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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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natural course under section 37- 92- 103(7). Id. at 932. Fort Collins sought to control a limited <br />amount of water at low flows so that boats and fish could pass through the boat chute and fish <br />ladder at the Power Dam. Fort Collins, 830 P.2d at 932. Golden did something similar by <br />constructing a low -flow channel that controls flows up to 30 c.f.s. However, Golden also <br />installed flow deflector devices throughout the channel from bank -to -bank and stabilized the <br />banks, and then claimed that it had thereby controlled the entire flow of Clear Creek in its natural <br />course or location. The State objectors conceded that Golden had controlled flows up to 30 c.f.s. <br />in the low flow channel, but argued that Golden had not controlled' bows above 30 c.f.s. when <br />the low flow channel was overtopped. <br />The amici curiae accept for the purposes of their arguments that Golden's structures <br />controlled water in its natural course or location at flows up to 30 c.f.s. in the low flow channel. <br />However, Golden's structures do not control water when the low flow channel is overtopped. <br />First, stabilizing the banks of Clear Creek is no different than what the U.S. Army Corps of <br />Engineers does throughout the nation. If the Court were to hold that stabilizing the banks of a <br />stream is all that is necessary to "control water in its natural course or location by means of a <br />structure or device," it would encourage landowners and others, including the federal <br />government, to do the same thing and claim in- channel diversions for recreational, fishery, or <br />wncuite purposes, which would effectively resurrect the riparian doctrine in Colorado. <br />Second, the flow deflector devices do not control water in its natural course or location <br />within the meaning of section 37- 92- 103(7). In Clear Creek, Go!I-c:. installed flo:: deflector <br />devices that were designed to create channels and chutes for kayakers, imitating [Ile ettect of <br />boulders in a natural stream. The deflector devices change the direction of the flow of the water <br />and change the hydraulics of the flow to create "waves and jets of water, self - scouring pools," <br />13 <br />
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