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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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of diversion. Id. at 800. Conversely, the Court did find legislative intent to depart from the <br />doctrine when the General Assembly enacted Senate Bill 97, declaring the Colorado Water <br />Conservation Board as the sole entity able to appropriate a minimum stream flow without a <br />diversion, between two designated points in the river. CRS §37 -92- 103(4) 10 C.R.S. (2001); <br />Colorado Water Conservation Bd., 197 Colo. at 476, 594 P.2d at 574. <br />Golden owns virtually all the land adjacent to the course and has access to the balance. <br />(Record V. 4, at 80 -82, Application, at 5.) Thus, Golden is a riparian owner, and its claim for the <br />entire flow of the river mirrors a riparian concept. Throughout its application and brief, Golden <br />requests the maximum flow of Clear Creek at any.given time. (Record V.1, at 6; V.3, at 484 -85, <br />487 -88.) Further; in the water court's decree, the court refers to the deflector dams as devices <br />controlling the "flow of water," (Record V.3, at,545), or directing the "flow of water." Id. at <br />546. The court also found that Golden's proposed use is beneficial because higher flows <br />generate greater course usage, id., and "high flow rates are a critical component of the course." <br />Id. Rate of flow is a riparian principle, yet Colorado has never recognized the riparian doctrine. <br />This decree in effect ties up the flow of the entire river, a riparian concept not recognized in <br />Colorado. <br />V. CONCLUSION <br />The water court's judgment should be reversed, and the case should be remanded for <br />application of correct definitions of "diversion" and "beneficial use." <br />Respectfully submitted this 7 I day of February 2002. <br />23 <br />
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