Pelle Karlsson and EvelynT. Karlsson - Page 25

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                  Ham suggests that there were probable reserves on the Utah                          
            tar sands properties, but Ham provides no reliable data or                                
            support for this assertion.  At trial, Ham testified that the                             
            Utah tar sands properties had possible reserves.  Regarding Burnt                         
            Hollow, he speaks vaguely in terms of “secondary reserves” and “a                         
            lot of reserves” without any greater precision.  Even                                     
            petitioners' other experts would not agree with Ham on this                               
            matter.  Neither Austin, Bursell, nor Cayias makes similar                                
            assertions or speaks in terms of reserves.  In fact, Cayias                               
            characterizes Burnt Hollow as “an exploration type risk”.                                 
                  (9)  Relying primarily on Bursell's estimates of a 50-                              
            percent recovery rate, petitioners dispute our finding that                               
            Cromwell's 20- to 70-percent oil recovery estimates were                                  
            unreasonable.  Bursell's 50-percent recovery estimate, however,                           
            itself is flawed.  Bursell uses a hypothetical viscosity for                              
            Burnt Hollow oil of 10,000 cp at 90 degrees Fahrenheit.  He then                          
            plots this hypothetical viscosity on a laboratory-derived curve                           
            correlating viscosity and recovery.  Bursell's theoretical                                
            viscosity, however, for Burnt Hollow is incorrect.  Even at 102                           
            degrees Fahrenheit, the viscosity of the tar at Burnt Hollow was                          
            indicated at over 1,000,000 cp.  At 90 degrees Fahrenheit, the                            
            tar would be even thicker, and the viscosity higher, nowhere near                         
            the 10,000 cp that Bursell uses.  In making his calculations,                             
            Bursell evidently did not have and did not consider the actual                            
            data from Burnt Hollow.  Factoring in this data on Bursell's                              



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