HomeMy WebLinkAbout06-17-2014 C6 Agreement and General Release with Madonna PropertiesCity of San Luis Obispo, Council Agenda Report, Meeting Date, Item Number
FROM: Carrie Mattingly, Utilities Director
Prepared By: David Hix, Deputy Director – Wastewater
SUBJECT: AGREEMENT AND GENERAL RELEASE WITH MADONNA PROPERTIES
RECOMMENDATION
Approve an agreement and general release with Madonna Properties in the amount of
$509,337.80 providing for the decommissioning of the City’s Madonna Sewer Lift Station,
relieving the City of all future operations and maintenance obligations related to the station, and
waiving potential claims against the City related to the location and operation of the station.
DISCUSSION
Background
In 1961 the City required the Madonna Inn (Inn) to install a sewer lift station to serve the Inn and
some adjacent parcels. After the lift station was completed the City accepted ownership
including operations and maintenance responsibilities. Several years later a gravity sewer, which
serves the adjacent parcels to the Inn, was installed on Madonna Road, leaving the Inn the only
parcel served by the lift station. The lift station has been continuously operated and maintained
by the City, on the Madonna property ever since.
The Madonna lift station is now at the end of its useful life and will require replacement. The
City only operates lift stations that benefit larger areas, served by multiple parcels connected by
public sewer mains. Because the lift station only serves the Inn, it has been a goal to relinquish
ownership and responsibility of this facility back to the Inn in order to avoid replacement and
operational costs and liabilities.
City staff met with representatives of the Inn at a recent site visit to discuss replacement of the
lift station. During this conversation it was determined by both the City and the Inn that no
documentation regarding ownership, access or service agreements, or easements existed. This
leaves the City in the vulnerable position of having no formal agreements or easements for
critical infrastructure it has assumed as an asset and operated continuously on private property.
Staff met with Council in closed session on March 4, 2014, for direction on how to best proceed
with the situation. During the site visit, the Inn had expressed its interest in having control of the
lift station and input into the design of the new facility. It was agreed that both the City and the
Inn would work cooperatively on an agreement satisfactory to both parties in order to avoid
replacement, operational and potential litigation costs.
The Agreement
Attached is a general release and settlement agreement that allows the City and the Inn to pursue
replacement of the lift station. The agreement constitutes a waiver of all existing or potential
legal claims between the parties relating to the location or operation of the lift station, establishes
June 17, 2014
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Agreement with Madonna Properties Page 2
a timeline and process that obligates the City decommission the existing lift station and obligates
the Property owner to construct a new, privately owned and maintained facility to City standards.
to settle all claims with the Inn after completion of a new facility while the City maintains and
operates the existing Madonna lift station during construction. The agreement indemnifies the
City during the construction of the new facility and releases the City of claims if, for some
reason, the new facility is not satisfactorily completed within the specified time frame and the
City is required to operate the existing station longer than anticipated. Once the new facility is
completed and operational, the City will decommission the old lift station.
This agreement is the result of a collaborative effort that allows both parties to pursue their goals
without resort to formal legal action. It also resolves the lack of documentation of ownership,
easements, access and egress issues and any related City liability subsequent liability.
FISCAL IMPACT
The agreement and general release will cost $509,337.80 in 2014-15. Replacement of the
Madonna lift station was identified in the 2013-15 Capital Improvement Plan, pages 3-152 – 156
for 2015-16 at a cost of $1,000,000. The Margarita Lift station project, which was budgeted for
in 2014-15, will not be ready for construction until 2015-16. Therefore, the $900,000 budgeted
for 2014-15 will be used to fund this agreement. Revisions to the 2014-15 CIP are reflected in
the 2013-15 Financial Plan Supplement.
ALTERNATIVES
1. Direct staff to replace the Madonna Lift Station then transfer ownership to the Inn. This
alternative would take an additional year, require access and egress agreements and
require negotiations and an agreement to transfer ownership.
2. Direct staff to replace the Madonna Lift Station and retain ownership and maintenance.
This alternative would take an additional year, require easement/access agreements and
require negotiations for a facility that only serves the Inn with no benefit to adjacent
properties. This option would also obligate the City to ongoing maintenance and
operations costs and associated liabilities.
ATTACHMENT
1. Agreement and General Release
t:\council agenda reports\2014\2014-06-17\agreement with madonna enterprises (mattingly-hix)\car-madonna council agenda report.docx
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Attachment 1
1
AGREEMENT AND GENERAL RELEASE
This Agreement and General Release (“Agreement”) is made and entered into in San
Luis Obispo County, California on ___________, 2014 by and between the City of San Luis
Obispo, a municipal corporation (collectively with its successors and assigns, “City”), and
Madonna Properties, LLC (collectively with their predecessors, successors and assigns,
“Customer”). City and Customer are hereinafter sometimes referred to individually as a “Party”
and collectively as the “Parties.” The “Lift Station” means the City sewer lift station and force
main located at 100 Madonna Road, San Luis Obispo, California 93405 (Assessor’s Parcel
Number 004-511-021) (“Subject Property”).
RECITALS:
A. In 1961, City required Customer to install the Lift Station to provide sewer service to
both the Subject Property and several adjacent properties (“Adjacent Properties”) which the
City subsequently accepted as a City asset, but without proper written documentation of an
access easement to the Lift Station.
B. Since the City’s acceptance of the Lift Station, the City has owned and operated the Lift
Station.
C. In 1965, the City approved the installation of a gravity sewer to service the properties
adjacent to the Subject Property, which eliminated any need for the Adjacent Properties to utilize
the Lift Station.
D. The Lift Station is now at the end of its useful life and requires replacement.
E. The City desires to relinquish ownership and responsibility of the Lift Station because it
only serves the Subject Property and there are no plans for it to serve any other properties.
F. Customer desires to have control and flexibility over the design of any new sewer
conveyance system or facility that serves the Subject Property.
G. The City and Customer desire to avoid costly litigation and to work together to achieve
an equitable solution and improved situation for both parties.
H. This Agreement is not binding upon either party upon and until the formal
approval of the terms and conditions of the herein Agreement by the City Council of the
City of San Luis Obispo (“Formal Approval”). The effective date of this Agreement
(“Effective Date”) shall be the date Formal Approval is obtained.
NOW, THEREFORE, in consideration of the premises and the mutual promises made
in this Agreement, and in consideration of the recitals, representations, warranties and covenants
herein contained, the Parties agree as follows:
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AGREEMENT
1. City Obligations:
a. Within thirty days of the Completion Date (defined in Paragraph 2.a), and subject to
Paragraph 2.b., City shall pay to Customer the total sum of $509,337.80 (Five
Hundred Nine Thousand, Three Hundred Thirty Seven Dollars and Eighty Cents),
(“Settlement Amount”), which amount is in settlement of all claims for
compensation by Customer that were asserted or could have been asserted by
Customer, including, but not limited to claims for just compensation, improvements
pertaining to the realty, temporary construction easements, land acquisition,
accommodations for business disruption both temporary and permanent, fixtures and
equipment, relocation assistance, relocation benefits, loss of goodwill,
precondemnation damages, interest, litigation expenses including attorneys’ fees,
appraisal fees, statutory costs, and for damages of every other kind and nature
suffered or to be suffered by Customer.
b. Within one year of the Completion Date (defined in Paragraph 2.a) or the Delayed
Completion Date (defined in Paragraph 2.b.), whichever is later, City shall abandon
and decommission the Lift Station. Upon written notification from the Utilities
Director that the Lift Station has been decommissioned and abandoned, the Lift
Station shall no longer be considered a City asset, and Customer may modify or
remove any or all remaining parts of the Lift Station as the property owner in
accordance with otherwise applicable laws, regulations, permits and/or approvals.
2. Customer Obligations:
a. Within 240 days of the Effective Date of this Agreement (“Anticipated Complete
Construction Date”), Customer shall have completed construction of a new sewer
conveyance system and any necessary related accessories to serve the Subject
Property (“New Facility”). “Complete construction” as used herein shall be defined
as Customer demonstrating to the approval of the City Utilities Director that the new
sewer conveyance system is a fully operational, code compliant sewer conveyance
system connected to the public sewer system. Customer acknowledges that nothing
in this Agreement shall be construed as the City approving the new sewer conveyance
system in its regulatory capacity and Customer shall be required to obtain any and all
legally required certificates, permits and/or other approvals from either City and/or
any other regulatory agency that may have jurisdiction over the new lift station and/or
its operation and/or maintenance. In the discretion of the City Utilities Director, the
parties may extend the Anticipated Complete Construction Date but only in writing
signed by both Customer and the Utilities Director.
b. The City, at is sole expense, shall continue to operate and maintain the Lift Station
until the Anticipated Complete Construction Date (including any extensions thereof).
If Customer fails to complete construction of the New Facility by the Anticipated
Complete Construction Date (including any extensions thereof), then the City shall
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continue to operate and maintain the Lift Station until the actual date Customer
completes construction of the New Facility (“Delayed Complete Construction
Date”). Customer shall reimburse the City for any and all actual and reasonable
costs related to or arising from the operation and/or maintenance of the Lift Station
after the Anticipated Complete Construction Date (including any extensions thereof)
and until the Delayed Complete Construction Date. City may deduct said costs from
the Settlement Amount specified in Paragraph 1.a.
c. Customer hereby grants permission to the City, its employees and agents reasonable
access to the Subject Property for the purposes of operating, maintaining,
decommissioning and/or abandoning the Lift Station.
d. Indemnification by Customer:
i. Except as expressly set forth herein, on and after the Anticipated
Completion Date (including any extensions thereof), Customer agrees to
indemnify, defend (with counsel selected by City but reasonably
satisfactory to Customer) and hold harmless City and City’s officers,
agents, employees, attorneys, successors and assigns from and against any
and all liabilities, losses, causes of action, claims, damages, costs, liens,
fines, penalties, and expenses (including reasonable attorneys’, experts’,
and consultants’ fees and expenses) arising out of or relating to the
operation, maintenance, and replacement of the Lift Station, including but
not limited to, any liability of City not specifically assumed by City
(including without limitation, any of: noncompliance with any
environmental laws or regulations; product liability claims; or liability
arising out of injury (including personal or bodily injury) to, or death of,
any person or damage to any property resulting from any error, omission,
negligence, or willful misconduct of Customer or Customer’s agents,
subcontractors or employees; any claim by any of Customer’s employees,
consultants or customers, disputes or proceedings or litigation or claims of
any type or nature associated with the Lift Station. Notwithstanding any
provision herein to the contrary, Customer shall not be obligated
hereunder to indemnify, defend and hold harmless City and City’s
officers, agents, employees, attorneys, successors and assigns for any and
all liabilities, losses, causes of action, claims damages, costs, liens, fines,
penalties, and expenses arising out of or related to any: (a) alleged acts of
fraud, gross negligence, negligence or professional malpractice by the
City, its officers, agents, employees, attorneys successors and assigns and
(b) the physical acts of the City, its officers, agents, employees, attorneys,
successors and assigns related to the decommission of the Lift Station.
ii. Other Indemnification Provisions: The foregoing indemnification
provisions are in addition to, and not in derogation of, any statutory,
equitable, or common law remedy either party may have against the other
for breach of any representation, warranty or covenant in this Agreement.
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3. Construction of Agreement: This Agreement is the result of arm’s length negotiations,
both Parties had an opportunity and participated in drafting this Agreement, and any ambiguity
of this Agreement shall not be interpreted against either Party to this Agreement.
4. Limited Release:
a. Except for the rights and obligations set forth in this Agreement, Customer for
themselves, their agents, assigns and related entities, fully releases, acquits and
discharges City, and the officers, directors, employees, attorneys, accountants, other
professionals, insurers and agents of City (collectively “Agents”) and all entities related
to City, from all rights, claims, demands, actions or causes of action which Customer
now have or may have against City arising from the acquisition of portions of the Lift
Station and the City’s acceptance of the Lift Station without proper documentation of an
access easement, including but not limited to, claims for just compensation,
improvements pertaining to the realty, temporary construction easements, land
acquisition, accommodations for business disruption, both temporary and permanent,
fixtures and equipment, relocation assistance, relocation benefits, loss of goodwill,
precondemnation damages, interest, litigation expenses including attorneys’ fees,
appraisal fees, statutory costs, and for damages of every other kind and nature suffered
or to be suffered by Customer.
b. This limited release is intended as a full and complete release and discharge of any and
all such claims that Customer may or might have against City and its related entities
arising from the acquisition of portions of the Lift Station and the City’s acceptance of
the Lift Station without proper documentation of an access easement. No other claims
that Customer may or might have against the city and its related entities and Agents are
hereby released. In making this limited release, Customer intends to release City, its
related entities and Agents from any liability of any nature whatsoever for any such
claim or injury or for damages or equitable or declaratory relief of any kind arising out
from the acquisition of portion of the Lift Station existing as of the Effective Date of this
Agreement, whether the claim arising from the acquisition of portions of the Lift
Station, or any facts on which such claim might be based, is known or unknown to the
Party possessing such claim as of the Effective Date. Solely for the purpose of the
limited release set forth in this Paragraph 4, Customer expressly understands and agrees
to waive all rights under Section 1542 of the Civil Code of the State of California, which
Customer understands provides as follows:
A general release does not extend to claims which
the creditor does not know or suspect to exist in his
favor at the time of executing the release, which if
known by him must have materially affected his
settlement with the debtor.
c. Customer acknowledges that it may hereafter discover facts or law different from or in
addition to those which it now believes to be true with respect to the release of such
claims arising from the acquisition of the Lift Station. Customer agrees that the
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foregoing limited release shall be and remain effective in all respects notwithstanding
such different or additional facts or law or any party’s discovery thereof. Customer shall
not be entitled to any relief in connection therewith, including, but not limited to any
damages or any right or claim to set aside or rescind this Agreement.
5. No Reliance: No Party nor any agents nor any related entities have made any statement
or representation to any other Party regarding any fact relied upon in entering into this
Agreement, and each Party expressly states it does not rely upon any statement, representation or
promise of any other Party or any Party’s agent or related entities in executing this Agreement,
except as is expressly stated in this Agreement. Each Party to this Agreement has made such
investigation of the facts and law pertaining to this Agreement, and of all other matters
pertaining thereto, as it deems necessary.
6. Termination: This Agreement may be terminated at any time prior to the payment of the
Settlement Amount by mutual written consent of the Parties. In the event of termination of this
Agreement by City or Customer as provided in this paragraph, this Agreement shall forthwith
become void and there shall be no liability or obligation on the part of any party, except to the
extent that such termination results from a breach by a party hereto of any of its representations,
warranties, covenants or agreements set forth in this Agreement.
7. Miscellaneous:
a. Advice of Counsel
Each Party has had the opportunity to receive independent legal advice with respect to the
advisability of making this Agreement and with respect to the meaning of California Civil Code
Section 1542. Each Party hereto, by its due execution of this Agreement, represents to every
other Party that it has reviewed each term of this Agreement with its counsel and that hereafter
no Party shall deny the validity of this Agreement on the ground that the Party did not have the
opportunity to receive the advice of counsel.
b. Further Documents and Assurances
Each Party agrees to execute such other or further documents or instruments or take or
cause to be taken such other or further action as may reasonably be necessary or appropriate in
order to more fully and completely effectuate the transactions contemplated by this Agreement
or to carry out its intent.
c. Entire Agreement
This Agreement constitutes the entire agreement between the Parties and supersedes any
prior understandings, agreements, or representations by or between the Parties, written or oral, to
the extent they relate in any way to the subject matter hereof or thereof.
d. Succession and Assignment
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This Agreement shall be binding upon and inure to the benefit of the Parties and their
respective successors and permitted assigns. Customer may not assign either this Agreement or
any of its rights, interests, or obligations hereunder without the prior written approval of City.
e. Expenses
City shall pay all of City’s own costs and expenses in connection with the negotiation,
execution and delivery of this Agreement and any related agreements or instruments. Customer
shall bear all its own costs and expenses in connection with the negotiation, execution and
delivery of this Agreement and any related agreements or instruments.
f. Counterparts
This Agreement may be executed in one or more counterparts, each of which shall be
deemed an original but all of which together will constitute one and the same instrument.
g. Headings
The section headings contained in this Agreement are inserted for convenience only and
shall not affect in any way the meaning or interpretation of this Agreement.
h. Notices
All notices, requests, demands, claims, and other communications hereunder will be in
writing. Any notice, request, demand, claim, or other communication hereunder shall be deemed
duly given if it is sent by registered or certified mail, return receipt requested, postage prepaid,
and addressed to the intended recipient as set forth below:
If to City:
City of San Luis Obispo
990 Palm Street
San Luis Obispo, CA 93401
Attn: Utilities Director
Tel: (805) 781-7140
Fax: (805) 781-7109
With a copy to:
J. Christine Dietrick, City Attorney
City of San Luis Obispo
990 Palm Street
San Luis Obispo, CA 93401
If to Customer:
Madonna Properties, LLC
284 Higuera Street
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San Luis Obispo, California
Telephone: (805) 543-0300
Fax: (805)
Attention: Clint Pearce
With a copy to:
Adamski Moroski Madden Cumberland & Green LLP
P.O. Box 3835
San Luis Obispo, California 93403
Telephone: (805) 543-0990
Fax: (805) 543-0980
Attention: Steven J. Adamski
Either Party may send any notice, request, demand, claim, or other communication
hereunder to the intended recipient at the address set forth above using any other means
(including personal delivery, expedited courier, messenger service, facsimile, telex, ordinary
mail, or electronic mail), but no such notice, request, demand, claim, or other communication
shall be deemed to have been duly given unless and until it actually is received by the intended
recipient. Either Party may change the address to which notices, requests, demands, claims, or
other communications hereunder are to be delivered by giving the other Party notice in the
manner herein set forth.
i. Governing Law
This Agreement is entered into under and shall be governed by and construed in
accordance with the laws of the State of California without giving effect to any choice or conflict
of law provision or rule (whether of the State of California or any other jurisdiction) that would
cause the application of the laws of any jurisdiction other than the State of California.
j. Amendments
No amendment of any provision of this Agreement shall be valid unless the same shall be
in writing and signed by City and Customer.
k. Waivers
Failure of either Party at any time to require the performance by the other Party of any
provision of this Agreement or any related agreement shall in no way affect the right to require
full performance of such provision thereafter. Furthermore, the waiver by either Party of a
breach of any provision of this Agreement or any related agreement will not be held to be a
waiver of any other provision of this Agreement or any related agreement.
l. Severability
The invalidity or unenforceability of any term or provision of this Agreement or any
related agreement shall not affect the validity or enforceability of the remaining terms and
provisions thereof.
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m. Specific Performance
Each Party acknowledges and agrees that the other Party would be damaged irreparably
in the event any of the provisions of this Agreement are not performed in accordance with their
specific terms or otherwise are breached. Accordingly, each Party agrees that the other Party
shall be entitled to an injunction or injunctions to prevent breaches and to secure specific
performance, in addition to any other remedy to which it may be entitled, at law or in equity.
n. Force Majeure
Neither Party shall be liable for failure to perform its obligations under this Agreement
when such failure is due to any cause beyond the reasonable control of the Party unable to
perform, excluding economic or financial reasons.
o. Independent Contractor
Pursuant to this Agreement and otherwise, each Party shall act as an independent
contractor and not as an agent of the other Party, and neither Party shall represent itself as an
agent of the other Party. No act done by either Party will be deemed to create a partnership or
joint venture with the other Party, nor will the provisions of this Agreement or the related
agreements be construed as creating a partnership or joint venture.
p. No Third Party Beneficiaries
This Agreement shall not confer any rights or remedies upon any Person other than the
Parties and their respective successors and permitted assigns.
IN WITNESS WHEREOF, the parties hereto have caused this Agreement to be duly
executed and made and entered into as of the date first set forth above.
___________________________________
CARRIE MATTINGLY
City Utilities Director
____________________________________
CLINT PEARCE on behalf of Madonna
Properties, LLC
APPROVED AS TO FORM:
___________________________________
J. CHRISTINE DIETRICK
City Attorney
APPROVED AS TO FORM:
___________________________________
STEVEN J. ADAMSKI
Attorney for Madonna Properties, LLC
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