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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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through the boat chute and fish ladder features of the Power Plant Diversion Dam. Decree, <br />� 16, supra These findings are substantially supported by the testimony of Robert Nastan, <br />the Construction and Services Manager, Light and Power Utility, City of Fort Collins, Rec. <br />Vol. 3, p. 116, 1. 18 - p. 117, 1. 1; p. 130, 1. 6 -11. <br />Despite the water court's finding that waters are directed to the boat chute and fish <br />ladder, and despite the graphic evidence presented by the design drawings for the Power <br />Plant Diversion Dam and the photographs of the Power Plant Diversion Dam that once <br />water is directed to the concrete conduits forming the boat chute and fish ladder those <br />conduits control the flow of diverted water through the features, the court found that the <br />river flows as it did prior to the construction of the Power Plant Diversion Dam. Photos, <br />Exhibits A -41 and A -42, Rec. Vol. 3, p. 115, 1. 13 - p. 117, 1. 1; Design Drawings, Exhibit <br />A -46, Rec. Vol. 3, p. 122, 1. 19 and p. 124, 1. 23 -25; Decree, 'f 17, supra, App. 1. The <br />finding that the river flow is unchanged contradicts the uncontroverted evidence and the <br />water court's own finding that the structure controls river flows under certain low flow <br />conditions. Fort Collins surmises that this inconsistency is based on the water court's <br />reading of the definition of diversion to require an appropriator to completely alter the <br />course of a river or control the entire flow of the river in order to "control water in its <br />natural course or location. "' <br />'In contrast, the Nature Center Diversion Dam alters the <br />course of the Cache La Poudre River, but Fort Collins did not <br />claim and the water court did not award a conditional water right <br />for the entire stream flow. Instead, the diversion was <br />conditionally decreed at the rate of 55 c.f.s. <br />Thorn \RepBrf.& 5 <br />
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