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I. ISSUES PRESENTED FOR REVIEW. <br />A. Whether the City of Golden's in- channel structures constitute a lawful "diversion" to <br />beneficial use of the waters of Clear Creek. <br />B. Whether recognition of the claimed water rights would undermine the doctrine of maximum <br />utilization. <br />C. Whether the amount of water claimed and decreed is reasonable and appropriate under <br />reasonably efficient practices to accomplish without waste the purpose for which the <br />appropriation is lawfully made. <br />II. STATEMENT OF THE CASE. <br />Amici curiae, Colorado Springs Utilities, Northern Colorado Water Conservancy District, <br />Municipal Subdistrict, Northern Colorado Water Conservancy District, and the Southeastern <br />Colorado Water Conservancy District adopt the Statement of the Case provided by amici curiae, Rio <br />Grande Water Conservation District, et. al., in their amici brief with the following addition. <br />In this case, the Court will address important questions regarding how recreational in- channel <br />appropriations will be defined, limited and administered. The answers to these questions will have <br />far - reaching impacts on the ability of water users in Colorado to develop waters of the state, utilize <br />2 <br />