Defendant failed to preserve this argument by raising it below. See Lane v. Town of Grafton, 166 Vt. 148, 153 (1997) ("Failure to raise a reason why summary judgment should not be granted at the trial level precludes raising it on appeal."). Even if we reached the argument, we would conclude that defendant's argument is contradicted by the applicable statute.

The complaint is a bare bones statement that merely provides the defendant with notice of the claims against it. See Lane v. Town of Grafton, 166 Vt. 148, 150-52, 689 A.2d 455, 456-57 (1997). Its purpose is to initiate the cause of action, not prove the merits of the plaintiff's case.

Our goal in interpreting a statute is to discern and implement the intent of the Legislature. See Lane v. Town of Grafton, 166 Vt. 148, 151, 689 A.2d 455, 456 (1997). We consider the purpose of the statute and look to "the broad subject matter of the law, its effects and consequences, and the reason and spirit of the law."

While petitioner asserts otherwise in his brief, he fails to show where he raised this argument below either in support of his own motion for summary judgment or in opposition to the State's motion for summary judgment. See V.R.A.P. 28(a)(4), (b) (explaining that argument on appeal must contain citations to the "parts of the record on which the appellant relie[d]"); Lane v. Town of Grafton, 166 Vt. 148, 153, 689 A.2d 455 (1997) ("Failure to raise a reason why summary judgment should not be granted at the trial level precludes raising it on appeal."). ¶ 23.

, the summary judgment decision against him will stand as the arguments he raised in this appeal were not raised below. See Bull v. Pinkham Eng'g Assocs., 170 Vt. 450, 459 (2000) ("Contentions not raised or fairly presented to the trial court are not preserved for appeal."); see also Lane v. Town of Grafton, 166 Vt. 148, 153 (1997) ("Failure to raise a reason why summary judgment should not be granted at the trial level precludes raising it on appeal."). To the extent plaintiff Morris argues that the court erred in granting summary judgment to the State based on the 1812 survey and the other evidence generated during its survey, we find that argument without merit.

On the other hand, the insurer asks us to dismiss the homeowners’ appeal because their claims are not preserved. See, e.g., Dallman v. Isaacs, 911 A.2d 700, 704-05 (R.I. 2006) (concluding that the plaintiffs, who failed to file a timely objection to the summary judgment motion, waived their appellate arguments challenging the grant of that motion); Lane v. Town of Grafton, 166 Vt. 148, 689 A.2d 455, 457 (1997) ("Failure to raise a reason why summary judgment should not be granted at the trial level precludes raising it on appeal."). We are not inclined to waive preservation.

Plaintiff failed to pursue these arguments below and we do not address them for the first time on appeal. See Lane v. Town of Grafton, 166 Vt. 148, 153 (1997) ("Failure to raise a reason why summary judgment should not be granted at the trial level precludes raising it on appeal."); see also In re White, 172 Vt. 335, 343 (2001) ("We have repeatedly stressed that we will not address arguments not properly preserved for appeal" and "[t]o properly preserve an issue for appeal a party must present the issue with specificity and clarity in a manner which gives the trial court a fair opportunity to rule on it." (quotation omitted)).

"Failure to raise a reason why summary judgment should not be granted at the trial precludes raising it on appeal." Lane v. Town of Grafton, 166 Vt. 148, 153, 689 A.2d 455, 457 (1997). In short, Vallee has not presented any basis for us to disturb the Environmental Division's decision to grant VTrans a stormwater permit for the proposed project.

The plaintiffs did not pursue their argument that the 1992 amendment was not validly voted on and approved. Cf. Lane v. Town of Grafton, 166 Vt. 148, 153 (1997) ("Failure to raise a reason why summary judgment should not be granted at the trial level precludes raising it on appeal."). The trial court granted summary judgment to the plaintiffs.

Petitioner waived this argument by failing to raise it below. See Lane v. Town of Grafton, 166 Vt. 148, 153, 689 A.2d 455, 457 (1997) ("Failure to raise a reason why summary judgment should not be granted at the trial level precludes raising it on appeal."). ¶ 9.