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161 1 A. -- made a decision on -- on their 1 being what it is, to make sure that our repair 2 actual repair plan. 2 extends far beyond where we expect it to be just to 3 Q. You're a consultant just like 3 make sure. And so those were the two options. 4 Mr. Justus and I are, and we give various options, 4 Q. And so in other words, the ERT is 5 and the client makes his own choice of what is done? 5 scmething of a highly skilled, educated estimate? 6 A. That's right. 6 A. I wouldn't say that. I'd say it's a 7 Q. Did you recommend then that it be -- 7 very accurate -- 8 that an excavation be made 12 to 16 feet dawn the 8 Q. But it's not the same as digging 9 air ventilation shaft because there was a connection 9 down? 10 between a hole in that shaft and sane type of 10 A. No. 11 subsurface pathway to the sinkhole in the Fontanari 11 Q. And when you dig down, is there 12 trench? 12 potential, in your experience, that you will find 13 A. Just so we're clear. Yes, I 13 more anomalies? 14 recamended that based on the Fugro study, the 14 A. I would find it unlikely. It's 15 horizontal throat, connection, pipe, whatever you 15 possible, but I would find it unlikely based on the 16 want to call it fran the surface hole at the north 16 geology in this area. 17 end -- north end of the Fontanari Ditch connected to 17 Q. Based on the geology or the ERT? 18 the air shaft at a depth of, I think, 9 to -- 9 or 18 A. Both. 19 10 feet is what the data suggested. 19 Q. Okay. And what is the geology upon 20 Q. Do you -- 20 which you rely relative to this particular site? 21 A. And so I recammended that they 21 A. As I indicated previously, we've got 22 excavate down, expose the air shaft, as I indicated 22 very thick colluvial materials consisting of boulder 23 previously. The geophysical survey doesn't 23 and cobble in a sand/clay matrix overlying the 24 give a -- doesn't give me defined lines of the 24 sandstone bedrock and where the coal seams and such 25 exact -- you know, it gives me a range, the air 25 are present. 161 163 1 shaft's in here, but we want to expose it so we know 1 Q. Which sandstone formation is it? 2 exactly where it is. My recamnendation was to do 2 A. I believe it is the -- I 3 that and then cap it and seal it and backfill. 3 shouldn't of -- I don't know off the top of my head. 4 Correct. 4 Q. Is it Rawlings? 5 Q. And did you recxmiend going down 25 5 A. I do not know off the top of my head. 6 feet as opposed to 16? 6 Q. Could you find out and advise 7 A. With -- with grout holes, yes. If we 7 Mr. Justus? 8 did cmpassion grouting, yes. 8 A. I could. 9 Q. And the recommendation that you were 9 Q. I would appreciate it very much. 10 making, that was based upon an ERT -- two ERT 10 A. Sure. Absolutely. 11 studies; am I correct? it Q. Now, do I understand-- or are you 12 A. That's correct. 12 asserting, as the consultant to Snowcap, along with 13 Q. And you do not actually know what 13 Mr. Stover, that the coal caverns beneath Tract 71 14 that anomaly looks like? 14 have not collapsed? 15 A. That's correct, and that is the 15 A. That's not the scope of my purview at 16 discrepancy between the -- if using an excavator, we 116 all. 17 can see it. We can see exactly, you know, what it 17 Q. So you don't know? 18 looks like. We can chase the hole fran the end of 18 A. I have -- I do not know. 19 the Fontanari Ditch and chase it dawn to the point 19 Q. And it's not — I'm not calling you 20 of intersection with the air shaft and clearly 20 an ignorant man. You just didn't test it? 21 identify the air shaft. 21 A. Yeah. I just -- 22 Q. And-- 22 MR. JUSTUS: Beyond the scope. 23 A. Whereas the grout — the grout -- and 23 A. That's not part of my scope. 24 that's why we went to 25 feet with the grout -- is 24 MR. JUSTUS: He hasn't testified to 25 not knowing exactly -- the resolution of the data 25 that. That's beyond the scope. 162 164