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Case No. 90SA514 Opening Brief for the Appellant
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Case No. 90SA514 Opening Brief for the Appellant
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6/24/2010 12:21:26 PM
Creation date
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Water Supply Protection
Description
Fort Collins and Thorton 86CW371
State
CO
Basin
South Platte
Water Division
1
Date
5/6/1991
Author
Michael D. White, Bruce D. Bernard, Teri L. Petitt
Title
Case No. 90SA514 Opening Brief for the Appellant
Water Supply Pro - Doc Type
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posted any signs at the site of the Nature Center Diversion Dam or stating Fort Collins' intent to <br />appropriate water rights for the two dams. Rec.Vol.III, p.227,1.10-15. <br />Fort Collins published notices in The Coloradoan on December 31, 1986 and <br />January 29, 1987 notifying the public of its intent to appropriate "in- stream water rights" within the <br />Poudre River. Ex.A -68; Rec.Vol.III, p.216,1.1-7; p.217,1.23-24; p.218,1.1-3. Neither the Nature <br />Center Diversion Dam nor the Power Plant Diversion Dam are mentioned in the notices, nor is <br />there any mention of a plan or an intent to divert water anywhere along the Poudre River. In <br />fact, the January 27, 1987 notice specifically stated that "no points of diversion are proposed." <br />Fx.A -68. <br />On May 27, 1988, Fort Collins filed what it styled as an "amendment" to the 1986 <br />Application seeking to appropriate a 55 c.fs. water right at two distinct points of diversion, the <br />"Power Plant Diversion Dam" and the "Nature Center Diversion Dam." Appendix C. The Power <br />Plant Diversion Dam is a concrete dam across the Poudre River which includes a boat chute and <br />a fish ladder. Appendix C, p.3. The Nature Center Diversion Dam is a rock and clay dam <br />designed to divert the Poudre River from its current channel to its pre -1983 historic channel <br />through the Colorado Nature Center. Rec.Vol.III, p.157,1.9-21; p.162,1.15-22; Appendix C, p.3. <br />The Colorado Nature Center is owned and operated by Colorado State University. Rec.Vol.III, <br />p.26,1.13-15. Fort Collins expressly removed all reference to in- stream rights, yet sought the same <br />date of appropriation as it sought in the 1986 Application, February 18, 1986. Appendix C, p.2, <br />5. Fort Collins also claimed that the "amendments" were "consistent" with the 1986 Application, <br />and thus sought to relate the filing date of the 1988 Application back to 1986. Appendix C, p.l. <br />5 <br />
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