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1 ORRICK, DAHLQUIST, HERRINGTON & SUTCLIFFE
405 Montgomery Street
2 San Francisco 4, California
Telephone: EXbrook 2-1120
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Attorneys for Protestant
4:Sierra Pacific Power Company
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BEFORE THE STATE WATER RIGHTS BOARD OF THE
STATE OF CALIFORNIA
11 In the Matter of the Application of
12 MEYERS WATER COMPANY
13 to appropriate unappropriated.water.
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16 PROTEST OF
17 SIERRA PACIFIC POWER COMPANY
Application
No.18038
In
19 The undersigned, SIERRA PACIFIC POWER COMPANY, a
20 corporation (hereinafter called "Protestant"), respectfully
21 protests the granting of the Application for a permit to appro-
'22 priate unappropriated water filed herein and dated February 28,
23 1958, and in support of such Protest states as follows:
24 10
75 Protestant is a corporation duly organized and
26 existing under the laws of the State of Maine; the address of
27 Protestant is 229 South Virginia Street, Reno, Nevada; the
2.8 address of Protestant in California is care of Orrick, Dahlquist,
29 Herrington & Sutcliffe, 405 Montgomery Street, San Francisco 4,
30 California.
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1 II
2 Protestant has read Notice of Application to Appro-
3 priate Water published by the State Water Rights Board and
4 dated June 27, 1958, relating to the above entitled Application
and hereby states that itis the owner of rights to the use of
6 water in Lake Tahoe and the Truckee River and their tributaries
7 and is and for many years last past has been in the exercise of
6 said rights.
9 III.
10 Protestant now uses and for many years last past
11 has used said water for the purposes of (a) generating electric
12 power to its five plants on the Truckee River known; respectively,
13 as Farad Plant, Fleish Plant Verdi Plant, Washoe Plant and
14 Reno Plant; (b) domestic use in the Cities of Reno and Sparks;
15 and (c) irrigation use upon lands lying under and contiguous to
16 the Highland Ditch in the State of Nevada. For a particular
17 description of said rights and for a statement of the points at
18 which diversion is made by Protestant, Protestant refers to and
19 makes part of this Protest the Final Decree in the action in the
20 District Court of the United States, in and for the District
21 of Nevada entitled, "The United States of America, plaintiff,
i2 vs. Orr Water Ditch Company, et al.", Equity Docket No. A-3,
23 and also the Final Decree in the proceeding in the District Court
24 of the United States in and for the Northern Pistrict of Cali -
25 fornia, Second Division, entitled "The United States of America,
26 plaintiff, vs, The Truckee River General Electric Company, a
L7 corporation, defendant", copies of which Decrees are on file
28 herein, Protestant is also the owner of various riparian rights
49.. in California upon the Truckee River and its tributaries.
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2 All of the water in Lake Tahoe is necessary to satis-
3 fy the storage requirements in Lake Tahoe, as set forth in said
4 Final Decrees, and to satisfy the rights of Protestant above
5 referred to. All of the waters in Lake Tahoe and its tribu-
taries are fully appropriated and are required in order to
'7 satisfy such appropriations and no basis for further appropriation
8 exists. If said proposed, appropriation is made the same will
result in injury to Protestant for the reasons hereinabove stated.
10 V.
11 Protestant has served a duplicate copy of the within
12 Protest upon Applicant by certified mail.
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14 WHEREFORE, Protestant prays that said Application of
15 Applicant be denied.
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17 DATED: July 3 , 1958.
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SIERRA PACIFIC POWER COMPANY,
Protestant
By 214.1 aseaift
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%•'IT, �INGTO & SIITr✓ LIFFE
Its Attorneys
JUL 8 2 149 PH '58
STATE WATER RIGHTS BOARD
SACRAMENTO
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