HomeMy WebLinkAboutFord St/ Sidnie Ct Neighborhood Committee 2005-09-22SETTLEMENT AGREEMENT
BY AND BETWEEN
FORD STREET/SIDNIE COURT NEIGHBORHOOD COMMITTEE,
THE CITY OF UKIAH,
and
THE COUNTY OF MENDOCINO
SETTLEMENT AGREEMENT
This Settlement Agreement (Agreement) is entered into as of September
2005 ("the Effective Date"), by and between the Ford Street/Sidnie Court
Neighborhood Committee, the City of Ukiah, and the County of Mendocino.
RECITALS
A. The City of Ukiah (City) is a general law city duly organized under the
laws of the State of California.
B. Ford Street/Sidnie Court Neighborhood Committee (Committee) is an
unincorporated association formed in 2005.
C. The County of Mendocino (County) is a county duly organized under
the laws of the State of California.
D. On February 7, 2005, the Committee filed a Petition for Writ of Mandate,
Ford Street/Sidnie Court Neighborhood Committee v. City of Ukiah (County of
Mendocino), Mendocino County Superior Court No. SCUKCVPT 0594063 (the
Action) challenging the City's approval of the Orr Creek Bridge/Orchard Avenue
Extension project (the project) and certification of the Revised Environmental
Impact Report (REIR).
E. Each of the parties believes that it would be in their best interests to
settle this case without further legal proceedings.
IT IS THEREFORE AGREED AS FOLLOWS:
AGREEMENT
In consideration of the promises contained herein, and for good and
valuable consideration, the sufficiency of which is hereby acknowledged, the City,
the Committee, and the County agree as follows:
1. INCORPORATION OF RECITALS
The Recitals above are expressly incorporated into this Agreement.
1
11. TERMS
1. Within ten (10) days of the Effective Date, the Committee will request a
dismissal of the Action with prejudice.
2. The City will evaluate whether the relocation of the bridge is a feasible
alternative to the proposed project. The evaluation will include the issuance,
within ten (10) days of the Effective Date, of an Request for Proposal (RFP), in
substantially the form attached hereto as Exhibit A, issued to more than two
qualified environmental consulting firms. The number of firms receiving the RFP
may be less than five.
3. The City will give the Committee an opportunity to review and comment
on any and all responses to the RFP (proposals) and take into account the
Committee's comments in deciding who is awarded the contract based on the
RFP.
4. The analysis on the project alternatives prepared by the firm awarded
the RFP will be presented to the City Council at a public meeting noticed as
required by law, with a 10-day notice to the persons and entities at the addresses
listed below in section XIII.B.
5. If the City Council determines that a project alternative is feasible and
environmentally superior, as those terms are defined in CEQA, the City will
prepare either a subsequent Environmental Impact Report (EIR), supplemental
EIR, or an addendum to the REIR, and follow all laws, including CEQA, in
processing the chosen document.
6. The City will complete the tasks described in subparagraphs 2-4 within
ninety (90) days of the Effective Date. It will complete the tasks described in
subparagraph 5 within the time required by law.
7. If the City Council approves the project alternative, it will consider
naming the road extension Randolph Road, in memory of Bill Randolph.
B. Attorneys' Fees and Costs.
Each party will bear its own attorneys' fees and costs.
2
III. NO ADMISSIONS.
This Agreement has been reached by the Parties to avoid the costs of
prolonged litigation and to efficiently and effectively manage disputes between
them as may arise concerning the Action. By entering into this Agreement, no
Party admits any issue of fact or law. Except as set forth in this Agreement, the
settlement of claims covered by this Agreement shall not be deemed to be an
admission or concession of liability or culpability by any Party, at any time, for any
purpose. Neither this Agreement, nor any document referred to herein, nor any
action taken to carry out this Agreement, shall be construed as giving rise to any
presumption or inference of admission or concession by any of the Parties as to
any fault, wrongdoing or liability whatsoever.
IV. INTEGRATION.
This Agreement constitutes the final and complete Agreement of the
Parties with respect to the subject matter hereof and supersedes all prior or
contemporaneous negotiations, promises, covenants, agreements or
representations concerning any matters directly, indirectly or collaterally related to
the subject matter of this Agreement.
Therefore, the Parties, and each of them, acknowledge that, in determining
to enter into this Agreement, each of them is relying solely upon its own
investigation and evaluation of the facts and circumstances giving rise to the
claims being resolved pursuant to the terms of this Agreement and not upon any
promise, covenant, agreement or representation by any Party, other than the
Parties' express agreements, representations and warranties contained in this
Agreement. The Parties have expressly and intentionally included in this
Agreement all collateral or additional agreements which may, in any
manner, touch or relate to any of the subject matter of this Agreement and,
therefore, all promises, covenants and agreements, collateral or otherwise, are
included herein. It is the intention of the Parties to this Agreement that it shall
constitute an integration of all their Agreements, and each understands that in the
event of any subsequent litigation, controversy or dispute concerning any of its
terms, conditions or provisions, no Party shall be permitted to offer or introduce
any oral or extrinsic evidence concerning any other collateral or oral agreement
between the Parties not included herein.
Notwithstanding the foregoing, in accordance with section VII below, the
Parties may enter into contemporaneous or subsequent written agreements that
amend, modify, clarify or explain this Agreement.
3
V. COUNTERPARTS.
This Agreement may be signed in counterparts and shall be binding upon
the Parties as if all of the Parties executed the original.
VI. WAIVER.
No waiver by any Party of any provision of this Settlement Agreement shall
be deemed to be a waiver of any other provision or of any subsequent breach of
any other provision. No waiver by any Party of any of such Party's rights under
the terms of this Agreement shall be effective unless such waiver is in a writing,
signed by such Party, which expresses, by its terms, an intention to waive a
Party's rights under this Agreement.
VII. AMENDMENT.
This Agreement cannot be amended modified, clarified or explained,
except by a writing executed by the Parties which expresses, by its terms, an
intention to modify this Agreement.
VIII. SUCCESSORS.
This Agreement shall be binding upon and inure to the benefit of, and be
enforceable by, the Parties and their respective administrators, trustees,
executors, personal representatives, successors and permitted assigns.
IX. CHOICE OF LAWS.
Any dispute regarding the interpretation of this Agreement, the
performance of the Parties pursuant to the terms of this Agreement, or the
damages accruing to a Party by reason of any breach of this Agreement shall be
determined under the laws of the State of California, without reference to
principles of choice of laws.
X. REPRESENTATION BY INDEPENDENT COUNSEL.
The Parties each acknowledge and warrant that each has been
represented by independent counsel of its own selection in connection with the
negotiations leading to this Agreement and the drafting of this Agreement; and
that in interpreting this Agreement, the terms of this Agreement will not be
construed either in favor of or against any Party.
4
j
XI. DISPUTE RESOLUTION.
The parties agree to submit any dispute which may arise concerning this
Agreement to Mendocino County Superior Court for resolution.
XII. MISCELLANEOUS.
A. Headings; Section References.
Captions and headings appearing in this Agreement are inserted solely as
reference aids for the ease and convenience of the Parties; they shall not be
deemed to define or limit the scope or substance of the provisions they introduce,
nor shall they be used in construing the intent or effect of such provisions.
B. Interpretation.
If any provision of this Agreement is finally determined by a court to be
invalid or unenforceable as written, the provision shall, if possible, be enforced to
the extent reasonable under the circumstances and otherwise shall be deemed
deleted from this Agreement. The other provisions of this Agreement shall remain
in full force and effect so long as the material purposes of the Agreement and
understandings of the Parties are not substantially impaired.
C. Binding Effect.
This Agreement shall be binding on and inure to the benefit of the Parties,
and their respective successors and permitted assigns.
D. Assignment or Transfer.
Neither Party shall assign or transfer this Agreement in whole or in part
except with the prior written approval of the other Party. Any unauthorized
attempt to assign or transfer this Agreement shall be null and void.
E. Authority.
Each person executing this Agreement warrants and represents that she or
he has the full legal authority to enter into this Agreement on behalf of the Party
for whom she or he executes this Agreement.
5
X1111. NOTICES.
A. Any and all notices between the parties provided for or permitted under
this agreement, or by law, shall be in writing and shall be deemed duly served:
1. When personally delivered to a party, on the date of such
delivery; or
2. When sent via facsimile to a party at the facsimile number set
forth below, or to such other or further facsimile number provided in a notice sent
under the terms of this paragraph, on the date of the transmission of that
facsimile; or
3. When deposited in the United States mail, certified, postage
prepaid, addressed to such party at the address set forth below, or to such other
or further address provided in a notice sent under the terms of this paragraph,
five days following the deposit of such notice in the mails.
B. Notices pursuant to this paragraph shall be sent to the parties as
follows:
If to the City of Ukiah: David Rapport
Rapport & Marston
405 W. Perkins Street
Ukiah CA 95482
Telephone: (707) 462-6846
Facsimile: (707) 462-4235
If to the Committee: Michele Tracy Taylor
on behalf of Bill Randolph
2033 Ralston Avenue, #63
Belmont CA 94002
Telephone: (650) 281-5320
With a copy to: Rose M. Zoia
Law Office of Rose M. Zoia
50 Old Courthouse Square, Suite 600
Santa Rosa CA 95404
Telephone: (707) 526-5894
Facsimile: (707) 526-5895
6
If to the County:
Frank Zotter
County Counsel
501 Low Gap Road
Room 1030
Ukiah CA 95482
Telephone: (707) 463-4446
Facsimile: (707) 463-4592
or to such other place as may from time to time be specified in a notice to each of
the parties hereto given pursuant to this paragraph as the address for service of
notice on such party.
IN WITNESS WHEREOF, the Parties have executed this Agreement as of
the day and year set forth above.
Dated: 2005 Ford Street/Sidnie Court Neighborhood
Committee
By: - - - -
Michele Tracy Taylor, on behalf of Bill
Randolph, Ford Street/Sidnie Court
Neighborhood Committee
Dated: 2005
The City of Ukiah
Mar shiku, Mayor
Dated: 2005 The County of Mendocino
By:
Chairman of the Board of
Supervisors
7
Approved as to form: CITY ATTORNEY
By: _
David rt
Rapport & Marston
Attorneys for City of Ukiah
LAW OFFICE OF ROSE M. ZOIA
By: -
Rose M. Zoia
Attorney for the Ford Street/Sidnie Court
Neighborhood Committee
COUNTY COUNSEL
By:
Frank Zotter
Attorney for County of Mendocino
8
CITY F KI
Orchard Avenue Extension
Alternative Route Analysis
quest for Proposal
Introduction
The City Of Ukiah recently certified an Environmental Impact Report and approved a
project to extend Orchard Avenue to Orr Creek, construct a bridge over the creek, and
extend the street further to Brush Street. The City is proposing to settle a law suit
challenging that EIR by considering whether an alternative site for the bridge represents
a reasonable and feasible project alternative, and if so, to analyze that project
alternative under the standards required by CEQA, including CEQA Guidelines Section
15126.6.
Scope of Work
The City desires to have an objective environmental analysis performed of the
alternative location of the bridge and any associated relocation of Orchard Avenue both
south and north of Orr Creek. Primary topics to be included in the analysis are (1)
whether the alternative is both within the range of reasonable alternatives which would
feasibly attain most of the project objectives and would avoid or substantially lessen any
of the significant effects of the project; and (2) If the relocation satisfies these criteria,
the analysis should evaluate the relative merits of the alternative as compared to the
project. In conducting that comparative evaluation, the analysis should consider noise,
traffic, and biological impacts of the project and the project alternative, as well as the
relative physical impacts of both the project and the project alternative on existing and
proposed future land uses that would be affected by them.
Description of Alternative
At the existing intersection of Orchard Avenue and Ford Street, Orchard Avenue would
veer to the east across private property at a 90-degree angle and extend to Highway
101 where it would then veer to the north at another 90-degree angle. It would extend
north paralleling the highway, functioning as a frontage road. A new bridge would be
constructed over Orr Creek in close proximity to the existing Highway 101 Bridge. From
there, Orchard Avenue would extend north and connect to Brush Street (see attached
diagram).
The width of the Orchard Avenue right-of-way and bridge would not change with the
alternative route.
The Ukiah General Plan designates the Orchard Avenue road extension as a Major
Arterial Street.
SubConsultants
The bid proposal to perform the alternative route analysis must include a list of tasks to
be performed by subconsultants and the costs associated with each task.
Work Performed by the City
The City Public Works/Engineering Department will evaluate and determine the costs for
acquiring the necessary right-of-way and potential redesign of the bridge associated
with the alternative route.
Bid Proposal Contents and For
Proposals should be written in a narrative form which will allow the reviewers to discern
the following information: professional qualifications; work program with detailed tasks;
completion schedule; methodology; experience and expertise in similar projects,
including success stories and list of clients; level of analysis; price quotations for each
required component of the project, as well as an overall price; and presumptions upon
which the proposal is based.
Three copies of the Bid Proposal must be submitted to:
Charley Stump, Director
Planning and Community Development
City of Ukiah
300 Seminary Avenue
Ukiah, CA 95482
(707) 463-6219
charleys@ci!2~fukiah.com
Attachments
1. Diagram of alternative street route and bridge location
2. Regional location map
2
$ a
SETTLEMENT AGREEMENT
BY AND BETWEEN
FORD STREET/SIDNIE COURT NEIGHBORHOOD COMMITTEE,
THE CITY OF UKIA,
and
THE COUNTY OF MENDOCINO
SETTLEMENT AGREEMENT
This Settlement Agreement (Agreement) is entered into as of
2005 ("the Effective Date"), by and between the Ford Street/Sidnie Court
Neighborhood Committee, the City of Ukiah, and the County of Mendocino.
RECITALS
A. The City of Ukiah (City) is a general law city duly organized under the
laws of the State of California.
B. Ford Street/Sidnie Court Neighborhood Committee (Committee) is an
unincorporated association formed in 2005.
C. The County of Mendocino (County) is a county duly organized under
the laws of the State of California.
D. On February 7, 2005, the Committee filed a Petition for Writ of Mandate,
Ford Street/Sidnie Court Neighborhood Committee v. City of Ukiah (County of
Mendocino), Mendocino County Superior Court No. SCUKCVPT 0594063 (the
Action) challenging the City's approval of the Orr Creek Bridge/Orchard Avenue
Extension project (the project) and certification of the Revised Environmental
Impact Report (REIR).
E. Each of the parties believes that it would be in their best interests to
settle this case without further legal proceedings.
IT IS THEREFORE AGREED AS FOLLOWS:
AGREEMENT
In consideration of the promises contained herein, and for good and
valuable consideration, the sufficiency of which is hereby acknowledged, the City,
the Committee, and the County agree as follows:
1. INCORPORATION OF RECITALS
The Recitals above are expressly incorporated into this Agreement.
II. TERMS
1. Within ten (10) days of the Effective Date, the Committee will request
and obtain approval of DAVID, I CANNOT GUARANTEE OBTAINING
DISMISSAL IF THE CLERK DOES NOT FILE IT WHEN RECEIVED - IT'S BEEN
KNOWN TO HAPPEN..... a dismissal of the Action with prejudice.
2. The City will evaluate whether the relocation of the bridge is a feasible
alternative to the proposed project. The evaluation will include the issuance,
within ten (10) days of the Effective Date, of an Request for Proposal (RFP), in
substantially the form attached hereto as Exhibit A, issued to more than two
qualified environmental consulting firms. The number of firms receiving the RFP
may be less than five.
3. The City will give the Committee an opportunity to review and comment
on any and all responses to the RFP (proposals) and take into account the
Committee's comments in deciding who is awarded the contract based on the
RF P.
4. The analysis on the project alternatives prepared by the firm awarded
the RFP will be presented to the City Council at a public meeting noticed as
required by law, with a 10-day notice to the persons and entities at the addresses
listed below in section XIII.B.
5. If the City Council determines that a project alternative is feasible and
environmentally superior, as those terms are defined in CEQA, the City will
prepare either a subsequent Environmental Impact Report (EIR), supplemental
EIR, or an addendum to the REIR, and follow all laws, including CEQA, in
processing the chosen document.
6. The City will complete the tasks described in subparagraphs 2-4 within
ninety (90) days of the Effective Date. It will complete the tasks described in
subparagraph 5 within the time required b y law.
7. If the City Council approves the project alternative, it ti,vill consider
naming the road extension Randolph Road, in memory of Bill Randolph.
B. Attorneys' Fees and Costs.
Each party will bear its own attorneys' fees and costs.
III. NO ADMISSIONS.
This Agreement has been reached by the Parties to avoid the costs of
prolonged litigation and to efficiently and effectively manage disputes between
them as may arise concerning the Action. By entering into this Agreement, no
Party admits any issue of fact or law. Except as set forth in this Agreement, the
settlement of claims covered by this Agreement shall not be deemed to be an
admission or concession of liability or culpability by any Party, at any time, for any
purpose. Neither this Agreement, nor any document referred to herein, nor any
action taken to carry out this Agreement, shall be construed as giving rise to any
presumption or inference of admission or concession by any of the Parties as to
any fault, wrongdoing or liability whatsoever.
IV. INTEGRATION.
This Agreement constitutes the final and complete Agreement of the
Parties with respect to the subject matter hereof and supersedes all prior or
contemporaneous negotiations, promises, covenants, agreements or
representations concerning any matters directly, indirectly or collaterally related to
the subject matter of this Agreement.
Therefore, the Parties, and each of them, acknowledge that, in determining
to enter into this Agreement, each of them is relying solely upon its own
investigation and evaluation of the facts and circumstances giving rise to the
claims being resolved pursuant to the terms of this Agreement and not upon any
promise, covenant, agreement or representation by any Party, other than the
Parties' express agreements, representations and warranties contained in this
Agreement. The Parties have expressly and intentionally included in this
Agreement all collateral or additional agreements which may, in any
manner, touch or relate to any of the subject matter of this Agreement and,
therefore, all promises, covenants and agreements, collateral or otherwise, are
included herein. It is the intention of the Parties to this Agreement that it shall
constitute an integration of all their Agreements, and each understands that in the
event of any subsequent litigation, controversy or dispute concerning any of its
terms, conditions or provisions, no Party shall be permitted to offer or introduce
any oral or extrinsic evidence concerning any other collateral or oral agreement
between the Parties not included herein.
Notwithstanding the foregoing, in accordance with section VII below, the
Parties may enter into contemporaneous or subsequent written agreements that
amend, modify, clarify or explain this Agreement.
V. COUNTERPARTS.
This Agreement may be signed in counterparts and shall be binding upon
the Parties as if all of the Parties executed the original.
VI. WAIVER.
No waiver by any Party of any provision of this Settlement Agreement shall
be deemed to be a waiver of any other provision or of any subsequent breach of
any other provision. No waiver by any Party of any of such Party's rights under
the terms of this Agreement shall be effective unless such waiver is in a writing,
signed by such Party, which expresses, by its terms, an intention to waive a
Party's rights under this Agreement.
V11. AMENDMENT.
This Agreement cannot be amended modified, clarified or explained,
except by a writing executed by the Parties which expresses, by its terms, an
intention to modify this Agreement.
VIII. SUCCESSORS.
This Agreement shall be binding upon and inure to the benefit of, and be
enforceable by, the Parties and their respective administrators, trustees,
executors, personal representatives, successors and permitted assigns.
IX. CHOICE OF LAWS.
Any dispute regarding the interpretation of this Agreement, the
performance of the Parties pursuant to the terms of this Agreement, or the
damages accruing to a Party by reason of any breach of this Agreement shall be
determined under the laws of the State of California, without reference to
principles of choice of laws,
X. REPRESENTATION BY INDEPENDENT COUNSEL.
The Parties each acknowledge and warrant that each has been
represented by independent counsel of its own selection in connection with the
negotiations leading to this Agreement and the drafting of this Agreement; and
that in interpreting this Agreement, the terms of this Agreement will not be
construed either in favor of or against any Party.
XI. DISPUTE RESOLUTION.
The parties agree to submit any dispute which may arise concerning this
Agreement to Mendocino County Superior Court for resolution.
XI1. MISCELLANEOUS.
A. Pleadings; Section References.
Captions and headings appearing in this Agreement are inserted solely as
reference aids for the ease and convenience of the Parties,- they shall not be
deemed to define or limit the scope or substance of the provisions they introduce,
nor shall they be used in construing the intent or effect of such provisions.
B. Interpretation.
If any provision of this Agreement is finally determined by a court to be
invalid or unenforceable as written, the provision shall, if possible, be enforced to
the extent reasonable under the circumstances and otherwise shall be deemed
deleted from this Agreement. The other provisions of this Agreement shall remain
in full force and effect so long as the material purposes of the Agreement and
understandings of the Parties are not substantially impaired.
C. Binding Effect.
This Agreement shall be binding on and inure to the benefit of the Parties,
and their respective successors and permitted assigns.
D. Assignment or Transfer.
Neither Party shall assign or transfer this Agreement in whole or in part
except with the prior written approval of the other Party. Any unauthorized
attempt to assign or transfer this Agreement shall be null and void.
E. Authority.
Each person executing this Agreement warrants and represents that she or
he has the full legal authority to enter into this Agreement on behalf of the Party
for whom she or he executes this Agreement.
X111. NOTICES.
A. Any and all notices between the parties provided for or permitted under
this agreement, or by law, shall be in writing and shall be deemed duly served:
1. When personally delivered to a party, on the date of such
delivery; or
2. When sent via facsimile to a party at the facsimile number set
forth below, or to such other or further facsimile number provided in a notice sent
under the terms of this paragraph, on the date of the transmission of that
facsimile; or
3. When deposited in the United States mail, certified, postage
prepaid, addressed to such party at the address set forth below, or to such other
or further address provided in a notice sent under the terms of this paragraph,
five days following the deposit of such notice in the mails.
B. Notices pursuant to this paragraph shall be sent to the parties as
follows:
If to the City of Ukiah
If to the Committee
David Rapport
Rapport & Marston
405 W. Perkins Street
Ukiah CA 95482
Telephone: (707) 462-6846
Facsimile: (707) 462-4235
!Vlichele Tracy Taylor
on behalf of Bill Randolph
2033 Ralston Avenue, =t63
Belmont CA 94002
Telephone: (650) 28-1-5320
With a copy to: Rose M. Zoia
Law Office of Rose M. Zoia
50 Old Courthouse Square, Suite 600
Santa Rosa CA 95404
Telephone: (707) 526-5894
Facsimile: (707) 526-5895
If to the County: Frank Zotter
County Counsel
501 Low Gap Road
Room 1030
Ukiah CA 95482
Telephone: (707)
Facsimile: (707) 463-4592
or to such other place as may from time to time be specified in a notice to each of
the parties hereto given pursuant to this paragraph as the address for service of
notice on such party.
IN WITNESS WHEREOF, the Parties have executed this Agreement as of
the day and year set forth above.
Dated: _ 2005 Ford Street/Sidnie Court Neighborhood
Comm ittee
B y ~
Michele Tracy Taylor, on behalf of Bill
Randolph, Ford Street/Sidnie Court
Neighborhood Committee
Dated: 2005 The City of Ukiah
Mark Ashiku, Mayor
Dated: _ , 2005 The County of Mendocino
B y -
, Chairman of the Board of
Supervisors
Approved as to form: CITY ATTORNEY
By:
David Rapport
Rapport & Marston
Attorneys for City of Ukiah
LAW OFFICE OF ROSE M. ZOIA
By=
Rose M. Zoia
Attorney for the Ford Street/Sidnie Court
Neighborhood Committee
COUNTY COUNSEL
Frank Zotter
Attorney for County of Mendocino
CITY OF UKIAH
Orchard Avenue Extension
Alternative Route Analysis
Request for Proposal
Introduction
The City Of Ukiah recently certified an Environmental Impact Report and approved a
project to extend Orchard Avenue to Orr Creek, construct a bridge over the creek, and
extend the street further to Brush Street. The City is proposing to settle a law suit
challenging that EIR by considering whether an alternative site for the bridge represents
a reasonable and feasible project alternative, and if so, to analyze that project
alternative under the standards required by CEQA, including CEQA Guidelines Section
15126.6.
Scope of Work
The City desires to have an objective environmental analysis performed of the
alternative location of the bridge and any associated relocation of Orchard Avenue both
south and north of Orr Creek. Primary topics to be included in the analysis are (1)
whether the alternative is both within the range of reasonable alternatives which would
feasibly attain most of the project objectives and would avoid or substantially lessen any
of the significant effects of the project; and (2) If the relocation satisfies these criteria,
the analysis should evaluate the relative merits of the alternative as compared to the
project. In conducting that comparative evaluation, the analysis should consider noise,
traffic, and biological impacts of the project and the project alternative, as well as the
relative physical impacts of both the project and the project alternative on existing and
proposed future land uses that would be affected by them.
Description of Alternative
At the existing intersection of Orchard Avenue and Ford Street, Orchard Avenue would
veer to the east across private property at a 90-degree angle and extend to Highway
101 where it would then veer to the north at another 90-degree angle. It would extend
north paralleling the highway, functioning as a frontage road. A new bridge would be
constructed over Orr Creek in close proximity to the existing Highway 101 Bridge. From
there, Orchard Avenue would extend north and connect to Brush Street (see attached
diagram).
The width of the Orchard Avenue right-of-way and bridge would not change with the
alternative route.
The Ukiah General Plan designates the Orchard Avenue road extension as a Major
Arterial Street.
SubConsultants
The bid proposal to perform the alternative route analysis must include a list of tasks to
be performed by subconsultants and the costs associated with each task.
Work Performed by the City
The City Public Works/Engineering Department will evaluate and determine the costs for
acquiring the necessary right-of-way and potential redesign of the bridge associated
with the alternative route.
Bid Proposal Contents and Form
Proposals should be written in a narrative form which will allow the reviewers to discern
the following information: professional qualifications; work program with detailed tasks;
completion schedule; methodology; experience and expertise in similar projects,
including success stories and list of clients; level of analysis; price quotations for each
required component of the project, as well as an overall price; and presumptions upon
which the proposal is based.
Three copies of the Bid Proposal must be submitted to:
Charley Stump, Director
Planning and Community Development
City of Ukiah
300 Seminary Avenue
Ukiah, CA 95482
(707) 463-6219
charlevs(dcitvofukiah.com
Attachments
1. Diagram of alternative street route and bridge location
2. Regional location map
n
DESIGNED: B. RANDOLPH
CHECKED:
ORCHARD AVENUE
TITLE
PROPOSE BRIDGE REALIGNMENT Y
THE PATHS AN OPEN SPACE COMMITTEE
SIZE I FSCM No.
SCALE 1 "=900' 1 DATE 8/9/2004
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CI OF UKIAH
Regional Location
10 mile- s_-e
11
SETTLEMENT AGREEMENT
BY AND BETWEEN
FORD STREET/SIDNIE COURT NEIGHBORHOOD COMMITTEE,
THE CITY OF UKIAH,
and
THE COUNTY OF MENDOCINO
SETTLEMENT AGREEMENT
This Settlement Agreement (Agreement) is entered into as of September
2005 ("the Effective Date"), by and between the Ford Street/Sidnie Court
Neighborhood Committee, the City of Ukiah, and the County of Mendocino.
RECITALS
A. The City of Ukiah (City) is a general law city duly organized under the
laws of the State of California.
B. Ford Street/Sidnie Court Neighborhood Committee (Committee) is an
unincorporated association formed in 2005.
C. The County of Mendocino (County) is a county duly organized under
the laws of the State of California.
D. On February 7, 2005, the Committee filed a Petition for Writ of Mandate,
Ford Street/Sidnie Court Neighborhood Committee v. City of Ukiah (County of
Mendocino), Mendocino County Superior Court No. SCUKCVPT 0594063 (the
Action) challenging the City's approval of the Orr Creek Bridge/Orchard Avenue
Extension project (the project) and certification of the Revised Environmental
Impact Report (REIR).
E. Each of the parties believes that it would be in their best interests to
settle this case without further legal proceedings.
IT IS THEREFORE AGREED AS FOLLOWS:
AGREEMENT
In consideration of the promises contained herein, and for good and
valuable consideration, the sufficiency of which is hereby acknowledged, the City,
the Committee, and the County agree as follows:
1. INCORPORATION OF RECITALS
The Recitals above are expressly incorporated into this Agreement.
1
11. TERMS
1. Within ten (10) days of the Effective Date, the Committee will request a
dismissal of the Action with prejudice.
2. The City will evaluate whether the relocation of the bridge is a feasible
alternative to the proposed project. The evaluation will include the issuance,
within ten (10) days of the Effective Date, of an Request for Proposal (RFP), in
substantially the form attached hereto as Exhibit A, issued to more than two
qualified environmental consulting firms. The number of firms receiving the RFP
may be less than five.
3. The City will give the Committee an opportunity to review and comment
on any and all responses to the RFP (proposals) and take into account the
Committee's comments in deciding who is awarded the contract based on the
RFP.
4. The analysis on the project alternatives prepared by the firm awarded
the RFP will be presented to the City Council at a public meeting noticed as
required by law, with a 10-day notice to the persons and entities at the addresses
listed below in section XIII.B.
5. If the City Council determines that a project alternative is feasible and
environmentally superior, as those terms are defined in CEQA, the City will
prepare either a subsequent Environmental Impact Report (EIR), supplemental
EIR, or an addendum to the REIR, and follow all laws, including CEQA, in
processing the chosen document.
6. The City will complete the tasks described in subparagraphs 2-4 within
ninety (90) days of the Effective Date. It will complete the tasks described in
subparagraph 5 within the time required by law.
7. If the City Council approves the project alternative, it will consider
naming the road extension Randolph Road, in memory of Bill Randolph.
S. Attorneys' Fees and Costs.
Each party will bear its own attorneys' fees and costs.
2
III. NO ADMISSIONS.
This Agreement has been reached by the Parties to avoid the costs of
prolonged litigation and to efficiently and effectively manage disputes between
them as may arise concerning the Action. By entering into this Agreement, no
Party admits any issue of fact or law. Except as set forth in this Agreement, the
settlement of claims covered by this Agreement shall not be deemed to be an
admission or concession of liability or culpability by any Party, at any time, for any
purpose. Neither this Agreement, nor any document referred to herein, nor any
action taken to carry out this Agreement, shall be construed as giving rise to any
presumption or inference of admission or concession by any of the Parties as to
any fault, wrongdoing or liability whatsoever.
IV. INTEGRATION.
This Agreement constitutes the final and complete Agreement of the
Parties with respect to the subject matter hereof and supersedes all prior or
contemporaneous negotiations, promises, covenants, agreements or
representations concerning any matters directly, indirectly or collaterally related to
the subject matter of this Agreement.
Therefore, the Parties, and each of them, acknowledge that, in determining
to enter into this Agreement, each of them is relying solely upon its own
investigation and evaluation of the facts and circumstances giving rise to the
claims being resolved pursuant to the terms of this Agreement and not upon any
promise, covenant, agreement or representation by any Party, other than the
Parties' express agreements, representations and warranties contained in this
Agreement. The Parties have expressly and intentionally included in this
Agreement all collateral or additional agreements which may, in any
manner, touch or relate to any of the subject matter of this Agreement and,
therefore, all promises, covenants and agreements, collateral or otherwise, are
included herein. It is the intention of the Parties to this Agreement that it shall
constitute an integration of all their Agreements, and each understands that in the
event of any subsequent litigation, controversy or dispute concerning any of its
terms, conditions or provisions, no Party shall be permitted to offer or introduce
any oral or extrinsic evidence concerning any other collateral or oral agreement
between the Parties not included herein.
Notwithstanding the foregoing, in accordance with section VII below, the
Parties may enter into contemporaneous or subsequent written agreements that
amend, modify, clarify or explain this Agreement.
3
V. COUNTERPARTS.
This Agreement may be signed in counterparts and shall be binding upon
the Parties as if all of the Parties executed the original.
VI. WAIVER.
No waiver by any Party of any provision of this Settlement Agreement shall
be deemed to be a waiver of any other provision or of any subsequent breach of
any other provision. No waiver by any Party of any of such Party's rights under
the terms of this Agreement shall be effective unless such waiver is in a writing,
signed by such Party, which expresses, by its terms, an intention to waive a
Party's rights under this Agreement.
VII. AMENDMENT.
This Agreement cannot be amended modified, clarified or explained,
except by a writing executed by the Parties which expresses, by its terms, an
intention to modify this Agreement.
VIII. SUCCESSORS.
This Agreement shall be binding upon and inure to the benefit of, and be
enforceable by, the Parties and their respective administrators, trustees,
executors, personal representatives, successors and permitted assigns.
IX. CHOICE OF LAWS.
Any dispute regarding the interpretation of this Agreement, the
performance of the Parties pursuant to the terms of this Agreement, or the
damages accruing to a Party by reason of any breach of this Agreement shall be
determined under the laws of the State of California, without reference to
principles of choice of laws.
X. REPRESENTATION BY INDEPENDENT COUNSEL.
The Parties each acknowledge and warrant that each has been
represented by independent counsel of its own selection in connection with the
negotiations leading to this Agreement and the drafting of this Agreement; and
that in interpreting this Agreement, the terms of this Agreement will not be
construed either in favor of or against any Party.
4
XI. DISPUTE RESOLUTION.
The parties agree to submit any dispute which may arise concerning this
Agreement to Mendocino County Superior Court for resolution.
XII. MISCELLANEOUS.
A. Headings; Section References.
Captions and headings appearing in this Agreement are inserted solely as
reference aids for the ease and convenience of the Parties; they shall not be
deemed to define or limit the scope or substance of the provisions they introduce,
nor shall they be used in construing the intent or effect of such provisions.
B. Interpretation.
If any provision of this Agreement is finally determined by a court to be
invalid or unenforceable as written, the provision shall, if possible, be enforced to
the extent reasonable under the circumstances and otherwise shall be deemed
deleted from this Agreement. The other provisions of this Agreement shall remain
in full force and effect so long as the material purposes of the Agreement and
understandings of the Parties are not substantially impaired.
C. Binding Effect.
This Agreement shall be binding on and inure to the benefit of the Parties,
and their respective successors and permitted assigns.
D. Assignment or Transfer.
Neither Party shall assign or transfer this Agreement in whole or in part
except with the prior written approval of the other Party. Any unauthorized
attempt to assign or transfer this Agreement shall be null and void.
E. Authority.
Each person executing this Agreement warrants and represents that she or
he has the full legal authority to enter into this Agreement on behalf of the Party
for whom she or he executes this Agreement.
5
XIII. NOTICES.
A. Any and all notices between the parties provided for or permitted under
this agreement, or by law, shall be in writing and shall be deemed duly served:
1. When personally delivered to a party, on the date of such
delivery; or
2. When sent via facsimile to a party at the facsimile number set
forth below, or to such other or further facsimile number provided in a notice sent
under the terms of this paragraph, on the date of the transmission of that
facsimile; or
3. When deposited in the United States mail, certified, postage
prepaid, addressed to such party at the address set forth below, or to such other
or further address provided in a notice sent under the terms of this paragraph,
five days following the deposit of such notice in the mails.
B. Notices pursuant to this paragraph shall be sent to the parties as
follows:
If to the City of Ukiah: David Rapport
Rapport & Marston
405 W. Perkins Street
Ukiah CA 95482
Telephone: (707) 462-6846
Facsimile: (707) 462-4235
If to the Committee: Michele Tracy Taylor
on behalf of Bill Randolph
2033 Ralston Avenue, #63
Belmont CA 94002
Telephone: (650) 281-5320
With a copy to: Rose M. Zoia
Law Office of Rose M. Zoia
50 Old Courthouse Square, Suite 600
Santa Rosa CA 95404
Telephone: (707) 526-5894
Facsimile: (707) 526-5895
6
If to the County:
Frank Zotter
County Counsel
501 Low Gap Road
Room 1030
Ukiah CA 95482
Telephone: (707) 463-4446
Facsimile: (707) 463-4592
or to such other place as may from time to time be specified in a notice to each of
the parties hereto given pursuant to this paragraph as the address for service of
notice on such party.
IN WITNESS WHEREOF, the Parties have executed this Agreement as of
the day and year set forth above.
Dated: 2005 Ford Street/Sidnie Court Neighborhood
Committee
By:
Michele Tracy Taylo~n beh of Bill
Randolph, Ford Street/Sidnie Court
Neighborhood Committee
Dated: Q 9~i/~/ 2005
The City of Ukiah
Mar shiku, Mayor
Dated:
2005
The County of Mendocino
Chairman of the Board of
Supervisors
7
Approved as to form: CITY ATTORNEY
By:-- - - -
David rt
Rapport & Marston
Attorneys for City of Ukiah
LAW OFFICE OF ROSE M. ZOIA
By:
Rose M. Zoia
Attorney for the F Street/Sidnie Court
Neighborhood Committee
COUNTY COUNSEL
By: 6"VV-P- ~~'~~4 -
Frank Zotter U- j
Attorney for County of Mendocino
8
CITY OF UKIAH
Orchard Extension
Alternative Analysis
Request for Proposal
Introduction
The City Of Ukiah recently certified an Environmental Impact Report and approved a
project to extend Orchard Avenue to Orr Creek, construct a bridge over the creek, and
extend the street further to Brush Street. The City is proposing to settle a law suit
challenging that EIR by considering whether an alternative site for the bridge represents
a reasonable and feasible project alternative, and if so, to analyze that project
alternative under the standards required by CEQA, including CEQA Guidelines Section
15126.6.
Scope of Work
The City desires to have an objective environmental analysis performed of the
alternative location of the bridge and any associated relocation of Orchard Avenue both
south and north of Orr Creek. Primary topics to be included in the analysis are (1)
whether the alternative is both within the range of reasonable alternatives which would
feasibly attain most of the project objectives and would avoid or substantially lessen any
of the significant effects of the project; and (2) If the relocation satisfies these criteria,
the analysis should evaluate the relative merits of the alternative as compared to the
project. In conducting that comparative evaluation, the analysis should consider noise,
traffic, and biological impacts of the project and the project alternative, as well as the
relative physical impacts of both the project and the project alternative on existing and
proposed future land uses that would be affected by them.
Description of Alternative
At the existing intersection of Orchard Avenue and Ford Street, Orchard Avenue would
veer to the east across private property at a 90-degree angle and extend to Highway
101 where it would then veer to the north at another 90-degree angle. It would extend
north paralleling the highway, functioning as a frontage road. A new bridge would be
constructed over Orr Creek in close proximity to the existing Highway 101 Bridge. From
there, Orchard Avenue would extend north and connect to Brush Street (see attached
diagram).
The width of the Orchard Avenue right-of-way and bridge would not change with the
alternative route.
The Ukiah General Plan designates the Orchard Avenue road extension as a Major
Arterial Street.
Exhibit A
SubConsoltants
The bid proposal to perform the alternative route analysis must include a list of tasks to
be performed by subconsultants and the costs associated with each task.
Work Performed by the City
The City Public Works/Engineering Department will evaluate and determine the costs for
acquiring the necessary right-of-way and potential redesign of the bridge associated
with the alternative route.
Bid Proposal Contents and Form
Proposals should be written in a narrative form which will allow the reviewers to discern
the following information: professional qualifications; work program with detailed tasks;
completion schedule; methodology; experience and expertise in similar projects,
including success stories and list of clients; level of analysis; price quotations for each
required component of the project, as well as an overall price; and presumptions upon
which the proposal is based.
Three copies of the Bid Proposal must be submitted to:
Charley Stump, Director
Planning and Community Development
City of Ukiah
300 Seminary Avenue
Ukiah, CA 95482
(707) 463-6219
charleys@cityofukiah.com
Attachments
1. Diagram of alternative street route and bridge location
2. Regional location map
2
Ex hi b i t A
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CI OF UKIAH
Regional Location
10 miles
Exhibit A
Exhibit A