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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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SB 216 supports a finding that 250 c.£s is the appropriate amount of water to allow <br />Colorado to develop its compact entitlements. The intent of SB 216 was to ensure that RICDs <br />"are integrated into the state's prior appropriation system in a manner which appropriately <br />balances the need for water-based recreational opportunities with the ability of Colorado citizens <br />to divert and store water under compact entitlements for more traditional consumptive use <br />purposes such as municipal, industrial and agricultural uses." (Exhibit 3, p.l). Co-Sponsor <br />Spradley stated that: "It makes sense that attention be given to the impact of these recreational <br />uses have on our state's future abilities to develop[] and use water resources." (Exhibit G, p. 3). <br />It is clear that exchange opportunities would be adversely impacted if flows of 1500 c.f.s. <br />are granted. "Impair" means to "weaken, to make worse" in Black's Law Dictionary 677 (5"' Ed. <br />1979). The CWCB's rules indicate that one factor for determining "impairment" is whether <br />exchange opportunities may be "adversely impacted." 2 CCR 408-3, Rule 7(a)(v). <br />The testimony at the CWCB hearing and at trial supports the finding that 250 c.f.s would <br />allow Colorado to develop its compact entitlements, but that 1500 c.f.s. would impair compact <br />development. The Applicant admitted that there will be adverse impact on development of <br />compact entitlements if the entire claim were granted, (v. V, pp. 44, 48-49), and that the RICD <br />would affect much of the basin above it. (v. IV, pp. 62-62, 65, 117, 119). <br />There is approximately 450,000 AF of water available for Colorado to develop under the <br />Colorado River Compacts and the "law of the river." (v. VI, p. 207). The proposed RICD would <br />impair Colorado's ability to develop a portion of that entitlement upstream of the RICD. (v. VI, <br />pp. 55-56; v. V, pp. 44, 48-49). Further, the proposed RICD would impair Colorado's ability to <br />use water under the 60,000 AF subordination or out of the "marketable pool" in the Aspinall <br />26
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