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C <br />ARGUMENTS <br />I. THE RULES OF THE MLRD UNEQUIVOCALLY REQUIRE AN APPLICANT TO <br />INDICATE THE WATER RIGHTS AND WATER SOURCES WHICH WILL SUPPLY <br />PROJECT WATER REQUIREMENTS. <br />This appeal focuses primarily on MLRD Rule 2.1,2(6)(d), <br />2 C.C.R. 407-1, which states: <br />Maps and Exhibits <br />All information required in this section <br />shall be submitted with each of the <br />application forms. <br /> <br />The operator shall indicate the water rights <br />and sources of water to supply the project <br />water requirements. The sources of rights <br />shall be investigated by the board, utilizing <br />available sources to obtain the necessary <br />information in a timely manner prior to the <br />board's consideration of the application. <br />Together, the Mined Land Reclamation Board ("Board") anri Battle <br />Mountain Resources, Inc. ("Battle Mountain") struggle for more <br />than 50 pages to explain why the plain language of this rule does <br />not mean what it says.l <br />1 References to the response briefs of the Board and Battle <br />Mountain are by name and page. <br />