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CWCB vs. Upper Gunnison River Water Conservancy District - Adjudication of RICD under SB 01-216
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CWCB vs. Upper Gunnison River Water Conservancy District - Adjudication of RICD under SB 01-216
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Last modified
7/16/2010 12:39:05 PM
Creation date
7/14/2010 3:45:43 PM
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Template:
Water Supply Protection
Description
Gunnison RICD
State
CO
Basin
Gunnison
Water Division
4
Date
3/14/2005
Author
CWCB, Upper Gunnison River Water Conservancy District
Title
CWCB vs. Upper Gunnison River Water Conservancy District - Adjudication of RICD under SB 01-216
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The above seemingly simple procedure gives rise to the <br />first issue presented for our review — namely, what is the <br />extent of the review performed by the CWCB prior to the water <br />court's adjudication? The CWCB, through Appellants, argues that <br />the General Assembly granted it expansive authority, in <br />particular, the authority to objectively determine what stream <br />flow is minimally necessary in order to provide a reasonable <br />recreation experience. Applicant, on the other hand, believes <br />that the CWCB's authority is limited to a.review of the <br />application strictly as submitted by the applicant for <br />appropriateness under the five statutory factors; that is, the <br />CWCB only may examine the applicant's own determination of the <br />amount of water it intends to appropriate for its proposed <br />recreation experience. <br />After a careful analysis of the plain language of sB 216 as <br />a whole, as well as noting the legislative history, we hold that <br />the General Assembly intended for the CWCB to analyze the <br />'application purely as submitted by the applicant, rather than to <br />objectively determine what recreation experience would be <br />reasonable, and what minimum stream flow would meet that <br />recreational need. As such, we hold that the General Assembly <br />intended for the CWCB to function as a narrowly constrained <br />fact - finding and advisory body when it reviews RICD <br />applications, rather than in an unrestricted adjudicatory role. <br />14 <br />
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