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Opening Brief
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Last modified
1/26/2010 4:41:42 PM
Creation date
7/29/2009 3:05:54 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
7/26/2004
Author
Ken Salazar, Susan Schneider
Title
Opening Brief
Water Supply Pro - Doc Type
Court Documents
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In SB 216, the Legislature imposed a clear physical limitation on recreational uses <br />separate and distinct from pre-SB 216 diversionary water rights by adding the term "minimum <br />stream flow." It would be unreasonable to interpret the language "minimum stream flow" as <br />having no meaning or effect beyond the pre-SB 216 limitations for diversionary water rights. <br />Colorado Motor Vehicle Dealer Bd. v. Brinker, 39 P.3d 1269, 1271 (Colo. App. 2001) (this <br />Court must give effect to each word and phrase used). If the Legislature had not intended for <br />this term to be given separate effect, it would not have added it. Id.; Leonard v. McMorris, 63 <br />P.3d 323 (Colo. 2003). <br />If the plain language of SB 216 is unclear, then this Court must determine the intent of <br />the Legislature. Colorado State Bd. of Medical Examiners v. Roberts, 42 P.3d 70, 72 (Colo. <br />App. 2001). Both the plain language and the legislative history of SB 216 clearly limit these <br />new recreational instream water rights to a minimum flow. <br />B. The Legislature intended to create "new water <br />rights" in SB 216 that were limited to a"minimum." <br />Until the Legislature authorized recreational instream flows in SB 216, there was no law <br />specifically authorizing such uses, and thus, there were no legislatively or court-imposed limits <br />on the size of recreational instream claims. The Legislature recognized that because "there <br />[were] no standards and procedures" for this "new kind of water right," it had to provide the <br />appropriate limitatians and procedures for claiming water for instream uses. (Exhibit G, Rep. <br />Jamison, p. 5; Rep. Young, p.7; Rep. Spradley, p.3; p.7). The Legislature also noted that without <br />some regulation, recreational instream flows could eviscerate the prior appropriation system by <br />allowing claims for entire stream reaches for boating by "putting some boulders in the water. ... <br />13
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