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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
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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 Conservancy Distr•ict <br />02CW038 <br />develop its interstate river compact entitlements;4 and applications for recreational in-channel water <br />rights by special interest groups (or even the federal government) that might be used to export water <br />yet those numbers have huge implications when they only occur two or three days a year and you <br />might be able to fill a reservoir for municipal use for 50 thousand people during those two days, <br />but you can't exchange the point of diversion up to where the reservoir is."); April 18, 2001 <br />Hearing at p. 28 (remarks of State Engineer Hal Simpson: "New reservoirs at higher locations in <br />the watershed that store water during that period of surplus, those high runoff months of May and <br />June, could be made ineffective if there's a very large downstream recreational water right."); p. <br />30 (remarks of First Assistant Attorney General Steve Sims: "There's other issues the water court <br />just cannot get to right now. For instance, considering the impact of a particular application on <br />future uses. That's a subject that's just off the table. A water court can't do that, and that would <br />probably malce some sense. That's a policy decision."); p. 33 (remarks of attorney Bob Trout <br />representing the Northern Colorado Water Conservancy District: "But I think what we're really <br />looking at here is the issue of how much is enough for one of these water rights ultimately is <br />going to be a policy balancing issue, balancing the claim needs for a particular course at a <br />particular place against the potential needs for future development upstream"); p. 36 (remarks of <br />then current CWCB member Patti Wells: "So for a minimal investment, an entity can completely <br />control up-stream water use and can also control downstream seniors. As you've heard, it would <br />interfere with changes and exchanges and in my view that's the future of municipal water rights, <br />particularly on the Platte and on the Clear Creek and other places where there's a lot of use."). <br />4 See April 12, 2001 Hearing at p. 39 (remarks of Mark Pifher: "How do you affect or <br />impact your ability to develop your compact in the future? What is maximum utilization? How <br />do you effectuate maximum utilization?"); April 18, 2001 Hearing at p. 28 (remarks of State <br />Engineer Hal Simpson: "I think one of the key issues - do these recreational in-channel diversions <br />limit our ability to develop our compact entitlements? I'm Colorado's Comxnissioner on five <br />interstate compacts and have quite a bit of familiarity with that issue. If a large recreational in- <br />channel water right was granted at a certain location it could very well prevent or limit our ability <br />to develop our unused compact entitlements."); p. 31 (remarks of First Assistant Attorney <br />General Steve Sims: "Another major issue, and this is the Attorney General's huge concern in this . <br />case, is the impact on these types of water rights on our compact entitlements"). <br />-5-
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