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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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claimed water for kayaking, rafting, canoeing and fishing purposes. The Applicant claimed <br />flows of up to 1500 cubic feet per second ("c.f.s.") as the minimum stream flow necessary for a <br />reasonable recreation experience. Specifically, the Applicant claimed the following flow rates, <br />in c.f.s.: <br />May <br />1-15 May <br />16-31 June <br />1-15 June <br />16-3 0 July 1- <br />15 July <br />16-31 Aug. <br />1-15 Aug. <br />16-31 Sept. <br />1-15 Sept. <br />16-3 0 <br />570 1190 1460 1500 1100 530 460 390 300 270 <br />The entire quantity claimed would amount to approximately 157,000 acre feet ("AF") of water <br />per year. (Findings of Fact, Conclusions of Law and Order, ("Order"), p. 5, attached hereto as <br />Exhibit A). <br />Pursuant to SB 216's procedural requirements, the Applicant presented its application to <br />the CWCB for review. § 37-92-103(10.3) & 37-92-102(5), C.R.S. (2003)). At the hearing <br />before the CWCB, the Applicant's chief expert witness and the course designer, Gary Lacy, <br />conceded that 250 c.f.s. would attract many boaters, including many experienced kayakers. (Mr. <br />Lacy's Letter, p. 1, dated June 21, 2002 (attached to State's Exhibit 5, v. 1) and Mr. Lacy's <br />Letter, p. 2, dated August 26, 2002 (attached to State's Exhibit 7, v. 1), both pages attached <br />hereto as Exhibit B; Exhibit A, p. 5; v. VII, pp. 221-222; v. V, pp. 177, 190). The evidence <br />further established that claims of 157,000 AF would have a negative effect on upstream <br />development; would prevent users upstream from benefiting from the 40,000 AF subordination <br />agreement involving water from the Aspinall Unit; and would prevent inbasin and transbasin <br />users from fully benefiting from the approximately 240,000 AF available for contract. (v. 1, <br />State's Exhibit 8). <br />2
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