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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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does not reach the level of speculation or waste. The CWCB again notes that there is no finding <br />by the CWCB that would suggest that there is." Concerning the Application for Water Rights of <br />Upuer Gunnison River Water Conservancy District in Gunnison Countv. Findinps of Fact, <br />Conclusions of Law and Order, p. 20 (December 26, 2003). <br />3. S B 216 only,Sives the CWCB an advisorv role in water court uroceedings bv <br />g,iving it the opportunity to present findings that are Uresumntive, subiect to <br />rebuttal. <br />The CWCB contends that the CWCB Findings and Recommendations must be upheld by <br />this Court unless the applicant provides "at least clear and convincing evidence that they are in <br />error." This is an incorrect statement of the Iaw for two reasons. First, only the factual findings <br />are to be treated by the water court as presumptively valid and subject to rebuttal. Second, these <br />presumptive facts may be rebutted by a preponderance of evidence rather than the "clear and <br />convincing" standard argued by the CWCB. <br />The statute sets forth six findings that the CWCB must make and requires these findings <br />to be reported to the water court. C.R.S. § 37-92-102(6)(b)(I-VI). The CWCB may defend such <br />findings through participation in the water court proceedings. C.R.S. § 37-92-102(6)(c). "All <br />findings of fact contained in the recommendation of the Coiorado Water Conservation Board <br />shall be presumptive as to such facts, subject to rebuttal by any party." § 37-92-305(13). Thus, <br />the CWCB factual findings (not the recommendation) must be treated by the water court as <br />presumptively valid. In contrast, the water court is directed to "consider" the CWCB's <br />recommendation. C.R.S. § 37-92-305(16). <br />When the Water Rights Administration Act of 1969 was amended by S.B. 216, the <br />legislature did not indicate the standard that must be met to rebut the CWCB findings. In the <br />19
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