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a duty to provide emergency services to along State Highway 119 including the <br />proposed quarry site. R. 1258-13284. <br />As relevant to the City's appeal of the grant of the Permit, the City takes <br />particular issue with how the MLRB has misapplied and misinterpreted its own <br />regulations in violation of various provisions of the Construction Materials Rules <br />and the Reclamation Act. R. 3259, Tr. 382:7-384:6. With a vested interest in <br />Gilpin County land use, the City has paid particular attention to the Applicant's <br />overt unwillingness to abide by the Gilpin County's land use permitting process, <br />which undisputedly will require a Gilpin County use by special review permit as <br />well as various other permits for the quarry site. R. 3023, Tr. 146:9-10; Tr. 148:2- <br />9. The City is also keenly aware of the MLRB's refusal to require, in violation of <br />the Rules and the Reclamation Act, compliance with the local permitting process. <br />Vol. I, 133. <br />Consistent with C.R.S. § 34-32.5-115(4)(d) of the Reclamation Act, C.M.R. <br />1.4.1(5)(d) requires that the Applicant affirmatively state that it "has applied for all <br />necessary approvals from local government." (Emphasis added.) Yet, it is <br />undisputed that Applicant has not applied for any approval from Gilpin County. <br />° The City's Motion for Determination of Standing, cited here, was never ruled on by the MLRB because the matter <br />of the City's standing as a party was resolved by stipulation of the parties. R. 2884, Tr. 7:12-25. <br />6 <br />