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Case No. 90SA514 Combined Anwer Brief and Opening Brief on Cross-Appeal
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Case No. 90SA514 Combined Anwer Brief and Opening Brief on Cross-Appeal
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6/14/2010 1:12:46 PM
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Water Supply Protection
Description
Fort Collins and Thorton 86CW371
State
CO
Basin
South Platte
Water Division
1
Date
6/10/1991
Author
Michael D. Shimmin, Douglas A. Goulding
Title
Case No. 90SA514 Combined Anwer Brief and Opening Brief on Cross-Appeal
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Collins, ( "Nastan "), Rec. Vol. 3, p. 116,1. 7- 17,pp. 113 -145. The dam is designed to direct <br />water through the boat chute and the fish ladder on the dam. Nastan, Rec. Vol. 3, p. 116, <br />1.18 -p. 117, 1. 1. <br />These diversion dams will facilitate and result in the beneficial uses of water claimed <br />in the application and decreed by the water court. Without the protection of decreed water <br />rights and their associated priority dates, these beneficial uses could be impacted by junior <br />water development on the Poudre River. <br />III. SUMMARY OF THE ARGUMENT <br />A. THE WATER COURT CORRECTLY DETERMINED THAT THE APPROPRIATION <br />DATE FOR FORT COLLINS' CONDITIONAL WATER RIGHTS WAS FEBRUARY 18, <br />1986. <br />1. <br />The first step analysis used by the water court in this case was wholly within <br />the guiding-principles of Colorado law <br />2. Under the facts and circumstances of this case the water court found that <br />the activities of Fort Collins demonstrated both intent and sufficient overt <br />acts to constitute an appropriation as of February 18 1986 and the record <br />supports these findings <br />B. THE WATER COURT'S DETERMINATION THAT FORT COLLINS' AMENDMENTS <br />TO THE APPLICATION RELATED BACK TO THE FILING DATE OF THE ORIGINAL <br />APPLICATION WAS CORR <br />C. FORT COLLINS' CONDITIONAL WATER RIGHTS ARE VALID APPROPRIATIONS <br />UNDER COLORADO WATER LAW. <br />1. The Water Right Determination and Administration Act of 1969 as amended <br />authorizes appropriations where water is controlled in its natural course by <br />means of a structure <br />2. The water court had sufficient evidence to support its determination that the <br />Nature Center Diversion Dam diverts water <br />FTCOL \PLEADING \BRIEF.APP 5 <br />
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