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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
Fields
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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Upper Gunnison River Water Conservancy District <br />02CW038 <br />that Mr. Lacy testified that the Gunnison whitewater Park has a minimum low-flow rate of 250 cfs. <br />(Lacy Tr. at 126, State Exiibit P.). <br />What the State ignores is Mr. Lacy's further explanation that the point of having a low-flow <br />channel is to allow boaters to use the reach in low flow times when it would otherwise be difficult or <br />impossible to navigate the river. The rest of the structure is not actually used until the flows exceed <br />the 250 cfs captured in the low flow channel. During runoff and times of higher flows in the river, <br />Mr. Lacy testified that flows of 250 cfs will not attxact many experienced boaters. Mr. Schumacher <br />testified that in the 2002 drought, his kayak business declined about 75%, largely due to the very low <br />flows in the Gunnison River that suxnnler. (Schumacher Tr. at 10.) <br />Mr. Kowalski testified that the lowest flow rate that "will attract many experienced boaters" <br />is what the CWCB considers to be the minimum flow for a reasonable recreation experience. <br />(Kowalski Tr. at 82.) He also acknowledged that there can be more than one such flow rate. <br />(Kowalski Tr. at 83.) Even using the CWCB's definition of the "minimum flow for a reasonable <br />recreation experience" as the lowest flow rate which "attracts many experienced boaters," it is clear <br />that 250 cfs does not meet this standard in all of the months for which the District appropriated the <br />water right. Further, at 250 cfs, the high flow structure fails to function at all. "Water rights are <br />decreed to structures." Dallas Creek Water Co. v. Huey, 933 P.2d 27, 38 (Colo. 1997). The <br />CWCB's amount totally ignores the high flow structure and therefore should be rejected. <br />-17-
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