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JAMES A. BECKWITH <br />LETTER TO BROCK BOWLES, CO DRMS / SNOWCAP COAL COMPANY RECLAMATION / PG. 6 <br />Conclusion and Recommendation <br />There are several types of non-invasive, subsurface testing of land: gravimetric; seismic; <br />electromagnetic and electrical; and magnetic or ground penetrating radar. Snowcap Coal chose <br />one: electrical resistivity testing (ERT). The reliability of the ERT results depends upon whether <br />it confirms known surface and subsurface activities of the underground mine. [Johnson and <br />Snow; 2002] [Appendix H] <br />Here, the known surface and subsurface conditions were three -fold. First, at some period <br />of time before 1978, an air ventilation shaft had been drilled between the mine cavern and the <br />surface of Fontanari Tract 71. This hole remained open at the surface and, presumably, remained <br />relatively open throughout its subsurface length. Since the air shaft was man -drilled and not <br />natural, then it is assumed the shaft is vertical or near -vertical, but not horizontal as in directional <br />drilling for oil and gas. A reasonable person would assume that any water inserted into the air <br />shaft would flow directly into the collapsed mine cavern. <br />Second, in June, 2014 thousands of gallons of water disappeared down a sinkhole located <br />in an irrigation ditch situated many feet west of the air ventilation shaft. The surface water was <br />confirmed as mine inflow by examining the outflow in the South Portal french drain. On April <br />4, 2016, this water disappearance was replicated with identical results. The 10,000 gallons <br />inserted on April 4, 2016, disappeared so quickly that it did not overflow the irrigation ditch. <br />Here, as well, a reasonable person would conclude that there was a subsurface void of a <br />dimension suitable to accommodate high volumes of water so quickly. <br />Third, the positions of the sinkhole and air ventilation shaft are not separated by great <br />distances. A reasonable person might assume, if not conclude, that the sinkhole somehow <br />connected to the air ventilation shaft: thus accounting for the rapidity of "disappearance". <br />The ERT results from Fugro do not comport with any of these three undisputed surface <br />conditions. Fugro does not report any anomalies under the sinkhole(s) [Fig. 5] nor does it report <br />any anomalies extending between the sinkholes and the air ventilation shaft [Fig. 5] The Fugro <br />Report only reports anomalies below the air ventilation shaft: a result one would expect if an air <br />shaft had been drilled. However, neither Fugro nor SCC ever dumped water down the air <br />ventilation shaft. Any opinions regarding water conductivity in the air ventilation shaft are thus <br />conjectural, at best. <br />In sum, the SCC Report, and its incorporated Fugro Report, is inconclusive, unreliable <br />and must be rejected in its present condition. Snowcap Coal did not investigate all Fontanari <br />Lands and thus did not fulfill its commitment to DRMS and Fontanari. The Fugro Report does <br />not explain the incidents of June, 2014 and April 4, 2016. It does not explain any relation <br />between the air shaft and the sinkholes. To determine the full extent of damage to Fontanari <br />land, DRMS must order SCC to "test again". <br />