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The MLRB HRMM Rules provide: <br />Rule 2.5.5 Party Status and Petition to Intervene <br />(1) The Office shall be granted party status upon request. <br />(2) Any other person may seek leave of the Board to intervene in such a <br />proceeding, and leave to intervene will be granted at the sole discretion of the Board <br />based upon the interest of the person and whether that interest is entitled to legal <br />protection under the Act and how that person is affected or aggrieved by the petition for <br />Declaratory Order. <br />(3) A petition to intervene shall set forth a concise statement of the facts necessary <br />to demonstrate the nature of its position, and the manner in which the statute, rule or <br />order in question does or does not apply to the Petitioner. <br />Intervenors meet the requirements set forth in the MLRB rules by providing information and <br />argument that aid the efficient resolution of the factual and legal disputes raised in Cotter <br />Corporation's appeal, to the extent that any legal or factual basis can be divined from the Cotter <br />Corporation's cursory appeal. <br />In this matter, as discussed below, Intervenors raise important questions of statutory <br />interpretation. As stated by the Colorado Court of Appeals, "[e]ven if pure questions of law are <br />concerned, agency review of the challenged action is desirable in order to provide the court with <br />the benefit of the agency's considered interpretation of its enabling statute." Kendal v. Cason, <br />791 P.2d 1227, 1229 (Colo. Ct. App. 1990). <br />Further, Intervenors may be adversely affected or aggrieved by any determination that the JD-6, <br />JD-8, or JD-9 mines do not qualify for DMO status, as requested by the Cotter Corporation. <br />Colorado Environmental Coalition (CEC) is a Colorado-based environmental advocacy <br />organization with three field offices in western Colorado and a main office in Denver. CEC has <br />approximately 3,500 individual members and over 90 affiliated organizations. CEC campaigns <br />engage citizens in the protection of Colorado's wild places, open spaces, wildlife and quality of <br />life. CEC is a known and active participant in public land management in Colorado, with a <br />demonstrated interest in energy development on Colorado's BLM lands. <br />Information Network for Responsible Mining (INFORM) is a nonprofit organization with the <br />mission of educating the public about the dangers that exist when unsafe and irresponsible <br />mining practices are permitted. Through the dissemination of information and education, <br />INFORM helps organize residents in local communities most threatened by these practices to <br />protect water quality, quality of life and the local economy. <br />The San Juan Citizens Alliance (SJCA) was founded in 1986 as a voice for environmental, <br />social, and economic justice in the San Juan Basin of southwest Colorado and northwest New <br />Mexico. San Juan Citizens Alliance works toward the protection of the wild lands, greater <br />corporate and governmental responsibility in the development of natural resources, and for the <br />protection of the waters in the Basin and includes more than 500 members who live in and who <br />care about the natural and human resources of the basin. <br />