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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
Fields
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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If Applicant's intent were the measure of the water right, then the legislative <br />intent, and the CWCB's role as fact finder, would be eviscerated. Further, if Applicant's <br />intent were the measure of the right, then the underlying basis would be the intent to <br />"protect Upper Gunison water resources from out-of-basin diversion," which was <br />Applicant's stated motive. Exhibit 41, 10-8. The State has never argued that transbasin <br />diversions should occur, it has only argued that the potential should not be completely <br />foreclosed because of one water user's subjective desires. In this case, the Applicant <br />openly expressed a true, but prejudicial, motive. Next time, subjective motives may not <br />be revealed. This demonstrates the perils of relying on subjective motives as opposed to <br />more objective determinations made by an agency composed of inembers from every <br />major river basin. <br />While the Applicant still must satisfy the additional requirements of beneficial <br />use, "can and will," diversion, intent and overt acts, the limitations and standards of SB <br />216 must also be satisfied. (CB, pp. 32-38). The use of the pre-216 term "without <br />limiting the generality of the foregoing" means that the requirements of reasonable and <br />appropriate uses and reasonably efficient practices are not limited. It does not mean that <br />there can be no additional requirements or standards to meet. <br />III. THE PLAIN LANGUAGE OF SB 216 SHOWS THAT THE CWCB IS <br />AUTHORIZED TO DETERMINE WHETHER TAE APPLICANT SEEKS <br />THE MINIMUM STREAM FLOW NECESSARY FOR A REASONABLE <br />RECREATION EXPERIENCE. <br />The Applicant also argues that while SB 2161imited who could file for such <br />rights, "the legislature did not go so far as to limit in any significantly new way the <br />amount of water that could be appropriated" and "the legislative history shows that no <br />7
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