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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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C. No Substantial Evidence Exists That the Mine Pool Supports a Violation of <br />Colo. Rev. Stat. & 34-32-116(7)(h). <br />The Board did not establish that the mine pool supports any violation of Colo. Rev. Stat. <br />§ 34-32-116(7)(h), which provides "[a]reas outside of the affected land shall be protected from <br />slides or damage occurring during the mining operation and reclamation." See Order ¶¶ 44-45, <br />AR:00852. To support its conclusion that Cotter violated subsection 116(7)(h), the Board first <br />determined that the area which had been adversely affected is Ralston Creek. Order ¶ 45, <br />AR:00852. The Board then determined that Cotter had failed to protect Ralston Creek because <br />"[t]he contaminated alluvial fill and mine pool water significantly increased the uranium levels <br />in Ralston Creek." Id. These findings do not establish that the mine pool supports any violation <br />of subsection 116(7)(h). <br />First, subsection 116(7)(h) does not even apply to the alleged contamination by the mine <br />pool. The term "damage" is not defined in the Act or its implementing regulations. See Colo. <br />Rev. Stat. § 34-32-103; 2 Colo. Code Regs. § 407-1, Rule 1.1. However, under basic elements <br />of statutory construction, the term "damage" should be construed to cover damage associated <br />with slides. 2A Norman J. Singer & J.D. Shambie Singer, Sutherland Statutes and Statutory <br />Construction § 47:16 (7th ed. 2010) ("[t]he coupling of words denotes an intention that they <br />should be understood in the same general sense"). This construction of the statute is supported <br />by the Hard Rock rule that was promulgated to implement section 34-32-116(7)(h), which states: <br />All grading shall be done in a manner to control erosion and siltation of the <br />affected lands, to protect areas outside the affected land from slides and other <br />damage. If not eliminated, all highwalls shall be stabilized. <br />2 Colo. Code Regs. § 407-1, Rule 3.1.5(3) (emphasis added). The regulation's focus on grading, <br />erosion, siltation, slides and stabilization of high walls shows that the purpose of subsection <br />33
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