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2013-03-22_REVISION - C1981008 (2)
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2013-03-22_REVISION - C1981008 (2)
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Entry Properties
Last modified
8/24/2016 5:18:46 PM
Creation date
2/20/2014 7:54:23 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1981008
IBM Index Class Name
Revision
Doc Date
3/22/2013
Doc Name
Joint Answer Brief of Defendents Colorado Mined Land Reclamation Board & DRMS 2010 CV548
From
DRMS
To
District Court, Montrose County Colorado
Type & Sequence
PR6
Email Name
DAB
Media Type
D
Archive
No
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presented, made its own evaluation of the evidence and concluded that PR -6 complied with the <br />requirements of the Act and Rules. R: 8479 -8481. Substantial deference is owed where, as here, <br />the agency resolves issues within its particular area of authority and expertise. Citizens for Clean <br />Air & Water v. Colo. Dep't of Pub. Health, & Env't, 181 P.3d 393, 397 (Colo. App. 2008). <br />The scope of the hearing was limited, by agreement of the parties, to four issues: 1) post <br />mining land uses, 2) topsoil resource management, 3) prime farmlands reclamation, and 4) public <br />participation10. R: 8461 -8462. As evidenced by the detailed final Order setting forth extensive <br />factual findings and legal conclusions, the Board carefully considered all four issues before <br />affirming PR -6.11 This decision is fully supported by substantial evidence and should be upheld. <br />1. Post Mining Land Use Approved in PR -6 is Supported by <br />Substantial Evidence <br />Plaintiffs generally argue that the Board's findings related to the post- mining land use <br />plans in PR -6 were arbitrary and capricious. Opening Brief, pp. 11 -12, 30. Plaintiffs disagree <br />with the Board findings, but they fail to identify what aspects of the Board's findings are <br />arbitrary or capricious and unsupported by the record. Plaintiffs fail to meet their legal burden <br />and wholly ignore the voluminous record upon which the Board based its decision. Under Rule <br />2.05.5, a plan of reclamation "shall contain a detailed narrative of the proposed use, following <br />reclamation of the land within the proposed Permit area ... the reclamation plan shall include a <br />10 Although in the Complaint at ¶20, Plaintiffs have not presented any arguments regarding <br />alleged deficiencies in the public process. Therefore, Plaintiffs abandoned these claims in this <br />appeal. <br />11 Findings by an administrative board may be express or implied from the facts. Colo. Ofc. of <br />Consumer Counsel v. Publ. Utils. Comm'n, 786 P.2d 1086 (Colo. 1990) (holding that upon <br />review of the record as a whole express findings on every point are not required). <br />14 <br />
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