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<br />continue until a new one is granted. Thus, Andesite can only conduct its <br />operation under its existing permit until a new permit is granted, and the <br />new permit cannot be granted unless Andesite cures its defaults. <br />Finally, Section 34-32-125(6)(b) provides that if the Board suspends <br />or revokes Andesite's permit, Andesite can only continue operations so as to <br />comply with the permit terms. Therefore, the landowner's Complaint is not <br />made moot by Andesite's mere filing of a new application. Were Andesite's <br />allegation in this regard to be true, any operator could defeat any complaint <br />by merely filing papers with the Board. <br />Respectfully submitted this Z~"-d day of ~]W~1 . 1983. <br />~flZ~l~ Y. -f"ll~i~w/ ~ <br />Kart Kumli, III, Reg. No. 11784 <br />Attorney and Counselor at Law <br />1375 Walnut Street, Suite 215 <br />P. O. Box 2279 <br />Boulder, CO 80306 <br />Telephone: 303/440-0075 <br />-3- <br />