2002-07-31_PERMIT FILE - M2002004

Home Browse Search

Applicant, GCC Rio Grande Pre - Hearing Statement July 30, 2002 Page 5 maps, drawings, calculations, narrative and any other materials from the mining permit application in providing testimony at the hearing. K. James Gill, P.E. Contour Engineering P.O. Box 555 Morrison, CO 80465 Phone: 303 - 697 -2655 Mr. Gill is a geotechnical engineer. Mr. Gill will be available to provide testimony regarding stability of foundations for structures, mining and reclamation activities at the Red Rock Plant and Mine. Mr. Gill may rely upon maps, drawings, calculations, narrative and any other materials from the mining permit application in providing testimony at the hearing. L. In addition to the above -noted technical presentations concerning the issues raised in the Pre - Hearing Order of June 7, 2002, the undersigned counsel for GCC Rio Grande may make presentations on legal and/or policy issues. M. Consistent with the Pre - Hearing Order, GCC Rio Grande anticipates the need to offer rebuttal testimony. Therefore, GCC Rio Grande reserves the right to designate additional witnesses; any of the above -noted witnesses may offer rebuttal testimony, as may be needed, to respond to the testimony made by the Division of Minerals and Geology or other parties to the proceeding. Rebuttal witnesses may rely upon maps, drawings, calculations, narrative and any other materials from the mining permit application in providing testimony at the hearing. III. TIME ALLOCATION The Pre - Hearing Order of June 7, 2002, provides that GCC Rio Grande shall have 50 minutes to make a presentation to the Mined Land Reclamation Board. GCC Rio Grande shall also have 45 minutes to cross - examine witnesses and make a rebuttal statement. Finally, GCC Rio Grande shall have 20 minutes to make a closing statement. GCC Rio Grande respectfully reserves the right to request additional adequate time for any new issues that may arise. IV. EXHIBITS GCC identifies the following exhibits for use at the hearing: Exhibit A: Expert Resources and Documents on Blasting {81408:3}