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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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it had on this issue, but also acted arbitrarily and capriciously, exceeded its <br />statutory and regulatory authority, and otherwise erred as a matter of law. <br />Similarly, the Appellee, Mined Land Reclamation Board ("MLRB") <br />mistakenly asserts that the MLRB's decision that CCDWP had complied with <br />Section 34-32.5-115(4)(a) and (d) C.R.S. and C.M.R. 6.4.13. is entitled to <br />deference. This argument also ignores the record and misstates the law as it <br />applies to this case. <br />All parties agree that the standard of review is set forth in Section 24-4- <br />106(11)(e), C.R.S. This standard sets forth at least nine grounds upon which this <br />Court is to review the MLRB's decision. If this Court finds that one of these <br />grounds exists, it must set aside the MLRB's decision. <br />In addition, Section 24-4-106(7), C.R.S. states in part as follows: <br />"...In all cases under review, the court shall determine all <br />questions of law and interpret the statutory and <br />constitutional provisions involved and shall apply such <br />interpretation to the facts duly found or established." <br />All parties also agree that CCDWP was required to establish that its <br />application was complete as required by Section 34-32.5-115(4) (a), C.R.S., that <br />CCDWP's proposed mining operation, reclamation plan and proposed future use of <br />the land was not contrary to the laws of Colorado and Gilpin County in particular, <br />as required by Section 34-32.5-115(4) (d), C.R.S., and that CCDWP had complied <br />z <br />
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