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PERMFILE126129
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PERMFILE126129
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Entry Properties
Last modified
8/24/2016 10:23:25 PM
Creation date
11/25/2007 2:54:24 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M2004067
IBM Index Class Name
Permit File
Doc Date
6/26/2007
Doc Name
City of Black Hawk Reply Brief
From
Court of Appeals
To
MLRB
Media Type
D
Archive
No
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34-32.5-116(4), C.R.S. and C.M.R. 3.1.10(1) require CCDWP's Reclamation Plan <br />to comply with more than just vegetative cover. Section 32.5-116(4)(fj, C.R.S., <br />states in pertinent parts as follows: <br />In those areas where revegetation is part of the <br />reclamation plan, land shall be revegetated so that a <br />diverse, effective, and long-lasting vegetative cover is <br />established that is capable of self-regeneration and is at <br />least equal, with respect to the extent of cover, to the <br />natural vegetation of the surrounding area. Species <br />chosen for revegetation shall be compatible for the <br />proposed post-extraction land use and shall be of <br />adequate diversity to establish successful reclamation." <br />Thus, a diverse, effective and long-lasting vegetative cover is required. This <br />cover must be capable ofself-regeneration. This cover must at least be equal, with <br />respect to the extent of cover, to the natural vegetation of the surrounding area. Dr. <br />Leopold does not argue or assert that the cover needs to be a ratio 1:1. However, <br />as per the statutory requirement, it must be at least equal to the surrounding area. <br />Lastly, both 34-32.5-116(4), C.R.S. and C.M.R. 3.1.10(1) require that the <br />revegetation plan provide for the greatest probability of success in plant <br />establishment and development..." C.M.R. 3.1.10(4) (emplasis added.) <br />Dr. Leopold's Opening Brief fully and adequately sets forth the deficiencies <br />and inadequacies in CCDWP's Reclamation Plan and resulting Reclamation Bond <br />and they need not be recited here again. As admitted by the MLRB, CCDWP's <br />mining operations will bring about a "profound change" to the mined lands. It is <br />this profound change that has not been adequately or responsibly addressed by <br />CCDWP, in its Reclamation Plan or its Reclamation Bond and thus it fails to <br /> <br />
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