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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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a. The water court recognized that the RICD is a beneficial use and that the <br />amount of the RICD must be established accordingly. <br />An RICD is a beneficial use and by definition, a use is not beneficial unless it is <br />accomplished without waste. "Beneficial use is the use of that amount of water that is <br />reasonable and appropriate under reasonably efficient practices to accomplish without waste the <br />purpose for which the appropriation is lawfully made ...." C.R.S. § 37-92-103(4). The <br />prohibition against waste requires that an appropriator take no more water than is necessary. In <br />other words, auy beneficial use is limited to the minimum amount of water necessary to <br />accomplish the purpose of the appropriation.s The use of the term "minimum stream flow" in the <br />definition of RICD, which is a subset of the definition of beneficial use, reaffirms that this <br />prohibition against waste applies even though the appropriation is for in-channel diversion. <br />C.R.S. § 37-92-103 (103). <br />In the case of an RICD, the purpose of the appropriation is a reasonable recreation <br />experience. A reasonable recreation experience is defined in the CWCB Rules as "an experience <br />in and on the water that would a11ow individuals with suitable skills and abilities relating to the <br />specific recreational activity for which the water right is being sought to partake in that activity." <br />(Rule 4(0)). Therefore, the RICD must be for no more than the amount necessary for the specific <br />recreational activity for which the appropriation is sought. In this case, the Upper Gunnison <br />District sought to provide opportunities for recreational boating for a variety of skill levels and <br />watercraft. These recreational opportunities were for the benefit of the local community, the <br />tourist base, and the Outdoor Recreation prograzn at Western State College, from May to <br />5 As recognized by Rod Kuharich in his testimony to the legislature, maximum utilization <br />requires the minimum amount of water necessary to accomplish the purpose for which <br />appropriation is made. The definition of RICD includes this concept. <br />15
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