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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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The water court's conclusion cannot be correct because such a requirement cannot <br />be harmonized with the overall statutory scheme for water right determination provided <br />by Title 37, Article 92, of the Colorado Revised Statutes. See City of Florence v. Bd. of <br />Waterworks of Pueblo 793 P.2d 148 (Colo. 1990) (The language of a statute should be <br />construed in harmony with the overall statutory scheme). The determination of a <br />conditional water right involves the determination of " a right to perfect a water right with <br />a certain priority upon the completion with reasonable diligence of the appropriation upon <br />which such water right is to be based." C.R.S. § 37 -92- 103(6), App. 2. Both "water right" <br />and "appropriation" reference the use or application to a beneficial uses of a specified <br />portion of the waters of the state. C.R.S. § 37- 92- 103(3) (a) and, App. 2 (12). Unless the <br />proposed beneficial uses cannot occur without altering the course of a stream, or unless <br />control of the entire flow of the stream is necessary to accomplish proposed beneficial uses, <br />"control water in its natural course or location" cannot mean control over the entire Mow <br />of a river. The applicant for a conditional water right cannot be required to show that the <br />applicant can and will effect greater control over a stream's flow than is necessary to <br />accomplish proposed beneficial uses. <br />There is no evidence to support the conclusion that the Power Plant Diversion Dam <br />does not control water in its natural course or location, the conclusion is based on an error <br />of law, and there is substantial evidence supporting the conclusion that the Power Plant <br />Diversion Dam controls water in its natural course or location as defined at C.R.S. § 37 -92- <br />103(7). <br />Thorn \RepBrf.& 6 <br />
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