Correspondence on Bonneville Unit of Central Utah Project

Page 192

"AlAAr"%: :.:A^^A'Aii|A;:.:;:- i:#<x ^ *,&r?«^ A % * A * X ' : - , .srr* "'''":rA3Sr ^BiiiSfSsllAAA"'' SIERRA CLUB LEGAL DEFENSE FUND, INC. by Ansel Adams in This is the American Earth JAMES W. MOORMAN Executive Director BARRY A FISHER JOHN D. HOFFMAN LAURENS H. SILVER Staff Attorneys, San Francisco H. ANTHONY RUCKEL Staff Attorney, Denver February 18, 1974 Mr. Curtis Oberhansly Twelve Exchange Place Salt Lake City, UT 84111 Re: CUP Litigation; Expert Witness Clair Nelson Dear Curt: Set forth below, and particularly in the attachments, are my thoughts regarding Clair Nelson's testimony in the preliminary injunction proceeding as an expert water resource planner and economist. Obviously the thrust we seek with Mr. Nelson, as we do with John McComb, is a showing that fuller and more detailed considera­tion of the entire CUP and the relationship to it of Currant Creek Dam and the Strawberry Aqueduct System could well result in a decision that certain substantial parts of such aqueduct system, including Curr^a^t^^eek^Dam^ may well not be needed in order to attain project purpoges. I have attached John McComb's affidavit attached to the motion for TRO and my letter to John of December 20, 1973. The points made therein are the points we need to place before the court in as brief and succinct a manner as possible. Obviously, Clair and John may both have some changes and adaptations to the materials enclosed which would more clearly or more accurately statetthe^ propositions we wish to make. However, the enclosed form ^s^good a starting point as I can conceive. I suggest you get to work immediately with Clair on his testimony. I believe you and he San Francisco: 311 California Street, Suite 311, 94104; Telephone [phone] Denver: 508 Majestic Bldg., 209 16th Street, 80202; Telephone [phone]