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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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Further, Plaintiffs misrepresent OSM's role in regulating coal mining in Colorado by <br />inferring that OSM has the final decision making authority related to permitting matters. <br />Colorado has been a primacy state since 1980. Therefore, the Board and Division, not OSM, <br />have exclusive responsibility to regulate coal permitting matters in Colorado. OSM may oversee <br />coal permitting, but it lacks the authority to direct the Division's permitting decisions. <br />Moreover, findings by OSM are not binding on the Division or WFC, nor are they immune from <br />appeal. In fact, the Division has informally contested some of the OSM findings that Plaintiffs <br />present as final, binding mandates from OSM. <br />Plaintiffs have improperly expanded the scope of review by asking this Court to consider <br />evidence and events that post -date the November 17, 2010 administrative hearing. Such request <br />should be rejected by the Court as contrary to the express language of the Act and the APA. <br />F. Objection to Request for Oral Argument <br />Defendants object to Plaintiffs request for oral argument. The Plaintiffs' arguments are <br />well documented and oral argument will not facilitate better understanding of the issues in <br />dispute. In addition to the extensive briefs, the Court can review the hearing transcript or the <br />administrative record for clarification. Oral argument is unnecessary and would only further <br />delay final resolution of this matter. Therefore, Plaintiffs' request for oral argument should be <br />denied. <br />G. Request for Attorney Fees and Objection to Plaintiffs' Request for <br />Attorney Fees <br />Defendants object to Plaintiffs request for costs and attorney's fees in this matter. <br />Plaintiffs have provided no justification as to why cost and attorney fees would be appropriate in <br />32 <br />
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