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completed even one full size test mine cavity? If it has, then the recovery of 7,655 tons of sodium minerals per well would indicate a need for at least 180 wells just to meet one year of anticipated production (1,400,000 tons of sodium products). If it has not completed a full size test mine cavity, then it would be premature to authorize a commercial mine operation based on assumptions, and not on the real or actual ability of the mining method to be successful. The extent of resources impacted by the proposed commercial mining operation and the potential for long-term signi£cant damage to surface water and groundwater resources of the Piceance Creek Basin are not justified. The DEIS must incorporate the data from test wells as part of the analysis of commercial viability. Otherwise, all of the forecast consequences in the DEIS relying on assumed production from wells are likely to be invalid. Overall, how can any person or other party make any assumptions about the project, when the monitoring data are not included in the DEIS; when the BLM is altering its conditions of approval without any public notification; and when the commercial viability of American Soda's mining method is not yet. validated. My specific comments and concerns regarding the materials transmitted are summarized below. Item 1: Has BLM verified OLat the Substitute Water Supply Plan was actually approved and that the conditions of that Plan are actual)}• being fulfilled? What level of assurance for water supply will be required by BLM before allowing the commercial mining plan to be initialed? Funkier, has anyone examined the adequacy of water volume from the water supply well to mmt all waterdcmand during conswction and initial operations before the pipelines arc completed to the Parachute Site - Item 2: The January 7, 1998 letter changing the frecba~rd requirement from four feel to two feet does not pro~~de any rationale for this change which is the specific data I requcstcd. Local winds and fetch conditions may cause wave action that can e~cecd four feet during very windy periods. What data were submitted by American Soda to justifi' a bvo foot freeboard? In older words, BLM established a COA that must have been based upon some assumptions or premise. This COA was changed, what data were provided to justify this change? In light of the potemi•il for wave hciglns substvttially excceding nvo feet, what does BLM intend to do to address this issue. 1 specifically requcstcd dtc monitoring data that verifies that the (recboard requirement has not been violated? These data were not provided. How is the freeboard monitored to ensure that it is being maintained? if no data are available, how dots the BLM know that American Soda is complying with the freeboard COA. On what basis is the statement made that no accidental discharges have occurred? Please provide the data to verify this statement. The package of infonnvion transmiuod to me was missing some of the attached materials that were identified as being included in response to my FOIA. I did not receive a copies of the approvals allowing discharges of the pond water into the drainage. Therefore, I need to see the two documents that authorized such discharges. Such permission ntusl include a number of assumptions, including the specific water quality (in temts ofoonslituenls and mncemmtions) thresholds that must be met and the verification of water quality that must be available to allow such discharges. Neither the BLR1 nor the State have the authority to allow discharges tlmt exceed state and federal regulatory water quality standards that could harm Piceance Creek. Regarding the damage to vegetation Gom core hole 20-]0, my field notes are at variance with tJte statements of damage in both your comments and American Soda's Report of Undesirable Event (RLJE). Specifically, my notes indicate that the damage extended about 100 yards or more down slope from the well pad and the 3