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JAMES A. BECKWITH <br />LETTER TO BROCK BOWLES, CO DRMS / SNOWCAP COAL COMPANY RECLAMATION / PG. 12 <br />losses are sufficient grounds, per se, to reject Snowcap's proposed Repair Plan and Cost <br />Estimate. <br />Summary <br />Snowcap's Plan is an interesting series of conflicts and contradictions. Mr. Stover claims <br />all subsidence will result within three years of mining cessation. DRMS, the U.S. Bureau of <br />Mines, Colorado statutes and judicial decisions say otherwise. Snowcap, Fugro, the U.S. Bureau <br />of Mines and the Illinois Geological Survey conclude that room and pillar collapse will result in <br />surface subsidence and subsurface fissures and cracks. Huddleston Berry deny such a <br />connection. Fugro and photographic evidence prove that 2,500 gallons of water was dumped <br />down the air shaft which rejected the water causing surrounding flooding. Snowcap claims it <br />was the rock pile, not the air shaft. Curiously, HBET nowhere acknowledges this experiment or <br />its results. From the experiment, Snowcap claims there is no hydrologic connectivity between <br />the air shaft and the mine. HBET claims the air shaft is free, open, and the only possible <br />connectivity. Fugro and Snowcap agree that the air ventilation shaft is backfilled and will not <br />accept water, while HBET and Mr. Berry do not comment on the air shaft being backfilled. <br />HBET and Mr. Berry propose a series of nearly 50 grout holes, each being 25 ft. deep. The holes <br />will surround, but not be on top of the air shaft. Snowcap says only two holes, each only 16 ft. <br />deep with one being directly on the air shaft. HBET makes no recommendation regarding a <br />backfill test pit in the Carey Pond. Snowcap claims the test pit is a conduit to the mine, and must <br />be covered in grout and concrete. HBET says its method is most expensive but will be <br />successful. Snowcap rejects the method; chooses the least expensive "one-time fix" but does not <br />say why or whether their method will be successful. In the end, Snowcap proposes to install a <br />grout cap to prevent water going down an air ventilation shaft when, by Snowcap's own <br />experiment, water will not go down that air ventilation shaft. <br />About the only conclusion a reasonable person would make is that Snowcap, Fugro, <br />HBET and Mr. Berry simply do not know the problem, and, thus, do not know the answer. This <br />is no way to cure a problem. The Snowcap Plan, therefore, must be rejected. <br />THE FONTANARI REPAIR PLAN <br />The Fontanari Plan is based on the concept of natural accommodation. Rather than <br />radical excavation, simply adopt surface irrigation methods that avoid large poolings of water <br />which would be lost down sinkholes. Choose crops which are best watered by the type of <br />irrigation allowable: given Snowcap's damages to the land. Level surface subsidence <br />depressions by importing topsoil: thereby leveling the growing field. Make significant repairs <br />and upgrades to the irrigation system to minimize water losses between the Rapid Creek <br />headgate and the point of irrigation. Rather than inconclusive tests that may, or may not <br />accurately describe sub -surface conditions, await Fontanari's extraction of basaltic materials <br />over a 15-20 year period. After all, Fontanari's mining plan covers more land and to a greater <br />depth than anything proposed by HBET or Snowcap. As sub -surface fissures and cracks are <br />uncovered, DRMS, Fontanari and Carey can cooperatively determine a repair uniquely and <br />