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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
Metadata
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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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these water rights would limit future uses (april 18, pp. 28-29 DAWN)9; the CWCB <br />consists of inembers with vast knowledge of water issues, who must be confirmed by the <br />Senate (april 18, p. 30 DAWN)10; and the CWCB has experience with instream uses, <br />experience in looking at future concerns and because members are from each drainage, it <br />is inherently objective and balanced in nature (april 18, pp. 37-40 DAWN)11 <br />Thus, the legislative history and the plain language of the statute show that the <br />CWCB must make findings that include determinations of the amount of water that <br />should be granted. <br />V. THE EVIDENCE AT BOTH THE CWCB HEARING AND AT TRIAL <br />SHOWS THAT 250 C.F.S. WAS THE MINIMUM STREAM FLOW <br />NECESSARY FOR A REASONABLE RECREATION EXPERIENCE <br />THAT PROMOTED MAXIMUM UTILIZATION AND DID NOT IMPAIR <br />COMPACTS IS NOT IN ERROR. BECAUSE THESE FINDINGS ARE <br />NOT IN ERROR, THEY SHOULD BE UPHELD. <br />a. 250 c.f.s. is the minimum stream flow necessary for a reasonable <br />recreation experience. <br />Notably, the Applicant has argued that the CWCB cannot make findings or <br />recommendations to this Court as to the amount of water that should be granted, but has <br />failed to argue or present any evidence that the amount requested was, in fact, the <br />"minimum stream flow" necessary for a reasonable recreation experience. At the CWCB <br />hearing and at trial, the Applicant's expert, Gary Lacy, who designed and oversaw <br />construction of the Gunnison course, admitted repeatedly that: "The Whitewater Park will <br />attract many boaters at 250 c.f.s. and above" and was "sufficient to attract experienced <br />8 Mike Shimmin, the attorney representing Fort Collins in Fort Collins, 830 P.2d 920. <br />9Ha1 Simpson, State Engineer. <br />10Steve Sims, First Assistant Attorney General. <br />"Patti Wells, former CWCB member and General Counsel for the Denver Water Board. <br />11
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