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Members of the Mined Land Reclamation Board Page 3 To interpret the above-referenced statutory provision of subsection 34-32-111(7) 2, the primary goal is to effect the intent of the General Assembly. Water Quality Control Div. v. Casias, 843 P.2d 665 (Colo. App. 1992). To determine this intent, one first looks to the statutory language itself, giving words and phrases their commonly accepted meaning. Shapiro and Meinhold v. Zartman, 823 P.2d 120 (Colo. 1992). If the statutory language is clear on its face, one does not need to resort to interpretive rules of statutory construction. Snyder Oil Co. v. Embree, 862 P.2d 259 (Colo. 1993) Moreover, "forced, subtle, strained or unusual interpretation should never be resorted to where the language is plain, its meaning is clear, and no absurdity is involved." Harding v. Industrial Commission, 515 P.2d 95, 98 (Colo. 1973) With these statutory rules of construction in mind, it is my opinion that subsection 34-32-111(7) exempts governmental subdivi- sions from the requirements to pay application fees and provide financial assurances when applying for section 111 permits to construct public roads, whether in conjunction with the Department of Transportation or otherwise. However, it is my opinion that, by not referring to the section of the MLRA that requires annual fees to be paid by a permittee, the General Assembly did not intend to exempt counties or any other governmental entity from the payment of those fees. 3 ------------------------------------------------------------------ 1 While the Counties' letter refers to subsection 34-32-111(7), C.R.S., which is found in the MLRA, the opinion accompanying the letter refers to section 34-32.5-111(7) in the Construction Materials Act. There is no subsection 34-32.5-111(7) in the Act. However, subsection 34-32.5-111 (6) contains identical language in the relevant provision to subsection 34-32-111(7), and the following discussion is applicable to both acts, though the references in the rest of this opinion will be to subsection 34-32- 111(7), unless otherwise noted. It should be noted that the Construction Materials Act now governs all permits for construction materials, including existing county-operated sand and gravel operations. See ~ 34-32.5-109(1), C.R.S. (1995 Repl. Vol.) 2 Subsection 34-32.5-111(6) provides: " (c) A governmental subdivision shall be exempt from subpara- graphs (II) and (III) of paragraph (b) of subsection (2) of this section when such subdivision, acting as an operator, requires a permit solely to mine construction materials for the construction of public roads under a contract with the Department of Transporta- tion or otherwise." Like § 34-32-111(c) and (d), Subparagraphs II and III above require application fees and financial warranties. 3 I understand from discussions with the Minerals Program staff of the Division, that the State Department of Transportation pays annual fees for sand and gravel pits it uses for the construction of public roads.