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addressing a violation arising from the same set of operative facts which was the <br />subject matter of WQCD's civil penalty proceeding.' <br />The charges predicating the administrative proceeding reviewed by the <br />district court appear in WQCD Notice of Violation (NoV) dated February 22, 1989 and <br />twice amended, on April 11, 1989 and June 27, 1989. The allegations of the WQCD <br />NoV, as well as the MLRD NoV, are summarized in Brief Appendix, Appendix -4. <br />GLOSSARY OF ACRONYMS <br />To aid in identification of the agencies and an understanding of the <br />bureaucratese, we include a glossary of acronyms. We follow the helpful prototype <br />contained in Ohio v. EPA, 36 ERC (BNA) 2065, 2068 (D.C. Cir. 1993). <br />CDH Colorado Department of Health. <br />CDPS Colorado Discharge Permit System (Colorado's <br />counterpart of the United States' discharge permit program), 11A <br />CoLo. REV. STAT. §§ 25 -8 -501 through -507 (1989 Repl. Vol.). <br />(CDPS was amended in 1991, but these amendments have no <br />application to the present proceeding.) <br />CSCMRA Colorado Surface Coal Mining Reclamation Act, 14 <br />Coro. REV. STAT. §§ 34 -33 -101 through 137 (1984 Repl. Vol.). <br />(CSCMRA was amended in 1992; these amendments principally <br />reorganized the Colorado Department of Natural Resources and <br />have no application to this proceeding; by the reorganization, MLRD <br />bcame an office within the Colorado Department of Natural <br />Resources' Division of Minerals and Geology, see Colo. S.L. ch. 260, <br />§§ 48 -70, pp. 1944 -70 (1992).) Pertinent excerpts from CSCMRA as <br />it was in 1989, the date of the alleged MLRD violation, are <br />2 Throughout the appeal before this Court, Mid - Continent will continue to refer to the <br />Mined Land Reclamation Division (MLRD) of the Colorado Department of Natural Resources <br />as such. With respect to the January and February, 1989 events that are the subject matter <br />of this proceeding, MLRD, not the Division of Minerals and Geology (DMG) created in 1992, <br />was the Colorado Department of Natural Resources' first tier subagency that proceeded against <br />Mid - Continent for an alleged violation of its permit. <br />Mid - Continent Answer Brief <br />2 Appeal No. 93 CA 297 <br />