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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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7/13/2012 10:30:46 AM
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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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Recreational instream flows were "new water rights," and thus, "there [were] no <br />standards and procedures" for water courts to follow for recreational instream flows because <br />such rights did not exist until "a need for this legislation [came] as a result of certain local <br />districts filing very large claims..." (Exhibit 1, pp. 1 -3). Therefore, some limits had to be <br />imposed to prevent appropriations that "command the entire flow of the river and can be <br />used by any entity to control all outstanding water...." (Exhibit 2, p. 1). <br />With no law authorizing such uses, there were no legislative or court- imposed <br />standards on how these valuable water rights were to be appropriated. With no limits, the <br />appropriation of water by "dropping a single boulder in a river" is not a "far -flung scenario" <br />as Appellee claims, but rather the natural extension of an unconstrained system for instream <br />water appropriations.6 (AB, pp. 22, 26). The Legislature noted that without some regulation, <br />recreational instream flows would change the prior appropriation system by allowing claims <br />for "putting some boulders into the stream" for boating. (Exhibit 1, p. 1). <br />As a result of the absence of standards applicable to this type of appropriation, the <br />water courts have provided inconsistent legal rulings and have granted unregulated <br />monopolies on entire water basins. This result was exactly what the Legislature feared in <br />6 Appellee argues that because SB 216 will prevent such a "parade of horribles," this <br />unlimited water right should be upheld. (AB, p. 28). While it is true that SB 216 will prevent <br />further unregulated abuses, that should not be the basis for this Court to uphold Appellee's <br />unregulated monopoly of the water basin. <br />M <br />
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