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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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will be conducted by this Board? Ordinarily, Fontanari would turn to governing rules and <br />regulations to answer the question. However, this Board's rules do not provide an answer. <br />On the one hand, Rule 2.07.4(1) sets forth the hearing procedures for applications for <br />permits, permit revisions or permit renewals. Rule 2.07.4(3) specifies the procedures for formal <br />hearings and, Sub. (b) thereof states that the hearing will be conducted in accordance with C.R.S. <br />24-4-105. This statutory provision allows for subpoenas, discovery, and various pre -hearing <br />procedures. <br />On the other hand, however, the current proceeding involves an application for approval <br />of technical revision (TR) of Snowcap's Permit C-1981-041 relating to hydrologic problems <br />caused to Fontanari and Carey lands occasioned from subsidence caused by collapse of <br />underground coal caverns. C.R.S. 34-33-116 specifically relates to such applications. Similarly, <br />Rule 2.08.4(6)(b)(iii) specifically relates to TR applications and sets forth the hearing <br />procedures. Under the general maxim of "specific laws control over general laws", therefore, <br />Fontanari would turn to Rule 2.08.4(6)(b)(iii) for guidance. <br />That Rule, however, does not provide sufficient guidance. Unlike Rule 2.07.4(3)(b), rule <br />2.08.4(6)(b)(iii) does not incorporate Section 24-4-105 as the guiding standard for the hearing. <br />Nor does the 2.08.4 rule incorporate any portion of the Administrative Procedures Act. The <br />2.08.4 rule states that the hearing on the Proposed Decision on the TR application will be <br />"expeditiously set and conducts": but the definition of "expeditious" means the speed by which <br />one performs an act. The term, itself, does not include an amendment of, say, the general <br />hearing rule in Rule 2.07.4(3)(b) nor does "expeditious" mean that a new and different procedure <br />is adopted for TR applications. <br />2 <br />
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