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property during the period of time that widespread subsidence has taken place on the Carey and <br />Fontanari Parcels. His testimony will include rebuttal and impeachment of other lay witness and <br />expert witnesses. Carey has more than eighteen years of experience in river planning and design. <br />He has managed over 90 major river engineering projects, with experience in analytical river <br />restoration design, river recreation enhancement, and non -point source pollution prevention <br />control. His skills include geomorphic assessments, wetlands restoration, river stability analysis, <br />bio -stabilization, sediment transport analysis, floodplain determination, flood damage <br />assessment, reservoir capacity analysis, dam break analysis, hydraulic design of structures in the <br />river environment, design of irrigation canals, hydraulic bridge design, diversion structure <br />design, and whitewater park design. Carey has also provided expert witness testimony for <br />recreational water rights in Colorado. He is currently registered as a Professional Engineer in <br />Colorado and eight other states, including Utah, Michigan and California. He holds a Master of <br />Science in Civil Engineering from the University of Utah and a Bachelor of Science in Physics <br />from Fort Lewis College. <br />VI. DISCOVERY/ SUBPOENAS <br />1. Discovery: The parties are generally not allowed discovery in a hearing <br />involving a Technical Revision. However, Snowcap's counsel has asserted' that the surface <br />subsidences on Tract 71 and Carey Tract derive from some cause other than collapse of <br />underground coal caverns in the Powderhorn Mine. To avoid surprise and prejudice at hearing, <br />Objector requests an Order of the PCHO directing Snowcap Coal to produce, not later than May <br />1, 2017, all evidence, both testimonial and documentary, it intends to present at hearing <br />supporting the above declaration. If such evidence includes any or all portions of Exhibits 1-10 <br />above, then the Order should require Snowcap to provide citations to all pages and paragraphs of <br />said exhibits. <br />2. Objector's geological and engineering consultants need access to the original ERT <br />data collected by Fugro Consultants in the April and August, 2016, field testing. Working with <br />Xerox copies of the same leads to inaccurate analysis. Objectors request that the original data be <br />provided to Mr. Ken Walter and Mr. John Withers on or before May 1, 2017. <br />VII. HEARING EFFICIENCIES <br />Carey joins in the proposed hearing efficiencies and stipulations set forth in Fontanari's <br />Pre -Hearing Statement. <br />Date: April 6, 2017 <br />3 <br />/s/R Gregory Stutz <br />R. Gregory Stutz <br />Attorney for Objector Carey <br />