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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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Whitewater kayakers, the course is designed to also function well at a range of flows up <br />to 2000 c.f.s...." (p. 2). (DAWN PREHEATING stmt- TED we need trial quotes). <br />Under these circumstances, the CWCB's finding that 250 c.f.s. is the minimum <br />stream flow necessary for a reasonable recreation experience should be upheld. <br />b. The Legislature granted the CWCB the authority to determine what <br />constitutes maximum utilization in its rules and in this case. <br />The General Assembly authorized the CWCB to determine whether a proposed <br />RICD uses the "minimum stream flow" for a"reasonable recreation experience" that <br />promotes "maximum utilization," among other things. § 37-92-102(6)(a)(V). <br />The Applicant argues that "maximum utilization" involves improper <br />speculation,12 that the statute improperly refers to the conjunctive use of surface water <br />and ground water, that this term has no application here, or that it is encompassed within <br />pre-216 determinations of beneficial use or within the definition of compact impairment. <br />13 (CB, pp. 24-27). <br />The fact that "maximum utilization" refers to "conjunctive uses" when such uses <br />are rarely, if never, implicated in recreational in-channel uses, does not mean that this <br />Court should ignore that term or apply pre-216 definitions or roll it into other terms <br />within SB 216. Rather, this Court must determine the legislative intent. <br />In interpreting a statute, a reviewing court must determine and give effect to the <br />intent of the General Assembly. To determine that intent, this Court must give effect to <br />12 At the hearings on SB 216, it was repeatedly acknowledged that this "new water right" would <br />involve determinations as to potenrial future uses. (See, e.g. p. 3 DAWN APRIL 12) (april 18, pp. 28-29 <br />DAWN april 18, pp. 37-40 DAWN). <br />13 "Maximum utilization is not promoted by speculation, and the District's current need for a water right <br />should not be denied because speculative future projects might be impacted." (CB, p. 26). "There are no <br />issues in this case involving the conjunctive use of surface water and groundwater...." (CB, p. 24). "In <br />addition to being incorporated into the notion of beneficial use..." "the compact impairment factor is <br />12
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