Loading...
HomeMy WebLinkAbout790503.tiff BEFORE THE WATER QUALITY CONTROL COMMISSION OF THE STATE OF COLORADO In the matter of the ) MOTION TO STAY FINAL ORDER ) OR DETERMINATION PENDING Proposed City of Northglenn ) CONSIDERATION OF MOTION TO Sewage Treatment Works to be ) RESCIND APPROVAL , FOR located in Weld County, ) RECONSIDERATION, AND FOR Colorado ) APPEAL OF DECISION COME NOW the Town of Frederick , the City of Ft . Lupton, the Weisner Subdivision Preservation Association, and the Board of County Commissioners of Weld County, Colorado and move for a stay of the decision entered orally by the Water Quality Control Commission approving the City of Northglenn ' s plans and specifications for the construction of a sewage treatment plant in Weld County , Colorado , and recommending to the United States Environmental Protection Agency that a construction grant be awarded to the proposed facility. These movants request that any final order or determina- tion of the Commission be stayed during the period of consi- deration of the Motion to Rescind Approval , for Reconsidera- tion, and for Appeal of Decision. AS GROUNDS THEREFOR, these movants cite the following authorities : 1 . Section 25-8-404 (2) provides that the thirty (30) day period for seeking judicial review of any final order or determination of the Commission shall be stayed while any application for a hearing, rehearing , or reconsideration is pending . 2 . A Stay pending consideration of the Motion to Rescind Approval , for Reconsideration for Adjudi- catory Hearing , and for Appeal of Decision would preserve movants ' right to judicial review of agency action pursuant to the Colorado Administra- tive Procedure Act , Section 24-4-106 , CRS 1973 , -1- 790503 M the Water Quality Control Act , Section 25- 8-404 , CRS 1973 , and the Due Process clause of the Colorado Constitution, Article II , Section 25 . BOARD OF COUNTY COMMISSIONERS OF WELD COUNTY, COLORADO By: LEE D. MORRISON #8067 Assistant County Attorney 915 10th Street Greeley, Colorado 80631 (303) 356-4000 ext . 369 THE TOWN OF FREDERICK, COLORADO ; TFIE CITY OF FT . LUPTON, COLORADO ; THE WEISNER SUBDIVISION PRESERVA- TION ASSOCIATION By: FRANCIS K. CULKIN #2969 Attorney at Law 720 South Colorado Blvd. Denver, Colorado 80222 (303) 759- 3495 CERTIFICATE OF MAILING The undersigned hereby certifies that a true and correct copy of the above and foregoing MOTION TO STAY FINAL ORDER OR DETERMINATION PENDING CONSIDERATION OF MOTION TO RESCIND APPROVAL, FOR RECONSIDERATION, AND FOR APPEAL OF DECISION , was placed in the U. S . mail , postage prepaid to : John D. Musick , Jr . Musick, Williamson , Schwartz , Leavenworth $ Cope , P. C . Attorney at Law 75 Manhattan Drive - Suite 1 P. O. Box 4579 Boulder, Colorado 80360 Sharon Metcalf Assistant Attorney General 1575 Sherman Street Denver, Colorado 80203 DATED this day of July, 1979 . -2- Hello