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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
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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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Board's finding and its approval of the Battle Mountain <br />permit. Mellow Yellow Taxi, at 20. <br />III. THE BOARD ACTED WITHIN ITB BTATQTORY AIITHORITY WHEN <br />IT APPROVED THE PERMIT APPLICATION BUSMITTED SY <br />BATTLE MOUNTAIN <br />CES argues that the MLRB acted in excess of its statutory <br />jurisdiction by approving an "incomplete" permit application. <br />In support of this argument CES alleges that Battle Mountain <br />failed to "indicate" the water rights and sources of water to <br />supply project water requirements, thus making the permit <br />application incomplete pursuant to Rule 2.1.2, 2 C.C.F.. 407- <br />1 of the MLRB regulations. CES states that, ". the <br />statutory requirement that an applicant minimize disturbances <br />to the hydrologic balance implies that the application must <br />fully disclose water information t0 enable the Board to <br />determine the degree of disturbance." CES' Opening Brief, pp. <br />9-10. A careful analysis of the plain language of the CMLRA, <br />the MLRB's Rules and Regulations, the record of the <br />proceeding, as well as the consistent policy of the MLRB with <br />respect to implementing its regulations demonstrates that CES' <br />argument is without merit. <br />A. The CMLRA Does Not Require That Water Rights Be <br />Obtained Before A Reclamation Permit Is Issued. <br />Neither the CMLRA nor the MLRB's Rulers and <br />Regulations make the acquisition of water rights a condition <br />precedent to MLRB consideration and approval of a reclamation <br />- 24 - <br />
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