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2012-04-27_GENERAL DOCUMENTS - C1981008
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2012-04-27_GENERAL DOCUMENTS - C1981008
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Last modified
8/24/2016 4:56:56 PM
Creation date
2/21/2014 9:53:41 AM
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DRMS Permit Index
Permit No
C1981008
IBM Index Class Name
General Documents
Doc Date
4/27/2012
Doc Name
Plaintiffs Response to Defendants Motion to Dismiss for Lack of Subject Matter Jurisd 2010 CV 367
From
Christopher G. McAnany Matthew A. Montgomery Dufford, Waldeck, Milburn & Krohn, LLP
To
District Court, Montrose County Colorado
Permit Index Doc Type
General Correspondence
Email Name
DAB
Media Type
D
Archive
No
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"an operator issued with any notice of violation or a cessation order pursuant to the <br />provisions of section 34 -33 -123 or any person having an interest which is or may be <br />adversely affected by such notice or order ... may request review thereof by the board <br />within ninety days..." Id. <br />In turn, Section 123 deals with notices of violation issued by DRMS following mine inspections, <br />and describes detailed administrative procedures for a mine operator following issuance of a <br />"written notice of violation" describing in detail the nature of the violation, potential penalties, <br />and "that the operator has the right to review of the notice or order in public hearing before the <br />board..." C.R.S. 34- 33- 123(4). Unmistakably, these sections deal with due process for mine <br />operators following notice of rule violations by DRMS. Thus, WFC relies upon provisions of <br />the SCMRA which have no applicability to the Federal oversight proceeding that was the subject <br />of the DRMS letter. On its face, the DRMS letter: a) is not a notice of violation under Section <br />123; b) does not appear to have been issued to Plaintiffs; and c) does not reference appeal rights, <br />as required by the plain language of the statute. Accordingly, this exhaustion argument rests on a <br />misapplication of the statute, and it fails as a matter of law. <br />4. EXHAUSTION OF REMEDIES IS NOT REQUIRED WHERE AN AGENCY <br />ADMITS THAT IT LACKS JURISDICTION TO GRANT THE REQUESTED <br />RELIEF. <br />Similarly, exhaustion of administrative remedies has not been required where it is beyond <br />doubt that further review would be futile because the agency will not grant the relief sought. <br />State v. Golden's Concrete Co., 962 P.2d 919, 923 -924 (Colo. 1989). In this case, a core issue is <br />that WFC mined through portions of the Morgan property without first complying with the <br />detailed regulatory scheme governing operations on prime farmland soils. This issue was raised <br />by Plaintiffs in the PR -06 permit revision proceeding, a proceeding which was specifically <br />focused on soil handling and reclamation practices in the wake of a determination by DRMS that <br />the Morgan property was prime farmland, and which was the subject of DRMS review, an appeal <br />N. <br />
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