E&B Natural Resources Management Corporation v. County of Alameda

CourtDistrict Court, N.D. California
DecidedNovember 4, 2019
Docket4:18-cv-05857
StatusUnknown

This text of E&B Natural Resources Management Corporation v. County of Alameda (E&B Natural Resources Management Corporation v. County of Alameda) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
E&B Natural Resources Management Corporation v. County of Alameda, (N.D. Cal. 2019).

Opinion

1 2 3 4 5 6 7 UNITED STATES DISTRICT COURT 8 NORTHERN DISTRICT OF CALIFORNIA 9 10 E&B NATURAL RESOURCES MANAGEMENT CASE NO. 18-cv-05857-YGR CORPORATION, ET AL., 11 Plaintiffs, ORDER DENYING MOTION TO INTERVENE 12 vs. Re: Dkt. No. 41 13 COUNTY OF ALAMEDA, ET AL., 14 Defendants. 15 16 Plaintiffs E&B Natural Resources Management Corporation (“E&B”); Laurie Volm; 17 Sharyl G. Bloom and Richard S. Bloom, co-trustees of The Lynn Bloom Trust; James C. Roth; 18 Dolores D. Michaelson; and Michael Karpé initiated this action against defendants County of 19 Alameda and Alameda County Board of Supervisors (the “Board”) (collectively, the “County”) 20 seeking to overturn the Board’s July 24, 2018 decision not to renew two conditional use permits 21 (“CUPs”) which defendants maintain are predicates to E&B’s continued operation of an oil 22 extraction and production facility on two parcels of land in Livermore, California. 23 Proposed defendant-intervenor, Center for Biological Diversity (“Center”), seeks to 24 intervene as a matter of right and permissively under Federal Rule of Civil Procedure 24. The 25 Center argues it is entitled to intervene because it spearheaded the administrative appeal 26 overturning the conditional approval of the CUPs, and the disposition of this lawsuit threatens 27 those efforts. In addition, the Center seeks to intervene to protect its interests in environmental 1 conservation and the welfare of nearby communities.1 2 Having carefully considered the papers submitted and the pleadings in this action, and for 3 the reasons set forth below, the Court hereby DENIES the motion to intervene. 4 I. BACKGROUND 5 The following background is taken from the First Amended Complaint (“FAC”): 6 Since 1966, E&B and its predecessors have possessed a series of CUPs permitting E&B to 7 operate an oil extraction and production facility on two parcels of land in Livermore, California. 8 In May of 2018, the Alameda County Planning Commission, East County Board of Zoning 9 Adjustments conditionally approved E&B’s permit renewal applications. The Center, an Alameda 10 County-based public interest group focused on environmental protection and combating climate 11 change, along with the Livermore EcoWatchdogs, appealed the conditional approval to the Board. 12 On September 11, 2018, the Board granted the Center’s appeal and denied the CUPs renewals, 13 citing lack of public need, land use conflicts, and environmental concerns. 14 Plaintiffs bring this action seeking to overturn the Board’s decision to deny the two CUPs 15 for oil and gas extraction in Alameda County on the grounds that the Board’s decision was 16 “arbitrary and capricious,” and that the Board acted “in excess of its jurisdiction” by divesting 17 E&B of its vested rights to use the parcels. Plaintiffs assert that the decision violated plaintiffs’ 18 due process rights and the Board’s own procedural standards because the Board denied the CUPs 19 due solely to political pressure and not legitimate regulatory concerns. 20 II. LEGAL STANDARD 21 Intervention is a procedure by which a nonparty can gain party status without the consent 22 of the original parties. United States ex rel. Eisenstein v. City of New York, 556 U.S. 928, 933 23 (2009) (“intervention is the requisite method for a nonparty to become a party to a lawsuit”). Rule 24 24 contemplates two types of intervention: intervention of right and permissive intervention. 25 Intervention exists as a matter of right when a federal statute confers the right to intervene or the 26 applicant has a legally protected interest that may be impaired by disposition of the pending action 27 1 and that interest is not adequately represented by existing parties. Fed. R. Civ. P. 24(a). 2 Permissive intervention may be allowed at a court’s discretion when a federal statute confers a 3 conditional right to intervene, or the applicant’s claim or defense and the main action share a 4 common question of law or fact. Fed. R. Civ. P. 24(b). 5 III. ANALYSIS 6 A. Intervention as of Right – Rule 24(a) 7 Courts in the Ninth Circuit apply a four-part test to determine whether intervention should 8 be granted as a matter of right, namely the applicant must (1) assert a “significantly protectable” 9 interest relating to the property or transaction that is the subject of the action; (2) show that 10 disposition of the action without intervention may as a practical matter impair or impede its ability 11 to protect that interest; (3) be inadequately represented by the parties to the action; and (4) file a 12 timely application. Donnelly v. Glickman, 159 F.3d 405, 409 (9th Cir. 1998); Cabazon Band of 13 Mission Indians v. Wilson, 124 F.3d 1050, 1061 (9th Cir. 1997). The applicant bears the burden of 14 establishing all four elements, and the rule is construed “broadly in favor of intervention.” 15 Donnelly, 159 F.3d at 409. Failure to satisfy any one of the requirements is fatal to the 16 application, and a court need not reach the remaining elements if one of the elements is not 17 satisfied. Perry v. Proposition 8 Official Proponents, 587 F.3d 947, 950 (9th Cir. 2009). 18 The Court addresses each element in turn. 19 1. Significantly Protectable Interest 20 To determine if an applicant has a “significantly protectable” interest relating to the 21 property or transaction that is the subject of the action, the Court must consider whether: (1) the 22 asserted interest is protectable under some law, and (2) a relationship exists between the legally 23 protected interest and the claims at issue. Wilderness Soc. v. U.S. Forest Service, 630 F.3d 1173, 24 1179 (9th Cir. 2011). A would-be intervenor has a sufficient interest for intervention purposes if it 25 demonstrates that “it will suffer a practical impairment of its interests as a result of the pending 26 litigation.” California ex rel. Lockyer v. United States, 450 F.3d 436, 441 (9th Cir. 2006). 27 “Although the intervenor cannot rely on an interest that is wholly remote and speculative, the 1 City of Emeryville v. Robinson, 621 F.3d 1251, 1259 (9th Cir. 2010) (quoting United States v. 2 Union Elec. Co., 64 F.3d 1152, 1162 (8th Cir. 1995)). In the environmental law context, there are 3 two factors that weigh in favor of finding that a “significantly protectable” interest exists: the 4 group has an interest in seeing a wilderness area preserved for the use and enjoyment of its 5 members, or actively participates in the administrative process leading to the litigation. See e.g. 6 Wilderness Soc., 630 F.3d at 1180; Citizens for Balanced Use v. Montana Wilderness Ass’n, 647 7 F.3d 893, 897-98 (9th Cir. 2011); Sagebrush Rebellion, Inc. v. Watt, 713 F.2d 525, 526-28 (9th 8 Cir. 1983). 9 At oral argument, plaintiffs conceded that the Center has a significantly protectable interest 10 in the outcome of this action. The Court agrees. The Center is an Alameda County-based public 11 interest group focused on protecting the environment and combating climate change.

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Bluebook (online)
E&B Natural Resources Management Corporation v. County of Alameda, Counsel Stack Legal Research, https://law.counselstack.com/opinion/eb-natural-resources-management-corporation-v-county-of-alameda-cand-2019.