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Case No. 02SA224 Eagle River Water and Sanitation District Answer Brief February 2003
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Case No. 02SA224 Eagle River Water and Sanitation District Answer Brief February 2003
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Water Supply Protection
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Case No. 02SA224 Eagle River Water and Sanitation District Answer Brief February 2003
State
CO
Date
2/18/2003
Author
Porzak, Glenn E.; Bushong, Steven J.
Title
Case No. 02SA224 Eagle River Water and Sanitation District Answer Brief February 2003
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Court Documents
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D. The Amount of Beneficial Use is Directly Correlated to the Amount of Diversion <br />The amount of beneficial use is directly correlated to the amount of water diverted. The <br />undisputed testimony shows that because water is controlled up to 400 c.f.s., all the water is <br />being used to create the whitewater features. (v.XI, p.45,1.20- p.46,1.4). The record makes <br />abundantly clear that the more water in the Park, the more use it receives, thereby maximizing <br />the beneficial use. (v.X, p.56,1.12 -17; v.XI, pp.43 -46; 93). This directly translates into <br />economic benefit for the local community. In its first season, the Park hosted the Teva <br />Whitewater Festival, which received widespread local coverage and was broadcast on FOX <br />Sports Net to millions of homes nationally. (v.XI, p.76,1.11 -19; v.X, p.56,1.18 -26). <br />Approximately 3,000 spectators attended the Festival's whitewater rodeo event. (v.XI, p.77, 1.1- <br />5). Now the Park has become the anchor event for an even larger sporting event. (v.XI, p.76, <br />1.1 -10). The value of the Parkin its first year of use was conservatively estimated at $1.9 <br />million, and the Park has an estimated capitalized value of more than $20 million. (v.XI, pp.91- <br />92; v.IV, p.865). <br />E. Water is Available for Appropriation <br />Thomas Williamson, an expert water resource engineer, testified that the claimed flows <br />were available for appropriation. (v.X, pp. 109-110). The claimed rights are for no more than <br />400 c.f.s. which reflects the design capacity of the course. (v.X, p.109,1.21 -24) Maximum flows <br />in June from 1989 to 1999 exceeded 1,000 c.f.s. on four occasions and exceeded the claimed <br />amount of 400 c.f.s. every year. (v.X, p.109,1.10-12). Because the water use in the Park is non- <br />consumptive, the Park works in tandem with downstream water rights as the water is <br />immediately available for reuse. (v.X, pp.l l 1 -113). <br />Sb1549 -5- <br />
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