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ENFORCE22351
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Last modified
8/24/2016 7:32:06 PM
Creation date
11/21/2007 10:09:33 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1981013
IBM Index Class Name
Enforcement
Doc Name
BRIEF OF BASIN RESOURCES INC IN RESPONSE TO PLAINTIFFS APPLICATION FOR TEMPORARY RELIEF
Violation No.
CV2000009
Media Type
D
Archive
No
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evidence to the Board at the hearing on its motion substantiatin¢ its claim that the vacation of the <br />NOV created significant prejudice to Basin Resources, including the risk of future enforcement <br />action. Indeed, the Division, which opposed the motion, admitted in its brief that Basin <br />Resources faced potential injury if the Division issued another subsidence-related NOV in the <br />future. See Response of Division of Minerals and Geology to Motion of Basin Resources to have <br />the Notice of Violation Adjudicated or, in the Alternative, Vacated with Prejudice (attached as <br />Exhibit B). The record in this matter therefore supports Basin Resource's claim and the Boazd's <br />conclusion that Basin Resources is or may be adversely affected by the vacation of the NOV. <br />Thus the Board had jurisdiction over the motion of Basin Resources both under its <br />general jurisdiction to review Division actions relating to Notices of Violation, and under the <br />specific provisions of the Coal .4ct authorizing Basm Resources to seek review of the vacation of <br />an NOV. <br />2. The Board's Order is Consistent with Law. <br />The Plaintiffs assert that the Board's decision was "arbitrary, capricious, unsupported by <br />substantial evidence, and otherwise inconsistent with law in that, as a matter of law, DMG has <br />the inherent and statutorily-implied authority to vacate any notice of violation that the agency <br />issues, without consulting with or obtaining prior approval of the Board." Application at § 21. <br />An agency interpretation that is in conformity with the statute and reasonably supported by the <br />agency's reasoning and record is entitled to great deference. Kramer v. Department of Revenue, <br />964 P.2d 629, 631 (Colo. App. 1998). Indeed, agency action will be found to be arbitrary and <br />capricious only when a reasonable person would be compelled [o reach a different conclusion. <br />Wildwood Child and .Adult Care Proeram, ]nc. v. Colorado Department of Public Health and <br />-~- <br />
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