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Case No. 02SA226 Town of Breckenridge Answer Brief February 2003
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Case No. 02SA226 Town of Breckenridge Answer Brief February 2003
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Water Supply Protection
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Case No. 02SA226 Town of Breckenridge Answer Brief February 2003
State
CO
Date
2/18/2003
Author
Porzak, Glenn E.; Bushong, Steven J.
Title
Case No. 02SA226 Town of Breckenridge Answer Brief February 2003
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Court Documents
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v. Hanson, 173 Colo. 239, 242, 477 P.2d 453, 454 (1970). This deference extends to "[a]ny <br />inferences or conclusions drawn by a trial court" from the evidence as well. Assocs. of San <br />Lazaro v. San Lazaro Park Props., 864 P.2d 111, 115 (Colo. 1993). "The trier of the fact alone <br />determines the weight of the evidence." Moseley v. Smith, 170 Colo. 177, 180, 460 P.2d 222, <br />223 (1969). As described herein, not only does the trial record support the Water Court's <br />findings, the evidence was often undisputed. <br />B. Breckenridge Met the Legal Requirements to Obtain Conditional Water Rights <br />In granting Breckenridge conditional water rights for the Park's fifteen control structures, <br />the Water Court applied the existing law to the undisputed evidence. In order to obtain a <br />conditional water right, the applicant must demonstrate: (1) that it has made the first step toward <br />the initiation of the decree, which includes a showing of intent and overt acts, Bijou Irrigation, <br />926 P.2d at 32; (2) that it can and will divert water to beneficial use and complete the project <br />within a reasonable time, § 37- 92- 305(9)(b); and (3) that unappropriated water is available. <br />Aspen Wilderness Workshop v. Hines Highlands, 929 P.2d 718, 724 (Colo. 1996). The Water <br />Court applied these factors and found each satisfied by Breckenridge. Decree at 4, 7. <br />The undisputed evidence supports these findings. Specifically, Breckenridge intended to <br />draw visitors and events to the Town during the non -ski season. (v.VII, pp.37 -38). Building a <br />world -class whitewater park was critical to accomplish that goal and water rights were necessary <br />to protect the investment in the Park. (v.VII, pp.37 -38, 58 -59). Breckenridge manifested its <br />intent by appropriating $419,000.00 for the Park's two phases (v.VII, p.63), obtaining all <br />required approvals and permits, including a federal 404 Permit (v,VII, p.66), hiring a course <br />designer (v.VII, p.39), constructing the Park (id.), and filing a water rights application. (v.VII, <br />Sb1546 -8- <br />
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