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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 Consei-vancy District <br />02CW038 <br />To limit recreational in-channel water rights to the "minimum flow for a reasonable recreation <br />experience" a;; the CWCB has done is too narrow, and, as previously discussed, flies in the face of <br />traditional Co::orado water rights law.18 In accordance with the definition of"beneficial. use", the flow <br />rates decreed should be reasonable and appropriate under reasonably efficient practices to accomplish <br />the intended purpose of the appropriation, which in tYus case is broader than simply "aittracting many <br />experienced boaters." As the evidence showed, the County authorized the design oj"a course that <br />would be a recreational amenity for the community, that would attract tourists, that would be suitable <br />for competiticns, and that would provide a recreationalboating classroomfor Western State College. <br />Such a course was designed and there is a specific plan, intent, and ability to fully construct it. The <br />District deterrcuned a reasonable and appropriate amount of water: by considering the- range of flow <br />rates at which the course was designed to function (the design parameters), by analyzing the amount <br />of flow availa.ble for appropriation, by examining the impacts that different flows inight have on <br />upstream wab;r users, and by considering input from the boating commuxuty. The varying flow rates <br />claimed in the application are all less than the maximum amount of 2000 cfs at which i;he course was <br />18 It flies generally in the face of the prior appropriation doctrine, whetrLer in <br />Colorado or other westem states. "So far as I am aware, it has never been held or contended that <br />in making an appropriation of water from a natural stream the appropriator is limited in the right <br />he can acquiri; to his minimum needs". Caldwell v. Twin Falls Salmon River Land <4c Water Co., <br />225 F. 584, 596 (D. Idaho 1915). <br />-18-
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