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various other regulatory and jurisdictional bodies that may be impacted by the <br />proposed mining activities. <br />If Applicant refuses to aclrnowledge what land use approvals are necessary <br />and, indeed, even hedges on the question of whether the Applicant recognizes the <br />County's authority to regulate its proposed mine, the MLRB could not determine, <br />as it is required to do so under C.R.S. § 34-32.5-115(4)(d), if the activity can be <br />lawfully conducted under the circumstances pursuant to Gilpin County's land use <br />regulations. Moreover, the vague language of the Stipulation leaves open for <br />interpretation whether the Applicant believes it must apply for any land use <br />approval at all, which is simply not an acceptable interpretation in light of the <br />unrefuted testimony from the County that at least three separate types of permits <br />are implicated here. <br />The MLRB's grant of the Permit under these circumstances is directly <br />contrary to the plain language of C.R.S. § 34-32.5-115(4)(d), C.M.R. 1.4.1(5)(d), <br />and C.M.R. 6.4.13 and amounts to the approval of an incomplete application <br />contrary to C.R.S. § 34-32.5-115(4)(a). <br />The interpretation of the law upon which the MLRB relies in an attempt to <br />justify this glaring inconsistency with the current requirements of the Rules and the <br />Reclamation Act is unavailing. During the hearing, Assistant Attorney General <br />zi <br />