Laserfiche WebLink
minutes of relevant meeting have already been disclosed to the State. The design <br />capacity for the course was the choice of the course designer, Gary Lacy. Mr. Lacy's <br />reasons and methods for choosing the design capacity and flow needs for the Course have <br />been presented in his expert disclosures and his deposition testimony and were generally <br />based on his knowledge of Clear Creek flow rates, and his understanding of what Golden <br />wanted. If the question asks what studies of recreation have been done since the Course <br />was constructed; Golden states it has already disclosed that information in the various <br />Rule 26 disclosures filed in this case, including the expert witness reports prepared by Dr. <br />Raucher, Mr. Lacy, Mr. Thompson and Dr. Danielson. <br />Interrogatory No. 3 : Provide a list of all professionals involved in the recreation flow <br />assessments and their qualifications for conducting such assessments. <br />Response: Golden objects to this interrogatory on the ground that it is confusing. <br />Golden does not know what the State means by "recreation flow assessments." Without <br />waiving that objection, Golden states again that the design capacity for the Course was <br />the choice of the Course designer, Gary Lacy. Mr. Lacy's credentials have already been <br />provided in expert witness disclosures and at his deposition. Other professionals who <br />have studied the Course have already been identified in Golden's various Rule 26 <br />disclosures in this matter. <br />Interrogatory No. 4 : If data collection involved surveys /interviews of recreation users, please <br />provide a description of each survey /interview effort. The description should include the survey <br />instrument; information about the population of interest, the aaxtplin' frame sample size, <br />- ` response rate; information about analysis strategies used; and any results, findings, or <br />conclusions deriving from the effort. <br />Response: As explained above, the idea for the Course was brought to Golden by boaters <br />in the area who suggested that Clear Creek in Golden presented a unique opportunity to <br />create an excellent boating course. The boaters in and around Golden made their case in <br />a variety of public meetings and through many letters to Golden. The letters and minutes <br />of relevant meeting have already been disclosed to the State. If the question asks what <br />studies of recreation have been done since the Course was constructed, Golden states it <br />has already disclosed that information in the various Rule 26 disclosures filed in this case, <br />including the expert witness reports prepared by Dr. Raucher, Mr. Lacy, Mr. Thompson <br />and Dr. Danielson. <br />Interrogatory No. 5 : If data collection involved any prediction -based modeling methods (e.g., <br />IFIM for recreation, single methods), please provide a description ofthe and _ <br />how it was applied. The description should include any transect information used (including <br />specific sites), specify method assumptions, and specify the flow evaluation criteria used. <br />Response: Golden object to this interrogatory on the grounds that it is unclear and <br />confusing. Golden is not sure what "prediction -based modeling methods" are or how <br />they would be used. Golden is also not sure what "data collection" effort the State would <br />like to know about. For these reasons, Golden cannot answer this interrogatory. Without <br />Lab0591 2 <br />