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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 Wcater Conservancy District <br />02CW038 <br />recreational water rights. See, for example, the legislative statement cited throughout the State's <br />Answer and a.ttached thereto as Exhibit H.6 <br />2. Recreational in-channel diversions are part of the overall legislative scheme of the <br />1969 Act. <br />The District recognizes that the General Assembly was concerned, as the State: asserts, about <br />very large claims for recreation rights that would command the entire flow of a river or stream, or <br />control all available water. (Answer at 6.)' The specific concern about the amount claixned arose in <br />6 "S.B. 216 is designed to ensure that decrees for recreational in-chan:nel diversions, <br />as recognize(i by the Colorado Supreme Court in the Ciry of Thornton v. City of Fort Collins <br />case, are integrated into the state prior appropriation system in a manner which appropriately <br />balances the need for water based recreational opportunities with th.e ability of Colorado citizens <br />to divert and store water under our compact entitlements for more traditional consumptive use <br />purposes, suc;h as municipal, industrial and agricultural uses....[N]othing in S.B. 116 is intended <br />to create a water right which did not previously exist by virlue of state Supreme Court <br />'interpretatioii of Colorado statute or to affect any pending challenges to applications for rights of <br />tYus nature tc the extent such challenges are found to be meritorious under existing :Law.") <br />(quoting froxn SB 216 Legislative Statement, State Ex. H). <br />' As demonstrated by the evidence presented by trial, the District has not engaged in this <br />sort of miscruef, no matter how haxd the State tries to argue to the contrary. The fact that the <br />District does not support transmountain diversions, and that the water rights it has appropriated <br />may affect c-,rtain kinds exchanges for out of basin use, do not mean that the Court must deny the <br />District's re<<sonable appropriation of flows that are within the desi.gn parameters o:f the Gunnison <br />Whitewater :Park, are intended to maximize beneficial use of the whitewater park, and are less <br />than the average flow of the Gunnison River during all time periods for which flows are <br />appropriated.. This is not a"water grab" of the sort feared by the General Assembl.?. <br />-6-
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