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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
Metadata
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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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It is clear from the Local Government Land Use Control Enabling Act that the <br /> General Assembly has conferred broad authority on counties to plan for and.regulate the use <br /> of the land within their respective jurisdictions. See generally Section 29-20-101 to 107, <br /> C.R.S.; Bowen/Edwards, supra. However, it should also be noted that this land use statute <br /> provides that "... where other procedural or substantive requirements for the planning for or <br /> regulation of the use of land are provided by law, such requirements shall control." Section <br /> 29-20-107, C.R.S. <br /> The questions involved in the matter at hand are two-fold: 1) Whether the Colorado <br /> Surface Coal Mining Reclamation Act preempts Pitkin County's land use or other authority <br /> regarding reclamation issues, and 2) Whether, aside from its land use authority, Pitkin <br /> County has asserted an interest sufficient to remain a party which can assert defenses to <br /> claims for relief one through four of the Amended Third-Party Complaint. <br /> PREEMPTION <br /> The purpose of the preemption doctrine is to establish a priority between potentially <br /> conflicting laws enacted by various levels of government. Bowen/Edwards, sutra. There are <br /> three basic ways by which a state statute can preempt a county ordinance or regulation: <br /> 1) the express language of the statute may indicate state preemption of all local <br /> authority over the subject matter; <br /> 2) preemption may be inferred if the state statute impliedly evinces a <br /> legislative intent to completely occupy a given field by reason of a dominant state interest. <br /> Such a legislative intent to preempt local control over certain activities cannot be inferred <br /> merely from the enactment of a statute addressing certain aspects of those activities. The <br /> determination must be made not only by the language used but by the whole purpose and <br /> scope of the legislative scheme, including the particular circumstances upon which the statute <br /> was intended to operate; <br /> 3) a local law may be partially preempted where its operational effect would <br /> conflict with the application of the state statute. State preemption by reason of an operational <br /> conflict can arise where the effectuation of a local interest materially impedes or destroys the <br /> 4 <br />
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