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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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new limits on `amount' were intended". (CB, pp. 15, 9). The plain language of SB 216 <br />and the legislative history show that the opposite is true. SB 216 imposes firm limits on <br />the amount of water that could be claimed by allowing only the "minimum stream flow" <br />necessary for a"reasonable recreation experience". The Applicant's characterizations of <br />SB 216 are simply wrong. <br />The Legislature imposed similar physical limitations on the only two instream <br />uses allowed in the state. Because neither water right requires diversion, and thus, there <br />would be no inherent physical limitation on the amount of water claimed, the only two <br />recognized instream use water rights in this State had to be limited by statute. The <br />CWCB's instream flow water rights are limited to the "minimum stream flow" necessary <br />to preserve the environment to a reasonable degree while recreational in-channel water <br />rights are limited to the "minimum stream flow" for a"reasonable recreation experience". <br />§§ 37-92-102(3), C.R.S. (2003) & 37-92-103(10.3). The Applicant would have this <br />Court ignore this material limitation in SB 216. <br />In SB 216, the Legislature provided an explicit physical limitation on the amount <br />of water that could be appropriated and granted the CWCB the authority to determine that <br />amount in order to prevent abuses and ensure fair and measured instream uses. The plain <br />language of SB 216 (and the legislative intent) shows that Legislature expressly granted <br />the CWCB the specific authority to determine whether the water right sought is the <br />"minimum stream flow ... for a reasonable recreation experience" to promote maximum <br />utilization and prevent compact impairment. When the Legislature defines a term in <br />statute, such as "recreational in-channel diversion" in section 37-92-103(10.3), that <br />definition governs whenever it appears in the statute (i.e., in section 37-92- <br />8
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