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JAMES A. BECKWITH <br />FONTANARI OBJECTIONS AND COMMENTS / SNOWCAP BOND APPLICATION SL -I I / PG. 2 <br />The Study Area contains valuable basaltic material located to a depth of 50-60 ft. <br />below the surface. The amount of rock (including large boulders) limits the surface use to <br />seasonal livestock grazing and wildlife habitat. Snowcap's Permit and Reclamation Plan <br />acknowledges these established uses of the Study Area. <br />B. SL -11 concerns lands with a history and continuing presence of subsidence. <br />It is well known that, in room -and -pillar mining, the collapse of tunnel roofs due to the <br />removal of pillar support during retreat mining causes surface subsidence. Room -and -pillar <br />mining—including retreat mining—was performed in the Study Area for well over one <br />hundred years.' This occurred in the Old Mine Workings (pre -1980) and New Workings <br />(1980-2000). Collapsed tunnels from both mining eras exist beneath the Study Area. <br />Surface subsidence (tension cracks; voids and depressions) have been present in the <br />Study Area for nearly as long. Mr. Jeff E. Magers of the United States Bureau of Mines first <br />noted tension cracks on Tract No. 70 in 1981-85.2 (Magers Report; Pg. 12; Figs. 10-11) <br />Those cracks merged or evolved into one tension crack 200 feet long and up to 9 feet deep in <br />1991. (Id.) By 2016, this massive tension crack again evolved into a continuous line of deep, <br />major sinkholes. DRMS' recent August 2018 inspection revealed the continued existence of <br />these sinkholes on Tract No. 70 as well as the presence of new and additional sinkholes in <br />both the northeast corner of Tract No. 70 as well as areas south of the 2016 sinkhole line. It <br />further revealed sinkhole lines along the western wall of the canyon on the tract's eastern <br />border. This latter area has suffered significant slumping in years past, with more current <br />slumping creating a bench 75 feet below the canyon's rim. This slumping is above an area in <br />which, in 1992 Powderhorn Coal Company recorded a lengthy north -south line of collapsed <br />tunnels. (Fontanari Exhibit 2) <br />As another example of the presence of subsidence, on Tract No. 71 surface water <br />migrated through the Old Mine Workings and into the South Portal via surface sinkholes <br />bordering two subsidence depressions in 2014. Inspection of Tract No. 71 in 2016 revealed <br />the continuous existence of these two large depressions, as well as numerous sinkholes <br />bordering the edge of each depression. Those findings were reported to DRMS in October <br />2016. DRMS' recent August 2018 confirmed the continued presence of both the depressions <br />' Coal mining beneath Tracts Nos. 70 and 71 began as early as 1888: when J.P. Harlow and <br />George Crawford first obtained a Coal Certificate and U.S. Patent for the southwest corner of <br />Sec. 34, TIOS, R98W. (Fontanari Exhibit 3) Local historians refer to the "Harlow Mine" as <br />the pre -cursor of the "Roadside Mine". The 1980 GEX Mine Map locates the original Harlow <br />Mine adit, or portal, at the north end of this plateau. <br />2 Surface Subsidence Over A Room -and -Pillar Mine in the Western United States; Jeff A. <br />Magers; United States Department of Interior; 1993 Hereafter, referred to as "Magers Report". <br />A copy of this Report is contained in Tab 10, Snowcap Application. <br />