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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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II. THE BOARD FAILED TO COMPLY WITH STATUTORY REQUIREMENTS <br />THAT IT CONSIDER ECONOMIC COSTS, ENVIRONMENTAL BENEFITS, <br />AND THE REASONABLENESS OF CORRECTIVE ACTION NO. 2 (MINE <br />DEWATERING AND TREATMENT). <br />A. The Act Requires That the Board Consider Economic Costs, Environmental <br />Benefits, and the Reasonableness of Corrective Action No. 2. <br />Courts should construe statutes so as to effectuate the presumed legislative policy <br />motivating the enactment. Moya v. Colorado Ltd. Gaming Control Comm'n, 870 P.2d 620, 623 <br />(Colo. Ct. App. 1994); see also Colorado Mining Ass 'n v. Board of Cnty. Comm'rs, 199 P.3d <br />718, 731 (Colo. 2009) (relying on legislative declaration at issue in Cotter's appeal to reject a <br />county land ban on use of chemicals for mine processing). The ascertainment and effectuation of <br />legislative intent is the polestar of statutory interpretation. Burns v. Board of Assessment <br />Appeals, 820 P.2d 1175, 1178 (Colo. Ct. App. 1991). The Supreme Court construes statutory <br />provisions as a whole, giving effect to every word and term contained therein, whenever <br />possible. Board of County Comm'rs v. Vail Associates, Inc., 19 P.3d 1263, 1273 (Colo. 2001). <br />The legislative declaration of the Mined Land Reclamation Act ( "Act ") states that: <br />The general assembly further declares that it is the intent of this <br />article to require the development of a mined land reclamation <br />regulatory program in which the economic costs of reclamation <br />measures utilized bear a reasonable relationship to the <br />environmental benefits derived from such measures. The mined <br />therefore incorrect in stating that the level of molybdenum has consistently exceeded since 2001 <br />a water quality standard for molybdenum in Ralston Creek of 0.035 mg/L, see Answer Brief at <br />18, because 0.035 mg /L is not the current Table value and the Table value has not been applied <br />in Segment 17b. Moreover, the Defendants grossly mischaracterize the situation in Ralston <br />Creek by citing to a page in the proposed Environmental Protection Plan ( "EPP ") that discusses <br />molybdenum concentrations in the mine pool, not in Ralston Creek. See Answer Brief at 18 <br />(citing AR:00140); see also Answer Brief at 19 (acknowledging that AR:00140 applies to levels <br />within the mine pool). The Division of Reclamation, Mining and Safety ( "Division ") Inspection <br />Report and "Notice of a Reason to Believe a Violation Exists at the Schwartzwalder Mine," <br />which initiated the enforcement action, contain no allegations regarding molybdenum. See <br />Answer Brief at 5, AR:00337, 00370 ( "The inspection found that concentrations of uranium in <br />Ralston Creek were exceeding stream standards. ") (emphasis added). <br />2 <br />
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