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Case No. 02SA224 Reply Brief March 2003
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Case No. 02SA224 Reply Brief March 2003
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7/13/2012 10:29:59 AM
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Water Supply Protection
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Case No. 02SA224 Reply Brief March 2003
State
CO
Date
3/17/2003
Author
Schneider, Susan
Title
Case No. 02SA224 Reply Brief March 2003
Water Supply Pro - Doc Type
Court Documents
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nE <br />reasonableness and waste as they relate to recreational instream flows in order to ensure <br />uniformity for future applications under SB 216. <br />V. This Court must reverse the water court's clearly erroneous <br />findings that whitewater features appear at flows below 200 c.f.s.. <br />The water court clearly erred in finding that whitewater features appear at flows under <br />200 c.f.s. Findings of fact by a trial court sitting without a jury will not be disturbed on <br />appeal unless clearly erroneous and not supported by the record. Vento v. Colorado Nat. <br />Bank- Pueblo, 907 P.2d 642 (Colo.App. 1995). These findings are clearly erroneous and <br />unsupported by the record. <br />If waste occurs where no whitewater features can be formed, as the Division 5 water <br />court held (v. VII, p. 1530), then the Appellee cannot obtain water rights for amounts below <br />200 c.f.s. if there is no support in the record that whitewater features appear below 200 c.f.s. <br />The finding that whitewater features appear at flows in excess of 30 c.f.s. is clearly <br />erroneous, and has no support in the record. <br />Appellee argues without any plausible support from the record that whitewater <br />features appear at 30 c.f.s. (AB, pp. 20 -21). If lows flows "function the same to control the <br />water for the intended beneficial use" as the high flows, then this Court should limit the <br />water right to that amount (as was done in the Fort Collins case) because that is enough water <br />to satisfy the purposes of Appellee. <br />However, Mr. Lacy, the course designer, provided the only evidence on the issue <br />when he testified that he was fairly certain that whitewater features occur at 200 c.f.s., but <br />probably not at any number below 200 c.f.s. (v. )U, p. 53). Despite this solid, undisputed <br />14 <br />
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