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<br />The BLM specifically denied American Soda's request to recover the mineral dawsonite. This <br />further supports our claim that dawsonite (and related by-products) should be monitored as part <br />of the American Soda operation to ensure this valuable mineral is preserved and protected <br />according to the lease requirements and that appropriate safeguards are in place to protect oil <br />shale. <br />SUNIMARY <br />Given that the distillation of oil shale is temperature and time dependent, American Soda <br />has not provided evidence the distillation of oil shale is not occurring. Furthermore, there <br />have been numerous attempts and inferences by American Soda to extract the alumina value <br />(from dawsonite) yet this is strictly forbidden under the current terms of American Soda's <br />current sodium leases because the removal of dawsonite implies the destructive distillation of oil <br />shale. <br />Since much of the information developed by the American Soda pilot operations has <br />been guarded under the auspices of confidential information and since American Soda has made <br />numerous references regarding the extraction of dawsonite we are lead to believe that such an <br />extraction must have been or is occurring in order for American Soda to have developed the <br />data. American Soda should be required to release this information for public review. An even <br />larger concern is that American Soda can not economically operate without using temperatures <br />which destructively distill oil shale. Since American Soda has not provided any information <br />regarding the feasibility of dawsonite extraction in this permit application or any other <br />regulatory filing the removal of this mineral, or the conversion of this mineral to other <br />aluminate products must be protected and monitored as part of any reclamation permit. Without <br />an accurate characterization and understanding of the solutions that will remain in the American <br />Soda cavities after nacholite extraction, the DMG and the public can not adequately assess this <br />reclamation permit especially as it relates to preservation of aquatic resources. <br />Since ely~ <br />hn C. Ehmann <br />ir. of Operations <br />