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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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"hydraulic holes," and other whitewater features that are used by kayakers and boaters (Record <br />V.3, at 545), just as boulders do in a natural stream. However, the flow deflector devices do not <br />control and concentrate water in its natural course in the way that Fort Collins's dam, boat chute, <br />and fish ladder controlled and concentrated water in its natural course, unless the Court is <br />prepared to say that boulders in a stream "control" water in its natural course. <br />The Fort Collins dam directs the water through a notch in the dam, and the water cannot <br />go anywhere else. At flow rates up to the decreed flow, the water will go through the notch. In <br />contrast, when water passes by Golden's flow deflector devices, it will go wherever the flow <br />takes it. The water may bounce against the device and create a certain type of whitewater feature <br />that may disappear for a moment and reappear moments later. At one moment, the water may be <br />forced one way by part of the Golden device, bAt the velocity of the flow at another moment may <br />change the way the water hits the device and an entirely different wave or feature may appear or <br />disappear. Mr. Lacy, the Golden course designer, stated that unconnected boulders make <br />features, which Golden's features were designed to imitate, that allow for tricks called "boofing <br />and splatting." (Record, V.5, at 27, 29.) These whitewater features are not constant, and while <br />Golden's structures may manipulate the hydraulics of some of the water, the amici curiae believe <br />that the General Assembly intended controlling water in its natural course or location to mean <br />something different than "boofmg and splatting." <br />In conclusion, when the low flow channel is overtopped, Golden's structures do not <br />control water in its natural course by means of a structure or device within the meaning of <br />section 37 -92- 103(7). However, even if the Court concludes that Golden's structures, or some of <br />them, do control water in its natural course or location at flows above 30 c.f.s., Golden did not <br />14 <br />
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