Texas Commission on Environmental Quality and Republic Waste Services of Texas, Ltd. v. the City of Aledo and the City of Willow Park

CourtCourt of Appeals of Texas
DecidedJuly 8, 2015
Docket03-13-00113-CV
StatusPublished

This text of Texas Commission on Environmental Quality and Republic Waste Services of Texas, Ltd. v. the City of Aledo and the City of Willow Park (Texas Commission on Environmental Quality and Republic Waste Services of Texas, Ltd. v. the City of Aledo and the City of Willow Park) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Texas Commission on Environmental Quality and Republic Waste Services of Texas, Ltd. v. the City of Aledo and the City of Willow Park, (Tex. Ct. App. 2015).

Opinion

TEXAS COURT OF APPEALS, THIRD DISTRICT, AT AUSTIN

NO. 03-13-00113-CV

Texas Commission on Environmental Quality and Republic Waste Services of Texas, Ltd., Appellants

v.

The City of Aledo and The City of Willow Park, Appellees

FROM THE DISTRICT COURT OF TRAVIS COUNTY, 261ST JUDICIAL DISTRICT NO. D-1-GV-12-000220, HONORABLE STEPHEN YELENOSKY, JUDGE PRESIDING

MEMORANDUM OPINION

The Texas Commission on Environmental Quality and Republic Waste Services of

Texas, Ltd. appeal the trial court’s judgment in a suit filed by the City of Aledo and the City of

Willow Park (the Cities) seeking judicial review of the Commission’s final order issuing to Republic

a permit to construct and operate a new municipal solid waste transfer station in eastern Parker

County. At a preliminary hearing conducted by the State Office of Administrative Hearings (SOAH),

the Cities were denied party status in the contested case to consider issuance of the permit. In their

petition to the district court, the Cities contended that they were improperly denied party status and

that, accordingly, the Commission’s issuance of the permit was reversible error. The trial court

agreed and reversed the Commission’s final order, vacated Republic’s permit, and remanded the

matter to the Commission. For the following reasons, we reverse the district court’s judgment and

render judgment affirming the Commission’s final order issuing the permit. BACKGROUND

Republic applied for a permit from the Commission to construct and operate a

municipal solid-waste transfer station,1 the Brazos Transfer Station. Republic planned to construct

the transfer station in an industrial subdivision in Parker County, outside the city limits of any

city but within Willow Park’s extraterritorial jurisdiction (ETJ), and planned to have buffer

zones—areas free from processing activities—around the facility between 95 and 400 feet wide.

After determining Republic’s permit application to be administratively complete,

the Commission referred the application to SOAH for a contested case. As required by law and

Commission rules, Republic published notice in local newspapers and to interested persons,

including the Cities, that SOAH would conduct a “contested case hearing . . . similar to a civil trial

in state district court” and provided that “[t]o request to be a party, you must attend the hearing

and show you would be adversely affected by the application in a way not common to members

of the general public.” On the date specified in the notice, SOAH held a preliminary hearing in

Parker County to hear requests of people seeking to be admitted as parties to the contested-case

proceeding and to establish a procedural schedule.

As representatives and on behalf of their respective cities, the mayors of Aledo and

Willow Park, along with other persons and entities who opposed the transfer station, appeared at the

hearing and requested party status. After listening to each requestor’s testimony, the administrative

law judge (ALJ) granted party status to twelve requestors, but denied the requests by the mayors of

1 A transfer station is a facility where waste is unloaded from collection vehicles and briefly held until it is reloaded onto larger long-distance transport vehicles for shipment to landfills or other treatment or disposal facilities.

2 Aledo and Willow Park. The ALJ denied the Cities party status on two grounds: (1) neither had

demonstrated a justiciable interest in the permit application and (2) neither had demonstrated its

mayor’s requisite authority to represent it in the proceedings.

The ALJ conducted a full evidentiary hearing several months later, after which he

recommended that the Commission grant the Brazos Transfer Station permit. The Cities filed

exceptions to the ALJ’s recommendation, arguing that he had improperly denied them party status.

The Commission followed the ALJ’s recommendation with some modifications and issued its

final order and permit. The Cities filed motions for rehearing with the Commission, again alleging

error in the denial of party status. The motions were overruled by operation of law.

The Cities filed suit in Travis County District Court challenging the Commission’s

order based on their exclusion from party status. The trial court issued a judgment reversing the

order, vacating Republic’s permit, and remanding the matter to the Commission with instructions

for a new preliminary hearing. In its judgment, the trial court identified no specific reasons for its

reversal of the Commission’s final order. However, in a letter ruling to the parties, the trial court

indicated that it was relying, in part, on its sua sponte determination that the ALJ had violated the

Cities’ due-process rights by, among other errors, not permitting the admission of documentary

evidence at the preliminary hearing. In its final order vacating the Commission’s permit, the trial

court further ordered that should Republic wish to continue to pursue its permit application, “an

evidentiary hearing must be held before [SOAH] at which [the Cities] will be entitled to present

evidence relevant to determination of their status as affected persons entitled to participate as parties

in any contested case hearing on the [permit] application.” Both the Commission and Republic

appealed the judgment.

3 DISCUSSION

Jurisdiction

In its first issue, Republic challenges the subject-matter jurisdiction of the district

court to consider the Cities’ petitions, arguing that because the Cities were not admitted as parties

to the contested-case proceeding from which they sought to appeal, they had not met (and could not

have met) the statutory prerequisites to filing an appeal under the Administrative Procedure Act

(APA). See Tex. Gov’t Code §§ 2001.003 (defining “party” as “person or state agency named or

admitted as a party” in contested case), .145(a) (motion for rehearing is prerequisite to administrative

appeal), .146(a) (motion for rehearing must be filed by “party”). Republic argues that because only

“parties” may file motions for rehearing and the Cities, by definition, were not “parties” under the

APA, their purported motions were nullities and did not fulfill the mandatory statutory prerequisite

to appeal. Having thus failed to exhaust their administrative remedies, Republic continues, the Cities

are not entitled to judicial review of the Commission’s order. See Temple Indep. Sch. Dist. v. English,

896 S.W.2d 167, 169 (Tex. 1995) (failure to timely file motion for rehearing deprives district court

of jurisdiction to review agency’s decision on appeal).

The Cities respond that section 5.351 of the Water Code governs jurisdiction over

their administrative appeal and that we must look to that statute for the parameters of entitlement to

judicial review. See Hooks v. Texas Dep’t of Water Res., 611 S.W.2d 417, 419 (Tex. 1981) (judicial-

review provisions of APA and Water Code should be read in conjunction and in harmony with each

other, and section 5.351 entitles person “affected” by agency action to judicial review); see also

Tex. Water Code § 5.351

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Texas Commission on Environmental Quality and Republic Waste Services of Texas, Ltd. v. the City of Aledo and the City of Willow Park, Counsel Stack Legal Research, https://law.counselstack.com/opinion/texas-commission-on-environmental-quality-and-repu-texapp-2015.