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Rebuttal Statement of Trout Unlimited
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Rebuttal Statement of Trout Unlimited
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Last modified
1/26/2010 4:42:03 PM
Creation date
8/10/2009 1:43:15 PM
Metadata
Fields
Template:
Water Supply Protection
File Number
8230.21A2
Description
CWCB Hearing: Objectors' Prehearing Statements
State
CO
Basin
Colorado Mainstem
Water Division
6
Date
5/17/2004
Author
Andrew Peternell, Trout Unlimited
Title
Rebuttal Statement of Trout Unlimited
Water Supply Pro - Doc Type
Court Documents
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Even if the "minimum stream flow. ..for a reasonable recreation experience" language of <br />C.R.S. § 37-92-103(10.3) had some effect, the application satisfies this standard. Notwithstanding <br />the Staff's assertion to the contrary, see Staff Prehearing Statement at 2, the Applicant has provided <br />evidence that the flow rates sought are the minimum necessary for a reasonable recreation <br />experience. The statement of Gary Lacy indicates that though the course will function best at high <br />flow rates, the course will provide a reasonable recreation experience and will function as designed <br />at flow rates between 120 cfs and 1900 cfs. Lacy Report at 5, 12. Recognizing that a"reasonable <br />recreation experience" is a flexible and subjective concept, the Applicant has sought a variety of <br />flow rates within this range. Mr. Lacy's report indicates that the various requested flow rates are <br />necessary to provide a reasonable recreation experience for the purposes for which the Steamboat <br />Course was constructed. Lacy Report at 15. <br />According to Black's Law Dictionary, "reasonable" is defined as "fair, proper or moderate <br />under the circumstances." Black's Law Dictionary, Pocket Edition 523 (Brian A. Garner ed., <br />1996) (emphasis added). Reasonableness, therefore, varies with changes in external factors, such as <br />the time of year and the flows available on other rivers. Thus, the reasonableness of an experience <br />is tied to the natural hydrograph; the flow required for a fair, proper or moderate experience in <br />September, when flows on the Yampa and other rivers across the region are naturally lower, would <br />be unacceptable during June runoff. <br />Accordingly, the flows the Applicant has requested for each two-week period identified in <br />the application are higher during times of the year when the natural flow of rivers in the region <br />would be higher and lower during period of naturally lower flows. In his report, Mr. Lacy stated <br />that low flows through the Steamboat Course during times of the year that other rivers axe high <br />would cause users to go to other similar venues with higher flow rates. Lacy Report at 15. Taking <br />into consideration the natural conditions of the rivers in the region during different times of the <br />year, the Applicant has carefully selected the minimum flow rates to produce a moderate recreation <br />experience for each of the respective two-week intervals. <br />The variation in requested flow rates is consistent with many CWCB appropriations under <br />the state's in-stream flow program. The language of C.R.S. § 37-92-103(10.3) defining an RICD as <br />"the minimum stream flow...for a reasonable recreation experience" closely resembles language <br />applicable to CWCB in-stream flow appropriations, which authorizes the CWCB to appropriate <br />"minimum stream flows...to preserve the natural environment to a reasonable degree." C.R.S. § <br />37-92-102(3). Many of the CWCB's own appropriations under the in-stream flow program are for <br />flows that vary throughout the year. In the same way that the minimum flow rate necessary to <br />preserve the environment to a reasonable degree may vary seasonally, creation of a reasonable <br />recreation experience may require higher flows during the times of year when higher flows <br />naturally occur. <br />Though the Staff argues that not all of the claimed uses are enhanced by the in-channel <br />structures, it concedes that the Steamboat Course may enhance some uses, such as kayaking. Staff <br />Prehearing Statement at 4. Similarly, Morrison Creek and the Upper Yampa both argue that the <br />high flows requested by the Applicant limit the use of the water to expert kayaking. Morrison <br />Creek Statement of Opposition at 3; Upper Yampa Statement of Opposition at 2-3. Thus, they <br />claim, the water will not be put to beneficial use within the meaning of a"reasonable recreation
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