Mahoney v. U.S. Department of the Interior

CourtDistrict Court, E.D. New York
DecidedApril 12, 2022
Docket2:22-cv-01305
StatusUnknown

This text of Mahoney v. U.S. Department of the Interior (Mahoney v. U.S. Department of the Interior) is published on Counsel Stack Legal Research, covering District Court, E.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Mahoney v. U.S. Department of the Interior, (E.D.N.Y. 2022).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK ------------------------------------------------x PAMELA MAHONEY, et al.,

Plaintiffs, MEMORANDUM AND ORDER -against- Case No. 22-cv-01305-FB-ST

U.S. DEPARTMENT OF THE INTERIOR, et al.,

Defendants. ------------------------------------------------x

Appearances: For the Plaintiffs: For Defendants: ERIC GRANT VINCENT LIPARI Hicks Thomas LLP United States Attorney’s Office 701 University Ave., Ste. 106 Eastern District of New York Sacramento, CA 95825 610 Federal Plaza, 5th Floor Central Islip, NY 11722 JOHN B. THOMAS JUSTIN BRAGA For Intervenor Defendant: CRYSTAL VICTORIA VENNING JANICE SCHNEIDER Hicks Thomas LLP STACEY VANBELLEGHAM 700 Louisiana, Ste. 2300 Lathan & Watkins LLP Houston, TX 77002 555 Eleventh St., N.W. Ste. 1000 Washington, D.C. 20004

KEGAN ANDREW BROWN Lathan & Watkins LLP 1271 Avenue of the Americas New York, NY 10020 BLOCK, Senior District Judge:

Plaintiffs Pamela Mahoney, Michael Mahoney, Lisa Solomon, and Mitch Solomon (“Plaintiffs”) are two married couples with residences in the Wainscott hamlet of East Hampton, New York. They seek a preliminary injunction1 to halt onshore trenching for the South Fork Wind Farm and South Fork Export Cable

Project (the “project”). Plaintiffs claim that the onshore digging will disrupt perfluoroalkyl and polyfluoroalkyl substances (“PFAs”) present in the groundwater, worsening the existing PFAS pollution in the wells on Plaintiffs’ properties. Defendants U.S. Department of the Interior (“DOI”), Bureau of Ocean Energy

Management (“BOEM”), U.S. Department of the Army (“Army”), and U.S. Army Corps of Engineers (“Army Corps”) (together, “Defendants”) are the federal government agencies that issued the permits for the offshore portion of the project

and the final environmental impact statement (“FEIS”) required by law to grant those permits. Defendant-Intervenor South Fork Wind, LLC (“SFW”) is the developer of the project. For the following reasons, Plaintiff’s motion is denied.

1 The Court previously denied the Plaintiffs’ First and Second Motions for Order to Show Cause insofar as they pertained to the temporary restraining order that plaintiffs sought. Therefore, the Court only addresses the preliminary injunction in this order. I. FACTS SFW is the developer of a commercial wind farm off the eastern shore of Long

Island. The wind farm is located in federal waters 35 miles east of Montauk Point, Long Island. To export the energy from the windmills to an existing onshore electric grid in East Hampton, trenches will be excavated to store underground cables which

will transfer the energy. The onshore route for the underground electric cables will pass by properties owned by the Plaintiffs in Wainscott. Plaintiffs, whose groundwater is presently contaminated by PFAS to the extent that they do not use their onsite water wells for drinking water, allege that trenching will exacerbate

PFAS contamination of the water on their properties. The permits to conduct the offshore portion of the project were issued by Defendants. For the onshore portion of the project, and specifically the trenching

that Plaintiffs claim will lead to further contamination of their groundwater, the permits were issued by the New York Public Service Commission (“NYPSC”). After years of administrative proceedings, the NYPSC issued a Certificate of Environmental Compatibility and Public Need under Article VII of the Public

Service Law allowing the project to move forward. These proceedings considered, among other things, the potential of the project to exacerbate PFAS contamination. The public was able to participate in the proceedings through hearings and the

submission of testimony or comments. Plaintiffs participated in this process. The NYPSC found that the project would not exacerbate existing PFAS contamination, in part because as proposed, the project provided for preventative measures to ensure

that groundwater flow was not materially altered. The NYPSC later denied a rehearing of the issue, holding that petitioners had not submitted sufficient evidence to demonstrate that the project’s provisions for dealing with PFAS were inadequate.

Subsequently, a non-profit organization called Citizens for the Preservation of Wainscott, Inc. (“CPW”) appealed NYPSC’s decision to New York state court, asking the court to enjoin SFW from onshore trenching. The state court denied the appeal on January 26, 2022. Separately, CPW and the Plaintiffs in this action filed a

petition in New York state court challenging the easement that the town of East Hampton had granted to SFW for the trenching in question. The state court denied that petition on February 17, 2022. It held that any potential migration of PFAS as a

result of the project could not stem from the grant of the easement, but from the manner in which the trenching is conducted. The court also found that challenges to the manner of construction were properly considered by the NYPSC, and that any further challenges to this should have been brought in the NYPSC’s proceedings,

not before the state court. On March 9, 2022, Plaintiffs brought the current action. They argue that Defendants did not conduct an adequate review of the project’s effect on PFAS

contamination in the FEIS, and therefore violated the National Environmental Policy Act (“NEPA”), the Clean Water Act (“CWA”), Outer Continental Shelf Lands Act (“OCSLA”), and Administrative Procedure Act (“APA”). Plaintiffs seek

preliminary injunctive relief to halt construction of the onshore export cable. II. PRELIMINARY INJUNCTION “A plaintiff seeking a preliminary injunction must establish that he is likely to

succeed on the merits, that he is likely to suffer irreparable harm in the absence of preliminary relief, that the balance of equities tips in his favor, and that an injunction is in the public interest.” Winter v. Natural Resources Defense Council, Inc., 555 U.S. 7, 20 (2008). If an injunction “disrupt[s] the status quo, a party seeking one

must meet a heightened legal standard by showing ‘a clear or substantial likelihood of success on the merits.’” N. Am. Soccer League, LLC v. U.S. Soccer Fed’n, Inc., 883 F.3d 32, 37 (2d Cir. 2018) (quoting N.Y. Civil Liberties Union v. N.Y.C. Transit

Auth., 684 F.3d 286, 294 (2nd Cir. 2012)). “Perhaps the single most important prerequisite for the issuance of a preliminary injunction is a demonstration that if it is not granted the applicant is likely to suffer irreparable harm before a decision on the merits can be rendered.”

Bell & Howell: Mamiya Co. v. Masel Supply Co. Corp., 719 F.2d 42, 45 (2d Cir. 1983). To establish irreparable harm, a movant “must demonstrate an injury that is neither remote nor speculative, but actual and imminent and that cannot be remedied by an award of monetary damages.” Shapiro v. Cadman Towers, Inc., 51 F.3d 328, 332 (2d Cir. 1995) (internal quotation omitted).

III. ANALYSIS Plaintiffs argue that without a preliminary injunction they will be irreparably

harmed by the likely exacerbation of preexisting PFAs contamination of the groundwater on their properties. To succeed on this prong, Plaintiffs must demonstrate that irreparable harm is not just possible, but likely.

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