Resolution No. 8924
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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
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WHEREAS, on December 13, 2001, the California Regional Water
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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
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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
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impacts of the NPDES Permits and the Trash Total Maximum Daily Load
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("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
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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
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standards that dates from 1974, and the inadequacies of the Basin Plan
are amplified in each of the TMDLs; and
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WHEREAS, the CPR Cities desire to challenge the Basin
Plan/Triennial Review to compel the Regional Board to complete the
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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;
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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.
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1 NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE
2 CITY OF VERNON AS FOLLOWS:
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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.
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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.
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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.
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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.
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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.
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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.
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p~ .J:.,EON~t~, Mayor
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ATTEST:
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10 BRUCE V. MALKENHORST, JR.
Acting City Clerk
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1 STATE OF CALIFORNIA
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ss
COUNTY OF LOS ANGELES
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I, BRUCE V. MALKENHORST, JR., Acting City Clerk of the City of
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Vernon, do hereby certify that the foregoing Resolution, being
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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.
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BRUCE V. MALKENHORST, JR.
Acting City Clerk
(SEAL)
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SUPPORTING
DOCUMENTS
1r 7~ c:J),/,2 s-
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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
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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
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