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2019-11-27_REVISION - C1981041
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2019-11-27_REVISION - C1981041
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Last modified
12/27/2024 2:48:39 PM
Creation date
12/2/2019 9:21:59 AM
Metadata
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Template:
DRMS Permit Index
Permit No
C1981041
IBM Index Class Name
Revision
Doc Date
11/27/2019
Doc Name
Response to Board Order
From
Law Offices of John R. Henderson
To
DRMS
Type & Sequence
SL11
Email Name
CCW
JDM
Media Type
D
Archive
No
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defines the term, nor does it further explain what constitutes "issuance of the proposed <br /> decision[.]" <br /> The Board fills this silence through its regulations. The Board, in interpreting section 34- <br /> 33-125(6), determined that issuance would be defined using the proposed decision's first date of <br /> publication. Specifically, it required that requests for adjudicatory hearings "must be received <br /> within thirty (30) days of the first publication of the proposed decision by the Division." Rule <br /> 3.03.2(6)(a). <br /> Rule 3.03.2(6)(a) is a reasonable interpretation of an issue on which the Act was silent— <br /> the precise definition of"issuance" or "issuance of the proposed decision." Accordingly, the <br /> Board's interpretation is entitled to deference and the regulation should be upheld. Coffman v. <br /> Colo. Common Cause, 102 P.3d 999, 1005 (Colo. 2004). ("[W]e must give particular deference <br /> to the reasonable interpretations of the administrative agencies that are authorized to administer <br /> and enforce a particular statute.");Mile High Greyhound Park, Inc. v. Colo. Racing Common, 12 <br /> P.3d 351, 353-54 (Colo. App. 2000) ("If the statute is silent or ambiguous with respect to the <br /> specific issue, the inquiry becomes whether the agency's interpretation is based on a permissible <br /> construction of the statute. When the statute is implicitly silent as to the issue to be determined, a <br /> court may not substitute its own construction of a statutory provision for a reasonable <br /> interpretation made by the administrator of an agency."(citations omitted)). <br /> Snowcap makes no effort (nor could it) to claim that the Board's interpretation is <br /> unreasonable. Instead, it attempts to manufacture a discrepancy between the Act's use of <br /> "issuance" and the Board's use of first publication date to deny Fontanari his right to an <br /> adjudicatory hearing. Snowcap's efforts are unavailing. <br /> 3 <br />
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