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1999-02-09_GENERAL DOCUMENTS - C1981017 (3)
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1999-02-09_GENERAL DOCUMENTS - C1981017 (3)
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Last modified
3/15/2021 5:06:15 PM
Creation date
5/3/2012 9:34:22 AM
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Template:
DRMS Permit Index
Permit No
C1981017
IBM Index Class Name
GENERAL DOCUMENTS
Doc Date
2/9/1999
Doc Name
Response to motion to strike
From
US District Court
To
Mid-Continent Resources, Inc. & DMG
Permit Index Doc Type
General Correspondence
Media Type
D
Archive
No
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DRMS Re-OCR
Description:
Signifies Re-OCR Process Performed
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whether the county's assertion of authority based on the special use permits would conflict <br /> and therefore, be preempted, by the Division's reclamation authority. <br /> The other interests raised by Pitkin County to support its participation in litigating <br /> claims one through four are interests that the everyday citizen has in seeing that reclamation <br /> is completed; these interests are not based on specific land use or other authority in the <br /> county, but rather something akin to a citizen's interest or perhaps*an interest as anticus <br /> curiae. It is the Division's position that these general interests are not sufficient to allow the <br /> county to raise defenses to claims one through four. <br /> One thing is clear from the Motion and from the county's response, all parties agree <br /> that the Division is the only entity with the authority to set reclamation requirements at the <br /> site; any assertion of authority which conflicts with the Division's authority and ability to set <br /> reclamation standards would be preempted under current law. <br /> GENERAL LAW <br /> To set the background for the preemption issue, it is helpful to look at the general law <br /> pertaining to counties. <br /> Unlike a home-rule municipality, a county is not an independent governmental entity <br /> existing by reason of any inherent authority of its residents; rather, it is a political subdivision <br /> of the state, existing only for convenient administration of state government to carry out the <br /> will of the state. Board of County Com'rs. La Plata County v. Bowen/Edwards Asssociates. <br /> Inc., 830 P.2d 1045 (Colo. 1992). As an agency of state government, a county possesses <br /> only the regulatory authority expressly conferred upon it by the state constitution or by <br /> statute, and such incidental implied powers as are reasonably necessary to carry out its <br /> express powers. Id. <br /> Although a county is prohibited by statute from adopting an ordinance that is in <br /> conflict with any state statute, an ordinance and a statute may both remain effective and <br /> enforceable as long as they do not contain express or implied conditions that are <br /> irreconcilably in conflict with each other. Id. <br /> 3 <br />
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