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issued. ,5 By initialing this statement, the applicant acknowledges that compliance with the Act <br />and Rules is a provision of the permit. <br />B) The record warrants the Board's assessment of civil penalties based on Cotter's <br />continuing non - compliance with its permit, the Act, and the Rules. <br />Substantial evidence supports the Board's determination that Cotter violated the <br />provisions of its permit by failing to implement the corrective actions required to prevent <br />ongoing violations of the Act. Cotter admitted that it violated Corrective Actions 2 and 3 <br />R:0252, 12 -17. The Board required those corrective actions to prevent ongoing violations of <br />the Act. Thus, the Board concluded, based on substantial evidence, that Cotter had violated the <br />Act. Both the Act and the Rules dictate that a violation of the Act is a violation of a permit <br />provision. The Board need go no further, since the Act provides that "[a]ny person who violates <br />any provision of any permit issued under this article shall be subject to a civil penalty." <br />Cotter has raised unpersuasive formalistic arguments regarding the content of the <br />December Order and the record. Cotter first argues that civil penalties were improper because <br />December Order does not explicitly state that Cotter violated its permit. Cotter attempts to hold <br />the Board's written order to a higher standard than the law requires. An agency's findings need <br />not represent a model of clarity and may be either express or implied from a review of the <br />administrative record as a whole. Arlberg Club, 762 P.2d at 150. The record clearly indicates <br />that the Board found a violation of the permit. R:0277. Cotter also argues that the record is <br />deficient because the Board did not enter the permit into evidence. Cotter again overstates the <br />standard required of the Board. Administrative hearings need not comply with the strict rules of <br />evidence. Colorado Citizens, 187 P.3d at 1213. The evidentiary standard is "whether the <br />s See page 6, item 8, available online at http: / /minim. state. co. us /MinForms /Hardrock %20112 %20App.pdf <br />18 <br />