Halaco Engineering Co. v. South Central Coast Regional Commission

*80REYNOSO, J., Concurring and Dissenting.

I concur in the judgment insofar as it upholds the trial court’s denial of the claims by Halaco Engineering Company (Halaco) to an exemption for the propane tank and to attorney fees. I respectfully dissent, however, from the majority’s holding that Halaco is entitled to the exemption, denied by defendant South Central Coast Regional Commission, for the continued use of its settling pond and waste disposal site. I cannot agree that the City of Oxnard’s approval of the construction and use of the pond and adjoining land as a waste disposal site, as found by the trial court, gave Halaco a vested right to engage in an ongoing process of industrial waste disposal within the coastal zone absolutely free of any regulation by the California Coastal Commission (Commission) through enforcement of reasonable conditions attached to a coastal zone development permit.

As the majority opinion recognizes, the only issue presented here is whether Halaco is entitled to escape even applying to the Commission for a permit to continue dumping waste dredged from its settling pond upon an ever-expanding area of its eastern parcel. “The burden of compliance with the permit requirement is insubstantial, and the Commission might, after all, grant the permit or impose conditions which are not sufficiently onerous to constitute a taking or otherwise offend principles of due process.” (Majority opn., ante, p. 64.) Yet the majority goes on to affirm a judgment that denies the Commission power to impose even those admittedly constitutional conditions upon the continuation of Halaco’s waste disposal operation.

Public Resources Code section 30600, subdivision (a), generally requires anyone “wishing to perform or undertake any development in the coastal zone” to “obtain a coastal development permit.”1 Section 30607 provides that any such permit “shall be subject to reasonable terms and conditions in order to ensure that such development or action will be in accordance with the provisions of this division,” i.e., the provisions of the California Coastal Act of 1976 (Act) (§ 30000). Chapter 3 of the Act (§ 30200 et seq.) sets forth a host of environmental “standards by which the. . . permissibility of proposed developments subject to the provisions of [the Act] are determined” (§ 30200). This statutory scheme clearly empowers the Commission not only to allow or prohibit proposed developments but also to regulate the manner in which the development is “performed” (§ 30600, subd. (a)) by imposing and enforcing reasonable conditions attached to the permits issued.

Section 30608, under which Halaco seeks complete exemption from such regulation, does not define “vested right.” The meaning of that phrase in *81California law has been elucidated almost entirely with respect to claimed rights to construct buildings or other static improvements. (See, e.g., Avco Community Developers, Inc. v. South Coast Regional Com. (1976) 17 Cal.3d 785 [132 Cal.Rptr. 386, 553 P.2d 546].) Once lawful construction work has passed a certain point, it is deemed unfair to interfere with completion of the structure as planned because without completion, the time and resources already expended would be wasted.

The “development” here, however, consists not of a structure but of an ongoing process, i.e., the dumping of solid waste disposal, derived from drosses, skimmings, sludges, and scraps, over an ever-widening area up to the boundaries of the parcel. (See § 30106, including in the definition of “development,” the “discharge or disposal of any dredged material or of any gaseous, liquid, solid, or thermal waste.”) Though the ultimate result of that disposal process may be hills or banks of material with predictable dimensions, their formation is not the purpose of the process; indeed, their disappearance would aid, not hinder, Halaco’s stated objectives. Unlike the developer of a construction project, whose inherent interest (other things being equal) is to complete construction as soon as possible, the “developer” of an ongoing industrial process, such as Halaco, normally wishes to prolong it as long as possible. Thus, developments consisting of ongoing uses may fairly be subject to regulation from which a construction project, on which substantial lawful work has already been done, should be exempt.

Section 30608’s use of the undefined phrase “vested right” to delineate a development’s exemption from the permit requirement implies an exemption no broader than that which is constitutionally required. A nonconforming use may be validly subjected to “a strict policy against [its] extension or enlargement” (County of San Diego v. McClurken (1951) 37 Cal.2d 683, 687 [234 P.2d 972]) and may be eliminated by reasonable amortization (Metromedia, Inc. v. City of San Diego (1980) 26 Cal. 3d 848, 881-885 [164 Cal.Rptr. 510, 610 P.2d 407], revd. on other grounds, 453 U.S. 490 [69 L.Ed.2d 800, 101 S.Ct. 2882]) or whenever it becomes a nuisance (City of Escondido v. Desert Outdoor Advertising, Inc. (1973) 8 Cal.3d 785, 790 [106 Cal.Rptr. 172, 505 P.2d 1012]; Livingston Rock etc. Co. v. County of L.A. (1954) 43 Cal.2d 121,128 [272 P.2d4]). The question whether Halaco’s dumping operation could be legally eliminated by these or other means, however, need not be reached here, for Halaco should be required to apply for a permit even if the only possible result is the subjection of its operation to Commission regulation through the imposition of reasonable conditions upon issuance of the permit.2 Even though Halaco may have a vested right *82against outright denial of a permit for its dumping operation, it does not have such a right to issuance of a permit free of reasonable regulatory conditions. (United States v. Riverside Bayview Homes (1985) 474 U.S. 121, — [88 L.Ed.2d 419, 426, 106 S.Ct. 455, 459]; American National Ins. Co. v. Fair Employment & Housing Com. (1982) 32 Cal.3d 603, 607 [186 Cal.Rptr. 345, 651 P.2d 1151].)

As the majority points out, a developer who claims a vested right as a basis for exemption from the permit requirement of the Act must first seek confirmation of the claim by the Commission and may not first assert the claim as a defense to Commission enforcement proceedings. (Ante, p. 63; South Coast Regional Com. v. Gordon (1977) 18 Cal. 3d 832 [135 Cal.Rptr. 781, 558 P.2d 867]; State of California v. Superior Court (1974) 12 Cal.3d 237 [115 Cal.Rptr. 497, 524 P.2d 1281].) That rule, however, does not bar the developer from applying for a permit and asserting, in the application proceeding, a constitutional or vested right to (1) issuance of the permit, albeit with conditions, and (2) freedom from overly onerous conditions. Halaco’s remedy is to pursue that course. “ [I]t is sheer guesswork to conclude that the Commission will abuse its authority by imposing impermissible conditions on any permits required. ... If the Commission does impose questionable conditions, the affected landowners may of course pursue their remedy of a petition for writ of administrative mandamus to review the factual and legal bases for the conditions imposed.” (Pacific Legal Foundation v. California Coastal Com. (1982) 33 Cal.3d 158, 174 [188 Cal.Rptr. 104, 655 P.2d 306].)

Accordingly, I would reverse the judgment below insofar as it grants a writ to require confirmation of a vested right in Halaco to continue its use *83of the settling pond and waste disposal site without obtaining a coastal development permit.

Bird, C. J., concurred.

All section references are to the Public Resources Code unless otherwise indicated.

There is an arguable analogy between Halaco’s claim of a right to continue dumping *82waste to the outer limits of its parcel and claims by operators of quarries or similar extractive enterprises to immunity from zoning laws purporting to prohibit their operations but enacted after the business was under way. The analogy is imperfect because it would be physically possible to move Halaco’s dumped material to a different location whereas the extractive enterprise cannot take out the rock or other earth material anywhere but at its original location. (McCaslin v. City of Monterey Park (1958) 163 Cal.App.2d 339, 349 [329 P.2d 522].)

In McCaslin, a quarry operator obtained an injunction against enforcement of an ordinance that would have limited the quarrying operation to the area already excavated. The operator was held entitled to extend the excavations to the entire tract. A constitutional barrier to legislative prohibition of the continuation of an existing extractive business, however, does not preclude reasonable legislative restrictions on the manner of conducting the business. (Id., at pp. 347-348; Dock Watch Hol. Quarry Pit, Inc. v. Tp. of Warren (1976) 142 N.J. Super. 103 [361 A.2d 12, 20] [“Nonconforming uses are clearly subject to . . . police power regulations”], affd., 74 N.J. 312 [377 A. 2d 1201]; Flanagan v. Town of Hollis (1972) 112 N.H. 222 [293 A.2d 328]; People v. Gerus (1942) 19 Misc.2d 389, 393-394 [69 N.Y.S.2d 283, 288].)