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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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102(6)(b)(I)&(IV)&(V)&(VI) ', C.R.S. (2003)). Farmers Ins. Exchange v. Bill Bloom, <br />Inc., 961 P.2d 465, 470 (Colo. 1998); R.E.N. v. Citv of Colo. Springs, 823 P.2d 1359 <br />(Colo. 1992). The introduction to section 37-92-103 also requires that the definition of <br />"recreational in-channel diversion" must apply whenever the term is used in article 37. <br />Thus, by statute, as well as case law, the CWCB has the clear mandate to <br />determine whether the Applicant sought the minimum stream flow. <br />IV. THE LEGISLATIVE HISTORY OF SB 216 ALSO SHOWS THAT THE <br />LEGISLATURE INTENDED THAT THE CWCB HAVE THE <br />AUTHORITY TO DETERMINE WHETHER THE APPLICATION SEEKS <br />THE MINIMUM STREAM FLOW NECESSARY FOR A REASONABLE <br />RECREATION EXPERIENCE. <br />The Applicant concedes that preventing excessive claims and compact <br />impairment were "prominent issues" in enacting SB 216, and provides appropriate <br />citations to the legislative history for support. (CB, pp. 3-6). In fact, the amount of water <br />was the key issue, which is why the Legislature defined "`recreational in-channel <br />diversion' such that only the `minimum' flow necessary to support the recreational <br />activity can be sought." (SB 216 Legislative Statement, p. 1 DAWN). <br />Representative Spradley stated ("for legislative history purposes") that under SB <br />216, the "minimum" flow "would mean that the applicant could potentially obtain a right <br />to the minimum amount of water necessary to float a kayak," and further explained that <br />7 Specifically, the Legislature granted the CWCB the authority to determine whether: <br />a. "the adjudication and administration of the [`minimum stream flow ... for a reasonable recreation <br />experience'] would impair the ability of Colorado to fully develop and place to consumptive beneficial <br />use its compact entitlements"; <br />b. "exercise of the [`minimum stream flow'] would cause material injury to instream flow water rights"; <br />c. "adjudication and administration of the [`minimum stream flow'] would promote maximum utilization <br />of the waters of the state..."; and <br />d. "[s]uch other factors as may be deternuned appropriate for evaluation of [`minimum stream flow'] and <br />set forth in rules...." §§ 37-92-102(6)(b)(I)-(VI) read in conjunction with 37-92-103(10.3). <br />9
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