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site visit by the BLM staff); and the injection fluid temperature was revised to allow temperatures greater than 300° Fahrenheit. When the Decision Record was issued for the Test Mine Plan, the interested parties assumed that the COAs would be implemented and that the public interests would be protected by these COAs. I realize there is a balance between facilitating the use of resources on public land (conservation) and protecting these resources to the point they cannot be exploited (preservation). Yet, in the BLM's role as stewards of public land revision of COAs without the public's knowledge or involvement creates concerns about the BLM's commitment to implement the required mitigation for the commercial mining project currently under consideration. It leads to the question, if American Soda's commercial mine plan is approved and COAs established, can the public rely upon the BLM to implement those COAs that are identified in the EIS. Some statement of policy and reassurance to the public would be appropriate given the pattern shown in the Test Mine Plan. Water Oualitv Issues If my interpretation of the water quality data summarized below is correct, the mining method being implemented by American Soda is impacting groundwater quality. Not only is the data itself questionable, the implications of the data for American Soda's mining method is that significant degradation of the Upper Aquifer has occurred from implementation of the Test Mine Plan. First, fluoride values in the Upper Aquifer monitoring wells would seem to indicate that fluids from the Lower Aquifer have been released into the Upper Aquifer. Second, when an isolated Total Dissolved Solid (TDS) value such as 29,400 TDS (Well 20-5, 6-29-98) occurs in an aquifer that is supposedly a designated Drinking Water Aquifer, it should ring bells and result in an immediate investigation as to the cause of that value, be it a sampling or analysis error or a release of drilling fluid into the affected area. Additionally, as shown in the graph developed by my investigations (attached to this document), the monitoring data shows that the aquifers underlying the American Soda's mine area are connected, not isolated. _ The conununication between the aquifers beneath the mine site has very substantial consequences for the potential environmental impacts of a commercial mining operation and these data and analysis were not included in the Draft Environmental Impact Statement (DEIS) prepared for the commercial mine project. It is absolutely essential that these monitoring data and all of the implications be included in the analysis contained in a recirculated DEIS. Commercial Viability The goal of the Test Mine Plan was to validate the environmental consequences of American Soda's untested mining method and also to demonstrate the commercial viability of this method. After two years (80% of the time allocated to the Test Mine Plan under the BLM's Record of Decision in May 1997) and several test wells, American Soda has produced only 7,655 tons of sodium minerals. Although an applicant has a right to risk money on a nonviable mining operation, it should not be allowed to occur when significant environmental resources are also at risk. Has American Soda 2