Uliano v. Maine Bd. of Envtl. Prot.

CourtSuperior Court of Maine
DecidedFebruary 18, 2003
DocketHANap-02-7
StatusUnpublished

This text of Uliano v. Maine Bd. of Envtl. Prot. (Uliano v. Maine Bd. of Envtl. Prot.) 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
Uliano v. Maine Bd. of Envtl. Prot., (Me. Super. Ct. 2003).

Opinion

STATE OF MAINE SUPERIOR COURT

HANCOCK, ss CIVIL ACTION DOCKET NO. AP-02-7 AM AA ome {4 i fh 7d h “ A fee : : ANTHONY and ERIN ULIANO, ) ) Petitioners ) ) v. ) ) MAINE BOARD OF ENVIRONMENTAL ) DECISION AND ORDER PROTECTION ) ) Respondent ) ) and ) ) PHOEBE B. BOYER, et al., ) ) Intervenors )

Pending before the Court is Anthony and Erin Uliano’s (the “Petitioners”’) appeal from the Maine Board of Environmental Protection’s (the “Board”) decision denying their application for a permit pursuant to the National Resource Protection Act (the “NRPA”). For the following reasons the Court affirms the Board’s decision.

Background

The Petitioners own waterfront property in Salsbury Cove on Eastern Bay in Bar Harbor, Hancock County, Maine. The property has approximately 300 feet of frontage on Eastern Bay. On February 12, 2001, the Petitioners filed a NRPA permit application with the Department of Environmental Protection (the “Department”) seeking a permit to build a 95-foot long by 6-foot wide private recreational dock with a 50-foot long aluminum ramp and a 16-foot by 20-foot wooden float secured by two granite-mooring

blocks. The Department held a public informational meeting to receive comment on the application. The Department examined the application, public comment, conducted site visits and viewed the property from across Eastern Bay in Lamoine. On August 6, 2001, the Department approved the application and found that the dock would not: (1) unreasonably interfere with existing scenic and aesthetic uses, or with existing recreational or navigational uses; (2) cause unreasonable erosion of soil sediment; (3) unreasonably inhibit the natural transfer of soil from the terrestrial to the marine or freshwater environment; (4) unreasonably harm significant wildlife habitat, aquatic habitat, or other aquatic life, or unreasonably harm freshwater wetland plant habitat, or threaten to endanger plant habitat, travel corridors, or freshwater, estuarine, or marine fisheries; (5) unreasonably interfere with the natural flow of any surface or subsurface waters; (6) violate any state water quality law including those governing the classifications of the State’s waters; (7) unreasonably cause or increase the flooding of the alteration area or adjacent properties; (8) be on or adjacent to a sand dune; and (9) be on an outstanding river segment as noted in 38 M.R.S.A. §480-P. Opponents of the application appealed the Department’s approval to the Board.

On January 3, 2002, the Board heard the appeal at which the opponents, the Petitioners, and the Department argued the merits of the case. The Board voted to conduct a site visit to assess whether the proposed project violated the NRPA’s “existing scenic and aesthetic uses” standard. On January 21, 2002, four of the ten Board members visited the site with the Board’s executive analyst and Department staff. They reconvened on February 21, 2002, to the conduct final deliberations. The four members

who conducted the site visit provided factual testimony describing their observations and discussed the scenic and aesthetic impacts of the project. The Board, pursuant to the NRPA and the Wetlands Protection Rules (the “Rules”) found that the Petitioners failed to demonstrate that there was no practicable alternative to the proposed project and that

the project would unreasonably interfere with scenic and aesthetic uses and voted six to

two grant the opponent’s appeal.

Arguments

The Petitioners allege that the NRPA’s “scenic and aesthetic use” standard is unconstitutionally vague. The Petitioners further argue that the Board’s use of the Rule’s “cumulative impact” and “practicable alternative” standards exceeds the Board’s rule- making authority, that they applied the standards in an arbitrary manner and finally that the standards themselves are unconstitutionally vague.

The Board contends the NRPA contains sufficient standards to guide their decision-making and that reasonable people need not guess at the meaning of the “unreasonably interfere with existing scenic and aesthetic uses.” Further, the Board

contends that they correctly relied upon the standards contained in the Rules in order to

interpret the NRPA’s statutory requirements.

#

Discussion Statutes

In the “Findings; purpose” section of the NRPA the legislature notes the importance the Maine’s various environmental resources and wetlands and further finds: “that the cumulative effect of frequent minor alterations and occasional major alterations of these resources poses a substantial threat to the environment and economy

of the State and its quality of life.” 38 M.R.S.A. § 480-A. To this end the NRPA requires individuals to apply for permits before they engage in certain activities,

including the construction of piers. 38 MR:S.A. § 480-D states in relevant part:

The Board of Environmental Protection shall grant a permit upon proper application and upon such terms as it deems necessary to fulfill the purposes of this article [the NRPA]. The board shall grant a permit when it finds that the applicant has demonstrated that the proposed activity meets the following

standards.

1.

In creating the

Existing uses. The activity will not unreasonably interfere with existing scenic, aesthetic, recreational or navigational uses.

Department the legislature provided that:

Subject to the Maine Administrative Procedure Act, the [Board] shall adopt, amend or repeal reasonable rules and emergency rules necessary for the interpretation, implementation and enforcement of any provision of law that the department is charged with administering.

To this end the Board enacted the Rules to “ensure that the standards set forth in Section

480-D of the [NRPAJ]... are met by applicants proposing regulated activity in, on, over,

or adjacent to a wetland or water body.” CMR 06-096-310(1). The relevant regulations

are as follows:

No activity shall be permitted if there is a practicable alternative to the project that would be less damaging to the environment. Each applicant must provide an analysis of alternatives (see Section 9(A)) in order to demonstrate that a practicable alternative does not exist. CMR 06-096-

310(5)(A).

Even if a project has no practicable alternative and the applicant has minimized the proposed alteration as much as possible, the application will be denied if the activity will have an unreasonable impact on the wetland. “Unreasonable impact” means that one or more of the standards of the Natural Resource Protection Act, 38 M.R.S.A. §480-D, will not be met. In making this determination, the department considers:

(a) The area of wetland that will be affected by the alteration and the degree to which the wetland is altered, including wetland beyond the physical boundaries of the project;

(b) The functions and values provided by the wetland;

(c) Any proposed compensation and the level of uncertainty regarding it; and (d) Cumulative effects of frequent minor alterations on the wetland.... When considering whether a single activity is reasonable in relation to the direct and cumulative impacts on the resource, the department considers factors such as the degree of harm or benefit to the resource, the frequency of similar impacts; the duration of the activity and the ability of the resource to recover; the proximity of the activity to protected or highly developed areas; traditional uses; the ability of the activity to perform as intended; public health or safety concerns addressed by the activity; and the type and degree of benefit from the activity (public, commercial or personal). CMR 06-096-310(5)(D). The Rules are not additional standards. The Board uses the Rules to interpret the NRPA and ensure applicants meet the NRPA’s standards.

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