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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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63. To support this position, Defendants contend that subsection (7) cannot be read separately <br />from the remainder of section 124 because doing so would mean "no written notice is required <br />before levying a civil penalty." Id. This contention is insupportable, as subsection 34- 32- 124(1) <br />specifies the notice and service requirements for violations of an "order, permit, notice of intent, <br />or regulation." Thus, written notice is required if the Board has reason to believe that a permit <br />violation has occurred. However, it does not follow that each of the remaining subsections of <br />section 34 -32 -124 must treat violations of an "order, permit, notice of intent, or regulation" in an <br />identical manner for all purposes. Indeed, as explained above, the legislature chose not to do so, <br />both in the case of suspending, modifying, or revoking a permit pursuant to section 34 -32- 124(6) <br />and assessing civil penalties pursuant to subsection 34 -32- 124(7). <br />Sixth, the Defendants' contention that the Court should defer to 2 Colo. Code Regs 407- <br />1, Rule 3.3.2(2)(b) should be rejected. A regulation may not modify or contravene an existing <br />statute. Cartwright v. State Bd. of Accountancy, 796 P.2d 51, 53 (Colo. Ct. App. 1990). "Any <br />regulation that is inconsistent with or contrary to a statute is void." Rigmaiden, 155 P.3d at 504; <br />see Colo. Rev. Stat. § 24- 4- 103(8)(a) ( "Any rule or amendment to an existing rule issued by any <br />agency ... which conflicts with a statute shall be void. "). The courts have a duty to invalidate <br />administrative regulations which conflict with the design of a statute. Cartwright, 796 P.2d at <br />53. As explained in one of the cases upon which the Defendants rely, see Answer Brief at 64, <br />"administrative regulations are not absolute rules. They may not conflict with the design of an <br />Act, and when they do the court has a duty to invalidate them." Travelers Indemnity Co. v. <br />which the Defendants rely and, instead, applied the "plain language" of the statute. 914 P.2d at <br />925. <br />17 The Act specifies that "[ajll rules and regulations shall be subject to the provisions of <br />section 24 -4 -103, C.R.S." Colo. Rev. Stat. § 34 -32- 108(2). <br />39 <br />
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