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Home My WebLink AboutMONTAVA - PHASE D CORE AND IRRIGATION POND - BDR240006 - SUBMITTAL DOCUMENTS - ROUND 2 - Supporting Documentation (8)Bushong & Holleman PC A t t o r n e y s� a t• L a w 1966 13th Street, Suite 270, Boulder, Colorado 80302 Steven J. Bushong Paul (Fritz) Holleman Cassidy L. Woodard Gunnar J. Paulsen Kate A. Bosh July 17, 2024 Heidi Hansen, P.E., CFM Water Utilities Development Review Manager' City of Fort Collins — Utilities 700 Wood Street Fort Collins, CO 80521 Re: Proposed Drainage Outfall for Montava Phase D Dear Ms. Hansen, Karen L. Henderson Of Counse! Veronica A. Sperling Rekr•ecl (303) 431-9141 BH-Lawyers.com I am in receipt of your letter to Max Moss dated June 18, 2024, and Max asked me to respond. This letter incorporates infonnation from Montava, Martin/Martin ("M/M"), and TST Inc. where appropriate. 1. Birky Order. Your letter raises questions regarding the Birky Order and its effect, if any, on the drainage outfall for Phase D(i.e. the outfall pipe under Mountain Vista Drive). In response, please consider the following: A. There are no inconsistencies between the AB Agreement and the Birky Order. Both agreements remain in place and reflect LWIC's acceptance of drainage under different circumstances. Although the 1986 AB Agreement was entered just 10 years after the 1976 stipulated agreement contained in the Birky Order, it does not mention or attempt to replace the Birky Order. Accordingly, while the Birky Order can help address some drainage issues arising on certain AB lands — the AB Agreement addresses the rest of the drainage on all the AB lands. B. Additional commonsense support for the above statement is evident by the fact that AB paid $150,000 to LWC for the additional stormwater discharge into the LWC even though the Birky Order already existed — so additional benefit was clearly contemplated. (See AB Agreeme�zt, recitals). Also, as noted in my June 12, 2024, letter to Mr. Sullivan, the 18" Birky pipeline does not begin to address stormwater historically generated on AB Lands as documented by M/M and the stormwater model. Heidi Hansen July 17, 2024 Page 2 of 5 C. Since the AB Agreement and the Birky Order are both in effect, they could both theoretically benefit the Phase D lands. However, that's not the case, The Birky Order does not appear to address any drainage from Phase D lands for the reasons stated below. D. Most of the Phase D lands lie outside of the lands that were identified in the Birky Order as potentially contributing drainage. (See attached Figure). Further, M/M concluded that the small portion of Phase D included in the Birky Order likely drained south and didn't benefit from the Birky Order. This is not surprising. Nor is it inconsistent with the Birky Order, which explains that the listed properties are "in general terms, the ownership of the lands from which such water is contributed ... [and] [t]he description of the lands are not intended to be definitive, but it is intended only to indicate that the parties designated own lands in the vicinity." (Birky Order, p.2). E. The Birky pipeline cannot be the single point of stormwater outfall from west of the RR right-of-way ("ROW") referenced in the AB Agreement. That single point of stormwater outfall from west of the ROW is necessarily the 12 x 24 wooden box culvert as explained below. F. The AB Agreement does not itself allow "waters arising west of said right-of-way [to] be conveyed into or discharged from structures east of said right-of-way, except for flows that have historically occurred." (AB Agreement ¶ 2.c) (emphasis added). Accordingly, the AB Agreement recognizes (and the M/M Model confirms) that some stormwater historically moved from west to east of the ROW and was then discharged from structures located east of the ROW. The Birky pipeline is exactly such a structure. G. The lands identified as contributing water to the Birky pipeline all exist west of the ROW, but were "contribut[ing] irrigation run-off, and flood water run-off and seepage and underground waters to the Birky land" that lie east of the ROW. (Birky Order, p. 2; see attached figure). Further, the Birky pipeline to be constructed to address the problem is also defined as being east of the ROW. So, the drainage included in the Birky Order was "discharged from" a structure constructed east of the ROW — not west of the ROW. H. Further evidence is seen in a recorded document certifying the construction and location of the Birky pipeline by M. W. Bittinger & Associates, Inc. about one inonth after the Birky Order ("Certification"). A copy is attached hereto. Also attached is a figure depicting the Birky pipeline from the Certification overlaid on an aerial photograph as prepared by TST. What is clear from the figure is that the Birky pipeline collected drainage that had already moved east of the ROW and existed near Mountain Vista Road. In other words, the Birky pipeline is not diverting water from west of the ROW — but instead collecting the water that has already moved fi-om west to east of the ROW as historically occurred. I. The figure depicting Birky Order pipeline is also consistent with information learned by Montava in speaking with Red Jewett, who was familiar with the fact that water historically ponded in the area along what is now Mountain Vista Road east of the ROW where the Birky Order pipeline was later constructed. Heidi Hansen July 17, 2024 Page 3 of 5 J. The only structure that can take water from west of the ROW and discharge it into the LWC is the wooden box culvert. Montava's investigations failed to identify any other existing structure capable of taking drainage from west of the ROW and discharging it directly into the LWC. Moreover, all information indicates that the wooden structure has been there and discharged into the LWC for a very long time and certainly before the AB Agreement. So, when the AB Agreement states "that there currently exists only one (1) point source of stormwater entry into the Ditch which conveys into the Ditch stormwater from A-B's land lying west of the right-of-way" — that is necessarily the wooden box culvert. K. Based on the above, the wooden box culvert takes stormwater from west of the ROW and discharges it into LWC. That is necessarily the "one (1) point source of stormwater entry into the Ditch" from west of the ROW. In contrast, the Birky pipeline takes stormwater that has already collected east of the ROW and delivers it about'/z mile to the LWC through a structure constructed entirely east of the ROW. Such an existing structure east of the ROW is allowed under the AB Agreement to continue operating as it historically did. 2. BNSF A�reement. Your letter also raises questions about the applicability of the 1961 Railway Agreement. As explained below, the 1961 Railway Agreement does not pertain to the wooden culvert, but the Phase D lands have an existing drainage easement through that culvert. A. At Montava's request it received from BNSF two existing agreeinents for piping under the ROW in the area of the wooden culvert. Upon reviewing the 1961 Railway Agreement, we agree it appears to allow a 12-inch corrugated metal (CMP) culvert — not the 12" by 24" wooden box culvert. B. Montava then asked for further information from BNSF on ROW crossings in this area and was given the attached diagram showing crossings under the ROW. As you will see, there are 3 possible crossings near the LWC. One is labeled "24" x 12" WB", which is a reference to the 24" x 12" wooden boX culvert. Montava agrees with the City that the CMP subject to the 1961 Railway Agreement does not appear to exist in that area and the wastewater pipe subject to the other agreement Montava was provided by BNSF is not relevant here. Thus, the wooden box culvert is the only existing structure at that location that can carry drainage water. Also, the BNSF diagram shows arrows passing through the ROW at the location of the wooden box culvert suggesting a drainage pathway. C. Montava has further inquired with BNSF on whether it has any other crossing agreement in that area and searched for records itself, but it appears no such agreement exists. That indicates the wooden box culvert was likely installed by BNSF or its predecessor to minimize the impact of drainage on the railroad, rather than at the request of a neighboring landowner. Consistent with that, the wooden box culvert is located where M/1VI determined that stonnwater naturally drains and collects and in very large storm events can even overtop the railroad at that location. Heidi Hansen July 17, 2024 Page 4 of 5 D. Montava has a drainage easement to continue using the wooden box culvert and does not require a separate agreement. That's because upgradient land in Colorado has a prescriptive right for natural drainage to continue flowing across lower gradient land. See, e.g., Hankins v. Bo�land, 431 P.2d 1007, 1010 (Colo. 1967). Drainage rights don't change with development. Specifically, the rule of law "adopted by Colorado has been summarized as follows: Natural drainage conditions may be altered by an upper proprietor provided the water is not sent down in a manner or quantity to do more harm than formerly." Hankins, 421 P.2d at 1010 (citations omitted). E. As explained below, Montava's proposed stormwater detention on Phase D lands will actually reduce the stormwater burden carried by the wooden box culvert by reducing a 100-year developed storm event to a historic 2-year event. Further the stormwater outfall from Phase D at Mountain Vista Drive relies on the historical drainage pathway and travels about 3/4 of a mile before reaching the wooden culvert under the ROW. F. In summary, the subject wooden structure is recognized by BNSF as an existing drainage culvert under the ROW. The lack of any more recent agreement for its construction coupled with the existing pathway for drainage from upgradient lands that leads to the culvert demonstrates the culvert was constructed to pass drainage from above-gradient lands. Colorado law recognizes that upgradient lands including Phase D have a prescriptive drainage easement to continue discharging drainage down its historical pathway, which passes through the wooden culvert into the LWC. That right was further recognized by LWC in the AB Agreement, which was approved by the City. 3. Field Visit Concerns. Finally, your letter raises some concerns from the May 30, 2024, site visit regarding the historical wooden culvert used to pass stormwater under the BNSF ROW. The following response was prepared by Montava, TST and M/M: A. This existing system has been in place for inany decades and has not been problematic. It is still functional and will remain functional until the new "ultimate condition" conveyance system is designed and built by the Montava team and the City according to the existing agreements, which will continue to discharge stormwater into the LWC at historic rates allowed by the AB Agreement. B. The outfall for Montava Phase D is the outlet of the proposed pipe under Mountain Vista Drive that introduces the substantially reduced storm flows from the project to the historic drainage path as identified in multiple studies. (See Montava Master Drainage Plan and the ICON Regional Study.) The designs for Montava Phase D are consistent with the City's stormwater criteria which required Montava to reduce the 100-year developed event to a 2-year historical outfall which has been accomplished at the Mountain Vista outfall. This will substantially improve the conditions that currently occur during larger events in the area of the historical wooden culvert. Heidi Hansen July 17, 2024 Page 5 of 5 C. The recent maintenance and cleaning of the culvert under BNSF has improved and stabilized the condition of this historic point of storm water flow until the new system is designed and built when needed in the future. D. Although minor improvements can be implemented to address some of the issues you note, there should be no need for major repairs or replacement of the structure at this time, especially when its future use will be greatly reduced. Thank you for the opportunity to respond to your concerns. Please let us know how else we can assist you in moving forward with Montava. Sincerely, BUSHONG & HOLLEMAN, PC C�>� � Steve Bushong Counsel for Montava cc: Max Moss, Project Manager — Montava Forrest Hancock, Development Director — Montava Ryan Byrne, PE, CFM, LEED AP Derek Patterson, PE �- �'5,,; r �•�-� - y �g .:'. � -�,-.� r. dr - � w . • 4 � tl � , �1. 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R �� y.�!' 158 16.2(}r� 1�5 12.7Ct°Jo 144 14.$�% 3.5�L 36.3D9� 56 6.?D°Jo 14C1 14.3f}°�'o Irri�ation and Flood 1Naters Irri�atican and Fl�,c�d'�.�aters Irrigatian and Flood �.+�faters Irrigation ar�d F1oad Waters Irrig�tior� and Flood '�fater5 Irri�ation a�nd Flood'�Naters TiDt2�l5 �77 1�D1.U(.�°�n .- -� r �.�e� ' - � - � � T.r � -i � .� #�'� � � '�, . �,� Y,��a..� �, r' _� .l�ya � [��'�, �.�r`,� 3w"� y C�1' � r . tT� •, _ • • � i �� ,f �* � . � i�#, � _ ° M' . a r . � �A 1�., `r . - ii^. y� �•v� ,i, �Y � y�,e � . . e F�� „-� s�r '�S �1�.: - i. y'Ji�� _ _ '+1'■� . �_ �p` "ii _ � ~'r � : _ _ u _ . ` '�I�. � � �1 I d�. a i I�llap Key Birky []r�ler C3wner� _ °!�� AV l wIF.. } a � �� i � �- � . , �E�` � � �?6 c� / ; p �� •a.. . 1wNi«. 1�►. '' iirrr�rr P YPEL7.�A:, DESCRIP i ION WHEREAS the Diatxict Gourt in and for tk� Cuunty of Larimer ar►d State of Colorado, in civil action �. 21652, en�itled The Board of C:ouncy commis- . si�uers,, pla:u�ttiff:, vs Cari W. 83 rky, et a_l. , de�endaa►l-s, (and in which other parLi�� ve�e third party def�ants, additional thi.rd part�• defeadants, and seccnd aet of adtlitioaal third party defEnd$nts) entered an ord�r dated the 23rd c�ay uf 3an•.iary, 1975, providiag ln part �s fnll.ow3: .� "�he �.3,ne, deptr and dimensioas of the �ipexir.e shall be precis�ly d�t�rmined and d��ihed by the e:�giriee�s aod a docum�ent so determin- �ng and describing i[ and making reference to this oxc�er st�ll h� recordeo in the office ai t�e Lsri�� C�unty Clerk � Recorder up.� the com.pletion of t��e require�nents of this r.rder." dNU k'HE�EAS, pursuant to such arder, C�e dsscr.fpti�a af the pipeli�►e has �. �,een determined by M. W. �ittinger b Associates, In�., the engineers ap�ointe� by �h� �GtaZL tQ malce the above determinati.or_. F1QS�1, .'!`EiEREFOKE, in complianr.e with saici order, M. W. Bittinger & Associates, In�o d�es certify the location and descrip�in� of said piF�line, Qver and acro�:� the lands of �he vurious parties, descri�iag therein th� width of the required ingre�s an� Qgress e.�semQnt r.eces:.ary for the i�struction, in►stallation, and per�an�eat mai�taiaance thereof. �.'he cies�riptidn of the aip�line ��rQss th� "Birky iands" is shawn on Ex�ibii "A". The descri�tior_. uf the pip�line a��oss Cou�,ty Ro�3 �50 �and its right-of- wav) �s descri�eci in Fachibit "B". The descr��ption Qf the pipeline across the "K.3.uver lands" is aescribed fn Eghi�it "�'. �10�1E pursuant to order c�f Co�rt as �.�.crzsai�, and date�' at Fort Callins, Colroado �his -��~day of Febru�ry, 1976. M. 3. w' . EITT�NGER � ASSOC�AT'�S, �23C . �' ? ,,� : , , , ,, �.r'1..-� *"� �f /� %` . $y: 9 � tl ,. Sh�t � at 2 •bnet� � � � M� _a v ��.. ; � �l C .i C % � `i .F: � � U � �, �I fi�? �G0199 k.X�i 1 i: iT ��A�� s�e�t :t or 2 vi�� L�gal d�scri��ion o� �►w easuaeat locate� in th� Sa:1C�,e-��t 1/�i of 5�:ct�.on 33, xo+wn:�h�Lp 8 P��r[t�, Kan�;e 6$ We�t uf the 6th Y.2:. and th� �a�t 1/2 vf SecCion 4, Tow��hip 7 Narth, Raa�e b8 i-lest of the Fth F,�I., L�ri�:er Gounty, Co1.c,rado. ,_ � A 2Q-�c,�L Nercu�,cieat drain��e pigeline ea�c'�1�ilt. 10 f�:�.t cach sx�3E� of the fo�l�win�; described c�.atcr�ine and d�U--fcx,t dtaie�.�:�,� yipEl.i�e c�r.��:ructi4n ea�e�eret, 30 feet Each s;i.cle of the fo2.locri.n� d�s::.rib�d iin.�. Considering the Z��rth lin�: o£ ,�iz S�:czi.on � as }%��i �1�� t; �Q°G�J'G4" E ancl with a�l b�arin�s coiiGained �iarE.'lA relat�.ve ther�to; Beginnir_g at ��►�int which be�rs N�D'GO'U�" E, 794.93 feet �r�� the Y�i�rth l/4 Carne� of s�id Section 4, pr�cecd S GO°S6'3�'' �1, �1.6�.OU f.eEt c�vre ot less t� t�►e North bank of tha I.ariwer ax�d w'�ld Car.al and ter��in:ition pr�iut af said easem�nt centerZine. Thie �in� ia 18-inch diameter and ie at a depth of 4-lf � tU �--i/2 f�et. . r:XNISiT '�L" Legu� ciE�scziptivn of an �asezaent locat�d irt the �cr�theast 1/4 of Section :�3, Tuwnship 8 ItiorCh, kai:n� 68 �:'�sC �f ti;� 6ttc P.:�`_. an.�. tlie Ea;,� ?/2 of Sectic�Z 4, Towr.�:��.p 7 t:uY4h� Ranve �3 ti'�! t oF �h� 6th P.��i. , i.�ri�er Ccunty, ColoTadc.. A 20-faoti perr�.anent drai.na�e pipeline easer��:.t, '� f�et eac:-: sidc of the fo11t�V�iz�g descr.-ibea ceni:erli�z a�id a SO-fao� draia��;� pir�laz►E cj.astructi.o� easet�QnC, 30 f eet 2ach si�� of the �oiiowir. ; desc� �.b�:c� :Zin�:. . Cor.s�derfn� tt:e l�orth line af sz3.d S�cticr. 4 �s b�arin�, 2� y0°C+��O�J'' �: and with �11 br:.�rings ccn�aizeu h�re.�:Y rela�ive tr.�re�a; B��ir.n;n�, at a point whieh bears it SE�35'S7" E, '�yl.?l Fe�t fr.:�e th� �`�orth l�!r Carntr. o£ sai� Section 4, p:oceed S 8g°3t3`L2" F:, 3G5.�� fee�, t:.en�ce S�L►n �6' 38" �.', 56. 65 f�et mure or les�s to CIs� Sou �2-� right-�� -way liT►e �� . C�►unty z'o�d a.nd cer�ination Po;n*' c,f �aid e�:s�e:�L c� :t��rlYr.e. This Iine starts as a i0-inch line and changes to zn I8-inch line �n thP secon� ca11. It hae a r�epth of from 6-1/2 feet to 8-I/2 feet. E�i�ilbiT "C►� L�:gal descripr.ioa af an easer.i�nt I.c�cated ir: the ��t�.;��ast 1/� o� Section 33, Tow��hip 8 itiorth, Rati;;L bS ��est t,� th� ��a P.r:. ai:d the Eas� 1/2 of Secti�:� 4, Tawn�hip I hor��, kan�;e b� +�est o� �he F��s P.:�,., LariLe� County, Colur�a�o� A 20-faot perr.ianent d�ai;ta�;e gip�I�ne eL�e.::�zit, 10 fee': e�ci► side af t�ie folloi�•ing des�r�b�d cer_te.rlii:E� ar�d a b�-foot drai.�r.,:de �ir�li.ne coastruc�;�� eas<went, 30 feet each �ide o` tt�e follc��•iz��; describ�d lir�e. . C:,ns:Lderzn,� the Nor�.i line �,f saicl Se��ion 4 as bearir.�; :y ��°�O��JC" E and with all bearic:�;s c�n.tained herezn re�.ati�v� Lheret�; Beginutng at �. �oi.nt whsch bear s Iv 86°39' S7" £, �r 91 � 21 f �� f row �h� 2vorth 1/4 Carner of said Se�ti�:� 4, procee3 S 8�°��'�.`�.'� E, 3�;.�J f�e�, th��nce S G�p5b'38" W, 26.FS fe�t more ox les.� to MhQ a�c��^. lin� t�x�:naLic�:� point o� said casem�nt centerlinf:� This line st:arts ae a?.�-inch line ancl ciiang�e to ran 18-inch line on the s�c:ond ca12. It hae � depth of 6-1/2 to 7-1/2 feet. �� . � , �� C a � �i �, a r x �� \ __ __ ' �'� _ � �-- �-'�'� __ 232i SLPZ _ >�22 5 anp __�3L�� 5�%j oy —� —�A � 1 �_�/a�('228//4 Sc �ss �� '" ��` /�� 2,d� / i �c � `, _ �, k . , • _ ••, : � _ , — • � .. . , _ . . _ � � � � d ,a. .t _ 234f2c c rd e I Crr P�pn MP 160e t� 5b"P�f �"�_ ��. �m � a i. 23orca �^D11:'i � 226�92 l2"C M`T 1 _ 1`28 / 52 ° 24 ""x /�'4 y � � o yK['� �& � �.2 �L � ; "y � , -� ' ��P` 1 { k, i.,� i 4 7,.A � �� f,. ; j�t �� -'. � �'�'a\. �� a' - �. � � � .. Q. „W�� r a � �; . �� , � �� ',�,i' � �t � w, � '<,, �`' c o�. �,� 3;1 �;�: