ESTATE OF WINIFRED SKORSKI VS. NEW JERSEY ECONOMIC DEVELOPMENT AUTHORITY (NEW JERSEY ECONOMIC DEVELOPMENT AUTHORITY)

CourtNew Jersey Superior Court Appellate Division
DecidedMarch 20, 2019
DocketA-3314-17T2
StatusUnpublished

This text of ESTATE OF WINIFRED SKORSKI VS. NEW JERSEY ECONOMIC DEVELOPMENT AUTHORITY (NEW JERSEY ECONOMIC DEVELOPMENT AUTHORITY) (ESTATE OF WINIFRED SKORSKI VS. NEW JERSEY ECONOMIC DEVELOPMENT AUTHORITY (NEW JERSEY ECONOMIC DEVELOPMENT AUTHORITY)) is published on Counsel Stack Legal Research, covering New Jersey Superior Court Appellate Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
ESTATE OF WINIFRED SKORSKI VS. NEW JERSEY ECONOMIC DEVELOPMENT AUTHORITY (NEW JERSEY ECONOMIC DEVELOPMENT AUTHORITY), (N.J. Ct. App. 2019).

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court." Although it is posted on the internet, this opinion is binding only on the parties in the case and its use in other cases is limited. R. 1:36-3.

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-3314-17T2

ESTATE OF WINIFRED SKORSKI,

Appellant,

v.

NEW JERSEY ECONOMIC DEVELOPMENT AUTHORITY,

Respondent. _______________________________

Argued March 4, 2019 – Decided March 20, 2019

Before Judges Sumners and Mitterhoff.

On appeal from the New Jersey Economic Development Authority.

Michael G. Sinkevich argued the cause for appellant (Lieberman & Blecher PC, attorneys; Stuart J. Lieberman and Michael C. Kondrla, of counsel; Michael C. Kondrla and Michael D. Sinai, on the briefs).

Laura Drahushak, Deputy Attorney General, argued the cause for respondent (Gurbir S. Grewal, Attorney General, attorney; Laura Drahushak, on the brief). PER CURIAM

Appellant, Estate of Winifred Skorski ("Estate"), appeals the New Jersey

Economic Development Authority's ("EDA") final agency decision denying its

application for a conditional hardship grant pursuant to the Underground Storage

Finance Act, N.J.S.A. 58:10A-37.1 to -37.23 ("UST Act" or "the Act"). Under

the Act, owners or operators of leaking underground petroleum storage tanks

may receive grants or loans for the upgrade or closure of tanks and the

remediation of contaminated properties. See N.J.S.A. 58:10A-37.49(a).1 To

receive a conditional hardship grant, an applicant, among other requirements,

"cannot reasonably be expected to repay all or a portion of the eligible project

costs if the financial assistance were to be awarded as a loan." N.J.S.A. 58:10A-

37.5(c)(1).

The Act and its implementing regulations do not discuss applications by

estates, but the EDA applies informal guidance contained in application

materials to evaluate applications by estates. The Estate challenges this informal

guidance, particularly a requirement that an estate's assets exceed its liabilities

in order to qualify for a conditional hardship grant, as improper de facto

1 The upgrade or closure of such tanks may be required by federal or state statutes. See N.J.S.A. 58:10A-37.4(a) (citing 42 U.S.C. 6991 to 6991(m) and N.J.S.A. 58:10A-21 to -35). A-3314-17T2 2 rulemaking that should have been subject to the formal rulemaking procedures

of the Administrative Procedure Act ("APA"), N.J.S.A. 52:14B-1 to -31.

For the reasons that follow, we agree with the Estate that certain

provisions of the EDA's informal guidance constitute improper de facto

rulemaking and reverse the EDA's denial of the Estate's application.

I.

The UST Act and Implementing Regulations

The UST Act established the Petroleum Underground Storage Tank

Remediation, Upgrade, and Closure Fund ("UST Fund") as a "special, revolving

fund" administered by the EDA. N.J.S.A. 58:10A-37.3(a). The UST Fund is

administered jointly by the New Jersey Department of Environmental Protection

("DEP") and the EDA. See N.J.S.A. 58:10A-37.12. Applicants seeking

assistance from the UST Fund must first apply to the DEP for consideration of

technical compliance with the cost guidelines developed by the DEP. N.J.A.C.

19:31-11.8(a). If the DEP deems the costs of the projects eligible, the EDA then

evaluates the applicant's financial condition to determine eligibility for a grant

or a loan. See N.J.A.C. 19:31-11.8 to -11.10.

The EDA "may award financial assistance from the fund to an eligible

owner or operator in the form of a loan or a conditional hardship grant[.]"

A-3314-17T2 3 N.J.S.A. 58:10A-37.5(a)(1). "A conditional hardship grant for eligible project

costs of an upgrade, closure or remediation shall be awarded by the [EDA] based

upon a finding of eligibility and financial hardship and upon a finding that the

applicant meets the criteria set forth in this act." N.J.S.A. 58:10A-37.5(c)(1).

By contrast, "[a] loan to an eligible owner or operator for the eligible project

costs of an upgrade, closure, or remediation shall be awarded by the authority

only upon a finding that the applicant other than a public entity is able to repay

the amount of the loan." N.J.S.A. 58:10A-37.59(c)(2).

The Act provides two initial eligibility criteria for a conditional grant for

remediation: (1) ownership of a qualifying tank; and (2) income and net worth

limits:

In order to be eligible for a conditional hardship grant for remediation, in the case of a regulated tank, the applicant shall have owned or operated the subject regulated tank at the time of tank closure. No applicant shall be eligible for a conditional hardship grant if the applicant has a taxable income of more than $250,000 or a net worth, exclusive of the applicant's primary residence and pension, of over $500,000. Any applicant with a taxable income of more than $200,000 who qualifies for a grant shall be required to pay no more than $1,000 of the eligible project costs.

[Ibid.]

The Act provides additional criteria for evaluating financial hardship:

A-3314-17T2 4 A finding of financial hardship by the authority shall be based upon a determination that an applicant cannot reasonably be expected to repay all or a portion of the eligible project costs if the financial assistance were to be awarded as a loan. The amount of an award of a conditional hardship grant shall be the amount of that portion of the eligible project costs the authority determines the applicant cannot reasonably be expected to repay.

[. . .] In making a finding of financial hardship for an application for the upgrade or remediation of a petroleum underground storage tank, where the petroleum underground storage tank is not a part of the business property of the owner, the authority shall base its finding upon the applicant's taxable income in the year prior to the date of the application being submitted.

Accordingly, for an application not pertaining to a business property, a

finding of financial hardship is based on: (1) "a determination that an applicant

cannot reasonably be expected to repay all or a portion of the eligible project

costs if the financial assistance were to be awarded as a loan" and (2) "the

applicant's taxable income in the year prior to the date of the application being

submitted." N.J.S.A. 58:10A-37.5(c)(1).

All recipients of loans, as well as recipients of a conditional hardship grant

for a property other than the recipient's residence, are subject to a lien on the

property in the amount of financial assistance awarded to the applicant. N.J.S.A.

A-3314-17T2 5 58:10A-37.16(a). Recipients of a conditional hardship grant for a tank at the

recipient's primary residence, however, are not subject to a lien on the property.

Ibid.

For conditional hardship grants, the lien is "removed upon repayment of

the amount of the grant that is unsatisfied or upon the end of a five-year period

in which the site . . . continued to be operated in substantially the same manner

as it was operated at the time of the award of financial assistance." N.J.S.A.

58:10A-37.16(c). In contrast, a recipient of a loan is required to repay the loan.

N.J.S.A. 58:10A-37.16(b) ("A lien that is filed on real property pursuant to a

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ESTATE OF WINIFRED SKORSKI VS. NEW JERSEY ECONOMIC DEVELOPMENT AUTHORITY (NEW JERSEY ECONOMIC DEVELOPMENT AUTHORITY), Counsel Stack Legal Research, https://law.counselstack.com/opinion/estate-of-winifred-skorski-vs-new-jersey-economic-development-authority-njsuperctappdiv-2019.