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PERMFILE110893
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PERMFILE110893
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Last modified
8/24/2016 10:07:33 PM
Creation date
11/24/2007 8:05:55 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M2004067
IBM Index Class Name
Permit File
Doc Date
12/7/2005
Doc Name
Reply of Appl in Supportof Denial Motion
From
Christopher G. Hayes PC
To
DMG
Media Type
D
Archive
No
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a. CCDWP's assurances that it is committed to applying for all necessary <br />federal, state and local permits are not credible and insufficient as a matter of law; <br />b. Evidence of Gilpin County's prior and current involvement in regulatory <br />disputes between itself and Phillip and Kathleen Wolf, persons who are neither the Applicant nor <br />even parties to this proceeding, should be considered by the Board; and <br />c. This Board's approval of the pending application should include a <br />condition specifying that any violation of Gilpin County's various ordinances should also be <br />deemed to "be in violation of the 112 permit." Gilpin County Response at 4. <br />3. Each of these objections lacks merit for the reasons outlined below: <br />CCDWP'S COMMITMENT TO OBTAIN ALL <br />NECESSARY FEDERAL, STATE AND LOCAL PERMITS <br />SATISFIES THE REQUIREMENTS OF THE LAW <br />4, C.R.S. § 34-32.5-109 provides, in relevant part, that this Boazd has exclusive <br />state-wide jurisdiction to issue reclamation permits, standards and financial warranties on <br />construction material operations. Subsection 34-32.5-109(3) also expressly provides that <br />operators "shall be responsible for assuring that the mining operation and the post mining land <br />use comply with city, town, county or city and county land use regulations and any master plan <br />for extraction...." (Emphasis added). <br />5. The enactment of these provisions in 1995 effectively overruled dicta in prior <br />cases such as C&M Sand & Gravel v. Board of County Commissioners, 673 P.Zd 1013 (Colo. <br />App. 1983), cited by Gilpin County, suggesting that county regulatory approval must be obtained <br />before this Board could grant an application. <br />2 <br />
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