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PERMFILE127629
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PERMFILE127629
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Entry Properties
Last modified
8/24/2016 10:24:46 PM
Creation date
11/25/2007 4:59:48 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M1999002
IBM Index Class Name
Permit File
Doc Date
6/18/1999
Doc Name
PREHEARING BRIEF OF GENERAL CHEMICAL
Media Type
D
Archive
No
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i • <br />Chemical shows below, the DMG also fails to correctly chazacterize the requirements of the <br />Rules, which do not authorize the DMG to establish standazds after the application is approved. <br />If the DMG has an alternative rationale for ignoring the statute, that rationale has not been <br />disclosed. Perhaps the DMG takes the position that the statutory diEiiculty is avoided entirely by <br />the simple expedient of granting the permit. Once a permit has been granted, it would be literally <br />true chat American Soda would have obtained a permit. before engaging in mining operations. <br />However, this expedient would violate standards canons of statutory construction. At a <br />minimum, it would not be construing the statute es a whole, and giving consistent, harmonious, <br />and sensible effect to all of its parts. wiComrrt nc v Colorado Public Utilitie9 Ca~mi~sion, <br />955 P.2d 1023 (Colo. 1998). <br />A grant-it-first-and-set-standards-after approach also presents practical difficulties that <br />argue against that interpretation. Taking the DMG approach literally, it appears that the DMG <br />will not be able to refuse permission to inject solution mining fluids if the Monitoring Program is <br />carried out, even if it later becomes apparent that the design of the Monitoring Program is flawed. <br />If the establishment of standards based on the Monitoring Program is indeed automatic, then the <br />DMG has surendered its authority to set standards as required by the statute and Rules, in a <br />dubious exchange for the authority to negotiate a research program. There is no basis in the <br />statute or the Rules for such a position. <br />
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