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2011-02-09_ENFORCEMENT - M1977300
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2011-02-09_ENFORCEMENT - M1977300
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Last modified
8/24/2016 4:30:54 PM
Creation date
2/15/2011 7:55:34 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M1977300
IBM Index Class Name
ENFORCEMENT
Doc Date
2/9/2011
Doc Name
Opening Brief of Plaintiff Cotter Corporation
From
Cotter Corporation
To
District Court
Email Name
DB2
AJW
DAB
Media Type
D
Archive
No
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Trend. AR:00947:13-25; 00520; 00948:16-950:9; 00521-00522. Whetstone also agreed that <br />there was no direct evidence that the mine pool was contributing uranium to Ralston Creek. <br />AR:00261-63. <br />After testimony closed, AR:01034:14-16, the Board deliberated. During those <br />deliberations, the Board Chairperson asked the Division for its "thoughts." AR:01043:11-12. <br />David Berry of the Division participated in the deliberations, including recommending that the <br />Board adopt the Division's positions. AR:01043:16-01045:12. <br />Cotter is continuing to work on long-term remediation strategies. AR:00306. Evaluation <br />of water quality data collected from Ralston Creek and groundwater monitoring are providing <br />critical information for determining an optimal approach to a long-term strategy. AR:00306. <br />ARGUMENT <br />I. Standard of Review <br />Under Colo. Rev. Stat. § 24-4-106(7), if this Court finds that the Board actions are: <br />arbitrary or capricious, a denial of statutory right, contrary to constitutional right, <br />power, privilege, or immunity, in excess of statutory jurisdiction, authority, <br />purposes, or limitations, not in accord with the procedures or procedural <br />limitations of this article or as otherwise required by law, an abuse or clearly <br />unwarranted exercise of discretion, based upon findings of fact that are clearly <br />erroneous on the whole record, unsupported by substantial evidence when the <br />record is considered as a whole, or otherwise contrary to law, then the court shall <br />hold unlawful and set aside the agency action and shall restrain the enforcement <br />of the order or rule under review, compel any agency action to be taken which has <br />been unlawfully withheld or unduly delayed, remand the case for further <br />proceedings, and afford such other relief as may be appropriate. <br />With respect to the standard of "unsupported by substantial evidence," some evidence in some <br />particulars is insufficient to meet the substantial evidence standard. Lassner v. Civil Services <br />Comm'n, 177 Colo. 257, 259, 493 P.2d 1087, 1089 (1972). <br />13
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