Recycle & Recover, Inc. v. Georgia Board of Natural Resources

Fletcher, Presiding Justice,

dissenting.

The majority opinion ignores the facts, misapplies the law, and sets bad policy by ruling that Recycle & Recover, Inc. need not wait the three years now required by law before seeking to expand its Cherokee County landfill by 300 percent. This decision allows Recycle to expand its landfill capacity from 11 million cubic yards to 35 million cubic yards while escaping reasonable statutory requirements. The handling of solid waste is too critical to public health to apply the law as it existed at the time Recycle first filed its application. Because Recycle does not have a vested right to a major modification of its landfill, I dissent.

In 1989, Recycle filed an application for a solid waste handling permit to operate a municipal solid waste landfill in Cherokee County. The Department of Natural Resources in 1992 issued a permit granting Recycle authority to operate the landfill with a capacity of 11 million cubic yards. An administrative law judge affirmed the issuance of the permit a year later. In August 1993, prior to the landfill opening, the company applied for a major modification to increase the landfill’s capacity to 35 million cubic yards. Before DNR could approve the application, the legislature amended the Georgia Comprehensive Solid Waste Management Act to prohibit the director from granting a major modification of a landfill “sooner than three years from the date any such facility commenced operation.”2 Relying on this amendment, DNR denied Recycle’s application for a major modification in January 1995. The trial court upheld the department’s decision and Recycle appealed.

1. Contrary to the majority’s conclusion, Recycle did not have a vested right to modify its existing solid waste handling permit. “ ‘To be vested, in its accurate legal sense, a right must be complete and consummated, and one of which the person to whom it belongs can*257not be divested without his consent.’ ”3 Recycle did not have a consummated right to a permit for a major expansion of its landfill because its application was incomplete when initially filed and when the three-year waiting period became effective. On April 14,1994, Recycle withdrew a critical document — its site assessment report — in response to DNR’s notice setting out the report’s deficiencies. As a result, DNR suspended its review of the proposed landfill site pending the resubmission of the assessment report. Thus, when the 1994 amendment went into effect on April 19, 1994, Recycle was not entitled to approval of its application because it had not yet complied with the requirements for a major modification.4

Nor did Recycle obtain a vested right in its application to modify. A person has no vested right in a procedure.5 The majority opinion states that it does not reach the “ultimate question of whether [Recycle] is entitled to issuance of a permit for major modification.”6 If this sentence means that Recycle has a vested right in its application, as opposed to the permit, then the majority gives Recycle the right to be heard without abiding by the three-year moratorium established in the 1994 amendment. The effect of this holding is to give Recycle a vested right in a procedure — the time for filing an application — contrary to state law.7

2. A state legislature may enact state laws under the exercise of its police power for the protection of the public “without violating any express or implied constitutional prohibition against retroactive statutes.”8 This inherent power to protect the lives, health, and property of citizens is not subject to any definite limitations.9 Applying these principles, this Court upheld the constitutionality of a 1975 act concerning adverse possession of certain mineral rights as applied to a pre-1975 deed.10 Similarly, the state must have the flexibility to eval*258uate pending applications for solid waste handling permits based on current standards, regulations, and technology.11 In this case, DNR evaluated Recycle’s site assessment based on a circular that was revised after its application was filed and imposed new criteria for performing site acceptability studies for solid waste landfills.

Based on its inherent police power, the legislature passed the solid waste management act to provide for a comprehensive statewide program to assure that landfills do not adversely affect the public health and safety or degrade the environment.12 To fulfill this purpose, the act makes it unlawful for any person to engage in solid waste handling or construct or operate a solid waste handling facility in Georgia without first obtaining a state permit.13 The act gives the Board of Natural Resources the power to promulgate rules and regulations that enforce the statute and to take all necessary steps to ensure effective enforcement.14 The act likewise grants broad enforcement powers to DNR, including the power to administer the act, issue permits, conduct studies, investigate compliance, implement comprehensive plans, institute enforcement proceedings, and exercise “all incidental powers necessary to carry out the purposes of this part.”15 This comprehensive regulatory scheme is a reasonable exercise of the state’s police power. Under it, the state may delay the application process for a major modification of a landfill to enable state regulators to evaluate the efficacy of the existing operation before approving a three-fold expansion in the landfill’s capacity.

Because of the distinction between a comprehensive state environmental law affecting public health and a local zoning ordinance governing land use, the zoning cases holding that property owners have vested rights do not apply in this case. A permit to handle solid waste is not a local zoning requirement, like a building permit or a special use permit, but is more in the nature of a state licensing requirement. Although both zoning and licensing regulations promote the general welfare, they accomplish this purpose by dissimilar means.16 “The fact that a zoning ordinance permits a use in a particu*259lar district does not authorize the use there without a license.”17 A license imposing additional restrictions on land use may be required when the use is affecting natural resources like air, soil, and water. As a result of these differences, we have previously refused to extend the theory of vested rights under zoning law to licensing regulations.18 Rather, the standards to apply in licensing cases are “those existing at the time of the hearing on the license application rather than at the time the application is filed.”19 Nothing in the plurality opinion in Banks County v. Chambers of Ga.20 requires a different result since that case addressed a narrow question of compliance with a local zoning ordinance.

Decided January 22, 1996 — Reconsideration denied February 16, 1996. Davis, Gregory, Christy & Forehand, Hardy Gregory, Jr., Dick *260Wilson, Jr., L. Robert Lovett, for appellant.

*2593. Since Recycle has no vested right and solid waste handling is a public health issue, the trial court correctly held that DNR should apply the law existing when it decided Recycle’s application.21 Under the 1994 amendment, Recycle’s application for a major modification of its Cherokee County landfill permit was untimely. OCGA § 12-8-24 (e) (1) provides that modifications of existing solid waste handling permits to allow horizontal expansion “shall be classified as major permit modifications and shall not be granted by the director sooner than three years from the date any such facility commenced operation,” unless the facility’s capacity is increased no more than ten percent. Recycle filed its application before it commenced operating its landfill under the 1992 permit and sought to expand the landfill’s capacity by more than ten percent. Therefore, it was not entitled to a modification under the statute.

I am authorized to state that Chief Justice Benham and Justice Sears join in this dissent.

*260Michael J. Bowers, Attorney General, Robert S. Bomar, Senior Assistant Attorney General, Barbara H. Gallo, Assistant Attorney General, Kirwan, Parks, Chesin & Remar, Robert S. Remar, Susan M. Garrett, for appellee.

See Ga. L. 1994, p. 1922 (codified at OCGA § 12-8-24 (e) (1) (Supp. 1995)).

Hayes v. Howell, 251 Ga. 580, 584 (308 SE2d 170) (1983) (quoting Merchants Bank v. Garrard, 158 Ga. 867, 871 (124 SE 715) (1924)); see also Black’s Law Dictionary 1402 (5th ed. 1979) (defining a vested right as an “[¡Immediate or fixed right to present or future enjoyment and one that does not depend on an event that is uncertain”).

Between the effective date of the 1994 amendment and DNR’s denial of Recycle’s application, Recycle resubmitted its site assessment report, hydro geological assessment report, and design and operation plan.

See Hunter v. Johnson, 259 Ga. 21, 22 (376 SE2d 371) (1989); Pritchard v. Savannah St. &c. R. Co., 87 Ga. 294 (13 SE 493) (1891).

266 Ga. at 255.

See Stone Mountain Indus, v. Wilhite, 221 Ga. 269, 271 (144 SE2d 357) (1965) (upholding the right of a county to increase the time for filing a rezoning application from 12 months to 18 months because the “original provision for a renewed application after 12 months gave no property owner a vested and irrevocable right to apply after 12 months”).

Bullard v. Holman, 184 Ga. 788, 792 (193 SE 586) (1937).

Pope v. City of Atlanta, 242 Ga. 331, 333 (249 SE2d 16) (1978), cert. denied, 440 U. S. 936 (99 SC 1281, 59 LE2d 494) (1979).

See Hayes, 251 Ga. at 585.

See OCGA § 12-8-24 (e) (granting director the power to modify solid waste handling permits according to rules promulgated by the board); cf. OCGA § 12-5-30 (d) (granting the director the power to revoke, suspend, or modify permits to discharge pollutants into waters of state based on any changed condition that requires the discharge to be reduced or eliminated).

OCGA § 12-8-21 (1992); see Solid Waste Management, 7 Ga. St. U. L. Rev. 231 (1990) (describing legislative history of 1990 bills amending the act).

OCGA §§ 12-8-24 (a); 12-8-30.10 (applying to all persons except individuals disposing of solid waste from their residence onto their own land which does not adversely affect the public health).

OCGA § 12-8-23.

OCGA § 12-8-23.1.

Cobb County v. Peavy, 248 Ga. 870, 872 (286 SE2d 732) (1982).

Id.

See id. (holding that issuance of a business license is not the same as issuance of a building permit); see also Jackson v. Three Aces Co., 249 Ga. 395, 396 (291 SE2d 522) (1982) (refusing to apply zoning rule in liquor licensing case).

Jackson v. Three Aces Co., 249 Ga. at 396.

264 Ga. 421 (444 SE2d 783) (1994). Even if the case were not distinguishable, its value as a precedent is questionable given that only three justices concurred in both the reasoning and result of the opinion. Two justices concurred in the judgment only, and two justices dissented.

See Jackson v. Three Aces Co., 249 Ga. at 396; cf. City of Valdosta v. Singleton, 197 Ga. 194, 208 (28 SE2d 759) (1944) (a reviewing court should apply the law as it exists at the time of its judgment where the law has been changed and new law impairs no vested right under the prior law).