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2013-03-22_REVISION - C1981008
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2013-03-22_REVISION - C1981008
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Entry Properties
Last modified
8/24/2016 5:18:46 PM
Creation date
2/20/2014 7:52:57 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1981008
IBM Index Class Name
Revision
Doc Date
3/22/2013
Doc Name
Answer Brief of Western Fuels Colorado 2010 CV548
From
Christopher Kamper, Stewart McNab Carver, Schwarz Mc Nab & Baily, LLC
To
District Court, Montrose County Colorado
Type & Sequence
PR6
Email Name
DAB
Media Type
D
Archive
No
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Walsh Report at R. 2616, last paragraph. No evidence was presented at the <br />hearing to challenge this conclusion. <br />19. In response to complaints made by Ms. Turner during the period <br />DRMS evaluated the PR -6 application, OSM issued a Ten Day Notice ( "TDN ") to <br />DRMS on April 6, 2010 to investigate Ms. Turner's allegations that Western <br />Fuels - Colorado was operating in violation of the Colorado Coal Program. By <br />letter dated April 23, 2010, DRMS responded to OSM: "Western Fuels — Colorado <br />is in compliance with Permit No. C- 1981- 008." R. 8531, 2nd paragraph. Plaintiffs <br />did not appeal this finding within the 90 day time limit provided by C.R.S. § 34- <br />33- 124(1)(a). DRMS never issued a Notice of Violation, never indicated there was <br />a basis for such a notice, and never followed any of the procedures provided <br />pursuant to C.R.S. § 34 -33 -123. <br />20. In the Plaintiffs' companion citizen suit (10 -CV -367), which was tried <br />in November 2012, Judge Ossola ruled that 20,000 cubic yards of topsoil had been <br />removed from the Morgan property. See Exhibit A at p. 7, last paragraph. Judge <br />Ossola specifically found that the plaintiffs' assertion that 190,000 cubic yards of <br />soil had been removed was not supported by the evidence in the case. Id. Judge <br />Ossola also found that a remedy of ordering Western Fuels - Colorado to import soil <br />from another location was not a practical remedy. Id. at p. 8, 2d paragraph. The <br />100145923 2 ; 10 <br />
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