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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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Upper Gunnison River Water Conser-vancy District <br />02CW038 <br />rebuttably presumptive finding on some objectively determined minimumstream flow for a reasonable <br />recreational experience, the CWCB is taking on a role not given it by the General Assembly. Here <br />again, no presumption should be accorded to the CWCB's gratuitous determination ofthe "minimum <br />stream flow necessary to provide a reasonable recreation experience." <br />Second, as explainedabove, the defuutionof"recreationalin-channeldiversion" does nothave <br />any objective minimum amount standard.14 Rather, it refers to the amount of water, type of diversion <br />and control structures, and recreation experience that comport with the application filed by the <br />appropriate local government entity. The CWCB takes the phrase "minimum stream flow for a <br />reasonable recreation experience" utterly out of context and, again, tries to create for itself a role that <br />it does not have. <br />During oral closing argument, the Court inquired whether there was some implicit finding in <br />the CWCB's "Findings and Recommendations" that there is compact impairment at rates b eater than <br />250 cfs and that maximum utilization was not promoted at such greater rates. Certainly such an <br />implication, if there is one, was refuted by the CWCB's own attorney, who opined during her closing <br />14 CWCB Duector Rod Kuharich told the legislature that "it's not all the water they can <br />physically get a hold of, but it's all the water that they can Yeasonably and eff ciently use. And <br />that really becomes the test of what those water rights can appropriate. And I think by this <br />definition; we have placed this water right in the same light that the other water right <br />classifications are." [Emphasis added]. Transcript of May 7, 2001 Hearing at p. 6. <br />-30-
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