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deviation to hit a 74-square foot target of the No. 2 Shaft. Id. Drilling through open cavities is <br />often more difficult than drilling through competent rock, because there is no hole to stabilize the <br />bit and avoid deviation and no means of flushing the hole to bring up cuttings from around the <br />bit. Id. Without "return" of drill cuttings, a driller would be drilling blind into the rock below <br />the existing voids, with a high potential for getting the bit stuck in the hole. Id. The drilling <br />through open voids could encounter steel, machinery, or ventilation piping. AR00962:1-21. <br />Few drillers would be willing to take this challenge, due to the higher probability of damaging <br />their equipment. AR:00268; 00961:25-00962:6. <br />The record contains no substantial evidence showing that the casing string at issue here is <br />capable of or could actually be centralized and anchored across void spaces in the Mine. <br />Similarly, the record contains no substantial evidence showing that in this situation anyone could <br />seal the open voids around the annular space and around the casing string (where it passes <br />through large mine voids) in the Mine sufficiently (or at all) to meet state requirements for well <br />sealing. The record contains substantial evidence that these problems exist. AR: 00268; <br />00962:22-00963:3. However, the Division did not seriously address them and the record <br />accordingly contains no substantial support showing that surmounting them can be done. <br />The Division acknowledged the feasibility challenges of Corrective Action No. 2. <br />AR:01005:19-01008:4. However, instead of providing cost information about the expenses of <br />efforts to overcome those challenges, the Division simply gave examples of other projects on <br />which such feats had been accomplished, without any consideration of whether those other <br />drilling projects were actually similar to the mine dewatering project at issue here. Most telling, <br />on the drilling issues, the Division discussed the incredible directional drilling done in response <br />18