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processes ~, and his out-right denial of the County's legitimate regulatory authority is directly relevant to whether the Applicant will be successful in obtaining the three or more required County permits. Further, the Applicant's inability to show that Mr. Wolf will cooperate in the County permitting process directly implicates one of the statutory grounds for denial of a 112 permit application: The proposed mining operation...is contrary to the laws or regulations of this state or the United States, including but not limited to all federal, state, and local permits, licenses, and approvals, as applicable to the specific operation. Section 34-32.5-115(4)(d), C.R.S. (emphasis added). Unless the Applicant obtains Mr. Wolfls cooperation in completing the County permitting process - a thing that the City will show, through its exhibits and witness testimony, is highly unlikely -this application will be contrary to the local land use laws. III. Reply to Division's Response to City's Motion for Conditions Due to time constraints and the City's desire to attempt to comply with the filing requirements set forth in C.M.R. 2.6(1), the City hereby reserves its right to reply to the Division's Response to the City's Motion for Conditions through witness testimony during the formal board heazing. IV. Response to Division's Request to Strike a Portion of its Rationale At this late date it is prejudicial to the objectors for the Division to attempt to modify the rationale that has formed the basis of every parties' prepazation in this matter. Further, and contrary ~ The City has attempted to subpoena Mr. Wolf to testify as a witness at the formal board hearing, and has been unsuccessful despite numerous attempts at service. The City knows Mr. Wolf was aware of its efforts and believes Mr. Wolf was actively evading service. The exhibits in question are meant to take the place of Mr. WolFs direct 3