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Answer Brief of Amici Curiae
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Answer Brief of Amici Curiae
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Last modified
1/26/2010 4:41:40 PM
Creation date
7/29/2009 1:56:16 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
9/29/2004
Author
Glenn E. Porzak, Anne J. Castle
Water Supply Pro - Doc Type
Court Documents
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water court decision, as well as the limits on beneficial use, waste and speculation that apply to <br />every water right, including RICDs. The State's argument also fails to acknowledge that the <br />water court did apply the additional limitations on RICDs that exist in the plain language of SB <br />216. <br />First, RICDs are subjected to the same beneficial use limits as all other water rights for <br />every purpose. As mentioned, the definition of "beneficial use" at C.R.S. § 37-92-103(4) <br />expressly includes RICDs, and states in relevant part: <br />"Beneficial use" is the use of that amount of water that is reasonable and <br />appropriate under reasonably efficient practices to accomplish without waste the <br />purpose for which the appropriation is lawfully made and, without limiting the <br />generality of the foregoing, includes ... recreational in-channel diversion <br />purposes. <br />This definition evidences the legislature's understanding that "beneficial use" and the <br />concept of reasonable and efficient use that phrase incorporates would be the limit on the amount <br />of water appropriated by an RICD. That approach is consistent with the case law in Colorado <br />which explains, "under prior appropriation ... beneficial use is the measure, scope, and limit of <br />the water right." Colorado Ground Water Comm. v. North Kiowa-Bijou Groundwater <br />Management Dist., 77 P.3d 62, 72 n. 17 (Colo. 2003) (citing Santa Fe Trail Ranches Properry <br />Owners Ass'n. v. Simpson, 990 P.2d 46, 53-54 (Colo. 1999)). <br />The Court should note the remarks of CWCB Director Rod Kuharich at the legislative <br />hearing on SB 216 on May 7, 2001, where he specifically noted that this traditional water law <br />concept would be the limit on RICD claims: <br />... But I think if you look at the definition, it's an attempt to fit this water right <br />into the process we have now. It talks about minimum amount of water necessary <br />to accomplish a reasonable recreational experience. I think [unintelligible] . <br />Reasonable and recreational and are two words that are used in there. <br />Tm1650 11
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