PSEG Renewable Transmission LLC v. The Richard Smith Snader Testamentary Trust, et al.

District Court, D. Maryland·Decided August 20, 2026·No. 1:26-cv-00793·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND

PSEG RENEWABLE TRANSMISSION LLC,

Petitioner,

v.

Case No. 26-cv-793-ABA THE RICHARD SMITH SNADER TESTAMENTARY TRUST, et al., Respondents.

MEMORANDUM OPINION On February 25, 2026, Petitioner PSEG Renewable Transmission LLC (“PSEG”) filed the petition in this case (“PSEG 7”), and an accompanying motion for a preliminary injunction (the “PI Motion”), to permit it to obtain temporary access to the properties of Respondents to perform non-invasive field surveys pursuant to Md. Code Ann., Real Property § 12-111. ECF Nos. 1 & 3. Respondents include several individuals as well as a trust that own or reside at properties that PSEG wishes to survey (the “Non-Government Respondents”) as well as The Board of County Commissioners for Carroll County, Maryland (“Carroll County” or “the County”), which holds conservation easements over properties where PSEG needs to complete surveys. ECF No. 1. The Court has previously issued preliminary injunctions in other nearly identical cases, including three that pertain to properties that are subject to the easements addressed herein. See PSEG Renewable Transmission LLC v. Arentz Family, LP, 788 F. Supp. 3d 705, 711–724 (D. Md. 2025) (hereinafter, “PSEG I”), aff’d -- F.4th --, 2026 WL 2263342 (4th Cir. Aug. 6, 2026); PSEG Renewable Transmission LLC v. Alvi Properties, LLC, et al., Case No. 1:25-cv-02296-ABA (“PSEG 2”); PSEG Renewable Transmission LLC v. Belfast Farms, LLC, et al., Case No. 1:25-cv-03352-ABA (“PSEG 3”). Carroll County filed a motion to dismiss for lack of subject matter jurisdiction and failure to state a claim. ECF No. 38. This Court granted a preliminary injunction as to the Non-Government Respondents only and reserved decision on Carroll County’s motion. ECF Nos. 45 & 46. With respect to the claims against the County, the Court held a hearing on May 12,

2026. ECF No. 58. For the reasons that follow, the motion for preliminary injunction (ECF No. 45) will be granted and the motion to dismiss (ECF No. 38) will be denied. I. BACKGROUND1 Thirty-three tracts of land that are subject to preliminary injunctions (“PIs”) under PSEG Renewable Transmission LLC v. Arentz Family, LP, et al., Case No. 1:25- cv-01235-ABA (“PSEG 1”), PSEG 2, or PSEG 3 or for which the owner has consented to PSEG’s surveys are covered by forty-five conservation easements held by Carroll County (some tracts of land are subject to more than one easement). ECF No. 1-8, Declaration of Dawn Shilkoski (“Shilkoski Decl.”), ¶ 7 (citing ECF No. 1-9 at 2–4); ECF No. 38-8 at 5. This includes thirty-seven forest conservation easements, three non-forested water resource protection easements, two floodplain management easements, one stormwater management easement, one stream-restoration easement, and one agricultural land

preservation easement. ECF No. 1-9 at 2–4; ECF No. 38-8 at 5; ECF Nos. 38-1, 38-2, 38- 3, 38-6, & 38-7 (the easement agreements). The County, relying on its conservation easements, has objected to PSEG performing cultural resource surveys on those properties. ECF No. 1 ¶ 76 (citing ECF No. 1-9, Shilkoski Decl. ¶ 7). The cultural resource

1 As much of the background of this case replicates PSEG I, the Court adopts its and the Fourth Circuit’s prior explanation of the background. 788 F. Supp. 3d at 711–715; -- F.4th --, 2026 WL 2263342 at *1–3. Therefore, this section will only include any background information that pertains specifically to this case, PSEG 7. surveys that PSEG is required to complete include shovel tests done by a hand shovel to create a hole that is approximately 1.5 feet in diameter and on average about 18 inches deep that would then be backfilled, a methodology approved by the Maryland Historical Trust. ECF No. 1-23 at 3. Many of the conservation easements, however, disallow any form of digging or removal of dirt or plant material. See ECF No. 38-1 ¶¶ 2–6; ECF No.

38-2 ¶ 2; ECF No. 38-3 ¶¶ 1–2; ECF No. 38-6 ¶ 2; ECF No. 38-7 at 2. Counties in Maryland are granted authority to enter into agreements with property owners for conservation easements that can serve different purposes such as restrictions on what can be built on or removed from a property. Md. Code Ann., Real Prop., § 2-118. Conservation easements are enforceable in the same manner as other easements or servitudes with respect to the property. Id. § 2-118(a). On April 11, 2025, during the Maryland Public Service Commission’s (“PSC’s”) early review of PSEG’s certificate of public convenience and necessity (“CPCN”) application, Christopher Heyn, the Director of Planning & Land Management for Carroll County, wrote a letter that he was “in full agreement” with the Power Plant Research Program (“PPRP”) that “the lack of critical field studies to evaluate alternatives and

minimize impacts is a concerning omission from the application,” and specifically noted a concern with the lack of survey studies done along the proposed route. ECF No. 1-23 at 12, 14. He then noted that approximately 128 acres of land along the route are in Carroll County and requested that the PSC require specific mitigation of impacts of the surveys based on the State and County Forest Conservation Codes. Id. at 13–14. On September 11, 2025, PSEG emailed a representative from the Carroll County Resource Management Division, Jonathan Bowman, indicating that it would need to conduct surveys on land subject to the County’s easements. ECF No. 1-23 at 9–11. Mr. Bowman responded to the email on October 14, 2025, confirming that he had received PSEG’s notification and requested a list of the properties at issue. Id. at 9. PSEG provided the list of properties on November 4, 2025, and Mr. Bowman confirmed receipt on November 7, 2025. Id. at 7–8. On February 17, 2026, PSEG’s counsel sent the County Attorney for Carroll

County, Timothy C. Burke, Esq., a formal “Notice of Intent to Conduct Cultural Resource Surveys on Certain Properties Located in Carroll County.” Id. at 2–6. The notice included a copy of the emails with Mr. Bowman and the list of properties. Id. PSEG requested that the County respond within seven days of the letter and stated that it would consider a lack of response as “an acknowledgement that PSEG has provided notice of its intent to take cultural resource surveys on the subject properties and will proceed with the cultural resource surveys accordingly in compliance with the specific notice requirements and terms of the Federal District Court’s preliminary injunctions.” Id. at 6. PSEG alleges that, as of February 24, 2026, no response had been received from the County. ECF No. 1-8, Shilkoski Decl., ¶ 40. PSEG filed a Petition in this Court on February 25, 2026. ECF No. 1.

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PSEG Renewable Transmission LLC v. The Richard Smith Snader Testamentary Trust, et al., (D. Md. 2026).

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