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lJ According to this article, it would appear that the American Soda process is likely to have an effect on dawsonite. As will be shown below, American Soda does not have the mineral rights to dawsonite and therefore dawsonite (aluminum / alumina's) must be considered in process solution and water monitoring program's analyses. The presence of dawsonite related compounds can also indicate the occurrence of destructive distillation of oil shale. AMERICAN SODA CORRESPONDENCE TO THE BLM Below are excerpts from a March 13, 1998 letter from Kurt Nielson of American Soda to Mike Pool of the BLM: "The task of attempting to develop the sodium minerels is seriously impeded by the unusual terms of these sodium leases." "The presently projected in situ mining operation may be limited and unnecessarily hampered by the uncertainties that remain because of the lease terms as they were issued. It must be remembered that the existing leases are total sodium leases that encompass all leasehold sodium minerals including dawsonite. However, the lease language impedes recovery of that soditun compound." "It makes far more sense to recognize the fact that in this area, oil shale's only possible value is as a production aid to produce alumina from dawsonite. Tn essence, oil shale is a soditan related product, not an independent product and should be included in the sodium lease." ....AND THE BLM RESPONSE TO AMERICAN SODA Below are excerpts from a Apri128, 1998 letter from Mike Pool of the BLM to Kurt Nielson of American Soda: "Thank you for your March 13, 1998, letter which raised several issues on development of your sodium leases in the Piceaoce Basin. Your letter identified three main issues: (1) e request to modify lease stipulations to allow higher temperatures for solution mining, (2) a lease exchange proposal, and (3) a request to modify or remove stipulations that would allow the extraction of the sodium mineral dawsonite." "Due to the solubility characteristics of dawsonite and its coexistence with oil shale, your third request will necessarily involve the destructive distillation of oil shale. The retorting process will create the leasable mineral shale oil or kerogen. The only authority the Bureau of Land Management (BLM) has to sanction the production of this commodity, even as a by-product, is through a lease issued under the authority of the Mineral Leasing Act of 1920. Your existing soditmt leases cannot be modified to allow the production of oil shale...... For these reasons, any new lease issued to authorize the mining and processing of oil shale and, in cogjunction with that operation, the recovery of dawsonite intermingled with and a wnstituent part of the oil shale deposit, will, of necessity be an oil shale lease or a multimineral (oil shale and sodium) lease."