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holes, any obstruction can often prevent the advancement of casings or pumps. Cotter Rebuttal, <br />Exh. 1, at 12. Pumps have been known to hang up on something as small as a welded bead, and <br />casing will not advance. Id. The Division also failed to explain how the casing string can be <br />centralized and anchored across the void spaces. Id. Further, the Division's position does not <br />address the ability to seal the open voids around the annular space and around the casing string <br />(where it passes through large mine voids) to meet state requirements for well sealing. Id. <br />While the Order states that the Division also proposed exploring the possibility of placing <br />the pump in Shaft no. 2, which bottoms at 800 feet below the Steve Level, Order 13 1, Cotter's <br />testimony and evidence in its Rationale regarding feasibility challenges assumed placement of a <br />pump in Shaft no. 2. Therefore, the Division's testimony about Shaft no. 2 being an alternative <br />possibility does not make sense. See Rationale at 7 (the second means of installing the pump and <br />piping, aside from the Sunshine adit, is "to excavate a drill pad on the surface above the mine <br />and use a drilling rig to drill a vertical hole to intercept the #2 Shaft which is 74 square feet in <br />area"). <br />Moreover, the Order relies on the Division's examples of successful drilling to intercept <br />small targets, Order 13 1, but the Rebuttal points out that, unless these examples utilized stoping <br />practices and timbering employed at the Schwartzwalder Mine, they could not be used as <br />examples for conditions similar to what would be encountered when drilling at the <br />Schwartzwalder Mine. Cotter Rebuttal, Exh. 1, at 12. The Rebuttal further states that it does not <br />appear. that any of the drilling targets in the Division's examples contained significant open voids <br />above the target, or piping, wires, shoots, rails, and other problems in drilling into the target. Id. <br />The Rebuttal provides three photographs (figures 6, 7, and 8) of the Schwartzwalder Mine <br />showing timbers and other potential obstructions to setting casing or a pump in the mine shaft, <br />13