Sawyer Envtl. Facilities, Inc. Sawyer Envtl. Facilities, Inc. v. Inhabs. of the Town of Hampden, Maine

CourtSuperior Court of Maine
DecidedJanuary 14, 2000
DocketPENap-99-26andcv-99-57
StatusUnpublished

This text of Sawyer Envtl. Facilities, Inc. Sawyer Envtl. Facilities, Inc. v. Inhabs. of the Town of Hampden, Maine (Sawyer Envtl. Facilities, Inc. Sawyer Envtl. Facilities, Inc. v. Inhabs. of the Town of Hampden, Maine) 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
Sawyer Envtl. Facilities, Inc. Sawyer Envtl. Facilities, Inc. v. Inhabs. of the Town of Hampden, Maine, (Me. Super. Ct. 2000).

Opinion

STATE OF MAINE SUPERIOR COURT PENOBSCOT, SS. oe Docket No. ee] an CV-99- 57

. MYK -PEA- pa ere SAWYER ENVIRONMENTAL FACILITIES, INC., Plaintiff, ov. ORDER ON 80B APPEAL AND MOTION FOR THE INHABITANTS OF THE _-JMMARY JUDGMENT

TOWN OF HAMPDEN, MAINE, and RAY PIPES, in his capacity as Code Enforcement Officer of said Town,

Defendant.

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. PENOBSCOT COUNTY - This matter is before the Court on Plaintiff’s two 80B Appeals of separate

decisions of the Hampden Zoning Board of Appeals. Also before the Court are opposing Motions for Summary Judgment and Judgment on the Pleadings on several related civil claims.

FACTS

This case arises out of a controversial proposal for an expansion of a landfill located in the Town of Hampden. The factual history spans a twenty-five year period concerning numerous developments of the landfill. In 1974, the predecessor of Plaintiff Sawyer Environmental Recovery Facilities (“SERF”) received a permit from the Town of Hampden to operate a landfill. Although the Hampden Zoning Ordinance did not specify landfills as a permissible use anywhere in the Town, the

Zoning Board of Appeals (“Zoning Board”) granted a permit for a landfill on Lots 44, 45, and 46.1 On March 12, 1975, the Maine Department of Environmental Protection (“DEP”) approved the Hampden landfill, pursuant to 38 M.R.S.A. §§ 1301, et seq. After receiving approval from the Hampden Planning Board on April 16, 1975, SERF’s predecessor opened the landfill.

In 1979, Hampden enacted a new Zoning Ordinance, which again did not allow landfills in any section of the Town. In 1985, the Hampden Planning Board granted site plan approval for another portion of SERF’s landfill. That site opened thereafter and closed in 1994,

On October, 20, 1998, the DEP issued a permit for construction and operation of another portion of the Hampden landfill. On January 28, 1999, Ray Pipes, the Hampden Code Enforcement Officer (“CEO”), issued a decision that allowed SERF’s vertical expansion but denied lateral expansion of the landfill.2_ Mr. Pipes determined that because landfills are not allowed anywhere in Hampden, SERF’s proposed expansion constituted a nonconforming use under the Hampden Zoning Ordinance, which prohibited expansion of nonconforming uses. As such, Pipes determined that SERF could not expand the landfill beyond the original footprint

approved by the DEP in 1975. SERF appealed the CEO’s decision to the Zoning

1. Since 1974, Hampden has reconfigured and renumbered the land area at issue here. The parties do not dispute that the land at issue here is within the boundaries of lots 44, 45, and 46, as they existed in 1974 when the Hampden Zoning Board of Appeals approved SERF’s landfill. See Defendant’s Memorandum, p. 4, filed August 20, 1999. To avoid confusion over lot numbers, throughout this opinion the Court refers to these three lots only by the numbers allocated in 1974.

2. The DEP approved SERF’s landfill expansion plan for an area that included land outside the boundaries of lots 44, 45, and 46. SERF’s application to the Town, which is at the center of this dispute, included only Lots 44, 45, and 46. As such, this order addresses SERF’s proposed expansion only for the land covered by the application to the Town, Lots 44, 45, and 46. Any proposal for expansion of land outside of Lots 44, 45, and 46 is not before the Court.

2 Board, which denied the appeal. SERF filed CV-99-57, which consists of an appeal of the Zoning Board’s decision, pursuant to Rule 80B of the Maine Rules of Civil Procedure, and three related civi] claims.

Subsequently, the Hampden Planning Board determined, based on the Zoning Board’s decision, that it lacked jurisdiction to review SERF’s site plan application. SERF appealed that decision to the Zoning Board, which denied the appeal. SERF then filed AP-99-26, appealing the Zoning Board’s decision that affirmed the Planning Board’s lack of jurisdiction, pursuant to Rule 80B. By order dated June 14, 1999, cases CV-99-57 and AP-99-26 were consolidated. On July 21; 1999, the parties submitted a stipulated record for Count I of CV-99-57.

1, CV-99-57 Count I Preemption

The parties have filed opposing motions for judgment on the stipulated record for Count I. “[T]o stipulate a record for judgment allows the judge to decide any significant issues of material fact that he discovers,” and to enter judgment

according to those findings. Boston Five Cents Savings Bank v. Secretary of H.U.D.D., 768 F.2d 5, 11-12 (1st. Cir. 1985).

Plaintiff argues that the Hampden Zoning Ordinance, which, according to the Town, prohibits expansion of the landfill, is preempted by the Solid Waste Management Act, 38 M.R.S.A. §§ 1301, et seq. Maine’s home rule statute confers - upon municipalities the authority to enact ordinances or bylaws as allowed by the Maine Constitution or general law, except those expressly or impliedly preempted by

statute. See 30-A M.RS.A. § 3001. The statute also provides a rebuttable

“ presumption that municipal ordinances are valid and will not be held preempted

unless the ordinance would frustrate the purpose of any state law. See id. The Law

Court has explained further that “[m]unicipal legislation will be invalidated, therefore, only when the Legislature has expressly prohibited local regulation, or when the Legislature has intended to occupy the field and the municipal legislation would frustrate the purpose of a state law.” International Paper Co. v. Town of Jay, 665 A.2d 998, 1002 (Me. 1995).

Plaintiff argues that Hampden’s Zoning Ordinance, as interpreted by the Town, frustrates the purpose of sections 1310-U and 1310-X and are, therefore, : preempted. Section 1310-U prohibits municipalities “from enacting stricter standards than those contained in this chapter” but allows them to enact reasonable provisions for numerous purposes, including “compatibility of the solid waste facility with local zoning and land use controls.” Section 1310-X authorizes the DEP to license existing disposal facilities for expansion, provided that the applicant meets specific criteria set forth therein. Defendants do not dispute the DEP’s determination that SERF’s proposed expansion fulfills these criteria. Rather, Defendants contend that the exclusion of landfills under the Zoning Ordinance falls within the scope of the Town’s authority granted in section 1310-U. The Court need not reach this issue because, as discussed below, Hampden’s Zoning Ordinance as applied to the facts of this case does not prohibit SERF’s proposed expansion.

2. CV-99-57 Count II Rule 80B Appeal

Plaintiff argues that the Zoning Board’s 1974 decision to allow SERE to construct a landfill in Hampden constituted a variance for lots 44, 45, and 46. SERF contends that the variance allows SERF to expand the landfill on these three lots and that the current Zoning Ordinance does not prohibit such an expansion. Defendants respond that the approval granted by the Zoning Board in 1974 applied only to the footprint of the original landfill as approved by the DEP in 1975. As such, Defendant asserts that the expansion is a nonconforming use, which is prohibited by the Zoning Ordinance.

A plaintiff seeking a Rule 80B appeal carries the burden of proof. See Tompkins v. City of Presque Isle, 571 A.2d 235, 236 (Me. 1990).

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Bluebook (online)
Sawyer Envtl. Facilities, Inc. Sawyer Envtl. Facilities, Inc. v. Inhabs. of the Town of Hampden, Maine, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sawyer-envtl-facilities-inc-sawyer-envtl-facilities-inc-v-inhabs-of-mesuperct-2000.