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Resolution No. 8924 . 1 2 3 RESOLUTION NO. 8924 A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF VERNON AUTHORIZING THE FILING OF LAWSUITS CHALLENGING THE NPDES BASIN PLAN/TRIENNIAL REVIEW AND AUTHORIZING THE CITY TO DO ALL ACTIONS DEEMED NECESSARY OR ADVISABLE CONCERNING THE LAWSUITS 4 5 6 7 WHEREAS, on December 13, 2001, the California Regional Water 8 9 10 11 12 13 Quality Control Board, Los Angeles Region ("Regional Board") adopted Order No. 01-182, a National Pollutant Discharge Elimination System ("NPDES") Permit for Municipal Storm Water and Urban Runoff Discharges within the County of Los Angeles and the incorporated cities therein, except the City of Long Beach (hereinafter "NPDES Permit"); and 14 WHEREAS, for the past four years the member cities of the Coalition for Practical Regulation ("CPR") have been requesting that the Regional Board prepare an adequate economic analysis of the 15 16 impacts of the NPDES Permits and the Trash Total Maximum Daily Load 17 ("TMDL") programs, but the Regional Board and the State Water Resources Control Board ("State Board") have adopted Trash TMDL programs and Metal TMDL programs that will cost the cities billions of 18 19 20 21 22 23 24 dollars to comply with; and WHEREAS, the CPR Cities, together with Los Angeles County and the County Sanitation Districts, funded a'complete review of the Basin Plan's administrative record in 2003, which disclosed glaring problems with the Basin Plan, which is the "general plan" for water 25 26 standards that dates from 1974, and the inadequacies of the Basin Plan are amplified in each of the TMDLs; and 27 WHEREAS, the CPR Cities desire to challenge the Basin Plan/Triennial Review to compel the Regional Board to complete the 28 1 legally required comprehensive economic analysis of the urban runoff 2 requirements, review and change specific water quality standards of 3 concern to the cities and compel the Regional Board to complete the 4 legally required implementation program and updates to the Basin Plan; 5 and 6 WHEREAS, the proposed litigation would assist in th~ 7 development of Basin Plan standards (beneficial uses and water quality 8 standards) that are sensible and cost-effective; and 9 WHEREAS, the proposed litigation is estimated to be in two 10 phases, the first phase would determine if the cities had legal 11 standing to bring the challenge to the Basin Plan and the second phase 12 would be challenges to the lack of disclosure of the economic impacts 13 on the cities, standards challenges and the lack of legally required 14 updates to the Basin Plan; and 15 WHEREAS, the estimated cost of $75,000.00 for the first 16 phase and $325,000.00 to $525,000.00 for the second phase will be 17 shared among the cities joining in the litigation; and 18 WHEREAS, the estimated cost to the City of Vernon for the 19 2005-06 fiscal year is $3,000.00 if 25 cities join into the first 20 phase of the litigation; and 21 WHEREAS, the estimated cost per year to the City of Vernon 22 for fiscal years 2007 to 2008 is $10,000.00; and 23 WHEREAS, the City believes such litigation to challenge the 24 Basin Plan/Triennial Review is appropriate to rectify the improper 25 actions and policies of the Regional and/or State Board. 26 / / / 27 / / / 28 / / / - 2 - 1 NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE 2 CITY OF VERNON AS FOLLOWS: 3 SECTION 1: The City Council of the City of Vernon hereby 4 finds and determines that the recitals contained hereinabove are true 5 and correct. 6 SECTION 2: The City Council of the City of Vernon hereby 7 approves and authorizes participating with other Cities and agencies 8 in the filing of a lawsuit challenging the Basin Plan/Triennial 9 Review. 10 SECTION 3: The City Council of the City of Vernon hereby 11 authorizes the retention of Richard Montevideo, Esq., of the law 12 offices of Rutan & Tucker, in coordination with other Los Angeles 13 County Cities, to file the appropriate lawsuit to further advise, 14 assist and represent the City in all matters concerning the lawsuit. 15 SECTION 4: The City Council of the City of Vernon hereby 16 authorizes the payment for its share of the litigation costs 17 associated with the filing of the lawsuit pursuant to the terms of its 18 retainer agreement with Rutan & Tucker. 19 20 21 22 23 24 25 SECTION 5: The City Council of the City of Vernon hereby directs the Acting City Clerk, or his designee, to send a copy of this resolution to: Richard Montevideo, Esq. Rutan & Tucker, LLP P.O. Box 1950 Costa Mesa, CA 92628-1950 SECTION 6: The City Council of the City of Vernon hereby 26 authorizes the Acting City Clerk, or his designee, to execute any 27 documents necessary to implement and carry out the purposes of the 28 lawsuit. - 3 - 1 SECTION 7: The Acting City Clerk of the City of Vernon 2 shall certify to the passage of this resolution, and thereupon and 3 thereafter the same shall be in full force and effect. 4 APPROVED AND ADOPTED this 7th day of December, 2005. 5 6 ~ . , ~/ . /. p~ .J:.,EON~t~, Mayor 7 ATTEST: 8 9 10 BRUCE V. MALKENHORST, JR. Acting City Clerk 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 - 4 - / 1 STATE OF CALIFORNIA 2 3 ss COUNTY OF LOS ANGELES 4 I, BRUCE V. MALKENHORST, JR., Acting City Clerk of the City of 5 6 Vernon, do hereby certify that the foregoing Resolution, being 7 Resolution No. 8924, was duly adopted by the City Council of the City of Vernon at a regular meeting of the City Council duly held on Wednesday, December 7, 2005, and thereafter was duly signed by the Mayor of the City of Vernon. 8 9 10 11 12 13 14 15 16 BRUCE V. MALKENHORST, JR. Acting City Clerk (SEAL) 17 18 19 20 21 22 23 24 25 26 27 28 - 5 - SUPPORTING DOCUMENTS 1r 7~ c:J),/,2 s- ?~.;2 ~ . RUTAN & TUCKERj .IIOI{NlYS AI LAW 611 ANTON BOULEVARD. FOURTEENTH FLOOR COSTA MESA. CALIFORNIA 92626-1931 DIRECT ALL MAIL TO: POST OFFICE BOX 1950 COSTA MESA. CALIFORNIA 92628-1950 TELEPHONE 714-641-5100 FACSIMILE 714-546-9035 INTERNET ADDRESS www.rulan.com ORANGE COUNTY SILICON VALLEY (408) 289-8777 A PARTNERSHIP INCLUDING PROFESSIONAL CORPORATIONS r Richard Montevideo Direct Dial: (714) 662-4642 E-mail: rmonlevideo@rutan.com February 7, 2006 RECeiVED FE3 1.5 2006 Community Servfces City of Vernon 4305 Santa Fe Avenue Vernon, CA 90058 Attn: Woody Natsuhara Re: Triennial Review/Basin Plan Challenge Dear City Representative: Through the informal ad hoc coalition known as the Coalition for Practical Regulation, we have been asked to represent a number of cities in Los Angeles County to challenge certain actions taken by the Los Angeles Regional Water Quality Control Board ("Regional Board"), the State Water Resources Control Board ("State Board") and/or the United States Environmental Protection Agency ("USEP A"), in connection with various urban and storm water runoff orders, regulations and requirements. Most recently, we have been asked to prosecute a challenge to the recently completed 2004 Triennial Review of the Water Quality Control Plan for the Los Angeles Region ("Basin Plan") by the Regional Board, as well as to prosecute a challenge to the Basin Plan itself. One of the main challenges to the 2004 Triennial Review and Basin Plan is the perceived failure of both the State and Regional Boards to comply with State and/or federal law when adopting and subsequently amending the Basin Plan, and when conducting a Triennial Review, e.g., not developing water quality standards and objectives that are reasonably and economically achievable, as they relate to storm water and urban runoff. With this retainer letter, the City of Vernon ("City"), a municipal corporation, is confirming its retention of the law firm of Rutan & Tucker to represent the City to prosecute the Triennial Review/Basin Plan Challenge, and to represent it in all such other related matters as the City has or may request, pursuant to Rutan & Tucker's representation of the ad hoc coalition of Cities known as the Coalition for Practical Regulation. The Building Industry Legal Defense Foundation ("BILD") has also agreed to join in as a Plaintiff/Petitioner in the Triennial Review/Basin Plan Challenge. This retainer letter therefore sets forth the terms upon which the City has retained Rutan & Tucker, and also provides its consent and appropriate conflict waivers for any potential conflicts that may be created by Rutan & Tucker's joint representation of the Cities and other agencies entities and associations in connection therewith, and/or in its representation of other clients on unrelated matters. 227065121 .0012 (,X2624.0 I ,,02:07.06 RUTA~ & TUCKER, City of Vernon February 7, 2006 Page 2 Our fees are generally based on the hourly design rates set by the firm, subject to periodic review and change, for the various attorneys involved in handling the matter. The rates vary depending upon the level of seniority, expertise and experience of the individuals involved. Starting in 2005, my hourly design rate was set at $375 per hour; however, because we are, in part, representing existing public entity clients, our hourly rate for purposes ofthis matter will be a composite rate of $225 per hour for all attorney time. This rate of $225 per hour, however, may be adjusted upward, as approved by the City of Signal Hill. Further, whenever possible, legal interns, law clerks, legal assistants and other professionals with a lower billing rate will be utilized, consistent with the proper representation of the interests of our clients in connection with this matter and without sacrificing proficiency. In addition to fees, our clients are also billed for all necessary costs incurred in connection with the representation, such as document copying costs, clerk and reporter's transcript fees and costs, service fees, telecopying fees, long distance telephone costs, mileage, computer assisted research, filing fees, expert and consultant fees and costs, administrative record fees, and other related litigation costs and out-of-pocket expenses. We render our statements on a monthly basis and they are payable within 30 days from the date of the invoice. The invoices will describe the work performed during the billing period and the identity of the individuals providing services, as well as a break down of billed costs. It is customary in matters of this nature that we receive a retainer as an advance against fees and costs prior to commencing work on the matter. However, given this office's prior representations of Cities who were a part of the Coalition for Practical Regulation in connection with this and other storm water and urban runoff matters, and given our existing relationship with your city, no retainer amount is being requested. Yet, the City of Signal Hill, on behalf of the Coalition for Practical Regulation, may be requesting a retainer amount for legal and other expenses to be incurred in this regard. Each City shall be responsible for its pro rata portion of the fees and costs, i.e., each City is responsible for paying its share of the invoices of the total billings, on a pro rata basis, based on the number of Cities identified as clients of this firm in connection with such matters at the time of the invoice, with each City paying an equal amount. If the City determines to drop out of the proceeding in issue, the City shall be responsible for the costs and fees incurred up to the time it withdraws from the proceedings, including the costs and fees to effectuate the withdrawal. Monthly invoices showing the costs and fees incurred will be sent to the City of Signal Hill, and any portion of the retainer amount remaining, upon the conclusion of this matter, if any, will be returned to the City within 30 days thereafter, by Signal Hill. The City of Signal Hill has agreed to be responsible for administering all financiallbilling matters. BILD and certain cities have agreed to join in the Triennial Review/Basin Plan litigation, initially, only through the demurrer/pleading stage (referred to as "Phase I" of the lawsuit), i.e., up to the time in which an answer is filed on behalf of the State and Regional Boards, with BILD and some cities in this group desiring to limit their financial contribution in this Phase 1 of the 227/065 J 21-0072 682624.01 .02/07/06 . . RUTAN & TUCKER, City of Vernon February 7, 2006 Page 3 litigation to a specific dollar amount. All such limitations on a city's involvement, as communicated to either this office or the City of Signal Hill, are hereby acknowledged and agreed to. For BILD and such cities that have determined to join in the Triennial Review/Basin Plan lawsuit tentatively through Phase 1, said entities will be notified once an answer to the complaint has been submitted on behalf of the State and Regional Boards, through a status report of the proceedings at that time, with BILD and such cities hereby agreeing that they will notify Rutan & Tucker if they wish to discontinue their involvement in the litigation at that time, and thus be dismissed from the lawsuit. Unless Rutan & Tucker receives a written request from such entity to be dismissed from the lawsuit, Rutan & Tucker will continue to prosecute the Triennial Review/Basin Plan lawsuit on behalf of such city and/or BILD, through the conclusion of any trial or further proceedings. As you know, Rutan & Tucker is currently acting as legal counsel to a number of cities and school districts in Orange, Los Angeles and Riverside counties, as well as a large number of private clients, some of which are presently adverse to some cities we are representing in the Triennial Review/Basin Plan lawsuit. However, Rutan & Tucker's representations of such public and private entities in the other matters, are unrelated to its representation of the cities in this matter. Rutan & Tucker therefore reserves the right to continue to represent such parties in these other unrelated matters, and any other parties in the future, which may be adverse to the City, but which are unrelated to our representation of the cities and BILD in connection with the subject proceedings. Your signature below will confirm this understanding and will confirm your waiver, on behalf of the City, of any such actual or potential conflicts of interest. In. representing the cities and BILD in these proceedings, it is our belief that the interests of all such parties, both financially and legally, will be consistent and that we will be able to proceed with a common strategy. Yet, there is always a potential for a conflict of interest to arise after additional facts involving the proceedings become known and/or as a result of a divergence in interest in the future because of positions that have or may be taken by any respondent or defendant. One of the purposes of this retainer agreement is to provide full disclosure of the scope of our representation and to minimize any such potential conflicts. California Rule of Professional Conduct section 3-310 provides in part that: Rule 3-310. Interests. A voiding The Representation Of Adverse * * * (C) A member shall not, without the informed written consent of each client: :>27065121..0012 I1X:>624.0 1 a02,07()6 . ~ RUTAN & TUCKER- City of Vernon February 7, 2006 Page 4 (1) Accept representation of more than one client in a matter in which the interests of the clients potentially conflict; or (2) Accept or continue representation of more than one client in a matter in which the interests of the clients actually conflict; or (3) Represent a client in a matter and at the same time in a separate matter accept as a client a person or entity whose interest in the first matter is adverse to the client in the first matter. (D) A member who represents two or more clients shall not enter into an aggregate settlement of the claims of or against the clients without the informed written consent of each client. In accordance with Rule 3-310, please be advised that there is a potential for the interests of the Cities and entities and agencies associated with the Cities in these proceedings (e.g. BILD), to become adverse in the future. As an example, a potential conflict could arise if one or more of the Cities wishes to proceed with a strategy in the Triennial Review/Basin Plan lawsuit, or with some other storm water matter, that is beyond what other Cities this office represents believe are reasonable or appropriate under the circumstances. Although at this time there is no indication that such a conflict exists, and the interests of the Cities and other entities this office represents are not in anyway presently adverse, such a potential for adverse interests exists, and could cause a different settlement or prosecution strategy in pursing the Triennial Review/Basin Plan lawsuit. If a conflict does occur, the City agrees that Rutan & Tucker may continue with its representation of the City of Signal Hill and those Cities and entities that are taking positions consistent with the City of Signal Hill, and may withdraw from its representation of the conflicted city, with the conflicted city then being permitted to substitute in new counsel, if it so desires. Your signature and acceptance of this retainer agreement below will constitute the City's approval of this provision on conflicts of interest, and will also permit Rutan & Tucker to continue to represent other private and public clients who are or may be adverse to the City presently and in the future, both in litigation and in non-litigation matters, but unrelated to the instant proceedings, as well as to continue to represent the other cities and entities in connection with the matters referenced herein. Of course, in the event an unwaivable conflict occurs, and we can no longer continue to represent the City's interests, any amounts remaining in the retainer collected by Signal Hill that are owed to the City in accordance with the above-referenced formula, would be returned to the City, along with copies of all research requested and other legal analysis prepared in the course of our representation of your interests in connection with these proceedings. 2n065121-0072 682624.0 I 302/07/06 . RUTAN & TUCKER, City ofYemon February 7, 2006 Page 5 Please recognize that although there is a potential for adverse interests in the future on the Triennial Review/Basin Plan lawsuit, we believe at this time that collective action on the part of each of the respective cities and BILD is to their mutual advantage. It is our beliefthat there is a strong common interest among each of the parties involved in the subject proceedings, which permits and allows for a coordinated strategy in pursuing these matters. In addition, to the extent any consultants and/or expert witnesses will be necessary to pursue these matters, at this time, we believe that a coordinated strategy among experts and consultants will be cost effective. In accordance with the requirements of California Business and Professions Code section 6148, I wanted to advise you that Rutan & Tucker maintains errors and omissions insurance coverage applicable to the services to be rendered as contemplated by this Agreement. We appreciate the opportunity to serve as your attorneys and anticipate a productive and harmonious relationship. If, however, you become concerned for any reason with the services we have or are performing, or the fees that have been assessed to the City, we encourage you to bring this matter to our attention immediately. If we perceive a problem with the representation, we will similarly bring it to your attention. Most such problems should be rectified by communication and discussion. If you wish Rutan & Tucker to represent the City in connection with this matter, we are requesting that you provide informed written consent by signing and returning this letter to us as soon as possible. We encourage you to seek independent counsel if you so desire regarding the importance of this consent, and we emphasize that you remain completely free to speak to independent counsel at any time, even if you decide to sign this Retainer Agreement and provide the consent requested herein. I would appreciate it if you would execute and return this letter, indicating the City's agreement with the above and authorizing us to act accordingly. If you have any questions or comments with respect to any of the matters set forth in this letter, please do not hesitate to call me. I look forward to working with you and the City and to a successful representation of your interests. Thank you again for considering Rutan & Tucker. Sincerely, RUTAN & TUCKER, LLP It (lJ;}n::J:::...~ Richard Montevideo RM:kmh Enclosure ]:>7 065121-0072 682624.0 I a02/07/06 R[JTA~ & TUCKER, City ofVemon February 7, 2006 Page 6 I have read and understood the contents of this letter and consent to Rutan & Tucker, LLP representing the City in accordance with the terms set forth above. Dated: c:211~(o6 CITY OF VER~ ~~ By: Mayor or City Manager 221.0651210072 682624.0 I a02'(J7I06 .. . 99,2r I J V A)~\ (~vDi I ~ ~ 1./30", COMMUNITY SERVICES & WATER DEPARTMENT OFFICE MEMORANDUM ('\ ~ / TO: ~ FROM: Bruce V. Malkenhorst, Jr., Acting City Clerk Samuel Kevin Wilson$irector of Community Services & Water DATE: November 17, 2005 SUBJECT: National Pollutant Discharge Elimination System (NPDES) - Water Quality Control Plan for the Los Angeles Region 4 (Basin Plan) - Triennial Review - Potential Litigation by Cities in the Los Angeles Basin The members of the Coalition for Practical Regulation (CPR) have attempted to work with the Los Angeles Regional Water Quality Control Board (Board) to establish reasonable requirements for the each of Total Maximum Daily Load (TMDL) programs. However, the Board has chosen to deny the requests to include an economic analysis and a scientific basis for each of the programs. The Trash TMDL with the "zero" trash requirement and the recent passage of the Metals TMDL with limits clearly show that cities cannot influence the TMDL programs at the Board level. An example of the lack of reasonable science in the establishment of the TMDL's is the limit set for copper in storm water which will be 100 times less than the maximum contaminant level in drinking water (see enclosure). More than 90 TMDL programs will be established in the future and the costs of these programs will be in the billions or dollant~ cost of the Metals TMDL alone is estimated to be 2.4 billion dollars. When the cities point out the scientific flaws, we are told that the cities can fund expensive scientific studies to correct the TMDLs. The current "TMDL by TMDL" strategy requires an inordinate amount of resources to review and prepare the record for potential legal challenges. What the cities have come to recognize is that the inadequacies of the Basin Plan are amplified in each of the TMDLs. The Basin Plan is the general plan that establishes the water standards for the region and was originally adopted in 1974. At that time, it established "beneficial uses" for the rivers and flood control channels - such as recreational swimming in the flood control channels and water quality objectives - such as "zero" trash. The cities were not involved in reviewing the Basin Plan in 1974, since the plan contained a policy statement that the standards were not to be applied to the municipal nmoff: 'Wo specifIC non point source control facilities are proposed under the Recommended (Basin) Plan. It is impractical to attempt to treat runoff generally... " The Coalition for Practical Regulation (CPR), Los Angeles County and the County Sanitation Districts funded a complete review of the Basin Plan's administrative record in 2003. This review disclosed glaring problems with the Basin Plan and has determined that the inadequacies of the Basin Plan are the "root" of the problems. The original water quality standards were developed to regulate industrial pollution and the sewer treatment plants. The cities are in the position that the standards are now being applied to storm water without the legally required economic analysis and without the Regional Board developing a detailed implementation program. The CPR cities believe that the Regional Board has an affirmative responsibility to prepare a comprehensive review of local government costs. Decision makers and the public deserve to know the long-term costs of the cities having to fund the TMDLs and NPDES programs. These costs will be required as cities consider Proposition 218 taxes and fees to fund the new requirements. The cities face a whole series of TMDLs over the next six years, including several Metals TMDLs and Bacteria TMDLs for both the Los Angeles and San Gabriel Rivers. The current strategy of requesting the Regional Board to improve the TMDLs by stressing the scientific and economic flaws with each TMDL, is not working. Both the Regional and State Boards are reacting to the time constraints in the TMDL Consent Decree. Instead of sound science driving the TMDLs, an unrealistic time schedule (that was effectively hidden from the cities in 1999) is controlling the process. It is unfortunate that the State's budget crisis has resulted in the Regional Board not having the resources to complete the Basin Plan updates required by State law every three years. The Triennial Review process has turned into a "wish list" of amendments and changes to the Basin Plan, which somehow never gets properly funded or completed. However, the cities must deal with the problems created by this consistent under funding of the Basin Plan reviews. The proposed litigation is not about objecting to programs that improve the surface water quality in our region. The litigation is about the development of Basin Plan standards (beneficial uses and water quality standards) that are sensible and cost-effective. Cities do not have unlimited municipal checkbooks to fund unrealistic federal and state urban run-off programs. The trial would be in two phases. The first phase is estimated to cost $75,000. This would be $3,000 per city, if25 cities join the litigation. This phase would determine if the cities had legal standing to bring the challenge to the Basin Plan. The second phase of the trial, which would be the challenges to the lack of disclosure of the economic impacts on the cities, standards challenges and the lack oflegally required updates to the Basin Plan, is estimated to cost $325,000 to $525,000. These costs would be over two fiscal years, FY2006-07 and 2007-08. Estimated costs are $10,000 per city, for these two fiscal years. CPR has contacted both Los Angeles County and the County Sanitation Districts to determine if either or both of these local agencies would join in the legal challenge. Legal costs to the cities could be reduced if either or both of these agencies join the litigation. I recommend the City of Vemon join with the other cities and enter the litigation about this critical issue. The funds for the NPDES litigation costs are budgeted in the 2005-06 fiscal budget for Street Systems Operations. SKW/sn Enclosure .- '- ()) > .- a:: .9~ - -o()) ())C) '- c ~<( E ~ en 0.....1 CU()) O~;; . - ....... '- ro a3 J2 L.OW ....... '- ()) C())C) (])O-CO Ob03 CO>~ Ow,- ,,, .~ ()) \..J-..c L. c........ (]) c. CO c.~()) c.,-S 02~ () CO 0 S-o - c ~co .- '- o ()) .- ..c c....... ::J CO ~~ ....... ()) S ~n r6'\7=~~nl~AV :J' l~qW~i\\. l~i\\. l~Arn s~p~UV sOl 1:n ::J.. ........ ('I)......... 0) ::::! ~n Z'~l = ~~nl~AV II 0> o ::J.. l~qW~i\\. 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