My WebLink
|
Help
|
About
|
Sign Out
Home
Browse
Search
2012-05-04_GENERAL DOCUMENTS - C1981008
DRMS
>
Day Forward
>
General Documents
>
Coal
>
C1981008
>
2012-05-04_GENERAL DOCUMENTS - C1981008
Metadata
Thumbnails
Annotations
Entry Properties
Last modified
8/24/2016 4:57:19 PM
Creation date
2/21/2014 9:53:00 AM
Metadata
Fields
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
There are no annotations on this page.
Document management portal powered by Laserfiche WebLink 9 © 1998-2015
Laserfiche.
All rights reserved.
/
14
PDF
Print
Pages to print
Enter page numbers and/or page ranges separated by commas. For example, 1,3,5-12.
After downloading, print the document using a PDF reader (e.g. Adobe Reader).
View images
View plain text
Once the Division issues any "order or notice of violation" pursuant to its enforcement <br />power under CRS § 34 -33 -123, or any "termination or modification thereof," review may be <br />obtained by anyone whose interests are "adversely affected" thereby. CRS § 34- 33- 124(1)(a); 4 <br />CCR 407 -2, Rule 5.03.5. The right of review is thus not limited to direct recipients of the order. <br />Plaintiffs' arguments run into a brick wall when they attempt to deal with the Board's <br />express finding that it lacked jurisdiction to review their claims based on plaintiffs' failure to <br />seek timely review. Exhibit 8 page 3 120. As described in the Opening Brief, the Board <br />concluded it lacked jurisdiction to hear plaintiffs' claims because the plaintiffs failed to present <br />them within 90 days of the Division's determination, which was the issue Western Fuel briefed <br />to the Board in Exhibit 7. The Board's construction of its own rules in response to that briefing <br />is entitled to deference from this Court, and is also a determination that can only be challenged in <br />the companion case, 10 -CV -548. See, Argument Section III.C. below. <br />B. The Division's May 18, 2010 Letter Does Not Create Jurisdiction. <br />Next, plaintiffs reference a May 18, 2010 letter the Division sent to Western Fuels during <br />the course of its review of PR -06. Response Brief Exhibit A. The issuance date was within the <br />90 -day period when review by the Board of the Division's April 23, 2010 determination was still <br />available. That explains the Division's statement that "further review of the written record ... <br />may cause the Division to reassess its initial determination." Id. at 1 (emphasis added). <br />However, the Division never did so, and does not do so in the letter. In its last briefing to this <br />Court before it was dismissed, the Division stated: <br />Although the Division has continuing interest in this matter ... its interests are <br />limited to permitting and regulatory matters.... To date, the Division has not <br />found WFC to be in violation of the Act related to the removal and handling of <br />prime farmland soils. <br />11 <br />
The URL can be used to link to this page
Your browser does not support the video tag.