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Mid - Continent Answer Brief <br />STATEMENT OF THE CASE <br />CAUSES OF ADVERSE DISCHARGES <br />FROM MCR's OUTFALL No. 016 <br />SNOWFALL <br />In the winter of 1988 -1989, snowfall observed at Redstone 4 W weather <br />reporting station indicates something of that winter's severe conditions in Coal Basin. <br />The snowfall at Redstone 4 W was officially reported as follows, MCR Ex. Nos. 2 -A <br />through 2 -D, Record 00224 - 00227: <br />Month, Year <br />November, 1988 <br />December, 1988 <br />January, 1989 <br />February, 1989 <br />Total Snowfall <br />Snowfall <br />in Inches <br />16.6 <br />50.75 <br />31.5 <br />75.5 <br />174.35 <br />MCR witness Scott Jones testified about the 48 -inch snowfall the weekend <br />' National Oceanic and Atmospheric Administration, National Weather Service <br />( "NOAA/NWS ") observation station Redstone 4 W (which stands for "Redstone, 4 miles West ") <br />was about twenty yards from the front doors of Mid - Continent's district office in Coal Basin. <br />This observation station is approximately one - quarter of a mile Northeast of the Outfall No. <br />016 ponds and approximately 150 feet lower in elevation than the Outfall No. 016 ponds. <br />Weather observations at Redstone 4 W were recorded by Mid - Continent employees and <br />reported to NOAA/NWS. The complete NOAA/NWS reports for the State of Colorado for the <br />months of November and December, 1988, and January and February, 1989, are, respectively, <br />MCR Exs. Nos. 1 -A through 1 -D, Record 00144 - 00233. The NOAA/NWS reports for Redstone <br />4 W for the same time period are, respectively, MCR Exs. Nos. 2 -A through 2 -D, Record 00224- <br />00227. <br />8 At the time of the WQCD hearing, Jones, a registered engineer and graduate of the <br />Colorado School of Mines (3 Tr. Jones, 7-8), was a longwall engineer for Mid - Continent. <br />However, he was initially hired as an environmental engineer (id. 7), and the environmental <br />engineer was responsibile for shooting potential avalanches as a control measure. <br />6 Appeal No. 93 CA 297 <br />