Citizens for a Clean Environment, LLC v. Aitkin Agri-Peat, Inc.

CourtDistrict Court, D. Minnesota
DecidedSeptember 8, 2025
Docket0:24-cv-02253
StatusUnknown

This text of Citizens for a Clean Environment, LLC v. Aitkin Agri-Peat, Inc. (Citizens for a Clean Environment, LLC v. Aitkin Agri-Peat, Inc.) is published on Counsel Stack Legal Research, covering District Court, D. Minnesota primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Citizens for a Clean Environment, LLC v. Aitkin Agri-Peat, Inc., (mnd 2025).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA

Citizens for a Clean Environment, LLC, Case No. 24-cv-02253 (ECW)

Plaintiff,

v. ORDER

Aitkin Agri-Peat, Inc.,

Defendant.

This matter is before the Court on Plaintiff Citizens for a Clean Environment, LLC’s (“CCE”) “Notice of Motion for Partial Summary Judgment” (Dkt. 20) and “Notice of Motion to Supplement the Record” (Dkt. 60); as well as Defendant Aitkin Agri-Peat, Inc.’s (“AAPI”) “Fed. R. Civ. P. 12(C) [sic] Motion for Judgment on the Pleadings” (Dkt. 24), “Fed. R. Civ. P. 15(a)(2) Motion to Amend Its Answer” (Dkt. 33), “Fed. R. Civ. P. 11 Motion for Sanctions Against Citizens for a Clean Environment, LLC and its Counsel Patrick W. Michenfelder of Throndset Michenfelder Law Offices, LLC” (Dkt. 37), and “Motion to Strike Plaintiff’s (1) Supplemental Declaration and (2) Related Reply Brief Argument” (Dkt. 50). The parties jointly consented to this Court’s jurisdiction on September 17, 2024. (Dkt. 14; see also Dkt. 16 (order effectuating consent).) The Court heard argument on the Motions on February 10, 2025. (Dkt. 54 (minute entry).) The Court addresses the Motions below. I. BACKGROUND This case concerns discharges of wastewater by a peat1 mine owned and operated by AAPI. CCE alleges that the Aitkin Peat Mine (“the Plant”), located at 1303 Peat Plant

Road in Cromwell, Minnesota (Dkt. 1 ¶ 9; Dkt. 29 at 1), sits south of East Highway 210 and is in proximity to Fond du Lac State Forest, the Sawyer State Wildlife Area, the Kettle Lake State Wildlife Management Area, and the Carl Sandell Wildlife Management Area (see Dkt. 1 ¶ 24; Dkt. 49 ¶ 12). As a part of its mining operations, the Plant discharges wastewater into a system of drainage ditches, which in turn flow west until the wastewater reaches the Kettle River. (Dkt. 26-2 at 28; see Dkt. 1 ¶ 23.) This wastewater is discharged under AAPI’s National Pollution Discharge Elimination System/State

Disposal System (“NPDES”) permit. (Dkt. 1 ¶ 23; see Dkt. 26-2 at 26-70.) In its Complaint, CCE alleges that the Plant’s wastewater discharges have “unlawfully low pH levels,” thereby violating the terms of its NPDES permit and consequently the Clean Water Act (Count I) and that the Plant’s conduct in discharging such wastewater constitutes Minnesota common law negligence (Count II). (Dkt. 1 ¶¶ 2, 45-61.) A. The Clean Water Act and NPDES Permitting in Minnesota The Clean Water Act (“CWA” or “Act”) was implemented “to restore and

maintain the chemical, physical, and biological integrity of the Nation’s waters” by

1 “Peat is the surface organic layer of a soil that consists of partially decomposed organic matter, derived mostly from plant material, which has accumulated under conditions of waterlogging, oxygen deficiency, high acidity and nutrient deficiency.” Peat, Int’l Peatland Soc’y, https://peatlands.org/peat/#:~:text=Peat%20is%20the% 20surface%20organic,high%20acidity%20and%20nutrient%20deficiency (last visited Sept. 8, 2025). Peat has several uses, ranging from horticulture, energy production, chemistry, and textiles. Id. creating a federal regime for regulating water pollution. 33 U.S.C. § 1251. “A central provision of the Act is its requirement that individuals, corporations, and governments secure National Pollutant Discharge Elimination System (NPDES) permits before

discharging pollution from any point source into the navigable waters of the United States.” Decker v. Nw. Env’t Def. Ctr., 568 U.S. 597, 602 (2013); see 33 U.S.C. § 1342 (describing permitting system for discharge of pollutants). The Act authorizes the Environmental Protection Agency (“EPA”) to issue permits for the discharge of pollutants subject to the requirements of the Act and other conditions. See 33 U.S.C. § 1342(a)(1); see also Env’t Prot. Agency v. California ex rel. State Water Res. Control Bd., 426 U.S. 200, 206 (1976) (“NPDE permits are secured, in the first instance, from the

EPA, which issues permits under the authority of s 402(a)(1).”); United States v. Sinskey, 119 F.3d 712, 715 (8th Cir. 1997) (“The NPDES authorizes the EPA to issue permits that allow the discharge of certain pollutants within specified limitations and with specified reporting and monitoring conditions.”). Under the CWA, “it is unlawful for any person to discharge a pollutant without obtaining a [NPDES] permit and complying with its terms.” California ex rel. State Water Res. Control Bd., 426 U.S. at 205; see also 33 U.S.C. § 1311(a). “Without more,

to violate an NPDES permit is to violate the Act.” United States v. STABL, Inc., 800 F.3d 476, 483 (8th Cir. 2015) (citation modified). Thus, the CWA “prohibits the discharge of pollutants in amounts exceeding the limitations specified in an NPDES permit.” United States v. Sinskey, 119 F.3d 712, 715 (8th Cir. 1997). Moreover, if a permit holder acts in compliance with their NPDES permit, the holder is typically shielded from enforcement under the CWA. 33 U.S.C. § 1342(k); see California ex rel. State Water Res. Control Bd., 426 U.S. at 205 (“With few exceptions, for enforcement purposes a discharger in compliance with the terms and conditions of an NPDES permit is deemed to be in compliance with those sections of the [CWA] on which the permit conditions are

based.”). A State can, with the approval of the EPA, take on issuing responsibilities for the waters within its own borders. See 33 U.S.C. § 1342(b); California ex rel. State Water Res. Control Bd., 426 U.S. at 207. The State of Minnesota has sought and obtained authorization to issue NPDES permits in Minnesota, where the Minnesota Pollution Control Agency (“MPCA”) performs this function. See Minn. Stat. § 115.03, subd. 1(a)(1), (3), (5), subd. 5 (Supp. 2025). “Accordingly, under the Minnesota Water

Pollution Control Act, Minn. Stat. §§ 115.01-09 (2020), the MPCA has the authority to administer and enforce all laws relating to the pollution of any waters of the state, including the authority to issue permits requiring compliance with the CWA.” In re Reissuance of an NPDES/SDS Permit to U. S. Steel Corp., 954 N.W.2d 572, 576 (Minn. 2021) (citation modified). The MPCA has designated Minnesota waters into different classes. Id. at 577. “As required by the Water Pollution Control Act and CWA, the MPCA adopts and

applies water quality and purity standards for each class of waters.” Id. Chapter 7050 of the Minnesota Rules sets forth the MPCA’s classification and associated quality standards. Id. (citing Minn. R. 7050.0110 (2019)). Relevant here, Minnesota Rule 7050.0170 states: 7050.0170 NATURAL WATER QUALITY. The waters of the state may, in a natural condition, have water quality characteristics or chemical concentrations approaching or exceeding the water quality standards.

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