John Pitt v. Public Service Commission of Kentucky

CourtCourt of Appeals of Kentucky
DecidedMarch 20, 2024
Docket2023 CA 000704
StatusUnknown

This text of John Pitt v. Public Service Commission of Kentucky (John Pitt v. Public Service Commission of Kentucky) is published on Counsel Stack Legal Research, covering Court of Appeals of Kentucky primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
John Pitt v. Public Service Commission of Kentucky, (Ky. Ct. App. 2024).

Opinion

RENDERED: MARCH 22, 2024; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2023-CA-0704-MR

JOHN PITT AND STEVE BALDWIN APPELLANTS

APPEAL FROM SIMPSON CIRCUIT COURT v. HONORABLE MARK A. THURMOND, JUDGE ACTION NO. 22-CI-00018

PUBLIC SERVICE COMMISSION OF KENTUCKY; HORUS KENTUCKY 1, LLC; AND STATE BOARD ON ELECTRIC GENERATION AND TRANSMISSION SITING APPELLEES

OPINION AFFIRMING

** ** ** ** **

BEFORE: COMBS, LAMBERT, AND MCNEILL, JUDGES.

COMBS, JUDGE: Steve Baldwin and John Pitt (Baldwin and Pitt) appeal an order

of the Simpson Circuit Court affirming a final order of the Public Service

Commission’s State Board on Electric Generation and Transmission Siting (the

Siting Board). Upon its review of the administrative decision, the circuit court determined that the agency did not act arbitrarily or outside the scope of its

authority and that it had not applied the law incorrectly. After our review, we

affirm.

Horus Kentucky 1, LLC (Horus) proposed to build a solar

photovoltaic electric generating facility on its property in Simpson County. In July

2021, it filed an application for a construction certificate with the Siting Board. As

part of its application, HK1 submitted an economic impact analysis, a site

assessment report, and a property value impact study.

Pitt and Baldwin petitioned the Siting Board to intervene in the

proceedings, and their motion was granted. Pitt and Baldwin requested and

received a public hearing on Horus’s application. The hearing was scheduled for

November 15, 2021, at the Public Service Commission offices in Frankfort.

In September, Horus filed revisions to its economic impact analysis.

It also submitted a sound level assessment report; a transportation effect and route

evaluation report; a property value impact study; zoning regulations for the City of

Franklin and Simpson County; and its conditional use permit applications and

exhibits. The Siting Board retained Harvey Economics to perform an independent

review of Horus’s proposed facility and application. Harvey Economics provided

a written report to the Siting Board.

-2- The Siting Board’s public hearing lasted approximately two and-one-

half (2 ½) hours. It heard testimony from many interested parties, including

Baldwin and Pitt. Thereafter, Baldwin and Pitt filed a post-hearing memorandum.

The Siting Board also received and considered public comments of

three adjoining property owners. These property owners expressed concern about

the proximity of the proposed facility to local cemeteries.

On December 29, 2021, the Siting Board entered its order granting

Horus’s application for a certificate of construction for the proposed facility. The

Siting Board’s Final Order included findings and conclusions with respect to each

factor enumerated by the provisions of KRS1 278.710(1). Additionally, the Siting

Board imposed thirty-two (32) mitigation measures and conditions upon

construction of the facility.

In January 2022, pursuant to the provisions of KRS 278.712, Baldwin

and Pitt filed an action against the Siting Board in Simpson Circuit Court

requesting that its final order be vacated on grounds that it was arbitrary,

capricious, or otherwise unlawful or unreasonable. Baldwin and Pitt alleged that

the evidence of record confirmed that the construction certificate should not have

been granted for numerous reasons:

including but not limited to the fact that the property around the proposed site is currently used for agricultural

1 Kentucky Revised Statutes.

-3- purposes and the solar panels will be clearly visible from the surrounding properties; the proposed site will not be in conformity with the rest of the countryside; there is no way that the solar farm can be completely concealed with vegetation; the proposed site will transform a quaint and quiet agricultural neighborhood to an industrial powerplant zone; the property value of surrounding acreage will be decreased; the existing roadways do not have sufficient space to allow construction vehicles to access the proposed solar farm site; the proposed site does not make adequate considerations for burial grounds and cemeteries; and it is still in question whether the proposed site complies with the applicable planning and zoning regulations in Simpson County, Kentucky.

The Siting Board and Horus denied that the administrative decision

was unsupported by substantial evidence and observed that the circuit court could

not substitute its judgment for that of the administrative agency. Pursuant to

statute, and on behalf of the Siting Board, the Public Service Commission certified

and filed with the circuit court two flash drives that contained an electronic copy of

its official administrative record of the proceedings.

Following a period of briefing, the matter was submitted to the circuit

court. Baldwin and Pitt argued that the order of the Siting Board was arbitrary,

capricious, and unsupported by substantial evidence because the Siting Board “did

not adequately consider the impact of the solar farm on scenic surroundings,

property values, noise levels, surrounding roads, and the economy.” The Siting

Board responded that it “conducted a robust review of the application and created a

substantial record that demonstrates the decision to grant the certificate to construct

-4- was not arbitrary or capricious because it is supported by substantial evidence.” In

reply, Baldwin and Pitt argued that the findings of the Siting Board were “contrary

to evidence on the record.”

The circuit court surveyed the evidence and considered the applicable

law. It concluded that the Siting Board correctly based its decision upon the

factors set out in KRS 278.710(1) and that its final order was supported by

substantial evidence. The circuit court denied the subsequent motion of Baldwin

and Pitt to alter, amend, or vacate, the order. This appeal followed.

Baldwin and Pitt “do not argue that the Siting Board and Simpson

Circuit Court did not have the benefit of voluminous records, data, testimony, and

reports.” Instead, “they contend that the sheer volume of information presented is

not enough to satisfy the substantial evidence requirement.” They challenge

evidence concerning the efficacy of vegetative buffers and the use of setbacks --

relying instead on their own testimony indicating that the facility would

significantly alter the agricultural character of the area and fail to conform to the

countryside. They argue that the Siting Board received no evidence “as to the solar

farm’s conformity with its surroundings.” They also challenge the value of reports

relied upon by the Siting Board; the substance of an interview with the county’s

property valuation administrator; the existence of evidence related to noise levels

associated with operation of the facility; the interpretation of a report related to

-5- vehicular access to the construction site; and, finally, the quality of an economic

impact analysis. They contend that the Siting Board’s decision to grant a

certificate of construction “was wholly unsupported by substantial evidence.”

The arguments advanced by Baldwin and Pitt rely exclusively upon

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Related

Commonwealth v. Thompson
697 S.W.2d 143 (Kentucky Supreme Court, 1985)

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John Pitt v. Public Service Commission of Kentucky, Counsel Stack Legal Research, https://law.counselstack.com/opinion/john-pitt-v-public-service-commission-of-kentucky-kyctapp-2024.