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2012-05-04_GENERAL DOCUMENTS - C1981008
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2012-05-04_GENERAL DOCUMENTS - C1981008
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Last modified
8/24/2016 4:57:19 PM
Creation date
2/21/2014 9:53:00 AM
Metadata
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Template:
DRMS Permit Index
Permit No
C1981008
IBM Index Class Name
General Documents
Doc Date
5/4/2012
Doc Name
Defendants Reply Brief in Support of Motion to Dismiss for Lack of Subject Matter Jurs 2010 CV 367
From
Christopher Kamper, Craig R. Carver, Carver, Schwarz, McNab & Baily, LLC
To
District Court Montrose County Colorado
Permit Index Doc Type
General Correspondence
Email Name
DAB
Media Type
D
Archive
No
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violation and cessation order," which it did not do in the instant case. CRS § 34 -33- 123(4). <br />Since Section 123 grants the Division the power to issue notices of violation and orders of <br />cessation, it perforce authorizes the Division to issue an order stating its "decision either not to <br />inspect or not to take enforcement action" as referenced in the Board's rules. Moreover, Rule <br />5.03.5 does not even refer to Section 123, but only refers to an "order or notice of violation." <br />This does not indicate a material difference between the language of the Board rule and that of <br />CRS § 34- 33- 124(1)(a), however it means plaintiffs had a right to review under the Board Rule if <br />not under the statute as they now interpret it. <br />Plaintiffs also ignore the federal regulations that control the very oversight process they <br />claim is at the center of their argument. Consider 30 CFR 842.11. Under subpart (b)(1)(ii)(B)(3) <br />of that regulation, the state authority receiving a TDN must take "appropriate action" to see that <br />a violation is corrected, or show "good cause" for not correcting it. Appropriate action includes <br />"enforcement or other action authorized under the State program." Thus, the TDN expressly <br />triggers the State program's enforcement powers. Good cause can include a finding that "the <br />possible violation does not exist." Id. at sub - subpart (B)(4). That is the finding issued in the <br />instant case. See, Opening Brief Exhibit 9 at 1 (describing Division action). This same <br />subparagraph authorizes the Division to state that it lacked jurisdiction over the alleged violation <br />(30 CFR 842.11(b)(1)(ii)(B)(4)(iii)), but the Division made no such finding nor was one required <br />by OSM even after extensive review of the record. Thus, the TDN triggered jurisdiction in <br />DRMS, which it exercised by conducting a records inspection as authorized by CRS § 34 -33 -122 <br />and by issuing an order authorized by CRS § 34 -33 -123 stating its decision not to take <br />enforcement action because it found no violation. <br />10 <br />
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