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20. Whether any of the pictures used by Division in presenting its case were rocks <br /> affected by Fontanari irrigation practices, or, simply rocks removed to increase safety in the area <br /> after years of similar rockfalls unrelated to irrigation; <br /> 21. Evidence contrary to Division testimony which appeared to blame Fontanari's <br /> irrigation for all or most of the I-70 rockfall, and which appeared to include rock masses <br /> removed by blasting or mechanically distant from any discharge point for Fontanari irrigation <br /> water; <br /> 22. Testimony from a surveyor as to the relative elevations of points discussed in The <br /> Division testimony, including the alleged discharge point on the cliff face, the elevation of the <br /> ponds created in the test pits and areas within the irrigation field; <br /> 23. Lay testimony challenging the assertion by Division that it was lied to concerning <br /> Fontanari's irrigation plans within the permit area; <br /> 24. Lay testimony challenging Division's assertion that it first became aware of the <br /> Fontanari construction n August 6, 2018 and that Fontanari misled them as to it being <br /> construction by Ute Water; <br /> 25. Expert hydrological testimony disputing in whole or part the Division's assertions <br /> regarding the direction and flow of waters from irrigation and the sandstone cap being a total <br /> water barrier; <br /> 26. Expert geologic and soils testimony challenging in whole or part the Division's <br /> assertions that voids were created by hydro-compactive soils and were unrelated to coal mine <br /> subsidence, and challenging the Division's assertion that the sandstone caprock was a complete <br /> barrier to water flow; <br /> 6 <br />