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2017-04-24_REVISION - C1981041 (2)
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2017-04-24_REVISION - C1981041 (2)
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Entry Properties
Last modified
4/25/2017 8:57:30 AM
Creation date
4/25/2017 7:33:25 AM
Metadata
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Template:
DRMS Permit Index
Permit No
C1981041
IBM Index Class Name
Revision
Doc Date
4/24/2017
Doc Name
Motion to Dismiss for Lack of Jurisdiction by Objector Fontanari Family Revocable Trust
From
James Beckwith
To
DRMS
Type & Sequence
TR69
Email Name
JHB
JRS
Media Type
D
Archive
No
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such lands are defined to include pasturelands and croplands and are not limited to simply <br />aquifers. All these post -mining uses are uses by the landowner and not the coal miner (assuming <br />the miner does not also own the land) and they most certainly are not for the administrative <br />agency. <br />The conflict in Board authority and jurisdiction now becomes clear. On the one hand, <br />reclamation is for the sole and express benefit of the private landowner: to restore usability of his <br />land to its prior use or an alternative use given the post -mining condition of the private land. <br />This benefit is conferred upon the private landowner by both statute and rule, as cited above. To <br />this end, the private landowner (a party that can be adversely effected by technical revisions, <br />permit revisions or other amendments) is authorized to file comments and objections to the mine <br />operator's proposed actions. On the other hand, if we believe Snowcap, §§34-33-115(1)(a) and <br />34-33-116(1) deny the private landowner any right or power to oppose, object to, seek denial of <br />or request alteration of the permit operator's proposed reclamation method. (Fontanari has <br />already raised, in its prior motion, the Board's lack of statutory authority to determine his <br />consent, or lack thereof, to the proposed "repair"). <br />The most fundamental element of Due Process is that the tribunal — whether court or <br />administrative — is a "competent tribunal": i.e., having the power to hear, consider and resolve, <br />all claims and defenses of all parties to a controversy. People v. Sandoval 383 P.M. 92, 101 <br />(Colo. App. 2016) (holding that an action taken by a tribunal lacking subject matter jurisdiction, <br />as an element of due process, is a nullity). Tulip Investments, LLC v. State ex rel Suthers 340 <br />P.M. 1126, 1133 (Colo. 2015) (subject matter jurisdiction concerns the tribunal's authority or <br />competence to hear or decide a case and is determined solely by the constitution or statutes.)A <br />tribunal that is empowered only to receive one party's arguments, but not the opposing <br />q <br />
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