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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
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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 />large part from Golden's application8 and the more general concern was over potential claims to the <br />entire flow of a river and how to balance recreational in-channel demands with the demands of more <br />traditional water rights.9 Many questions were posed and statements made as to how the legislature <br />should address this concem. Yet, as explained herein and iri the District's opening Closing Brief, the <br />legislative concerns were addressed by limiting the class of appropriative entity and thereby <br />preserving local control over recreational in-channel water rights, while at the same time giving the <br />CWCB a certain reviewing role. The concept of beneficial use as applied to the water rights was not <br />altered. On the contrary, recreational in-channel diversions were integrated into the definition of <br />"beneficial use" in a manner that explicitly did not limit the existing definition. <br />The uutial version of Senate Bill 216 described a statutory scheme whereby a local <br />government entity was required, before initiating any water rights filing in the water court, to submit <br />$ Golden's claim was described in the 4f l8/Ol SB 216 legislative hearing by Sta.te <br />Engineer Ha1 Simpson as being so large that it was "available less than 1% of the time, looking at <br />historic record". See n. 2 of Applicant's Closing Brief. He described Breckenridge's filing also as <br />being "available less than 1 percent of the time". Id. In contrast, as shown by Exhibit UG-9, the <br />District's claim here is at all times less than the average Gunnison River flow. <br />9 See, e.g., April 18, 2001 Hearing at p. 33 (remarlcs of attorney Bob Trout <br />representin.g the Northern Colorado Water Conservancy District: "But I think what we're really <br />looking at here is the issue of how much is enough for one of these water rights ultimately is <br />going to be a policy balancing issue, balancing the claim needs for a particular course at a <br />particular place against the potential needs for future development upstream"). State Exhibit 9 <br />contains the legislative hearing transcripts. -7- <br />
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