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Thus, the MLRB erred in failing to require the applicant to comply with <br />C.M.R. 6-4-13 and § 34-32.S-11S(4), C.R.S. and this Court should reverse the <br />MLRB's Order accordingly. <br />B. The MLRB erred in granting a reclamation permit in file M-2004- <br />067 since CCDWP did not provide a sufficient Reclamation Plan, as required <br />by Section 34-32.5-116, C.R.S. and C.M.R 3.1.10 and 6.4.5 and did not provide <br />an adequate estimate of reclamation costs or an adequate reclamation bond, <br />as are required by Section 34-32.5-117, C.R.S. and C.M.R 4.2.1 and 6.4.12. <br />CCDWP's Answer Brief asserts that the MLRB's finding that CCDWP's <br />Reclamation Plan and Reclamation Bond met the statutory requirements and <br />regulations of Section 34-32.5-116, C.R.S. and the C.M.R. is supported by <br />substantial evidence, but CCDWP does not state evidence in the record upon which <br />to base this assertion. CCDWP merely recites the statutory requirements, lists <br />numerous adequacy concerns that were presented and states, in conclusory fashion, <br />that CCDWP's Reclamation Plan was compliant. Dr. Leopold need not reiterate <br />the evidence to the contrary discussed in her Opening Brief, but would state that a <br />reasonable person, when considering all of the evidence in the record as to the <br />inadequacies of the Reclamation Plan and Bond, would be fairly and honestly <br />compelled to reach a conclusion that both the Reclamation Plan and Reclamation <br />Bond were insufficient and inadequate. Both CCDWP and the MLRB agree that <br />this is the standard to be applied. Ramseyer v. Colorado Department of Social <br />Services, 89S P.2d 1188, 1192 (Colo. App. 1995). <br />In its Answer Brief, the MLRB mistakenly asserts that Dr. Leopold's <br />"vegetative cover" requirement is the only revegetation standard. To the contrary, <br />Dr. Leopold would assert, and believes that the Division would agree, that Section <br />6 <br />