Wheelabrator Clean Water System, Inc. v. King George County

43 Va. Cir. 370, 1997 Va. Cir. LEXIS 393
CourtKing George County Circuit Court
DecidedSeptember 23, 1997
DocketCase No. CH95-82
StatusPublished
Cited by3 cases

This text of 43 Va. Cir. 370 (Wheelabrator Clean Water System, Inc. v. King George County) is published on Counsel Stack Legal Research, covering King George County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Wheelabrator Clean Water System, Inc. v. King George County, 43 Va. Cir. 370, 1997 Va. Cir. LEXIS 393 (Va. Super. Ct. 1997).

Opinion

By Judge William H. Ledbetter, Jr.

In this zoning case, a landowner seeks a determination that it has die right to transport biosolids from its storage facility for application on other properties.

Facts

All of the pertinent facts are stipulated.

Soaring Vista Properties owns Waterloo Farm, a 180-acre farm in an A-l zoning district in King George County.

Bio Gro is in the business of removing treated and stabilized sewage (“sludge” or “biosolids”) from municipal wastewater treatment plante and applying it to agricultural land. Normally, Bio Gro transports the biosolids by truck from municipal plants directly to farms far immediate application. However, federal and state regulations restrict this activity during inclement weather. Therefore, storage facilities are needed so that when land application is prohibited or curtailed, especially during winter, Bio Gro can haul the material from the municipal treatment plants to the storage facilities where it will be held until it can be applied to die farms. Both the land application of biosolids and the storage of biosolids are regulated by federal and state authorities.

[371]*371Bio Gro owns such a storage facility on Waterloo Farm. The facility has a capacity of approximately 20,000 cubic yards. Bio Gro received permite for die facility from appropriate regulatoiy agencies and began operation in 1988.

Heretofore, Bio Gro has used its facility only for storage of biosolids to be applied to Waterloo Farm. Because of changes in the zoning ordinance and tira manner in which the County recently resolved a dispute with the operator of a similar facility, Bio Gro now contends that it has die right to use its storage facility for off-site application.

In order to understand the controversy, a chronology of events is necessary.

The County adopted its zoning ordinance in 1982 and readopted it with revisions in 1983. That original ordinance allowed the application of biosolids on agricultural land with a conditional use permit. Nothing was said about storage.

in 1984, the County amended its ordinance to permit the application of biosolids on fiaras in A-l zoning districts as a matter of right. Again, no mention was made of storage.

On September 3, 1987, the County amended its zoning ordinance to address biosolids storage facilities for the first tinte. The new provision, § 4.6.2.3, allowed such a storage facility, but only for use on die farm upon which it was located. Transporting the material to any other site was expressly prohibited.

The County issued a building permit to Bio Gro for its Waterloo Farm storage facility cm June 10, 1988. Hie permit bore the notation that biosolids stored in tite facility could not he transferred off the property.

As noted above, Bio Gro began operation in 1988.

The County amended § 4.6.2.3 in 1989. hi essence, the amendment abolished biosolids storage facilities as a by-right use in A-l zoning districts and instead required a special use permit The restriction on the use of such facilities to on-site application of the biosolids remained intact

On September 23,1993, the County repealed §4.6.2.3 in its entirety.

At the same time, an operator of another biosolids storage facility, C & R Contractors, asked the County for permission to transport biosolids from its facility mi Bogue Farm for tod application on other farms. The request was denied. C & R Contractors Sled suit On December 19,1994, a consent decree was entered in that case by which C & R Contractors was allowed to transport biosolids from its Bogue Farm storage facility to other farms within a 60-mile radius.

[372]*372 Effect ofRepeal of § 4.6.2J

When the County repealed §4.6.2.3 in 1993, it removed all reference to biosolid storage facilities in its zoning ordinance.

According to the zoning ordinance, uses not specifically listed are prohibited.

Unlike early zoning ordinances that generally permitted any use not expressly excluded from a particular zoning district, most modem ordinances permit only frióse uses specifically named and prohibit all others. These modem ordinances are sometimes referred to as "inclusive” zoning ordinances. See Wiley v. Hanover County, 209 Va. 153 (1968). The County’s ordinance is of that type. Thus, any use not specifically permitted in A-l zoning districts is prohibited. If biosolid storage facilities are not specifically allowed in A-l zoning districts, they are prohibited.

It follows that the effect of the 1993 repeal of §4.6.2.3 is to prohibit biosolids storage facilities, thereby returning the County’s zoning law to its pre-1987 status.

Non-Conforming Use

Bio Gro contends that it may continue to operate its facility as a nonconforming use.

A nonconforming use is a use which lawfully existed prior to the enactment of a zoning ordinance or an amendment and is allowed to continue despite the fact that it does not comply with the newly-enacted ordinance or amendment. Such a pre-existing use is a vested right that zoning laws generally cannot annul See 83 Am. Jur. 2d, Zoning and Planning, § 624.

Virginia’s enabling legislation protects pre-existing uses as "vested rights” but authorizes localities to restrict nonconforming uses in various ways. See Virginia Code § 15.1-492. The County ordinance adopts the nonconforming use provisions permitted by state statute.

To qualify as a protected use, the nonconforming use must have existed, in lawful form, prior to the date of adoption of tire ordinance or amendment. Here, there is no doubt that Bio Gro operated its biosolids storage facility on Waterloo Farm for several years prior to the 1993 repeal of § 4.6.2.S which had the effect of banning such facilities. However, there is also no doubt that Bio Gro did not operate its facility for storage of biosolids for off-site application.

[373]*373The second prerequisite for protection as a nonconforming use is that the use must not have been expanded, extended, or enlarged since the effective date of the zoning restriction. This point is pivotal.

Virginia courts have recognized that a nonconforming use need not remain static. Trivial, insubstantial, or reasonably customary and incidental change is permitted. However, unlawful changes of use can result from increased volume or frequency of use. See 83 Am. Jur. 2d, Zoning and Planning, § 669. The degree of relevance of any change depends in each case upon the quantum of the increase and its effect upon the purposes and policies the zoning ordinance was designed to promote.

The leading case is Knowlton v. Browning-Ferris, 220 Va. 571 (1979), in which the Supreme Court held that the magnitude of the change in size and scope and tire effects of that change upon the purposes and policies of the zoning ordinance was such that the character of the use had changed thereby disqualifying it as a protected nonconforming use. Also see Spotsylvania County B.Z.A. v. McCalley, 225 Va. 196 (1983).

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Related

Pima Gro Systems, Inc. v. King George County Board of Supervisors
52 Va. Cir. 241 (King George County Circuit Court, 2000)
Carolinas Cement Co. v. Zoning Appeals Board
50 Va. Cir. 502 (Warren County Circuit Court, 1999)
Pima Gro Systems, Inc. v. Zoning Appeals Board
47 Va. Cir. 356 (King George County Circuit Court, 1998)

Cite This Page — Counsel Stack

Bluebook (online)
43 Va. Cir. 370, 1997 Va. Cir. LEXIS 393, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wheelabrator-clean-water-system-inc-v-king-george-county-vacckinggeorge-1997.