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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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the channel, install boulders or deflector devices in the channel, and claim large flows for various <br />forms of recreational boating, on the basis that higher flows attract more boaters. <br />The prior appropriation doctrine is a doctrine to allocate a scarce resource, water, for <br />beneficial use. Empire Lodge Homeowners' Assoc. v. Moyer, No. 00SA211, 2001 WL 1598753, <br />at *4 (Colo. 2001). Over time, the appropriation doctrine, born of the harsh conditions of the <br />environment in our state and the experience of the early settlers, has evolved to satisfy the needs <br />of the citizens of Colorado. Colorado River Water Conservation Dist. v. Colorado Water <br />Conservation Bd., 197 Colo. 469, 474, 594 P.2d 570, 573 (1979); Bd. of County Comm'rs of <br />County of Arapahoe v. Collard, 827 P.2d 546, 549 -50 (Colo. 1992). But, it should never be <br />forgotten that the prior appropriation doctrine was a rejection of the riparian doctrine that applied <br />in England and eastern states where conditions were vastly different. Id. <br />Contrary to prior appropriation, the riparian doctrine is based upon the premise that every <br />riparian owner is entitled to the continued natural flow of the river. United States v. Rio Grande <br />Dam & Irrigation Co., 174 U.S. 690, 702 (1899); Colorado River Water Conservation Dist. v. <br />Rocky Mountain Power Co., 158 Colo. 331, 336, 406 P.2d 798, 800 (1965) (citing Schodde, <br />supra.). Under the riparian doctrine, each adjacent landowner has the right to use the water, <br />which flows in the stream as it was meant to run without diminution or alteration. Rio Grande <br />Dam and Irrigation Co., 174 U.S. at 702. <br />In Rocky Mountain Power, relying upon statutory enabling language, the Colorado River <br />Water Conservation District attempted to keep a minimum of water in the river for <br />piscatorial habitat preservation without any form of diversion. Rocky Nloacratairi Power Co., 158 <br />Colo. at 3' )2, 406 P.2d at 799. The Court held that by enacting the statute that the District relied <br />upon, the Colorado legislature did not intend such a departure from the well - established doctrine <br />
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