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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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other, so- called run -of -the -river facilities, do not. Rather, run -of -the -river facilities operate by <br />placing a structure, such as a weir, in the river channel; the structure then channels the river's <br />flow through power - generating turbines that are set either in or adjacent to the river channel.3 <br />Building structures to control water so that it flows through a turbine set in (or adjacent to) a <br />river channel is similar to building structures to control water so that it moves through a kayak <br />course set in (or adjacent to) a river channel. The structures are different, of course, but one can <br />achieve both purposes without consuming water. Moreover, calls from either type of user, while <br />they may limit certain upstream development, deliver water to downstream users. <br />Not only does Colorado law recognize non - consumptive uses, but Colorado has never <br />previously discriminated against such uses. State law provides for priority administration of <br />decreed hydropower rights, even though such rights are non - consumptive. Rocky Mountain <br />Power Co. v. White River Elec. Assn, 151 Colo. 45, 52, 376 P2d 158, 161 -62 (1962); Bd of <br />County Comm 'rs of County of Arapahoe v. Crystal Creek Homeowners Assoc., 14 P.3 d 325 <br />(Colo. 2000) (Arapahoe County 11). Similarly, in the Court's recent decision in Arapahoe <br />County II, the Court not only reiterated that flood control — another non - consumptive use —was a <br />beneficial use but also flatly rejected an argument that such use was waste. Id, at 339, citing <br />Pueblo West Metro. Dist. v. Southeastern Colo. Water Conservancy Dist., 689 P.2d 594, 603 <br />(Colo. 1984) (flood control is a beneficial use). Finally, Colorado recognizes recreation and fish <br />3 Xcel Energy's Shoshone Power Plant on the Colorado River above Glenwood Springs is an <br />example of a large run -of -the -river hydroelectric power plant in Colorado that operates <br />immediately adjacent to the river channel. For a description of the various types of hydroelectric <br />power plants, see Energy Matters, "Types of Hydroelectric Power Plants" (1998), <br />http: //Iibrary.thinkquest.org/ 20331 / types/hydro /types.html ?tqskipl= 1 &tqtime =0403, attached <br />hereto as Appendix D. For a more detailed description of run -of -the -river plants, see, Australian <br />CRC for Renewable Energy Ltd. http: / /wwwphys.murdoch.edu.au /acre /refiles/hydro /text.htn 1, <br />pp 8 -9 (2002) attached hereto as Appendix E. <br />E <br />
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