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40 <br />1 board was acting under its continuing jurisdiction <br />2 over the original notice of violation or whether <br />3 this was a new proceeding, and there was hours of <br />4 debate about whether this was a new proceeding or <br />5 the old proceeding. <br />6 Basin's view is that you have authority <br />7 under the original NOV and its contest to have <br />8 acted all the way through this, and frankly, we <br />9 think you should say, We have jurisdiction over the <br />10 notice of violation, all the proceedings relate to <br />11 that, that's our basis for jurisdiction. <br />12 If your view of your jurisdiction is <br />13 different, I think the order needs to describe <br />14 that. I think you can decide that today and put it <br />15 in the order, but we need the know that. <br />16 We would also appreciate a description <br />17 of the statutory basis for this entire <br />18 reconsideration process because it's not apparent <br />19 to me from reading the statute or the regulations <br />20 the basis for which the board can sua sponte <br />21 reconsider its prior actions. So a description of <br />22 that would be useful and, I think, really give a <br />23 complete description of what's happened here. We <br />24 need all those thing decided sooner rather than <br />25 later. <br />