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INTRODUCTION <br />0 Pursuant to the Energy Act of 2005 and Section 21 of the Minerals Leasing Act (1920, as <br />amended, 30 USC 241), the Bureau of Land Management (BLM) solicited research, <br />development, and demonstration (RD&D) proposals to demonstrate technologies for unlocking <br />the energy now trapped in oil shale deposits and to nominate lands to be leased for a potential <br />subsequent commercial project. Each 160-acre RD&D lease application was to include a request <br />for 4960 acres to be reserved for a preference-right commercial lease area. As established under <br />the Act, BLM would non-competitively convert the preference-right acreage into a commercial <br />oil shale lease for fair market value upon successful demonstration of an environmentally sound <br />and economically viable shale oil recovery technology. <br />Ultimately, of the 20 nominations received, six were accepted, including the one proposed by <br />E.G.L. Resources, Inc. The BLM issued the Oil Shale RD&D Lease COC 69169 effective on <br />January 1, 2007. E.G.L. Resources, Inc. assigned the lease to E.G.L. Oil Shale, LLC (EGL). <br />E.G.L. Oil Shale, LLC, formally changed its name to American Shale Oil, L.L.C. (AMSO) on <br />May 12, 2009, and AMSO is the current lease holder and lease operator. We retain the use of the <br />EGL name in this document when referring to EGL documents. Pursuant to that lease, AMSO <br />will work closely with the BLM throughout the RD&D program to establish the foundation of a <br />commercial shale oil project. <br />This Plan of Development (POD) is based on site specific exploration, evaluation, and extensive <br />• collaboration among AMSO and other oil shale researchers from 2007 through early 2009. This <br />POD is consistent with the principles laid out in EGL's Application for Oil Shale Research, <br />Development and Demonstration Lease and Request for Lands to Be Reserved for Preference <br />Right Lease submitted to the BLM September 2, 2005; in the proposed Plan of Operations <br />submitted to the BLM February 10, 2006; and in the Addendum to the Plan of Operations <br />submitted to the BLM on July 30, 2008. <br />EGL's proposed Plan of Operations was submitted without opportunity for site specific <br />exploration. The plan was to recover shale oil from the regionally rich Mahogany (R-7) and R-6 <br />oil shale interval. This interval contains aquifers that are of potential future use. The plan <br />envisioned aquifer dewatering, retorting, and post-retort aquifer remediation. <br />AMSO's site-specific research and development work to date, and its desire to avoid aquifer <br />impacts rather than to remediate the aquifers, identified a better approach. The herein defined <br />Illite Mining Interval, shown in Figure I-1, lies below the aquifers and is isolated from the <br />aquifers by a protective cap of nahcolitic oil shale. AMSO believes it can develop and <br />commercialize shale-oil recovery from the Illite Mining Interval in a manner that avoids <br />significant impact to the overhead nahcolitic oil shale and to the aquifer resources. Initial <br />commercialization of the Illite Mining Interval is wise resource management, as it allows the <br />accumulation of knowledge and experience prior to developing the more challenging nahcolitic <br />and leached zone oil shale resource. <br />• <br />6