HomeMy WebLinkAboutGERRARD ROADWAY DEDICATION - 29-02 - CORRESPONDENCE - LEGAL COMMUNICATIONAPR-09-2001 10:57 P.04
Douglas D. Konkel, Esquire
ATTORNEY AT LAW
April 5, 2001
Page 3
general street system, the loss or limitation of access is a non-compensable exercise of the state's
police power. Troiano v. Colorado Department of Hi iwAys,170 Colo. 484, 463 P:2d 448 (1969);
Radinsky v_ City and County of Denver. 159 Colo. 134, 410 P.2d 644 (1966). Examples of the
proper exercise of the police power include: change of access from direct access to state highway
to indirect access through a frontage road, Davis, su ra., construction of a solid median, Thorton v.
City of Colorado Springs, 173 Colo. 357, 478 P.2d 665 (1970); loss of all access to a particular
street, Department of Highways v. Interstate -Denver West, 791 P.2d 1119,1120- I 121 (Colo. 1990).
When accesses are closed via the police power, the question is whether the closure has
triggered a right of compensation The Colorado Supreme Court has ruled that a landowner is.
entitled to compensation only if the limitation or loss of access rises to the level. of "substantial
impairment of access." Davis, supra. at 664; Interstate -Denver West, supra. at 1121; Shaklee v.
Board of County Commissioners, 176 Colo. 559, 491 P.2d 1366, 1368 (1972). It is highly unlikely
that, given the facts of this situation, the limitation of access results in "substantial impairment of
access." If there are cases that you are aware of that present plausible arguments to the contrary, I
am inviting you to tell me about them.
Sincere
. Paul Eckman
Deputy City Attorney
W PE:med
PC: Cam McNair, City Engineer
Kathleen Reavis, Senior Transportation Planner
TOTAL P.04
APR-09-2001 10:57 P.03
Douglas D. Konkel, Esquire
ATTORNEY AT LAW
April 5, 2001
Page 2
improvements so as to not only make the street as safe as possible for the public but also so as to
keep the street from simply failing as one of the City's major transportation corridors.
You are correct that the Harmony Road Access Plan needs to be amended. You are correct that the
timing of this project, vis-a-vis the amendment to the Harmony Road Access Plan is:awkward. The
City is vigorously pursing an amendment for these changes to the Harmony Road Access Plan, along
with others over the full course of Harmony Road. This amendment is necessary for the protection
of the public health, safety and welfare in order to meet the needs of the City's Transportation Master
Plan and in order to bring traffic flows into balance and to provide for safe and appropriate
capacities. I can appreciate that the traffic volumes generated by the Gerrards' business are very low. .
However, if full access is allowed in front of the business, others will likely use that full access to
make left turns from the south, u-turns from either direction and all manner of other peculiar traffic
moves which will seriously compromise safety at that location. This problem must be solved by the
City.
It would not violate the present Harmony Road Access Control Plan for the City to construct a solid
median all the way from Timberline Road to the railroad tracks. If need be, that can be done. The
plan that the City has in mind is to continue to pursue the amendment to the Harmony Road Access
Control Plan, while at the same time construct the Timberline RoadfHannony Road intersection
improvements and median improvements with the three-quarter access provided into the property
across Harmony Road from the Getrards as a temporary detour for traffic desiring to travel on
Timberline Road. Neither the City Council nor CDOT is, at this point, legally committed to making
permanent, this detour. If it is not approved, then the access to the south would have to be closed
and/or, moved to the west a few feet to match the existing driveway, and the three-quarter access
would also have to be closed and the solid median constructed, as I suggested earlier. The
acceptance of the proposed Harmony Road Access Plan Amendment remains undetermined until
both the City and CDOT approve it. ITaving said that, I also believe that both the City and CDOT
staff firmly support the proposed amendments to the Harmony Road Access Plan. So, it may not be
unreasonable to believe that the amendments will ultimately be approved in light of significant
public transportation needs. L,
TurZng to the question of the threatened inverse condemnation action, I must disagree with
you that there is a taking resulting from construction of this median. Numerous cases support the
principle that the construction of a median blocking left turn traffic movements does not constitute
a taking. A landowner's right of access to and from their property may be regulated to protect the
public health, safety and welfare, to maintain smooth traffic flow, to maintain highway right-of-way
drainage, and to protect the functional level of public highways. State Department.of Highways v.
Davis, 626. P.2d 661, 665 (Colo. 1981). The common law police power to regulate access has been
codified at §43-2-147(1)(a), C.R.S. (2000). If property retains reasonable access to and from the
APR-09-2001
10:56 P.02
City Attorney
City of Fort Collins
Douglas D. Konkel, Esquire
ATTORNEY AT LAW
1405 South College Avenue, Suite I
Fort Collins, CO 80524
Dear Doug:
April 5, 2001.-
' d PR r C.
i11
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I have received from Kathleen Reavis a copy of your March 14, 2001 letter to Tess Jones,
Regional Access Manager for CDOT, regarding the concerns of the Gerrard Family Limited
Partnership as they relate to the proposed construction project for the intersection of Timberline
Road and Harmony Road in Fort Collins. I understand from your letter that the Gerrards intend to
seek an injunction against the intersection construction project on the basis that the:project violates
the Harmony Road Access Plan, the State Highway Access Code, state law, and an
intergovernmental agreement between the City and the State. 1 also understand that the Gerrards
intend to commence an inverse condemnation action alleging a taking because the construction
Project includes the installation of a raised median in Harmony Road in front of the Gerrard's
property.
First, with regard to the threatened injunction action, the Gerrards can, and likely will, do
precisely as they please with regard to the commencement of such an action. However, I strongly
believe that such action would not prevail given current Colorado law. In discussing this matter with
the City staff, I was made aware of some facts that struck me as a reasonable solution. It is my
understanding that the Gerrard's recently acquired property to the:north and east of their building so
that they would have circulation access out to Timberline Road at a point north of the intersection
of Timberline Road and Harmony Road. I understand that the City is willing for the Gerrards to
have access on'rimberline Road at that location, which seems to me to provide a workable solution
to this problem. So, I would suggest that the Gerrards might also consider spending: the money that
they would save by not having to purchase an injunction bond and litigate a case that doesn't appear
to me to have a great likelihood of success, by instead improving their properties: and paving an
internal road to improve 9verall property access via Timberline Road.
I certainly understan and sympathize with the sen5ltivity that the Gerrards must have over
the limitation of their access to Harmony Road in front of their building, but, at the same time, the
City must be sensitive to what seem to be to be very important safety issues pertaining to traffic on
Harmony Road. Harmony Road is, as you know, rapidly becoming a major thoroughfare in the City.
As traffic volumes increase on Harmony Road the City must be able to make the necessary
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