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2013-01-29_REVISION - C1981008
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2013-01-29_REVISION - C1981008
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Entry Properties
Last modified
8/24/2016 5:12:31 PM
Creation date
2/20/2014 7:55:50 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1981008
IBM Index Class Name
Revision
Doc Date
1/29/2013
Doc Name
Paintiffs Opening Brief 2010 CV 548
From
Christopher G. McAnany Dufford, Waldeck, Milburn & Krohn, LLP
To
District Court, Montrose County Colorado
Type & Sequence
PR6
Email Name
DAB
Media Type
D
Archive
No
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process also demands that reasonable procedural accommodations be made were <br />necessary because of unforeseen circumstances, particularly where the evidence is <br />highly relevant and probative of a central issue in the proceeding. Indeed, the <br />Administrative Procedures Act provides that when necessary to ascertain facts <br />affecting substantial rights of a parry, the adjudicatory body can receive evidence not <br />otherwise admissible under rules of evidence if it is sufficiently probative. C.R.S. § <br />24- 4- 105(7). <br />Here, the Boyd and Dearstyne letters were highly probative and should have <br />given pause to DRMS and the Board. Indeed, the objection by counsel for DRMS <br />suggests that the agency was less concerned about fact finding than in defending its <br />position. In relevant part, Mr. Boyd noted that the native Barx topsoil on the Morgan <br />Property is "very agriculturally productive soil because of its chemical and physical <br />properties, primarily: depth greater than or equal to 40 inches; near zero rock fragment <br />percentage; near neutral pH; low salt content; and well draining texture." R. 8446. <br />Further, Mr. Boyd noted that if applicable regulations require soils to be reclaimed to <br />its original condition pre- mining, then "the topsoil replacement material and methods <br />being used and proposed in Permit Revision #6 would not meet soil criteria <br />established for Land Capability Classification IIe, which Barx soil falls into." Id. In <br />26 <br />
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