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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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• <br />without explicit authority via the "legislative process. "9 <br />The "essential underpinning" of Fort Collins was not "whether the structures were <br />constructed and operate to accomplish the intended beneficial use," as Appellee argues. to <br />(AB, p. 18). The essential underpinning was whether the definition of diversion could <br />encompass the traditional dam impoundment structure used for boat passage: Thus, Fort <br />Collins was about the evolving definition of diversion, not about substantially changing <br />Colorado water law to include recreational instream flows. <br />Because Fort Collins involved a traditional dam impoundment structure", it was part of <br />the gradual shift in the definition of "diversion" under Colorado water law and not part of <br />"long- standing case law" eroding the diversion requirement as Appellee mistakenly asserts. <br />(AB, pp. 11 -12). In 1969, a subtle change occurred when the Legislature defined diversion <br />as removing water or controlling water in its natural course or location. §§ 148 -21 -3, C.R.S. <br />(1969); 148 -9 -1, C.R.S. (1963); 37- 92- 103(7). The "controlling water" language was never <br />intended to abrogate the diversion requirement, but rather was designed to include diversions <br />9 In Colorado, the constitution "obliterated the common -law doctrine of riparian rights" or <br />"continuous flow," and substituted in lieu thereof the doctrine of appropriation. Opper Lander <br />v. Left Hand Ditch Co., 31 P. 854, 856 (Colo. 1892); Sternberger v. Seaton, 102 P. 168, 169 _ <br />(Colo. 1909). Recreational instream flow rights are riparian in nature, and thus, have never <br />been a part of Colorado water law until SB 216. <br />10 Under this reasoning, any structure, including a boulder engineered into a stream bank <br />would constitute a diversion, as noted by the Legislature. (Exhibit 1, p. 1). <br />11 This Court merely recognized that "[a] dam certainly qualifies as a structure or device" <br />under section 37- 92- 103(7), even though it is not specifically listed as a means of diversion. <br />830 P.2d at 930. If, on the other hand, the dam incorporating the boat chute had allowed the <br />water to "continue[] to flow as it did prior to the renovation" then that dam structure would <br />not have controlled the water. Fort Collins, 830 P.2d at 932. <br />7 <br />
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