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Applicant's Closing Reply Brief
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Applicant's Closing Reply Brief
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Last modified
1/26/2010 4:41:38 PM
Creation date
7/29/2009 12:51:38 PM
Metadata
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Template:
Water Supply Protection
File Number
8230.2B2
Description
Discovery
State
CO
Basin
Colorado Mainstem
Water Division
4
Date
12/3/2003
Author
Cynthia F. Covell
Title
Applicant's Closing Reply Brief
Water Supply Pro - Doc Type
Court Documents
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UppeY Gunnison River Water Conservancy District <br />02CW038 <br />See Applicant's Closing Brief at 17. <br />Although the State's Answer does not mention it, CWCB Director Kuharich's above-quoted <br />remarks were made just after the SB 2161egislative statement was read by Representative Spradley.15 <br />Clearly, despite the references to "rr inimum" flow in the legislative statement, Director Kuharich did <br />not think there was an objective minimum flow criteria. Rather, he thought that SB 216 was placing <br />recreational in-channel water rights into the same class as other water rights which could command, <br />not "all the water they can physically get a hold of', but rather only "the water that they can <br />reasonably and efficiently use".' 6 These notions of reasonable and efficient use articulated by Director <br />'s The only support for State can fmd for its argument that (1) the legislative history <br />and (2) the plain language both reflect an objective minimum flow criteria is found in (1) an <br />isolated excerpt from the legislative statement which was prepared, not by_a legislator, but by <br />attorneys for Northern Colorado Water Conservancy District and (2) the fact that the definition of <br />"recreational in-channel diversion" includes the phrase "min;mum stream flow ... for a reasonable <br />recreation experience". As is apparent from reading the rest of the remarks both during the <br />5/7/01 legislative hearing at which this legislative statement was read and during all the other <br />legislative hearings, no one really thought that the final version of SB 216 contained objective <br />minimum flow criteria. As for the State's reliance on the "minimum stream flow ... for a <br />reasonable recreation experience", see the arguments in Applicant's Closing Brief concerning the <br />plain language of the rest of the statutory provision from which this isolated phrase is taken. <br />16 Though SB 216 had changed by the time CWCB Director Kuharich made his <br />5/7/01 statement explaining his understanding of how SB 216 allowed recreational in-channel <br />water rights to claim amounts of water that could be reasonably and efficiently used, this <br />understanding appears to be the same as the understanding that the CWCB, and presumably <br />Director Kuharich, started with. See handout provided by Kuharich to legislature on 4/12/01 as <br />-13-
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