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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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effectuating his diversion. He is not entitled to command the whole or a substantial flow <br />of the stream merely to facilitate his taking the fraction of the whole flow to which he is <br />entitled." Colorado Springs v. Bender, 148 Colo. 458, 366 P.2d 552, citing Schodde v. <br />Twin Falls Land & Water Co., 224 U.S. 107 (1912); A-B Cattle Co. v. U.S., 589 P.Zd 57, <br />61 (Colo. 1978)(maximum utilization demands efficient use of water). "[T]he objective <br />of `maximum use' administration is `optimum use. "' Matter of Rules Governing Water <br />in Rio Grande and Conejos River Basins, 674 P.2d 914, 935 (Colo. 1983). <br />Third, no party disputes that at 250 c.f.s, maximum utilization is, in fact, <br />promoted. Further, at the hearing on the RICD and at trial, the Applicant's own evidence <br />showed that 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. <br />TED - I stopped here, but check out the law/basic set up on the other arguments <br />below FILL IN FACTS ETC <br />The Applicant "compromised" by requesting high flow amounts (1200 c.f.s.) in <br />an effort to balance the desires of the recreationists (who wanted the higher flows) with <br />the desires of the interests in future development (who wanted the lower flows). (Greg <br />Peterson, the Chair of the Upper Gunnison River Water Conservation District, Exhibit F, <br />Transcript, p. 56). The result was flow amounts that would create "impact" to future <br />upstream use (the flows were "up a little bit higher as far as impact" -- there would be <br />"some sort of impact" (id., p. 54)). <br />, ,y <br />Finally, the evidence at trial vA show that 250 c.f.s. promotes maximum <br />utilization here because that amount of water will provide a"reasonable recreation <br />15
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