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2003-07-17_REVISION - M1977534
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2003-07-17_REVISION - M1977534
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Last modified
6/15/2021 2:58:18 PM
Creation date
11/21/2007 11:36:39 PM
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Template:
DRMS Permit Index
Permit No
M1977534
IBM Index Class Name
REVISION
Doc Date
7/17/2003
Doc Name
Response to Comments from SEO
From
Porzak Browning & Bushong
To
DMG
Type & Sequence
AM1
Media Type
D
Archive
No
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<br />failed to meet its burden. The Objectors affirmatively proved by a preponderance <br />of the evidence (e) that injury will result and (b} that the tendered water does not <br />meet their normal use requirements. <br />30. No conflict exists between this Court's determination end the <br />determination by the Water Quality Control Division to issue a discharge permit <br />for the GWTP. The Division end the Court address different issues and answer <br />different questions, subject to different standards. The Division determines <br />whether to allow any discharge at all by balancing competing interests on the <br />stream. C.R.S. 525-8102(5). The Court determines whether to allow the <br />discharger to divert water it would not otherwise be entitled to take by furnishing <br />a substitute supply to users downstream. The Court considers the effects on <br />particular water users, and applies the standards of non-injury and suitability for <br />the normal uses of the receiving waters. C.R.S. 537-92-305(3) and (5). <br />31. A plan for augmentation is a water matter within the exclusive <br />jurisdiction oY the water judge. C.R.S. 537-92-302(1) and 537-92-203(1). The <br />Water Quality Control Division may not interfere with the jurisdiction of the <br />Water Court or take any action that would result in injury to water rights. C.R.S. <br />525-8-104. <br />32. The uses to be protected pursuant to C.R.S. 537-92-305(3) and (5); are <br />the actual uses that have normally been made of the receiving 'waters even if <br />those uses have not been decreed. The actual uses of water from Standley <br />Reservoir include use for municipal drinking water, as well as recreation and <br />irrigation. The decreed uses of water from Standley Reservoir include domestic, <br />irrigation, and municipal uses, as described in paragraphs 7-9 above. The Court <br />concludes that the GWTP effluent does not meet the quality requirements of the <br />actual or decreed uses of water from Standley Lake. <br />33. As a matter of law, the degradation of water quality identified in the <br />Findings of Fact above constitutes injury to the legally protected rights of the <br />Objectors. <br />34. Golden contends that its sewage is not a "substitute supply" es that <br />term is used in C.R.S. 537-92-305(5) and 537-80-120. Golden plans to divert out- <br />of-priority high quality water from Clear Creek that otherwise would go <br />downstream to fill the Objectors' decrees. in order to prevent injury to the <br />Objectors' in-priority water rights, Golden must replace 100 percent of its out~f- <br />priority diversions. Effluent from the GWTP would be counted, under Golden's <br />plan, as part of the water available to users downstream in lieu of the natural flow <br />of high quality water they would otherwise receive. In practical effect this is an <br />exchange and the sewage is part of the substitute supply. If the sewage is not <br />subject to the quality requirements, the result would be that downstream users <br />would receive water of a lesser quality than that to which they would otherwise be <br />entitled, to their injury. This is precisely the injury C.R.S. 537-92-305(5) and 537- <br />80-120 are intended to prevent. In order to prevent that injury, all of the water <br />returning to the stream for which credit is sought against the out-of-priority <br />diversion must meet all of the requirements necessary io prevent injury, including <br />the quality requirement. Even if C.R.S. 537-92-305(5) and 537-80-120 do not <br />-8- <br />
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