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Applicant's Closing Brief: Case No. 02CW038
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Applicant's Closing Brief: Case No. 02CW038
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Last modified
1/26/2010 4:41:33 PM
Creation date
7/28/2009 11:54:47 AM
Metadata
Fields
Template:
Water Supply Protection
File Number
8230.2B3
Description
Pleadings
State
CO
Basin
South Platte
Water Division
4
Date
10/22/2003
Author
Cynthia F. Covell
Title
Applicant's Closing Brief: Case No. 02CW038
Water Supply Pro - Doc Type
Court Documents
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? <br />Upper Gunnison River Water Conservancy Distr•ict <br />02CW038 <br />find "compact impaument" as a result of the District's recreational water right when there is no <br />evidence that any out-of-basin project is presently being contemplated that will be affected by the <br />whitewater course, and that out-of-basin projects that have been contemplated, such as the Union <br />Parlc project and the 1989 Colorado Water Resources and Power Development Authority project <br />a1e not being pursued or even considered. <br />Finally, the District's recreational water right has no effect on downstream development <br />opportunities, and both Mr. Seaholxn and Mr. Slattery testified that an out-of-basin project could <br />theoretically be undertaken from Blue Mesa Reservoir downstream of the whitewater reach. <br />There is simply no compact impairment as a result of this water right. This application is <br />simply not the "water grab" feared by the General Assembly. The flows sought in the application are <br />significantly less than the average flows in the Gunnison River in the reach during each of the relevant <br />tune periods. See Ex. UG-9 and UG-16. The District's agreement not to place a call for the water <br />right when the Guruiison Tunnel or Redlands Power Canal rights are or could be calling even fiu-ther <br />reduces the impact of this claim for less than average flows, and precludes a call by the whitewater <br />park in dry times. <br />Exhibit UG-13 shows that with the Gunnison Tunnel call limitation, the recreational water <br />right is proj ected to call in 4- 8% of all years, except for during the two two-week periods from mid- <br />June through mid-July. During those time periods, the call projection is 35% (June 15-30) and 27% <br />-23-
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