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Answer to Applicant's Closing Brief: Case No. 02CW38
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Answer to Applicant's Closing Brief: Case No. 02CW38
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Last modified
1/26/2010 4:41:46 PM
Creation date
7/30/2009 12:09:57 PM
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Template:
Water Supply Protection
File Number
8230.2B3
Description
Pleadings
State
CO
Basin
Colorado Mainstem
Water Division
4
Date
1/1/3000
Author
District Court, Water Division 4
Title
Answer to Applicant's Closing Brief: Case No. 02CW38
Water Supply Pro - Doc Type
Court Documents
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decreeing the minimum amount was necessary to ensure that the flow of the entire stream <br />would not be completely tied up by a RICD. (Exhibit C, p. 3). <br />Senator Entz, sponsor, stated that the bill was introduced to give the CWCB "the <br />principle responsibility" to evaluate recreational water rights and to ensure that "the <br />amount of water being requested is reasonable and appropriate". (DAWN may 3, 2001 <br />p. 1, emphasis added). The Legislature wanted to prevent filings for "very large water <br />claims for in channel water diversion for recreational purposes" (Exhibit 2, p. 2), and to <br />prevent claims that "command the entire flow of the river and can be used by any entity <br />to control all outstanding water". The Legislature explicitly stated that it was not deciding <br />whether recreational in-channel uses could exist prior to the passage of SB 216, but <br />rather, was reconfirming that if recreational in-channel uses were permitted, they could <br />only be decreed for the minimum amount necessary to provide for a reasonable <br />recreational experience. (Rep. Lola Spradley, a sponsor of Senate Bi11216, at the House <br />Agriculture, Livestock and Natural Resources Committee Hearing on May 7, 2001, <br />attached hereto as Exhibit DAWN). <br />Additional testimony also supports the Applicant's citations showing that "the <br />ultimate policy question" was how much water should be granted that would allow future <br />upstream consumptive uses. (DAWN april 12, 2001, pp. 14, 23, 28-29, 38, april 18, <br />2001. pp. 22-23). Granting the CWCB the authority to determine the amount of water <br />was justified repeatedly because: the CWCB has ample experience with such processes <br />and the CWCB process could serve as a"very valid pattern" for these similar <br />appropriations (dawn april 18, p. 26)8; the CWCB has the experience and ability to <br />establish reasonable rules, to set standards and to determine whether, and to what extent, <br />10
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