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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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seek," when C.M.R. 1.4.1(5)(d) unambiguously requires that the applying must <br />have already occurred, "the Applicant has applied." <br />Moreover, as a mere pledge to seek all necessary County permits, the <br />Stipulation fails to give meaning to C.R.S. § 34-32.5-115(4)(d), which implicitly <br />requires the MLRB to make a finding that the proposed operation is not contrary to <br />the regulations of Gilpin County. As a practical matter, in order to have any <br />meaning whatever C.R.S. § 34-32.5-115(4)(d) requires the MLRB to consider at <br />least enough of the applicable local permitting requirements to determine whether <br />a proposed mining operation would be contrary to law, "including but not limited <br />to all...local permits, licenses, and approvals, as applicable to the specific <br />operation." C.R.S. § 34-32.5-115(4)(d). <br />The Applicant's outright refusal to identify the permits it would seek is <br />puzzling in light of the testimony by Tony Petersen, Gilpin County's Director of <br />Community Development, regarding the specific applicable land use approvals <br />required to be obtained by the Applicant in order to conduct mining activity on the <br />property. His testimony indicates that there is no uncertainty about what permits <br />will be required, and the Applicant, upon mere consultation with the County, <br />would have learned the same. Mr. Peterson readily identified "special use permit <br />for mining," a grading permit, and an ISDS (individual sewage disposal system) <br />19 <br />
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