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Second Request to Remove Cease and Desist Order. Ex. F (GIR's Second Request to Remove <br /> Cease and Desist Order). The Division did not acknowledge receipt of GIR's Second Request to <br /> Remove Cease and Desist Order or otherwise respond to it. Again having heard nothing from the <br /> Division, on July 28, 2022, GIR submitted another request to the Division seeking the Division's <br /> removal of the Cease and Desist Order ("GIR's Third Request to Remove Cease and Desist <br /> Order"). Ex. G (GIR's Third Request to Remove Cease and Desist Order). <br /> On July 29,2022,the Division finally responded to GIR's prior requests.Rather than agree <br /> to remove the Cease and Desist Order based on GIR's compliance with the Division's own prior <br /> conditions for doing so,the Division stated "[d]ue to current circumstances the Division feels the <br /> decision to remove the Cease-and-Desist Order must be made by the Board" ("Division's July 29, <br /> 2022 Letter")Ex. H,p. 1 (Division's July 29,2022 Letter).The Division's July 29,2022 Letter did <br /> not elaborate on what "current circumstances" the Division believes exist that now require the <br /> Board,rather than the Division,to make a decision concerning the removal of the Cease and Desist <br /> Order. The fact remains that GIR has complied with all of the requirements imposed by the Board <br /> in its Cease and Desist Order and the additional requirements imposed by the Division to submit <br /> proof of water sampling tests to demonstrate compliance with the discharge permit from April <br /> through June 2022. In addition,GIR is otherwise in full compliance with all other requirements of <br /> its permit No. M-1977-410. <br /> II. The Board Should Remove the Cease and Desist Order <br /> A. GIR Has Complied with the Corrective Actions Set forth in the Cease and Desist <br /> Order <br /> As set forth above, GIR has complied with all of the substantive Corrective Actions set <br /> forth in the Cease and Desist Order,including: <br /> 4 <br />