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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 RiveY Water Conservancy District <br />02CW038 <br />pool' in the Aspinall Unit upstream of the RICD" (Answer at 18), such "impairment" does not lead <br />to a finding that Colorado's ability to fully develop its Colorado River Compact entitlement is <br />impaired. The evidence showed that the claimed water right has no impact whatsoever on <br />downstream water rights or water rights in other parts of the Colorado River drainage. The evidence <br />also showed that the full remaining amount of Colorado's compact entitlement could be developed <br />either downstream of the water right or in other parts of the Colorado River drainage. Thus, even <br />assuxning the State's unfounded legal conclusion concerning impairment upstream of the District's <br />water right was correct, the evidence simply does not justify a finding that this causes an impairment <br />of Colorado's overall ability to develop its Colorado River Compact entitlement. <br />In surrunary, the CWCB's arguments concerning compact impaument are either irrelevant or <br />unsupported by the evidence. <br />4. Onlv the CWCB's firidings of fact are presumptive on the water court. <br />The State clauns that "[t]he legislature did not intend that the recommendations be separated <br />from the findings for this court's review," and that the "intent of the legislature is clear from the plain <br />language of the statute." (Answer at 20.) Notwithstanding this assertion, the State's argument <br />completely ignores the actual language of the statute, which authorizes the CWCB to malce findings <br />and a final recommendation, and provides that only the fmdings of fact are presumptive on the court. <br />-29-
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