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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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claimed beneficial uses would take place, regardless of whether the structures were put in place. <br />The 1988 Application and its claim of "diversions" at the two dams was clearly an attempt by Fort <br />Collins' to obtain in- stream flows by reference to these two "diversions" of convenience. <br />2. Fort Collins failed to establish that the water can and will be ben eficially used for <br />the claimed uses. <br />The trial court erred in awarding Fort Collins an appropriation for the Nature <br />Center Diversion Dam, which allows the City to call water down the Poudre River through Fort <br />Collins, in the face of the limitation that Fort Collins has no right to assert dominion and control <br />over the flows or to prevent others from appropriating those flows in the reach downstream from <br />the dam where the claimed beneficial uses are supposed to take place. <br />Testimony at trial demonstrates that Fort Collins' claimed purpose for the Nature <br />Center Diversion Dam is to realize in- stream beneficial uses in the historical river channel within <br />the Nature Center. Rec.Vo1.III, P. 157, 1.9 -17. The claimed need for the dam is to allow water <br />to "flow through the Nature Center and therefore provide habitat for fish, other animals -- <br />raccoons, that type of thing." Rec.Vo1.III, P. 162, 1.15 -22. However, Fort Collins does not own <br />or operate the Nature Center. It is owned and operated by Colorado State University. <br />Rec.Vo1.III, p. 26, 1.13 -15. Fort Collins was required pursuant to its stipulation with the CWCB <br />to disclaim any right to assert dominion and control to water as it flows through the Nature <br />Center, and indeed, that restriction is set forth in the decree entered by the trial court. Decree, <br />p.6, ¶19. Fort Collins therefore has absolutely no control over how, or whether, the water will be <br />used within the reach of the river where the claimed beneficial uses are supposed to take place. <br />29 <br />
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