Pennsylvania Coal Co. v. Township of Conemaugh

612 A.2d 1090, 149 Pa. Commw. 22
CourtCommonwealth Court of Pennsylvania
DecidedJuly 6, 1992
Docket1576 C.D. 1991
StatusPublished
Cited by13 cases

This text of 612 A.2d 1090 (Pennsylvania Coal Co. v. Township of Conemaugh) is published on Counsel Stack Legal Research, covering Commonwealth Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Pennsylvania Coal Co. v. Township of Conemaugh, 612 A.2d 1090, 149 Pa. Commw. 22 (Pa. Ct. App. 1992).

Opinion

McGINLEY, Judge.

The Pennsylvania Coal Company, Cooney Bros. Coal Co., J.C. Stineman and Associates and Elizabeth A. Roudabush (collectively, Owners), and the Pennsylvania Coal Association (Association) appeal from an order of the Court of Common Pleas of Cambria County (common pleas court) that granted the preliminary objections of Conemaugh Township (Township) and dismissed Owners’ complaint seeking declaratory judgment on the validity of the Township’s Zoning Ordinance (Ordinance) regulating surface mining operations. We reverse and remand.

Owners are property owners or lessees of land on which surface coal mining operations, permitted by the Department *24 of Environmental Resources (DER), are conducted. Owners also own or lease other properties in the Township with surface mineable coal and other reserves. The Association is a non-profit association of surface and underground bituminous coal mine operators. Several of the Association’s members own or lease coal reserves in the Township.

On January 2, 1991, the Township approved a comprehensive amendment to the Ordinance. The new provisions of the Ordinance extensively regulate the operation of surface coal and noncoal mining activities. On January 30, 1991, Owners filed a complaint in the common pleas court seeking a declaratory judgment invalidating these provisions. 1 In Count I of their complaint, Owners contend that the Ordinance provisions regulating surface mining are invalid on the grounds that they are preempted by state statutes regulating surface mining and reclamation operations. In Count II, Owners contend that the Ordinance prohibits surface mining in all but one district and thus deprives Owners of their property without just compensation and violates their rights to due process and equal protection under the state and federal constitutions. In Count III, Owners contend that the Ordinance provisions regulating surface mining bear no rational relation to the protection of the public health, safety or welfare of the Township and amounts to an impermissible de facto exclusion of surface mining operations in the Township. In Count V, Owners seek an injunction preventing the Township from enforcing the challenged provisions of the Ordinance or otherwise interfering with Owners’ coal mining operations.

On February 8, 1991, the Township filed preliminary objections to the complaint, asserting that the ZHB has exclusive jurisdiction over the Owners’ challenge to the Ordinance and that these same issues have been raised in Owners’ appeal pending before the ZHB. The Township also demurred on the ground that Owners have failed to state a cause of action in preemption. On June 25, 1991, the common pleas court sustained the Township’s preliminary objections and dismissed *25 Owners’ complaint, noting that Owners’ substantive appeal before the ZHB raises the same issues. In an opinion in support of its order the common pleas court noted that pursuant to Section 909.1(a) of the Pennsylvainia Municipalities Planning Code (MPC), 2 the ZHB has exclusive jurisdiction to hear all issues raised by Owners and that the MPC provides a full and adequate statutory remedy. The common pleas court also rejected Owners’ contention that the Ordinance provisions regulating surface mining operations were preempted by state and federal law. Owners timely appealed.

Owners contend the common pleas court erred in holding that they have an adequate statutory remedy, which they are pursuing via a substantive challenge to the Ordinance before the ZHB, because the challenged provisions regulate the operation of surface mining and reclamation operations; that the common pleas court erred in remanding Owners’ complaint to the ZHB because the ZHB has no power to adjudicate complaints for equitable or declaratory relief; and that the common pleas court erred in holding that the Ordinance provisions regulating surface mining were not preempted by the Surface Mining Conservation and Reclamation Act (SMCRA), 3 and Noncoal Surface Mining Conservation and Reclamation Act (N-SMCRA). 4 Our review of a common pleas court’s order sustaining preliminary objections is limited to a determination of whether the objections were properly sustained, resolving any doubt by overruling the objections. Appeal of Hempfield Township, 102 Pa.Commonwealth Ct. 514, 518 A.2d 1314 (1986).

Owners’ first contention is that the common pleas court erred in holding that Owners have an adequate statutory remedy at law on the ground that Owners’ substantive challenge to the Ordinance before the ZHB provides an adequate *26 remedy thereby divesting the common pleas court of jurisdiction. Owners contend that the Township is not really regulating zoning but regulating an area which the state has preempted. In Plymouth Township v. Montgomery County, 109 Pa.Commonwealth Ct. 200, 531 A.2d 49 (1987), this Court noted that courts have jurisdiction to review and negate local ordinances regulating the operation of waste disposal facilities which are qualitatively different from traditional zoning ordinances regulating the location of these facilities. Id. at 208, 531 A.2d at 53. In Plymouth Township we concluded that where a township inextricably connects zoning provisions with operation regulations, the administrative process is not adequate, and equity jurisdiction is appropriate in the common pleas court to achieve a prompt and unified resolution. Id. at 209, 531 A.2d at 53.

In the present case the challenged provisions of the Ordinance clearly regulate the operation of surface coal mining in the Township in addition to location and physical configuration. For example, Section 902 requires surface mining applicants to submit to the Township information already required to be submitted to DER to obtain a permit under its regulations. See Reproduced Record (R.R.) at 84a-88a. Also, the Ordinance regulates the operation of other activities which are appropriate aspects of surface mining, specifically: Sections 409 and 410 (construction of structures within specified distances of streams or wetlands); Section 1412 (timber harvesting); Section 1414 (extraction of coal); Section 1418 (excavations and fills); Section 1419 (storm water management); and Section 1420 (blasting).

A review of these provisions of the Ordinance indicates that the Township seeks to regulate the operation of surface mining activities within its borders. These provisions are more extensive than the traditional land use controls accomplished by zoning. In accord with Plymouth Township, we must conclude that the common pleas court erred in holding that the ZHB has exclusive jurisdiction of all challenges to the *27 Ordinance, and accordingly we conclude that the common pleas court erred in dismissing Owners’ equity complaint.

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Bluebook (online)
612 A.2d 1090, 149 Pa. Commw. 22, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pennsylvania-coal-co-v-township-of-conemaugh-pacommwct-1992.