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2011-08-11_ENFORCEMENT - M1977300
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2011-08-11_ENFORCEMENT - M1977300
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Last modified
8/24/2016 4:36:47 PM
Creation date
10/17/2011 12:01:17 PM
Metadata
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Template:
DRMS Permit Index
Permit No
M1977300
IBM Index Class Name
Enforcement
Doc Date
8/11/2011
Doc Name
Joint Answer Brief
From
MLRB and DRMS
To
District Court
Email Name
DB2
Media Type
D
Archive
No
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language that separately authorized cease and desist orders to prevent the violation of a prior <br />enforcement order. There are few, if any, conceivable circumstances where an operator could <br />violate an enforcement order without also violating provisions of the Act, Rules, or permit. In <br />light of the legislature's broad grant of authority to issue cease and desist orders, the omission of <br />the phrase "violation of an order" should not be interpreted as the prohibition Cotter suggests. <br />Cotter's interpretation divests the Board of the discretion that the General Assembly <br />intended to provide. The Act states that the Board "may" issue a cease and desist order if it finds <br />any violations of any provisions of the Act, Rules, or permit exist. Cotter's interpretation would <br />lead to the result that the Board must issue a cease and desist order immediately upon finding a <br />violation of the Act, Rules or permit, or forever waive the right to issue a cease and desist order <br />in the future. An interpretation that restricts the Board's ability to enforce its regulatory mandate <br />is contrary to the General Assembly's broad grant of regulatory authority. See C.R.S. § 34 -32- <br />105(4) (2010). Board member Bob Randall expressed his concerns that Cotter's interpretation <br />would yield "an absurd result that I don't think was intended by the legislature." R:0288,1. 7 -12. <br />Mr. Randall correctly articulated the rule against statutory interpretations that would conflict <br />with legislative intent and lead to an absurd result. See Henisse, 247 P.3d at 579; see also Lucero <br />732 P.2d at 646. <br />The Board's interpretations of the Act are reasonable and should be afforded deference. <br />By enforcing the August Order, the Board sought to prevent ongoing violations of the Act. Board <br />member Barbara Green explained that, "it all collapses into the fact that the [August] order was <br />issued because we did find a violation of the act and regulation ... in the end what we would be <br />doing is imposing a cease and desist order to enforce the statute, because that's the underlying <br />13 <br />
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