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2016-10-27_REVISION - C1981041
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2016-10-27_REVISION - C1981041
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Entry Properties
Last modified
5/3/2017 12:00:39 PM
Creation date
10/27/2016 12:27:21 PM
Metadata
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Template:
DRMS Permit Index
Permit No
C1981041
IBM Index Class Name
Revision
Doc Date
10/27/2016
From
James A. Beckwith Attorney & Councelor at Law
To
DRMS
Type & Sequence
TR69
Email Name
BFB
DIH
Media Type
D
Archive
No
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JAMES A. BECKWITH <br />LETTER TO BROCK BOWLES, CO DRMS / SNOWCAP COAL COMPANY RECLAMATION / PG. 13 <br />intelligently adapted to the issue. Finally, rather than keeping Snowcap in charge of repairs, <br />require Snowcap to deposit into trust, or deposit a bond, covering the present costs to repair the <br />Martin Crawford Ditch; to level the surface depressions; to install surface crops and irrigation <br />systems; and, to cover the future costs of repairing the subsurface fissures and cracks. Then, let <br />the landowners be free of Snowcap Coal Company. <br />A. Reservation of Rights to Submit Late -Filed Reports <br />Given the time constraints imposed upon it, Fontanari is submitting as much technical <br />data as it can assemble within the ten (10) days after publication of Snowcap's Plan. Other data <br />will be received after the filing of this letter. Fontanari reserves the right to supplement this <br />Response with the data as it is received. Copies of all data received and submitted will be given <br />to Snowcap Coal Company. <br />B. Repairs and Upgrades to the Irrigation System <br />Fontanari has valuable water rights in Rapid Creek which will be lost if Fontanari cannot <br />apply irrigation water to surface crops in Tracts 70 and 71. Specifically, Fontanari has an <br />adjudicated right to 5.3 cfs, transmitted through the Martin Crawford Ditch as one element of his <br />irrigation system. The irrigation system, however, has sustained damages from other <br />subsidences (not addressed by Snowcap in its Plan) and needs improvement to be efficient in the <br />delivery of water to the point of irrigation. Mr. David A. Fox, of Fox Engineering Solutions, has <br />inspected the Fontanari lands and the Martin Crawford Ditch. Mr. Fox's recommendations, and <br />costs estimates are contained in Appendix Q, attached. Mr. Fox's estimate of repairs is <br />$409,000.00. <br />Drip irrigation requires a water pond in order to provide sufficient pressure and volume. <br />Thus, Carey Pond is now and will forever be a vital element of the irrigation system. Snowcap's <br />proposal is simplistic: put a group cap on a hole. The proper upgrade (or "repair", as it were) is <br />to line the Carey Pond with 60 mil. High Density Polyethylene (HDPE) material used in ponds in <br />the oilfields. This requires: removal of overburden surrounding the pond; grading of proper bank <br />angles; installation of a cushioning layer of silica sand or other material to avoid the HDPE liner <br />from puncture by sharp rocks or soils; laying of the HDPE liner over the cushioning material; <br />heat welding the joints of the HDPE material; and, overlapping the banks with the HDPE <br />material. A specific estimate of costs to line the Carey Pond will be a late -filed support. <br />Nonetheless, the experience of Mr. Beckwith (through oilfield clients) with such projects <br />suggests a cost of $200,000 to line the Carey Pond to prevent — as requested by Snowcap — <br />surface waters from entering the mine caverns. <br />
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