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PERMFILE64575
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PERMFILE64575
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Entry Properties
Last modified
8/24/2016 11:10:31 PM
Creation date
11/20/2007 8:27:14 PM
Metadata
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Template:
DRMS Permit Index
Permit No
M1988112
IBM Index Class Name
Permit File
Doc Date
3/14/1990
Doc Name
ANSWER BRIEF OF THE MLRB
Media Type
D
Archive
No
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"uncertain and speculative" (Opening Brief, p. 14). Hut even so, <br />CES offers no explanation of its contention that the Board cannot <br />rely on "uncertain and speculative" evidence. The Hoard is in <br />the business of issuing permits based on its understanding of <br />what is likely to occur in the future. Each of the general <br />requirements set forth in § 34-32-116(7), C.R.S. (1984 & 1988 <br />Supp.) require the Board to forecast, to some extent, how a pro- <br />posed mining pl<<n will unfold in the future. Accordingly, the <br />proposition urged by CES is not only inconsistent with the case <br />law concerning the standard of judicial review, it also is incon- <br />sistent with the statutory scheme set up by the Act. <br />The third error in CES's argument is the most profound. <br />CES contends that the statutory directive to minimize the <br />hydrologic balance requires the Board to assess the impact the <br />project will have on the water rights of other users in the sys- <br />tem. The Board clearly rejected that contention at the hearing <br />and focused its inquiry into the hydrologic balance on the threat <br />of environmental harm and the likelihood of unanticipated deple- <br />tions of the surface and ground water systems (r. v. 3, pp. <br />561-565). <br />It is reasonable for the Hoard to decline to insinuate <br />itself into Colorado's system of prior appropriation. Section <br />34-32-116(7)(q), C.R.S. (1989) certainly does not, on its face, <br />require the Hoard to evaluate water rights. CES's argument is <br />based solely on the meaning of the phrase "hydrologic balance," <br />-15- <br />
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