Tennessee Riverkeeper, Inc. v. Afrakhteh

CourtDistrict Court, M.D. Tennessee
DecidedJune 11, 2024
Docket3:23-cv-00749
StatusUnknown

This text of Tennessee Riverkeeper, Inc. v. Afrakhteh (Tennessee Riverkeeper, Inc. v. Afrakhteh) is published on Counsel Stack Legal Research, covering District Court, M.D. Tennessee primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Tennessee Riverkeeper, Inc. v. Afrakhteh, (M.D. Tenn. 2024).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF TENNESSEE NASHVILLE DIVISION

TENNESSEE RIVERKEEPER, INC., ) ) Plaintiff, ) Case No. 3:23-cv-00749 ) Judge Aleta A. Trauger v. ) ) ARDAVAN AFRAKHTEH, ) ) Defendant. )

MEMORANDUM

Ardavan Afrakhteh has filed a Motion to Dismiss (Doc. No. 14), to which Tennessee Riverkeeper, Inc. filed a Response (Doc. No. 17), and Afrakhteh filed a Reply (Doc. No. 19). On May 10, 2024, the court entered an Order (Doc. No. 20) converting Afrakhteh’s motion, in part, to a motion for summary judgment and requiring the parties to file additional materials necessary to addressing the relevant issues in connection with Rule 56. Tennessee Riverkeeper filed a subsequent Response (Doc. No. 21), and Afrakhteh filed a Notice of Additional Materials (Doc. No. 22). For the reasons set out herein, the converted motion will be granted. I. BACKGROUND A. The CWA, the NPDES, and Tennessee’s General Permit for Construction The Clean Water Act (“CWA”) imposes “a default regime of strict liability,” whereby the discharge of any covered pollutant into the waters of the United States amounts to a violation of the statute unless subject to a specific exception. Sierra Club v. ICG Hazard, LLC, 781 F.3d 281, 284 (6th Cir. 2015) (quoting Piney Run Preservation Ass’n v. Cty. Comm’rs of Carroll Cty., 268 F.3d 255, 268–69 (4th Cir. 2001)). That zero-tolerance approach, however, is only a baseline, because the CWA also makes individualized exceptions—albeit limited, conditional (“NPDES”) permitting system. An NPDES permit authorizes a covered party to discharge otherwise-barred effluents into waters covered by the CWA, subject to “limits on the type and quantity of pollutants that can be released,” among other requirements. S. Fla. Water Mgmt. Dist. v. Miccosukee Tribe of Indians, 541 U.S. 95, 102 (2004). Discharge of pollutants into the waters

of the United States without an NPDES permit, or in violation of the terms of an NPDES permit, is typically a violation of the CWA, but an authorized discharge made in compliance with a permit is not. 33 U.S.C. §§ 1311(a), 1342(a), 1365(f). As a result, the NPDES system allows regulators to fashion the CWA’s prohibition into a more tailored regime in which some discharges are tolerated, within limits and subject to oversight and conditions. The Tennessee Department of Environment and Conservation (“TDEC”), which administers the NPDES in Tennessee, has elected to regulate runoff-based discharges from construction sites through a statewide General Permit for Discharges of Stormwater Associated with Construction Activities (“General Permit”), which a developer or other party may opt into by filing a sufficient “Notice of Intent,” or “NOI.” (Doc. No. 17-1 at 6–8.) The General Permit

potentially applies to an array of “operators” of a construction site—including developers, builders, and contractors—as long as the relevant party has some sufficient degree of “operational control” over the development. (Id. at 12.) Accordingly, any given project may have multiple recognized operators at a time. By the terms of the General Permit, “[p]ermittees are jointly and severally liable for a violation related to construction activities that affect the same project site, unless a permittee affirmatively demonstrates to the satisfaction of the Department that its own action, or failure to act, was not a cause of the violation.” (Id. at 11.) The General Permit recognizes that sometimes control and/or operation of a construction project may change hands after an NOI was filed but before the underlying project is finished. In such a situation, the General Permit requires the new operator to seek its own approval to continue the project: New operators proposing to conduct construction activities at a site with existing coverage must submit an NOI. The NOI should be submitted prior to the new operator commencing work at the site. The NOI must reference the project name and tracking number assigned to the primary permittee’s NOI. The NOI may not need to be submitted immediately upon assuming operational control if the portion of the site controlled by the new operator is inactive and all the previously disturbed areas are permanently stabilized.

A new operator working as a residential home builder may submit Form CN- 1249, the Stormwater Pollution Prevention Plan (SWPPP) for Single Family Residential Homebuilding Sites.

(Id. at 16.) A party that is late in filing its NOI may still do so, but, “[w]hen a late NOI is submitted,” any resultant “authorization is only for future discharges,” meaning that “[a]ny prior, unpermitted, discharges or permit noncompliances are subject to penalties” under the Tennessee Water Quality Control Act (“TWQCA”), Tenn. Code Ann. § 69-3-115. (Id.) Similarly, a construction site operator who made a CWA-covered discharge before opting into the General Permit or receiving another NPDES permit could be liable under the CWA. See 33 U.S.C. §§ 1311(a), 1342(a). The General Permit also establishes procedures for terminating coverage, providing that “[p]rimary permittees wishing to terminate coverage under this permit must submit a completed Notice of Termination (NOT) form,” which TDEC reserves the right to review and, if necessary, reject. (Id. at 56–58.) The General Permit recognizes three situations in which termination of coverage may be granted: the actual completion of the project; the permittee’s obtainment of coverage under a different permit; or that the “permittee has transferred control of all areas of the site for which he is responsible (including, but not limited to, infrastructure, common areas, stormwater drainage structures, sediment control basin) under this permit to another operator, and that operator has submitted an NOI and obtained coverage under this permit.” (Id. at 56–57.) “An owner’s or developer’s responsibility to comply with requirements of [the General Permit] extends until permit coverage is terminated in accordance with” the General Permit’s procedures. (Id. at 11.) B. The CWA’s Citizen Suit Provision and This Case

The CWA grants the government1 a significant “enforcement arsenal,” including “administrative, civil, and criminal sanctions.” Gwaltney of Smithfield, Ltd. v. Chesapeake Bay Found., Inc., 484 U.S. 49, 53 (1987). Congress, however, chose not to leave enforcement decisions entirely in the hands of regulators. Rather, the CWA includes a “citizen suit” provision that permits a private party with a constitutionally sufficient injury to “commence a civil action on his own behalf . . . against any person . . . who is alleged to be in violation of (A) an effluent standard or limitation under this chapter or (B) an order issued by the Administrator or a State with respect to such a standard or limitation.” 33 U.S.C. § 1365(a). A private party’s authority to enforce the CWA, however, is narrower than a regulatory agency’s. For one thing, a private party cannot file a citizen suit without giving a 60-day notice

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Tennessee Riverkeeper, Inc. v. Afrakhteh, Counsel Stack Legal Research, https://law.counselstack.com/opinion/tennessee-riverkeeper-inc-v-afrakhteh-tnmd-2024.