HomeMy WebLinkAboutWater Board - Minutes - 01/15/1988WATER BOARD MINUTES
January 15, 1988
Members Present
Norm Evans, President, Henry Caulfield, Vice President, Neil Grigg, Jo Boyd,
Tom Moore, John Scott, MaryLou Smith, Tom Sanders, Dave Stewart, Jim
Kuiken (alt.), Chester Watson (alt.)
Staff
Mike Smith, Dennis Bode, Andy Pineda, Linda Burger, Paul Eckman, Assistant
City Attorney
Guests
Darell Zimbleman, Assistant Manager, Northern Colorado Water Conservancy
District
John Carlson, Special Legal Counsel, City of Fort Collins
Members Absent
Ray Herrmann
President Norm Evans opened the meeting. The following items were discussed:
Minutes
The minutes of December 18, 1987 were approved as distributed.
Norm Evans distributed a draft of a memo to be sent to Mayor Estrada regard-
ing conflicts of interest. The Board, at the last meeting, asked Dr. Evans to
follow up with some inquiry about specific areas of conflicts of interest.
He asked the Board to give him comments or suggestions or other concerns they
would like to have expressed in the memo.
Status Report on Excalibur and U.S. Reserved Rights
Mike Smith introduced John Carlson, special counsel for the City of Fort Col-
lins, who was invited to the meeting to give a status report on the Excalibur
case as well as an update on the U.S. Reserved Rights issue.
Water Board Minutes
January 15, 1988
Page 2
Mr. Carlson prefaced his remarks by stating that if someone asks a question
during the discussion that he thinks is inappropriate to answer unless the
group was in a legal confidential session, he could perhaps provide an answer
on a privileged basis at a later time. He believes it is important to take
these pains because the City of Fort Collins has invested a great deal of
money in acquiring and perfecting its rights in the Michigan Ditch, a trans -
mountain water supply out of the North Platte River. There are contractual
and distribution arrangements that have been made by the City over the years
involving return flows from the Michigan Ditch. These are also of tremendous
importance economically in contracts with Platte River Power Authority and
arrangements with Anheuser-Busch.
The Excalibur claim is essentially a claim for the right to divert 5,000 AF
annually out of North Park, as a 1986 and 1987 series of water rights. They
propose a pipeline from a point considerably downstream on the Michigan
River. They propose, somehow, in an undefined manner, to pump that water
over the mountains, again by an undefined manner, to deliver it to the Den-
ver -metro region. At the time they filed their application for water rights
on December 31, 1986, they asserted that they had a contract with a water and
sanitation district which was then called the Dolly-O-Denver Water and Sani-
tation District, now called the Douglas County Metropolitan District, to pur-
chase the water. It is very clear that Excalibur itself is not a water pro-
vider and does not have any use for the water other than "to make a buck."
They need to show a legitimate end user and a contractual arrangement for
that end use; otherwise, they are speculators and not entitled to water
rights. They have taken great "surface pains" to try to legitimize the
claim.
The reason the claim is important to the City of Fort Collins has to do with
the inter -state decree of the U.S. Supreme Court which equitably apportioned
the waters of the North Platte River between Nebraska, Wyoming and Colorado.
The U.S. Supreme Court entered its original decree in 1945 and it supple-
mented that decree in the mid 1950's. Under the terms of that original
decree, Colorado was limited to irrigation of approximately 120,000 acres in
North Park. A second limitation was imposed and that is one of grave and
important interest to the City of Fort Collins. The U.S. Supreme Court said
that the quantity of water that could be exported out of North Park to the
Front Range through the Michigan Ditch and the Cameron Pass Ditch, owned by
Water Supply and Storage Co. (the only trans -mountain diverters), was limited
to 60,000 AF in any 10 year running average period. Any new appropriator of
water in North Park who today seeks a water right for exportation, must fit
within that 60,000 AF supply that is allowed to be exported. The Michigan
Ditch, in its heyday for irrigation use, could divert 6-7,000 AF in a good
year. The Cameron Pass ditch is a small ditch with a very limited water sup-
ply and unable to divert large quantities --perhaps 300-400 AF. The Michigan
Ditch is a large system, and when it is in working order, it is essentially
fully able to consume that available exportation.
Water Board Minute• •
January 15, 1988
Page 3
When the City first looked at the claim, their question was, how could one of
these 10-year running averages work if Excalibur came in and diverted the
water in a year when Fort Collins didn't need it? They would use up part of
that 60,000, and in later years when Fort Collins needed it, there wouldn't
be any water for Fort Collins. That remains a concern, Mr. Carlson stressed,
although an unusual concern; the problem of trying to make consistent the
doctrine of an annual appropriation amount versus the 60,000 AF over 10
years. Mr. Carlson went on to say: "As we have gotten into the case, it's
become even more serious than that because it is very clear, and I think
Excalibur makes no bones about it, that their plan is to try to destroy Fort
Collins' right to use the Michigan Ditch to its decreed extent. This type of
thing used to be called claim jumping," he laughed, "and we all know how
claim jumpers were treated in those days." Now we take a more civilized
approach in the form of court warfare.
There is no capacity in the 60,000 AF export as a practical matter, unless
the City of Fort Collins' rights are delimited or constrained. Obviously, the
City has invested substantial funds in acquiring and rehabilitating that
ditch to make sure it has a full water supply.
The Excalibur people are a series of partnerships. One group is called the
Ballar partnership and that involves a real estate investor/developer in the
Denver area named Bill Walters. There are other investors whose identity we
aren't completely sure of, Mr. Carlson admitted. There is also a group of
investors from the Fort Collins area named Goodman and Blessman. The Excali-
bur people are hoping to appropriate water, sell it and make a lot of money.
In order to make their claim, they are hoping that the District mentioned
earlier will legitimize them by taking them past the hurdle of being a specu-
lator. Mr. Carlson said that, at this point, they are in the midst of very
heavy discovery. Earlier this week, they took a deposition of the president
of the district that is supposed to purchase the water from Excalibur. It
turns out that the District is 2,000 acres of land south of Denver; raw land
that has never been developed. The district has existed 10-20 years and has
been treated as a dead district by the Department of Local Affairs. Develop-
ers acquired it 2-3 years ago and activated it. The district has no inhabi-
tants, no service, no zoning, no plating, and yet they have all of these
grandiose plans. The board of directors has authorized the issuance of $500
million in bonds. It is clear that the district is run by a man who is the
principal manager of the group of investors. It is clear the district has no
very firm plans. It is also clear that the district doesn't have the finan-
cial where -with -all to cover those bonds, Mr. Carlson reported.
Mr. Carlson and colleagues will take a series of 10-12 depositions of all the
people involved, and examine what causes them to be entitled to a water
right. Did they validly initiate a water right? Do they have anything
behind it or is it a speculative scheme? He related that it will be a very
time consuming, expensive proposition and wasteful for City employees because
they are having to devote an extraordinary amount of time to it.
Water Board Minutes
January 15, 1988
Page 4
A pre-trial conference is scheduled in April. Trial has been set for 5 days
in mid -May. The issue is: Did Excalibur make an appropriation? Have they
done things that are required under Colorado law to have an appropriation?
Will it hurt Fort Collins under the terms of the inter -state decree? They
clearly intend to attack the validity of the Fort Collins right, Mr. Carlson
emphasized. If Fort Collins wins, "you will be in the same position as you
were in before. It doesn't create any new revenue for you. Unfortunately,
you are purely in a defensive posture," he concluded.
Mr. Carlson asked for questions and comments. MaryLou Smith asked for a
clarification. It is her understanding that Excalibur has to do some work to
show that they have a vaTid request. In addition, they need to show that
Fort Collins has an invalid right. "What if Excalibur is shown to be an
operation that doesn't have a valid claim, doesn't that still put us in the
position of having this come up again with someone else who might be a more
reputable operation? Perhaps we need to do something to clarify our right so
that we won't have to pay out these legal fees over and over to defend our
right." "That is a possibility," Mr. Carlson responded, "but it seems to me
that the Colorado Supreme Court has decided a case, not involving Fort Col-
lins, that gives substantial reason to believe that our decrees are valid."
It seems to him that unless and until a court had said our decrees are not
valid, and did not protect our position, there is no sense in making new
claims or re -litigating or confirming those proceedings. Ms. Smith restated:
"Is it possible to make our claim more solid so we would be less likely to be
sued in the future?"
"That is a possibility, Mr. Carlson replied, "although there are some prob-
lems with that." It seems to him that until our position relative to Excali-
bur is more definitely known, we shouldn't address that. "It may be some-
thing we can sit down and talk about in a legal session when the dust
settles." Mr. Carlson reiterated that we have two overwhelming objectives:
1) to show the court that Excalibur has not initiated a valid appropriation
and 2) to the extent our rights are attacked, to beat down that attack. If we
beat down that attack in the context of this case, that ought to dissuade
other people, he assured the Board.
Neil Grigg asked what court will it be tried in? "It's in the Water Court
Division 6 in Steamboat Springs," Mr. Carlson replied. They seem to be ini-
tiating ancillary or subordinate litigation. They have challenged Platte
River's and the City's diligence rights on Rawhide Reservoir and a challenge
to a miner augmentation plan involving Michigan Ditch water and Mr. Carlson
was told that in December they made an exchange filing by which they hope to
run the water using exchanges on the Poudre and on the Platte back up the
river to their district which lies south of Chatfield Reservoir.
In Dr. Grigg's second question he asked if what they are doing to us amounts
to harassment, and if our costs are high, is it possible for us to counter
sue and recover some of those costs? "I have seen only one case in which a
court awarded fees and costs on that kind of ground in a water case," Mr.
Carlson replied. "However, when we met with Excalibur, we advised them that
Water Board Minute
January 15, 1988
Page 5
we intended to seek those fees and costs." Whether the court will award us
that sort of thing remains to be seen. You would have to have a total vic-
tory and have convinced the court that it was frivolous, he added. Paul Eck-
man agreed that he hasn't seen that kind of an award very frequently. Mr.
Carlson stated that if the facts develop that allow us to do that, we will
seek it wholeheartedly.
Someone asked who Excalibur's attorneys are. Mr. Carlson answered that they
have "a whole houseful of them!" The principal counsel is a firm called
Albright and Buchanan. Martha Albright is the attorney for Excalibur. He
mentioned 3 other firms that are involved.
Henry Caulfield referred to Division 1 versus Division 6 in the Supreme
Court case which was addressed in Mr. Carlson's memo. "I gather you don't
want to discuss that any further," he said. "Do you want to discuss the dil-
igence question with respect to development of the Michigan Ditch?" Mr.
Carlson agreed that those discussions would be more appropriate in an execu-
tive session. He did relate, however, that Excalibur's claim is that the
decrees Fort Collins got back in the '70's were not entered by the proper
court, and the "reason they seem to want to say that is they want to drive us
back into court to seek confirmation and then allege that our rights are
smaller than we fervently believe they are. That is why they are threatening
the Division engineer. They want to try to compel us to submit ourselves to
the court. We want to have the Supreme Court uphold what it has already said
and that is, our decrees are appropriate."
Henry Caufield commented: "I take it the court doesn't take responsibility
for what jurisdiction it assumes." "That's true," Mr. Carlson replied,
"judges acting in their official capacity are immune from civil suit."
In case it isn't challenged, is there a statute of limitations, Mr. Caulfield
,wanted to know. "The rule of law is that a judgement, if the court had
jurisdiction over the persons that were necessary and over the subject
matter, then the judgement is unassailable." They can't be attacked, but if
the court lacked jurisdiction over persons or subject matter, then the judge-
ment is void. It can be attacked anytime--100 years later supposedly. The
theory is that the constitution of the U.S. requires that people have due
process of law and an opportunity to be heard before their rights can be
adjudicated, Mr. Carlson explained.
Mr. Caulfield continued: "Without getting into your legal judgements that
you don't choose to discuss, could we review for the benefit of the Board,
with respect to the Michigan Ditch, what we are really talking about?" As he
understands it, we are talking about a ditch that was developed by a water
company many years ago, that at some point was taken over by the North Poudre
Irrigation Co. At that time, under its term, it had a certain historic use.
The use went down substantially for parts of it. At that point, the City
bought it from North Poudre. The City immediately began to re -develop it.
"That's substantially correct," Mr. Carlson said. The water rights were
appropriated by farmers in the Poudre Valley. The Ditch came into the hands
Water Board Minutes
January 15, 1988
Page 6
of North Poudre which was a successor. The decrees total to over 140 cfs.
The Ditch is constructed in very difficult terrain at a high altitude, so
there were snow slides and tremendous wear and tear on the wooden pipe. In
the '20's, '30's and '40's it diverted enormous quantities of water. In the
'50's the diversion fell off substantially. Through the '60's that continued
to be the case. North Poudre chose not to spend much money on it. In
1972-73, an arrangement was struck between Fort Collins and North Poudre
where North Poudre conveyed the Michigan to Fort Collins. Fort Collins con-
veyed a series of agricultural rights that it had acquired through the years
in the Poudre Basin to North Poudre; an arrangement that was the subject of a
court action in Division 1 Water Court in 1974, at which time Fort Collins
entered the decree. "The important fact to remember is that, by and large,
although Fort Collins owns the Michigan Ditch, the physical molecules of the
Michigan Ditch continue to go up to the North Poudre system. That is because
the physical constraints of Fort Collins' system require you to work a series
of exchanges. NPIC transfers CBT water to Fort Collins at Horsetooth Reser-
voir which is gravity flow into the Fort Collins system, and they take the
Michigan Ditch water. The point here is we don't need any change; we are
still using it for irrigation in some sense," he stressed.
Henry Caulfield asked about the water in the Michigan Ditch that is part of
the City's understanding of Joe Wright. "That made Joe Wright more feasible
than otherwise it would have been," he said. Mr. Carlson responded: "That's
correct, but after it is stored in Joe Wright, it still goes to North
Poudre." Mr. Carlson explained that there are also exchanges that are worked
whereby return flows are accounted for after the North Poudre units come into
the City. The return flows from that are accounted for as Michigan Ditch
water and the return flows from the Michigan Ditch that go into North Poudre
are accounted for as CBT return flows. "It is a complex accounting matter,"
he said, "that was developed in the 1970's to accommodate these interests."
As soon as Fort Collins acquired the property, it launched a substantial
effort to cause the Ditch to be in good shape and that has been a huge under-
taking which has gone on consistently year in and year out since 19721
It was essentially completed before Excalibur filed a claim, Mr. Caulfield
asserted. Mr. Carlson thinks that "any court in the world" would have to
look at that should they actually put Fort Collins' interest at issue and
attack. "Even though there was a period of time when there was a reduced
level of use," Mr. Caulfield continued, "before Excalibur filed a claim, the
City had substantially rehabilitated the Ditch to Lake Agnes." "Yes, but that
happened in a period in which there was a very small degree of demand in the
City," Mr. Carlson responded, "and when the City was in a very wet cycle, so
there was not a corresponding exercise of the rights over there that would
show a draft on the stream system." He explained that the draft on the North
Park stream system has remained relatively modest because Joe Wright happened
to remain full with native water and the City's lack of demand in that
"remarkable" wet cycle.
Water Board Minute •
January 15, 1988
Page 7
As Mr. Caulfield understands, the City has, under certain court rulings, the
right to have substantial surpluses of water. Mr. Carlson explained that
this is why Excalibur wants to attack the validity of the City's decree. If
the decree is good, they've got no "home," and for them to get anywhere, they
must reduce Fort Collins' share of that 60,000 AF. Unless they do that, they
have nothing. "If they only get about 1,000 AF, we all know that the project
is not feasible." At this point, they have estimated the cost at $18 million
to pump the water out of North Park. They haven't estimated the cost to take
it to Denver. There are substantial economic analyses and engineering ques-
tions that have to be addressed, he added.
Tom Moore was curious about the $18 million figure. He believes that one
could probably buy that much water for $6 million. During depositions did
you get any ideas as to why they think this is economically feasible? Mr.
Carlson replied that the value of water is always determined by where you
are. In the Northern District, CBT water is available at a reasonable cost,
and pretty freely transferable within the District. The Dolly-O-Denver
District is not in an area of any raw water supply. They are near the Platte
but that river is pretty well appropriated by Denver, Englewood and all of
the agricultural users. People in the Denver area are looking at water cost-
ing $6-7,000 per AF in today's market. That's far more than the cost of water
here. "We know that there are prices the market won't bear. They don't know
that yet or if they do, they aren't acknowledging it." Mr. Moore contends
that this seems out of anyone's range. "We agree," Mr. Carlson said, "and we
intend to show it."
Jo Boyd asked: "Could there be the possibility of something akin to "green
mail" in the corporate structure, where you set up and frighten someone
enough by your takeover attempt that they will buy you off?" "I have no
doubt that they are trying to do that," Mr. Carlson stated. "It's a form of
blackmail."
Norm Evans remarked that this has been a very fruitful exchange and suggested
that the discussion now be directed to the Federal Reserved Rights issue.
Dr. Evans asked a question that was brought up in previous discussions. What
is the state attorney general doing in this matter and does it relate to what
Ward Fischer and the Water Users are trying to do? Mr. Carlson explained
that the State Legislature has appropriated funds, and the firm of Simons
and Lee has the prime contract. They are doing work in analysis of one par-
ticular claim that the government is making. The claim on the front range
that is of most concern to the water users involves an allegation that when
the U.S. Congress created the National Forest back in the 1890's and passed
the Organic Act, they impliedly intended that sufficient water should be kept
in all the streams to keep the stream channels viable and cleansed of sedi-
ment. There are several problems with that theory. In reviewing the legis-
lative history and the text of the act, you find nothing in it. In fact, in
the act itself there is a provision that says, "all water rising on the
national forest may be appropriated under the laws of the state." "That
hasn't stopped Uncle before," Mr. Carlson laughed. The theory that the gov-
ernment is advancing is somewhat new. It came on the heals of a defeat they
Water Board Minutes
January 15, 1988
Page 8
suffered in the U.S. Supreme Court in the case of U.S. versus New Mexico.
There they were claiming that the forests were created with the implied water
purpose of recreation and aesthetics. They have developed a methodology in
the Forest Service that shows that channels degrade. They therefore have
asserted that it is not in the U.S. Government's interest for a channel to
degrade. The methodology they have developed to quantify that theory indi-
cates that streams need flushing or scouring flows to prevent the channels
from degrading. Mr. Carlson has been told by engineers involved, that the
methodology they use is a stream channel sediment loading study that was done
in Nebraska and that it has no relevance to Colorado high mountain streams.
The consequence of that is that they might have some proof problems.
There is another more basic issue. The U.S. Government has conceded that the
reason they need the flushing and scouring flows is to deliver more water to
appropriators off the forest. They say the claim is not made on their own
behalf, but is made to benefit people downstream. There are instances in the
front range and elsewhere, particularly the San Luis Valley, where the last
thing people who have a head gate out on the flat lands need, is more sedi-
ment. In fact, it can be shown to be a detriment and whether that is con-
sistent with their claim remains to be seen. Mr. Carlson related that he and
a group of water users throughout the state tried to get the Colorado Supreme
Court to rule as a matter of law that these kinds of claims simply could not
be considered, and had previously been ruled not to be recognizable claim to
prior case laws. In the fall of 1987, the Colorado Supreme Court unanimously
said, "everybody gets their day in Court. Give them a chance to try and
prove it." Apparently they are going to advance those claims first in Divi-
sion 1. If your head gates and diversion structures are all below national
forest land, it ought not to be a case of great concern. If you have struc-
tures and reservoirs on national forest land, then you must satisfy yourself
that the recognition of the claim will not interfere with the storage yield
that you thought you had. He suspects that for Fort Collins, the principal
concern will be, "how does this impact the rights we have at Joe Wright
Reservoir?" There may be opportunities to settle and resolve this with the
U.S. because, he believes they are anxious to acquire rights that would pre-
clude future development and do it in a way that perhaps wouldn't ruin exist-
ing uses. "It's hard for them to advance the theory they have developed
without applying it both prospectively and retrospectively."
The second signal the Forest Service has given Mr. Carlson in other parts of
the state is, "if you have a reservoir that is 60-70 years old we aren't
going to hurt you. We'll just make a deal. You can have that reservoir and
we will subordinate to you." Mr. Carlson said he asked "what about a reser-
voir that has been there 10 years? That's a tougher question, they say,
since that stream may have not reached equilibrium. "It remains to be seen,"
he concluded. It is his understanding that Simons and Lee has done an enor-
mous amount of work for the state. He believes the attorney general will make
a big effort on this issue. Mr. Carlson had a discussion with the attorney
general in which his office was considering consolidating all the cases in
the state in front of one court. "A group of us who met with him said we
thought that was the craziest thing we'd ever heard, because individual
Water Board Minute
January 15, 1988
Page 9
cases, where circumstances and facts can be different, tend to get lost and
it becomes significantly more expensive for them. We opposed the idea."
"Who has done the legal research on the question of what watershed management
meant in the Forest Service in the 1890's through the first decade of the
century," Mr. Caulfield wanted to know. "I happen to know that the forests
were acquired because of watershed management --the theory was that the forest
would hold back the water in such a way as to yield more," he recalled. Mr.
Carlson agreed. "We tried to argue that in the supreme Court," he added.
"We filed every document we could find that described what they were intend-
ing at the time the forests were created. The supreme court said no, we want
to let them have a trial.." That will be argued again, Mr. Carlson emphas-
ized.
Dr. Evans pointed out that the firm for which Water Board member Chester Wat-
son works has been doing work on this case. Dr. Watson confirmed that his
company has the contract for technical oversight on SLA for the attorney Gen-
eral's office. Mr. Carlson said he is familiar with the firm and is impressed
with their work.
Mr. Carlson continued. Other than people with reservoirs, the other group
with a problem are people with head gates on national forests. Mr. Caulfield
pointed out that North Poudre is among those.
Jim Kuiken said it is still not clear to him what the relationship is between
the state attorney general's case and the case with the Cache La Poudre Water
Users. Mr. Carlson replied that it is the same case. "Water cases tend to
be a general free-for-all. The State is acting for everybody's good. The
trouble is, many people might say, "our interest may not get sorted out." The
other point is that the state isn't in a position to say, "we own the water
rights that are going to be hurt." The state attorney general's office sig-
naled a willingness to try to provide as much help and service as people
want; particularly in the engineering area.
Chairman Evans thanked Mr. Carlson for his status report on Excalibur and the
update on the Reserved Rights issue. "It appears our water interests are in
good hands," he said.
Update. Northern Colorado Water Conservancy District
Darell Zimbleman confirmed that the District and the Cache La Poudre Water
Users are involved in the Reserved Rights case. The NCWCD has some contracts
with Ev Richardson at CSU to help them with some analyses.
Henry Caulfield recalled from the last meeting that Brian Werner agreed to
supply information about reservoir levels along with numbers about the Dis-
trict's water distribution, etc. People on the District's mailing list used
to get the reservoir information, Mr. Caulfield said. Mr. Zimbleman promised
to check on that.
Water Board Minutes
January 15, 1988
Page 10
Mr. Caulfield asked if there were any new issues. He said that Mr. Werner
agreed to inform the Board of forthcoming issues. Mr. Zimbleman said, "to
the degree that we can, we will try to do that." He added that he isn't
aware of any new issues.
Dr. Evans referred to the "slow down in the transfer of Bureau power facil-
ities" as a matter that may be worth reporting on. Mr. Zimbleman said it is
"on hold" for the time being while they try to resolve some of the issues
that have been raised. Apparently there is an evaluation team being created
by the Department of the Interior that "supposedly" will set criteria by
which the Department can transfer power facilities to the irrigation dis-
tricts. "I don't know why that's an issue now," he remarked, "because the
Bureau has been doing it for years." John Scott said that he thinks they
began meeting this past Tuesday. Thaine Michie, Director of PRPA is on that
committee. Mr. Caulfield said that raises the question of reducing the amount
of power that is available to the Western Area Power Administration for
administration. Mr. Scott replied that he doesn't think that amount will
ever change whether it is in Bureau hands or District hands.
Dr. Evans had a question relating to the municipal sub -district. There is
some kind of a reserve fund that has been under discussion. Could you clarify
what it is? Mr. Zimbleman explained that what happened was this: "When we
did the Series D restructuring, we refunded the Series C with Series D. The
District set up an escrow fund to pay off those series C bonds." When the
stock market crashed, the value of those securities went up considerably. The
District took advantage of the opportunity to take those government securi-
ties and buy other government securities which resulted in earnings of
$300,000 for the Sub -district. The money was placed into an operations
reserve fund. Now will the money be used, Dr. Evans inquired. Mr. Zimbleman
explained that the District believes the Windy Gap Project will develop
48,000 AF a year. "In order to do that we need to pump zero some years and
90,000 other years," he said. "Quite frankly, it is difficult to deal with
zero pumping one year and 90,000 the next year." What the District has said
all along that they would like to do, is set up a reserve fund that the Dis-
trict can manage by billing the Windy Gap participants on an even basis each
year, and use that reserve fund to manage the ups and downs. Thus, the
cities would not have to deal with high rates one year and low rates the
next. The $300,000 is the seed money for creating that operations reserve.
Conflicts of Interest
Paul Eckman was asked to report on three items that he was asked to get
answers for at the last meeting in specific areas of conflicts of interest.
He acknowledged the draft memo to the Mayor on conflicts of interest which
Dr. Evans distributed to the group. After the discussion today, Mr. Eckman
will prepare a more formal report in writing on this subject which he will
give to each Board member.
He first discussed the interpretation of Paragraph 6 in the Boards and Com-
missions Ethics Statement: "A member of a board or commission should refrain
from representing any person or interest for compensation before the City
Water Board Minute •
January 15, 1988
Page 11
Council or any board or commission of the City on any matter which pertains
to the function or activity of the board or commission on which such member
serves."
He talked with the City Attorney about this and the question arose, what is
a person or interest? Is the City a person or interest? It was clearly not
the City's intention, as in Dave Stewart's case, that a board member working
for the City couldn't explain to the City Council what he had done for the
City. The City is not a person or interest in that sense; another client
would be. "If you had a client that was paying you separate from the City,
and you went to the Water Board or the City Council and talked on behalf of
your client as a Board member, that is what that paragraph was intended to
cover; not appearing before the City Council with the City as you client."
Henry Caulfield asked about Jim Kuiken's case where he is an employee of a
company that is doing work for the City. Mr. Kuiken said that it seems to
him Paul Eckman's opening statement explained that if you represent the City
before the Council, ("In my case I'm under contract to the City.") that is
allowable, but if I was under contract to Thornton, for example, and came
before City Council, that would be representing another interest. Is that
your distinction, he asked Mr. Eckman. "That's the correct interpretation of
par. 6," Mr. Eckman replied.
Dave Stewart asked, "isn't that contrary to the articles that you passed out
last time?" That gets to the other more difficult part of it which is that
charter section point that was discussed at the last meeting, Mr. Eckman
replied. He paraphrased Art. IV, Section 9 of the Charter: "No officer or
employee of the City shall be financially interested directly or
indirectly, ..in the supply of services except personal services as an
officer or employee. Any violation of this section..... shall render the
contract voidable." In those cases Dave Stewart referred to, those were
always clearly officers; one was a city council member and one was a director
of a special district. City Council members are always officers. They even
receive compensation --meager as it is. Board and commission membership is a
gray area. All of you are appointed subject to removal and the question that
is hard to answer with a guarantee is whether you are not an officer or
employee.
Mr. Eckman then explained the indemnification part of the question because it
describes what a public employee is. He brought along a copy of the Govern-
mental Immunity Statutes of the state just to read the definition of what the
State Legislature says a public employee is. It defines a public employee as
an officer, employee, servant, or authorized volunteer of the public entity,
whether or not compensated, elected or appointed. "So you fit within that
definition of public employee." Let's suppose you are authorized volunteers.
That means, "a person who performs an act for the benefit of a public entity
at the request of and subject to the control of such public entity." You are
within the control of that entity because you are subject to removal. That
makes you a public employee for purposes of the Governmental Immunity Act.
The good news is you get indemnification and you receive sovereign immunity.
Water Board Minutes
January 15, 1988
Page 12
"A public entity shall be immune from liability in all claims for injury
which lie in tort except for certain exceptions, like the operation of motor
vehicles of the City, public buildings, public roads, public hospitals,
jails, operation of public utilities." In other words, we have sovereign
immunity for all civil claims in state courts under this state law. By a
later provision of this article we read that: "as long as the public
employees are acting within the scope of their employment, and the act that
they committed or the omission occurred during the performance of their
duties, and the act was not willful or wanton," you have sovereign immunity.
You also have, by statute, the City's indemnification of you in state
claims.
Mr. Eckman said he would send Board members copies of 2 resolutions the City
Council passed last June which extend that indemnification to federal claims
too. One resolution defines willful or wanton: "conduct purposefully com-
mitted which the employee must have realized is dangerous, done heedlessly and
recklessly without regard to consequences or the rights and safety of others,
particularly the claimant." Last time Council met, it provided a funding
mechanism for that indemnification through its insurance. There would be
$150,000 per person, $400,000 per incident coverage. If you get sued in
excess of that, the City has an excess carrier policy up to $1 million. If
it is more than E1 million, you have to look at the general wealth of the
City to the extent that it can be tapped for coverage.
As far as a taxpayer suit is concerned, Mr. Caulfield asked, as we covered?
"Yes," Mr. Eckman replied, "you will have indemnification." "You will have
indemnification if there is a suit for damages against you in a civil claim;
you will have both the indemnification with regard to payment of the judge-
ment and you would have the City's defense. If at a later time, a court
should decide you were willful and wanton in your behavior, you would have to
pay back the cost of your defense."
Chester Watson asked if there is an ethics board in the City. "No," Mr. Eck-
man replied, "but the City Council has an ethics committee that they use
internally to determine conflicts, but I don't know if that committee deter-
mines conflicts outside the Council." Dr. Watson believes it would be benefi-
cial if there were such a committee or board that a board or commission mem-
ber could consult if he/she had questions.
Mr. Eckman said he struggles with this issue. It is awkward to say you are
public employees for the purpose of indemnification under state law, and then
turn around and say, "but you are not public employees for the purpose of the
charter which prohibits officers and employees from having contracts with the
City." He believes that the intention of the charter was that officers or
employees in that context were people who were paid for their services;
"employees like me, and officers like City Council members." Authorized
volunteers don't fit that definition. "I feel comfortable arguing that," he
assured, "but unfortunately I can't make any guarantees." Mr. Eckman
believes that the Water Board is the most critical board with regard to this
issue because there are so many professional consulting people on the board.
Water Board Minute •
January 15, 1988
Page 13
Dave Stewart suggested that the City consider an ethics board. He also asked
about the situation when he was doing work for Water Supply and Storage Co.
and the Council asked him to give a presentation on his work. Mr. Eckman
believes that, in that case, since the Council requested that he give the
presentation, they waived that provision; on that one occasion at least.
Chester Watson suggested that if one might be in a situation like that, it
would be advisable for the Council to make an affirmative statement in that
regard.
Paul Eckman related that the differences in those frightening cases he cited
last month, was that those involved were clearly officers.
Chairman Evans reviewed what Mr. Eckman was requested to cover and it
appeared that he had explained all of those items. The only item that Dr.
Evans would write to the Council about is the suggestion of creating an
ethics Board.
Paul Eckman will put everything that was discussed in written form for Board
members to keep as a reference. He will also include the indemnification
resolutions.
Committee Reports
Program Evaluation Committee
Neil Grigg, committee chairman, reported that at the last meeting President
Evans appointed a number of standing committees. Today each committee chair-
man was to report what his/her committee's charge would be. Dr. Grigg's com-
mittee met on January 5 and grappled with some substantive issues that relate
to what the work of the Water Board should be. Each Board member received a
copy of the preliminary report of the Program Evaluation Committee. The
report raises a number of questions that the Water Board needs to deal with
relative to the work of the Water Board in general, the work of the staff and
also the work of the other standing committees.
The Program Evaluation Committee has several duties and these relate to
goals, objectives strategies and Board performance, according to Dr. Evan's
handout. In the past, the Water Board's goals have been very general. Our
committee sees a need to make these goals more specific if the Water Board
is going to be effective in its own work, Dr. Grigg related. He thinks the
name of the committee is in a sense a misnomer because the committee deals
with establishing goals and objectives, strategies and plans as well as
evaluating programs. Establishing goals is the first step in planning the
work of the Water Board. Program evaluation is the last step. In essence
the committee is charged with planning and evaluating what the Water Board is
doing. Dr. Grigg said if we are going to do that correctly, we must know
what the Water Board is supposed to do. If you consult the City Code and the
Water Board Bylaws, you find that they are general and vague. Generally they
state that the Water Board is supposed to be advisory to the City Council on
matters relating to water rights, "and matters pertaining to the municipal
water works and wastewater treatment systems." The Water Board has dealt
Water Board Minutes
January 15, 1988
Page 14
very little with matters relating to wastewater treatment and very little
with the water works facilities. "We spend most of our time dealing with
water rights issues. The question is, is that correct?" Dr. Grigg's analy-
sis of that, and this is generally what was discussed when the committee met,
is that we need to be clear about the role of the Water Board as advisory to
the City Council viz -a -viz the role of the staff. Because we are an advisory
board and the City Council is a legislative policy group, it appears to Dr.
Grigg that the role of the Water Board ought to include formulating policy in
matters where the City Council has to set policy or have to make decisions
that have to do with legislation. "Our charge ought not to deal with any
operational matters that staff should be carrying out. That's a chain of man-
agement responsibility that culminates with the city manager as the chief
executive of the City." Dr. Grigg is proposing this as a way to distinguish
matters that the Water Board should get into to advise the staff and Council
on. On operational matters that staff deals with, the Water Board should be
kept informed about them but not get involved in them.
As a way for the Water Board to know what is going on, Henry Caulfield made a
proposal which Dr. Grigg included as a tentative recommendation of the com-
mittee. Once a year, at a meeting, the staff would inform the Board about
plans involving the water works, physical facilities and operational and
financial matters. Water Board would be fully informed, but would not have
to deal with those matters.
Following is the suggested charge of the committee: "The Program Evaluation
Committee will prepare goals, objectives, strategies and plans for consid-
eration by the full Water Board. In preparing goals, the committee is guided
by the principle that the Water Board considers policy matters that require
decisions and actions by the City Council, but normally only receives infor-
mation and reports about normal utility operations without providing advice
about them unless policy matters are involved. The committee evaluates and
reports the performance of the Board in achieving its goals."
Next Dr. Grigg took the goals that were articulated at the workshop and con-
verted them to a revised list. On the right side of the page he listed how
those goals can be achieved with specific actions by the staff and by the
Water Board committees, following the principle that the Water Board doesn't
deal with staff matters, but does deal with policy matters. It appears to Dr.
Grigg that if the committees do everything that is listed, they are going to
be kept very busy and the staff will be overwhelmed trying to stay up with
the committees. He gave an example. No. 1 says "complete and implement the
Water Supply Policy plan." He proposed two additional goals: "to articulate
Fort Collins' role and strategy in response to Metro -Denver and to develop a
strategy for dealing with the Northern Colorado Water Conservancy District.
He sees those three things as being linked to the Water Supply Policy plan.
The plan could include resolution of the metering issue and the response to
Metro -Denver. What he proposes as a working strategy is that issue be
referred to the Program Evaluation Committee for development of the strategy
Water Board Minutes
January 15, 1988
Page 15
and the committee would work with the staff. As he mentioned earlier, the
committee is misnamed in that it needs to deal with strategy development, so
he has recommended it be changed to the "Planning and Evaluation Committee."
He gave two more examples of goals that need to be referred to committees.
Under "formulating a policy regarding in -stream flows," he believes that
staff could prepare a draft policy and that would be referred to the Legisla-
tive and Finance Committee. Under "adopt policy regarding watershed protec-
tion," staff would prepare a policy. He would refer it to the Engineering
Committee. He went on to list other goals and what he believed would be the
appropriate committee assignments.
"We need to grapple with these issues and assignments as a Water Board," he
said. In conclusion, he presented these specific recommendations:
* The Program Evaluation Committee notes that committee work dealing with
preparation of overall water supply strategies and response to Metro -Denver
does not logically fall to any of the standing committees. It recommends
that this issue be referred to the Program Evaluation Committee to provide the
staff with a forum to formulate strategy and preliminary policy suggestions
prior to presentation to the full Water Board.
* The committee recommends that the Board request an annual presentation by
the staff where operational plans are reviewed. The purpose of this briefing
would be to inform the Board about capital, operational and financial plans
under consideration by the staff but which do not require specific Board
action.
* The committee recommends that no additional recommendation be made to the
Council by the Board at this time about metering. If the Council requests
additional information or studies, the Board should respond. The committee
cautions that should the Council decide to accept the draft Water Supply Pol-
icy document without the phased metering plan, it should be informed that the
estimates of water supply needs and developer contributions are based on a
scenario of metering and are not valid without the phased metering program.
The basis for this recommendation is that it seems best for the City Council
to make the next move.
* Since the duties of the committee described above entail planning as well
as evaluation of programs, it is recommended that the name of the committee
be changed to the "Planning and Evaluation Committee."
Norm Evans said that Neil Grigg's report raises two questions: One the dif-
ferentiation between the operational matters and the policy matters. He
understands that operational matters are those that don't require Council
approval and policy matters are those that do, more or less. Yet, there are
some policies that don't necessarily require Council approval, but they are
major polices within the Utility. His reaction is there may be a difficult
distinction to draw. A second part of that question relates to a comment
Mike Smith made earlier that staff would appreciate it if the Water Board
Water Board Minutes
January 15, 1988
Page 16
was depending less upon the staff to originate policy ideas. Is this in
harmony with your feelings, he asked Mike Smith. What staff would like is
for the Water Board to be less dependent on staff to research an issue and
return with a policy, Mr. Smith responded. There is considerable expertise
on the Board which would allow the Board to formulate policy that they might
recommend to Council as well. The Board shouldn't think that it is entirely
up to staff to initiate policies, he added.
Dr. Evans asked for Neil Grigg's reaction. Dr. Grigg responded that he
doesn't see how any committee could go very far without at least getting the
basic data from the staff. It is hard for a new member to have the histori-
cal background to proceed on his/her own. In fact, the staff has a tremendous
amount of power compared to Board members because they control the informa-
tion. An exception might be the Conservation and Public Education Committee
where they might have ideas and make moves that staff hadn't thought about,
he said.
Mr. Smith said he would feel uncomfortable if the sub -committees went off on
their own without some input from staff.
Mr. Caulfield said that he made the suggestion to have the equivalent of an
annual meeting, where the Water Board would review, in effect, the activities
of the Water Utilities. As you look at the ordinance establishing the Water
Board, the Board appears to be responsible for everything that is involved
with the Utility. From the public point of view, Mr. Caulfield thinks it is
important for the Water Board to recognize this. The annual meeting idea is
to take cognizance of it. "On the basis of that, we can decide if we have
any interest in particular things." On the other hand, this Board does not,
want to become involved in many areas; for example, the sizing of the trunk
sewers. However, the Board shouldn't say that its interest is only that
which would go to the Council for action. There are operating policies the
staff may want to share with Board, and that staff may want advice on --that
"staff doesn't have to go to the Council on and the Board doesn't have to go
to the Council on, that could be important for us to discuss." Neil Grigg
said, "that's what I would like to do, but the code and bylaws say we are
advisory to the City Council, not advisory to the Water and Wastewater Util-
ity."
Dr. Evans related that the code does say other things about responsibilities.
Dr. Grigg conceded that it does have one "murky" statement in the charter
that charges the Board "to provide advice on all matters of concern to the
City with which the foregoing matters are substantially related."
"Let's assume that a subject came up, Mr. Caulfield conjectured where the
Board debated with staff on a particular matter, and where staff resisted
implementation of what the Board thought was very important. The only way
we could force staff to do it would be through the Council." Ultimately the
Council is the authority that could decide something, he stressed. There are
many things short of going to the Council that staff and the Board could
agree on after discussion, he believes.
Water Board Minutes
January 15, 1988
Page 17
Mike Smith believes the Board may be getting "into some muddy water there,"
and he isn't sure where it may lead. Mr. Caulfield insisted that it is not
his intention that the Board would delve into "a lot of things that staff has
to do." MaryLou Smith pointed out that there is some confusion on this and
it is worth clearing up. For instance, all of the tasks that the goals say
the Water Board should tackle, would be an inordinate amount of work. Does it
become the role of the Water Board to say, "these are our goals, and we want
staff to work with us on these goals; that becomes a direct relationship
between us and staff implementing our goals, when our bylaws say we are to
advise Council. Our bylaws say nothing about our advising staff. "It is
also unclear how much leeway the Water Board has about asking staff to help us
meet our goals. If we are to do the things that we list, and it takes all of
staff's time and they have also been directed by Council to do things to meet
their goals, it becomes very confusing for staff. "Perhaps we are trying to
clear something up that has worked well in the past. Have we had some actual
problems with it?
Mr. Smith said there haven't been problems in the past. "It has worked okay."
What he seems to be hearing, however, is that the Water Board wants to go a
step further. Marylou Smith admits that as chairman of the Conservation and
Public Education Committee, she has felt some confusion in trying to deter-
mine the charge of that committee. "Do we work with staff on what they are
already doing to evaluate whether changes need to be made?" That is not a
part of the Water Board's stated duties.
Henry Caulfield pointed out that there is a section in the Bylaws relating to
that under, Relations with Staff, Section C: "On matters not requiring Coun-
cil action, and where the Board and staff are in agreement, the staff is
expected to carry out promptly, an agreed upon action." On the other hand,
if the Water Board felt strongly about an issue that staff did not favor, the
Water Board could work with the Council to get the issue resolved.
Paul Eckman read the duties of the Water Board according to the charter:
"The duties of the Water Board are: a) to advise the Council on matters per-
taining to acquisition, control and disposition of water rights; b) to advise
the Council on matters pertaining to the municipal water works and wastewater
treatment systems; c) and to perform such other duties and functions, and
have such other powers as may be provided by ordinance of the Council."
MaryLou Smith said, "and our bylaws read just that way." Mr. Eckman added
and the code says the same thing as the charter.
The question is, are there any other ordinances that empower the Water Board
to do anything other than advise the Council, Mr. Eckman asked. There is
during emergencies such as a severe shortage of water, Dr. Evans replied,
when the Water Board could impose restrictions. Mr. Eckman read that in case
of a water emergency, "the City manager is authorized to order any restric-
tions on the use of water." Drought or water shortage is another section but
then it is an advisory role. "In the event of drought or water shortage, the
City Council may place restrictions on all uses of City water and even prohi-
Water Board Minutes
January 15, 1988
Page 18
bit if necessary, all domestic uses of City water, if the Water Board so rec-
ommends." Dennis Bode related that there is also an area having to do with
satisfaction of raw water requirements. Paul Eckman read: "The Water Board
determines which water rights are acceptable to the City," and that's not an
advisory role. That is one of the only areas where the Water Board is the
final authority.
Henry Caulfield suggested that in line with the recommendation of the commit-
tee chairman, to remand this matter back to the sub -committee for further
consideration in light of this discussion. Neil Grigg reminded his committee
that they will meet on January 21 at 3:00.
The Water Board went into executive session to consider a confidential water
acquisition opportunity. The staff recommended that the proposal not be pur-
sued. The Water Board concurred.
Since there was no further business, the meeting was adjourned at 5:20 p.m.
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Water Board 5ecretary