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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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Littleton, 390 P.2d 471, 477 (Colo. 1964) (statutory term "disposed of' took on definite <br />limitations because of its association with the word "sell "). <br />The Defendants' interpretation also ignores the rule that "constructions that would render <br />meaningless a part of the statute should be avoided." Terry, 791 P.2d at 376. As explained <br />above, had the legislature intended the word "damage" to mean any damage, of any kind, or even <br />"damage that is not slide - related," the word "slides" in section 34- 32- 116(7)(h) becomes <br />meaningless. The Defendants' interpretation of section 34- 32- 116(7)(h) should, therefore, be <br />rejected. See Terry, 791 P.2d at 377 (rejecting statutory construction that renders statutory <br />language of "no effect "). <br />The Defendants' interpretation of section 34- 32- 116(7)(h) is undermined by the Board's <br />Rule 3.1.5(3) which interprets section 34- 32- 116(7)(h) and makes clear that the purpose of the <br />section is to protect against damage associated with slides. Rule 3.1.5(3) states: "All grading <br />shall be done in a manner to control erosion and siltation of the affected lands, to protect areas <br />outside the affected land from slides and other damage. If not eliminated, all highwalls shall be <br />stabilized." 2 Colo. Code Regs. 407 -1, Rule 3.1.5(3) (emphasis added). The rule's focus on <br />grading, erosion, siltation, slides and stabilization of high walls shows that the purpose of <br />section 34- 32- 116(7)(h) is to protect against damage associated with slides. Therefore, to the <br />extent the Board's interpretation of section 34- 32- 116(7)(h) is relevant to that statute's meaning, <br />this court should find that the word "damage" means damage associated with slides and does not <br />include uranium concentrations in the mine pool or Ralston Creek. <br />The cases upon which the Defendants rely for their interpretation of section 34-32 - <br />116(7)(h) do not support their position that "damage" means all damage that is not slide related. <br />In Bloomer v. Board of County Comm'rs, 799 P.2d 942, 946 (Colo. 1990), the court used the <br />27 <br />
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