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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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Rep. Plant, p. 2; Exhibit J, Rep. Spradley, p. 1). The plain language of both SB 97 and SB 216 <br />shows that the legislative grant of authority to the CWCB to determine the "minimum" stream <br />flow necessary to preserve the environment to a"reasonable" degree is too similar to be <br />coincidental to the legislative grant of authority to the CWCB to determine the "minimum" <br />stream flow necessary for a"reasonable recreation experience." <br />In CWCB, the Legislature properly delegated "the power to determine some fact or state <br />of things to effectuate the purpose of the law," even though the Legislature did not define the <br />phrase "`such minimum flows ... as required to preserve the natural environment to a <br />reasonable degree."' CWCB, at 576 (no emphasis added). Similarly, here, the Legislature also <br />properly delegated the power to determine some fact or state of things to effectuate the purpose <br />of the law, even though the Legislature did not define the phrase such minimum flows for a <br />reasonable recreation experience. <br />With both SB 97 and SB 216, the Legislature properly imposed physical limitations on <br />instream uses separate and distinct from traditional diversionary water rights and properly gave <br />oversight for such claims to the CWCB. <br />B. The legislative history shows that the Legislature <br />granted the CWCB the authority to determine <br />whether the RICD is for the minimum stream flow <br />necessary for a reasonable recreation experience. <br />If the plain language is not clear, the legislative history of SB 216 shows that the <br />"ultimate policy question" was how much water should be granted for recreational instream uses. <br />(Exhibit H, April 12, 2001, pp. 28-29, 38; Exhibit K, April 18, 2001, pp. 22-23). Thus, the <br />Legislature specifically gave the CWCB the responsibility to evaluate recreational water rights <br />17
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