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IV. Summary of the Argument <br />This de novo review of the MLRB's grant of a Section 112 Reclamation <br />Permit is an opportunity for this Court to give real meaning to the Construction <br />Materials Rules and the Reclamation Act, provisions of which the MLRB and the <br />district court have misconstrued and misapplied in granting the Permit. C Bar H, <br />Inc. v. Board of Health in and for Jefferson County, 56 P.3d 1189, 1192 (Colo. <br />App. 1992). In particular, this Court must take the opportunity to clarify how the <br />local land use permitting process coincides with and nevertheless interrelates with <br />the Reclamation Act permitting process despite the MLRB's staunch desire to <br />artificially sepazate the two processes. R. 3240-3241, Tr. 363:24-364:4; 364:15- <br />19; see also R. 3275, Tr. 398:13-17. By operation of the plain and unambiguous <br />language of C.R.S. § 34-32.5-115(4)(d), C.M.R. 1.4.1(5)(d), and C.M.R. 6.4.13, <br />the MLRB is obligated to confirm that local land use regulations are not ignored or <br />violated by the proposed mining operation. Yet, the MLRB failed to do so here, <br />and, in doing so, ignored the requirements of its own regulatory scheme. <br />Similarly, in employing a strained, informal, and unsupported interpretation <br />of the definition of the term "affected land," the MLRB failed to properly apply <br />definitions of that term contained in the Reclamation Act, at C.R.S. § 34-32.5- <br />103(1), and the Construction Materials Rules, at C.M.R. 1.1(3). As a result, the <br />ii <br />