Liverpool Township v. Stephens

DISSENTING OPINION BY

Judge PELLEGRINI.

I respectfully dissent. Not following the well-settled law of this Commonwealth, the majority finds that Liverpool Township (Township), a township of the second class, has no authority to regulate where sewage sludge is placed on property because it impermissibly interferes with “geological standards” set by administrative regulations of the Pennsylvania Department of Environmental Protection (DEP). I suggest that regulation has nothing to do with “geological standards” because it has nothing to do with “geology,” but has everything to do with “smell” — bad smells-— caused by sewage sledge dumped from other places that affect the ability of citizens of second class townships to enjoy their homes, property and lives. Because the General Assembly recognized that the statewide administrative regulations issued by DEP do not take into consideration local conditions and only deal with the operation of waste sites, it gave second class townships the authority to enact legislation regulating the placement of sludge and other solid waste to protect the health, welfare and safety of their citizens.

In 1993, the Township adopted Ordinance 13 “pursuant to the provision of the Act of May 1, 1993, P.L. 103, as amended by the Act of May 9, 1961, P.L. 194 (53 P.S. Section 65708).”1 It made it unlawful *1039“for any person to use or continue to use their land or other land as a storage, transfer, collection, processing or disposal site of solid waste or residual waste unless such person shall have a permit....” Article III.l of Ordinance 13. The permit application to operate any of the facilities was to be in accord with the Solid Waste Management Act (SWMA)2 and, among other requirements, the SWMA prohibited the application of waste “within 500 yards of any dwelling, church, school or other building or buildings which from time to time are utilized for human occupancy or residency.” Dean Stephens (Stephens) admitted to disposing of solid waste on his farm and further admitted that he had not applied for a permit from the Township as required by Ordinance 13.3

The Township filed a complaint in equity seeking an injunction against Stephens from utilizing his property as a disposal site for solid waste until he applied and received an appropriate permit from the Township. Stephens defended against the action contending that he did not need a permit from the Township because he had a permit from DEP for the agricultural utilization of sewage sludge on a portion of his farm. He argued that he did not have to seek a permit from the Township because the area sought to be regulated by the Ordinance, i.e., the disposal of solid waste, was preempted by the SWMA and the rules, regulations, standards and procedures promulgated by DEP. The trial court and the majority agrees, holding that Ordinance 13 was preempted from local regulation because it had been preempted by the General Assembly’s enactment of the SWMA, and the Township had no authority to enact such legislation.

The Township contends Ordinance 13 was not preempted by the SWMA because it had the authority to enact Ordinance 13 with its powers given to it under the Second Class Township Code.4 Whether a state statute preempts local regulation is determined by the intent of the General Assembly. The General Assembly can specifically express its intent by either providing that municipalities may enact ordinances not inconsistent with state law or by expressly forbidding municipal regulation.5 However, the General Assembly is often silent and is not presumed to have *1040preempted the field by legislating in it; therefore, it must be clearly shown that it was the General Assembly’s intent to preempt the field by legislation. Retail Master Bakers Association v. Allegheny County, 400 Pa. 1, 161 A.2d 36 (1960); Baird v. Township of New Britain, 159 Pa.Cmwlth. 333, 633 A.2d 225 (1993). The presumption against preemption is based on the understanding that what is being preempted is the ability of the municipality, through its elected local officials, to address the needs of its citizens.

Once it has been determined that an area has not been preempted, local legislation cannot interpose hurdles that would stand as obstacles “to the accomplishment and execution of the full purposes and objectives of the legislature.” Klein v. Straban Township, 705 A.2d 947, 950 (Pa.Cmwlth.1998); Duff v. Toumship of Northampton, 110 Pa.Cmwlth. 277, 532 A.2d 500 (1987). Because recently, in Southeastern Chester County Refuse Authority v. Zoning Hearing Board of London Grove Township, 898 A.2d 680 (2006), where we held that the SWMA did not preempt local regulation, the issue in this case is whether the Township Ordinance has interposed regulatory hurdles that would frustrate the purpose of the state legislation.

Applying those standards in Sunny Farms, Ltd. v. North Codorus Toumship, 81 Pa.Cmwlth. 371, 474 A.2d 56, 59 (1984), we addressed the exact issues involved in this case. An operator of a landfill challenged an ordinance that prohibited the construction and operation of an underground, hazardous waste disposal facility and provided “[n]o such site for incineration or for disposition by the Sanitary Land Fill method shall be established within five hundred (500) yards of any dwelling, church, school or any other building or buildings which, from time to time, are utilized for human occupancy.” In that case, we held that the township had the power under Section 2101 of the Second Class Township Code, 53 P.S. § 67101, to enact legislation regarding where a solid waste site could be located as well as not being preempted by the SWMA. We stated:

We reject the contention that [local regulation] is preempted by the SWMA (Act 97), thus rendering the Township powerless to require a buffer zone between the waste site and occupied residences. Both Act 97 and its predecessor, the now repealed Pennsylvania Solid Waste Management Act (Act 241), are substantially similar in that each provides for extensive state regulation of the construction and operation of solid waste disposal facilities. When we construed Act 241 and failed to find explicit language evincing a legislative intent to override local zoning regulations, we allowed local regulation of sanitary landfills on the condition that engineering and geological standards were not stricter than the state’s.

The majority attempts to distinguish Sunny Farms from the facts of this case in several ways. First, relying on Municipality of Monroeville v. Chambers Development, 88 Pa.Cmwlth. 603, 491 A.2d 307 (1985), the majority tries to explain away Sunny Farms claiming what was at issue was a zoning ordinance which has not been preempted by the SWMA, while the setback here was in an ordinance regulating where sewage sludge could be deposited. We did say in a stray comment in Monroe-ville that the ordinance in question in Sunny Farms was a zoning ordinance, not a police power ordinance, but by examining primary sources, not secondary ones, it is *1041evident that characterization was wrong. In Sunny Farms, referencing the title of the ordinance, we expressly stated that “Ordinance 18 was enacted under the township’s power granted by Section [2101] of the Second Class Township Code (Code), [53 P.S. § 67101], ‘[t]o regulate or prohibit the dumping or otherwise depositing of ashes, garbage, rubbish and other refuse materials within the township.’ ” 6 474 A.2d at 60. It cannot be any clearer that the ordinance in Sunny Farms was not a zoning ordinance.

Second, as a fall back position, the majority then states regardless of whether it was a zoning ordinance or not, the ordinance in Sunny Farms regulated the “placement” of the waste while Ordinance 13 regulates how waste is disposed of, which has nothing to do with aesthetics or property values. In Sunny Farms, we held that a township’s waste disposal ordinance disallowing the placement of a dump within 500 yards of any dwelling was permissible even if the landfill operator had a zoning occupancy permit to place it to the border of its property. More recently, in Hunlock Township v. Hunlock Sand and Gravel Corporation, 601 A.2d 1305 (Pa.Cmwlth.1992), we held that a second class township had the power to enact an ordinance under Section 2101 of the Second Class Township Code to forbid the maintenance, operation and utilization of a sewage sludge composting facility or solid waste facility within a 2,000 feet radius of any residence or residential area. See also Kavanagh v. London Grove Township, 33 Pa.Cmwlth. 420, 382 A.2d 148 (1978).

Other than the Ordinance here being less restrictive — because a farmer can still farm up to his property line — and the dump in Sunny Farms and the sewage sludge composting facility in Hunlock requiring the setback area to remain fallow, I cannot see any difference that a farmer could not dump sewage sludge within 500 yards of the dwelling at issue here and those that precluded dumping in Sunny Farms and Hunlock. All those ordinances impose setback requirements regulating only “where” the waste is put down, none of which goes to the operation of the site which involves “how and when” waste can be put down.

Third, the majority then states that Ordinance 13 interferes with geological or engineering standards set by DEP, admittedly preempted, and has nothing to do with advancing aesthetics or protecting property values. A similar argument was made in Sunny Farms. In that case, the landfill operator also contended that the local 500-yard proximity requirement conflicted with and was an impermissibly more strict engineering or geological standard than that provided for by the regulation of 25 feet [now 50 feet] contained in the state regulation. Finding that a second class township had the authority to enact the regulation under [Section [2101] of the Second Class Township Code, moreover, empowers local government to protect and enhance “the quality of life of its citizens,” 474 A.2d at 60], we held that the proximity requirements were not imper-missibly more strict than the narrow, *1042technical, engineering concerns addressed by DEP regulations because rather than directly setting specific, engineering or geological standards, the Ordinance, consistent with basic land use planning principles, promoted and protected public health, property values and aesthetics. We then went on to quote our Supreme Court in Franklin Township v. Department of Environmental Resources, 500 Pa. 1, 6, 452 A.2d 718, 720 (1982), which emphasized a local government’s major responsibility in environmental matters as follows:

Aesthetics and environmental well-being are important aspects of the quality of life in our society, and a key role of local government is to promote and protect life’s quality for all of its inhabitants.

As to the majority’s statement that Ordinance 13 has nothing to do with aesthetics or property values, I would suggest that aesthetics involve more than an historic village green — no matter where you live, if you had to smell another person’s sewage sludge all day, you would say that was a matter of aesthetics and that it would adversely affect your property’s value, not to mention the health and welfare of the community.

Finally, the majority finds that Section 2101 of the Second Class Township Code does not authorize second class townships to enact supplemental regulations of solid waste, even though we specifically said so in both Sunny Farms and Hunlock. Section 2101 of the Second Class Township Code provides:

The board of supervisors in the manner authorized by the act of July 7, 1980 (P.L. 380, No. 97), known as the “Solid Waste Management Act,” and the act of July 28, 1988 (P.L. 556, No. 101), known as the “Municipal Waste Planning, Recycling and Waste Reduction Act,” may prohibit accumulations of ashes, garbage, solid waste and other refuse materials upon private property; including the imposition and collection of reasonable fees and charges for the collection, removal and disposal thereof.

The majority then states that “Townships have always regulated junkyards, littering and trash pickup and Section 2101 simply authorizes the continuation of these worthy efforts. However, it specifically requires that such township regulation be done ‘in the manner authorized by [the SWMA].’ ” (Opinion at 1036.) Under the majority’s interpretation, because only the Second Class Township Code has such a provision, all other municipalities could prohibit the disposal of trash and ignore the SWMA altogether — the ultimate reverse preemption. The majority does not recognize that “authorized” is a grant of power coming from the SWMA and has nothing to do with departmental regulations issued pursuant to its grant of power which goes to the operation of the waste site itself, not off-site effects of the waste disposal site.

Recognizing that solid waste sites would be located in second class townships of the Commonwealth, the only sensible interpretation of the General Assembly’s reason for enacting this provision is to interpret Section 2101 of the Second Class Township Code as we did in Sunny Farms and Hunlock, which was that under that provision, second class townships had the ability, other than through land use ordinances, to provide for setback requirements of solid waste disposal sites to insure the health, safety and welfare of the community.

For the reasons set forth in this opinion, I respectfully dissent.

Judge McGINLEY joins in this dissenting opinion.

. 53 P.S. § 65708 of the Second Class Township Code was originally enacted by the Act of May 1, 1933, P.L. 103, No. 69, but was amended by the Act of November 9, 1995, P.L. 350, 53 P.S. § 67101 and renumbered as *1039Section 2101 of the Second Class Township Code. For convenience purposes, we will refer to it by its renumbered cite throughout the opinion even where previous opinions referred to it by its old number.

. Act of July 7, 1980, P.L. 380, as amended, 35 P.S. §§ 6018.101-6018.1003.

. The SWMA is silent on proximity requirements. DEP regulations provide for less severe setbacks and buffers than does Ordinance 13. 25 Pa.Code §§ 271.915, 275.202 and 275.203. For instance, 25 Pa.Code § 202(5) provides "the land application of sewage sludge may not be conducted within 50 feet of a property line within which the sludge is applied, unless otherwise approved by [DEP], in writing,” and 25 Pa.Code § 271.915(c)(3) mandates that sewage sludge not be applied to farm land that is "within 300 feet from an occupied dwelling.”

. Act of May 1, 1933, P.L. 103, as amended, 53 P.S. §§ 65101-68701.

. For an example of express preemption, Section 602 of the Oil and Gas Act, Act of December 19, 1984, P.L. 1140, as amended, 58 P.S. § 601.602, provides:

Except with respect to ordinances adopted pursuant to the act of July 31, 1968 (P.L. 805, No. 247), known as the Pennsylvania Municipalities Planning Code, and the Act of October 4, 1978 (P.L. 851, No. 166), known as the Flood Plain Management Act, all local ordinances and enactments purporting to regulate oil and gas well operations regulated by this act are hereby superseded. No ordinances or enactments adopted pursuant to the aforementioned acts shall contain provisions which impose conditions, requirements or limitations on the same features of oil and gas well operations regulated by this act or that accom*1040plish the same purposes as set forth in this act. The Commonwealth, by this enactment, hereby preempts and supersedes the regulation of oil and gas wells as herein defined.

. Not only is it clear from our decision in Sunny Farms, the trial court in Sunny Farms expressly identified the ordinance as one controlling waste disposal. Sunny Farms, Ltd. v. North Codorus Township, 67 Mun.L.R. 183, 1976 WL 17411 (York County 1976). ("That case [Greater Greensburg Sewage Authority v. Hempfield Township, 5 Pa.Cmwlth. 495, 291 A.2d 318 (1972)], involved a dispute as to whether a township zoning ordinance prohibiting disposition of sludge from a sewage disposal plant could be applied to a disposal plant the operation of which had been authorized by the Department of Environmental Resources. Although the township legislation there controlled zoning rather than waste disposal as here....”)