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ENFORCE34652
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ENFORCE34652
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Entry Properties
Last modified
8/24/2016 7:44:30 PM
Creation date
11/21/2007 2:17:57 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1981013
IBM Index Class Name
Enforcement
Doc Name
MLRB COMBINED MOTION TO DISMISS AND RESPONSE TO PLAINTIFFS APPLICATION FOR TEMPORARY RELIEF
Violation No.
CV2000009
Media Type
D
Archive
No
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notice of violation is only implied by operation of the statute's grant of authority to the Boazd to <br />hold hearings on notices of violations. <br />The statute states that `'[a]n operator issued a notice of violation ...may request review <br />thereof by the board within ninety days after the issuance of the notice ... or within ninety days <br />after its modification, vacation, or termination." § 34-33-124(1)(a), C.R.S. Because the starute <br />affords an operator the opportunity to appeal a vacation of a notice of violation to the Board, it is <br />a logical conclusion that the language therefore gives rise to an implied authority on the part of <br />the Division, at ]east in some cases, to vacate a notice of violation. <br />The statute goes on to say, however, that "[u)pon receipt of [a] request for a hearing, the <br />hearin¢ shall be held ...." § 34-33-124(1)(a), C.R.S. (emphasis added). It is this language that <br />lies at the core of the cturent dispute. The Boazd interprets the mandate that a hearing "shall be <br />held" when an operator or other party so requests to mean that, once a request for hearing on a <br />notice of violation is submitted pursuant to § 34x3-124(])(a), C.R.S., the Board's jurisdiction <br />over the final disposition of that notice of violation has been invoked in the same way that this <br />Court's jurisdiction is invoked upon the filing of a complaint and answer in a civil action. The <br />statutes and regulations for the Coal regulation program certainly provide that the Division has <br />the authority to carry Hilt many functions related to the enforcement of the notice of violation <br />even after the Board's jurisdiction has been invoked by a request for hearing. Once the Board <br />has jurisdiction over the notice of violation hearing, however, it would be illogical and <br />unreasonable to interpret the statute to extend the Division's implied authority so far as to allow <br />the Division to unilaterally terminate both the notice of violation as well as the Board's <br />jurisdiction, in the face of the explicit language in the statute that states that, once requested, a <br />13 <br />
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