Pelle Karlsson and EvelynT. Karlsson - Page 20

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            property, not a tar sands property; (2) the Carmel VaporTherm                             
            technology was unique, and water for its use would be available                           
            at low cost; (3) testing is not critical to a determination of                            
            the usefulness of a particular technology; (4) it was not                                 
            unreasonable to project that world oil prices would continue to                           
            rise; (5) the Monroe field was not 90 percent depleted; (6)                               
            Elektra had available the expertise of Todd Doscher, whose                                
            expertise alone made the EOR technology licensed by Cromwell                              
            valuable; (7) during the 1980's, there existed no industry norm                           
            for the license of EOR technology; (8) there existed proven ways                          
            to recover oil from tar sands properties, and the tar sands                               
            properties licensed by Cromwell had reserves of oil; and                                  
            (9) Cromwell's estimates for recovery of oil from tar sands                               
            properties using the licensed EOR technology were reasonable.                             
                  We address each of petitioners' allegations in order.                               
                  (1) Bursell's and Ham's bald opinions that Burnt Hollow does                        
            not constitute a tar sands property are unsubstantiated and                               
            conflict with industry definitions.  The Burnt Hollow property                            
            has an API gravity of 2 degrees and a viscosity of 1,000,000 cp                           
            at reservoir conditions, making this property a tar sands                                 
            property under any recognized definition.  Further, whether Burnt                         
            Hollow constitutes a heavy oil property or a tar sands property                           
            does not change the fact that Cromwell's acreage had no reserves.                         







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