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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
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IV. Because recreational water rights had never been recognized, there <br />were no administrative rules, statutory guidelines, objective tests or <br />diversion requirements to prevent inconsistent rulings and <br />monopolistic appropriations. <br />The Appellee argues that its water right should not be limited and that no duty of <br />water should be applied to its water right. (AB, pp. 18, 23). However, all legislatively or <br />court sanctioned water rights are limited. The requirement that water be physically diverted <br />from the stream created physical limits on the amount of water that could be appropriated, <br />Denver v. Northern Colo. Water Conservancy Dist., 276 P.2d 992, 998 (Colo. 1954), and <br />ensured maximum utilization. CWCB, 594 P.2d at 573. Under SB 216, the appropriator is <br />limited to the "minimum stream flow" necessary for a "reasonable recreation experience" <br />with consideration of the "maximum utilization" of the water. §§ 37- 92- 103(10.3) &37 -92- <br />102(6)(b)(V). Similarly, the amount of water granted in Fort Collins was appropriately <br />limited to low flows only (a reasonable amount of 30 c.f.s.). Likewise, this Court must <br />impose some limits on Appellee's water right if the Court upholds the existence of the water <br />right. <br />All water rights are limited to a reasonable and appropriate amount. § 37 -92- <br />103(4). The water user is required to use the water efficiently, and without waste in order to <br />ensure maximum utilization and prevent "unrealistically high" use of this scarce resource. <br />§ 37- 92- 103(4); Consolidated Home Supply v. Berthoud, 896 P.2d 260, 271 (Colo. 1995). <br />Water courts had never applied these long - standing legal concepts and definitions to <br />recreational instream flows until Golden, Eagle and Breckenridge. As a result, the water <br />courts have applied differing definitions of these concepts, resulting in subjective, <br />11 <br />
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