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Amici Curiae Brief of Northwest Colorado Council of Governments, Town of Minturn, Grand County, Gunnison County, Pitkin County
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Amici Curiae Brief of Northwest Colorado Council of Governments, Town of Minturn, Grand County, Gunnison County, Pitkin County
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Last modified
1/26/2010 4:41:41 PM
Creation date
7/29/2009 2:36:11 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
Barbara Green, Anne Castle, John M. Ely, David Baumgarten
Title
Amici Curiae Brief of Northwest Colorado Council of Governments, Town of Minturn, Grand County, Gunnison County, Pitkin County
Water Supply Pro - Doc Type
Court Documents
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C.R.S. § 37-92-103(10.3). The legislature did not, however, describe or limit what might be a <br />"reasonable recre,3tion experience." What may be reasona.ble is based on the type of recreational <br />activity intended 'by the appropriator. As is the case with any water right, the a;mount of water <br />required for the F:ICD, and how and when it will be used turn on the purpose of the <br />appropriation. Se:e e.g., Santa Fe Ranches, 990 P.2d at 56 (degree of use historically made of <br />manufacturing ri€;hts turns on the requirements of the particular enterprise.) 'T'}ie decision <br />whether to constcuct a world-class kayak course, an inner tube float feature or roddlers' wading <br />pool has been left to the discretion of the governmental entity constructing the RICD structures <br />as it responds to the requirements, values and financial resources of the public. The type and <br />degree of a"reasDnable recreational experience" for a toddler differs enormou;dy from tha.t <br />which would be reasonable for a world-class kayaker. <br />The defir.ation of a reasonable recreation experience adopted in the CVUCB Rules <br />underscores that what may be reasonable depends completely upon the type oiE rerreational <br />experience inten3ed by the appropriator: <br />Reasonable Recreation Experience. Means an experience in and on tYie water that <br />would a11ow individuals with suitable skills and abilities relating to the specific <br />recreatio:nal activity for which the water right is being sought to partake in that <br />activity. 2 CCR 408-3, Rule 4(0). <br />Thus, the concept o£"reasonable" is deternuned by the nature of the specific i-ecreational activity <br />intended by the local government. In the proceedings below, there was amplf; evndence of the <br />intended recreation experience sought, the design parameters of the Upper Gunnison River <br />Water Conservancy District's whitewater pazk, and the water flows required to cr.eate the <br />recreational experience sought. Accordingly, Judge Patrick properly refused to second-guess the <br />Ievel of recreatic)nal experience intended by the applicant. Since Judge Patric;k found that the <br />10
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