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JAMES A. BECKWITH <br />SNOWCAP COAL / TR -69 / SUMMARY OF FONTANARI OBJECTIONS / PG. 5 <br />A walk through that portion of the Carey Tract west of the Carey Subsidence Trough <br />reveals a complete absence of sinkholes, troughs or other surficial indications of the removal of <br />subjacent support. A similar walk through #71 Tract reveals just the opposite: numerous <br />sinkholes; and, two well-defined subsidence troughs. <br />7. Seepage Via Basaltic Aggregate: Snowcap's counsel has suggested that the <br />surface subsidence is due to geologic factors other than collapse of the coal caverns. (Response <br />to Request for Clarification; Fn. 1, Pg. 1) It seems to be Snowcap's argument that surface waters <br />enter the basaltic aggregate; soften the ground; and, because the aggregate is permeable, this soft <br />ground leads to surface subsidence troughs. Pardon the pun, but such a theory does not hold <br />water. <br />That portion of the Carey Tract west of the Carey Subsidence Trough has the same <br />basaltic aggregate to a depth similar to that of #71 Tract. This portion of the Carey Tract was <br />regularly irrigated by flood waters. Yet, this same portion is devoid of any sinkholes, surface <br />troughs or other "subsidence" features. Clearly, it is the collapsed coal caverns, and not the <br />permeability of the basaltic aggregate, which had led to sinkholes, surface troughs, and <br />unquestioned water entering the mine caverns (whether in active mining or after later withdrawal <br />and collapse!). <br />8 Alternative Surface Crop Irrigation Methods Not Considered By Snowcap: It is <br />undisputed that flood irrigation can no longer be conducted on #71 Tract and the eastern portion <br />of the Carey Tract around the Carey Trough. The surface and sub -surface conditions will simply <br />not allow such irrigation without water flowing into the collapsed mine caverns. There are, of <br />course, well-known alternatives: e.g. drip irrigation for trees and bushes, and sprinkler irrigation <br />for grasses and grazing areas. The most obvious "repair" would be to adopt these irrigation <br />alternatives and thereby allow surface irrigation while also preventing cavern flooding. <br />Yet, Snowcap does not discuss these alternatives in either its Report of Investigation or <br />its Repair Plan. Instead, Snowcap insists that plugging two "anomalies" below the surface (even <br />though not in either of the observed subsidence troughs) will prevent all future hydrologic <br />communication between surface and coal cavern. Stated differently, Snowcap insists that putting <br />its thumb in one hole in the dike will plug all the other holes in the dike. Not so. <br />9 Alternative Irrigation Methods Require Piping of the Martin Crawford Ditch: <br />Flood irrigation relies upon gravity and can be accomplished via open ditches. Sprinkler and <br />drip irrigation, however, rely upon pressure to push water through the drip or sprinkler system. <br />In turn, this requires piping the supply ditch to avoid loss of water through natural seepage (as in <br />an open ditch), and to preserve and promote the "head" or force of the water. <br />Stated differently, piping the Martin Crawford is not required because there has been <br />subsidence (arising from collapsed mine caverns) below the open ditch. Instead, piping is <br />required because the existing conditions on Carey and #71 Tract (which prohibit flood <br />irrigation) require drip or sprinkler irrigation which can be achieved only from the head and <br />quantity that comes from piping. <br />