Eagle Environmental II, L.P. v. Commonwealth

Justice NEWMAN,

dissenting.

I respectfully dissent from the Majority Opinion in this matter. I believe that the Environmental Quality Board (“the EQB”), when promulgating the regulations at issue in this matter, 25 Pa.Code § 287.127(c) and 25 Pa.Code § 271.127(c), exceeded its statutory authority.

The Department of Environmental Protection (“DEP”), as an administrative agency, has not only the authority, but also the duty to promulgate rules and regulations to enable it to more efficiently and effectively carry out its legislatively supplied control. See generally 2 Pa.C.S. § 102(a); accord Hospital Ass’n of Pa. v. MacLeod, 487 Pa. 516, 410 A.2d 731, 733 (1980) (“substantive rule-making is a widely used administrative practice, and its use should be upheld whenever the *522statutory delegation can reasonably be construed to authorize it”). However, equally unassailable is the principle that “the Legislature cannot constitutionally delegate the power to make law to any other branch of government or to any other body or authority.” Gilligan v. Pa. Horse Racing Comm’n, 492 Pa. 92, 422 A.2d 487, 489 (1980) (citing State Bd. of Chiropractic Examiners v. Life Fellowship of Pa., 441 Pa. 293, 272 A.2d 478, 480 (1971)).

The General Assembly may “confer authority and discretion in connection with the execution of the law [and] may establish primary standards and impose upon others the duty to carry out the declared legislative policy in accordance with the general provisions of the act.” Id. (internal quotation and citation omitted). However, “(1) the basic policy choices must be made by the Legislature; and (2) the legislation must contain adequate standards which will guide and restrain the exercise of the delegated administrative functions.” Id. (quoting William Penn Parking Garage, Inc. v. City of Pittsburgh, 464 Pa. 168, 346 A.2d 269, 291 (1975), and Chartiers Valley Joint Sch. Dist. v. County Bd. of Sch. Dirs., 418 Pa. 520, 211 A.2d 487, 493 (1965)). “The power and authority to be exercised by administrative commissions must be conferred by legislative language clear and unmistakable. A doubtful power does not exist. Such tribunals are extra judicial. They should act within the strict and exact limits defined.” Green v. Milk Control Comm’n, 340 Pa. 1, 16 A.2d 9, 9 (1940) (internal citation omitted).

Although courts traditionally accord some deference to the interpretation made by the agency charged with administration of the act, the meaning of a statute is essentially a question of law for the court, and, when convinced that the interpretative regulation adopted by an administrative agency is unwise or violative of legislative intent, courts disregard the regulation. Pa. Human Relations Comm’n v. Uniontown Area Sch. Dist., 455 Pa. 52, 313 A.2d 156, 169 (1973); see also United States v. Cartwright, 411 U.S. 546, 93 S.Ct. 1713, 36 L.Ed.2d 528 (1973); Skidmore v. Swift & Co., 323 U.S. 134, 65 S.Ct. 161, 89 L.Ed. 124 (1944).

*523Therefore, this review begins with the statutes themselves, i.e., the Solid Waste Management Act (“SWMA”), 35 P.S. §§ 6018.101-6018.1003, and the Municipal Waste Planning, Recycling and Waste Reduction Act (“Act 101”), 53 P.S. §§ 4000.101-4000.1904 (collectively, “the Acts”). Sections 105(a) of the SWMA and 302 of Act 101 expressly provide the EQB with the authority to develop and adopt regulations to carry out the purposes of the legislative enactments. 35 P.S. § 6018.105(a);1 53 P.S. § 4000.302.2 The purposes of the Acts include: (1) protecting the public from the dangers of waste; and (2) implementing Article I, Section 27 of the Pennsylvania Constitution. 35 P.S. § 6018.102; 53 P.S. 4000.102(b). The crux of the issue before us in these consolidated cases is whether the EQB had the constitutional authority to promulgate the harms/benefits test.

In Payne v. Kassab, 11 Pa.Cmwlth. 14, 312 A.2d 86, 94 (1973) aff'd, Payne v. Kassab, 468 Pa. 226, 361 A.2d 263 (1976), the Commonwealth Court held that' Article I, Section 27 of the Pennsylvania Constitution “was intended to allow the normal development of property in the Commonwealth, while at the same time constitutionally affixing a public trust concept to the management of public natural resources in Pennsylvania.” The Court explained that controlled development is preferable to no development. Id. In so holding, the Commonwealth Court articulated the following three-pronged test for judicial review of a decision emanating from such a balancing of environmental and social factors:

(1) Was there compliance with all applicable statutes and regulations relevant to the protection of the Common*524wealth’s natural resources? (2) Does the record demonstrate a reasonable effort to reduce the environmental incursion to a minimum? (3) Does the environmental harm that will result from the challenged decision or action so clearly outweigh the benefits to be derived therefrom that to proceed further would be an abuse of discretion?

Id. On appeal, this Court affirmed the Order of the Commonwealth Court. We stated that “[i]t is manifest that a balancing must take place, and ... the legislature has made careful provision for just that.” Payne v. Kassab, 468 Pa. 226, 361 A.2d 263, 273 (1976) (emphasis added). “The elaborate safeguards provided [by Section 13(b)], if truly complied with by the governmental departments and agencies involved, vouchsafe that a breach of the trust established by Article I, § 27 will not occur.” Id.

However, the statute at play in Payne provided explicit direction for performing this balancing by enumerating twenty-three social, economic and environmental factors3 for *525courts to consider in performing an Article I, Section 27 balancing test. Payne v. Kassab, 468 Pa. 226, 361 A.2d 263 (1976). Notably, the Majority fails to mention that consideration of the establishment of a school or making of a charitable contribution are not among the factors enumerated in the statute.

Unlike the statute at issue in Payne, the Acts in the instant case do not provide express authority for such balancing. I find this omission telling. “If the statute expressed such authority, we would be engaged in this controversy----Indeed, in light of our duty to discern legislative language clear and unmistakable in every case ... the absence of specific language in the SWMA should have been dispositive.” Slip Op. at 56 (Labuskes, J., dissenting). If the Legislature wished for the DEP to, via regulation, balance these harms, it was *526capable of saying as much. I believe that where the Legislature has declined to provide such direction to the regulatory agency, we cannot presume there was an unspoken grant of this power. Rather, I believe, in such instances the Legislature intended to perform this task itself. The Acts themselves are the result of this balancing.

In Nat’l Solid Wastes Mgmt. Ass’n v. Casey, 143 Pa. Cmwlth. 577, 600 A.2d 260 (1991), the Governor argued that he had the authority to issue the Order pursuant to Article I, Section 27 of the Pennsylvania Constitution. However, the Commonwealth Court rejected this argument, reasoning that “[t]he Governor’s power is to execute the laws and not to create or interpret them.” Id. at 263 (quoting Shapp v. Butera, 22 Pa.Cmwlth. 229, 348 A.2d 910 (1975)).

Additionally, we find no authority for [the] Executive Order ... in Article I, Section 27 of the Pennsylvania Constitution .... The balancing of environmental and societal concerns, which the Commonwealth argues is mandated by Article I, Section 27, was achieved through the legislative process which enacted [the SWMA and Act 101] and which promulgated the applicable regulations. Article I, Section 27 does not give the Governor authority to disturb that legislative scheme. Neither does it give him the authority to alter DER’s responsibilities pursuant to that scheme.

Id. (internal citation omitted). We entered a per curiam Order affirming the decision of the Commonwealth Court, Nat'l Solid Wastes Mgmt. Ass’n v. Casey, 533 Pa. 97, 619 A.2d 1063 (1993), which has no precedential effect. See Commonwealth v. Tilghman, 543 Pa. 578, 673 A.2d 898, 904 (1996) (explaining that a per curiam affirmance becomes the law of the case, but to adopt the rationale employed by the intermediate appellate court, we would need to enter a per curiam Order to affirm “on the basis of the opinion of the lower court”).

While Payne and Casey have limited applicability to the matter sub judice, nevertheless, they are the pronouncements of the law in this Commonwealth most relevant to our case. What Payne and Casey do stand for in this context is that *527Article I, Section 27 of the Pennsylvania Constitution creates a public trust in the government to ensure that any advances or changes to the natural landscape do no more harm to the environment (or historic, natural or scenic areas) than is necessary to accomplish an important public work, and that the benefit of the important public work outweighs the harm that the environment (or historic, natural or scenic areas) will suffer.

Article I, Section 27, when conceived in this manner, limits consideration of harms and benefits to those directly related to the proposed public work. I do not agree that:

The language of the [SWMA] or [Act 101] clearly and unambiguously confers on the [EQB] the authority to promulgate a harms/benefits environmental assessment test which, under the guidelines published by the [DEP] considers “establishing schools” and “charitable contributions” as possible “social and economic benefits” of municipal or residual waste landfill.

Eagle Environmental v. DEP, 818 A.2d 574, 584 (Friedman, J., dissenting) (internal quotations omitted). Thus, while a harms/benefits analysis in a general sense is not only appropriate, but also required, the promulgation of regulations defining the confines of such an analysis must be a matter of careful drafting. Where the harms/benefits test of the EQB falls afoul of this principle is in the scope of “social and economic benefits” that DEP can consider when deciding whether to grant an application.

A social or economic benefit is generally educationally or financially based, and has social and economic impacts. Impacts are not to be categorized separately as “social” or “economic” benefits; the category of “social and economic benefits” is a single concept. The category includes, [inter alia ], establishing schools, charitable contributions and free waste disposal for communities.

August 24, 2002, Environmental Assessment Process, Phase I Review, DEP Document Number 254-2100-101, page 8 (emphasis added).

*528I agree with Judge Friedman who states in her dissent, “I see no connection between regulating waste ‘disposal’ and establishing schools or making charitable contributions.” Eagle, 818 A.2d at 586. The establishment of schools in the surrounding community and the contribution of funds to charities, while beneficial to the public at large, have nothing to do with the construction of a waste disposal site.

The petitioners in this case have suggested that “benefits” like the establishing of schools and the making of charitable contributions are akin to coerced contributions. (See majority at-, 818 A.2d at 583.) I agree. Indeed, it appears that an applicant who would not otherwise be entitled to a municipal or residual waste landfill permit based on the harms/benefits test could buy such a permit by agreeing to pay enough money that, according to the DEP’s calculations, benefits would outweigh harms.

Id. n. 8. The harms/benefits test promulgated by the EQB effectively allows an entity seeking to create a waste disposal facility to buy a permit.4 The system of balancing employed by the EQB contravenes the Acts because it enables the DEP to compromise the protection of the environment based upon what it perceives to be a general benefit to the community.

Therefore, I find that Article I, Section 27 of the Pennsylvania Constitution, and its reference in the purpose provisions of the SWMA and Act 101, limit the authority of the EQB to promulgate regulations pursuant to these statutes. Specifically, the EQB erred by developing a regulatory scheme whereby an entity can pump enough money into the community surrounding the planned site of a public work to trump significant environmental concerns about the proposed project. The only benefits relevant to an Article I, Section 27 determination are *529those directly related to the proposed project for which a permit is sought. Accordingly, in light of the narrow scope of the challenge made in the instant case, I believe the harms/benefits test is invalid to the extent that it allows for the consideration of the establishment of schools and contributions to charities in determining the social and economic benefits of a municipal or residual waste landfill.

Justice EAKIN joins this Dissenting Opinion.

. Section 105(a) of the SWMA provides as follows:

The [EQB] shall have the power and its duty shall be to adopt the rules, regulations, criteria and standards of [DEP] to accomplish the purposes and to carry out the provisions of this act, including but not limited to the establishment of rules and regulations relating to the protection of safety, health, welfare and property of the public and the air, water and other natural resources of the Commonwealth.

. Section 302 of Act 101 states that "[t]he [EQB] shall have the power and its duty shall be to adopt the regulations of [DEP] to accomplish the purposes and to carry out the provisions of this act.”

. Section 13(b) of Article XX of the Administrative Code of 1929 provides as follows:

Upon the submission of the preliminary plan or design to the Department of Transportation for any transportation route or program requiring the acquisition of new or additional right-of-way, the Department of Transportation except in cases involving complaint proceedings under the jurisdiction of the Public Utility Commission shall have the power and its duty shall be to follow the hearing procedures now or hereafter required by the Federal Government for Federal-aid transportation programs pursuant to Titles 23 and 49 of the United States Code as amended and the regulations and procedures thereunder even though the transportation route or program does not contemplate the use of or actually employ Federal funds. At the hearings required by this subsection the Department of Transportation shall consider the following effects of the transportation route or program:
(1) Residential and neighborhood character and location;
(2) Conservation including air, erosion, sedimentation, wildlife and general ecology of the area;
(3) Noise, and air and water pollution;
(4) Multiple use of space;
(5) Replacement housing;
(6) Displacement of families and businesses;
(7) Recreation and parks;
(8) Aesthetics;
(9) Public health and safety;
(10) Fast, safe and efficient transportation;
*525(11) Civil defense;
(12) Economic activity;
(13) Employment;
(14) Fire protection;
(15) Public utilities;
(16) Religious institutions;
(17) Conduct and financing of government including the effect on the local tax base and social service costs;
(18) Natural and historic landmarks;
(19) Property values;
(20) Education, including the disruption of school district operations;
(21) Engineering, right-of-way and construction costs of the project and related facilities;
(22) Maintenance and operating costs of the project and related facilities;
(23) Operation and use of existing transportation routes and programs during construction and after completion.
At the hearings required by this section, the public officials named in clause (15) of subsection (a) of this section shall make a report indicating the environmental effects of the proposed transportation route or program. The Department of Transportation shall not construct or reconstruct any portion of the transportation route or program unless the Secretary of Transportation makes a written finding published in the Pennsylvania Bulletin that:
(1) No adverse environmental effect is likely to result from such transportation route or program; or
(2) There exists no feasible and prudent alternative to such effect and all reasonable steps have been taken to minimize such effect. For the purpose of this subsection environmental effect shall refer to the effects enumerated in this subsection.

71 P.S. § 512(b).

. Although the Majority attempts to assuage my concern regarding this issue by noting that the regulations require that mitigation plans adequately protect the environment, it fails to do so. My concern is the relationship between the harm caused and the benefit provided. Simply stating that adequate protections must be in place does not ensure that the benefit conferred on the public relates to the damage suffered by the environment. It is this lack of relation between the harm and benefit that I believe is not supported by the statutory grant of rulemaking authority.