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04SA44 Amici Curiae Brief
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Water Supply Protection
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Amici Curaie brief from the Rio Grande Water Conservation District in support of CWCB in the Upper Gunnison River Water Conservancy District's RICD Case No. 02CW038.
State
CO
Basin
Gunnison
Water Division
4
Date
7/26/2004
Author
Rio Grande Water Conservancy District
Title
04SA44 Amici Curiae Brief
Water Supply Pro - Doc Type
Court Documents
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Water judge refused to make these determinations because he believed that such limits would <br />infringe on the right to appropriate guaranteed by the Colorado Constitution. As will be shown, <br />the Water judge was incorrect. <br />B. The Water Court's Refusal to Limit the'RICD is Contrary to Long - Established <br />Water Law Principles. <br />The Water judge's refusal to limit the Applicant's determination as to the size and scope <br />of its water right for an RIM is not only inconsistent with the letter of section 37- 92- 103(10.3) <br />and purpose the of Senate Bill 216, but also with the doctrine of "maximum utilization of the <br />water of this state." Fellhauer v. People, 167 Colo. 320, 336, 447 P.2d 986, 994 (1968) <br />(emphasis in original); see also Alamosa -La Jara Water Users Protection Ass'n v. Gould, 674 <br />P.2d 914, 935 (Colo. 1983) ( "the objective of `maximum use' administration is `optimum <br />use."'). Appropriations for irrigation and municipal purposes are limited by how much the <br />appropriator can divert under reasonably efficient practices for a particular use: "A water right <br />comes into existence only through application of the water to the appropriator's beneficial use; <br />that beneficial use then becomes the basis, measure, and limit of the appropriation." Santa Fe <br />Trail Ranches Prop. Owners Ass'n v. Simpson, 990 P.2d 46, 53 (Colo. 1999). "Beneficial use," <br />as defined in section 37 -92- 103(4), includes four elements: The use must be an amount of water <br />that is (a) reasonable and appropriate (b) under reasonably efficient practices (c) to accomplish <br />the purpose for which the appropriation is lawfully made (d) without waste. For example, it has <br />been held that water users cannot command the entire flow of a stream to place a portion of the <br />stream to beneficial use. See City of Colorado Springs v. Bender, 148 Colo. 458, 462, 366 P.2d <br />552, 555 (1961); Empire Water & Power Co. v. Cascade Town Co., 205 F. 123, 129 (8th Cir. <br />1913); Schodde v. Twin Falls Land & Water Co., 224 U.S. 107, 117(1912). Significantly, while <br />15 <br />
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