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2012-03-30_GENERAL DOCUMENTS - C1981008
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2012-03-30_GENERAL DOCUMENTS - C1981008
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Last modified
8/24/2016 4:55:41 PM
Creation date
2/21/2014 9:54:09 AM
Metadata
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Template:
DRMS Permit Index
Permit No
C1981008
IBM Index Class Name
General Documents
Doc Date
3/30/2012
Doc Name
Defendants Brief in Support of Motion to Dismiss for Lack of Subject Matter Jurisd 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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Colorado has been a primacy state since 1979. See, L. 79, p. 1254 § 1, effective July 1, <br />1979. Among the duties and purposes spelled out in the enabling statute of the Coal Program are <br />the following: <br />It is the further intent of the general assembly by the enactment of this article to <br />protect society and the environment from the adverse effects of surface coal <br />mining operations, assure that the rights of surface landowners and other persons <br />with a legal interest in the land or appurtenances thereto are fully protected from <br />such operations. <br />CRS § 34 -33 -102. <br />In exercising its delegated powers to regulate coal mining, the Division has accumulated <br />years of experience with coal mining and reclamation. Plaintiffs have admitted that the technical <br />questions of fact in this controversy related to mining and reclamation of Prime Farmlands are <br />"uniquely within the expertise and experience of DRMS." Plaintiffs' Response to Colorado <br />Division of Reclamation, Mining and Safety's Motion to Dismiss Itself as a Party Defendant, <br />Civil Action No. 10 -CV -367, filed May 3, 2011, page 3 113. Thus, DRMS and the Board have <br />both the expertise and jurisdiction to remedy claims of violations of regulations of the Colorado <br />Coal Program. <br />In exercising its expert judgment and jurisdiction, the Colorado Coal Program arms the <br />Division and Board with a formidable arsenal of regulatory weapons. For example, <br />[If] an authorized representative of the [Division] determines that any condition or <br />practices exist at a surface coal mining operation which is subject to this article or <br />that any operator is in violation of any requirement of this article or any permit <br />condition required by this article, which condition ... is causing or can reasonably <br />be expected to cause significant imminent environmental harm to land, air, or <br />water resources, such authorized representative ....shall, in addition to the <br />cessation order, impose affirmative obligations on the operator requiring <br />operator to abate the imminent danger or the significant imminent environmental <br />harm. <br />10 <br />
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