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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
Fields
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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interpretation that harmonizes and gives effect to those provisions. See Gerganoff, 241 P.3d at <br />935; People v. Dist. Ct. 713 P.2d at 921 -22. <br />The Board's Rules interpret the Act's overlapping provisions in a manner that effectuates <br />the purposes underlying the legislative scheme. Rule 3.3.2 provides that "the Board may impose <br />civil penalties upon its determination, after a hearing, that a violation of the provisions of a <br />permit, the Act, or these Rules has occurred." 2 C.C.R. § 407 - 1:3.3.2 (2010). Rule 3.3.2 <br />acknowledges the fact that section 109(5)(a) requires that the Act and Rules be incorporated as <br />permit provisions and distills that concept in plain and simple language. A regulation that is <br />expressly or impliedly authorized by the enabling statute should be given force and effect. <br />Colorado Citizens for Ethics in Gov't v. Comm. for Am. Dream, 187 P.3d 1207, 1217 (Colo. <br />App. 2008)(explaining that administrative rules are presumed valid and will not be struck down <br />unless the challenging party has demonstrated that they are invalid beyond a reasonable doubt). <br />The General Assembly expressly authorized the Board to promulgate reasonable rules and <br />regulations respecting the administration of the Act. C.R.S. § 34 -32 -108 (2010). Accordingly, <br />the Board is authorized to promulgate a reasonable rule such as Rule 3.3.2 that clarifies and <br />reconciles the Act's overlapping regulatory concepts. See Id at 1218. <br />The Board's permit application forms mirror the interpretation codified in Rule 3.3.2. <br />The Board's permit form, which all applicants must submit, requires that the applicant initial the <br />following statement: "It is a provision of this permit that the operations will be conducted in <br />accordance with the terms and conditions listed in your application, as well as with the <br />provisions of the Act and the Mineral Rules and Regulations in effect at the time the permit is <br />17 <br />
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