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PERMFILE110893
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PERMFILE110893
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Entry Properties
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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THIS BOARD MAY NOT ADOPT A <br />10. In Town of Frederick v. Norrh American Resources Co., 60 P.3d 758 (Colo. App. <br />2002), and other recent cases, Colorado appellate courts have offered new guidance on the issue <br />of state and local preemption. <br />11. Among other things, these cases declare that state agencies may only enforce the <br />mandates given them by the state legislature, and local governments may only enforce local <br />laws. In Town of Frederick, the court of appeals declared that a fine imposed by a local <br />government for an alleged violation of a state regulation was unlawful. 60 P.3d at 765-66. <br />12. Here, Gilpin County proposes a condition declaring that any violation of county <br />zoning regulations should also be deemed a violation of the state 112 permit to be issued by this <br />Board. Any such condition would violate Town of Frederick. This Board's enforcement <br />jurisdiction is limited to that granted it by the Colorado General Assembly. <br />WHEREFORE, for [he foregoing reasons as well as all reasons stated in the Motion or <br />otherwise supported by the record: <br />A. CCDWP asks that all persons and organizations who have submitted <br />objections based on grounds that are beyond the MLRB's jurisdiction be declared ineligible for <br />party status. These objectors do not assert injury to interests that are entitled to legal protection <br />under the Act. <br />B. CCDWP also asks that all persons who filed objections but failed to <br />appear at the November 21 Pre-hearing Conference be declared ineligible for party status. <br />4 <br />
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