HomeMy WebLinkAbout2021CV30425 - Save The Poudre And No Pipe Dream Coporation V. Northern Colorado Water Conservancy District, Northern Integrated Supply Project Water Activity Enterprise, The City Of Fort Collins - 039 - Motion To Partially Dismiss Larimer County District Court
201 La Porte Ave, Suite 100
Fort Collins, CO 80521
COURT USE ONLY
SAVE THE POUDRE, and
NO PIPE DREAM CORPORATION
Plaintiffs
v.
NORTHERN COLORADO WATER CONSERVANCY
DISTRICT,
NORTHERN INTERGRATED SUPPLY PROJECT
WATER ACTIVITY ENTERPRISE, and
THE CITY OF FORT COLLINS, a Colorado home rule city
and municipal corporation,
Defendants.
Attorneys for Northern Colorado Water Conservancy
District and Northern Integrated Supply Project Water
Activity Enterprise:
Bennett W. Raley, #13429
Peggy E. Montaño, #11075
William Davis Wert, #48722
Mirko L. Kruse, #52488
TROUT RALEY
1120 Lincoln Street, Suite 1600
Denver, CO 80203
Telephone: (303) 861-1963
FAX Number: (303) 832-4465
email: braley@troutlaw.com, pmontano@troutlaw.com,
dwert@troutlaw.com, mkruse@troutlaw.com
Case No. 21CV30425
DEFENDANTS NORTHERN COLORADO WATER CONSERVANCY DISTRICT
AND NORTHERN INTEGRATED SUPPLY PROJECT WATER ACTIVITY
ENTERPRISE’S REPLY ON ITS C.R.C.P. 12(b)(5) MOTION TO PARTIALLY
DISMISS PLAINTIFFS’ FIRST AMENDED COMPLAINT
Defendants, the Northern Colorado Water Conservancy District (“Northern Water”) and
Northern Integrated Supply Project Water Activity Enterprise (“NISP Enterprise” and together
“the Northern Parties”) submit this Reply to Plaintiffs’ Response in Opposition (“Response”) to
DATE FILED: October 22, 2021 4:20 PM
FILING ID: 7BF34BEDD8CDA
CASE NUMBER: 2021CV30425
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the Northern Parties’ C.R.C.P. 12(b)(5) Motion to Partially Dismiss Plaintiffs’ First Amended
Complaint (“Motion”).
INTRODUCTION
Plaintiffs’ Response avoids directly addressing many of the points and authority raised in
the Motion, electing instead to make arguments to distract from the issues at hand. This Reply
responds to those arguments and establishes why, as a matter of law, Plaintiffs cannot sustain their
claims relating to the Board of Northern Water’s (“Board”) actions under the Location and Extent
Review Statute, C.R.S. § 31-23-209 (“L&E Statute”).
ARGUMENT
I. Northern Water’s Board Acted within Its Authority under the L&E Statute to
Overrule Disapproval of the NISP Enterprise’s Application.
A. Plaintiffs Misconstrue the Legal Standard under C.R.C.P. 12(b)(5).
Plaintiffs contend that the Motion should be denied on the basis that Plaintiffs’ claims
“present[] issues of first impression” and therefore “there is no substantive case law requiring
dismissal of any of Plaintiffs’ claims.” Response at 3. In support of this argument, Plaintiffs point
to a footnote in the Motion explaining that although there have not been judicial decisions
interpreting the L&E Statute applicable to municipalities, there have been several persuasive
decisions interpreting its sister statute that applies to counties, section 30-28-110(1)(a), C.R.S. See
Response at 3 (citing Motion at 5 n.1). This argument is not a proper basis for avoiding dismissal
of their claims.
First, it is important to note that legal issues of first impression can be decided at the
dismissal stage. Just because a certain legal issue is not controlled by directly “on point” precedent
does not mean the reviewing court must defer a ruling on the issue until after the dismissal stage.
See, e.g., Coyle v. State, 2021 COA 54, ¶ 1, 492 P.3d 366, 368 (affirming district’s courts dismissal
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under C.R.C.P. 12(b)(5) deciding legal issue of first impression); Abu-Nantambu-El v. State, 2018
COA 30, ¶ 1, 433 P.3d 101, 102 (same).
Additionally, as the Northern Parties noted in their Motion, the precedent interpreting the
statute for counties should be authoritative as to this Court’s interpretation of the L&E Statute for
municipalities. Most significantly, the statutes employ very similar language:
[N]o road, park, or other public way, ground,
or space, no public building or structure, or
no public utility, whether publicly or
privately owned, shall be constructed or
authorized in the unincorporated territory of
the county until and unless the proposed
location and extent thereof has been
submitted to and approved by such county or
regional planning commission.
§ 30-28-110(1)(a).
[N]o street, square, park or other public way,
ground or open space, public building or
structure, or publicly or privately owned
public utility shall be constructed or
authorized in the municipality or in such
planned section and district until the location,
character, and extent thereof has been
submitted for approval by the commission.
§ 31-23-209.
In addition, both statutes are implemented through, and referred to as, “location and extent”
review processes. Compare City of Fort Collins Land Use Code (“LUC”) § 2.1.3(E) (describing
the SPAR process to review the “location, character and extent” of projects “under section 31-23-
209, C.R.S.”) with Larimer County Land Use Code, § 6.4.4.B (outlining the procedure for
“location and extent review in accordance with C.R.S. § 30-28-110”). And although the Supreme
Court was applying the statute for counties in Hygiene Fire Protection District, the Court opined
generally on the codification of the long-standing rule that political subdivisions may override
“county or municipal” zoning regulations. Bd. of Cty. Com’rs of Cty. of Boulder v. Hygiene Fire
Protection Dist., 221 P.3d 1063, 1068-69 (Colo. 2009) (emphasis added). Under the separate but
very similar statutes governing the location-and-extent review processes for cities and counties,
there is no basis to treat one differently than the other. Therefore, case law interpreting section
30-28-110(1)(a) is authoritative as to this Court’s interpretation of section 31-23-209 in ruling on
the Motion.
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B. Plaintiffs’ Response Does Not Contest That Northern Water’s Board is the
Governing Body of the NISP Enterprise.
Plaintiffs do not address the authority cited in the Motion explaining that the Board of
Directors of Northern Water is the governing body of the NISP Enterprise and had the authority
under the L&E Statute to overrule the Planning Commission. See Response at 5. Instead,
Plaintiffs argue that their interpretation of the L&E Statute required Northern Water, not the NISP
Enterprise, to submit the SPAR application. Id. Plaintiffs are incorrect.
The L&E Statute contemplates the application being submitted by “the governmental body
having jurisdiction” over the project. § 31-23-209. As its name suggests, the NISP Enterprise is
the governmental body having jurisdiction over the development of NISP. See Amend. Compl., ¶
16 (“NISP is a raw water development and pipeline project proposed by the Enterprise . . . .”).
And NISP includes construction of the specific project at issue here, the Poudre River Intake and
Pipeline. See Amend. Compl., ¶ 17.
The L&E Statute then states that if the planning commission disapproves of the application,
the decision to overrule that decision is made by “such governmental body.” § 31-23-209. In this
instance, Northern Water owns the NISP Enterprise, see Amend. Compl. ¶ 11, and the Board of
Northern Water governs the NISP Enterprise pursuant to the Water Activity Enterprises Act,
§ 37-45.1-103(3) (“The governing body of the water activity enterprise shall be the governing
body of the district which owns the enterprise . . . .”); see also Bennett Bear Creek Farm Water &
San. Dist. v. City & Cty. of Denver, 928 P.2d 1254, 1267 n.18 (Colo. 1996) (“Local governments
are also empowered to establish water activity enterprises under control of the governing body of
such ‘districts.’”).
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C. The NISP Enterprise Did Not Need to Own or Operate Parcels Prior to its
SPAR Submission.
Plaintiffs continue to assert that SPAR requires the applicant to own or operate the parcels
upon which the project will be constructed at the time the application is submitted. Response at
6. This requirement is simply not found in the LUC and Plaintiffs’ Response does little to refute
the proper interpretation offered by the Northern Parties in their Motion.
As the Northern Parties point out, and as Fort Collins has agreed, see Fort Collins’
Response to Plaintiffs’ Motion for Preliminary Injunction, the Fort Collins Municipal Code
expressly states that when interpreting its provisions, the past tense must be interpreted to include
the present and future tenses. Fort Collins Muni. Code § 1-2 (“Tense. Words used in the present
or past tense include the future as well as the present or past.”). Therefore, the Plaintiffs
erroneously attribute significance to the LUC’s usage of the past tense “owned or operated” to
require that the NISP Enterprise needed to own or operate the parcel of land upon which the Poudre
River Intake and Pipeline will be constructed at the time of the SPAR application.
In addition, “owned or operated” does not modify “parcels” alone; it modifies the entire
term “improvements to parcels.” This is clear because the LUC uses “improvements to parcels”
to broadly capture any type of public project, that is, any type of man-made improvement to raw
land, which is consistent with the LUC’s definition of “improvement.” See LUC § 5.1.2 (defining
“improvement” to mean “any man-made, immovable item which becomes part of, is placed upon
or is affixed to real estate”). As further support, “operated” naturally modifies “improvements to
parcels” (i.e. projects) because one would not normally describe a “parcel” alone as something
“operated.” Because “owned or operated” modifies “improvements to parcels,” it also becomes
clear that “owned or operated” cannot take on the significance Plaintiffs attribute to it. These
improvements are merely concepts at the time of their review under SPAR—they have not been
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constructed. Yet Plaintiffs would require them to be “owned or operated” at the time of SPAR
review. More naturally, the use of the past tense “owned or operated” was simply a default verb
tense chosen by the drafters, sufficient to communicate the real requirement of this clause that only
proposed improvements owned or operated “by public entities” may utilize the SPAR process.
Other SPAR provisions in the LUC reaffirm that the import of this language was merely to
clarify that only public projects qualify for SPAR review. Subsection 2.1.3(E)(2), entitled
“Applicability,” simply states, “A Site Plan Advisory Review [SPAR] shall be applied to any
public building or structure.” See also LUC § 2.16.2(C). Nowhere in the SPAR provisions of the
LUC is it suggested that prior land ownership is a necessary pre-condition to filing an application.
Also important is the fact that the L&E Statute itself contains no suggestion that the
underlying land must be owned before location-and-extent review can proceed. § 31-23-209; see
also Bd. of Cty. Comm’rs of La Plata Cty. v. Bd. of Adjustment of Durango, 768 P.2d 1250, 1251
(Colo. App. 1988) (noting simply that section 209 is applicable “to public buildings to be
constructed or authorized.”); City of Boulder v. Hygiene, 221 P.3d 1063, 1067 (Colo. 2009)
(explaining that location-and-extent review provides “an opportunity to review and approve or
disapprove a proposed public project”).
Plaintiffs’ Response does not attempt to rebut this reasoning and the much more sensible
interpretation that section 209 was simply a default verb tense chosen by the drafters, sufficient to
communicate the real requirement of this clause that only improvements owned or operated “by
public entities” may utilize the SPAR process. See Response at 6-8. Instead Plaintiffs’ Response
focuses on a preemption analysis, which the Court only needs to consider in the event Plaintiffs’
interpretation is accepted. Id.
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D. Plaintiffs Incorrectly Assert the Board’s Action was Quasi-Judicial.
In its First Amended Complaint, Plaintiffs raise several due process challenges to the
Board’s decision to overrule the Planning Commission pursuant to the L&E Statute. Amend.
Compl., ¶¶ 59(g), 59(h), 66(g) & 66(h). The Motion explains why these challenges fail as a matter
of law because the Board’s action was quasi-legislative in nature and therefore does not implicate
the procedural safeguards of due process. Motion at 8-11. In response, Plaintiffs disagree that
this action was quasi-legislative. Response at 8-10. The Plaintiffs also assert that the Northern
Parties’ position “stands in stark contrast” with their response to Plaintiffs’ motion for a
preliminary injunction where Northern described the proceeding Plaintiffs’ sought to enjoin there
as a “typical quasi-judicial proceeding.” Id. at 9.
Plaintiffs overlook, however, that their original complaint and concurrent preliminary
injunction motion were challenging a SPAR proceeding yet-to-be-held by the Planning
Commission. See Plaintiffs’ Complaint, ¶ 87 (June 9, 2021); Plaintiffs’ Motion for Temporary
Restraining Order and/or Preliminary Injunction at 9 (June 9, 2021). Their First Amended
Complaint, by contrast, focuses not on the actions in the SPAR proceeding undertaken by the
Planning Commission but on the actions in the August 12, 2021, proceeding undertaken by the
Board. See Amend. Compl., ¶¶ 59(g), 59(h), 66(g) & 66(h).
The Board’s decision to overrule the Planning Commission constituted a separate action
taken by a separate governing body. That action was quasi-legislative in nature because the
Board’s decision was inherently discretionary, policy driven, and forward-looking. See City and
Cty. of Denver v. Eggert, 647 P.2d at 222 (noting that quasi-legislative action “requires the
balancing of questions of judgment and discretion”). The Board’s decision did not apply pre-
determined criteria set forth in the L&E Statute or second-guess the Planning Commission’s
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decision under the LUC. The purpose of the decision made by the Board under the L&E Statute
was to consider the feedback provided by the Planning Commission and ultimately decide whether
the project should continue forward toward development. Plaintiffs’ Response does not
distinguish Farmers Water Development Co. v. Colorado Water Conservation Board, where the
Court similarly held that the Colorado Water Conservation Board’s (“CWCB”) decision to file an
application to appropriate an instream flow right “to preserve the natural environment” was a
quasi-legislative action because the decision involved a policy determination within the CWCB’s
discretion. 2015 CO 21, ¶ 26, 346 P.3d 52, 59-60.
Regardless, if the Court does not wish to rule on these grounds, it need not do so, because
Plaintiffs’ due process challenges equally and independently fail because, as discussed in the next
subsection, Plaintiffs have not alleged a constitutionally protected property interest.
E. Plaintiffs Do Not Identify a Property Interest Protected Under Due Process
and Do Not Distinguish Hillside Community Church.
Plaintiffs have not alleged a constitutionally protected property interest and therefore their
grievances cannot rise to the level of constitutionally redressable due process claims. Confusingly,
Plaintiffs respond that the Northern Parties are the entities without a property interest. Response
at 11. The Northern Parties do not raise a due process challenge in this litigation and therefore this
contention is irrelevant. More to the point, Plaintiffs assert that their property interest stems from
their status as taxpayers and their ability as members of the public to access and use some of the
parcels that the Poudre River Pipeline would be constructed through for recreation.1 Id. These
allegations fall far short of establishing a constitutionally protected property interest.
1 This argument resembles an argument that Plaintiffs’ have standing in this suit. Standing poses
a separate (and lesser) hurdle that Plaintiffs are required to overcome. See Stanczyk v. Poudre
School Dist. R-1, 2020 COA 27M, ¶¶ 40, 83-86, __P.3d __, __ (determining that teacher had
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In general, protected property interests include physical property and certain entitled
benefits. Hillside Cmty. Church v. Olson, 58 P.3d 1021, 1025 (Colo. 2002). The property interest
must be exclusive to the general public, as “[t]he hallmark of property, the Court has emphasized,
is an individual entitlement grounded in state law . . . .” Logan v. Zimmerman Brush Co., 455
U.S. 422, 430 (1982). As such, courts have routinely rejected purported property interests in the
mere non-exclusive privilege to access and enjoy public lands and spaces. See Meyers v. City of
New York, 812 Fed. App’x 11, 16 (2d. Cir. 2020) (holding that zoning laws granting access to
public park “run to the public generally” and do not constitute protected property interests); Brown
v. United States Forest Service, 465 F.Supp.3d 1119, 1128 (D. Or. 2020) (ruling that recreationist
did not identify property interest in keeping roadway gate open to public areas used for recreation);
Wayfield v. Town of Tisbury, 925 F.Supp. 880, 881 (D. Mass. 1996) (holding plaintiff had no
property interest in access to public library). Therefore, Plaintiffs’ ability to access and recreate in
Fort Collins Natural Areas—common to any member of the public—does not constitute private
“property” that implicates the attendant guarantees in our state and federal constitutions protecting
against deprivation without due process.
Nor can Plaintiffs create “property” out of expectations for how the Board’s August 12,
2021, proceeding should have been conducted. See Hillside Cmty. Church, 58 P.3d at 1023
(“[P]rocedural guarantees stemming from state law or local ordinance do not create a
constitutionally cognizable property interest.”). Plaintiffs attempt to distinguish Hillside
Community Church and related court of appeals decisions by noting that the plaintiffs in those
cases brought their due process claims under 42 U.S.C. § 1983, not C.R.C.P. 57. This is a
standing to raise due process claim but no protected property interest to sustain it); Del.
Riverkeeper Network v. Fed. Energy Reg. Comm’n, 243 F. Supp.3d 141, 150, 151 (D.D.C. 2017)
(stating that “the threshold” to establish standing compared to a property interest “is lower”).
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distinction without a difference. The elements needed to establish a due process violation remain
the same regardless of the remedial device used to seek vindication of those rights in court. Am.
Mfrs. Mut. Ins. Co. v. Sullivan, 526 U.S. 40, 59 (1999) (“The first inquiry in every due process
challenge is whether the plaintiff has been deprived of a protected interest in ‘property’ or
‘liberty.’”). The requirement to assert a cognizable property interest clearly stems from the Due
Process clause itself, not Section 1983. See Baker v. McCollan, 443 U.S. 137, 144 n.3 (1979)
(stating that Section 1983 “is not itself a source of substantive rights, but a method for vindicating
federal rights elsewhere conferred by those parts of the United States Constitution”).
Plaintiffs go on to argue that property interests can be found where the government has
limited discretion in whether to issue a permit or not, and Plaintiffs then connect this with certain
mandatory and non-discretionary language in the LUC and the L&E Statute. Response at 12-13.
On that basis, Plaintiffs apparently find a property interest. Id. at 13. It is true that state law can
create protectable property interests in certain entitled benefits, and those entitlements are
sometimes found where the government’s discretion in whether to deliver them or not are
substantially limited. These entitlements may come in the form of public employment contracts
or entitled benefits such as disability benefits. Adams Cty School Dist. No. 50 v. Dickey, 791 P.2d
688, 694 (Colo. 1990) (employment contract); Whiteside v. Smith, 67 P.3d 1240, 1247-48 (Colo.
2003) (disability benefits). But Plaintiffs stretch this precept to assert that the language in the LUC
and L&E Statute somehow grants every citizen a property right in the enforcement of the
procedures contained in those provisions. This argument once again attempts to create a “property
right in mere procedure” and runs against the holding in Hillside Community Church. 58 P.3d at
1026.
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F. Plaintiffs Do Not Establish the Vagueness Doctrine’s Applicability to the L&E
Statute.
Plaintiffs contend that the void-for-vagueness doctrine does not just apply to penal statutes
but civil land use statutes as well, citing Sellon v. City of Manitou Springs, 745 P.2d 229, 233
(Colo. 1987) and Hartley v. City of Colorado Springs, 764 P.2d 1216, 1226 (Colo. 1988).
Response at 15. The civil laws analyzed under the doctrine in those cases, however, imposed
zoning regulations and governs the conduct of individuals; they were not merely statutes of
procedure governing the powers of local governments.
In addition, Plaintiffs’ Response does not address at all the separate and independent basis
for why the void-for-vagueness doctrine does not apply here: Plaintiffs cannot challenge the L&E
Statute’s vagueness with respect to the procedures it requires of the Board. People v. Graves, 2016
CO 15, ¶ 19, 368 P.3d 317, 325 (citing Village of Hoffman Estates v. Flipside, 455 U.S. 489, 495
(1982)) (holding that a “litigant cannot complain of the vagueness of the law as applied to the
conduct of others”).
CONCLUSION
For the reasons stated in the Motion and herein, this Court should partially dismiss
Plaintiffs’ First Amended Complaint for declaratory and injunctive relief under C.R.C.P. 12(b)(5).
As a matter of law, Plaintiffs are not entitled to relief for their claims challenging the Board’s
action to overturn the Planning Commission’s disapproval pursuant to the L&E Statute. Under
Rule 12(b)(5), the Court should therefore dismiss this portion of Plaintiffs’ claims, found in
paragraphs 59(a), 59(b), 59(f), 59(g), 59(h), 59(i), 60, 66(a), 66(b), 66(f), 66(g), and 66(h) of their
First Amended Complaint.
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Respectfully submitted: October 22, 2021.
TROUT RALEY
___/s/ Peggy E. Montaño
Peggy E. Montaño, #11075
Bennett W. Raley, #13429
William Davis Wert, #48722
Mirko L. Kruse, #52488
1120 Lincoln Street, Suite 1600
Denver, CO 80203
Telephone: (303) 861-1963
Facsimile: (303) 832-4465
braley@troutlaw.com
pmontano@troutlaw.com
dwert@troutlaw.com
mkruse@troutlaw.com
Attorneys for Defendants, Northern Colorado
Water Conservancy District and Northern
Integrated Supply Project Water Activity
Enterprise
Pursuant to C.R.C.P. 121, a printed or printable copy of the
document bearing the original, electronic, or scanned
signatures is on file in the offices of counsel.
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CERTIFICATE OF SERVICE
I certify that on October 22, 2021, a true and correct copy of the foregoing Defendants
Northern Colorado Water Conservancy District and Northern Integrated Supply Project
Water Activity Enterprise’s Reply on its C.R.C.P. 12(B)(5) Motion to Partially Dismiss
Plaintiffs’ First Amended Complaint was served via the Colorado Courts E-Filing System, on
the following:
Name Attorney Organization
City of Fort Collins Marni L Nathan Kloster Nathan Dumm and Mayer PC
City of Fort Collins Nicholas Poppe Nathan Dumm and Mayer PC
City of Fort Collins John R Duval City Attorneys Office
No Pipe Dream Corporations John McClain Barth John M Barth Attorney at Law
Save the Poudre John McClain Barth John M Barth Attorney at Law
S/ Britta Petersen
E-filed pursuant to C.R.C.P. 121 §1-26 via the
Colorado Courts E-Filing System. A printed or
printable copy of this document bearing the
original, electronic, or scanned signatures is on
file at the office of Trout Raley