Case No. 01SA252 Motion for Leave to File a Breif as Amici Curiae April 2002

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February 27, 2002). The State Amici already own many millions of acre -feet of water rights for such traditional purposes as irrigation, municipal and industrial uses. Their concern in this matter is that non - consumptive, in- channel rights may interfere with future diversions for water- consumptive projects that are, today, not protected under the seniority of a conditional right. The State Amici join with the State to present the view that non - consumptive, in- channel use of water is a lesser form of water right as to which this Court should impose different standards. By contrast, the Amici identified in this motion (the "Conservation Amici") seek to inform the Court on the existing law that requires non - consumptive, in- channel rights to be treated the same as other rights for other purposes. The Conservation Amici are all conservation and recreation groups with one thing in common — an interest in having water flowing in rivers for environmental and recreational purposes. Each understands the importance of recreation and tourism to its members and Colorado's economy. Recreation and tourism represent the biggest and fastest growing industry in many parts of Colorado and the money generated from those businesses, both directly and indirectly, is critical to the state's long -term economic health. The Conservation Amici will assist the Court in understanding the ramifications and significant negative impacts that will result from the limitations on non - consumptive, in- channel rights urged by the State and the State Amici. In short, the above - listed Amici seeking to support Golden in this appeal will assist the Court in understanding how the ruling sought by the State and State Amici would be a dramatic departure from existing law and would seriously harm Colorado's "New West" economy and sensibilities. The Conservation Amici are able and willing to meet the briefing schedule applicable