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Case No. 02SA226 Reply Brief March 2003
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Case No. 02SA226 Reply Brief March 2003
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Water Supply Protection
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Case No. 02SA226 Reply Brief March 2003
State
CO
Date
3/17/2003
Author
Schneider, Susan
Title
Case No. 02SA226 Reply Brief March 2003
Water Supply Pro - Doc Type
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X <br />which granted the only exception to the diversion requirement for the CWCB. In citing this <br />case, Appellee fails to address the meaning of the Court's specific emphasis that it was "not <br />hereby causing any erosion of the many opinions of this court ... holding that a diversion is <br />an essential element of the water appropriation...." CWCB, 594 P.2d at 575 (emphasis <br />added). Yet, Appellee asserts that it, along with the CWCB, may appropriate water for <br />instream uses because of this "long line of precedent." (AB, p. 12). <br />Notably, in the same year that this Court upheld the right of the CWCB to obtain <br />instream flows and required diversion as an essential element for all other water rights, this <br />Court also ruled that the legislative process Was the proper method to accommodate "the <br />increasing demand for recreational space on the waters of this state...." Id.; Emmert, 597 P.2d at <br />1029. Thus, in order for Fort Collins to have ruled that recreational instream flows were <br />thereafter legal, the Court would have had to overrule both CWCB and Emmert and the "long <br />line of precedent" upholding the diversion requirement. <br />This Court should reverse the water court's grant of recreational instream flow <br />appropriations because such uses have never been authorized by this Court or the Legislature <br />until SB 216. <br />M. Prior to SB 216, the Legislature Had Never Authorized a Right to <br />Appropriate Recreational Instream Flows. <br />In 1979, this Court clearly recognized the legislative intent that diversion was an <br />"essential element" of water appropriations (except for CWCB appropriations). CWCB, 594 <br />P.2d 570. Nonetheless, the Legislature was prompted to pass another law reiterating that the <br />CWCB was the only exception to the diversion requirement after Fort Collins applied for its <br />I <br />
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