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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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rate of the proposed RICD" becaine a factor in determining whether maximum utilization is <br />promoted. 2 CCR 408-3, Rule 7(e)(vii). The CWCB rules and determinations on <br />"maximum utilization" are entitled to deference. Urbish v. Lamm, 761 P.2d 756 <br />(Colo.1988). <br />This Court should hold that the Legislature authorized the CWCB to make a <br />presumptively valid determination as to the minimum stream flow necessary for a reasonable <br />recreation experience that also promotes maximum utilization and does not impair compact <br />entitlements. <br />C. The CWCB's Findings and Recommendations were <br />supported by the evidence. <br />The Water Court should have upheld the CWCB Findings and Recommendations <br />because they were not proven wrong by a preponderance of the evidence. The Appellee <br />argues that the standard of reviewing the CWCB Findings and Recommendations is a <br />preponderance of the evidence, rather than clear and convincing evidence. (v. VI, p. 87). <br />Under either standard, unless the CWCB Findings and Recommendations are proven wrong <br />by a preponderance of the evidence, they must be upheld. Because the record supports those <br />Findings and Recommendations, the Water Court erred in not upholding them. <br />All reasonable doubts as to the correctness of the CWCB determinations must be <br />resolved in favor of the agency. Bird v. Citv of Colorado Sprin s, 489 P.2d 324, 325-26 <br />(Colo. 1971). A party challenging a presumptively valid finding bears the burden of <br />overcoming that presumption, and courts "indulge every intendment in favor of its validity." <br />16
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