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Reply Brief; Case No. 04SA44
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Reply Brief; Case No. 04SA44
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Last modified
1/26/2010 4:41:38 PM
Creation date
7/29/2009 12:57:14 PM
Metadata
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Template:
Water Supply Protection
File Number
8230.2F
Description
Colorado Supreme Court Appeal
State
CO
Basin
Colorado Mainstem
Water Division
4
Date
10/15/2004
Author
Ken Salazar, Susan Schneider
Title
Reply Brief; Case No. 04SA44
Water Supply Pro - Doc Type
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1998). Here, the objective, as recognized by the Appellee, was to impose limits on in- <br />channel uses as "protections against abuse" and because of fear of "misuse." (Brief, pp. 11- <br />12). The only inherent abuse that the Legislature discussed in enacting SB 216 was a <br />concern about the amount that could be claimed. <br />Both the plain language'a and the legislative history of SB 216 clearly limit these new <br />recreational instream water rights to a minimum flow. ls If the plain language is not clear, <br />the legislative history of SB 216 shows that the "ultimate policy question" was how much <br />water should be granted for recreational instream uses. (Exhibit H, pp. 28-29, 38; Exhibit K, <br />pp. 22-23). Legislators'6 repeatedly stated that they wanted to mandate that future claims <br />could only be decreed for the minimum amount necessary in order to ensure that the flow of <br />the entire stream would not be completely tied up by in-channel uses, allowing one entity to <br />control the water. (Exhibit J, Legislative Statement; Exhibit G, pp. 3-4,10; Exhibit H, p. 1; <br />Exhibit I, p. 18). <br />14 The word "minimum" is defined by Black's Law Dictionary p. 1268 (Sth ed. 1979) as the <br />"least quantity assignable, admissible or possible in [a] given case and is opposed to maximum." <br />This is also a common-sense interpretation. <br />ls CRCD argues that the word "minimum" should not be given effect, but that the phrase <br />"pursuant to an application" in section 37-92-103(10.5) should be given effect. (Brief, p. 12). <br />The term "minimum" is an unambiguous term found in any dictionary, unlike the words <br />"pursuant to an application," which has no plain meaning. Nonetheless, CRCD argues that <br />"pursuant to an application" should be interpreted to mean that the Appellee's intent should <br />decide the amount of the right. The State asks this Court to review the legislative history of both <br />terms to determine the legislative intent. Such review will show that the Legislature repeatedly <br />expressed a desire to restrict flows to a minimum, but never even mentioned the phrase "pursuant <br />to an application," let alone its alleged significance. Finally, the phrase modifies the clause <br />"between specific points defined by control structures" and does not modify the words <br />"minimum" or "reasonable." <br />10
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