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~~ ~ <br />~ MICHAEL C. IRELAND, P.C. <br />Artomev a[ lain <br />permit application by Rio Blanco County that you should know before approving this permit <br />application. First, as stated above, it has become clear that the baseline data reported in the Draft <br />EIS for ground water is not adequate, and indeed, it may be skewed. The grouml water data <br />were selected from more numerous data, and may have been selected in a way that suggests that <br />the ground water quality may be worse than it really is. Of course a finding that baseline ground <br />water quality is poor would help American Soda show that its project's negative impacts on <br />ground water might not matter as much. Also, American Soda has been operating test wells as <br />pan of an experimental mine approved by the BLM. Because inadequate baseline work was done <br />before approving these wells, it is possible that the test wells have negatively affected ground <br />water quality in a way that will make establishing a good baseline difficult or impossible now. <br />During the same hearing, American Soda asserted that it could well recover $600,000,000 <br />in resources from the operation. Given the potential profits and their description of operating <br />costs, this is hardly a marginal project that will fail if six months or a year is set aside to establish <br />reliable baseline data before a permit is issued. <br />Given the unusual progress of this application, and the grossly inadequate EIS prepared by <br />the BLM, I believe you have no choice but to prepare a Supplemental EIS before approving the <br />UIC permits American Soda has requested. Otherwise, EPA may be out of compliance with its <br />own NEPA obligations. I welcome the opportunity to appear at your July 13 hearing on behalf of <br />the Colorado Native Plant Society to further clarify these comments. <br />Yours sincere) <br />~~~~. <br />Michael C. Ireland <br />C:\AAyF files\U ICobj ect607.ltr.wpd <br />