Friends of Merry meeting Bay v. Central Maine Power Company

CourtSuperior Court of Maine
DecidedJanuary 15, 2021
DocketCUMbcd-cv-20-36
StatusUnpublished

This text of Friends of Merry meeting Bay v. Central Maine Power Company (Friends of Merry meeting Bay v. Central Maine Power Company) 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
Friends of Merry meeting Bay v. Central Maine Power Company, (Me. Super. Ct. 2021).

Opinion

STATE OF MAINE BUSINESS & CONSUMER COURT CUMBERLAND, ss. DOCKET NO. BCD-CV-2020-36

FRIENDS OF MERRYMEETING BAY, ) KATHLEEN MCGEE, ED FRIEDMAN, ) and COLLEEN MOORE ) ) Plaintiffs, ) COMBINED ORDER ON THE ) ENVIRONMENTAL HEALTH TRUST’S v. ) MOTION FOR LEAVE TO FILE AMICUS ) CURIAE BRIEF AND DEFENDANT’S ) MOTION TO DISMISS CENTRAL MAINE POWER COMPANY ) ) Defendant. )

Before the Court are the Environmental Health Trust’s (the “EHT’s”) motion for leave to

file an amicus curiae brief, and Defendant Central Maine Power Company’s (“CMP’s”) motion

to dismiss Plaintiffs’ complaint for failure to state a claim upon which relief can be granted in

accordance with M. R. Civ. P. 12(b)(6).

In its motion for leave to file an amicus curiae brief, the EHT asserts that neither the

Maine Rules of Civil Procedure, nor the Business and Consumer Docket Procedure Rules

prohibit the filing of an amicus brief by a non-party. For this reason, and because the EHT

asserts it has a substantial and compelling interest in the case, it requests leave from the Court to

file its brief. The Court denies EHT’s motion.

Separately, CMP moves to dismiss the Plaintiffs’ complaint asserting that the nuisance

claim is preempted by both Federal Aviation Administration (“FAA”) and Federal

Communications Commission (“FCC”) regulations. Conversely, Plaintiffs assert that the FAA’s

guidance to CMP constitutes a legally unenforceable recommendation rather than a set of

requirements, and that the FCC regulations cited by CMP are inapplicable to the facts of this

1 case. The Court finds Plaintiffs’ nuisance claims subject to preemption, and thus grants CMP’s

motion to dismiss in its entirety. Plaintiffs are represented by Attorneys Bruce Merrill, William

Most, and David Lanser. CMP is represented by Attorneys Gavin McCarthy and Matthew

Altieri. The Environmental Heath Trust is represented by Attorney Scott Sells.

FACTUAL BACKGROUND

In 2019, CMP replaced two utility towers that support power lines across the Chops

Passage of the Kennebec River as the river flows into Merrymeeting Bay. While the old towers

were 195-feet-tall, the new towers reach approximately 240-feet-tall. The towers are outfitted

with flashing safety lights, aimed at alerting aircraft of their presence. Additionally, in response

to concerns from Plaintiffs and other members of the public about the frequency of flashing

lights, the towers will include an Active Aircraft Detection Lighting System (the “Radar

System”) that uses radar to trigger the flashing lights when aircraft are detected within

approximately 3.5 miles of the towers.

In accordance with FAA regulations, CMP filed public notice of the proposed tower

construction with the Secretary of the FAA. In response, the FAA issued a “determination of no

hazard to air navigation” with respect to the towers on March 12, 2018. (Pl.’s Ex. A). The no

hazard determination explained that the FAA had conducted an aeronautical study, which

“revealed that the structure does not exceed obstruction standards and would not be a hazard to

air navigation, provided certain conditions are met. Id. The FAA’s determination was

conditioned on the structure being “marked/lighted in accordance with an FAA Advisory

Circular. 1

1 See FAA Circular 70/746001 L Change 1, Obstruction Marking and Lighting, a med-dual system—Chapters 4, 8,(M-Dual),&12” (“The FAA Safety Lighting Standards”)

2 On March 25, 2020, in response to a revised submission by CMP to cover the use of the

Radar System, the FAA issued a new determination of no hazard, again conditioned on the

marking of the towers and utilization of a lighting system. In issuing its determination, the FAA

provided that the towers are subject to the licensing authority of the FCC. Next, on July 21, 2020

the FCC issued CMP a radio station authorization permitting the towers to broadcast using

frequencies of 9.2-9.5 GHz. Plaintiffs requested the FCC conduct an environmental assessment,

but the FCC declined, apparently finding that the Radar System did not cause RF exposure

exceeding the FCC’s safety standards. See 47 C.F.R. § 1.1306(c)(2) & 1.1307.

LEGAL STANDARD

Two motions are before the Court in this matter: 1) the EHT’s motion for leave to file

amicus curiae, and 2) CMP’s motion to dismiss the complaint for failure to state a claim under M.

R. Civ. P. 12(b)(6).

First, the term amicus curiae implies “the friendly intervention of counsel to remind the

Court of some matter of law which might otherwise escape its notice and in regard to which it

might go wrong.” Hamlin v. “Perticuler Baptist Meeting House”, 103 Me. 343, 69 A. 315, 318

(Me. 1907). Unlike appeals, the Maine Rules of Civil Procedure neither authorize nor prohibit the

filing of an amicus brief by a non-party in the Business and Consumer Court when it serves as a

trial court. Though not applicable at the trial court level, the Rules of Appellate Procedure permit

amicus curiae briefs to be filed if parties to the appellate proceeding consent, “or by leave of the

Law Court.” M.R. App. P. 7A(e)(1)(A).

Maine Trial Courts have previously considered amicus filings under limited circumstances.

See e.g. United States Bank N.A. v. Cozzone, 2019 Me. Super. LEXIS 109, *4. However, the First

3 Circuit Court of Appeals has urged caution with respect to the federal trial courts: “We believe

that a district court lacking joint consent of the parties should go slow in accepting” an amicus

brief. Strasser v. Doorley, 432 F.2d 567, 569 (1st Cir. 1970). 2 As such, the Court will grant an

amicus curiae brief only where there is good reason to believe it can assist the Court reach a correct

legal conclusion.

Second, when reviewing a motion to dismiss under Rule 12(b)(6), the Court “consider[s]

the facts in the complaint as if they were admitted.” Bonney v. Stephens Mem. Hosp., 2011 ME 46,

¶ 16, 17 A.3d 123. The complaint is viewed “in the light most favorable to the plaintiff to determine

whether it sets forth elements of a cause of action or alleges facts that would entitle the plaintiff to

relief pursuant to some legal theory. Id. (quoting Saunders v. Tisher, 2006 ME 94, ¶ 8, 902 A.2d

830). “Dismissal is warranted when it appears beyond a doubt that the plaintiff is not entitled to

relief under any set of facts that [it] might prove in support of [its] claim.” Id.

DISCUSSION

I. EHT’s Motion for Leave to File an Amicus Curiae Brief

In support of its motion for leave to file an amicus curiae brief, EHT asserts that it has a

substantial and compelling interest in the case, and can aid the Court in addressing the unique

and significant harm suffered by those who cannot seek relief from federal agencies.

Specifically, EHT describes the light and radio frequencies emitted from the Towers as

“needless” and believes there is a likelihood of harmful health and environmental effects

stemming therefrom. “As a leader in state-of-the art scientific research into the areas of harm

2 The First Circuit has also noted that “the prime if not sole, purpose of an amicus curiae brief is what its name implies, namely, to assist the court on matters of law.” Banjeree v. Bd.

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

Related

Rice v. Santa Fe Elevator Corp.
331 U.S. 218 (Supreme Court, 1947)
City of Burbank v. Lockheed Air Terminal, Inc.
411 U.S. 624 (Supreme Court, 1973)
Jones v. Rath Packing Co.
430 U.S. 519 (Supreme Court, 1977)
Freightliner Corp. v. Myrick
514 U.S. 280 (Supreme Court, 1995)
Buckman Co. v. Plaintiffs' Legal Committee
531 U.S. 341 (Supreme Court, 2001)
Farina v. Nokia, Inc.
625 F.3d 97 (Third Circuit, 2010)
US Airways, Inc. v. O'DONNELL
627 F.3d 1318 (Tenth Circuit, 2010)
Arnold E. Strasser v. Joseph A. Doorley, Jr.
432 F.2d 567 (First Circuit, 1970)
Timothy French v. Pan Am Express, Inc.
869 F.2d 1 (First Circuit, 1989)
Arizona v. United States
132 S. Ct. 2492 (Supreme Court, 2012)
Saunders v. Tisher
2006 ME 94 (Supreme Judicial Court of Maine, 2006)
Bonney v. Stephens Memorial Hospital
2011 ME 46 (Supreme Judicial Court of Maine, 2011)
Carlin Robbins v. New Cingular Wireless PCS, LLC
854 F.3d 315 (Sixth Circuit, 2017)
Hamlin v. Perticuler Baptist Meeting House
69 A. 315 (Supreme Judicial Court of Maine, 1907)

Cite This Page — Counsel Stack

Bluebook (online)
Friends of Merry meeting Bay v. Central Maine Power Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/friends-of-merry-meeting-bay-v-central-maine-power-company-mesuperct-2021.