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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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Code Regs. § 407-1, Rule 1.1(6). The Division and applicant are allowed additional time before <br />a decision which ranges from 90 to 365 days. See Colo. Rev. Stat. § 34-32-115; 2 Colo. Code <br />Regs. § 407-1, Rules 1.4.1(9), 1.4.8(1). Public notice and opportunity for comment are also <br />provided. 2 Colo. Code Regs. § 407-1, Rules 1.6.2, 1.7. <br />The Board never addressed Cotter's position in its Order. The failure to address this <br />position is a violation of the Colorado APA. Colo. Rev. Stat. § 24-4-105(14)(a) (requiring a <br />statement of findings and conclusions upon all material issues of fact, law, or discretion <br />presented by the record). <br />V. The Board's Decision-Making Process Was Unlawful and Violated Cotter's Rights <br />to Due Process and Cotter's Rights Under the Colorado APA. <br />At the Hearing, after testimony closed, AR:01034:14-16, the Board deliberated on the <br />merits of the Division's claims against Cotter. The Board's Chairperson, Ms. Kraeger-Rovey, <br />AR:00863:4, stated "we don't have data that specifically says there is a problem, but we're <br />lacking data that says there is not a problem." AR:01034:23-24. Board member Mr. Paulin <br />stated "[w]hether we need to pump - pump and make the cone of depression in - I'm not sure <br />that anybody's convinced me that that's going to help anything." AR:01039:20-22. Board <br />member Ms. Green characterized the Board's options as to "go ahead with the staff <br />recommendation of the corrective action," or to "find in favor of the operator and say there's <br />absolutely no reason for a corrective action [No. 2]," or "we could ask the staff and operator to <br />come back to us with some kind of monitoring plan that would present an early warning system <br />that would be before a water supply was contaminated." AR:01038:13-19. Further, Ms. Green <br />stated "[I]'m thinking if others feel uncomfortable, that perhaps the more prudent course of <br />action ... would be somehow continue with directions to explore this early warning system, <br />36
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