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<br />1 <br /> <br />o <br /> <br />(1) uefendant-Intervenor claims that <br />Plaintiffs are not entitled to any relief under the claims <br />or causes of action pleaded by Plaintiffs. <br />(2) Defendant-Intervenor claims that <br />Plaintiffs had failed to state a claim upon which relief can <br />be granted. <br /> <br />f.) Defendant-Intervenor {State of Colorado} <br /> <br />claims: <br /> <br />(1) Defendant-Intervenor claims that <br />Plaintiffs are not entitled to any relief under the claims <br />or causes of action pleaded by Plaintiffs. <br />(2) Defendant-Intervenor claims that <br />Plaintiffs had failed to state a claim upon which relief can <br />be granted. <br />(B) UNCONTROVERTED FACTS <br />(1) That the document entitled Simulated <br />Effects of the Proposed Narrows Reservoir on the Water Table <br />Aquifer along the South Platte River, Morgan County, Colorado, <br />is the only seepage study done for, or by the Bureau of <br />Reclamation [Bureau} since January 1, 1976. <br />(2) That there are presently in existence no <br />stability studies specifically for the Narrows Dam site. <br />(3) There is no final structural design for <br />the Narrows Site. <br />(4) No transient analysis of seepage losses <br />has been conducted on the Narrows Site. <br />(5) That no studies have been completed in <br />~he past 25 years which deal with the increased velocity of <br />groundwater beneath the dam due to the hydraulic head caused <br />by stored water in Narrows Dam. <br />(6) That no studies have been completed that <br />attempt to deal with the effect that divergences from steady- <br />sta~e conditions could have On groundwater aquifers and <br /> <br />seepage. That such a study is essential to performing a <br /> <br />-d- <br />