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Case No. 90SA514 Reply Brief of Cross-Appellant, City of Fort Collins
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Case No. 90SA514 Reply Brief of Cross-Appellant, City of Fort Collins
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6/14/2010 1:11:42 PM
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Water Supply Protection
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Fort Collins and Thornton 86CW371
State
CO
Basin
South Platte
Water Division
1
Date
7/15/1991
Author
Michael D. Shimmin, Douglas A. Goulding
Title
Case No. 90SA514 Reply Brief of Cross-Appellant, City of Fort Collins
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I <br />"beneficial use "), App. 2. In specifying 55 c.f.s. as the amount of the appropriation, Fort <br />Collins relied on the professional judgment of an expert in the areas of water resources and <br />environmental engineering who testified that 55 c.f.s. was reasonable, appropriate, and not <br />excessive to fulfill the fishery purposes for which Fort Collins claimed water rights. <br />Testimony of Mr. William T. Pitts, Rec. Vol. 3, p. 189, 1. 9 - p. 194, 1. 11. The water court <br />found that water in the amount of 55 c.f.s. is a reasonable amount for the appropriations <br />at the Power Plant Diversion Dam and the Nature Center Diversion Dam, in accordance <br />with the requirement of C.R.S. § 37 -92- 103(4). Decree,' 13, supra App. 1. <br />Thornton's argument is based on confusion over the application of the "can and will' <br />test imposed upon conditional water rights applications by C.R.S. § 37- 92- 305(9)(b). <br />Despite Thornton's citation to § 305(9)(b), Thornton seeks to apply the "have been" <br />diverted and "have been" beneficially used test imposed upon absolute water rights <br />applications by C.R.S. § 37- 92- 305(9)(a). Thornton Response Brief, p. 15, n. 5. Fort <br />Collins does not claim an absolute water right for the Power Plant Diversion Dam. <br />Therefore, Fort Collins does not have the burden of providing a record of the diversions <br />at the boat chute and fish ladder or the burden of demonstrating that in- priority diversions <br />were beneficially used. <br />Fort Collins met the § 305 (9) (b) requirements by demonstrating that there is <br />unappropriated water available for appropriation, Decree, 'f 12 and 32, supra App. 1, and <br />further demonstrated the ability to complete the appropriation by showing that the <br />structure had been constructed before the time of the trial, Decree, 'f 10 and 14, supra <br />Thorn \RepBrf.& 9 <br />
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