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Because the proposed use is non-consumptive, it allows for successive use of water downstream. <br />As such, the project more than satisfies the legal requirements of the maximum utilization <br />doctrine. In addition, the Gunnison Course will benefit the local economy, environment and <br />quality of life, all relevant factors to the maximum utilization determination under Alamosa. <br />Though the proposed RICD right might impact future upstream uses of water, as <br />discussed above the impact is mitigated by a number of factors, and consideration of future uses <br />is inappropriate in any event. <br />M. CONCLUSION <br />For the above reasons, in addition to the reasons set forth in TtJ's prehearing statement, <br />TU encourages the CWCB to make the requisite findings and a favorable recommendation to the <br />water court regarding the Applicant's water rights application. <br />? <br />RespectfjVlly submitted this, day of August, 2002, <br />Vc2 :3,.tf = <br />Andrew Peternell, Reg. No. 32455 <br />Trout Unlimited <br />1966 13t' Street, 5uite LL60 <br />Boulder, Colorado 80302 <br />6 <br />/.