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Applicant has applied for all necessary approvals from local government." C.M.R. <br />.. . <br />1.4.1(5)(d) (emphasis added). <br />Here, it is undisputed that the Applicant made no representation of having <br />applied for County permits, and in fact has done nothing to comply with County <br />permitting requirements. See R. 2903, Tr. 26:10-14; R. 43). As such, the MLRB <br />approved an incomplete application in violation of C.R.S. § 34-32.5-115(4)(a), <br />which permits denial of incomplete applications. Moreover, the MLRB failed to <br />give meaning to C.R.S. § 34-32.5-115(d), which permits denial if the proposed <br />mining operation as contrary to local permits, licenses, and approvals. In this <br />regard, the MLRB's approval of the application was not only unsupported by <br />substantial evidence in the record, as is required by C.R.S. § 24-4-106(7), but was <br />entirely unsupported by any evidence in the record. <br />III. Conclusion <br />For the reasons detailed above and as previously set forth in the City's <br />Opening Brief, as well as for the reasons articulated by the other Objectors, the <br />City requests this Court to reverse the district court's Amended Order affirming the <br />io <br />