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2017-03-09_REVISION - C1981041
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2017-03-09_REVISION - C1981041
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Entry Properties
Last modified
3/29/2017 12:40:21 PM
Creation date
3/29/2017 12:24:57 PM
Metadata
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Template:
DRMS Permit Index
Permit No
C1981041
IBM Index Class Name
Revision
Doc Date
3/9/2017
Doc Name
Requests for Hearing before MLRB
From
Scott Schultz
To
DRMS
Type & Sequence
TR69
Email Name
JHB
JRS
Media Type
D
Archive
No
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The agency statute and its implementing regulation specifically require that the "board," <br />which is defined at C.R.S. § 34-33-103(4) as "the mined land reclamation board created pursuant <br />to section 34-32-105," hear any objections to a proposed decision on a technical modification to <br />a permit and set forth the timeline for that body to hold the hearing and render its decision. See <br />C.R.S. § 34-33-116(4); and 2 CCR 407-2:2.08.4(6)(b)(iii). The Colorado Mined Lands <br />Reclamation Board (the "Board") is a definite and distinct entity from DRMS. See Cold Springs <br />Ranch v. Dept. of Nat. Res., 765 P.2d 1035, 1036-37 (Colo. App. 1988). <br />The intent of the General Assembly is clear that that Board alone should hear the timely <br />objections of any person who asserts that they may be adversely affected by a proposed technical <br />revision to a permit. See C.R.S. § 34-33-116(4). Nowhere does the statute suggest that an <br />alternative procedure under C.R.S. § 24-4-105 of the APA may be substituted; rather the hearing <br />must be to the Board. Id.; see also Romer v. Bd. of County Commis of County of Pueblo, 956 <br />P.2d 566, 567 (Colo.1998) (absence of specific provisions or language in a statute "is not an <br />error or omission, but a statement of legislative intent"). Therefore, Fontanari and Carey's <br />demands for an evidentiary hearing to an ALJ must be denied. The law requires that the hearing <br />concerning their objections to the Proposed Order must be to the Board and in the manner <br />provided by the Regulations of the Colorado Mined Land Reclamation Board for Coal Mining, 2 <br />CCR 407-2. <br />B. Fontanari and Carey have failed to present any evidence or arguments <br />demonstrating that the Board, or its members, cannot act with integrity, honesty, or <br />impartiality with respect to the C.R.S. § 34-33-116(4) hearing on the objections to <br />the Technical Revision. <br />Fontanari argues that "the existing record ... clearly requires the appointment of a non- <br />DRMS hearing officer in order to protect the right to a fair and impartial hearing on the issues <br />
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