Patricia “Nemi” Trent thought she’d covered her bases. Last year, this well-preserved West Baltimore senior citizen received a citation from the city for a bag of trash found without a trash can several blocks from her house; a piece of paper with her name on it was inside. At a hearing before the Environmental Control Board (ECB), the regulatory agency that adjudicates civil citations, Trent explained that her garbage can had been wheeled off by thieves, who must have dumped her trash en route. The presiding administrative judge lowered her fine and advised her to purchase a paper shredder, she says. “I took her suggestion,” she says. “If anything comes to me in my mail slot, I make sure my name is nowhere on it.”

In January of this year, enforcement officers reported finding a piece of mail addressed to Trent in a city-owned vacant lot around the corner from her house. The lot also contained a mattress, a sink, and a large pile of overflowing trash bags. Trent received two citations, one for the voluminous pile of trash ($50) and the other for the fact that it was found on a non-trash day ($50). The evidence that the trash was hers consists of two photographs of the garbage and one closeup of a piece of mass mail addressed to “Patricia Trent or Current Resident.” (These are posted on the Baltimore Housing Department web site.) There are no wide shots that include both the envelope and the trash. “I never received that piece of mail,” Trent says. “And I’m a senior citizen. How am I gonna carry a mattress and a sink?”

Trent requested a hearing once more. She brought a pro bono lawyer from Legal Services for the Elderly and a letter of support from the Druid Heights Community Development Corporation, where she volunteers. She hoped that evidence of good character—the grant for 100 free recycling bins she helped her community obtain last year, partly by using photos of the very same trash-strewn lot; the tree-planting she’d initiated; the certificates and letters of commendation for community service she’d received from city officials over the years, going back to Mayor Kurt Schmoke—would help. But the administrative judge upheld the citations. To appeal would cost $50, plus the cost of transcripts from her hearing ($3 per page). “I’m livid,” she says. “I didn’t do it. Quite frankly, it seems like they’re more interested in fining somebody than they are in getting the right person.”

Many people seem to be livid at the Environmental Control Board lately. At least three lawsuits involving the board are currently pending in Circuit Court, and Baltimore Inspector General David McClintock says complaints have reached his office. (“I have seen some inquiries and we are in the process of assessing what the best course of action is for that,” he says.) Meanwhile, a bevy of local bloggers are busy sniffing for corruption. Gadfly Adam Meister has pointed out on his Charm City Current blog that ECB Administrative Judge Gary Brooks lives next door to former mayor Sheila Dixon, and the anonymous, now defunct Baltimore Government Watch revealed that Administrative Judge Patricia Welch is married to Martin Welch, chief judge of the Baltimore City Circuit Court, which hears ECB appeals. (ECB Executive Director Sandra Baker says Martin Welch has never been assigned an administrative review from ECB. “And we’d be the first to say that that would be unethical,” she adds.) Baltileaks, a site modeled after WikiLeaks, has released several public documents related to the ECB, including financial disclosure statements by members of the board and administrative judges’ contracts.

Residents and landlords have complained to City Paper, as well. About 10 people who communicated with a reporter had wide-ranging complaints about the ECB. They included objections to what the board considers evidence of a violation—generally a photograph or two, as in Trent’s case, and the testimony of an enforcement officer—and complaints that notices of a right to a hearing were never received, that rulings on appeals were not forthcoming, that the cost of those appeals was prohibitively expensive, and that the ECB lacks oversight.

One man, who wished to remain anonymous because he fears retribution from the city, received citations two years ago for trash stuck in the hedges around his house. Ever since his hearing—which he describes as “Soviet Gulag-style”—he’s been filing Maryland Public Information Act requests, reviewing state and federal regulations, and digging into court filings in an effort to discredit the agency. “My experience has been that it’s basically a rubberstamp,” he says.

No one has provided clear proof that the Environmental Control Board is corrupt. But judging by the frustrations it tends to evoke in those subject to its rulings, this city agency has a long way to go to achieve transparency and the trust of citizens. While supporters—some public officials, for instance—believe the ECB is simultaneously cleaning up the city and filling its coffers, opponents see the agency as an inflexible, Kafkaesque bureaucracy that exists solely to rake in revenue. Corrupt or not, there appears to be little solid evidence that the ECB has succeeded in cleaning up the city during its more than decade-long tenure. Meanwhile, it’s not making any friends.

The hearing rooms at the quasi-judicial Environmental Control Board in downtown Baltimore have all the majesty of office cubicles. After receiving a citation in the mail, those who request a hearing are ushered to a desk under drop ceilings and fluorescent lights, facing one of two administrative judges, who wear no robes. In one corner of the room, an office assistant mans a tape recorder and in some cases a projector, which is used to display photographs, or “exhibits,” during the hearing. The hearings are theoretically open to the public, but the arrival of a reporter who didn’t identify herself as such caused some consternation.

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