My WebLink
|
Help
|
About
|
Sign Out
Home
Browse
Search
2011-05-26_ENFORCEMENT - M1977300
DRMS
>
Day Forward
>
Enforcement
>
Minerals
>
M1977300
>
2011-05-26_ENFORCEMENT - M1977300
Metadata
Thumbnails
Annotations
Entry Properties
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
There are no annotations on this page.
Document management portal powered by Laserfiche WebLink 9 © 1998-2015
Laserfiche.
All rights reserved.
/
52
PDF
Print
Pages to print
Enter page numbers and/or page ranges separated by commas. For example, 1,3,5-12.
After downloading, print the document using a PDF reader (e.g. Adobe Reader).
View images
View plain text
an administrative body's decision." Burns, 820 P.2d at 1176; see Colorado Municipal League v. <br />Mountain States Tel. & Tel. Co., 759 P.2d 40, 45 (Colo. 1988) (a statement on cross - examination <br />inadequate to meet substantial evidence standard because it was more of a legal estimate than an <br />expert opinion). <br />The Defendants' other attempts to refer to economic reasonableness fail completely. For <br />example, the Defendants argue that Tom Mountfort of Denver Water "refuted Cotter's statement <br />that dewatering was too costly or infeasible." See Answer Brief at 24 (citing AR:00414). This <br />citation is to a letter stating that "Denver Water and other water utilities face similar challenges <br />in their day -to -day operations and are capable of managing these challenges at a reasonable <br />cost," and that "[w]ith proper engineering, Cotter should be able to find a cost effective <br />equipment installation technique." This statement fails to identify the similar challenges, fails to <br />identify "reasonable cost," and fails to address any costs of Mine Dewatering and Treatment <br />other than equipment installation. <br />As recognized by the Defendants, Cotter did not have the burden to prove at the July 12, <br />2010 hearing ( "Hearing ") that it was not economically reasonable to implement Corrective <br />Action No. 2. See Answer Brief at 53. The Defendants ignore their own burden by arguing that <br />Cotter should have submitted evidence regarding costs. See Answer Brief at 53. An agency may <br />not delegate its responsibility to consider a specified factor to a regulated party. Gerber v. <br />Norton, 294 F.3d 173, 185 (D.C. Cir. 2002). <br />C. No Substantial Evidence Exists in the Record of Any Costs That Denver <br />Water or Arvada Water Are Incurring Resulting from Uranium in Ralston <br />Creek or Reservoir, Any Costs That Either Entity Will Incur If Uranium <br />Concentrations in the Reservoir Increase, or Any Costs for Treating the <br />Creek and Reservoir. <br />The findings of an agency decision must show what evidence is relied upon. Mellow <br />Yellow Taxi Co. v. PUC, 644 P.2d 18, 19 (Colo. 1982). The Order fails to cite to any evidence <br />9 <br />
The URL can be used to link to this page
Your browser does not support the video tag.