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<br />the earlier. <br />4. The doctrine of relation back, however, <br />stands in contrast to the Colorado <br />constitutional doctrine of appropriation of <br />water rights because it recognizes a water <br />right before satisfaction of the <br />fundamental requirement of actually putting <br />water to beneficial use. Hallford points <br />out the tension between the need to <br />recognize conditional water rights for <br />costly, long range water projects. and the <br />need to guard against speculation and <br />hoarding undeveloped water rights. <br />Hallford, Conditional Water Rights at 353. <br />Much of the Hallford article concerns a <br />recent trend in Colorado to strictly apply <br />the law of conditional water rights, and <br />perhaps to weed out some of the less viable <br />water projects in favor of better ones. <br />See especially C.R.S. Sections 37-92- <br />103 (3) (a) and 305 (9) (b); Trans-County <br />Water, Inc. v. Central Colorado Water <br />Conservancy District, 727 P2d 60 (Colo. <br />1986); Denver v. Colorado River Water <br />Conservation District, 696 P2d 730 (Colo. <br />1985); Southeastern Colora~o Wa~er <br /> <br />4 <br />