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PERMFILE40809
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PERMFILE40809
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Last modified
8/24/2016 10:43:39 PM
Creation date
11/20/2007 10:30:49 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M1988112
IBM Index Class Name
Permit File
Doc Date
3/14/1990
Doc Name
RESPONSE BRIEF OF BATTLE MTN RESOURCES INC TO COSTILLA CNTY COMMITTEE FOR ENVIRONMENTAL SOUNDNESS
Media Type
D
Archive
No
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An agency's Construction of the statute it is charged to <br />administer, or of its own regulations promulgated under express <br />statutory authority, is afforded great deference and will be <br />overturned only where it is plainly erroneous or internally <br />inconsistent. Orsin4er Outdoor Advertising inc. v. Department of <br />Highways, 752 P.2d 55 (Colo. 1988). Such deference is especially <br />appropriate where the agency's construction of the statute or <br />interpretation of the regulation is based upon expertise or <br />technical knowledge. See Roberts Constr. Co. v. United States <br />Small Business Admin., 657 F. Supp. 418 (D. Colo. 198''). <br />II. THE SOARD'8 FINDING THAT DISTURBANCE TO THS HYDROLOGIC <br />BALANCE 1fOIILD SE MINIMIZED WAS SUPPORTED SY SUHBTANTIAL <br />EVIDENCE. <br />Under the Mined Land Reclamation Act, the Board must determine <br />that "[d]isturbances to the prevailing hydrologic balance of the <br />affected land and of the surrounding area and to the quality and <br />quantity of water in surface and ground water systems both during <br />and after mining operation and during reclamation shall be <br />minimized." §34-32-116(7)(q) C.R.S. CES argues erroneously that <br />the Board must find that "the prevailing hydrologic balance of the <br />area will not be disturbed." Plaintiff's Brief at 13,14. In so <br />doing, CES overstates the standard for the Board's finding. The <br />Board need only determine that disturbances to the hydrologic <br />balance are minimized. <br />- 10 - <br />
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