HomeMy WebLinkAboutAgenda Report - January 7, 2004 J-01AGENDA ITEM J-01
CITY OF LODI
COUNCIL COMMUNICATION
TM
AGENDA TITLE: Ordinance No. 1738 entitled, "An Ordinance of the City Council of the City of Lodi
Amending Title 8 — Health and Safety — Chapter 8.24, Comprehensive Municipal
Environmental Response and Liability, by Repealing and Reenacting Section
8.24.010 —'Definitions,' Subsection '2,' and 8.24.040 —'Liability,' Subsection 'F,' to
the Lodi Municipal Code Relating to Abatement Action Cost and Recovery Issues"
MEETING DATE:
PREPARED BY:
January 7, 2004
City Clerk
RECOMMENDED ACTION: Following reading by title, it would be appropriate for the City
Council to adopt the attached Ordinance No. 1738.
BACKGROUND INFORMATION: Ordinance No. 1738 entitled, "An Ordinance of the City Council of
the City of Lodi Amending Title 8 — Health and Safety — Chapter
8.24, Comprehensive Municipal Environmental Response and
Liability, by Repealing and Reenacting Section 8.24.010 —
`Definitions,' Subsection `2,' and 8.24.040 —'Liability,' Subsection 'F,' to the Lodi Municipal Code Relating
to Abatement Action Cost and Recovery Issues" was introduced at the regular City Council meeting of
December 17, 2003.
Pursuant to state statute, an ordinance may be adopted five days after its introduction following reading
by title.
This ordinance has been approved as to form by the City Attorney.
FUNDING
SJB/JMP
Attachment
None required.
APPROVED:
council/councom/Ord lnance2.doc
Susan J. Blacicston
City Clerk
ixon`Flynn, City Manager
AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF LODI AMENDING
TITLE 8. m- HEALTH AND SAFETY - CHAPTER 8.24, COMPREHENSIVE
MUNICIPAL ENVIRONMENTAL RESPONSE AND LIABILITY, BY REPEALING
AND REENACTING SECTION 8.24.010 — "DEFINITIONS," SUBSECTION "2," AND
5.24.040 m "LIABILITY," SUBSECTION "F," TO THE LODI MUNICIPAL CODE
RELATING TO ABATEMENT ACTION COST AND RECOVERY ISSUES
BE IT ORDAINED BY THE CITY COUNCIL OF THE CITY OF LODI AS FOLLOWS:
ECT'IQN 1. Section 5.24.010 61Definitions" Subsection "2" of the Lodi Municipal Code is
hereby repealed and reenacted to read as follows:
2. The terra "abatement action costs" means:
A. at or in connection with any site (or any separate subdivision or area within a site) at
which the city is not liable under 42 UJ S.C.§ 9607 for the costs of response to site conditions
resulting in whole or in part from the release or threatened release of hazardous substances to
which the city has responded or is responding under this chapter, any and all legal, technical, or
administrative fees and costs, and Interest and other casts of financing incurred by the city in
performing or preparing to perform an abatement action in compliance with the requirements of
this chapter. The term "abatement action costs" shall specifically include, but shall not be limited
to, any and all of the following costs incurred by the city:
I. to retain expert assistance in health, law, engineering, and environmental
science, expert witness services and legal fees and reasonable costs of litigation (including, but
not limited to, internal costs of the city attorney's office or outside legal counsel deemed
necessary at the sole discretion of the city to effectively respond to conditions at and emanating
from the site) to shady, investigate, abate, remove, remediate, or respondto an actual or
threatened environmental nuisance or any endangerment to the public health, welfare, or the
environment that may be presented by an actual or threatened environmental nuisance;
ii. to investigate or respond to the existence, or threat of an environmental
nuisance;
iii. to monitor, assess, or evaluate an environmental nuisance or any
endangerment to the public health, welfare, or the environment that may be presented by an
actual or threatened environmental nuisance;
iv. to prevent, minimize, or mitigate an environmental nuisance or any
endangerment to the public health, welfare, or the environment that may be presented by an
actual or threatened environmental nuisance;
V. to oversee and monitor the performance by any responsible party of any
investigation or abatement action in response to a condition which is or may be an
environmental nuisance;
A. to review, comment on, or revise a responsible party's plans and
proposals submitted pursuant to Section 5.24.050(E) or to oversee and monitor the
performance by any responsible party of any of the monitoring and testing activities which may
be required pursuant to Section 5.24,050(E);
vii. to prepare for or undertake necessary enforcement activity authorized by
this Chapter 0.24, including the recovery of abatement action costs incurred or to be incurred by
the city or any injunctive relief authorized by this chapter to respond to an environmental
nuisance, including enforcement activity deemed necessary by the city to obtain information and
site access authorized by this chapter; and
viii. costs of investigation and evaluation, as authorized by the city council, of
such financing, With recourse to the maximum e . xten.t avalla. ble solely against the present and
future assets. and r . ecoveries pledged to comprehensive municipal environmental response fund
or any sub -fund of the comprehensive municipal environmental response fund created by the
city council as authorized by Section 8.24.070(A), as may be necessary and proper to
accomplish the purposes set forth in this chapter; and
ix. costs of issuing, servicing, and retiring of any financing instruments
authorized by the city council as provided in Section 8.24.070, with recourse to the maximum
extent available solely against the present and future assets and recoveries pledged to the
comprehensive municipal environmental response fund or any sub -fund of the comprehensive
municipal environmental response fund created by the city council as authorized by Section
8.24.07.0(A); and
S. At or in connection with any site (or any separate subdivision or area within a site) to
which the city has responded or is responding under this chapter, and at which the city is liable
under 42 U.S-Ce§ 9607 for the costs of response to site conditions resulting in whole or in part
from the release or threatened release of hazardous substances, all such fees and costs
included within the definition set forth in subsection 2(a) of this Section 8.24.010, except that
such term shall not for purposes of this chapter include, at or in connection with any site (or any
separate subsection or area within a site) to which this subsection 2(b) applies, any attorneys
fees and costs, expert witness fees and costs or other litigation costs incurred or to be incurred
by the city in the preparation or conduct of any litigation to recover abatement action costs
pursuant to this chapter, or to secure judicial abatement of an environmental nuisance pursuant
to this chapter.
C. Notwithstanding the provisions of subparagraphs (a) and (b) of this subsection 2, the
term shall not include any costs incurred to compel compliance with an 'information demand
issued pursuant t o Section 8.24,050(B) of this chapter prior to the entry of a judicial order
upholding that information demand, in whole or in part.
SECTIOPL2. Section 8.24.040 - "Liability' Subsection T" of the Lodi Municipal Code is hereby
repealed and reenacted to read as follows:
F. Recovery of Attorneys Fees By Prevailing Party Pursuant to California Government Code
Section 38773-5.
1. Reasonable litigation expenses, including attorneys and expert witness fees and
costs, and litigation costs may. be recovered by the prevailing party in any action or
administirative proceeding brought or continued in whole or in part pursuant to this chapter by
the city attorney;
a. to recover abatement action costs incurred and to be incurred by the City
b. to secure or compel compliance with an Abatement Action Order issued
pursuant.to this chapter, to enforce an information demand, or an access, inspection or
monitoring order, following a judicial order upholding the demand or order in whole or in
part; or
C. to secure abatement of an actual or threatened endangerment to the
public health, welfare, or the environment arising out of, in whole or in part, an actual or
threatened environmental nuisance.
2. Notwithstanding Paragraph 1 of this Subsection F, the recovery of such fees and
costs, including attorneys' fees, by the prevailing party is strictly limited to those individual
actions or a proceeding in which the city elects, at the initiation of that individual action or
proceeding, to seek recovery of its own attorneys' fees.
SECTION 3e. All ordinances and parts of ordinances in conflict herewith are repealed insofar
as such conflict may exist.
SECTION 4.. No Mandatory Duty of Gane. This ordinance is not intended to and shall not be
construed or given effect in a mariner which imposes upon the City, or any officer or employee
thereof, a mandatory duty of care towards persons or property within the City or outside of the
City so as to provide a basis of civil liability for damages, except as otherwise imposed by law.
SECTION Severability. If any provision of this ordinance or the application thereof to any
person or circumstances is held invalid, such invalidity shall not affect other provisions or
applications of the ordinance which can be given effect without the invalid provision or
application. To this end, the provisions of this ordinance are severable. The City Council
hereby declares that it would have adopted this ordinance irrespective of the invalidity of any
particular portion thereof.
ECTION 60 Effect of On-going Actions. The effect of this Ordinance upon preceding or on-
going actions or proceedings shall be determined in accord with the fallowing provisions of this
section 6:
(A) Notwithstanding the repeal of Section =8.24.010(2) and Section 8.24.040(F) of
Title 8 of the Health and. Safety Code by operation of sections 1 and 2 of this Act, any action
taken pursuant to those Subsections shall remain in effect, and be subject to Chapter 8.24
(p rnmencing with Section 8. 4..010) of Title 8 of the Health and Safety Code, as including the
subsections reenacted by section 1 of this Act.
1
(B) The repeal and reenactment of Section 8.24.010(2) and Secti n 8.24.040(F) of
Title 8 of the Health and Safety Code by sections 1 and 2 of this Act shall no terminate, affect,
or modify any proceeding, carder, or agreement issued or entered into by the l ity, or any officer
or employee of the City pursuant to Chapter 8.24, or any rights or obligations arising out of or
pursuant to those provisions, and notwithstanding the effective date of this act, the provisions of
Chapter 8.24 (commencing with Section 8.24.010) of Title 8 of the Health and Safety Cade, as
including the subsections reenacted by sections 1 and 2 of this Act, shall apply retroactively to
those proceedings, carders, or agreements.
SE!�L'ION 7. This ordinance shall be published one time in the "Lodi News -Sentinel," a daily
newspaper of general circulation printed and published in the City of Lodi and shall take effect
thirty days from and after its passage and approval.
Approved this 71h day of January, 2004
State of California
County::... n Joaquin; ss.
1, Susan. J, Blackstcn, City Clerk of the City of Lodi; do hereby certify that Ordinance No.
1 738 was introduced at a regular meeting of the City Council of the City of Lodi held
Decernber 3 2003, and was thereafter passed, adopted and ordered to print at a regular
meeting of said Codicil held January 7, 2004, by the following Grote:
AYES: COUNCIL MEMBERS - Beckman, Howard, and Land
NOES; COUNCIL MEMBERS - Hitchcock and Mayor Hansen
ABSENT: COUNC1L.M MBERS - Nene
ABSTAIN COUNCIL MEMBERS - None
I further certify that Ordinance No. 1733 was approved and signed by the Mayor on the date of
its Passage and the same has been published pursuant to law,
SUSAN J. BLACKST®N
City Clerk
Jennifer Perrin
From: Ron Bernasconi [Ron@BernasconiCommercial.com]
Sent: Wednesday, January 07, 2004 4:45 PM
To: Susan Blackston; Susan Hitchcock; Emily Howard; Keith Land; John Beckman; Larry Hansen
Subject: We need independent legal advise before we make any changes to MERLO or our Contract with
Envision
Honorable City Council Members,
am very concerned by the actions recently taken in dosed session and would have appeared before
the Council tonight. However, I haveto run a practice tonight and therefore request that the City
Clerk file thefollowing as my public testimony at tonight's regular meeting of the Lodi City Council.
I n 1999 City Attorneys Michael Donovan and Randy Hays expressed no doubt that the city would
more than recover all expenses incurred when we relied upon their advise to borrow $16 million
dollars from Lehman Brothers at 20 to 300/6.
I n fact City Attorney Hays told the SOcramento Bee, "The way the laws are designed, we can't
lose'll
Then on December 24, 2003 the Sacramento Bee reported that A "Court ruling may put Lodi on the
spot for million' after Judge Damrell ruled that portions of the city's cleanup ordinance known as
MERLO conflicted with federal lav and was unconstitutional.
Asa result, Lodi cannot recover the $22.5 million it spent in legal fees or the $7.5 million in interest
financing Envision's ill-conceived legal strategy.
In his40 page ruling Damrell removed the portions of MERLO that were unconstitutional and
approved the remainder of the ordinance.
Now our City Attorneys are asking the Council to consider new additionsto MERLO, which would be
ill-advised without an independent legal review.
Frankly, 11th hour additions to MERLO on the eve of trial may further anger the Judge if they are
viewed as attempts to d rcumvent his regent rul i ng.
Another potential threat to our City emanates from the plan to renegotiate our contract with Envision.
Now, we would all love to have Envision slash its fees, but can we trust them not to slip in dauses
that elevates thei r i interests above those of the City?
We should be able to rely on our City Attorney. However, Randy Hays has proven to be nothing more
that a rubber stamp to anything Donovan presents and it would be foolish to believe that any member
of the City Council can negotiate contract language with an attorney(s) without independent counsel to
protect the City's interests. As the sayi ng goes, "Those who act as thei r own attorney have a fool
for a dient."
1/8/2004
Moreover, renegotiating our contract with Envision after the Court's recent rebuke of our legal
strategy not only makes the City look weak and stupid; it may undermine the City's ability to
proceed against Envision for malpractice, which maybe our only way out of this debacle.
Apparently, 4 Council members believe it would be too expensive to hire another outside attorney
because even though Envision'sfees Ere accruing at an alarming rate, Envision is collecting only
what they can squeeze out of our insurer, USF&G.
ronically, this is how it should have been from the start. H aving to be accountable to USF&G would
have stemmed the overbilling that occurred while Hayswasasleep at the SNitch as Envision burned
through the $16 million dollar Lehman Loan before they even got to trial.
Now after spending dose to $30 million dollars on a lawsuit that is basically being thrown out of
court on the eve of trial, it should be painfully apparent to everyone that there is nothing more
expensive than bad legal advise and that falling to secure independent legal counsel would beafalse
economy.
Why doesn't the City use the firm it has already retained to review Envision'sLegal Bills especially
since that expenditure has already paid for itself.
Clearly, we need independent legal counsel to deal with Hays and Envision. This what Redding did
when they suspected H ays of malfeasance.
Accordingly, I respectfully request that the City Cound1;
1) Secure independent legal counsel to review, the conduct of our City Attorney(s) and make sure any
contract with Envision requires Envision to maintain Lawyer's professional liability insurance to
protect the city from Envision's errors and omissions.
2) Secure independent legal counsel to review any changes to the City's Contract with Envision. I an
also making a public records request for the City's current contract with Envision and I am requesting
a copy of the proposed replacement contract with Envision at least 5 days prior to any vote by the City
Council to approve the replacement contract.
3) Table any changes to MERLO until you have secured independent legal counsel to review and
approve our Attorneysi proposed changes to ME RLO.
Thank you for your consideration,
Ron Bernasconi
Court ruling may put Lodi on the spot for millions
By Cameron Jahn -- Bee Staff Writer
Published 2.15 a.m. PST Wednesday, December 24, 2003
Two key Lodi city off idals reacted in shock Tuesday to afederal judge's ruling that they say guts the
dty's high-stakes toxic deanup lawsuit, leaving the taxpayers potentially Iiablefor millions of dollars in
legal costs.
1/8/2004
US District Judge Frank C. DamrelI Jr. on Monday ruled that the city'sdea up ordinanceconfIicts
with federal law and is unconstitutional.
DamrdI said the city's legal strategy --
winning
-
winning money f rom insurance carriers of
pol l uti ng busi nesses -- is set up to benef it
attorneys and investors rather than speed up
environmental cleanups as Congress
i ntended.
Asa result, Lodi cannot recover the
estimated $22.3 million it has spent in legal
expenses since 1996 or the more than $7.5
million in interest costs on f i nand ng those
Expenses.
The city has invested $6.3million of itsown
money in lawsuits agai nst several downtown
busi nesses and thei r i nsurers. The bal ance of
$16 million spent on legal outlayswas
borrowed at credit-card interest rates from
the investment banking firm Lehman Brothers of New York.
Lawyers for the city had pitched the loan as a no -risk way of financing a legal battle it otherwise could
not afford. They said Lehman would be repaid only from insurance money won in settlements or
j udgments.
Some city officials now believe Lehman is not going to walk avay from the loan and will try to recover
the money f rom the city.
Lodi, with apopulation of 59,000, has an annual budget of about $29 million.
"The way it appears to me, everything we've worked on for the last eight years has been thrown out,"
Councilwoman Susan Hitchcock said. "The people who are losing are the citizens of Lodi."
Lori Gualco, lead attorney for Guild Cleaners, one of the defendants, called thejudge'sruling "the
death knell -- it's ail over for the city, basically."
But Michael Donovan, the head of the city's legal team, disputed Damrell'sruling. He said Monday's
decision would not be a significant setback.
"I would say that the strategy is sound," Donovan said. "The trial judge has given us his opinion, and
it's far from the final judgment on the matter."
The 40 -page ruling was Darnrell's harshest yet in the city's 3 -year-old suit to compel dry cleaners and
other businesses to remove industrial solvents that tainted an estimated 600 acres in the central
business district.
1/8/2004
In his ruling this week, Damrell granted two insurance companies, Fireman's Fund and Unigard, a
permanent injunction preventing Lodi from enforcing adeanup ordinance the city enacted in 1997.
DamrelI agreed with an appellate court that said Lodi can't legislate its way out of liability in the
cleanup because the city also is partly responsible for the contamination: The city's leaky sewer system
may have allowed the pollutants to seep into the ground.
He also said the ordinance is the polar opposite of what Congress intended decades ago when it passed
the federal toxic cleanup act, known asthe,perfund law.
The laAt d lows for limited cost recovery in cleanups but not "an opportunity to profit at the expense of
the environment," Damrell said.
Lodi's ordi nance compels businesses found responsible for the pollution to paynot onlythecost of the
cleanup but also to reimburse the city for all itslegai and finandai costsin bringing enforcement action.
The city's "cost recovery scheme generates the opportunity for a fi nanciai wi ndfal I for some few
fortunate professionals, aswell as Lehman Brothers, Inc., an investment bank, which has no interest in
cleaning up the contaminated site," Damrell said.
Thejudgesaid Lodi'sattorneys "hate often produced unnecessarily voluminous or redundant filings
and imaginative ploys that havesent this litigation needlessly down paths." That means"important
remediation efforts have been brought to a grinding halt."
Lodi has a Jan. 12 trial date before Damrell, but some city off idais now wonder whether to risk trial.
"I is as if the judge said, 'We've given you enough dues along the way but you haven't followed them,
and wdretelling you onceand for all don't go this route because you'll bewasting your money,'"
Hitchcock said.
The Lodi City Council will meet in dosed session Dec. 30 to decidewhat to do.
Lodi Mayor Larry Hansen said thecity isnow in "limbo," suspiciousof its Expensive legal team and
their risky strategy yet entirely reliant on thosela yersfor advice.
"I try not to have knee-jerk reactions, but their credibility isdefinitely in question," he said. "I feel like
we're losing control of the strategy."
Lodi cannot fire Donovan without consent of the Lehman Brothers investors, who remain anonymous.
Meanwhile, thedty has launched an audit of Donovan'sbills, which total morethan $14 million.
Hitchcock on Tuesday said she had already heard from a number of Lodi residents outraged by the
city's legal quanday and looking to point fingers.
"This is reel ly a travesty of poor management and poor leadership," shesaid. "I definitelythink the
publicwill hold people accountable" at thebailot box.
1/8/2004