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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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<br />The policy of maximum utilization does not require a single-minded endeavor <br />to squeeze every drop of water from the valley's aquifers. C.R.S. § 37-92- <br />591(2)(e) makes clear that the objective of "maximum use" administration is <br />"optimum use." Optimum use can only be achieved with proper regard for all <br />significant factors, including environmental and economic concerns. See <br />C.R.S. § 37-92-102(3). <br />Alamosa La-.Iara Water Users Protection Ass'n v. Gould, 674 P.2d 914, 935 (Colo. 1983). <br />The Steamboat Course places the water of the Yampa River to additional legally recognized <br />beneficial use without injury to any existing absolute or conditional water rights. Because the <br />proposed use is non-consumptive, it allows for successive use of water downstream. As such, the <br />project more than satisfies the legal requirements of the maximum utilization doctrine. In addition, <br />the Steamboat Course will benefit the local economy, environment and quality of life, all relevant <br />factors to the maximum utilization determination under Alamosa. <br />The importance of non-consumptive and in-channel uses to the state of Colorado cannot be <br />overstated. Most Colorado rivers are over-appropriated. Empire Lodge, 39 P. 3d at 1149-50. So, <br />today, the appropriation of water for non-consumptive use may be one of the few ways for new <br />appropriators to add to the panoply of water use in the state without stopping another existing use. <br />Although Routt County ("County") argues that the economic benefit that has been provided by the <br />Steamboat Course is limited, see County Prehearing Statement at 1-3, the County fails to recognize <br />the growing importance of recreational opportunities to Colorado's future economy. Water in <br />rivers-whether appropriated for recreational in-channel use, a fish ladder, an instream flow to <br />protect the environment to a reasonable degree or a release for fish and recreatiorial purposes- <br />contributes substantially to Colorado's tourist-based economy. Fishing generates $1.3 billion <br />dollars annually to the state economic base, while rafting adds $122 million. American Sportfishing <br />Association, "1996 Sport Fishing Participation and Economic Impact for Colorado," <br />http://www.asafishing.org/content/statistics/economic; Colorado River Outfitters Association, <br />"Colorado's River Rafting Industry Questions & Answers to Commonly Asked Questions," <br />http://www.croa.org/faq.htm. As Colorado increasingly suffers limited availability of its waters for <br />consumptive use, non-consumptive and in-channel uses are gaining importance in the maximum <br />utilization of the state's water resources. <br />III. CONCLUSION <br />For the above reasons, in addition to the reasons set forth in TU's prehearing statement, TU <br />encourages the CWCB to make the requisite findings and a favorable recommendation to the water <br />court regarding the Applicant's water rights application. <br />Respectfully submitted this 17th day of May, 2 <br />r -? <br />Andrew eternell, Reg. No. 32455 <br />5
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