Information concerning mathematical modelling of the South Park ground water system, as developed and used by the Applicant for making predictions upon which the Application rests, was derived by Principia from a wide variety of source documents produced over a time period exceeding a year and three months starting on October 24, 1998. These sources of information are included in the following list of documents.

[1] Bruce, B. W. And R. A. Kimbrough (1999)
Hydrologic and Water-Quality Data for Surface Water, Ground Water and Springs in North-Central Park County, Colorado, April 1997 - November 1998
USGS Open-File Report No. 99-183, 11p + 3 Figures + 9 Tables.

[2] Eastman, H. (1999,2000)
Deposition Taken by Attorneys for Objectors, November 1999, January & February, 2000. 2, CD-ROM + 1, Diskette containing electronic files, and a set of USGS map copies containing sketches of vegetation-area polygons Produced to Principia, January, 2000.

[3] Hesemann, T. (2000)
Deposition Taken by Attorneys for Objectors, January 2000.

[4] Jehn Water Consultants, Inc. (JWCI) (1997a)
Percolation Test Report: South Park Conjunctive Use Project
Report Prepared for City of Aurora, May 22, 1997, 43p + 57 Figures + 10 tables + 5 Appendixes.

[5] Jehn J. (1999)
Deposition Taken by Attorneys for Objectors, November 1999.

[6] JWCI (1997b)
Lower South Park Aquifer Test Report: South Park Conjunctive Use Project
Report Prepared for City of Aurora, July 15, 1997, 34p + 15 Figures + 3 Tables + 3 Plates + 5 Appendixes.

[7] JWCI (1997c)
South Park Basin, Initial Ground Water Model Development Report
Prepared for City of Aurora, December 19, 1997, 86p + 39 Figures + 18 Tables + 4 Appendixes + 4 Plates.

[8] JWCI (1998a)
SPCUP Modeling Files: SPCUP & NOCUP Runs, Input, Output, Calibration Runs
1, TRAVAN Tape Produced to Principia, dated October 23, 1998.

[9] JWCI (1998b)
SPCUP Modeling Files: SPCUP & NOCUP Runs, Input, Output, Calibration Runs
1, TRAVAN Tape Produced to Principia, Dated November 4, 1998 to Replace Unreadable Tape Dated October 23, 1998.

[10] JWCI (1998c)
SPCUP Modeling Files: SPCUP & NOCUP Runs, Input, Output, Calibration Runs
2, TRAVAN Tapes Produced to Principia, Dated November 23, 1998.

[11] JWCI and Leonard Rice Consulting Water Engineers, Inc. (LRCWEI) (1998)
Initial Surface and Ground Water Modeling Report of the South Park Conjunctive Use Project
Prepared for City of Aurora, July 31, 1998, 72p + 15 Figures + 15 Tables + 2 Appendixes + 1 Plate.

[11] JWCI (1999a)
Documentation of Calibration Targets for the South Park Basin Ground Water Model
Report Submitted on Ms. Isobel McGowan, February 1, 1999, 5p + 23p of Table-1 + 1p Footnotes.

[12] JWCI (1999b)
SPCUP Model Input Packages Files, Correct Version
3, 1.4Mb Diskettes Produced to Principia on March 18, 1999, Dated March 5, 12 and 18.

[13] JWCI (1999c)
SPCUP Modeling Files: Input, Output, Calibration, MODFLOW Fortran and Executable Code, Sensitivity Analyses
5, CD-ROM & Memorandum Produced to Ms. Isobel McGowan, Dated June 7, 1999.

[14] JWCI (1999d)
Computer Files SPCUP Model, Construction of South Park Basin Ground Water Model, Percolation Test Files, Aquifer Test Files
1, CD-ROM & Memorandum Produced to Principia, Dated July 26, 1999.

[15] JWCI (1999e)
South Park Conjunctive Use Project Water Budget
Letter Report Circulated on August 17, 1999.

[16] JWCI (1999f)
Modeling for the SPCUP
Letter Report to Ms. Isobel McGowan Clarifying Model Predictive Simulations, October 5, 1999.

[17] JWCI (1999g)
Model Files and QSS Runs for Benchmark Runs
1, CD-ROM Produced by JWCI to Martin & Woods on October 6, 1999, Supplied to Principia on November 8, 1999.

[18] LRCWEI (1997)
South Park Conjunctive Use Project; Surface Water Availability
Preliminary Engineering Report, Division No. 1, case No. 96CW014, Prepared for COA, July 1997.

[19] LRCWEI (1999a)
1407 - South Park Conjunctive Use Project; Surface Water Model
1 CD-ROM Produced to Principia, Dated July 1999.

[20] Park County Sportsmen's Ranch, LLP (Applicant) (1999)
Decree Exhibit-Z: Terms & Conditions to Prevent Injury to Surface Water Rights
Document Transmitted by Bernard Lyons Gaddis & Kahn, P.C. to Principia, June 24, 1999.

[21] Rocky Mountain Consultants, Inc. (RMCI) (1998a)
Elkhorn Thrust Fault Investigation, Data Summary Report: South Park Conjunctive Use Project
Prepared for City of Aurora, July 1998

[22] RMCI (1998b)
Preliminary Engineering Feasibility Report: South Park Conjunctive Use Project
Report Prepared for City of Aurora, August, 1998.

[23] RMCI (1998c)
Electronic Copies of Files used by RMC in Running the South Park Basin Ground Water Model
3, CD-ROM + Table Listing Files Produced to Principia on November 24, 1998.

[24] RMCI (1998d)
Additional Information regarding Elkhorn Thrust Fault Study
Electronic Files & Memorandum Produced to S.S. Papadopoulus on November 24, 1998.

[25] RMCI (1999a)
1407 - South Park Conjunctive Use Project, Aurora Raw Water System Model, South Park Yield Model, SPCUP Operations Model
1, CD-ROM Produced to W.W. Wheeler & Associates on November 25, 1998, Produced to Principia on March 15 1999.

[26] RMCI (1999b)
RMC Plates & Figures from August 1998 Preliminary Engineering Feasibility Report - SPCUP, Fig. 1.1, Plates I & II
1, CD-ROM Produced to Principia on March 24, 1999.

[27] Technical Review Committee (1998)
Objectors' Report on the Technical Review of Applicant's Ground Water Modelling Report
Report Attached to Objectors' Report to the Court and to Applicant, and Request to Convert Case Management Conference to Status Conference, February 12, 1998.

[28] United States Geological Survey (USGS) (1998a)
An Assessment of the Water Resources of Park County, Colorado, With an Emphasis on the Evaluation of the Water Resources in the Vicinity of the Sportsmen's Ranch
Preliminary Proposal Submitted to the Center of Colorado Water Conservancy District, July 2, 1998.

[29] USGS (1998b)
An Assessment of the Water Resources of Park County, Colorado
Preliminary Proposal Submitted to the Park County Commissioners, October 30, 1998.

[30] USGS (1998c)
An Assessment of the Water Resources of Park County, Colorado
Revised Proposal Faxed to Mr. J. J. Kahn, November 12, 1998.

[31] USGS (1999)
Water Quality Data for Park County
Document Transmitted by Bernard Lyons Gaddis & Kahn to Principia, June 16, 1999.

The contents of these documents were not found to be compatible or consistent with respect to matters that are relevant and significant in this case. Apart from issues of consistency, the materials produced by the Applicant reveal that significant revisions and other modifications were made to the ground water model after its documentation was formally produced in this case. The information contained in materials actually produced by the Applicant was incomplete in several respects. To this day, other preparatory materials involving manipulations of data in at least three groupings, clearly used by the Applicant to construct this model and to prepare its input data sets, currently remain either produced only partly or not produced at all.

Strenuous attempts have been made by Principia to assemble complete information concerning the Applicant's modelling efforts such that a fair, current and representative model picture could be subjected to analysis. In keeping with this approach, conversations held by Dr. Schreüder with the Applicant's modelling expert did yield some clarifications and resulted in his electronic production of additional modelling files. The contents of these files have been identified as being at odds with the Applicant's own reports and with deposition testimony provided by the Applicant's modelling expert. As a consequence, although successive revisions to these files have been received periodically by Principia and analyzed thereafter, it is unclear whether or not this set of files is indeed complete, up-to-date and exactly as used by the Applicant for modelling the South Park ground water system, its stream-aquifer interactions and the proposed water development actions central to the Application.

The outcome of systematic analysis of the Applicant's model of the South Park ground water system, as conducted by Principia, are presented in the following sub-sections as graphical images accompanied by brief descriptions. They have been grouped together under several relevant topic categories. The images are based entirely upon modelling information produced by the Applicant in one form or another. They depict features of the models that are relevant to the Application, and results predicted with it. Wherever appropriate, additional information on surface features extracted from the USGS' digital topography maps has been superimposed upon these images in order to improve their clarity with references to features found in South Park.