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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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Third, at the hearing on the RICD, the Applicant's own evidence showed that an <br />RICD of 250 c.f.s. promotes maximum utilization and optimum use here, because that <br />amount of water will provide for a"reasonable recreation experience" and will allow <br />adequate opportunities for future upstream development. In seeking amounts greater than <br />250 c.f.s. in its RICD application, the Applicant failed to choose an amount that would <br />promote maximum utilization because the higher amounts chosen would have admittedly <br />impacted maximum utilization. The Applicant "compromised" by requesting high flow <br />amounts (1200 c.f.s.) in an effort to balance the desires of the recreationists (who wanted <br />the higher flows) with the desires of the interests in future development (who wanted the <br />lower flows). (Greg Peterson, the Chair of the Upper Gunnison River Water <br />Conservation District, Exhibit F, Transcript, p. 56). The result was flow amounts that <br />would create "impact" to fuiure upstream use (the flows were "up a little bit higher as far <br />as impact" -- there would be "some sort of impact" @d., p. 54)). <br />Finally, the evidence at trial will show that 250 c.f.s. promotes maximum <br />utilization here because that amount of water will provide a"reasonable recreation <br />experience" for many boaters, including experienced kayakers, (Exhibit F, Transcript, p. <br />38) and will also allow adequate opportunities for future upstream development. The <br />Applicant's engineering expert has testified that the proposed RICD 'unpairs junior <br />upstream development potential in certain years. (Deposition transcript, Expert Jim <br />Slattery, Exhibit H, pp. 38, 70, 79). <br />Because SB 216, case law, and the Applicant's own evidence sufficiently show <br />that 250 c.f.s. promotes maximum utilization by allowing reasonable recreation <br />12
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