BMR Brunswick, LLC v. Maine Dep't of Environmental Protection

CourtSuperior Court of Maine
DecidedJuly 2, 2014
DocketCUMap-13-077
StatusUnpublished

This text of BMR Brunswick, LLC v. Maine Dep't of Environmental Protection (BMR Brunswick, LLC v. Maine Dep't of Environmental Protection) is published on Counsel Stack Legal Research, covering Superior Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
BMR Brunswick, LLC v. Maine Dep't of Environmental Protection, (Me. Super. Ct. 2014).

Opinion

r£NTERED AUG n 8 201~~) STATE OF MAINE SUPERIOR COURT CUMBERLAND, ss CIVIL ACTION Docket No. AP-13-077 J4 vV- cvtm- V1-0~-Jtt BMR BRUSNWICK, LLC, et. al.

Petitioners

v. DECISION AND ORDER

STATE OF MAINE, DEPARTMENT OF ENVIRONMENTAL PROTECTION, et. al.

Respondents

This matter is before the Court on petitioner's 80C appeal of a decision

of the Maine Department of Environmental Protection ("MDEP") to issue a

stormwater management permit to respondent Northern New England

Passenger Rail Authority ("NNEPRA") for the construction of a railroad

maintenance facility. Petitioners argue that they are "abutters" under MDEP

rules and therefore were entitled to notice of NNEPRA's permit application,

which they did not receive. NNEPRA and MDEP argue that petitioners are

not abutters and were therefore not entitled to notice under the rules.

The facts of this case are not in dispute. NNEPRA plans to construct a

passenger train layover facility on land it owns in Brunswick, Maine. One of

the permits NNEPRA was required to obtain to build the facility is the

Stormwater Law Permit ("Stormwater Permit") under 38 M.R.S. § 420-D

1 (2013). Under MDEP rules, a Stormwater Permit applicant is required to

mail notice of the application "to abutters, as determined by local tax records,

or other reliable means ...." 06-096 C.M.R. ch. 2, § 14(A). NNEPRA did not

notify the petitioners of their Stormwater Permit application.

The petitioners own property near the site of the proposed layover

facility, however, each of petitioners' lots is separated from NNEPRA's lot by

a strip of land owned by the State of Maine.l (R. at Tab 12.) In 1991, the

Maine Central Railroad Company conveyed the strip of land 2 abutting

NNEPRA's lot to the State but reserved for itself a "rail freight easement"

over the property. (Stipulations ~ 4.) Railroad tracks pass over the State's

land that NNEPRA and others use to transport passengers and freight.

(Stipulations ~ 5.)

Analysis

1. Standard of Review

In reviewing agency action pursuant to M.R. Civ. P. SOC, "review is

limited to whether the government agency abused its discretion, committed

an error of law, or made findings not supported by substantial evidence in the

record." Seider v. Bd. of Exam'rs of Psychologists, 2000 ME 206, ~ 8, 762 A.2d

551 (quotation marks omitted). "Considerable deference is given to the

agency's interpretation of its own rules, regulations, and procedures, and [the

1 The parties agree that the Brunswick tax map incorrectly shows NNEPRA as the owner of Lot 18 on Tax Map U26. (Stipulations «JJ 1.) The State acquired that lot by deed in 1991 and still owned it as of the date of NNEPRA's permit application. (Stipulations «JJ 2.) 2 The strip of land consists of Lot 92 on Tax Map U23 and Lot 18 on Tax Map U26. (Stipulations 'l['l[ 2-3; R. at Tab 12.)

2 court] will not set aside the agency's findings unless the rule or regulation

plainly compels a contrary result." Mulready v. Bd. of Real Estate Appraisers,

2009 ME 135, ~ 13, 984 A.2d 1285 (quotation marks omitted).

2. Standing

NNEPRA challenges petitioners' standing to bring the appeal.

"Whether a party has standing depends on the wording of the specific statute

involved." Nelson v. Bayroot, LLC, 2008 ME 91, ~ 9, 953 A.2d 378. In this

case, MDEP's rules provide:

Any person may seek judicial review of a final Commissioner or Board decision by filing a petition in Superior Court in accordance with 5 M.R.S. section 11001 et seq. and M.R. Civ. P. 80C, except where otherwise provided by law. The filing of an appeal with the Board is not a prerequisite for a judicial appeal.

06-096 C.M.R. ch. 2, § 28. Accordingly, the Maine Administrative Procedure

Act ("Maine APA") is the governing statute for petitioners' appeal.

Under the Maine APA, "any person who is aggrieved by final agency

action" is entitled to judicial review. 5 M.R.S. § 11001(1) (2013). "A person is

aggrieved within the meaning of the AP A if that person has suffered

particularized injury-that is, if the agency action operated prejudicially and

directly upon the party's property, pecuniary or personal rights." Nelson,

2008 ME 91, ~ 10, 953 A.2d 378. NNEPRA argues that petitioners have not

suffered any particularized injury to confer standing in this case.

A party that demonstrates a particularized injury is free to ra1se

procedural issues that affect the validity of an administrative decision,

3 regardless of whether those specific issues are related to the alleged injury.

Matter of Lappie, 377 A.2d 441, 443 (Me. 1977). Thus, petitioners in this case

do not need to show that their property will be affected by stormwater runoff,

which is the subject of the permit. The standing analysis is more general: the

issue is "whether the asserted effect on the party's rights genuinely flows

from the challenged agency action." Nelson, 2008 ME 91, , 10, 953 A.2d 378.

"An abutter generally has standing to participate in and appeal from

local administrative decision-making regarding zoning and land use issues."

Wister v. Town of Mount Desert, 2009 ME 66, , 12, 97 4 A.2d 903. Even if

petitioners were not abutters under MDEP's rules, their close proximity to

the project site makes them abutters for the purposes of standing. Sahl v.

Town of York, 2000 ME 180, , 9, 760 A.2d 266. "When the appealing party is

an abutter, the party need only allege 'a potential for particularized injury' to

satisfy the standing requirement." Sproul v. Town of Boothbay Harbor, 2000

ME 30, , 6, 746 A.2d 368.

Petitioners allege that they will be negatively impacted by increased

noise, vibrations, and emissions if the railway facility is constructed. These

allegations are sufficient to give petitioners standing. See Sahl, 2000 ME 180,

, 10, 760 A.2d 266 (finding standing where petitioners alleged motel

expansion would obstruct their view of the ocean and create more traffic);

Matter of Lappie, 377 A.2d at 443 (finding standing where petitioner alleged

4 that a waste disposal facility might "pose problems of rodent control, litter,

and seepage into ground water").

3. Actual Notice

NNEPRA argues that, even if petitioners did not receive the notice

required under the rules, they nevertheless had actual notice of the

application but chose not to participate in the permitting process. At most,

NNEPRA can only point to evidence in the record that shows one of

petitioners, Daniel Sullivan, had knowledge that NNEPRA was applying for

a Stormwater Permit. NNEPRA asks the court to infer that the other

petitioners also had knowledge. The court declines to make such an inference.

Because there is no evidence with respect to the other petitioners' knowledge,

NNEPRA' s actual notice argument lacks merit.

4. Abutters

The crux of this case requires the court to decide a simple question: are

petitioners abutters under MDEP rules? If petitioners are abutters, they were

entitled to notice of NNEPRA's Stormwater Permit application.

MDEP rules define abutter as follows:

A. Abutter.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Mulready v. BOARD OF REAL ESTATE APPRAISERS
2009 ME 135 (Supreme Judicial Court of Maine, 2009)
Sahl v. Town of York
2000 ME 180 (Supreme Judicial Court of Maine, 2000)
Wister v. Town of Mount Desert
2009 ME 66 (Supreme Judicial Court of Maine, 2009)
Matter of Lappie
377 A.2d 441 (Supreme Judicial Court of Maine, 1977)
Seider v. Board of Examiners of Psychologists
2000 ME 206 (Supreme Judicial Court of Maine, 2000)
Sproul v. Town of Boothbay Harbor
2000 ME 30 (Supreme Judicial Court of Maine, 2000)
Schaefer v. State Tax Assessor
2008 ME 148 (Supreme Judicial Court of Maine, 2008)
Nelson v. Bayroot, LLC
2008 ME 91 (Supreme Judicial Court of Maine, 2008)

Cite This Page — Counsel Stack

Bluebook (online)
BMR Brunswick, LLC v. Maine Dep't of Environmental Protection, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bmr-brunswick-llc-v-maine-dept-of-environmental-protection-mesuperct-2014.