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PERMFILE134388
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PERMFILE134388
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Entry Properties
Last modified
8/24/2016 10:35:05 PM
Creation date
11/26/2007 2:15:01 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M2004067
IBM Index Class Name
Permit File
Doc Date
6/25/2007
Doc Name
Continued Reply Brief
From
Court of Appeals
To
DRMS
Media Type
D
Archive
No
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Thus, contrary to the MLRB's argument, the exhibit requirements set forth <br />at C.M.R. 6.4.13 for Section 112 permits do not supplant the C.M.R. 1.4.1(5) <br />requirements but are in addition to those requirements. Under both Section 110 <br />and Section 112 permits, the application must include a statement that "the <br /> <br />Applicant has applied for all necessary approvals from local government." C.M.R. <br />1.4.1(5)(d) (emphasis added). And for both Section 110 and Section 112 permits, <br />the applicant must include an exhibit describing the permits, licenses, and <br />approvals that "are held or will be sought," C.M.R. 6.3.6 (emphasis added), or <br />that the applicant "holds or will be seeking," C.M.R. 6.4.13 (emphasis added), for <br />a much broader list of potentially relevant permits. <br />This Court is not bound by the MLRB's strained interpretation of the <br />Construction Material Rules that ignores the plain language and clear requirements <br />of C.M.R. 1.4.1(5)(d) and C.M.R. 1.4.5(1), which mandate that an application for a <br />Section 112 permit "shall" contain "a statement that the Applicant has applied for <br />all necessary approvals from local government." Mishkin v. Young, 107 P.3d at <br />396-97; Envirotest Systems, Corp. v. Colo. Dept. of Revenue, 109 P.3d at 145. <br />Rather, in this de novo review, this Court may apply the plain and ordinary <br />meaning of the provisions to give meaning to both C.M.R. 1.4.1(5) and C.M.R. <br />6.4.13 and to require a Section 112 applicant to make "a statement that the <br />9 <br />
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