HomeMy WebLinkAbout11/14/2006, PH 5 - PUBLIC HEARING FOR THE REVIEW AND RECONSIDERATION OF RELOCATION ASSISTANCE ELIGIBILITY FOR THE ROSE council �I a�
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5
CITY O'F SAN LUIS OBISPO
FROM: Jay Walter, Public Works Director
SUBJECT: PUBLIC HEARING FOR THE REVIEW AND RECONSIDERATION
OF RELOCATION ASSISTANCE ELIGIBILITY FOR THE ROSE
GARDEN INN
CAO RECODEIENDATION
1. That Council open and conduct a public hearing to review the City's initial determination.
that the owners of the Rose Garden Inn are not eligible to receive relocation assistance in
connection with the Calle Joaquin Relocation Project.
2. That the Council upon conclusion of public hearing and based on consideration of the
evidence presented makes the findings for the denial of the Rose Garden Inn's request.
DISCUSSION
Background
The request for relocation as by the Rose Garden Inn stems from a public project to
construct roadway and other improvements to the freeway interchange between 101 and Los
Osos Valley Road .(the Calle Joaquin Relocation Project). Modifications to the interchange
include the relocation of Calle Joaquin so that it wraps around the back of the Rose Garden Inn
before connecting to the existing Calle Joaquin in front of the Rose Garden Inn (Attachment 1).
In order to make these public improvements it was necessary to acquire a small, unoccupied
portion of the Rose Garden Inn's property from its property owners. This property could not
voluntarily be acquired from the owners. As a result, an eminent domain proceeding brought by
the City of San Luis Obispo is now on file in the San Luis Obispo County Superior Court:
Attachment 1 shows the unoccupied portion of the Rose Garden Inn's property to be acquired
and the general vicinity of the Calle Joaquin Realignment Project (the "Project") is shown on
Attachment 2.
California Law Regarding Relocation Benefits
California law allows persons or businesses displaced by a public project to recover what are
commonly known as relocation benefits. The payment of relocation benefits is an administrative
procedure completely separate from eminent domain proceedings. Relocation benefits are not
determined in an eminent domain proceeding. Rather, the City decides the amount of relocation
benefits and provides them to the displaced property owner ("displacee"). The displacee may
challenge that determination in court in a separate proceeding, but only after a City Council has
Relocation Assistance Public Hamtng�
Page 2
made a final decision on the subject. Generally, relocation benefits consist of moving expenses,
re-establishment expenses, and monetary assistance with higher rental payments at a new
location.
In California, relocation benefits are available only to persons who will be displaced by, or who
will move as a result of a public project, California Code of Regulations (CCR), Title 22,
Chapter 6, Section 6034(a). The Project only involves the acquisition of minor right of way and
slope easement interests located on the unoccupied southern and northwestern portions of the
subject property. This acquisition does not result in any displacement from the existing motel.
As a result, it is staff's and outside Legal Counsel's opinion that the Rose Garden Inn should not
be afforded displacee status or be considered eligible for relocation assistance.
Necessary Findings are Not Met
In order to find that the Rose Garden Inn is eligible to receive relocation assistance, the City
Council must find and determine that the Rose Garden Inn will be forced to physically move or
be displaced from the property. As mentioned above, only an unoccupied portion of the Rose
Garden Inn's property has been taken in connection with the Project. The motel buildings will
not be impacted by the Project.
Further Analysis of the Inn's Claim for Relocation Benefits
The Rose Garden Inn's representatives have attempted to rely upon the California Department of
Transportation's (CalTrans) Right of Way Manual ("Manual") to support their claim for
relocation benefits (June 16, 2006 request for relocation letter- Attachment 3). They believe that
the provisions for eligibility provided under the Manual are more favorable to their claim for
relocation benefits than the California Code of Regulations. However, the Manual is only
applicable to CalTrans projects in which federal funds are being used. The Project at issue here
is not a CalTrans project, and no federal funds are involved. In any case, the Manual's definition
of an eligible "displaced person" is similar to the California Code Regulations definition
mentioned above. In particular, the Manual defines a "displaced person" as someone who moves
from real property as the direct result of the acquisition of property for a public project.
CalTrans Right of Way Manual, section 10.01.03.01. All of the citations mentioned in the June
16, 2006 letter are from the inapplicable CalTrans Right of Way Manual. Attachment 4 is the
City's September 1, 2006, response (prepared by outside Legal Counsel)to the Rose Garden Inn,
denying eligibility for relocation benefits.
The Rose Garden Inn contends that as a result of the Project, the Inn's buildings will have to be
reconfigured so that its entrance is located on the opposite side of the property from where it is
now. Among other things, the Rose Garden Inn wants compensation for moving its reception
building to the other side of the property, and reconfiguring its motel units at the rear of the
property so that they face the relocated Calle Joaquin Road. The Rose Garden Inn is making an
identical claim for these construction costs in the pending eminent domain matter, and that claim
will ultimately be decided by a jury. However, the Staff believes that.this claim is not within the
purview of relocation benefits because the Rose Garden Inn is not a"displaced person."
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Relocation Assistance Public I eanng�
Page 3
In summary, the Rose Garden Inn does not have eligibility for relocation benefits because:
1. The Rose Garden Inn has not been required to move from its property as a result of the
Proj ect;
2. The Rose Garden Inn does not meet the definition of a "displaced person" under the
California Code of Regulations;
3. The Rose Garden Inn's claims for reconstruction of the motel buildings to face the
relocated Calle Joaquin Road will be decided in the pending eminent domain proceeding.
Recommended Process for the Public Hearing
It is recommended, and the Rose Garden Inn property owners and their legal counsel have been
so advised, that Council's Public Hearing on this topic be conducted as follows: The Rose
Garden Inn's representatives should be permitted to make a 20-minute presentation supporting
its position regarding relocation assistance, the City staff should be provided a 10-minute period
to detail its recommendation regarding relocation assistance, and the Rose Garden Inn should
have a final five minute period in which to rebut the City staffs recommendations. It is further
recommended that strict adherence to these guidelines be enforced.
Following the hearing, if Council finds, based on its consideration of any documentary
evidence, testimony, comments, and oral case argument that may be presented, and all other
evidence and records pertaining to this matter, that the evidence warrants the necessary findings
to support the City's position that the Rose Garden Inn is not entitled to receive relocation
assistance, then staff recommends that the City Council, in the exercise of its discretion, and
taking vote on this matter, deny the Inn's request for relocation assistance reconsideration. The
Council may take action following the hearing or provide direction to staff in order that a
resolution can be brought back for Council adoption at a future meeting.
FISCAL IMPACT
Denial of the relocation benefits may result in displacees seeking redress in court, resulting in
potential unknown costs to the City. Allowing for award of relocation benefits will result in the
City determining the amount of such benefit based on moving expenses, re-establishment
expenses, and increased rental expenses. If the displacees later object to that amount, they may
proceed to Court, again resulting in potential unknown costs to the City.
All documentary evidence which the Rose Garden Inn intends the City Council to review has been
previously submitted. Petitioners were notified by letter on October 30, 2006, that all materials to be
considered had to be submitted no later than November 9, 2006. Materials timely submitted will be
copied and distributed to Council prior to this hearing.
Relocation Assistance Public .mg '
Page 4
ALTERNATIVE
Further Stag'Review. Direct staff to review displacees' claim for relocation benefits and return
to Council with a recommendation on an appropriate amount of relocation expenses to be
provided to displacees. This alternative is not recommended because staff does not believe that
displacees have a valid claim for benefits.
ATTACHMENTS
1. Vicinity Map
2. Overview Photograph
3. June 16, 2006 Request Letter from William S. Walter
4. September 1, 2006 Response Letter
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- _ATTACHMENT
LAW OFFICES
WILLIAM S. WALTER
A PROFESSIONAL CORPORATON
TELEPHONE 1605) 541-6601 THE BELLO MOUSE EMAIL
FACSIMILE (805) 541-6640 679 MONTEREY STREET WWALTERQTCSN.NET
SAN LUIS OBISPO. CALIFORNIA 93401
June 16,2006
VIA FACSIMILE
AND U.S.MAIL
Anthony W.Bagnette,Esq.
Price Postal&Parma,LLP
200 East Carrillo Stieet,Fourth Floor
Santa Barbara, CA 931010
Jonathan P.Lowell
City Attorney
City of San Luis Obispo
990 Palm Street
San Luis Obispo,CA 93401
RE: Relocation Assistance Eligibility for Rose Garden Inn
Gentlemen:
Our preliminary review of the above referenced matter indicates the availability of
relocation assistance in partial take situations, while we acknowledge that such assistance may
not be duplicative of just compensation awarded through condemnation.
Section 10.05.01.00 provides that, "Relocation can be to the remaining portion of the
property if a partial acquisition has occurred. (See 10.05.13.01: Reestablishment payments for
moves to the remainder.)" "Reestablishment payments can be paid to a business that must
reconfigure or make modifications to the remainder in order to accommodate the displaced
portion of the business."
This assistance includes the following categories:
Sec. 10.05.05.01 Transportation of Personal Property-,
Sec. 10.05.05.02 Disconnecting/Dismantling;
Sec. 10.05.05.03 Utility and Service Lines;
Sec. 10.05.05.04 Telephone Equipment;
Sec. 10.05.05.05 Modifications to Personal Property;
.Sec. 10.05.05.07 Storage of Personal Property;
Sec. 10.05.05.08 Move and Storage Insurance;
Sec. 10.05.05.10 Licenses, Permits,Fees and Certification;
Sec. 10.05.05.11 Professional Services;
C` ATTACHMENT 3
Price Postel&Parma,LLP
City Attorney, City of San Luis Obispo
June 16,2006
Page 2
Sec. 10.05.05.12 Re-lettering and Reprinting;
Sec. 10.05.10.01 Loss of Tangible Personal Property;
Sec. 10.05.10.02 Purchase of Substitute Personal Property;
Sec. 10.05.10.03 Cost to Sell Property;
Sec. 10.05.11.00 Misc. Expenses;
Sec. 10.05.14.00 Reestablishment Expenses;
See. 10.05.14.02 One time Advertisement of Replacement Location;
Sec. 10.05.14.03 Exterior Signing;
Sec. 10.05.15.00 Non-Occupant Owner Reestablishment expenses;
-See. 10.05.22.00 Compensation for Loss of Goodwill.
Please provide this office at your earliest opportunity with copies of the applicable
relocation assistance regulations for this project,in light of whether it is receiving federal or state
funding. In addition, please provide us with information regarding the claims and eligibility
determination process, including any administrative appeals and a description of such appellate
bodies, forms and documentation requirements,and other applicable information.
We would appreciate your prompt attention to this matter so that we can avoid, as we are
sure the City will appreciate, any potential duplication with the claims to be asserted in the
pending condemnation proceedings.
Very truly yours,
William S. Walter
cc: Wayne Hanson
Western Inns
Steven Mugglebee,Esq.
0656
PRICE, POSTEL & PARMA LL ATTACHMENT
ARTHUR R. GAUDI COUNSELLORS AT LAW
JAMES H. HURLEY,JR.
J.TERRY SCHWARTZ 200 EAST CARRILLO STREET, SUITE 400
DAVID W.VAN HORNE SANTA BARBARA, CALIFORNIA DANIEL C. DAVID
PETER D. SLAUGHTER SUSAN M. BASHAM
DOUGLAS 0. ROSSI 93101-2190
ERIC.P. HVOLBOLL
CRAIG A. PARTON
CLYDE E.WULLBRAN DT
RETIRED PARTNERS
KENNETH J. PONTIFEX MAILING ADDRESS P. O. BOX 99 JOHN KERR WILSON
CHRISTOPHER E. HASKELL SANTA BARBARA, CA 93102-0099 TERRY JOHN CONNERY
TIMOTHY E. METZINGER DAVID K..HUGHES
TODD A.AMSPOKER
PENNY CLEMMONS
MARK S. MANION TELEPHONE (805) 962-0011
MELISSA J. FASSETT OUR FILE NUMBER
IAN M. FISHER FACSIMILE (805) 965-3978
ANTHONY W. BAGNETTE
SMOHARRAM
AM ZODEH 18931.8 (Calle Joaquin)
SAM ZODNIFER K. HANRAHAN
KRISTIN M. R. SLABEY
LESLEY E. CUNNINGHAM
September 1, 2006
VIA U.S. MAIL
William S. Walter
Walter&Bornholdt
679 Monterey St.
San Luis Obispo, CA 93401
Re: City of San Luis Obispo v. Hanson, et al.
San Luis Obispo County Superior Court No. CV050169
Dear Mr. Walter:
The City of San Luis Obispo ("City") has reviewed your letter of June 16, 2006 and does
not believe your clients are eligible for relocation assistance as a result of the Calle Joaquin
Relocation Project ("subject project").
The citations you submitted in support of your claim that relocation assistance is
warranted in the subject case are not applicable to the subject project. Although you did not
identify them as such, Sections 10.05.05.01-05, 10.05.05.07, 10.05.05.08, 10.05.05.10,
10.05.05.11, 10.05.05.12 , 10.05.10.01-03, 10.05.11.00, 10.05.14.00, 10.05.14.02, 10.05.14.03,
10.05.15.00, and 10.05.22.00 are all apparently from Chapter 10 of the California Department of
Transportation (CalTrans) manual. However, the subject project, as defined in the City's
Resolution No. 9635 (2004 Series) approved December 7, 2004, is a municipal project to realign
Calle Joaquin, not a CalTrans project.
The City utilizes 25 CCR Chapter 6 to determine an applicant's eligibility to receive
relocation assistance. Unlike the protections you allege are afforded you pursuant to CalTrans
Manual Section 10.05.01.00', 25 CCR § 6034 requires that a party physically move or be
displaced from the property before that party is considered a displacee and is considered for
relocation benefits. (25 CCR § 6008(f) defines displaced persons as "Any person who moves
from real property, or who moves his personal property from real property...")The subject
project involves the condemnation of minor right of way and slope easement interests located on
the unoccupied southern and northwestern portions of the subject property. This take does not
' It should be noted, it appears-after a cursory review of CalTrans Manual Section 10.01.03.01,that your
claim for relocation would most probably not be supported even if the.subject project were a CalTrans project.
Additionally,Section 10.05.13.01 cited in the parenthetical in paragraph 2 of your letter details what a displacee
(assuming such status is granted) is not entitled to payment for and does not support any claim for relocation
benefits.
ATTACHMENT 14
William S. Walter
September 1,2006
Page.2
result in any displacement from the existing motel. As a result,your clients are not afforded
displacee status nor are they eligible for relocation assistance.
Pursuant to your request, a copy of 25 CCR Chapter 6 is forwarded.
Finally, you may pursue an administrative appeal pursuant to 25 CCR §§ 6156 and 6158
in the form of either an informal oral presentation or seek a formal review and reconsideration by
the City Council. Such request for an administrative appeal should be submitted through:
The City Attorney's Office
c/o Jonathan Lowell
City of San Luis Obispo
990 Palm Street
San Luis Obispo, CA 93401
This request must comply with 25 CCR Chapter 6 and be submitted pursuant to the time
requirements of 25 CCR §§'6156(d) and 6158(d)(1) and(2).
Very truly yours,
Anthony W. Bagnette
for PRICE,POSTEL&PARMA LLP
cc. Jonathan Lowell
Timothy Bochum
0658
s�tu�o
`J RECEIVED
_ N'U'V 1 a 2006
SLO CITY CLERK
aV�CEN'SE�
MEMORANDUM
From the Office of the City Attorney
November 14, 2006
To: Mayor and City Council
Via: Ken Hampian, City Administrative Officer
From: Jay Walter, Public Works Director
Subject: Postponement of Public Hearing for Review and Reconsideration of Relocation
Assistance Eligibility for the Rose Garden Inn (Item PH 5)
Legal counsel for the owners of the Rose Garden Inn has requested that the hearing be
postponed. The City Attorney's office and our outside condemnation counsel will work with the
requestors' lawyers to schedule a new hearing date and clarify the procedures applicable to the
hearing. The rescheduled public hearing will be renoticed, so there is no need for the Council to
continue the November 14 hearing. It is recommended the Council direct staff to reschedule this
public hearing in the future on a date to be determined.
RDC AiG.
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LAW OFFICES
WILLIAM S. WALTER
A PROFESSIONAL CORPORATION
TELEPHONE (SOS) S41-6601 THE BELLO HOUSE EMAIL
FACSIMILE (6051 541-6640 679 MONTEREY STREET WWALTEROTCSN.NET
SAN LUIS OBISPO, CALIFORNIA 93401
November 14, 2006
VIA FACSIMILE
AND U.S. MAIL
Todd Amspoker, Esq.
Anthony W. Bagnette, Esq.
Price Postai &Parma, LLP
200 East Carrillo Street, Fourth Floor
Santa Barbara, CA 931010
Jonathan P. Lowell
City Attorney
City of San Luis Obispo
990 Palm Street
San Luis Obispo, CA 93401
Clerk, City of San Luis Obispo (Personal Delivery)
990 Palm Street
San Luis Obispo, CA 93401
RE: Relocation Assistance Eligibility for Rose Garden Inn
Dear Sirs:
This will confirm the conversation Marsha Forrest of my office had with Lauren Beers of
Mr. Amspoker's office this afternoon in which Lauren told Marsha the public hearing for the
review and recossideTanon of r:,locatior, assistance eligibility for the Rose Garden inn has been
taken off calendar and will not go forward. Therefore, I will not attend the City Council Meeting
tonight, November 14, 2006.
Very truly
yours,
William S. alter
cc: Wayne Hanson
Stephen T. Mugglebee, Esq.