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Case No. 01SA252 Motion for Leave to File a Breif as Amici Curiae April 2002
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Case No. 01SA252 Motion for Leave to File a Breif as Amici Curiae April 2002
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Case No. 01SA252 Motion for Leave to File a Breif as Amici Curiae April 2002
State
CO
Date
4/8/2002
Author
Kassen, Milenda R.; Zimmerman, Kathleen C.
Title
Case No. 01SA252 Motion for Leave to File a Breif as Amici Curiae April 2002
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STATEMENT OF ISSUE PRESENTED FOR REVIEW <br />Should this Court treat Golden's recreational use of water differently from other <br />beneficial uses based upon policy concerns that are either inapplicable to these facts or that <br />heretofore have not been applied through Colorado law? <br />STATEMENT OF THE CASE <br />The undersigned Amici adopt Golden's Statement of the Case. <br />SUMMARY OF ARGUMENT <br />Each of the undersigned amici is involved with the conservation of waterways for <br />environmental and recreational purposes. Thus, each supports the right of appropriators to put <br />water to non - consumptive, in- channel beneficial uses. Such rights, whether for recreational or <br />fishery purposes are an important manifestation of Colorado's water law's system flexibility and <br />are particularly necessary to sustain Colorado's new economy which is increasingly dependant <br />on recreation and tourism rather than on the agriculture or extractive industries that dominated <br />the state at the time it adopted its water law system. <br />An opinion overturning Golden's decree based on a finding that Golden's appropriation <br />either did not constitute a beneficial use or violated the state policy of maximum utilization of its <br />scarce water resources would change Colorado's water law system in ways that would hurt the <br />state's ability to respond to changing economic and social realities. Contrary to the position of <br />appellants and their amici, this Court has never before imposed a public interest test when <br />considering whether an applicant's use of water was beneficial. Certainly this Court has not <br />engaged in weighing one proposed use against another. <br />
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