My WebLink
|
Help
|
About
|
Sign Out
Home
Browse
Search
2025-11-24_GENERAL DOCUMENTS - M1986123
DRMS
>
Day Forward
>
General Documents
>
Minerals
>
M1986123
>
2025-11-24_GENERAL DOCUMENTS - M1986123
Metadata
Thumbnails
Annotations
Entry Properties
Last modified
11/24/2025 9:26:08 AM
Creation date
11/24/2025 9:19:49 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M1986123
IBM Index Class Name
General Documents
Doc Date
11/24/2025
Doc Name Note
Petition For Reconsideration
Doc Name
Correspondence
From
Witwer, Oldenburg Barry & Groom, LLP
To
DRMS
Email Name
JR2
AME
CMM
Media Type
D
Archive
No
There are no annotations on this page.
Document management portal powered by Laserfiche WebLink 9 © 1998-2015
Laserfiche.
All rights reserved.
/
27
PDF
Print
Pages to print
Enter page numbers and/or page ranges separated by commas. For example, 1,3,5-12.
After downloading, print the document using a PDF reader (e.g. Adobe Reader).
View images
View plain text
In addition, for very good and well-established reasons, courts and other <br /> adjudicative bodies do not get involved in settlement negotiations. Thus, the <br /> Colorado's Rules of Evidence, the principles of which the Board is required to honor <br /> under DRMS Rule 2.8.1(2), have long considered evidence on offers to compromise <br /> to be inadmissible. See Colo. R. Evid. 408. Not only is such evidence irrelevant to <br /> the issue the Board should be deciding (i.e., whether the plan complies with DRMS <br /> Rules), but courts have also long understood that it is simply bad policy to consider <br /> such evidence because a court's intrusion into settlement negotiations will naturally <br /> chill the free and open discussions that best facilitate successful negotiations. <br /> Therefore, to the extent that the Board's decision was influenced by speculation as <br /> to the extent or reasonableness of the parties' settlement negotiations, it would be <br /> inappropriate for the Board to rely upon such a line of reasoning. <br /> As to the second rationale, it is also inappropriate for the Board to "simply move <br /> on" without determining whether or not all DRMS rules had been scrupulously <br /> followed. As discussed above, DRMS Rule 3.1.10(1) sets a high bar for successful <br /> revegetation: <br /> In those areas where revegetation is part of the Reclamation Plan, land <br /> shall be revegetated in such a way as to establish a diverse, effective, <br /> and long-lasting vegetative cover that is capable of self-regeneration <br /> without continued dependence on irrigation, soil amendments or <br /> fertilizer, and is at least equal in extent of cover to the natural <br /> vegetation of the surrounding area. <br /> Close examination of this rule reveals that it establishes a high bar in any situation, <br /> mandating"diverse, effective, and long-lasting vegetative cover that is capable of <br /> self-regeneration without continued dependence on irrigation, soil amendments or <br /> fertilizer." But the next clause in this Rule is perhaps most relevant in this case. It <br /> mandates revegetation that "is at least equal in extent of cover to the natural <br /> vegetation of the surrounding area." As discussed below in Part III and as well- <br /> illustrated by a proper interpretation of Exhibit A, the depth and quality of the <br /> topsoil that naturally existed on O'Brien property before mining is incredibly fertile. <br /> Therefore, it should not be surprising that it will naturally require high-quality and <br /> topsoil of an adequate depth to achieve vegetative cover that "is at least equal to" <br /> the adjacent, non-mined parts of O'Brien property. <br /> 6 <br />
The URL can be used to link to this page
Your browser does not support the video tag.