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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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should be construed as written." Citv of Aurora v. Bd. of Countv Comm'rs, 919 P.2d 198, 200 <br />(Colo. 1996) citing Colo State Bd. of Med. Examiners v. Saddoris, 825 P.2d 39, 42 <br />(Colo. 1992). If the statute is unambiguous and does not conflict with other statutory provisions, <br />this Court does not need to look any further. People v. Luther, 58 P.3d 1013, 1015 (Colo. 2002). <br />Only when the statute is unclear should the court look to "legislative history, prior law, the <br />consequences of a given construction and the goal of the statutory scheme." Id: S.B. 216 is <br />unambiguous and does not require this Court to look at the legislative history in order to <br />understand its meaning. <br />Basically, S.B. 216 makes three changes to the 1969 Water Rights Administration Act. <br />First, it amends the definition of beneficial use to include RICDs and limits those who may <br />appropriate water for a RICD to local governments. C.R.S. § 37-92-103(4), (7) and (10.3). <br />Second, the Act creates an advisory role for the CWCB by requiring the CWCB to make findings <br />of fact and recommendations to the water court on an RICD application. C.R.S. § 37-92-102(6). <br />Third, it establishes criteria that both the CWCB and the water court must apply to evaluate an <br />RICD. C.R.S. § 37-92-102(6)(b). The CWCB findings of fact on these criteria are <br />presumptively valid. C.R.S. § 37-92-305(13). With these exceptions, the process to obtain a <br />decree for* an RICD is the same as any other water rights application. <br />The CWCB relies heavily on quotes from particular legislators to explai.n legislative <br />intent. This is not appropriate. First, as explained above, S.B. 216 is not ambiguous, and <br />therefore, the Court does not need to look at legislative history. Second, the legislative history is <br />inconsistent. For example, the CWCB quotes Senator Perlmutter stating, "a rebuttable <br />presumption is stronger than an advisory suggestion." (CWCB's Opening Brief at 20). Yet, the <br />13
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