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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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would theoretically be appropriated to the Cascade Town Company would inhibit other users <br />from appropriating water to beneficial use. Id. at 129. <br />In City of Colorado Springs v. Bender, Bender claimed injury after a junior appropriator, <br />the City of Colorado Springs, rendered his well unusable by lowering the water level in the <br />aquifer below the intake of Bender's pumping facilities. 148 Colo. at 460, 366 P.2d at 554. The <br />trial court enjoined the City of Colorado Springs from diverting water from the aquifer during <br />the irrigation season to prevent injury to Bender's senior irrigation right. Id. The Supreme Court <br />reversed the injunction, finding that while Bender's right was senior, he was not entitled to relief <br />unless he had a reasonable means of diversion to accomplish the purpose for which his <br />appropriation was lawfully made. 148 Colo. at 462, 366 P.2d at 555 (citing Schodde, supra). <br />Applying the principles from these cases to Golden's claim demonstrates that the <br />amounts awarded by the water court are not "the use of that amount of water that is reasonable <br />and appropriate under reasonably efficient practices to accomplish without waste the purpose for <br />which the appropriation" may be lawfully made. In this case, Golden's claim for flow rates to <br />create whitewater features can be compared to Schodde's claim to the flow of water to move the <br />water wheel. The flows necessary to create whitewater features only occur at higher rates, but <br />are not necessary to accomplish the purpose of recreational boating. Higher flows are needed <br />only for a specific type of recreational boating, i.e., intermediate to advanced whitewater <br />kayaking. In Schodde, the flows necessary to operate the water wheel were not considered <br />reasonable and appropriate under reasonably efficient practices to accomplish the purpose of <br />irrigation. As observed in Schodde, when the downstream user threw back the water and stopped <br />the flow of Snake River, Schodde's water wheel no longer turned water away from the river. <br />However, if Schodde had used a different and reasonably efficient method to divert water from <br />17 <br />
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