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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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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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The State also argues that the Water Court erred "in granting a water right for months <br />where the evidence showed there was no use." State's Br. at 24. First, the State ignores the <br />record evidence that use did, in fact, occur every month even if reduced by low flows, (v.X, pp. <br />55 -56; v.XI, pp.43 -44, 88), and elsewhere in its Brief acknowledges that fact. State's Br. at 3. <br />Second, and more importantly, the State completely misunderstands the nature of a conditional <br />water right. The District could have applied for a conditional water right before the Park was <br />even constructed. At the time of trial, the Park had operated only one summer during an <br />extremely dry year. Reduced use of the Park during August, September, and October of 2001 <br />when flows were low does not mean the water right should be denied for those months, as the <br />State asserts. If anything, the reduced use demonstrates the importance of flow in maximizing <br />use and the necessity of a water right to maintain the value of the Park. <br />As with any conditional water right, future diligence proceedings will determine the extent <br />to which the District's water right has been made absolute. See Metropolitan Suburban Water <br />Users Ass'n v. Colo. River Water Conservation Dist., 365 P.2d 273, 288 (Colo. 1961). Vail and <br />the District have invested considerable time and money in constructing the Park structures and in <br />adjudicating the conditional water rights ($290,000 at the time of trial). (v.X, p.42,1.6 -7). As <br />noted in Metropolitan Suburban, "[i] f they have. miscalculated and fail, the loss is theirs - -if they <br />succeed, it will be for the eternal benefit of the peoples of the state of Colorado." Metropolitan <br />Suburban, 365 P.2d at 288. <br />C. The Park Structures Control Water in the Channel as Required for an Appropriation <br />The Water Court applied existing law regarding control and diversion in finding that the <br />Park structures concentrate and control water in the natural stream at flows up to the maximum <br />amount for which the District applied. That finding is well- supported by the record. The District <br />Sb 1549 -10- <br />
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