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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 />designed to function. They are all less than the average flow in the Gunnison River during each <br />particular tune period for which a water right was claimed. (Exhibit UG-9 shows the average flow <br />in the river and the amounts claimed during each applicable time period.) While the flow rates <br />claimed will undoubtedly have an impact on upstream users, all water rights have such an impact. <br />The District determined that the proj ected impact ofthe amounts claimed (see exhibit UG-9 depicting <br />this impact) was acceptable. Indeed, the evidence showed that many - if not most - upstream water <br />users are already subj ect to impacts that affect, but do not foreclose, their ability to appropriate water <br />and that the added incremental impact of the RICD would not foreclose further development. The <br />amounts claimed address the needs of the boating community. The evidence also showed that the <br />course, once constructed, can function efficiently and thereby allow a reasonably efficient diversion <br />practice. <br />In light of all the factors considered by the District and evidence presented at trial, the amount <br />claimed is certainly reasonable and appropriate under reasonably efficient practices to accomplish the <br />intended purpose. Further, the amounts claimed allow the District to maximize its beneficial use. <br />The District intended to appropriate varying amounts within the design parameters of the <br />Gunnison whitewater course in order to maximize beneficial use of the water appropriated for the <br />whitewater park by providing a recreational amenity that will be widely used by bo aters with a variety <br />ofskills, experience and water craft during the months ofMay through October, without commanding <br />-19-
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