Rule 26‎(A)‎‎(2)‎ Disclosure of the CWCB and the State and Division Engineers

• Description: Golden RICD
• State: CO
• Basin: South Platte
• Water Division: 1
• Date: 1/26/2001
• Author: Ken Salazar, Bo Shelby, Doug Whittaker
• Title: Rule 26‎(A)‎‎(2)‎ Disclosure of the CWCB and the State and Division Engineers
• Water Supply Pro - Doc Type: Court Documents

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Summary of Opinions
The following document contains a statement of all opinions to be expressed at trial, by
expert witnesses for the State of Colorado.
Dr. Bo Shelby.
Bo Shelby, Ph.D., Confluence Research and Consulting, 3 600 Northwest Thrush,
Corvallis OR, 97330 [phone]. Dr. Shelby will be offered as an expert witness to
express opinions about quantifying recreational instream flows, evaluating the
effectiveness of flows on whitewater courses (both natural and manmade) in achieving
desired recreational opportunities, and subjects concerning kayaking. Bo Shelby's
qualifications are set forth in the attached resume. He will be compensated at the rate of
$325 per hour for testimony at deposition or trial, and $165 per hour for other work. He
has been deposed and testified at trial once in the past four years, in the case of Ci of
Waterbury v. Town of Washington et al Superior Court, Waterbury, CT.
1 • Will opine that the Golden methodological process for conducting recreation flow
needs assessments was inadequate and did not meet the industry standard.
2. Will opine that Golden has failed to define the term "world class whitewater
course" with specificity about the desired conditions it seeks to produce at each alleged
structure.
3. Will opine that Golden has failed to define the whitewater features sought to be
produced by each alleged structures at its whitewater course with specificity and how
flow levels effect desired conditions at each alleged structure.
4. Will opine that the term "world class" whitewater can be defined as. synonymous
to high quality recreation or can be defined by the flows at which world class events can
be conducted on the course.
5. Will opine as to the types of whitewater features typically desired on "world
class" whitewater courses.
6. Will opine as to the flow range on the Clear Creek Whitewater course, as
designed, that the types of whitewater features typically desired on "world class"
whitewater courses are achieved.
7. Will opine as to the diminishing utility of increased enjoyment that occurs as flow
amounts exceed the low end of the range when whitewater features typically desired on
"world class" whitewater courses are achieved.