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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
Fields
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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And I do think that it's consistent with the test that other water users have to <br />comply with because any water user, be it agricultural, municipal or industrial, is <br />governed by the test of efficiency where it's not all the water they can physically <br />get a hold of, but it's all the water that they can reasonably and efficiently use. <br />And that really becomes the test of what those water rights can appropriate. And I <br />think by this definition, we have placed this water right in the same light that the <br />other water right classifications are. <br />Transcript of May 7, 2001 Hearing at p. 6(Attached as Appendix to the Brief of State Amici) <br />(emphasis added). <br />The water court applied the beneficial use standard to the claim at issue, and held "the <br />Court is persuaded and finds that the amount sought in this instance does not reach the level of <br />speculation or waste. The Court again notes that there is no finding by the CWCB that would <br />suggest that there is." Decision at 20. <br />Second, contrary to the fears expressed by the State and its Amici, the plain language of <br />SB 216 imposes restraints on RICD rights that prevent the dangers these parties purport to be <br />concerned with. Most notably, a RICD cannot materially impact Colorado's compact <br />entitlements. In this regard, the water court applied each of the factors identified in § 37-92- <br />102(b)(6) in rendering its decision. Decision at 20-22. Moreover, there is the further limit that <br />RICD water rights can only be claimed by local governmental and quasi-governmental entities, <br />thus ensuring local input and accountability. <br />Finally, contrary to the primary argument advanced by the State Amici, the water court in <br />this case did not hold that the General Assembly is restricted from imposing additional limits on <br />RICD claims. Rather, the Court examined the plain language of SB 216 and the limits set forth <br />therein against the well-developed body of law that generally applies to appropriation of water <br />under Colorado's Constitution. On the basis of that analysis, the water court concluded that the <br />Tm1650 12
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