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Case No. 01SA252 Brief of Amici Curiae February 2002
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Case No. 01SA252 Brief of Amici Curiae February 2002
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Case No. 01SA252 Brief of Amici Curiae February 2002
State
CO
Date
2/7/2002
Author
Robbins, David W.; Montfomery, Dennis M.; Wells, Patricia L.; Lawrence, Kim R.; Maynes, Frank E.; Dingess, John M.; Miller, Lee E.
Title
Case No. 01SA252 Brief of Amici Curiae February 2002
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Court Documents
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However, the Court recognized that the amount of water claimed by the City of Fort Collins in <br />that case was the minimum flow necessary to accomplish the purpose of recreational boating on <br />a stretch of the Poudre River and to allow fish to ascend a fish ladder in a dam, not the entire <br />flow of the Poudre River or a substantial portion thereof. Golden has taken wing with the <br />Court's decision in the Fort Collins case and claimed virtually the entire flow of Clear Creek for <br />whitewater kayaking. The water court, by awarding large flows to Golden for whitewater <br />kayaking, has created a potential nightmare for the State of Colorado and its water users. <br />There is nothing in Colorado statutes or the decisions of this Court to suggest that the <br />right to appropriate by controlling water in its natural course or location for recreational purposes <br />is limited only to cities or political subdivisions of the state. In fact, under the Water Court's <br />interpretation of "diversion" and "beneficial use," any entity, including the federal government, <br />would be free to make similar appropriations. If Golden is entitled to an appropriation <br />commanding a substantial portion of the flow of Clear Creek for recreational boating, merely by <br />constructing deflector devices in the channel that span from bank -to -bank, there is nothing to <br />prevent any individual or group from doing the same thing on any river or stream in this state; <br />and, in fact, there_ is nothing to prevent the federal government from constructing similar <br />structures and claiming substantial flows for recreational boating below federal dams and <br />reservoirs or on rivers and streams that flow through federal lands. Furthemaor-1, r--creKtio al <br />boating is not limited to kayaks. Rafts and power craft of all sizes are also used for recreational <br />boating and could demand far greater levels of flow under the water court's interpretation of <br />beneficial use. <br />Under a truly frightening scenario, the federal government could construct structures <br />similar to Golden's devices across the Colorado River at or near the Colorado -Utah state line and <br />0 <br />
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