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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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7/13/2012 4:34:01 PM
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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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In addition to increased use of the Park, the Water Court also found that the high flows <br />added additional economic value: "These higher flows attract the greatest number of users, <br />spectators, and competitive events." Id. In fact, Vail's "ability to continue to attract <br />competitions depends on the possible availability of high flows in the 400 cfs range." Id. Given <br />the foregoing, the Water Court was justified in holding that flows up to 400 c.f.s. are put to <br />beneficial use, are not wasted, and are reasonable. <br />ii. The Water Rights Are Also Reasonable In the Context of Gore Creek and the <br />Downstream Users <br />Proven beneficial use of the full amount of water requested is all that is typically required <br />to demonstrate reasonableness and a lack of waste. However, the Water Court further explained <br />the reasonableness and lack of waste in the specific factual context of Gore Creek and the <br />location of the Park relative to downstream use. Because the vast majority of the water is already <br />being called through the Park by downstream senior rights, a non - consumptive right such as the <br />Park's is one of the few new uses that could be decreed on such an over - appropriated stream. <br />(v.X, pp. 112-113). This is further reflected in the Water Court's findings that the Park will not <br />impact Colorado's Compact Entitlements, Decree at 6 -7, and undercuts the State's <br />unsubstantiated claims that the District is seeking to monopolize water. The District's water <br />rights simply protect Vail's investment by minimizing the extent to which the Park could be de- <br />watered by an upstream exchange by one of these downstream senior rights. <br />4. Appellants' Arguments on Duty of Water, Reasonableness, Waste and <br />Subjectiveness Are Unsupported By Existing Law and Record Evidence <br />The State and Northern's arguments opposing the fmding of reasonableness are virtually <br />identical to those already addressed by Breckenridge; thus, the District incorporates <br />Sb1549 -17- <br />
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