If a megaload were to go into the river on Highway 12, it would be difficult and complicated to bring in a large enough crane to lift it out of the river, ITD maintenance engineer Doral Hoff acknowledged under cross-examination. Some spots along the river simply wouldn't accommodate that type of crane. But, Hoff said, "We're confident it won't go into the river. ... We've had a number of wide loads go up U.S. 12 and we haven't had any accidents."

Asked how long it would take to get a load out of the river, Hoff said, "We don't know how long it might be. It could take up to a month or two months, I don't have any idea. But during that time the traveling public wouldn't be inconvenienced." Attorney Natalie Havlina responded, "But there would be something the size of a small building in the middle of the river." Hoff said, "Yes." When she questioned whether a huge crane attempting to retrieve the load would block traffic, Hoff said that'd be part of what ITD would take into account in planning for the load's removal. He mentioned experience dealing with avalanches along the route in 2008. "One methodology would be to cut this drum up," he said. At that point, he said, "It would be a reduced load of no value to ConocoPhillips."