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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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flow ... for a reasonable recreation experience;" (2) promotes maximum utilization; and (3) <br />and does not impair compact entitlements. <br />Further, if the statutory mandate is unclear, the legislative history clearly shows that <br />the Legislature specifically gave the CWCB the responsibility to evaluate recreational water <br />rights and to ensure that "the amount of water being requested is reasonable and appropriate. <br />..." (Exhibit L, May 3, 2001 Sen. Entz, p. l; see also Exhibit H, April 12, 2001, pp. 28-29, <br />38; Exhibit K, April 18, 2001, pp. 22-23). The Legislature's grant of authority to the CWCB <br />to determine whether the amount of water claimed was the "minimum" was justified <br />repeatedly because the CWCB has broad experience with in-channel uses that could serve as <br />a"very valid pattern" for these similar appropriations and has the experience and ability to <br />establish reasonable rules, to set standards and to determine whether, and to what extent, <br />such in-channel rights could limit future uses. (Exhibit K, pp. 26, 28-9, 37-40). Because <br />members are from each drainage, the CWCB is more objective and balanced in nature with <br />regard to state matters than local entities. <br />Finally, under the CWCB rules, the determination of flow amounts is a factor that <br />must be considered in reviewing the applications. 2 CCR 408-3, Rule 7(e)(vii). The <br />Legislature authorized the CWCB to "establish further criteria governing such diversion, <br />such as additional guidance upon the appropriate time of day, season of use, length of reach <br />and minimum utilization demands, in order that additional objective benchmarks for judging <br />the propriety of such appropriations are established." (Exhibit J, p.l). As contemplated by <br />section 37-92-102(6)(b)(VI), the CWCB conducted appropriate rulemaking so that the "flow <br />15
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