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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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made in reclaiming and fertilizing by irrigation portions of our <br />unproductive territory. Houses have been built, and permanent <br />improvements made; the soil has been cultivated, and thousands of <br />acres have been rendered immensely valuable, with the <br />understanding that appropriations of water would be protected. <br />Deny the doctrine of priority or superiority of right by priority of <br />appropriation, and a great part of the value of all this property is at <br />once destroyed. <br />Coffin v. Left Hand Ditch Co., 6 Colo. 443, 446 (1882). <br />There are those today, as there were in 1876 when the Colorado Constitution was <br />adopted, who do not agree with the doctrine of prior appropriation and believe that water should <br />be left to flow in streams as nature intended. As the state of Colorado has developed, the <br />General Assembly has tried to accommodate the interest in preserving the natural environment <br />by allowing the appropriation by the state of Colorado in the manner prescribed by law of such <br />minimum flows as are required to preserve the natural environment to a reasonable decree. The <br />General Assembly has also provided that a diversion can occur by controlling water in its natural <br />course or location by means of a structure or device. But the General Assembly has acted within <br />the context of the prior appropriation doctrine, not by recognizing common law principles of <br />riparian proprietorship. <br />In considering whether the amounts claimed by Golden, and awarded by the water court, <br />are beneficial, the Court should consider whether Golden's claim is for an amount of water that <br />is reasonable and appropriate under the prior appropriation doctrine, which is intended to make <br />water available for beneficial uses. Recognizing a claim for an instream flow for recreational <br />boating that is unreasonable and inappropriate will deprive the citizens of the state of Colorado <br />of their right, guaranteed by the constitution, to divert unappropriated water to beneficial uses. If <br />this Court affirms the water court's decree, one can imagine that those opposed to the doctrine of <br />prior appropriation will simply purchase land near the Colorado borders, stabilize the banks of <br />2l <br />
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