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Trial Brief Case No. 02CW38
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Trial Brief Case No. 02CW38
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Last modified
1/26/2010 4:41:45 PM
Creation date
7/30/2009 12:05:22 PM
Metadata
Fields
Template:
Water Supply Protection
File Number
8230.2B3
Description
Pleadings
State
CO
Basin
Colorado Mainstem
Water Division
4
Date
9/5/2003
Author
Ken Salazar, Susan J. Schneider
Title
Trial Brief Case No. 02CW38
Water Supply Pro - Doc Type
Court Documents
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Because the finding that 250 c.f.s. is the "minimum stream flow" necessary to <br />provide a"reasonable recreation experience in and on the water" is supported by the <br />satisfactory evidence and supports the purposes of SB 216, this Court must uphold the <br />presumptive validity of that CWCB determination. <br />III. THIS COURT SHOULD NOT OVERTURN THE PRESi7MPTIVELY <br />VALID FINDING THAT LIMITING THE RICD TO 250 C.F.S. WOULD <br />PROMOTE MAXIMUM UTILIZATION OF COLORADO'S WATERS. <br />This Court should not overturn the presumptively valid finding that limiting the <br />RICD to 250 c.f.s. promotes maximum utiliza.tion of Colorado's waters under section 37- <br />92-102(6)(a)(V) because this fmding is supported by satisfactory evidence and, thus, is <br />clearly not "in error beyond a reasonable doubt." Because any questions as to the <br />correctness of that finding must be resolved in favor of the CWCB, this Court must <br />uphold the CWCB's fmding as valid. <br />The CWCB's finding that a RICD of 250 c.f.s. promotes maximum utilization of <br />Colorado's waters supports the purposes of SB 216 and is supported by the case law and <br />the Applicant's own evidence. First, SB 216 supports a finding that the RICD promotes <br />maximum utilization at 250 c.f.s. because the intent of SB 216 was to ensure maximum <br />utilization by allowing only minimal and reasonable appropriations of water to ensure <br />that the state could develop and use its water in the future. § 37-92-103(10.3). Co- <br />Sponsor Spradley stated that: "It makes sense that attention be given to the impact of <br />these recreational uses have on our state's future abilities to develop and use water <br />resources." ( Exhibit C, p. 3). Additionally, the Senate heard testimony that because the <br />diversion requirement created inherent physical and monetary limitations on the amount <br />of water that could be claimed and there were no such limita.tions here for instream uses, <br />10
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