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Objection to BMRI's AM-03 <br />Page 17 of 23 <br />February 22, 2008 <br />confined aquifer. The top layer thickness was chosen such <br />that the entire top layer would encompass the fold-out of the <br />deepest San Luis well (300 feet). (p. 2) <br />His report generates a number of questions. What is the depth, dimensions and <br />boundaries of the unconfined aquifer in this lower basin? Does it encompass the <br />Salazar Ranch? Does it encompass the town of San Luis? Does it encompass other <br />domestic and stock irrigation wells in the area? What are the answers to the above <br />questions if addressed to the confined aquifer as opposed to the unconfined aquifer? <br />How are both the confined and unconfined aquifer In this area described in the <br />literature, U.S.G.S. studies? Is the confined aquifer under artesian pressure? (Note <br />Diagram RG12, 2004 CW 24, p. 102, Exhibit F illustrating the interconnections between <br />two aquifers.) What is the inter-connection between the two aquifers? Is there an <br />underlying geological and hydrological basis. to distinguish the two aquifers? <br />Conversely, on what basis were the parameters of the unconfined aquifer chosen for <br />purposes of the Lytle modeling analysis? On what basis. were parameters chosen for <br />the confined aquifer? Are there physical facts to support it? <br />As to the use of MODFLOW, what are the underlying base assumptions that <br />need to be in place before using MODFLOW? What assumptions need to be made to <br />determine its accuracy and relevancy for use at. this particular sub-part of the Rio <br />Grande Basin? What assumptions must be in place before one can use MT3DMS? <br />What assumptions must be in place before one can use MODFLOW in conjunction with <br />MT3DMS? <br />The Lytle report appears to address two target areas for its investigation - (1) <br />that area of the aquifer underneath the Salazar.Ranch; and (2) the model area which <br />includes the Salazar Ranch and the town of San Luis.. To the extent that only the area <br />underneath the Salazar Ranch is targeted, why is that area chosen as the target area? <br />Does control of the land surface on the ranch connote control of the underlying aquifer? <br />Is there some type of physical barrier in the aquifer underlying the ranch that prevents a <br />constituent from leaving that area? What physical facts or characteristics of the aquifer <br />support the contention that any constituent introduced into the aquifer underneath the