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v <br />_Y <br />DISTRICT COURT, WATER DIVISION NO. 4, <br />STATE OF COLORADO <br />Montrose County Justice Center <br />1200 North Grand Avenue Bin A <br />Montrose, CO 81401-3146 <br />970.249.2859 <br />CONCERNING THE APPLICATION FOR WATER <br />RIGHTS OF THE UPPER GUNNISON RIVER <br />WATER CONSERVANCY DISTRICT ? COURT USE ONLY ? <br />IN GUNNISON COUNTY <br />Cynthia F. Covell, #10169 Case Number: 02CW038 <br />Alperstein & Covell, P.C. <br />Gilbert Y. Marchand, Jr., Of Counsel, #19870 <br />1600 Broadway, #2350 Water Division No. 4 <br />Denver, CO 80202-4923 <br />Phone: (303) 894-8191 <br />Fax: (303) 861-0420 <br />cfc(a-)alpersteincovell.com <br />gymlaw@earthnet.net <br />APPLICANT'S CLOSING BRIEF <br />Applicant, Upper Gunnison River Water Conservancy District ("applicant" or "District"), <br />through its undersigned attorneys, submits the following closing brief: <br />1. Introduction. <br />T'his is the first case to be tried under Senate Bill 216 (attached hereto as Exhibit A and <br />referred to herein as SB 216). To assist the Courtin applying SB 216 in this case, this Closing Brief <br />describes the milieu in which SB 216 was enacted, the problems it was intended to address, and how <br />its provisions are integrated into traditional water law concepts. The truly new concepts found in <br />SB 216, a limitation on the type of appropriator, and the need to consider impairxnent of interstate <br />compact entitlements, are discussed. The Brief then demonstrates that the District's application was <br />_? . <br />.424