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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
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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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P.2d 798, 800 (Colo. 1965). Similarly, this Court squarely rejectede the claim that Article <br />XVI, section 5, of the Colorado Constitution establishes "the public right to recreational use <br />of all waters in the state," and recognized that such uses should "be accommodated [by] the <br />legislative process." People v. Emmert, 597 P.2d 1025, 1028-29 (Colo. 1979). <br />Several amici argue that Article XVI, section 6, provides protection for recreational <br />uses. (Amici Brief of Steamboat Springs, et al., p. 2). That argument is wrong. In fact, the <br />Legislature questioned whether the diversion requirement in Article XVI, section 6 of the <br />Colorado Constitution prohibited instream or in-channel uses.' Further, in upholding CWCB <br />instream flows as an exception to the diversion requirement,8 this Court held that "[t]he <br />crucial consideration is that this court has never decided a case such as this on a <br />constitutional basis." CWCB, 594 P.2d at 574. <br />Finally, several amici rely heavily on City of Thornton v. City of Fort Collins, 830 <br />P.2d 915 (Colo. 1992), rather than address the plain language of SB 216. In that case, <br />however, this Court: (1) neither sanctioned claims of any "size and scope" nor recognized a <br />constitutional right to recreational instream uses; (2) granted only "low flows" (30 c.f.s. as <br />6Several briefs posit that Emmert is irrelevant because it deals with criminal trespass. However, <br />this Court has recently recogn.ized that Emmert stood for the proposition that Article XVI, <br />section 5, of the Constitution "was primarily intended to preserve the historical appropriation <br />system of water rights upon which the irrigation economy in Colorado was founded." Board of <br />Countv Com'rs of Countv of Park v. Park Countv Sportsmen's Ranch, LLP, 45 P.3d 693, 710 <br />(Colo. 2002). <br />7 The legislative interrogatories to this Court are found in Exhibit E is attached only to the <br />Opening Brief - as are all exhibits cited except Exhibit 19d1, Exhibit 1, and Exhibit J, which are <br />attached hereto). <br />BThis Court emphasized that it was "not hereby causing any erosion" of the diversion requirement. <br />CWCB, 594 P.2d at 570. <br />4
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