My WebLink
|
Help
|
About
|
Sign Out
Home
Browse
Search
Case No. 02SA226 Town of Breckenridge Answer Brief February 2003
CWCB
>
Water Supply Protection
>
DayForward
>
5001-6000
>
Case No. 02SA226 Town of Breckenridge Answer Brief February 2003
Metadata
Thumbnails
Annotations
Entry Properties
Last modified
7/16/2012 9:02:18 AM
Creation date
7/13/2012 4:15:35 PM
Metadata
Fields
Template:
Water Supply Protection
Description
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
Water Supply Pro - Doc Type
Court Documents
There are no annotations on this page.
Document management portal powered by Laserfiche WebLink 9 © 1998-2015
Laserfiche.
All rights reserved.
/
116
PDF
Print
Pages to print
Enter page numbers and/or page ranges separated by commas. For example, 1,3,5-12.
After downloading, print the document using a PDF reader (e.g. Adobe Reader).
Show annotations
View images
View plain text
rights, and the right of the public to appropriate a water right "by a structure or device ... which <br />controls water within its natural watercourse." Id. at 930 -31. Simply stated, "[t]he exclusive <br />authority vested in the CWCB to appropriate minimum stream flows does not detract from the <br />right to put to beneficial use unappropriated waters by removal or control." Id. at 930. Thus, the <br />State's argument for why Fort Collins is no longer good law is based on the same argument <br />already raised, litigated, and rejected in Fort Collins. <br />iii. The Fort Collins Decision is Not a Narrow Exception Limited to Its Facts <br />As noted above, the Fort Collins decision simply reflects one application of the existing <br />statutory language that allows an appropriation when there has been in- channel control by some <br />structure or device. It is not a narrow exception to the law as suggested by the State. <br />First, this Court found the boat chute and fish ladder to be the controlling structure, not the <br />dam in which those structures were located. Id. at 932 ( "A chute or ladder therefore may qualify <br />as a `structure or device' which controls water in its natural course or location under section 37- <br />92- 103(7) "). There is no requirement that there be a pre- existing dam or that Fort Collins is <br />limited to a small notch in a dam. That would also be inconsistent with Section 103(7), which <br />provides for in- channel control by some "structure or device" in addition to a "reservoir." § 37- <br />92- 103(7). Second, the beneficial use was not limited to or decreed for "safe passage" as. the <br />State argues, but for "recreational and wildlife uses" including "kayaks and inner tubes." Fort <br />Collins, 830 P.2d at 932. Lastly, this Court did not limit its holding to some "unspecified low <br />flow" as the State implies. The reference to "unspecified low flow" was simply part of the Water <br />Court's holding, and that holding was reversed. Id. <br />The fallacy of the State's control argument is that it could be overcome by constructing the <br />Park parallel to the stream, and then diverting up to 500 c.f.s. of the river into that channel. <br />Sb 1546 -17- <br />
The URL can be used to link to this page
Your browser does not support the video tag.