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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
Court Documents
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to the water court" means that both the findings and recommendations should be considered <br />by the Water Court; otherwise, the Legislature would not have required the CWCB to present <br />any recommendations to the Water Court. <br />Finally, the Findings are ultimately tied to the Recommendation, and the <br />recommendation contains "findings of fact," which are presumptively valid. 37-92-305(13). <br />Thus, if this Court does not interpret section 37-92-305(16) as meaning that the CWCB's <br />Recommendation must be considered by the water court as presumptively valid, then this <br />Court should, nonetheless, hold that to the extent that the Recommendation contains findings <br />of fact, it is presumptively valid. <br />B. The CWCB must make a Finding as to whether the "minimum stream flow" <br />promotes maximum utilization or impairs compact entitlements. <br />By refusing to interpret SB 216 to "preclude an Applicant from determining precisely <br />the size and scope" of in-channel recreational uses, the Water Court rejected the role of the <br />CWCB to make a presumptively valid determination as to the minimum stream flow <br />necessary for a reasonable recreation experience. <br />The Appellee argues that "if the CWCB were permitted to calculate the `minimum <br />flow for a reasonable recreation experience,' it would necessarily usurp the role of the <br />appropriator, because there is no way to calculate the flow without reference to the recreation <br />experience sought by the appropriator." (Brief, p. 21). The CWCB agrees that the intent of <br />the appropriator is relevant to the type of recreational experience sought (i.e., kayaking or <br />rafting), but disagrees with the Appellee that the Legislature provided that the Appellee's <br />intent controls the amount of water that could be claimed (see Argument III above). <br />13
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