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i <br /> <br />protection levels may not be deferred for thirteen months while tha Monitoring Program is being <br />conducted, and American Soda may not proceed with development activities in the interim. <br />Further, the establishment of standards after the application has been granted is <br />inconsistent with the Rules for public participation. Rule 1.7.1 provides for comments on any <br />permit application. However, until the results are in, there are limits on the meaningiuf comment <br />that can be made on either the Monitoring Program, or appropriate numeric protection levels. An <br />objector would also be foreclosed ent'arely from questioning whether Monitoring Program has <br />been property carved out. <br />The DMG Response to Commrnt Number 20 is an argument for an exception to the <br />statute and Rules. The exception is contrary to the requirements of Rule 3.1.7(3). <br />2. Collectiaa of data does not eliminate the need for exercise of judgment, and <br />therefore cannot eliminate pressures to a:ereise judgment in favor of the project once it is <br />underway. <br />The DMG assumes that the data collection effort contemplated by the Monitoring <br />Program will be successful. It does not account For the possibility that the cxeattion of the <br />Program may prove to be flawed, or that the results may in some other way be inconclusive or <br />unsatisfactory. This is not mere speculation. One of the American Soda wells which had <br />produced suspect data has akeady been removed from consideration. As a General Chemical <br />witness will note, groundwater quality may not be uniform in the aquifer, and groundwater flows <br />