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PERMFILE52361
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PERMFILE52361
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Entry Properties
Last modified
8/24/2016 10:56:10 PM
Creation date
11/20/2007 3:18:32 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M2004067
IBM Index Class Name
Permit File
Doc Date
5/8/2007
Doc Name
Opening Brief
From
Court of Appeals
To
DRMS
Media Type
D
Archive
No
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activities occurring at the mining operation." C.M.R. 6.4.19(a) and (b}. The <br />interpretation of the term also deternunes the boundaries of the two hundred (200) <br />foot radius that identifies what property owners must be notified of the mining <br />application pursuant to C.M.R. 1.6.2(e)(ii). <br />At the core of the issue of the definition of the term "affected land" is the <br />question of whether, when properly applied, the statutory and rule-made definition <br />of the term includes State Highway 119, which must be upgraded by the addition <br />of turn lanes in order to accommodate quarry traffic. <br />The Highway Access Permit issued to the Applicant by the Colorado <br />Deparhnent of Transportation ("CDOT"), dated August 23, 2005, which is part of <br />the Application, included the condition that the Applicant must add acceleration <br />and deceleration lanes to State Highway 119. R. 980-88; 987, ¶ 34-35. The City, <br />along with other Objectors, has argued that under the plain language of C.R.S. § <br />34-32.5-103(1) and C.M.R. 1.1(3), these additional lanes constitute "substantial <br />upgrades" to State Highway 119, causing the highway to come within the <br />boundary of the "affected land." Vol. I, 137. The two hundred (200) foot radius <br />for C.M.R. 6.4.19 must be drawn from at least the mid-point of the Highway 119, <br />making the radius encompass additional significant man-made structures on Black <br />Hawk-Central City Sanitation District property that, under C.M.R. 6.4.19(a) and <br />9 <br />
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