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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
6/11/2010 2:58:18 PM
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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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flow and provided notice that Fort Collins was not seeking a water right by diversion. The 1986 <br />Application states that " points of diversion are ,proposed [emphasis added] Instead, it notified <br />the world that: <br />The existence of in- stream flows of water up to the amounts specified above, <br />undiminished in both quantity and quality, are necessary to fulfill the purposes of <br />the Recreation Corridor. [Emphasis added] <br />Appendix B, p.3, 4. <br />On May 27, 1988, Fort Collins filed its so- called "amendment" to its 1986 <br />Application which provided notice to the world that Fort Collins no longer intended to appropriate <br />in- stream flows, but now intended to appropriate water by diversion at the Nature Center <br />Diversion Dam and at the Power Plant Diversion Dam. Appendix C, p.1, 5. <br />A water court may decree rights no more extensive that those sought in the <br />application. Danielson v. Jones, 698 P.2d 240, 244 (Colo. 1985); United States v. City and County <br />of Denver, 656 P.2d 1, 35 (Colo. 1982); Accord City and County of Denver v. Vail Valley <br />Consolidated Water District 751 P.2d 68, 73 (Colo. 1988). Fort Collins' 1986 Application sought <br />only in- stream flows. If Fort Collins sought a direct use by diversion decree at the Nature Center <br />Diversion Dam, it must seek that decree specifically. It may not rely upon an application seeking <br />a completely different class of appropriation to support a decree for a diversion at the Nature <br />Center Diversion Dam. See City and County of Denver v. Northern Colorado Water Conservation <br />15 This was the first time that Fort Collins demonstrated any kind of intent to divert and appropriate a water right at <br />the Nature Center Diversion Dam by overt acts sufficient to put interested persons on notice of its intended appropriation. <br />22 <br />
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