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<br />Comment 3 The Reclamation Permit Application Does Not Address The Impact on <br />Future Mineability of Oil Shale and Therefore Is Incomplete (Mining Method, Pg. D-2 <br />and Preference Right Sodium Lease Serial Number C-0118328) <br />The sodium leases provided to American Soda specifically stipulates that groundwater <br />resources and rich oil shale with grades in excess of 25 G.P.T. must be protected. <br />Why is there no mention at all of the adverse impact the solution mining operation will <br />have on the oil shale matrix and the present future mineabikity of this valuable <br />resource? If American Soda has indirectly inferred (i.e. by not commenting on future <br />mineability of oil shale) that this is not an issue because there is no impact, where is the <br />supporting evidence? <br />Comment 4 No Mention of Posting of Reclamation Bonds (Parachute Site Structure and <br />Facilities, Pg. D-S) <br />Will the DMG require American Soda to post reclamation Bonds for the disturbed areas <br />at the Parachute site including the four ponds and for disturbed areas of the Piceance <br />site? If not, why not? <br />Comment 5 Unita and Piceance Sites May Contain Potable Water (Table D-3, Pg. D-1~ <br />Perched aquifers are known to exist in adjacent properties to the leases held by <br />American Soda. Has American Soda diligently investigated the presence of a perched <br />aquifer beneath their leases in the Unita formation? What, if any, definitive hydrologic <br />tests were conducted to determine the existence, extent, and water quality of such a <br />perched water system beneath the American Soda project site? Have specific pump <br />tests been conducted to determine the presence of a perched aquifer system? If such <br />formations exist, there is a high probability such an aquifer contains drinking quality <br />water. Since American Soda's leases stipulate that groundwater resources must be <br />protected and since perched aquifers aze know to exist in adjacent properties shouldn't <br />the Reclamation Permit Application address this issue? <br />Comment 6 What Contingency Places Are In Place For Erosion and Sediment Control <br />(Section 4.0 -Evaluation Of Reclamation Success, Pg. 8) <br />If erosion and sediment control measures aze not successful, what type of remedial <br />actions will be used in these problem areas? <br />Page 2 <br />