cannot judge the likely enviromnental <br />impacts because you have no starting point. Though the EIS is missing baseline data for <br />air, surface and ground water, I am particularly concerned about the lack of ground water <br />data. 'Ilse EIS acknowledges than degradation of ground water quality could occur, either <br />because of subsidence, because of movement of heated pressurized water ihrc~ugh <br />fracturing in the bedrock, or both. Howaver, there is no real baseline data in the EIS and <br />so there is way to evaluate the likelihood or extent of such impacts, and there will be no <br />way to evaluate precisely during operations whether and where such impacts are <br />occurring. <br />Dan Jackson of the EPA admitted to me by telephone thatthe UIC permit cannot <br />be issued absent the baseline data and a monitoring plan -he concedes the EC-2 rating of <br />the DEIS precludes issuing a permit. However, he said the applicant had offexed more <br />information and pronri sect it would be available on issue of a draft permit. I do not <br />understand how the DEIS can be finalized without public comment on the same <br />information used by the EPA in evaluating a UIC permit. <br /> <br />! ,~ <br />The project proponent, American Soda acknowledged that ground water quality <br />baseline data in the EIS aze "anomalous" during a meeting this week of the Frio Blanco <br />