My WebLink
|
Help
|
About
|
Sign Out
Home
Browse
Search
Rebuttal Statement of Town of Silverthorne
CWCB
>
Water Supply Protection
>
DayForward
>
3001-4000
>
Rebuttal Statement of Town of Silverthorne
Metadata
Thumbnails
Annotations
Entry Properties
Last modified
1/26/2010 4:41:19 PM
Creation date
7/24/2009 12:13:57 PM
Metadata
Fields
Template:
Water Supply Protection
File Number
8230.51A1
Description
Applicant's Prehearing Statements: Legal Documents
State
CO
Basin
Colorado Mainstem
Water Division
5
Date
6/6/2005
Author
David W. Robbins
Title
Rebuttal Statement of Town of Silverthorne
Water Supply Pro - Doc Type
Litigation
There are no annotations on this page.
Document management portal powered by Laserfiche WebLink 9 © 1998-2015
Laserfiche.
All rights reserved.
/
7
PDF
Print
Pages to print
Enter page numbers and/or page ranges separated by commas. For example, 1,3,5-12.
After downloading, print the document using a PDF reader (e.g. Adobe Reader).
Show annotations
View images
View plain text
• only be achieved with proper regard for all significant factors, <br />including environmental and economic concerns. <br />Id. 674 P.2d 914, 935 (Colo.1983)(emphasis added). <br />Consistent with the foregoing, RICD rights are a new, clean use of water on top of, and <br />that work in tandem with, existing and future downstream diversions, generating significant <br />revenue for local communities without polluting or consuming a single drop of water. Colorado's <br />doctrine of "maximum utilization" is served because water is put to beneficial use and then <br />passes undiminished for other Colorado consumptive uses and to fulfill Colorado's compact <br />delivery obligations. <br />Colorado also has an extremely strong "anti-speculation doctrine" which precludes <br />recognition of a water right for unspecified future uses. See, e.g., Colorado River Water <br />Conservation Dist. v. Vidler Tunnel Water Co., 594 P.2d 566 (Colo. 1979); See also Three Bells <br />Ranch Assoc. v. Cache La Poudre Water Users Ass'n, 758 P.2d 164, 173-74 n. 11 (Colo.1988). <br />Thus, the position advocated or suggested by some objectors that Silverthorne's RICD must be <br />subject to future, undefined and unfiled, exchanges is not well grounded in the law. It is a <br />twisting of the "maximum utilization" doctrine to suggest that water must be left for other <br />unspecified future uses than used for nonconsumptive recreational use within the reasonable <br />flow, time of day, and season of use limitations that are part of Silverthorne's claim. Maximum <br />utilization does not presume to benefit any individual appropriator, nor to elevate the rights or <br />interests of one city, town, or region over others. Denver holds numerous and voluminous <br />• absolute and conditional water rights on the Blue River. The doctrine of maximum utilization <br />simply cannot be contorted to fit Denver's notion that its perceived need for even more Blue <br />River water in the future can supersede Silverthorne's ability to make a valid lawful <br />appropriation in this case. <br />Denver also argues that the Silverthorne RICD cannot operate unless all downstream <br />water rights having priorities senior to 2004 are being satisfied. Silverthorne believes that this is <br />a misstatement of the law as it applies to nonconsumptive appropriations. Silverthorne believes <br />that this issue is purely a legal issue and that the CWCB should defer to the Water Court's <br />determination of this issue. It is to be noted, however, that if Denver's legal analysis is correct, <br />there would be no water available for almost any CWCB instream flow claim, nor would plans <br />for augmentation be approved, not to mention the RICD claims, because most stream systems in <br />Colorado are over-appropriated. The fact that Water Court's have recently approved new RICDs <br />in such over-appropriated basins should alert the CWCB that Denver's legal theory has not been <br />adopted by the Water Courts. <br />Staff has asserted that the RICD claim will not impinge on the doctrine of maximum <br />utilization, except during September. Staff has suggested that this issue may be resolved by a <br />"dry-year condition and/or trigger flows." As a concession to Staff on this issue, Silverthorne, as <br />discussed above, has agreed to incorporate trigger flows in any decree that it seeks in this case. <br />Several Objectors discussed the impact of the RICD on future, undecreed, exchanges <br />• and other uses of water that may or may not occur in the future. Silverthorne believes that the <br />concern is overstated for many reasons. The RICD will have a 2004 priority date and be subject <br />4
The URL can be used to link to this page
Your browser does not support the video tag.