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07SA293 Advance Sheet Headnote The Water Right Determination and Administration Act of 1969 The Colorado Ground Water management Act beneficial use well appropriation
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07SA293 Advance Sheet Headnote The Water Right Determination and Administration Act of 1969 The Colorado Ground Water management Act beneficial use well appropriation
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11/10/2015 11:10:56 AM
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Water Supply Protection
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Colorado Supreme Court opinion regarding classifying use of water for coalbed methane production as a beneficial use.
State
CO
Date
4/20/2009
Title
07SA293 Advance Sheet Headnote The Water Right Determination and Administration Act of 1969 The Colorado Ground Water management Act beneficial use well appropriation
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Fe Trail Ranches Prop. Owners Ass'n v. Simpson, 990 P.2d 46, 58 <br />(Colo. 1999) ( "Our state legislature and courts . . . have never <br />accepted the proposition that water officials may determine the <br />water rights of citizens; this is a judicial function under the <br />adjudication statutes. "). Finally, we note that the Engineers <br />took no action with regard to diversions in this case. <br />We emphasize that determining the boundaries of "beneficial <br />use" requires careful case -by -case factual analysis, Zigan, 758 <br />P.2d at 182, and our holding today addresses the unique <br />circumstances involved in CBM production. The definition of <br />"beneficial use," however, is a "broad" one, see id., and we <br />agree with the Ranchers that it is broad enough to cover the <br />extraction of water to facilitate CBM production. In rendering <br />our decision, we observe that the General Assembly may choose to <br />make modifications to the statutes in light of our opinion.6 See <br />Sw. Colo. Water Conservation Dist., 671 P.2d at 1323 -24. <br />B. <br />The Engineers and BP argue that because "beneficial use" is <br />an ambiguous term, we should defer to the Engineers' <br />interpretation and hold that the extraction of water to <br />6 Although the Colorado Constitution subjects tributary water to <br />constitutional constraints, it does not define the term <br />"beneficial use." The General Assembly thus has authority to <br />define the term within those constraints, as it has done in the <br />1969 Act. <br />20 <br />
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