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Frank G. Cooley, Self and Handed in Written Statement by John R. Donnell The comments (both written and oral), received on the Draft Statement of Basis (SOB) and the Permit, have been paraphrased and grouped into major topics of common concern with responses provided that address the issues within the listed topic. This response to comments is considered to be an addendum to the existing SOB and is part of the EPA's Administrative Record for the Yankee Gulch Class III Permit. Response To Issues and Comments Comment I: The Permit should not be issued. The following eight (8) paraphrased comments express opposition to the issuance of the Permit: 1. To meet its obligations under NEPA and the Safe Drinking Water Act, EPA has no choice but to withdraw the Draft Permit and to commence preparation of an SEIS using complete and correct ground-water baseline data and information about the injection process, subsidence resulting from operations, and the likelihood of upwazd movement of contaminants from the injection zone into underground sources of drinking water. (This issue is specifically addressed in the response to comment 2.) 2. The EPA's proposal to issue a Permit and then requ've the gathering of baseline data is backwards and begs the question: Why is EPA in such a hurry to issue this Permit? 3. We (Rocky Mountain Chapter, Sierra Club) look forward to the EPA withdrawing the Draft UIC Pernut in light of the numerous issues yet to be resolved. 4. We (Colorado Native Plant Society, Yampa River Branch) aze not opposed to all development, but we aze opposed to development at any cost to the environment and resources of the State of Colorado. 5. The applicant has submitted erroneous ground-water data. The applicant has been involved in deliberate deception regazding the ground-water data submitted for use in developing the Draft Permit. Deny Permit until the ground-water baseline data for this project is redone. (This issue is also addressed in the response to comment 5.) 6. Why must the EPA approve all 550 wells to be used over the next 30 years, especially when so much crucial information about effects of those wells on overlying USDWs is missing? The Area Permit should not be issued until more information is gathered. (This issue is also addressed in the response to comment 3.)