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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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are within what the Act and Rules require. R: 8478 -8479; Order, <br />p. 4 -5. <br />Accordingly, and contrary to Plaintiffs' arguments, the Board's affirmance of the post- mining <br />land use sections of PR -6 is not arbitrary or capricious as it is supported by substantial evidence <br />based upon the whole record, and it should be upheld. <br />2. Substantial Evidence Supports Topsoil Resource <br />Management and Prime Farmlands Reclamation Plans <br />Approved in PR -6 <br />Plaintiffs generally argue that the Board's findings related to topsoil management, soil <br />redistribution and prime farmland reclamation plans in PR -6 are arbitrary and capricious. <br />Plaintiffs disagree with the Board findings, but, once again, they fail to identify what aspects of <br />the Board's findings are arbitrary or capricious and unsupported by evidence in the record. <br />Plaintiffs fail to meet their legal burden and wholly ignore the voluminous record upon which the <br />Board based its decision. <br />Topsoil management plans must conform to the requirements of Rule 4.06 and, because <br />of the newly - designated prime farmland soils on the Morgan Property, PR -6 must also comply <br />with Rule 4.25. As considered by the Board, Permit section 2.05.4(2)(d), Topsoil Redistribution, <br />addresses these regulatory standards and Map 2.05.4 -4 displays the type, manner, and depth of <br />topsoil replacement in the permit area. R: 7854 -7857. In addition, to address the prime <br />farmlands requirements, WFC added Section 2.06.6, which provides references to the location(s) <br />in the Permit that address each prime farmland requirement. R: 7867 -7869. This information <br />was considered by the Division and Board prior issuing approval of PR -6. <br />19 <br />
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