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that an immediate concern for economic growth is not conducive to the detailed consideration of regulatory requirements that must last, by American Soda's own account, at least 30 years. This is not an abstract concern. The Monitoring Program itself betrays hasty preparation. For example, the premise of the direction of groundwater flows (p.5), on which the appropriate location and number of the monitoring wells depends, is closer to assumption than fact. No scientific evaluation of that premise is possible with the data that have been disclosed. In the event that [he supposed groundwater d'uections are incorrect, the entire proposal for the location and quantity of monitoring wells is likely to be flawed. Without the data and detailed analysis of how American Soda arrived at the conclusions concerning groundwater flows, it is impossible to evaluate and approve the monitoring plan. Further, the standards for some pazameters, such as alkalinity, chloride, and sulfate, are so extraordinarily high that the baseline will not be meaningful. One blatant example is the PQL and MDL for chloride which is off by several orders of magnitude. The high thresholds will delineate a baseline which reveals little, and which cannot provide a meaningful standard for later monitoring. The statute wisely counsels that the preliminary science be completed, and digested in the crucible of public cornment, before pressure is allowed to build for the commencement of operations. The Monitoring Program is headed in the right direction but is in need of more careful•consideration and review. It must also be carried oui before mining operations begin. The second policy underlying the stamte is a recognition that it is difficult to halt or even meaningfully adapt a project that is already under way. Comment 14 testifies to American Soda's desire to commence commercial operations as soon as possible. It is hard to imagine that American Soda will have lost this desire after thirteen months of data have been collected. Given the poor choice of PQLs, we know in advance that the data will be inconclusive, but one can anticipate that American Soda will insist on going forward because it will have satisfied the DMG's demands as embodied in the Monitoring Program. In the event that the Monitoring Program is adjusted to provide for a sound baseline, and that the data eventually prompts the DMG to propose conditions or bonding requirements which are economically unacceptable to American Soda, there will be an equally predictable clash. American Soda may be prepared to take the regulatory risks associated with developing baseline data after the fact, but these are not risks that the statute allows American Soda to take. Further, American Soda was in a position to have avoided this kind of delay by preparing a baseline while conducting its pilot plant operations. It chose not to do so, and there is nothing about this choice that authorizes the DMG to waive the requirements of the statute. There are also other concerns about the methodology being employed, which likewise azgue that American Soda is not ready for permit authorization. At several points in the text of page A-1 through A-3 of American Soda's Environmental protection Plan Summary Reference Document, American Soda addresses the issue of toxic materials that will be disposed or disturbed as a result of mining operations. It does so by brief reference to definitions in the rules; general denials that designated chemicals will be used; and broad