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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
Court Documents
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b. The signs and notices posted and published on December 31, 1986 establish <br />and provide notice of one an intent to appropriate in- stream flows. <br />The signs posted and notices published by Fort Collins do not provide support for <br />a date of appropriation of February 18, 1986, or even of December 31, 1986. Ex.A -68. These <br />signs and notices do not refer to, or give notice of, an intent by Fort Collins to appropriate a <br />water right by diversion at the Nature Center Diversion Dam. The only notice provided by the <br />posting of these signs and the publishing of these notices was of Fort Collins' intent to appropriate <br />in- stream flows. Moreover, while signs were posted at various sites along the stretch of the Poudre <br />River from the Overland Trail bridge to the I -25 bridge, no sign of any kind was posted at the site <br />of the Nature Center Diversion Dam. Rec.Vo1.III, p.227, 1.10 -12. The reason for this is not <br />mysterious -- Fort Collins simply had no plans to construct the Nature Center Diversion Dam as <br />of December 31, 1986. <br />C. The Water Court Erred In Holding That The Filing Date Of The Amended <br />Application Should Relate Back To The Filing Date Of The Original Application. <br />Vested appropriative water rights in Colorado are subject to the first -in -time, first- <br />in-right priority system set forth in C.R.S. § 37 -92 -306. See Appendix A, p.iv, v. Under this <br />system, the date of appropriation awarded a water right determines the relative priority among all <br />water rights filed within a single calendar year. Id. All decreed water rights filed within a calendar <br />year, however, are junior to all priorities awarded to water rights filed in prior calendar years. <br />Id. Therefore, a determination of whether the application filed by Fort Collins in 1988 should <br />relate back to the filing of the 1986 Application determines, in effect, whether the priority awarded <br />18 For example, a water right filed in 1987 and decreed a date of appropriation of May 1, 1985, is nevertheless <br />considered senior in priority to a water right filed in 1988, even though it received an earlier date of appropriation, such <br />as January 1, 1985. <br />24 <br />
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