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Answer Brief of Appellee Upper Gunnison River Water Conservancy District
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Answer Brief of Appellee Upper Gunnison River Water Conservancy District
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Last modified
1/26/2010 4:41:39 PM
Creation date
7/29/2009 1:49:58 PM
Metadata
Fields
Template:
Water Supply Protection
File Number
8230.2F
Description
Colorado Supreme Court Appeal
State
CO
Basin
Colorado Mainstem
Water Division
4
Date
9/30/2004
Author
Cynthia F. Covell
Title
Answer Brief of Appellee Upper Gunnison River Water Conservancy District
Water Supply Pro - Doc Type
Court Documents
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developers and others, the Upper Gunnison Board was experienced with water ri.ghts, and gave <br />careful consideration to the water rights it was being asked to claim for the whitewater park. (Vol. <br />IV, 85:25 - 86:19; 87:16 - 23; 146: 22-25; 148: 13-21). <br />Because the Board took such pains in crafting its application, Colorado's rernaining unused <br />Colorado River c;ompact entitlement can be fully developed notwithstanding the i-ecreational in- <br />channel diversion. (Vol III at 1107-1108.) The water rights claimed by Upper Gunnison are <br />nonconsumptive, and have no adverse impact on water users below the whitewater course. (Vol. V, <br />222:20 - 223:2). The vast majority of the Colorado River drainage is located below the whitewater <br />park. Both Uppi;r Gunnison's and CWCB's expert agreed that the only possible; impact of the <br />requested use woul , be- minor arnd would only impact junior upstream users. (Vol. VII, 60:23 - <br />63:21; 63:22 - 64:18; VoT: D(iEx. UG-13, admitted at Vol. V, 24:6-9; Vol. V, 16:6 -- 24:9; Vol. IX, <br />Ex. UG-198 at 1:.-14). Potential out-of-basin uses, such as transmountain diversion projects, are <br />only feasible during wet years, because the Aspinall Unit water rights "call out" the ,water available <br />to out-of-basin uses during dry and average years. In any event, the evidence showed. that no known <br />existing proposals, for any transbasin diversion project above the whitewater course; exist. Even if <br />F <br />some arise, the evidence showed that the RICD would not preclude them. <br />As a nonconsumptive water right, the recreational in-channel diversion will leave water in <br />the river for other users. The course employs reasonably efficient diversion struiatures, and the <br />optimum use of th.ose structures achieves the County's intended purpose of attxacting a wide variety <br />of users to the coizrse. The application was not based on speculation, but on carefiLl analysis, and <br />it will contribute i:o the regional economy, while protecting future upstream development. Indeed, <br />6
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