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Reply Brief and Response Brief of Appleant, City of Thornton
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Reply Brief and Response Brief of Appleant, City of Thornton
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Last modified
6/14/2010 1:11:58 PM
Creation date
6/11/2010 3:29:51 PM
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Water Supply Protection
Description
Fort Collins and Thornton 86CW371
State
CO
Basin
South Platte
Water Division
1
Date
7/27/1991
Author
Michael D. White, Bruce D. Bernard, Teri L. Petitt
Title
Reply Brief and Response Brief of Appleant, City of Thornton
Water Supply Pro - Doc Type
Court Documents
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This Court has consistently held that the "first step" toward the appropriation of a <br />conditional water right occurs, and the date of appropriation is established, upon the concurrence of <br />two events: (1) intent on behalf of the applicant to take the water and put it to beneficial use; and <br />(2) a demonstration of this intent by overt physical acts sufficient to put third parties on notice of the <br />proposed appropriation. Twin Lakes Reservoir and Canal CompaLiy Company v. Cily of AMen, 192 Colo. 209, <br />557 P.2d 825, 828 (1976) ( " Twin Lakes "); City of Amen v Colorado River Water Conservancy <br />District 696 P.2d 758, 761 (Colo. 1985) ( "As en "); Fruitland Irrigation Co v Kruemline 62 Colo. <br />160, 162 P. 161 (1916) ( " Fruitland "). The intent required to establish a date of appropriation is <br />shown by a "a fixed purpose to pursue diligently a certain course of action to take and beneficially <br />use water from a particular source." City & County of Denver v Colorado River Water Conservancy <br />District 696 P.2d 730, 745 (Colo. 1985) ( " Denver "); Bar 70 Enterprises Inc v Tosco Corporation <br />703 P.2d 1297, 1307 (Colo. 1985) ( " Bar 70 Enterprises "). As such, pursuant to C.R.S. § 37-92 - <br />103(3)(a)(II), a purported appropriator must "have a specific plan and intent to divert, store, or <br />otherwise capture, possess, and control a specific quantity of water for specific beneficial uses." The <br />overt act required to establish a date of appropriation "must be of such character as to: (1) manifest <br />the necessary intent to appropriate water to beneficial use; (2) demonstrate the taking of a substantial <br />step toward the application of water to beneficial use; and (3) constitute notice to interested persons <br />of the nature and extent of the proposed demand upon the water supply." Aspen, supra, 696 P.2d <br />at 762 -63. <br />1- The Land_ Use Plan and nnnmuincr resolution do not s appQrt a <br />February 18 1986 date of appropriation <br />Fort Collins asserts that the adoption of the Land Use Plan by the City of Fort Collins <br />on February 18, 1986, "signified the crystallization of the City's intent to appropriate water in the <br />3 <br />
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