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AGENDA REPORT ACTION: 64'
CITY OF MOORPARK
TO: Honorable City Council
FROM: Mary R. Lindley, Assistant to the City Manager rI!
DATE: July 25, 1995 (CC Meeting of August 2)
SUBJECT: Consider Participation in the Joint Powers Agreement
Related to the Planning and Conservation League vs.
Ventura County Transportation Commission Lawsuit.
Background
On July 12, the City Council considered the draft Joint Powers
Agreement (JPA) and took action to defer participation until
additional information was known about the intent of PCL and the
potential ramifications for the City. The Council directed staff
to reagendize the JPA following the July 13 AVCC meeting.
The Association of Ventura County Cities (AVCC) held its meet on
July 13 to amend and approve a JPA between the ten cities in
response to a lawsuit filed against the Ventura County
Transportation Commission (VCTC) by the Planning and Conservation
League (PCL) . AVCC requested that the city councils of the ten
cities consider joining the JPA and allocating funds for their
proportion of the total legal costs ($25, 000) . Moorpark's share is
$1, 100.
Previous to the July 13 meeting, the Moorpark City Council
considered the draft JPA on July 12 and took action to defer
participation until more was known about the intent of PCL and the
potential ramifications for the City.
In summary, the complaint filed by PCL argues the following: 1)
VCTC abused its discretion when it determined that there were no
"unmet transit needs" in Ventura County which could be reasonably
met; and 2) therefore, VCTC inappropriately allocated local TDA
funds for streets and roads. PCL believes that there is an "unmet
need" for passenger rail service (Metrolink) to and from Ventura.
TDA regulations state that funds can be used for street and road
purposes only if there are no "unmet transit needs" . PCL is
seeking a temporary restraining order to prevent the County
Auditor-Controller from distributing all TDA funds until the
complaint is resolved.
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TDA Joint Powers Agreement
July 25, 1995
Page 2
If PCL prevails, the restraining order could withhold the cities'
TDA funds for transit and streets and roads purposes for an
undetermined amount of time. In FY 1995/96, the City of Moorpark's
total TDA allocation is approximately $550, 000. It is also
possible that a action could be taken that would release funds for
transit purposes only.
The purpose of the JPA is to provide legal counsel for the cities.
AVCC members agreed that it was in their best interest to jointly
retain legal counsel since the interests of the cities and VCTC are
not necessarily the same. While the cities have not been named as
co-defendants, they may wish, at some time in the future, to be
named as a "real party in interest" in order to protect their
interests. It is important to remember that approximately $14
million in TDA funds are at stake.
At its July 13 meeting, AVCC members made the following changes to
the Agreement:
1) Language was included that states that the Administrative
Committee may not exceed the initial $25, 000 deposit without
the consent of all the parties.
2) Parties may withdraw from the JPA unilaterally at such time
as an additional deposit is requested by the Administrative
Committee; i.e. , if approval is given to exceed $25, 000.
These amendments seemed to provide AVCC members with the assurance
they needed. Participants in the JPA know that their financial
commitment will not increase unless they agreed, and they can
terminate their participation if additional costs are later
approved.
In addition, on July 13 AVCC members selected the following
individuals to comprise the Administrative Committee as identified
in the JPA: Councilmember Roger Campbell (Fillmore) ; Arnold Dowdy,
City Manager (Santa Paula) ; and Mark Sellers, City Attorney
(Thousand Oaks) .
To date, the cities of Ojai, Santa Paula, Ventura, Fillmore, and
Camarillo have considered and approved the Agreement. The other
cities are expected to follow within the next two weeks.
Staff is recommending that the City Council approve the City's
participation in the JPA now rather than later to insure that its
interests are well represented. As stated previously in the staff
report, the City's $550, 000 in TDA funds are in jeopardy. In
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TDA Joint Powers Agreement
July 25, 1995
Page 3
addition, the selection of an attorney is currently underway and
the City should participate in that process. Lastly, in the event
that the other cities choose to be named as a "real party in
interest" , the City of Moorpark will want to insure that the
position they set forth represents its best interests.
In the event that one or more of the cities declines participation
in the JPA, the cost to each participating party will increase
slightly. Staff suggests that the City Council approve its
participation predicated on Moorpark's share of the costs being
$1, 100. If the cost increases, direct staff to return to Council
for approval.
Recommendation (Roll Call Vote)
Staff recommends that the City Council:
1. Approve Moorpark's participation in the Joint Powers
Agreement related to the Planning and Conservation League
vs. Ventura County Transportation Commission pending
confirmation that the City's cost will not exceed $1, 100;
2 . Direct the Mayor to sign the Agreement on behalf of the
City; and
3 . Approve the allocation of $1, 100 from the General Fund
Reserves for Moorpark's share of the Agreement's costs.
attachment
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JOINT EXERCISE OF POWERS
AGREEMENT BY AND AMONG THE
CITIES OF THE COUNTY OF VENTURA
THIS JOINT EXERCISE OF POWERS AGREEMENT (this "Agreement") is
entered into pursuant to Government Code Section 6500, et seq., by and among the
following public agencies:
(a) CITY OF CAMARILLO,CALIFORNIA,a general law city
(b) CITY OF FILLMORE, CALIFORNIA, a general law city,
(c) CITY OFMOORPARK,CALIFORNIA,a general law city,
(d) CITY OF OJAI, CALIFORNIA, a general law city,
(e) CITY OF OXNARD, CALIFORNIA, a general law city,
(f) CITY OF PORT HUENEME, CALIFORNIA, a general
law city,
(g) CITY OF SAN BUENAVENTURA, CALIFORNIA, a
charter city,
(h) CITY OF SANTA PAULA, CALIFORNIA, a general law
city,
(i) CITY OF SIMI VALLEY, CALIFORNIA, a general law
city, and
(j) CITY OF THOUSAND OAKS, CALIFORNIA, a general
law city
(hereinafter, individually, "Party" and, collectively, "Parties").
1. Recitals. This Agreement is made and entered into with respect to the fol-
lowing facts:
(a) Each Party is a public entity, duly organized and existing
under the Constitution and the laws of the State of California; and
ooUo.a
(b) Each Party is situated within the boundaries of the County
of Ventura, California (the "County"); and
(c) Each Party has the express power to sue and be sued in its
own name; and
(d) On June 5, 1995, the Planning and Conservation League and
Robert Cote ("PCL") filed a petition for writ of mandate and complaint
for injunctive relief against the Ventura County Transportation Commis-
sion (the "VCTC"), as respondent, and Thomas O. Mahon, Ventura
County Auditor-Controller, as real party in interest ("Mahon"), Ventura
County Superior Court Case No. CIV155605, seeking:
(i) A peremptory writ of mandate directing VCTC
to set aside and vacate its finding of no unmet transit needs
in Ventura County which may reasonably be met and the
resulting allocation of Transportation Development Act
("TDA") funds to the County and the cities in the County
for streets and roads purposes; and
(ii) During the pendency of the action,the issuance
of a temporary restraining order and preliminary injunction
or, in the alterative, after hearing, a permanent injunction,
restraining Mahon from releasing TDA funds to the County
and the cities in the County for street and road purposes
based upon VCTC's allocation; and
(iii) For costs of suit and attorney's fees pursuant to
Code of Civil Procedure §1021.5
(the "Litigation"); and
(e) PCL .has indicated that it intends to amend its petition to
name each of the Parties as an additional real party in interest; and
(f) The purpose of this Agreement is to provide a defense to the
Litigation in the event that the Parties are named defendants therein; and
(g) Although each Party has the right to provide its own defense
to the Litigation, litigation by all Parties would be duplicative and, in
some cases, prohibitively costly; and
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(h) The Parties desire by this Agreement to set forth the terms
and conditions under which a single defense to the Litigation shall be pro-
vided on behalf of all Parties, to provide for the management and direc-
tion of the Litigation, to provide for the allocation of expenses incurred
with respect to the Litigation and to set forth various other matters re-
lating to the defense of the Litigation; and
(i) The legislative body of each of the Parties has found and
determined that the public interest, convenience and necessity require the
execution of this Agreement.
2. Nature of Agreement. The Parties, by execution of this Agreement, do
not intend to create a separate agency or entity, within the meaning of Government
Code §6503.5, and no provision of this Agreement shall be construed to do so.
3. Administration of Agreement. The administration of the activities called
for in this Agreement is delegated to and vested in an Administrative Committee. The
Administrative Committee shall be comprised of:
(a) The mayor of one of the Parties who shall be selected and
shall serve at the pleasure of the Association of Ventura County Cities
(the "AVCC") who shall also serve as chairperson of the Committee; and
(b) The city manager of one of the Parties who shall be selected
by and shall serve at the pleasure of the AVCC (the "Manager"); and
(c) The city attorney of one of the Parties who shall be selected
by and shall serve at the pleasure of the AVCC.
4. Authorization of Administrative Committee. By execution of this Agree-
ment, each Party authorizes and directs that the Administrative Committee employ
legal counsel, diligently defend the Litigation on behalf of each of the Parties and co-
operate and coordinate such defense with VCTC and Mahon to the extent practicable.
Each Member of the Administrative Committee shall be, at all times, an officer
or employee of a Party to this Agreement. If any Member of the Administrative Com-
mittee ceases to be an officer or employee of a Party, or if the Member's agency ceases
to be a Party, a new Member shall be promptly selected in the same manner as the orig-
inal Member. The Administrative Committee shall keep all Parties informed of the
activities of the Administrative Committee.
The Administrative Committee is authorized and directed, on behalf of all Par-
ties, to perform all acts necessary or desirable to execute and administer this Agreement,
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including, but not limited to, selecting and retaining legal counsel; providing day-to-day
management and direction of the Litigation, including the right to determine all matters
of tactics and strategy on which legal counsel requests direction; reviewing all expendi-
tures; and conducting settlement negotiations, if any, provided that any proposed settle-
ment agreement shall require the unanimous consent of all agencies then party to this
Agreement.
S. Accounting. The Manager shall receive all funds paid by the Parties pur-
suant to this Agreement and shall provide an accounting of all such funds received and
expended pursuant to this Agreement. The Manager shall be responsible for the safe-
keeping of all such funds. The Administrative Committee shall review, periodically,
receipts and expenditures authorized by the Manager and report the results thereof to
the Parties.
6. Obligations of the Parties. Each Party shall pay, upon demand, its share
of all expenses incurred in the performance of activities hereunder in the amounts called
for by this Agreement. The "share" of each of the Parties shall be calculated as follows:
One Hundred Percent (100%) of all costs and expenses shall be apportioned among the
Parties and each Party shall pay the same percentage of such expenses which that
Party's population bears to the population of all Parties. For purposes of apportioning
all expenses incurred under this Agreement, the Parties agree that the following table
accurately reflects the Parties, the population of each Party and the percent of each
Party's population with respect to the population of all Parties:
January, 1995
Population
(State Dept. Percent of
of Finance) Total
Oxnard 154,558 24.6
Santa Paula 27,093 4.3
Thousand Oaks 112,600 17.9
Moorpark 27,544 4.4
Simi Valley 103,660 17.0
Port Hueneme 21,772 3.2
San Buenaventura 100,677 16.0
Fillmore 12,872 2.1
Ojai 8,154 1.3
Camarillo 58,472 9.0.
In the following events:
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(a) Any of the public agencies referred to in the preamble of this
Agreement determine not to become a party hereto and declines to
execute this Agreement; or
(b) Any Party withdraws from this Agreement in the manner set
forth in Section 8(a) of this Agreement,
the Manager shall recalculate the appropriate share of each Party based upon the figures
set forth above and shall notify each Party of the results of that recalculation.
7. Deposit for Fees. Upon execution of this Agreement, each Party shall pay
to the Manager the sum listed after the name of each Party, which sum represents each
Party's appropriate share of the initial deposit (the "Initial Deposit") for estimated legal
expenses:
City Amount
Oxnard $ 6,150.00
Santa Paula 1,075.00
Thousand Oaks 4,475.00
Moorpark 1,100.00
Simi Valley 4,250.00
Port Hueneme 800.00
San Buenaventura 4,000.00
Fillmore 525.00
Ojai 325.00
Camarillo 2,250.00.
All bills and invoices for expenses incurred pursuant to this Agreement shall be
directed to the Manager who shall review, audit and, if appropriate, pay the same;
provided, however, that the Initial Deposit shall not be exceeded without the consent
of all Parties hereto.
If the Administrative Committee determines that the Initial Deposit is insuf-
ficient to meet estimated or actual legal expenses, it shall seek the consent of all Parties
for such additional deposit or deposits (the "Additional Deposit" or "Additional Depos-
its") as it deems necessary to carry out the purposes of this Agreement. If the
Administrative Committee receives the consent of the Parties to assess an Additional
Deposit, it shall calculate the additional amounts due from each of the Parties under the
formula set forth in Section 6 above and bill each of the Parties accordingly. Bills of
the Parties shall be prepared for each calendar quarter in which activity occurs and shall
be payable immediately upon demand to the Manager.
00tO9S
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,
8. Termination of Agreement. This Agreement shall terminate:
(a) As to any Party, at such time as that Party determines not
to consent to an Additional Deposit, otherwise only upon the unanimous
consent of all Parties hereto;
(b) As to this Agreement, in its entirety:
(i) When the Litigation is finally resolved by the
final judgment of a court of competent jurisdiction or settle-
ment; or
(ii) When all Parties approve the termination of
this Agreement.
9. Disposition of Funds. Upon termination of this Agreement, the Manager
shall disburse all funds then remaining to each of the then Parties in amounts equal to
the percentage of participation by each of the Parties, as set forth in Section 6 of this
Agreement.
10. Amendment. This Agreement may be amended at any time upon the ap-
proval of all Parties. •
11. Notices. Notices pursuant to this Agreement shall be in writing and given
by personal service upon the Party to be notified or by depositing the same in the cus-
tody of the United States Postal Service, or its lawful successor, postage prepaid, ad-
dressed as set forth on Exhibit "A" attached hereto and incorporated herein by this
reference.
Notices shall be deemed given pursuant to this Section 11 upon the day of
personal service or two (2) consecutive calendar days following the deposit of the same
in the custody of the United States Postal Service.
12. Effective Date. The effective date of this Agreement shall be July 1, 1995.
13. Counterparts. This Agreement may be executed in counterparts which
shall be filed with the Manager.
14. Governing Law. The provisions of this Agreement shall be enforced and
interpreted in accordance with the laws of the State of California, except that no
interpretation of this Agreement shall be based upon the identity of the drafters of this
Agreement.
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•
This Agreement has been executed by authorized representatives of the Parties
as follows:
CITY OF CAMARILLO, CALIFORNIA
By
Michael D. Morgan, Mayor
APPROVED AS TO FORM:
J. Robert Flandrick, City Attorney
CITY OF FILLMORE, CALIFORNIA
By
Linda Brewster, Mayor
APPROVED AS TO FORM:
J. Roger Myers, City Attorney
CITY OF MOORPARK, CALIFORNIA
By
Paul W. Lawrason, Jr., Mayor
APPROVED AS TO FORM:
Cheryl J. Kane, City Attorney
CITY OF OJAI, CALIFORNIA
By
Nina V. Shelley, Mayor
APPROVED AS TO FORM:
Monte L. Widders, City Attorney
MOWS
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1 J. WILLITE
• , . S, 084343
i
926 i Stre- .„ - 612
2 Sacramento, • 95814
Telephone: (916)446-5475
3 Fax No: (916) 448-1789
4 Attorney for Petitioners
The Planning and Conservation League and
5 Robert Cote
6
7 SUPERIOR COURT OF THE STATE OF CALIFORNIA
8 COUNTY OF VENTURA
9
10
THE PLANNING AND CONSERVATION ) Case No. .
11 LEAGUE, and ROBERT COTE )
) MEMORANDUM OF POINTS
12 Petitioners/Plaintiffs ) AND AUTHORITIES LY
) SUPPORT OF PETITON FOR .
13 v. ) WRIT OF MANDATE AND
) COMPLAINT FOR INJUNCTIVE
14 ) RELIEF i
VENTURA COUNTY TRANSPORTATION ) i
15 COMMISSION and DOES 1 through 10 ) If,
)
16 Respondent/Defendant )
) '
17 ) Date:
) Time:
18 THOMAS 0. MAHON, VENTURA COUNTY ) Dept:
AUDITOR-CONTROLLER, )
19 )
Real Party in Interest )
20 )
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