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2011-05-26_ENFORCEMENT - M1977300
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2011-05-26_ENFORCEMENT - M1977300
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Last modified
8/24/2016 4:33:50 PM
Creation date
8/10/2011 2:35:59 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M1977300
IBM Index Class Name
ENFORCEMENT
Doc Date
5/26/2011
Doc Name
Reply Brief of Plaintiff Cotter Corporation (N.S.L.)
From
Cotter Corporation
To
District Court
Email Name
DB2
Media Type
D
Archive
No
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construction that best effectuates the legislative intent and design. Family Tree Found. v. <br />Property Tax Administrator, 119 P.3d 581, 582 (Colo. Ct. App. 2005). In this case, the <br />legislative intent and design require consideration of benefits and economic reasonableness. The <br />Defendants also ignore that section 34 -32 -116 does, in fact, require that "economics" are to be <br />taken into account in carrying out reclamation. See Colo. Rev. Stat. § 34- 32- 116(7)(q). <br />The Defendants also argue that the requirements in the legislative declaration apply only <br />to the development of a mined land regulatory program. Answer Brief at 54. Such an argument <br />makes no sense in light of the last sentence of Colo. Rev. Stat. § 34 -32- 102(2), stating that the <br />financial condition of an operator shall not be a factor in considering economic reasonableness. <br />The financial condition of an operator would be relevant only in establishing reclamation <br />standards for specific operators, not for an entire program. See Stevinson Imports, Inc. v. City <br />and County of Denver, 143 P.3d 1099, 1103 (Colo. Ct. App. 2006) ( "[C]ourt should not interpret <br />a statute in ways that defeat the legislature's obvious intent or render part of the statute <br />meaningless or absurd. "). Moreover, if the Defendants are arguing that the legislature's <br />declaration — "the economic costs of reclamation measures utilized bear a reasonable relationship <br />to the environmental benefits derived from such measures," see Colo. Rev. Stat. § 34 -32- 102(2) <br />— applies only to developing regulations, the legislature would have referred to "promulgating <br />rules," similar to the language in Colo. Rev. Stat. § 34 -32- 116.5(5). Instead, it expressed its <br />intent that economic costs bear a reasonable relationship to environmental benefits in <br />implementing the entire mined land reclamation program. It then separately stated that actions <br />of both the Board and Division be subject to considerations of economic reasonableness. <br />The Defendants point to cases stating that a statute should not be interpreted to mean <br />what it does not express, but here the legislative declaration is clear that economic costs of <br />4 <br />
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