Laserfiche WebLink
This brief is a combination of (1) Fort Collins' Response to Thornton's Opening Brief <br />(concerning the Nature Center Diversion Dam), and (2) Fort Collins' Opening Brief on <br />Cross - Appeal (concerning the Power Plant Diversion Dam). <br />B. STATEMENT OF THE FACTS <br />Beginning in the late 1970s, Fort Collins recognized the Poudre River as an <br />important community asset to be used and developed for municipal and recreational <br />purposes, and expressed this goal in written planning documents. Testimony of Richard <br />Shannon, Utilities Director for the City of Fort Collins ( "Shannon "), Rec. Vol. 3, pp. 24 -38, <br />App. 5; Exh. A -1, A -2, A -3, and A -7. Beginning in the early 1980s, Fort Collins studied the <br />preservation and enhancement of water in the Poudre for fishery and other recreational <br />water uses, in conjunction with Fort Collins' recreational development along the Poudre. <br />These studies are written, public documents. Exh. A -17, A -19, A -32, A -33, A -34, A -38, and <br />A -40. <br />As part of a continuing municipal planning process, Fort Collins made <br />recommendations for the purpose of protecting and enhancing the Poudre in furtherance <br />of municipal recreational goals. Exh. A -1, Rec. Vol. 3, p. 25, 1. 11 -20, p. 30, 1. 23 - p. 31, <br />1. 3. A diversity of community and recreational interest groups participated in making the <br />Poudre River area the focal point of this municipal planning concept, and united with Fort <br />Collins in 1984 to form the Poudre River Trust. Shannon, Rec. Vol. 3, p. 37,1. 13 -25; App. <br />5. <br />FTCOWLEADINGW IEF.APP 3 <br />