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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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through application of the water to the appropriator's beneficial use." Id. at 53. "[B]eneficial use <br />is a broad concept and the characterization of a use as beneficial requires case by case factual <br />analysis." Zigan Sand & Gravel v. Cache La Poudre, 758 P.2d 175, 182 (Colo. 1988). <br />There should be no dispute that recreational boating can be a beneficial use. This Court <br />upheld recreational boating as a beneficial use in Fort Collins, 830 P.2d at 932, with specific <br />reference to "kayaks and inner tubes." Beneficial use includes "such newly evolved <br />appropriative uses as fish and wildlife, snowmaking, recreation, boat chutes, nature center <br />diversions and stream augmentation for rafting flows." Santa Fe Trail Ranches, 990 P.2d at 55 <br />n.13. In this manner, beneficial uses have evolved with the Colorado economy from mining, to <br />agriculture, and more recently to recreation and tourism. Nowhere is this more important than <br />for many West Slope towns and counties. (v.VII, p.162). <br />The State ignores this Court's expansive interpretation of beneficial use and argues that the <br />beneficial use statute expressly limits recreation to impoundments. State's Br. at 9. Essentially, <br />the State seeks to use the express statutory reference to recreation in order to curtail recreation. <br />The State contrives this argument by ignoring the expansive statutory language which reads that <br />a beneficial use "without limiting the generality of the foregoing, includes the impoundment <br />of water for recreational purposes, including fishery or wildlife." § 37- 92- 103(4) (emphasis <br />added). Clearly, the statute is not intended as a limitation to the potential beneficial uses that <br />otherwise meet the general requirements! Simply stated, beneficial use is a question of fact, <br />8 The State's argument is further inconsistent with the statutory definition of diversion which <br />expressly allows for in- channel control by a "reservoir ... or other structure or device." § 37 -92- <br />103(7) (emphasis added). Clearly, an impoundment is not the only way water may be controlled <br />in- channel for a beneficial use. <br />Sb 1546 -20- <br />
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