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<br />2. [Aquifer Det"mition] <br />The Agipito Associates, Inc. ("AAI") Ground Water and Surface Water Monitoring Plan does <br />not define the referenced upper and lower aquifers. The plan also does not discuss the <br />monitoring of the upper portion of the Lower Aquifer. Without this information, the plan is <br />incomplete and does not provide enough information to determine if the hydrogeological <br />quality is being adequately preserved. <br />3. [Groundwater Contamination] <br />To accurately characterize baseline water quality data measures should be taken to avoid <br />aquifer communication. The most important aspect of all well development is the prevention <br />of communication between aquifers. The Applicant provides no discussion on how the <br />completion of their wells will be carved out and certified to ensure that the well designs are <br />properly implemented to avoid aquifer communication especially during the development of <br />baseline data. <br />4. [Anomalous Water Quality Data] <br />Water data quality and aquifer characterization provided by the Applicant to date has been <br />completely anomalous to data which pre-existed for the Piceance region. While the Applicant <br />has developed this elaborate plan which proposes to conduct future studies in coordination <br />with the USGS, there remains a concern that a conflict of interests exists. Given the <br />Applicant's disregard to existing data, the fact that the Applicant did not do their homework <br />upfront on water quality data as legally obliged, the fact that the AAI plan shows total <br />disregard for aquifer communication and contamination, and the fact that accurate baseline <br />water quality data is critical to understanding the hydrogeological impact of this solution <br />mining process, the permit must not be approved. The only efficient way to resolve this issue <br />is mandate that a qualified, independent third party be responsible for developing the baseline <br />data, ensuring proper well completion techniques and overseeing all other water related <br />issues. Given the derelict nature in which the Applicant has handled this important and <br />critical issue, the DMG must intervene because otherwise, the precedence being set would be <br />environmentally harmful. <br />OTHER MONTfORING DEFICIENCIES <br />The Applicant states that after establishment of the baseline data they are going to reduce <br />their monitoring when in fact, they should increase their monitoring. The purpose of the <br />monitoring is to establish if the operations is having any effect on the ground water quality. It is <br />important to establish this fact as early as possible before the Applicant's operations irreversibility <br />damages the aquifer. Furthermore, increased monitoring is critical during the commercial phase <br />because so little is yet known about the potential effects of this process. To state the obvious, the <br />Applicant has made a clew distinction between development stage operations and commercial <br />stage operations and recommends cutting back monitoring when they transition to full commercial <br />scale production. This is absolutely ludicrous. Heavy monitoring should occur at least through <br />the completion of the fast panel (5 years). By then, enough data will be available to determine <br />the level of monitoring going forwazd. The amount of monitoring should also be a function of <br />