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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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Whether an order is supported by adequate findings of fact is a question of law. <br />Stevinson Imports, Inc. v. City & County of Denver, 143 P. 3d 1099, 1101 (Colo. Ct. App. 2006). <br />Findings of ultimate fact involve a conclusion of law, or at least a mixed question of law and <br />fact, and settle the rights and liabilities of the parties, and those findings are not binding on the <br />reviewing court. Id. <br />II. The Board Failed To Comply with Statutory Requirements That It Consider <br />Economic Costs, Environmental Benefits and the Reasonableness of Corrective <br />Action No. 2 (Mine Dewatering and Treatment). <br />The Act defines "reclamation" as "the employment during and after a mining operation <br />of procedures reasonably designed to minimize as much as practicable the disruption from a <br />mining operation ...." Colo. Rev. Stat. § 34-32-103(13) (emphasis added); AR:00252. <br />Moreover, Colo. Rev. Stat. § 34-32-102(2) requires that the economic costs of reclamation <br />measures utilized bear a reasonable relationship to the environmental benefits derived from such <br />measures, and that considerations be given to economic reasonableness. AR:00257-58. <br />A. The Board Failed to Consider, and the Record Does Not Contain Substantial <br />Evidence of, the Costs of Corrective Action No 2 (Mine Dewatering and <br />Treatment), Thus RenderinL, the Order Unlawful and Arbitrary and <br />Capricious. <br />Cotter appeals, inter alia, the following Findings and Conclusions of Law in the Order <br />(without which the Order must be vacated): <br />32. ... The Division considers the costs of the corrective actions less than the costs of <br />cleaning the water in Ralston Creek and Reservoir. AR:00850. <br />33. ... Dewatering the mine will be expensive. However, the benefit (protecting <br />Denver and Arvada's drinking water supply) justifies the expense. AR:00850. <br />36. ... The Board considered the potential expense of dewatering the mine against <br />the threat to human health and safety posed from contaminated water migrating to <br />14
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