HomeMy WebLinkAboutOpinion - Ethics Review Board - 10/22/2012 - Opinion No. 2012-2RESOLUTION 2012-104
OF THE COUNCIL OF THE CITY OF FORT COLLINS
ACCEPTING ADVISORY OPINION AND RECOMMENDATION NO. 2012-2
OF THE ETHICS REVIEW BOARD
WHEREAS, the City Council has established an Ethics Review Board (the "Board")
consisting of three members of the City Council; and
WHEREAS, the Board is empowered under Section 2-569 of the City Code to render
advisory opinions and recommendations regarding actual or hypothetical situations of
Councilmembers or board and commission members of the City; and
WHEREAS, the Ethics Review Board met on October 22, 2012 and October 30, 2012, to
consider whether Mayor Karen Weitkunat has a conflict of interest in participating in decisions of
the City Council and/or the Urban Renewal Authority Board pertaining to the possible
redevelopment of the Foothills Mall; and
WHEREAS, the Board has issued an advisory opinion with regard to this matter; and
WHEREAS, Section 2-569(e) of the City Code provides that all advisory opinions and
recommendations of the Board be placed on the agenda for the next special or regular City Council
meeting, at which time the City Council shall determine whether to adopt such opinions and
recommendations; and
WHEREAS, the City has reviewed the opinion and recommendations of the Board and
wishes to adopt the same.
NOW, THEREFORE, BE IT RESOLVED BY THE COUNCIL OF THE CITY OF FORT
COLLINS that Opinion No. 2012-2 of the Ethics Review Board, a copy of which is attached hereto
and incorporated herein by this reference as Exhibit"A,"has been submitted to and reviewed by the
City Council, and the Council hereby adopts the opinion and recommendations contained therein.
Passed and adopted at a regular meeting of the Council of the City of Fort Collins this 6th
day of November A.D. 2012.
OF pORTOO( Mayor o Te
ATTEST: SEAL
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City Clerk
EXHIBIT "A"
OPINION No. 2012-2 OF THE ETHICS REVIEW BOARD
OF THE CITY COUNCIL OF THE CITY OF FORT COLLINS
October 31, 2012
Backeround.
This advisory opinion and recommendation is being provided to the City Council by the Ethics
Review Board (the `Board") under Section 2-569(e) of the City Code•in response to an inquiry
submitted to the Board by Mayor Karen Weitkunat. The question submitted is whether the
Mayor has a conflict of interest in participating in decisions of either the City Council or of the
Fort Collins Urban Renewal Authority(the "URA") with regard to the possible redevelopment of
the Foothills Mall (the "Mall"), in view of the fact that the Mayor's residence is located in close
proximity to the Mall.
Summary of Opinion and Recommendation.
The majority of the Board believes that, in the judgment of a reasonably prudent person, the
Mayor may realize or experience some direct and substantial benefit or detriment from the
redevelopment of the Mall because of the proximity of her residence to the site of the
redevelopment, and that this benefit or detriment would be different in kind, and not just in
degree, from that experienced by the general public. Therefore, the Board recommends that the
Mayor declare a conflict of interest with regard to any decisions of the City Council related to
the Mall redevelopment.
The Board does not believe that a conflict of interest exists with regard to decisions that the
Mayor may make with regard to the Mall redevelopment as a member of the URA Board of
Directors. That is because the conflict of interest standards applicable to URA Board members
are different than the City Charter standards that are applicable to decisions of the City Council,
and the Mayor clearly does not have the kind of financial interest in the Mall redevelopment
project that would disqualify her from participating in URA decisions related to the project.
The Information Presented to the Review Board.
No formal application has yet been submitted to the City with regard to the possible
redevelopment of the Mall. However, both the City Council and the URA Board of Directors,
which is comprised of the members of the City Council, will likely have proposals related to the
redevelopment presented for their consideration in the near future. The decisions of the City
Council may include the following:
Opinion of the Ethics Review Board
Opinion 12-2
October 31, 2012
Page 2 of 4
1. Financial incentive proposals.
2. Decisions related to the Foothills Mall Metropolitan District Amended Service Plan and
related intergovernmental agreement regarding the operation and maintenance of public
facilities.
3. Decisions related to the Youth Activity Center lease, which the City currently operates in
a building on the Mall property.
The Council would also be called upon to hear any appeal of the Planning and Zoning Board's
decisions related to the Mall, if such an appeal is filed.
In addition, the URA board will be making decisions related to the Mall, including possible
approval of a resolution authorizing an agreement to negotiate with Alberta Development
Partners, LLC ("Alberta"), the developer of the Mall, and a resolution authorizing the acquisition
of certain property interests by eminent domain actions that would, if approved, make the Mall
redevelopment more likely.
Attached to this Opinion as Exhibit "1" is a general description of the work that Alberta intends
to undertake during the course of the redevelopment. It appears that the redevelopment will
include not only the reconstruction of retail establishments at the Mall but also multi-family
residential development, both of which may significantly increase the amount of vehicular traffic
in and out of the Mall property.
The Mayor's residence is located approximately 350 feet from the Mall redevelopment site, on
the other side of Swallow Road. The "notice zone" within which neighboring property owners
will receive written notice of the Mall redevelopment project under Section 2.2.6 of the City's
Land Use Code (the "LUC") has been established at 1,000 feet. The reason that notice of a
proposed development,project is mailed to persons within this zone is to ensure the owners of
properties that may be directly affected by the project can express their views to City staff about
the project as it is being reviewed by the City, and can also appear before the City's decision
makers, including the City Council, to express any concerns they might have.
The Mayor has indicated that she does not anticipate that the redevelopment project will have
any significant impact on the value of her residence or the quality of life that she enjoys as a
resident of the area. She points out that the Mall and its related traffic impacts already exist, and
that the redevelopment proposal is unlikely to affect neighboring properties in the same way or
to the same extent that a"greenfield" development proposal might.
To better assess whether the Mall redevelopment may have a direct and substantial impact on the
value of properties in close proximity to the Mall, the Board inquired of City staff, who in turn
contacted several appraisers and one real estate broker. Staff reported that there was a consensus
Opinion of the Ethics Review Board
Opinion 12-2
October 31, 2012
Page 3 of 4
among those they interviewed that, at least over the long term (the next ten years), properties
close to the Mall will increase in value as a result of the Mall redevelopment. There was also an
indication that neighboring properties could experience a negative, rather than positive, impact if
the redevelopment significantly impacts traffic flows or views or generates additional noise or
lighting. The consensus was that properties closer to the main access areas of the Mall would be
more significantly impacted, one way or the other, than those farther away.
Opinion and Recommendations.
The Board considered the information provided by the Mayor and the staff in light of the conflict
of interest provisions of the City Charter, which are attached as Exhibit 'S" It is clear to the
Board that the Mayor does not have a "financial interest" in the upcoming Council decisions
about the Mall redevelopment, as that term is defined in the Charter. The closer question is
whether she has a "personal interest," that is, whether, in the judgment of a reasonably prudent
person, the Mayor "would realize or experience some direct and substantial benefit or detriment
different in kind from that experienced by the general public" if she were to participate in City
Council decisions that will make the redevelopment of the Mall more or less likely.
In view of the information presented to the Board, the majority of the Board (Councilmembers
Manvel and Poppaw) believes that the Mayor does have a conflict of interest under this standard
and should not participate in City Council decisions related to the Mall redevelopment.
Councilmembers Manvel and Poppaw hold this opinion primarily because it appears likely,
based upon the information provided by City staff, that the redevelopment of the Mall will, at
least over time, significantly increase the value of the Mayor's residence, especially in view of
the blighted conditions that presently exist at the Mall. Conversely, if the Mall redevelopment
negatively impacts nearby properties in terms of traffic, lighting, noise and views, these impacts
would be different in kind from those experienced by the rest of the community.
The third member of the Board, Councilmember Kottwitz, believes that the Mayor does not have
a conflict of interest since there is no clear indication that either the property values or quality of
life of persons residing in close proximity to the Mall will be directly and substantially affected
by the Mall redevelopment in a way that is different from the general public.
In arriving at its opinion and recommendation, the Board considered previous opinions and
recommendations provided by the Board in Opinions No. 1999-8 and 2004-1, including the
various factors that the Board has recommended be considered in this kind of situation. The
factors that the Board has considered include: the size of the group that will likely be affected in
the same way and to the same extent as the Councilmember who is the subject of the inquiry; the
magnitude of the potential financial or personal impact that the Councilmember may experience;
the need for the Councilmember to participate in the upcoming decision(s) as an elected
representative; and how close the connection is between the upcoming decision(s) and the
potential impact on the Councilmember. However, the Board disagrees with the
Opinion of the Ethics Review Board
Opinion 12-2
October 31, 2012
Page 4 of 4
recommendation contained in Opinion 1992-8 that Councilmembers who are faced with any kind
of official capacity decision involving public or private property located within 500 feet of their
residence should always recuse themselves on the assumption that the proximity of the property,
in itself, creates a conflict of interest. Instead, the Board believes that, while such proximity
should automatically call for Board review of the situation, each such situation should be
considered on a case-by-case basis, applying the factors recited above.
As to the Mayor's ability to participate , in URA Board decisions regarding the Mall
redevelopment, all three Board members agree that no conflict of interest exists under the state
conflict of interest laws that are applicable to the URA Board. The statutory conflict of interest
rule that applies specifically to URA Board members is limited to situations in which URA
Board members have a financial interest in the projects that they are considering, and the other,
more general ethical rules and principles for "local government officials and employees" do not
speak to the Mayor's situation. The ethical rule that is contained in the URA statute reads as
shown below.
31-25-104(3) No commissioner, other officer, or employee of an authority nor
any immediate member of the family of any such commissioner, officer, or
employee shall acquire any interest, direct or indirect, in any project or in any
property included or planned to be included in any project, nor shall he have any
interest, direct or indirect, in any contract or proposed contract for materials or
services to be furnished or used in connection with any project.
Because the Mayor has no interest, direct or indirect, in the Mall redevelopment project, she has
no conflict of interest in URA decisions related to the project. However, the Board believes that,
because the URA Board consists of the members of the City Council, the same ethical rules
should apply to the URA as apply to the City. This change can be accomplished through an
amendment to Section 2-483 of the City Code because the City Charter exempts the officers and
employees of its authorities from its conflict of interest rules only if the City Code expressly
authorizes such an exemption, which it presently does. Therefore, the Board recommends that
Section 2-483 be amended so as to eliminate that exemption.
This advisory opinion was reviewed and approved by Councilmembers Ben Manvel, Lisa
Poppaw and Aislinn Kottwitz, as regular members of the Ethics Review Board, for distribution
to members of the Council and for distribution to the City Clerk, to be maintained in the
permanent file of opinions of the Ethics Review Board.
Dated this 31s`day of October, 2012
S ephen jr. Roy
City Attorney
SEM
ARCH)TECTS
FOOTHILLS
Foothills is an.existing one-level covered mall containing approximately 250,000 square feet of
small shop GLA and three (3)single-level department stores located along the east side of
College Avenue, north of Monroe Drive in Fort Collins, Colorado.
The Owner intends to undertake a major redevelopment of the project that will include the
deconstruction df approximately 93,000 square feet of existing in-line-tenant GLA,'67,000
square feet mall common area and back of house,two (2)anchor buildings totaling 150,000
square feet and a number of freestanding buildings located'on outparcel lots surrounding the
mall. The new work includes redevelopment of the entire site, incorporating mall interior
renovations and new mall entries together with the development of outdoor lifestyle and
entertainment components and freestanding retail buildings along College Avenue: Multi-unit
residential on the eastern edge of the site offers a transition between the adjacent
neighborhoods and the commercial core of the current mall area and incorporates key
stormwater facilities within its design.
The proposed redevelopment will create a project that embodies a contemporary Colorado-
style. The design incorporates natural'materials that'are in harmony with the traditional
architecture of historic downtown. The project will be a unique combination of indoor
shopping, open air eateries and outdoor shops, as well'as green spaces and a great lawn that
functions as community gathering place. Outdoor spaces will be enhanced with beautiful
Colorado style landscape,pedestrian amenities, entertainment opportunities,and exciting
fountains. The design allows for opportunities for lifestyle, shopping,dining and entertainment.
The project will be a local,'as well as regional draw.
The redevelopment work will be permitted/entitled in phases described by their corresponding
DCP's roughly"as follows: 1 . •
DCP 1 Selective Deconstruction and Site Preparation
DCP 2 Overall Site Improvements
DCP 3 Mall Renovation
DCP 4 Parking Structure
DCP 5 West Green Shops
DCP 6 East Green Shops
DCP 7 North College Avenue Shops
DCP 8 South College Avenue Shops
DCP 9 West and East Green Amenities
DCP 10 Residential
DCP 1 SELECTIVE DECONSTRUCTION
1. Deconstruction of'a lai'ge'po'nion of the existing mall building(tenant GLA, common area
and BOH), including provisions for temporary barricading and egress.
2. Deconstruction of existing parking fields and site areas affected by new work.
98 Spruce Street, Suite 201 1 Denver Colorado 80230
EXHIBIT
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Foothills narrative SEMARCHITECTS
8/22/12
3. Inventory of existing vegetation and implementation of an approved tree harvesting,
transplantation, and mitigation strategy.
4. Implementation of an approved relocation of the Larimer County Ditch currently.present on
the South East quadrant•of the site.
DCP 2 SITE IMPROVEMENTS
1. Parking designs to reduce the site's heat island effect. .
2. Pedestrian linkages throughout the site including travel through the mall structure and links
to the Mason Street Corridor.
3. Pedestrian linkages throughout the site including travel through the mall structure and links
to the Mason Street Corridor.
4. Drainage improvements employing 100%biological treatment for stormwater.
5.. Balanced grading concepts minimizing soil import/export from the site.
6. Enhanced landscaping,plazas, and amenities increasing open•space from existing
quantities.
DCP 3 MALL RENOVATION
1. Creation of a new East/.West mall concourse connection linking pedestrian traffic through
the project site. New roof structure running the width of the mall connecting the new east
and west entries.
2. New mall entry from the west with porte-cochere
3. New mall entry from the east
4. New mall entry near Macy's,.with new retail box adjacent
5. New mall entry facing College Ave,with end court between new junior anchors
6. New junior anchoi tenants and entertainment tenant at south end of mall(pad only)
7. New or enhanced exterior wall finishes on existing walls
8. New floor finishes throughout the existing interior common.area
9. New ceilings and lighting throughout the existing interior common area including new
clerestory windows within existing high bay exterior walls
10.New transition ramps/stairs at four existing locations
11.New interior FFE,planters and landscaping throughout the existing interior common area
12.New fountain in center court
13.New public toilet rooms
14.New mall offices (the existing offices are in an area to be deconstructed)
15.New interior/exterior signage and way finding package .
16.Parking field modifications to the east and south
17. Parking lot lighting and exterior lighting
18.New service courts associated with modifications to the existing mall building
19.Three new exterior entries to the Macy's anchor store
20.New and modified hardscape/landscape around the perimeter of the mall
21.Review/rework existing mechanical, electrical, fire sprinkler and fire alarm systems
throughout•the existing interior'common area
22. Entry icon/signage
Page 2
Foothills narrative SEMARCHITECTS
8/22/12
DCP 4 PARKING STRUCTURE
1. 4 levels or structured parking above a grade level of parking
2. Concierge Area including Valet
3. Public Family Toilets and Lounge
DCP 5 WEST GREEN SHOPS
1. Four new freestanding retail shell buildings
2. Hardscape/landscape areas around and between the new buildings
3. Develop parking areas adjacent new buildings
4. Exterior lighting
5. Entry icon/signage from East Foothills Parkway
DCP 6 EAST GREEN SHOPS
1. Four new freestanding restaurant,shell buildings
2. New cinema building
3. Hardscape/landscape areas around and between the new buildings
4. Parking field modifications to the southeast
5. Parking lot lighting/exterior lighting
6. New service courts associated with restaurant buildings
DCP 7 NORTH COLLEGE AVENUE SHOPS
1. Three new freestanding retail/restaurant buildings
2. Hardscape/landscape areas around and between the new buildings,"and along College"
Avenue.
3. Entry icon/signage from College Ave
4. New service courts associated with retail/restaurant tenant buildings
S. Develop parking areas adjacent new buildings including new parking field to the northwest.
6. Parking lot lighting/exterior lighting
DCP 8 SOUTH COLLEGE AVENUE SHOPS
1. Three new freestanding retaiV restaurant buildings
2. Hardscape/landscape areas around and between the new buildings, and along College
Avenue.
3. Entry icon/signage from College Ave
4. New service courts associated with retail/restaurant tenant buildings
5. Develop parking areas adjacent new buildings including new parking field to the northwest.
6. Parking lot lighting/exterior lighting
DCP 9 WEST AND EAST GREEN AMENITIES
1. Develop new landscaped "green" lifestyle components with seasonal features, ice skating
rink/elevated stage/gathering area and amenities
2. Mature landscaped areas with native materials
3. Town Center presence at East Green
Page13
Foothills narrative
SEM .
A KC FI 1 T E CTS
8/22/12
4. Pedestrian connection gateways at East/West concourse,to Mall and activity nodes within
the pedestrian circulation network.
DCP 10 RESIDENTIAL
1. Develop Multi-Unit Residential and associated site improvements.
Execution of the project will include numerous sustainable practices during its implementation
including:
Reuse of existing building components
Redesign of parking areas to decrease heat island effect
Enhanced pedestrian connections to the areas surrounding the development
Increased areas of enhanced landscaping and amenities
Incorporation of xeric landscape materials
Implementation of mature vegetation mitigation and relocation strategies
Salvage and reuse of existing topsoil
Recycling of crushed paving
Incorporation of regional materials
Biological treatment for stormwater management
Balanced site design quantities
Construction waste stream management .
Recycling of refrigerants
Recycling of construction materials
The redevelopment of Foothills offers a comprehensive mixed use development solution to
both local and regional challenges the current Foothills Fashion Mall.represents. It offers
market-driven opportunities with a focus on lifestyle, environment,and amenities by enhancing
the current commercial environment. This proposal describes the elements that comprise this
design and is offered for review and approval to the City of Ft Collins as a component of the
Development Review process.
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Page
Art.IV§6
3) the interest that an officer, employee or relative
has as a recipient of public services when such ser-
vices are generally provided by the city on the same
terms and conditions to all similarly situated citizens,
regardless of whether such recipient is an officer,
employee or relative;
4) the interest that an officer, employee or relative
has as a recipient of a commercially reasonable loan
made in the ordinary course of business by a lending
institution, in such lending institution;
5) the interest that an officer, employee or relative
has as a shareholder in a mutual or common invest-
ment fund in the holdings of such fund unless the
shareholder actively participates in the management
of such fund;
6) the interest that an officer, employee or relative
has as a policyholder in an insurance company, a de-
positor in a duly established savings association or
bank, or a similar interest-holder, unless the discre-
tionary act of such person, as an officer or employee,
could immediately, definitely and measurably affect
the value of such policy,deposit or similar interest;
7) the interest that an officer, employee or relative
has as an owner of government-issued securities un-
Section 9. Conflicts of Interest.less the discretionary act of such owner, as an officer
Definitions. For purposes of construction of this Sec. or employee, could immediately, definitely and
n 9, the following words and phrases shall have the measurably affect the value of such securities;or
following meanings: 8) the interest that an officer or employee has in the
Business means a corporation, partnership, sole proprie- compensation received from the city for personal
torship, firm,:enterprise, franchise, association, organiza- services provided to the city as an officer or employ-
tion, self-employed individual, holding company, joint ee.
stock company, receivership; trust, activity or entity. Officer or employee means any person holding a position
Financial interest means any interest equated with mon- by election, appointment or.employment in the service of
ey or its equivalent. Financial interest shall not'include: the city, whether part-time or full-time, including .a
member of any authority, board, committee or commis-
l) the interest that an officer, employee or relative sion of the city,other than an authority that is:
has as an employee of a business, or as a holder of an
ownership interest in such business, in a decision of l) established under the provisions of the Colorado
idSRevisedtatues;any public body, when the decision financially be re- Rev
fits or otherwise affects such business but entails no 2) governed by state statutory rules of ethical con-
foreseeable, measurable financial benefit to the of- duct; and
ficer, employee or relative;
3) expressly exempted from the provisions of this
2) the interest that an officer, employee or relative Article by ordinance of the Council.
has as a nonsalaried officer or member of a nonprofit
corporation or association or of an educational, reli- Personal interest means any interest (other than a finan-
gious, charitable, fraternal or civic organization in cial interest) by reason of which an officer or employee,
the holdings of such corporation, association or or- or a relative of such officer or employee, would, in the
aanization;
EXHIBIT
Supp.No,103
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judgment of a reasonably prudent person, realize or expe- 3) Interests in other decisions. Any officer or em-
rience some direct and substantial benefit or detriment ployee who has, or whose relative has, a financial or
different in kind from that experienced by the general personal interest in any decision of any public body
public. Personal interest shall not include% of which he or she is a member or to which he or she
1) the interest that an officer, employee or relative makes recommendations, shall, upon discovery
thereof, disclose such interest in the official recordshasamemberofaboard, commission, committee,
of the,city in the manner prescribed in subsection (4)or authorityhority of another governmental entity or of a
hereof, and shall refrain from voting on, attemptingnonprofitcorporationorassociationorofaneduca-
tional, religious, charitable, fraternal, or civic organi- to influence, or otherwise participating in such deci-
zction;sion in any manner as an officer or employee.
2) the interest that an officer, employee or relative 4) Disclosure procedure. If any officer or employ-
ee has any financial or personal interest requiringhasinthereceiptof,public services when such set-
vices are generally provided by the city on the same
disclosure under subsection (3) of this section, such
terms and conditions to all similarly situated citizens; person shall immediately upon discovery thereof de-
clare such interest by delivering a written statementor
to the City Clerk, with copies to the City Manager
3) the interest that an officer or employee has in the and, if applicable, to the chairperson of the public
compensation, benefits, or terms and conditions.of body of which such person is a member, which
his or her employment with the city. statement shall contain the name of the officer or
Public body means the Council or any authority, board, employee, the office or position held with the city by
such person, and the nature of the interest. If said of-
fice
service area department or bf-
ficer or employee shall discover such financial orTiceofthecity.
personal interest during the course of a meeting or in
Relative means the spouse or minor child of the officer or such other circumstance as to render it practically
employee,any person claimed by the officer or employee impossible to deliver such written statement prior to
as a dependent for income tax purposes, or any person action upon the matter in question, said officer or
residing in and sharing with the officer or employee the employee shall immediately declare such interest by
expenses of the household. giving oral notice to all present,:including a descrip- %
b) Rides of conduct concerning conflicts of interest. tion of the nature of the interest. .
1) Sales to the city. No officer or employee, or rela- 5) Violations. Any contract made in violation of
this Section shall be voidable by the city. If voidedfive
in
such officer or employee, shall have a
al or within one (1) year of the date of execution thereof,cial interest in the sale to the city of any real or
personal property, equipment, material, supplies or the party obtaining payment by.reason of such con-
services, except personal services provided to the tract shall, if required by the city;forthwith return to
city as an officer or employee, if: the city,all or any designated portion of the monies
received by such individual from the city by reason
a. such officer employee is n member of the of said contract, together with interest at the lawful
Council; maximum rate for interest on judgments.
Res.No.71.12,2.11-71.approved,election-4-6-7 1:Ord.No. 155,b. such officer or employee exercises, directly 1988. 12-20.88,approved,election 3-7-89;Ord. No. 10. 1997,§ I,
or indirectly; any decision-making authority 274-97,approved,election 4-8-97;Ord. No.22.2001.§2,2-20-01,
concerning such sale; or approved.election4-3-01)
c. in the case of services, such officer or em-
ployee exercises any supervisory authority over
the services to be rendered to the city.
2) Purchases front the city. No officer, employee
or relative shall, directly or indirectly, purchase any
real or personal property from the city, except such
property as is offered for sale at an established price,
and not by bid or auction, on the same terms and
conditions as to all members of the general public.
i
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Supp.No.103