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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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natural environment to a reasonable degree. The Legislattiire gave the CWCB this authority <br />because of its experience with instream/in-channel uses. <br />The Appellee states that it is "ridiculous" to argue that there is a similarity between <br />in-channel recreational water rights and instream flow water rights. (Brief, p. 20). However, <br />the plain language of both SB 97 and SB 216 shows the similarities between the legislation <br />authorizing CWCB instream flow water rights and recreational in-channel water rights. Both <br />are used within the stream. Both are limited to the "minimum stream flow" and the CWCB <br />(as acknowledged by the Appellee) plays a role in reviewing each that does not exist for <br />other water rights. Finally, both are non-consumptive as to downstream users. <br />Section 37-92-102(3) states the CWCB "is hereby vested with the exclusive authority, <br />on behalf of the people of the state of Colorado, to appropriate in a manner consistent with <br />sec-tions 5 and 6 or article XVI of the state constitution, suck waters of natural streams and <br />lakes as the board determines may be required for minimum stream flows or for natural <br />surface water levels or volumes for natural lakes to preserve the natural environment to a <br />reasonable degree." Senate Bill 73-97 ("SB 97") "creat[ed] a right to appropriate" water for <br />uses instream, and "limited" those appropriations to "a particular amount of water, i.e., the <br />minimum amount necessary...." Aspen Wilderness Warkshop, Inc. v. Colorado Water <br />Conservation Bd., 901 P.2d 1251, 1260 (Colo. 1995) (emphasis added). Similarly, SB 216 <br />created a"change in water law" that was limited to a particular amount of water, i.e., the <br />minimum amount necessary. (See Exhibit G, p. 2; Exhibit J, p. 1). <br />19
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