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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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word "or" to "demarcate[] different categories" of roads identified in the statute, but was not <br />faced with how to interpret the meaning of any specific category. Here, the issue is not the <br />demarcation of categories, but how to interpret the word "damage." Zab, Inc. v. Berenergy <br />Corp., 136 P.3d 252, 255 -56 (Colo. 2006), does not here apply because it yields an absurd result. <br />If, as the Defendants contend, "slides" and "damage" are "separate and unrelated categories" <br />within section 34- 32- 116(7)(h), then the word "slides" is made meaningless. The legislature <br />would not have intended this result. See Terry, 791 P.2d at 376 -77. Moreover, in Zab, Inc., the <br />court used its demarcation rule solely to determine that the statute it was construing was <br />susceptible to more than one meaning, and not to determine the meaning of the disputed statutory <br />language. 136 P.3d at 256. <br />Even if section 34- 32- 116(7)(h) is sufficiently broad to cover damage unassociated with <br />slides, which it is not, the Board failed to show that the mine pool supports a violation of that <br />section. To support its conclusion that Cotter violated section 34- 32- 116(7)(h), the Board <br />expressly relied on a finding that "mine pool water significantly increased the uranium levels in <br />Ralston Creek." Order ¶ 45, AR:00852. As explained above, the record before the Board does <br />not establish that the mine pool has increased the uranium levels in Ralston Creek, and certainly <br />not significantly. Under these circumstances, a violation of section 34- 32- 116(7)(h) based on a <br />finding that the "mine pool has significantly increased the uranium levels in Ralston Creek" is <br />unsupported by substantial evidence and should be set aside. <br />D. The Board Lacks Statutory Authority to Order Mine Dewatering and <br />Treatment Under These Circumstances. <br />As shown above and as explained in Cotter's Opening Brief, the record is without <br />substantial evidence that the mine pool supports a violation of Colo. Rev. Stat. <br />§§ 34- 32- 116(7)(c), - 116(7)(g), and - 116(7)(h). Without such evidence, no causal nexus exists <br />28 <br />
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