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ENFORCE37501
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ENFORCE37501
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Last modified
8/24/2016 7:46:28 PM
Creation date
11/21/2007 3:35:15 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1981013
IBM Index Class Name
Enforcement
Doc Date
8/23/2001
Doc Name
THE TATUMS MOTION TO DISMISS
Violation No.
CV2000009
Media Type
D
Archive
No
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Instead of reading the statute as a whole and harmonizing its provisions wherever possible, $asin <br />demands that this Court construe one sentence in the Coal Act to deprive several other provisions <br />of any force or effect. Such a reading violates the fundamental principles of statutory construction. <br />The Coal Act and its implementing regulations authorize DMG to administer the program, <br />subject to review by the Boatel and the courts. Inherently, if not explicitly, the power to administer <br />the approved State program includes the power to issue notices of violation and the power to vacate <br />such notices. 'The existence of that inherent power is confirmed by Section 5.03.7 of the Coal Act's <br />implementing regulations, which specifies particular grounds on which DMG may aot vacate <br />enforcement action. Moreover. Cola. Rev, Stat. § 34-33-17A(1)(a), oa which Basin's claim depends, <br />provides the Boazd with jurisdiction to adjudicate challenges to the propriety of DMG's decisions <br />to modify, vacate, or terminate enforcement action and thus confirms DMG's authority to take those <br />types of actions in the first place. <br />Nowhere in the Colorado statutes or regulations is there an express or implied limitation on <br />DMG's authority to vacate notices of violation while challenges to such notices aze pending before <br />this Boazd (except, of course, on those grounds specified in Section 5.03.7 of the regulations). The <br />provisions of the statutes and rcgulations that drrect [he Board to conduct hearings and issue <br />decisions on challenges to notices of violation exist alongside statutory and regulatory provisions <br />that authorize DMG to vacate its enforcement actions, subject to the Board's power to review such <br />decisions. Read together and harmonized in a manner that fosters the intent of Congress and the <br />Colorado Legislature, the Coal Act and its implementing regulations instruct the Board how to <br />handle challenges to "live' enforcement action while at the same time allowing DMG to terminate <br />-12- <br />ll9-d E10/919'd OE9-1 E95E99EE9E S3~tlfI0E3tl 1tl801tlN 100-YlOlii 4I~Zl 1992-EZ-9fltl <br />
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