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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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1.11 -16). In addition, attracting more boaters translates into more economic value. Decree at 5. <br />Thus, not only is the full 400 c.f.s. controlled and put to beneficial use, the increased diversions <br />are directly related to increased use and economic value. There is nothing subjective about these <br />measurable factors. <br />Moreover, underlying virtually any beneficial use of water is the preference of the <br />appropriator or end user. The size of lawns, the number of parks, the type of landscaping, the <br />length of fairways, and the amount of snowmaking on a ski run can all increase water demand <br />and are all based, in part, upon subjective preferences. That does not render the use unreasonable <br />in the eyes of the law. As already noted, reasonableness is determined in the factual context of <br />the beneficial use sought by the applicant. <br />iii. Reasonableness and Waste Require Are Determined on a Case by Case Basis, <br />Not Empirical Formulae, and there Are No Inconsistencies Between the District <br />and Golden Decrees <br />The State suggests that some empirical formulae for reasonableness and waste are <br />necessary. However, beneficial use is a question of fact and depends upon the circumstances in <br />each case. Thus, "courts have not tried to precisely define a reasonable amount." James N. <br />Corbridge & Teresa A. Rice, Vranesh's Colorado Water Law 47 (Rev. ed. 1999). Likewise, a <br />determination of "efficiency of use is made in each adjudication." Id. at 51. By examining the <br />extensive uncontested evidence, the Water Court made clear factual findings regarding the <br />reasonableness and efficiency of the District's application and concluded: <br />When tested against the intended purposes and the downstream reuses of this non- <br />consumptive water right as explained in paragraph 4H above, as well as the efficiency of <br />the diversion detailed in paragraph 4G above, the Court concludes that the 400 c.f.s. <br />claimed in May, June, and July and the lesser amounts claimed in the other months as set <br />forth in paragraph 417, are reasonable and there is no waste. <br />Decree at 6. <br />Sb 1549 -19- <br />
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