HomeMy WebLinkAboutMINUTES - 08081995 - D5 D. 5
TO: BOARD OF SUPERVISORS
FROM: VAL ALEXEEFF, DIRECTOR
GROWTH MANAGEMENT & ECONOMIC DEVELOPMENT AGENCY
AND
VICTOR J. WESTMAN, COUNTY COUNSEL
DATE: AUGUST 8, 1995
SUBJECT: DOUGHERTY VALLEY SETTLEMENT WITH EBMUD
SPECIFIC REQUEST(S)OR RECOMMENDATIONS)&BACKGROUND AND JUSTIFICATION
RECOMMENDATIONS:
CONSIDER approval of settlement agreement in EBMUD vs Contra Costa County et al,
No. C93-00235 and Contra Costa County vs EBMUD et al, No. 727221-7.
FISCAL IMPACT:
No direct cost to General Fund. Staff costs covered in fees.
BACKGROUND/REASONS FOR RECOMMENDATIONS:
The July 28, 1995 version of the settlement agreement is attached (Attachment A), along with a
summary of key points prepared by EBMUD (Attachment B). This version is to be considered by
EBMUD on August 8, 1995. This document has been negotiated by staff under general direction of
the Board of Supervisors and EBMUD Board.
CONTINUED ON ATTACHMENT: _YES SIGNATUREt A,
RECOMMENDATION OF COUNTY ADMINISTRATOR RECOMMENDATION OF BOARD COMMITTEE
APPROVE OTHER
SIGNATURE(S):
ACTION OF BOARD ON August 8 , 1995 APPROVED AS RECOMMENDED X OTHER X
Victor Westman, County Counsel , presented,.the_.staff .recommendationx-that the
Boatd:?of .Supervisors approve the above settlement agreement and direct staff
to take all further actions necessary to see that it is finally executed and
entered where it is to be filed. On motion of $upervisor DeSaulnier, IT IS
BY TH�O 1C E9�,QaED that the staff recommendation is APPROVED.
I HEREBY CERTIFY THAT THIS IS A TRUE AND CORRECT
COPY OF AN ACTION TAKEN AND ENTERED ON THE
_UNANIMOUS(ABSENT ) MINUTES OF THE BOARD OF SUPERVISORS ON THE
AYES: 2 , 4 . 5 NOES: 1 , 3 DATE,SHOWN.
ATTESTED August 8 , 1995
ABSENT: none ABSTAIN: none
PHIL,BATCHELP14,CLERK Oy THE BOARD OF
SUPE SORS(NY COUNT MINISTRATOR
VA:dg BY1A11 J.DEPUTY
ebmudset.bo
Contact: Val Alexeefl'(646-1620)
CC: County Administrator
County Counsel
GMEDA Departments
EBMUD(via GMEDA)
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ATTACHMENT A
DRAFT
July 28, 1995 (Second Version)
AGREEMENT TO SETTLE LITIGATION RELATING TO THE
DOUGHERTY VALLEY GENERAL PLAN AMENDMENT, SPECIFIC PLAN
AND ENVIRONMENTAL IMPACT REPORT AND RELATING TO
THE WATER SUPPLY MANAGEMENT PROGRAM AND ENVIRONMENTAL
IMPACT REPORT OF THE EAST BAY MUNICIPAL UTILITIES DISTRICT
This Agreement is entered into by and among the East Bay Municipal Utilities
District, a municipal utility district ("EBMUD" or the "District"), the County of Contra Costa,
a political subdivision of the State of California (the "County"), Windemere Ranch Partners, a
California limited partnership ("Windemere"), and Shapell Industries of Northern California, a
Division of Shapell Industries Inc., a Delaware corporation ("Shapell"). This Agreement is
effective as of August _, 1995.
RECITALS
A. Windemere and Shapell are the owners of certain real property (the "Property")
in the Dougherty Valley, which is located in an unincorporated area of southern Contra Costa
County. On December 22, 1992, the County approved a General Plan Amendment and a
Specific Plan for the Property, and certified as adequate a final environmental impact report
for the project (the "1992 Approvals").
B. In January, 1993, EBMUD filed a lawsuit entitled EBMUD v. County of
Contra Costa et al., No. C93-00235, in Contra Costa County Superior Court (the "Dougherty
Valley Lawsuit") challenging the legal adequacy of the 1992 Approvals.
C. In October, 1993 EBMUD adopted an updated Water Supply Management
Program and certified as adequate a final environmental impact report for the Program (the
"WSMP").
D. In December, 1993, the County, Windemere and Shapell filed lawsuits entitled
County of Contra Costa v. EBMUD et al., No. 727221-7, Windemere Ranch Partners v.
EBMUD et al, No. 727243-9 and Shapell Industries Inc. v. EBMUD et al., No. 727206-8, all
in Alameda County Superior Court (the "WSMP Lawsuits"), challenging the legal adequacy of
the EIR supporting the Water Supply Management Program.
E. On April 25, 1994, the Dougherty Valley Lawsuit was heard in Contra Costa
Superior Court before the Honorable David L. Allen. On May 26, 1994, the court issued its
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July 28, 1995 (Second Version)
ruling on the Lawsuit, holding that the 1992 Approvals were not legally adequate insofar as
they related to the provision of water. On September 23, 1994, The County, Windemere and
Shapell filed notices of appeal.
F. In January, 1995 the Board of EBMUD adopted the WSMP Action Plan for
potential use of American River water.
G. The parties desire to resolve these Lawsuits without further litigation, to
provide a framework for cooperation, to avoid future lawsuits, and to remove the pending
challenges to the WSMP and the 1992 Approvals. Accordingly, for good and valuable
consideration, it is hereby agreed as follows:
AGREEMENT
1. EARLY CONSULTATION BETWEEN EBMUD AND THE COUNTY
(a) The County and EBMUD desire to establish a cooperative mechanism
for.early consultation and coordination of water supply planning and land use planning.
EBMUD and the County recognize the County's responsibility for land use planning and
EBMUD's responsibility for water planning and delivery, including its responsibility to serve
existing customers and expected new customers within its existing service area, and to manage
the natural resources available to it without undue impacts on the environment.
(b) To facilitate consultation and coordination between the two agencies, the
Boards of the County and EBMUD shall continue the practice of holding joint meetings of the
Boards to discuss matters of mutual interest, such meetings to be held annually or as needed.
The meetings shall be scheduled by the County Administrator and the District's General
Manager.
(c) Designated staff from the County and EBMUD shall establish a regular
meeting schedule, with meetings to occur at least quarterly, for the purpose of carrying out the
consultation and coordination activities described herein.
(d) Exhibit A to this Agreement provides a process for the County's prompt
notification and consultation with EBMUD concerning development applications when
EBMUD may be considered a possible provider of water service. The purpose of notification
and consultation is to provide for early discussion and exchange of information related to the
water demand of such proposed new development, the timing of such new demand, the
availability of water supply and system capacity to meet the demand, and the impact, if any, of
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July 28, 1995 (Second Version)
such demand on service to existing customers taking into account other development projects
that are pending or proposed within the County. Where development outside the service area
of any water provider is under review by the County, early consultation will include
consideration of alternative providers.
(e) The County and EBMUD staff shall consult at the regularly scheduled
meetings or as needed with respect to the District's water supply planning. Consultation shall
include discussion and exchange of information related to the availability of water supply
sources, additional storage capacity, and additional facilities to meet the needs of existing and
future customers in the County both inside and outside the District's existing service
boundary. Where the District is considering the approval or rejection of options for securing
additional water supply or capacity, consultation will include consideration and discussion of
feasible alternatives.
(f) County and District staff shall also consult at the regularly scheduled
meetings or as needed with respect to other topics of mutual interest, including but not limited
to each agency's long-range planning activities, projected near-term land development
projects, reclamation and conservation programs and opportunities, water quality issues, and
cooperation on development of new water supplies.
(g) The County and the District will also discuss at their meetings pending
legislative proposals for coordination of land use and water service planning, and will consult
as to possible agreement on proposals for joint support in the legislature.
2. CONFIRMATION OF SERVICE TO COUNTRY CLUB AT GALE RANCH
(a) EBMUD confirms that the Country Club at Gale Ranch ("CCGR")
project is located within its current district boundaries, and that the District will provide water
service to that project. Consistent with the Preliminary Work Agreement between EBMUD
and Shapell and with the County's 1994 approvals, facilities will be sized to serve CCGR
only. In planning facilities, EBMUD will follow standard engineering practices, and will not
design a system for the purpose of precluding future options for extension of service.
(b) EBMUD will not oppose annexation of the elementary school site
located adjacent to existing district boundaries, as shown on Exhibit B, with the understanding
that the property would be used only for school and/or park purposes. At the time that
construction of the middle school, as shown on Exhibit B, is being planned, the parties will
consult to discuss which water district would be the most logical provider for that site. After
such consultation, if it is determined that EBMUD would be the most logical provider for that
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July 28, 1995 (Second Version)
site, EBMUD would not oppose annexation of the site into the District with the understanding
that the property would be used only for school and/or park purposes.
3. DISMISSAL OF CHALLENGE TO WSMP
EBMUD is proceeding with its WSMP, including the WSMP Action Plan
which includes potential use of American River.water. Within ten days following execution of
this Settlement Agreement, the County, Shapell and Windemere will dismiss with prejudice the
WSMP Lawsuits which would eliminate the challenge to implementation of the District's water
supply and storage alternatives contemplated therein. County, Shapell and Windemere further
agree not to file any lawsuit challenging the approval by EBMUD of actions implementing the
WSMP to the extent such actions are in substantial conformance with the WSMP as heretofore
approved by EBMUD, and so long as such actions are consistent with, and do not impair the
District's ability to carry out, this Agreement.
4. DESIGNATION OF DSRSD AS PREFERRED WATER PROVIDER
(a) Shapell and Windemere are using and will continue to use their best
efforts to secure permanent water service for that portion of the Dougherty Valley located
outside CCGR and the elementary school site (and, conditionally, the middle school site, as
described in paragraph 2), from the Berrenda Mesa Water District, and the Dublin San Ramon
Service District and/or Alameda County Zone 7. These efforts include negotiation of
contracts for the transfer, transmission and delivery of water, environmental review and
approval of the transfer and delivery of the water by applicable regulatory agencies, and
LAFCO approval of annexation by DSRSD of the above-described portion of the Property.
The specific actions and approvals anticipated, and a timetable for their expected dates of
completion, are described in Exhibit C.
(b) Shapell and Windemere will provide EBMUD with all non-confidential
documents prepared in connection with the process described in Exhibit C for review and
monitoring. Shapell and Windemere agree that they will consult with EBMUD regarding any
concerns EBMUD may raise relating to that process. The purpose of this provision is to
assure that EBMUD's ability to develop adequate water supplies for existing customers and
future developments within the existing service area, and EBMUD's existing water rights or
its efforts to secure additional water supplies, are not adversely affected by the proposed water
transfer and delivery. EBMUD reserves the right to comment throughout the process, but will
not oppose implementation of the program nor file any legal challenge to any aspect of the
DSRSD/Berrenda Mesa water transfer and delivery program, including the adequacy of
environmental review and annexation of the Property into DSRSD, to the extent it is carried
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out in substantial conformance with the program for the proposed water transfer as described
in the documents transmitted from Windemere to EBMUD on July _, 1995. The foregoing
waiver shall not bar a legal challenge by EBMUD in the event that the environmental impact
report for the proposed water transfer discloses information not previously provided to
EBMUD involving potential adverse effects upon EBMUD's existing water rights or its efforts
to secure additional water supplies.
(c) In the event the proposed DSRSD/Berrenda Mesa water supply cannot
be secured, Shapell and Windemere will use best efforts to secure water from alternative
sources or suppliers. In so doing, Shapell and Windemere will consult with EBMUD
regarding alternative methods of securing and delivering water which do not involve primary
water service from EBMUD. The County, Shapell and Windemere shall not initiate
annexation proceedings to any other provider before completing this consultation. EBMUD
will not file any legal challenge to any aspect of any alternate program for provision of water
to the Property, including the adequacy of the environmental review and annexation into any
other district, unless and to the extent that EBMUD's ability to develop adequate water
supplies for existing customers and future developments within the existing service area, and
EBMUD's existing water rights or its efforts to secure additional water supplies would be
adversely affected by the alternative water transfer and delivery program.
(d) Accomplishment of "best efforts" as referred to in paragraphs 4(a) and
(c) above shall require that Shapell and Windemere undertake in good faith a diligent and
timely effort to initiate and complete each action, and each regulatory approval process that is
necessary to secure permanent water service for Dougherty Valley from DSRSD/Berrenda
Mesa, including the anticipated actions and approvals identified in Exhibit C, Section B
hereto. In addition, in the event that the foregoing method of providing water service cannot
be secured, accomplishment of "best efforts" shall include the diligent pursuit of the additional
steps set forth in Exhibit C, Section C. "Best efforts" shall also include a significant financial
investment as set forth in Exhibit C.
(e) Upon execution of this Agreement, the County will initiate amendments
to the Dougherty Valley Specific Plan to designate DSRSD rather than EBMUD as the
preferred water provider outside of CCGR and, consistent with paragraph 2, the school sites.
Any reference to EBMUD as a potential water provider in the Specific Plan shall be consistent
with and include the conditions and limitations set forth in this Settlement Agreement. Prior to
action being taken by the County on the Specific Plan, EBMUD shall be given the opportunity
to review and comment upon the text of the proposed amendment in the manner specified in
paragraph 6(b) of this Agreement. Action on the Specific Plan Amendment shall occur prior
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July 28, 1995 (Second Version)
to or contemporaneous with any action taken by the Board of Supervisors on the Development
Agreements and rezoning for the Property.
(f) Approval of tentative subdivision maps for the Project shall be
conditioned on verification of an adequate water supply for the subdivision, the condition to be
satisfied prior to recordation of the final map, by verification that capacity exists to serve the
specific project ("will serve letters") or comparable evidence of adequate water supply.
Where EBMUD is proposed to provide water service to the Property or a portion thereof
pursuant to the terms, conditions, and limitations set forth in this Agreement, EBMUD shall
not be obligated to provide such verification unless and until the applicable portion has been
annexed to EBMUD in conformance with the terms, conditions and limitations set forth in this
Agreement.
(g) Under the circumstances and subject to the terms, conditions and
limitations set forth herein, including without limitation the requirements of paragraph 4(h):
(i) No earlier than July 1, 1999, Shapell and Windemere may submit to
EBMUD a request to initiate preliminary planning work for water service from EBMUD.
Upon receipt of such request, EBMUD will undertake the activities for preparation of a
preliminary work agreement ("PWA") referenced as "PWA Development" on Exhibit D to this
Agreement, not including retention of the consultant and execution of the PWA. EBMUD,
Windemere and Shapell shall utilize best efforts to complete these activities by December 31,
1999. All work performed by EBMUD pursuant to this request shall be undertaken at
Shapell's and Windemere's sole expense, and undertaking such work shall provide no
assurance for the provision of water service unless and until the Property is annexed to
EBMUD as provided herein.
(ii) At Shapell's and/or Windemere's request made no earlier than
January 1, 2000, EBMUD will enter into a PWA with Shapell and/or Windemere, retain
consultants as necessary and perform the work included in the PWA, including project
development, environmental documentation, and project design as shown on the estimated
timetable in Exhibit D. Any such planning, project development and design work shall be
undertaken at Shapell's and Windemere's sole expense, and undertaking such work shall
provide no assurance for the provision of water service unless and until the property is
annexed to EBMUD as provided herein.
(iii) EBMUD, Windemere and Shapell shall cooperate through the
exercise of best efforts to conduct and complete the activities in (ii) above in a timely manner
which (following annexation, facilities construction and other required activities) will allow
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commencement of hook-ups to the Property by January 1, 2002. The parties to the PWA shall
utilize all reasonably available techniques to reduce the estimated shortest time shown on
Exhibit D for performing the planning activities in (ii) above, including the use of outside
consultants at Windemere's and/or Shapell's. expense, and phasing of planning and
construction; provided, however, nothing herein constitutes a commitment or guarantee by
EBMUD that, despite the use of best efforts, activities in (ii), above, and construction
activities can be completed in time to commence hook-ups by January 1, 2002.
(iv) Shapell and Windemere shall not submit an application to LAFCO
for annexation to EBMUD of the Property outside of CCGR and the elementary school site
(and possibly the middle school site, as provided in paragraph 2), or any part thereof, prior to
July 1, 2000. EBMUD will cooperate beginning January 1, 2000 in providing in a timely
fashion information reasonably necessary for the preparation, submittal and processing of
such application. EBMUD agrees that it will not oppose any application for annexation of the
Property into the District filed on or after July 1, 2000, and (upon the successful completion of
annexation) will provide water service to the Property, but only upon the terms, conditions and
limitations set forth in paragraph (h) below. Any work done by EBMUD and any expense
incurred by Shapell and Windemere prior to commencement of annexation proceedings does
not relieve Shapell and Windemere from continuing their best efforts, as required in paragraph
4(h)(i), to secure an alternative water supply.
(v) EBMUD will not approve, or issue a request for bids for
construction of, EBMUD facilities to serve the Property prior to completion of annexation
proceedings and EBMUD will not provide hook-ups to the Property prior to January 1, 2002.
Upon successful completion of the annexation process, EBMUD will take all necessary steps
to complete the planning, review and implementation process needed for the provision of water
to the Property in a timely fashion. The anticipated specific actions and approvals required,
and an estimated timetable for completion of each based upon information currently known to
EBMUD, is attached hereto as Exhibit D. The parties to the PWA shall utilize all reasonably
available techniques to reduce the shortest estimated time shown on Exhibit D for performing
the planning, review and implementation process; provided, however, nothing herein
constitutes a commitment or guarantee by EBMUD that, despite the use of best efforts, the
planning, review and implementation process can be completed in time to commence hook-ups
by January 1, 2002.
(h) Shapell and Windemere agree that any annexation application, annexation,
and water service for the Property shall be subject to the terms, conditions and limitations set
forth below:
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July 28, 1995 (Second Version)
(i) Shapell and Windemere shall have worked through exercise of best
efforts as defined in Exhibit C to secure an alternative water supply for all or any portion of
the Property through Berrenda Mesa, DSRSD, Zone 7 or other providers, but without success.
Shapell and Windemere will not seek annexation for any portion of the Property for which a
permanent alternative water supply has been secured.
(ii) Until such time as a sufficient water supply is available to meet
demand in the EBMUD service area and the Property, as determined in the manner set forth in
Exhibit E, water service for any portion of the Property outside CCGR and the school sites
shown on Exhibit B shall be subject to an offset fee to fund the cost of conservation programs
or other methods necessary to offset additional water demand created by new hookups in the
development. The calculation for the offset fee, and provisions governing payment of the
offset fee are set forth in Exhibit F
(iii) The number of new water service hook ups per year would not
exceed 600. Any hook ups not used in any given year may be carried forward to future years,
but in no event shall the number of hookups in any given year exceed 750.
(iv) During any period in which the District has declared a drought
emergency pursuant to Water Code § 350, EBMUD would issue no new water service hook-
ups to the Property, and County, Windemere and Shapell would not submit an application to
LAFCO for annexation to EBMUD and would request that LAFCO withhold decision on any
pending application for annexation to EBMUD.
(i) It is expressly understood and agreed that notwithstanding any other
provision of EBMUD policy or regulation, any amounts paid by Windemere and/or Shapell to
EBMUD for planning or design for water service to the Property pursuant to this paragraph 4
shall be credited to and result in an equivalent reduction of the System Capacity Charge
applied to the development and shall not be refunded directly to Windemere and/or Shapell.
0) If EBMUD determines, in its sole discretion, that it has adequate water
to serve new customers outside the District's boundaries, Shapell and/or Windemere may
apply to EBMUD for water service without the restrictions and limitations set forth in this
Agreement, and EBMUD will give impartial consideration to such application. However,
EBMUD does not contemplate allowing such applications at this time.
5. PROJECTS MUST BE DESIGNED TO ACCOMMODATE RECLAIMED
WATER
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EBMUD and the County will require that the projects in the Dougherty Valley
be designed and built to accept and utilize reclaimed water for irrigation purposes in public
and semi-public areas. County, Shapell and Windemere will consult with EBMUD in order
that reclaimed water programs contemplated for the Dougherty Valley may be coordinated and
compatible with EBMUD's reclamation programs.
6. DEVELOPMENT AGREEMENTS TO BE CONSISTENT WITH THIS
AGREEMENT
(a) County, Shapell and Windemere agree that any development agreements
that may be adopted for the Property shall be consistent with and shall not abrogate or limit
compliance with or implementation of, the provisions of this Settlement Agreement.
Specifically, any development agreement adopted for the Property shall include the substance
of the following provisions:
(i) The Dougherty Valley project, including any subsequent
modifications, shall be subject to all terms and provisions of this Settlement Agreement; and
(ii) Nothing provided in any development agreement adopted for the
Property is intended to or does abrogate or limit the enforceability or effectiveness of this
Settlement Agreement. If there is conflict between any such development agreement, if such is
approved, and this Settlement Agreement, the terms of this Settlement Agreement shall
prevail.
(b) County, Shapell and Windemere agree that any preliminary data relating
to proposed development agreements which is submitted to the Dougherty Valley Oversight
Committee shall also be submitted to EBMUD at the same time. In addition, at least 15 days
prior to the presentation of such agreements to the County Board of Supervisors, the County,
Windemere and Shapell shall provide the text of the agreements to EBMUD for its review
with respect to the substance of the provision required by this paragraph. The County,
Windemere and Shapell shall make every reasonable effort to incorporate into such agreements
EBMUD's comments on the language of any provisions relating to the obligations set forth in
this paragraph.
(c) The County, Windemere, and Shapell agree not to seek or approve
revisions to any development agreement for the Property following its initial adoption in any
manner which limits, conditions, restricts, or abrogates any provision of this Settlement
Agreement. The County, Windemere and Shapell will submit any such proposed revisions to
EBMUD for comment in the manner specified in subparagraph (b) above.
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7. RESOLUTION OF LAWSUIT RELATING TO THE 1992 APPROVALS
(a) The parties desire to resolve all disputes relating to the 1992 Approvals,
and to that end, all parties agree to take action jointly to accomplish by appropriate procedures
and with the appropriate court(s) the vacation, elimination or modification of the Judgment and
Writ of Mandate and/or dismissal of the Dougherty Valley Lawsuit, in order that the 1992
Approvals remain in effect. In the event that the settlement agreements in the case of Town of
Danville et al v County of Contra Costa et al (C93-00231) are effectuated prior to the
effective date of this Settlement Agreement, the parties agree to join in the collective efforts of
all the parties to the two lawsuits to accomplish by appropriate procedures and with the
appropriate court(s) the vacation, elimination or modification of the Judgment and Writ of
Mandate and/or dismissal of the Dougherty Valley Lawsuit in order that the 1992 Approvals
and supporting EIR remain in effect. EBMUD further agrees not to file any action against the
approval of any Development Agreements, rezonings or Preliminary Development Plans for
the Property to the extent such approvals are in substantial conformance with the 1992
Approvals as modified to reflect the Country Club at Gale Ranch approvals, this Settlement
Agreement, and any other settlement agreements entered into to settle the lawsuit entitled
Town of Danville et al v County of Contra Costa et aL. EBMUD retains the right to
oppose and file a legal challenge against such approvals, and any other subsequent approvals
for the Project, with respect to the subject of water availability or quality to the extent such
approval or approvals are not based upon or in substantial conformance with the 1992
Approvals as modified to reflect the Country Club at Gale Ranch approvals, this Settlement
Agreement, and any other settlement agreements entered into to settle the lawsuit entitled
Town of Danville et al v County of Contra Costa et al .
(b) Except as otherwise provided in paragraph 4(b) EBMUD retains its right
to comment upon and oppose future Dougherty Valley project-level applications (such as
tentative maps) and any future environmental impact reports that may be required, with respect
to the subject of water availability or quality. EBMUD also retains the right to oppose and
legally challenge any approvals which seek to designate EBMUD as the preferred water
provider or to annex any of the Property to EBMUD to the extent they are inconsistent with
the provisions of this Settlement Agreement.
8. DISPUTE RESOLUTION PROCESS
(a) If a dispute arises relating to the interpretation of, enforcement of or
compliance with the terms and provisions of this Agreement, the parties to the dispute will
first attempt to resolve it through informal discussions, which may include designated
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representatives of Shapell and Windemere, the County and EBMUD. Any party may convene
such discussions through written notice delivered by confirmed facsimile transmission or
overnight delivery to the other parties, providing at least ten days' notice, and setting a date,
time and place for such discussions. The convening party shall reasonably accommodate the
parties' schedules in selecting and/or altering the date and time of the discussions. In the
event a dispute cannot be resolved in this manner within twenty-one (21) days, upon
agreement among the parties, the dispute may be referred to a mediation process.
(b) The dispute resolution process described above shall be undertaken in
good faith and exhausted prior to judicial review; provided, however, that no parry to this
Agreement hereby loses or waives its right to file an action to comply with any applicable
statute of limitations or loses or waives its right to assert the operation of any applicable
statute of limitations as an affirmative defense. In the event that an applicable statute of
limitations would expire during the pendency of the dispute resolution process described
above, the parties may agree in writing to toll such statute of limitations for such period as
may reasonably be necessary to complete the dispute resolution process.
9. RULES AND REGULATIONS GOVERNING WATER SERVICE TO
CUSTOMERS OF EBMUD; FRUSTRATION OF PURPOSE
Any water service provided to the Property by EBMUD pursuant to the terms,
conditions and limitations of this Agreement shall be subject to compliance by Windemere and
Shapell with the lawful and non-discriminatory application of the Rules and Regulations
Governing Water Service to Customers of EBMUD, and any amendments thereto that may be
adopted. In no event, however, shall any party to this Agreement take any action (whether by
the amendment of said Rules or otherwise) which has the purpose or effect of frustrating the
accomplishment of the purposes of this Agreement or the exercise of the rights conferred
under this Agreement; provided, however, that actions of the District to (a) modify its rates,
charges and fees, (b) adopt reasonable revisions to its engineering standards and practices, and
(c) provide for compliance with standards, requirements and regulations promulgated by
federal, state, and local authorities other than EBMUD shall not be deemed to frustrate the
accomplishment of the purposes of this Agreement.
10. GENERAL PROVISIONS
(a) Each party expressly waives any rights or benefits available to it under
the provisions of Section 1542 of the California Civil Code, which provides as follows:
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A general release does not extend to claims which the creditor
does not know or suspect to exist in his favor at the time of
executing the release, which if known by him must have
materially affected his settlement with the debtor.
(b) Each party represents that the contents of this Agreement have been
explained to it by its duly authorized counsel and that this Agreement is executed voluntarily,
with full knowledge of its significance and contents and with full authority.
(c) The terms and conditions of this Agreement shall be binding upon, and
inure to the benefit of, the parties to this Agreement and their respective successors and
' assigns.
(d) This Agreement constitutes the entire Agreement among the parties with
respect to the subject matter hereof and supersedes any prior understandings or agreements
among the parties, whether oral or written. This Agreement may not be amended or modified
unless made in writing and signed by each of the parties. Where an amendment or
modification that would affect only one of the Property owners need not be approved by the
other Property owner.
(e) Neither the negotiation of this Agreement, nor any action taken to carry
out this Agreement, (i) is or may be construed or used as an admission or concession by or
against any party to this Agreement of any fault, wrongdoing or liability, or (ii) may be
offered or received in evidence in any action or proceeding against any Party to this
Agreement in or before any court, administrative agency or tribunal for any purpose;
provided, however, that this Agreement and its exhibits may be filed in the Lawsuit as
evidence thereof. The Parties to this Agreement further agree that the provisions of California
Evidence Code Sections 1152 and 1154 apply to all negotiations and settlement discussions
leading to, and all actions taken to carry out, this Agreement, and that such negotiations,
discussions and actions shall not be admissible for any purpose other than as necessary to
effectuate, enforce or defend the provisions of this Agreement.
(f) Shapell and Windemere will each pay to EBMUD attorneys fees in the
amount of$97,000, payable within five business days following disposition of the Dougherty
Valley Lawsuit pursuant to paragraph 7(a) of this Agreement. This obligation is several and
not joint. Except as provided herein, each party shall bear its own costs and fees incurred in
the Lawsuit and this Settlement Agreement.
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July 28, 1995 (Second Version)
(g) Shapell and Windemere agree and warrant that they will provide a copy
of this agreement to any purchasers, assignees or successors-in-interest of the Property who
will be affected and governed by the terms and conditions of this Agreement, prior to the
transfer of title. In the event of the failure to provide the foregoing notice, Windemere and
Shapell agree to defend, indemnify and hold EBMUD harmless from any and all loss or
expense incurred by EBMUD resulting therefrom, provided that the developer affected shall
have the right to assume the defense of any claim made or action brought against EBMUD on
the basis of which EBMUD makes a claim under this paragraph 10(g). In addition, the
County, Windemere and Shapell agree that the requirements of this Agreement shall be
incorporated into conditions of approval subsequently issued within the Property if EBMUD is
proposed to provide water service to the portion of the Property affected by the approval.
COUNTY OF CONTRA COSTA
Date: 1995 By:
Chair of the Board of Supervisors
Date: 1995 EAST BAY MUNICIPAL UTILITIES
DISTRICT
By:
Chair of the Board of Directors
Date: 1995 SHAPELL INDUSTRIES OF
NORTHERN CALIFORNIA
By:
President
13
DRAFT
July 28, 1995 (Second Version)
Date: 1995 WINDEMERE RANCH PARTNERS
By:
Managing Partner
14
DRAFT
July 28, 1995 (Second Version)
EXHIBIT LIST
EXHIBIT A Process for notification and consultation concerning land use and water
service matters.
EXHIBIT B School Sites
EXHIBIT C DSRSD steps and timetable and "best efforts" steps.
EXHIBIT D Timeline for Planning/Design/Annexation/
Construction
EXHIBIT E Method for determination sufficiency of water supply system
EXHIBIT F Offset fee calculation and provisions governing payment
15
DRAFT
July 28, 1995 (Second Version)
EXHIBIT C
Efforts to Obtain Water Service from Source Other than EBMUD
Paragraph 4 of this Agreement provides as a condition to certain EBMUD
obligations that Shapell and Windemere will have exercised best efforts to secure an alternative
water supply (through DSRSD, Zone 7 or other providers). Windemere and Shapell have
undertaken or intend to undertake all reasonable and appropriate steps to obtain such water
including those set forth below. To the best of Windemere and Shapell's knowledge, the
activities, actions and approvals set forth below is a complete and accurate list of steps needed
to secure permanent water service from a supplier other than EBMUD. In the event that
additional activities, actions or approvals are subsequently identified which in the exercise of
diligence should be undertaken in securing alternative permanent water service, such additional
efforts will be diligently pursued as though they were included within this Exhibit C.
Windemere and Shapell will continue to exert all reasonable efforts in
furtherance of securing permanent water service from a supplier other than EBMUD until such
time as application is made for annexation to EBMUD pursuant to the terms, conditions and
limitations of paragraph 4 of this Agreement. Windemere and Shapell shall provide reports
three times per year to EBMUD describing the activities and accomplishments since the
previous report with regard to each of the activities, actions, and approvals set forth in this
Exhibit C. Each report also shall provide updated information concerning the schedule for
expected completion of each element in this Exhibit C and shall describe any newly identified
elements for addition to Exhibit C including the estimated dates for completion of the new
elements.
Windemere and Shapell shall be deemed to have used "best efforts" for the
purposes of this Agreement if and when:
• in addition to undertaking each of the actions specified in Sections A and B
below, they collectively have expended funds in the aggregate amount of
$500,000 or more in furtherance of such actions; and
• under the circumstances specified in Section C below, Windemere and Shapell
undertake the actions specified in Section C below and they collectively have
expended funds in the aggregate amount of$250,000 or more in furtherance of
such actions.
16
DRAFT
July 28, 1995 (Second Version)
A. Initial Survey
For over two years, Windemere and Shapell have undertaken an extensive
search to identify viable sources of water as an alternative to EBMUD. Extensive discussions
with State Water Project contractors and other entities with claims to State Water Project
entitlements have occurred, including districts in San Joaquin, Calaveras, Amador, Stanislaus
and Kern counties. A variety of other potential sources were considered, including the
Mokelumne River and the American River. Through this process, entitlements held by
Berrenda Mesa Water District presented the most immediately practicable option for obtaining
a successful transfer that would provide a permanent source of water for Dougherty Valley.
As a result, Windemere and Shapell have undertaken or intend to undertake the steps set forth
in Section B, below, to effectuate such a transfer.
B. Berrenda Mesa Water District
1. Water District Contracts
• Enter into a reimbursement agreement between DSRSD and Windemere for the
purchase of Berrenda Mesa water. (Complete)
• Obtain water purchase agreement between DSRSD and Berrenda Mesa
("Berrenda Mesa/DSRSD Contract"). (Complete)
• Confirm State Water Project Contractors' agreement to the Monterey
Principles, allowing for permanent transfers and making both agricultural and
municipal contractors subject to equitable reductions in water supply during
drought shortages. (Complete)
• Amend Berrenda Mesa/DSRSD Contract to add Shapell as party. (Complete)
• Obtain Kern County Water Agency approval of Berrenda Mesa/DSRSD
Contract. (Complete)
2. Zone 7
• Obtain DSRSD Board's formal request of Zone 7 to deliver, transport and store
water entitlements obtained from Berrenda Mesa ("DSRSD Request").
(Complete)
17
DRAFT
July 28, 1995 (Second Version)
• Obtain Zone 7 Board approval of DSRSD Request after certification of the Final
EIR, as described in Section B.3, below. (Expected December 1995)
3. Complete environmental review for transfer, storage, treatment and conveyance
of water from Berrenda Mesa Water District to DSRSD. (Certification of Final
EIR expected December 1995)
4. LAFCO Actions
• File LAFCO application for annexation to DSRSD. (Expected December 1995)
• Obtain LAFCO approval of annexation of Dougherty Valley (other than CCGR
and school sites adjacent to CCGR) to DSRSD. (Expected January 1996)
5. Other Agencies
• Obtain Department of Water Resources approval of transfer of Berrenda Mesa
Water to DSRSD. (Expected February 1996)
C. Alternative Methods of Delivery and Sources of Water
Although Windemere and Shapell anticipate that all of the actions necessary for
the Berrenda Mesa transfer, conveyance, storage and delivery can be completed in a timely
manner, it is possible that unforeseen physical or fiscal constraints will prevent either the
contemplated method of delivery or the legal transfer of water rights from this particular
source. In such event, Shapell and Windemere will initiate other efforts to secure alternative
methods of delivery of water sources. As appropriate, these efforts will include the following:
1. With respect to the method of delivery, it is possible that, although all other
steps necessary for the transfer may occur, use of Zone 7 facilities will prove infeasible. If
and when such an event occurs, but in no event later than July 1, 1996, Windemere and
Shapell will promptly commence and diligently pursue the following:
• Initiate design work for construction of new DSRSD water treatment plant and
conveyance facilities.
• Study and initiate necessary contractual negotiations for storage alternatives,
such as Semitropic Water Storage District Groundwater Bank, New Melones
Reservoir or Los Vaqueros Reservoir.
18
DRAFT
July 28, 1995 (Second Version)
• Requesting DSRSD to initiate such actions as may be necessary for DSRSD to
become a contractor with the State Water Project.
2. If all actions necessary to accomplish the Berrenda Mesa transfer are not
completed by July 1, 1996, Windemere and Shapell at that time will promptly and diligently
pursue the following:
• Conduct a statewide search for water from other sources, including other State
Water Project contractors and entities previously contacted, and other holders of
contractual water supply entitlements and state-issued water rights.
• Initiate discussions with parties identified as potential sources through statewide
search.
• Make preliminary determinations regarding legal, financial and technical
feasibility of possible sources.
• Actively pursue negotiations with feasible candidate sources.
• If such negotiations are successfully progressing with respect to a potential
feasible source or sources, conduct preliminary engineering analysis and
environmental review and identify necessary governmental approvals.
• If the above steps are successful, complete engineering analysis, environmental
review and obtain necessary governmental approvals.
• Upon obtaining necessary governmental approvals, commence design and
construction work necessary to effectuate transfer and conveyance.
19
DRAFT
July 28, 1995 (Second Version)
EXHIBIT E
METHOD AND STANDARD FOR DETERMINING THE SUFFICIENCY OF THE
EBMUD WATER SUPPLY SYSTEM FOR EXISTING AND FUTURE NEEDS BOTH
FOR THE DISTRICT'S SERVICE AREA AND THE PROPERTY
To determine the sufficiency of the District's water supply system to meet
current and future demand in the EBMUD service area and the Property, the District will
perform a computer analysis using its EBMUDSIM computer model. The water supply
system will be deemed sufficient if the analysis shows that the water supply system can meet
existing and future demand in the District's service area and the Property through the design
' drought cycle without requiring rationing in excess of 25% as set forth in the District's
September 1993 Final Environmental Impact Report on its Updated Water Supply Management
Program ("WSMP").
Except as modified herein, all model assumptions contained in such analysis
shall be identical to those used to determine the 130 TAF Need for Water reported in the
WSMP. Assumptions regarding instream flow and reservoir operating criteria related to
fishery or other in-stream resource protection requirements will be modified to reflect the
District's offer of settlement to the Federal Energy Regulatory Commission ("FERC") and
will be subject to further modification based upon results of the State Water Resources Control
Board, FERC, or other regulatory proceedings with jurisdiction affecting EBMUD water
supplies which address these requirements. Assumptions regarding system capacity
components which reduce the need for water such as addition of a connection to the Folsom
South Canal, addition of storage to Pardee Reservoir, institution of a conjunctive use program,
water reclamation projects, water conservation programs or similar capacity components, will
be subject to modification. The capacity of Camanche Reservoir will be reduced from 430
A.F. to 413 A.F. to reflect recent survey data. Upon execution of this Agreement, a complete
set of computer printouts delineating the District's need for 130 TAF of additional capacity
will be delivered to the designated representative of Windemere and Shapell. Whenever the
District makes a determination of system delivery capacity pursuant to this section, a complete
set of computer output will be delivered to the parties to this Agreement.
20
DRAFT
July 28, 1995 (Second Version)
EXHIBIT F
CALCULATION OF OFFSET FEE AND
PROVISIONS GOVERNING PAYMENT OF OFFSET FEE
The offset fee shall be 1.65 times the Future Water Supply ["FWS'] portion of
the System Capacity Charge ["SCC"I in effect at the time that the offset fee is paid and the
base amount of the FWS shall be credited against the SCC paid at the time of hook-up. The
Property shall constitute a separate SCC region. Water demand figures for residential and
commercial structures to be utilized in computing the offset fee will be calculated according to
the method utilized by EBMUD for its System Capacity Charge unit demand calculations, and
will take into account the following factors, among others: Actual use by households in the
area expected to exhibit similar potable water demand characteristics; Specific Plan restrictions
and other conditions of approval which have an impact on water usage, such as requirements
for xeriscaping, the use and availability of reclaimed water for public and semi-public areas,
and other relevant design features; and the varying lot sizes of each type of single family
residence. The water demand figures shall be determined prior to payment of the first offset
fee. Unit water demand will be recalculated based upon actual water use within the Property
measured beginning the second year following occupancy.
The offset fee shall be paid no less than one year prior to the issuance of the
water meter for the residential or commercial structure or other use. Within 30 days of the
date on which it is determined that EBMUD has developed a sufficient water supply (as
defined in Exhibit E), that portion of the offset fees which reflects .65 times the FWS portion
of the SCC shall be refunded for any units for which an offset fee has been paid but for which
no water meters have been issued. If construction on the Property is halted, at the request of
the payor(s), the offset fees for some or all of the units which have not been issued a water
meter shall be refunded, except that EBMUD shall retain .65 times the FWS for each such unit
and shall have no further obligation to Windemere and Shapell as to any such funds retained
by EBMUD. A halt in construction shall be defined as a six-month period during which no
water meters have been issued.
As an alternative to payment of the offset fee, until sufficient water is available
as determined in the manner set forth in Exhibit E, Windemere and Shapell may secure an
alternate source of water, of a quality and quantity satisfactory to EBMUD and not involving
water under consideration as a possible alternative source for EBMUD under its WSMP,
which EBMUD could purvey on an interim or permanent basis. EBMUD will reasonably
cooperate in the foregoing, subject to payment by Windemere and Shapell of all costs incurred
by EBMUD.
21
ATTACHMENT B -
SUI-WNfA RY OF
.AGREEMENT TO SETTLE LITIGATION RELATING TO
THE DOUGIMRTY VALLEY GENERA.PLAN AMNDII MT,SPECIFIC PLAN
AND ENVMONMMEENTAL DVACT REPORT
AN^D RELATING TO THE WATER SUPPLY MANAGEMENT PROGRAM
AND ENVIRONMENTAL UVRACT REPORT
OF'TEW EAST BAY MUNICIPAL UTILITY DISTRICT
The Board of Diractm of East Bay Mwicipal Chihty District will be consideaing approval of a
proposed settlement agreemmt whkh sets forth the terms and conditions under which the district
would dismiss its lawsuit entitled MRM v, rmnty Cmbm Costa eta .,No.C93.00233,in Contra
Com County Superior Court,chali"ing the county's approval of a Cvm=W Pian Anmdment and
a Specific Plan for DouOaty Valley,And the mvironrnartal impact report on which such approval
was based. The settlement agrcom ant also provides fen'dismissal of the lawsuit filed by Contra
Costa County,Windemae Ranch,.Partners,and Shapell Industries ofNordmm Califomk cbal,lenging
the envffon=tat impact report preparad by ESMUD far its dater Supply Mansgarncmt Program
adopted in October 1993. Provisions of the agreement are anmmnrbed as follows;
Section 1. Zl.RLYC0NST LTATJ0NB,ET WEENEBAfUD AND 7M COUNTY
Under the agm=e:nt,EBMUD and the county would establish a regular meeting schedule for the
purpose of coordinating activities related to water supply planning and land use planning. A
notification and consultation process would be established to provide for early discussion and
exchange of infonnati.on related to water demaad of proposed new development,the availability of
water supply and sysW=capacity to meet the demand,the impact on service to existing customers,
and avajlal>ility of water supply sou Ices to meet The needs of existing and future customm ia the
county.
Section x. CONFflt7t 77ON OF SERC7CE TO C'OUNTRY CL UR AT GALE)L4NCE
The agrmxnnrtt would confim the provision of water service to the Country Club at Cale Ranch,
which is located 'within the district's Current service boundaries, and further confirms that water
supply facilities will be simd to save the Country=Ctub at kale Rich only. ERMUD would agree
not to oppose amexation of school sites located wear the Country Club at Gale Bauch development
and adjacent to the existing EBMUD boundary,provided that such school sites would be used only
for school and/or part purposes.
A-
section 3. DISMISSAL SAL OF CMA4 LENGE TO WSMP
The agreement would ,provide for dismissal of the action filed by the courxty, shapall and
Windemere,cW1enging the adequacy of the environmental impact report for adaption of EBMi TD's
Water supply Management program.
Section4. DESIGNATION UFDSRSD AS PREFERRED WATER PROVIDER
The agreement would require Shapell and Windersiere to continue to use best efforts to secure
permanplt water service for the Dougherty Malley from the Dublin San Ramon Servicce District,
as an alternative to seekitg water service from EBMUD. These of its include cottrracts for the
transfer and delivery of water from Betrenda Mesa Nater District to DSRSD, environmental
documentation,approval by applicable regulmory agcoti-es,and LAFCC approval of annexation of
the Daugherty Valley property to ASRSD. In the event tha proposed 13SRSDAImmda Mew water
supply cannot be delivered using Zone 7 facilities,Sbapell and WmdcmGre will initiate efforts to
secure altemative methods of transfer and delivery,including design work for new DSRSD treatment
and conveyance facilities. it actions nacessmy to accomplish the Berrenda Mesa transaction are not
completed by My 1, 1996,Wmdm nere and Shapell will pursue efforts to obtain a watsr supply from
other sources,including other'State Waier Project contractors. Best efforts also inch a significant
!Rn=ial investment of 5750,040 in efforts to secure an altmutive rawly for Dougherty Valley.
Section 4 of the agreement specifies terms, conditions and limitations which would apply in the
event that Shapell and Windermere are unsuccessful in securing an afternahive water supply for
Daugherty Valley{having worked to do so in urordame with the provisions of the agreement),and
seek annexation for any poWon of the Dougherty Valley to EBMUD. The terms,conditions and
limitations which would appy to such application for annexation to EBMUD are s==mrized as
follows:
(a) Shzpell and Windemore would not submit an application to LAFCC for an=atiozs to
F,BMUD of Dougherty Vey property prior to July 1, 2000. BBMUD would not oppose such
applinatian for annexation subject to the following conditions;
1) Shapell snd Wiadempre have completed best efforts, as defined in the
agroo=n# t4 secure an alterzadve water supply,but have been.unsuccessful;
2) water service for any portion of Dougherty Valley would'be subject to an
offset fee to fund the cost of conservation programs or other methods
necessary to offset additional water demand created by new hook-ups is the
developmctrt. The offset fee would be calculated at 1.65 times the Future
Water Supply portion of the ERMUD Syswm Capacity Cliarp in effect at
the firm of payment. The offset fee would be paid no less than one year prior
to the issuanc-e of the water meter is order that programs to offset the new
demand can be implemented in advance;
-2-
71 the number of new water service hook-itps per year would not exceed 600;
4) during any period in which the district has declared a drought emergency
pursuant to Water Code section 350, EBMUD would issue no new water
service hook-ups to the property,and,there would be no application made to
LAFCO for w=xation to EBMUD;and
5) ESMUD would not provide water service hook-ups within the annexed
Dougherty Vallcy property toy time prior to January 1,2002.
(b) In order to allow for planning of facilities necessary to commence delivfty of water service
after January 1, 2002,planniug work could be undertaken at Shapell and Winde3mere's expose,
commencing January 1,2000,but such work would provide no assurance for the provisio n of wader
service unless mid until the property is annexed to EBNIUD subject to the terms,limitations and
conditions ofthe agreement
Section 3. Pizom s MUST BE D.SSIGNED TO ACCOMMODATE RECL&MEI'?
WATER
f
The agreement would provide that EB WM and the county will require dw projects in Dougherty
Valley be designed W built to accept and utilize reclaimed'water for irrigation purposes in public
and semi-public areas.
N2cfian f. DEVELOPMENT AGREEMENTS TO BE CONSISTENT 07TH TIM
SETTLE MVTAGR Y-MENT
The agreement would provide that any developmwt agreements that may be adopted for Doughmty
Valley shall be consistent with the terms,conditiow and limitations of the setdament agrement,and
any development agreement adopted far the property shall reference the terms and pw vWons of the
settlement agreement.
Section 7 RESOLUTION OF LAWSUIT REY A77NG TO THE.7992 APPROVALS
Based upon,the terms of the serd=ent agrccm=t,the pard es would jointly scat:modiftcataion of the
judgment and writ of m=daw avdlnr dismissal of the Dougherty Vd L-y law=it,d=eby leaving the
1992 General Plan Amendment and Speeific Flan for Dougherty Valley in effect.
Section 8. DISPUTE RESOLUTIONPROCESS
This section would provide for an infontlal dispute resolution process,prior to initiatim of litigation,
to resolve any dispute that may arise relating to the inhapretation of, caforccmcro o�or compliance
with the terms of the settlement agreement.
-3
i
s
Section 9 RULES AND REGULATIONS GOVERN)NG DATER SERPTCE 2'O
C4 STOMEBS OF MY UD;FR LS'TRATION OF PURPOSES
This section would specify that water service provided to Dougherty Valley by EBMUD,pursuant
to the turns,conditions and limitations of the settaemiu t agent,would be subject to compliance
by Mrwdem=and Shapell with the rules and regulations gov=ing water=-vice to custornrrs of
B$MIJD. =This section would furfur provide that no party shall take any action which has the
pose or effect of frustrating the purposes of the agreement or the exercise of rights conferred
under the agreement.
Section 10. GEIVERAL PROVISIONS
Under section 10 of the Agreement,Shapell and Windemere would pay EBMUD attomays' fees in
the amount of$194,000.
-4-
AGREEMENT TO SETTLE LITIGATION RELATING TO THE
DOUGHERTY VALLEY GENERAL PLAN AMENDMENT, SPECIFIC PLAN
AND ENVIRONMENTAL IMPACT REPORT AND RELATING TO
THE WATER SUPPLY MANAGEMENT PROGRAM AND ENVIRONMENTAL
IMPACT REPORT OF THE EAST BAY MUNICIPAL UTILITY DISTRICT
This Agreement is entered into by and among the East Bay Municipal Utilities
District, a municipal utility district ("EBMUD" or the "District"), the County of Contra Costa,
a political subdivision of the State of California (the "County"), Windemere Ranch Partners, a
California limited partnership ("Windemere"), and Shapell Industries of Northern California, a
Division of Shapell Industries Inc., a Delaware corporation ("Shapell"). This Agreement is
effective as of August 8, 1995.
RECITALS
A. Windemere and Shapell are the owners of certain_real property (the "Property")
in the Dougherty Valley, which is located in an unincorporated area of southern Contra Costa
County. On December 22, 1992, the County approved a General Plan Amendment and a
Specific Plan for the Property, and certified as adequate a final environmental impact report
for the project (the "1992 Approvals").
B. In January, 1993, EBMUD filed a lawsuit entitled EBMUD v. County of
Contra Costa et al., No. C93-00235, in Contra Costa County Superior Court (the "Dougherty
Valley Lawsuit") challenging the legal adequacy of the 1992 Approvals.
C. In October,,1993 EBMUD adopted an updated Water Supply Management
Program and certified as adequate a final environmental impact report for the Program (the
11 WSMP").
D. In December, 1993, the County, Windemere and Shapell filed lawsuits entitled
County of Contra Costa v. EBMUD et al., No. 727221-7, Windemere Ranch Partners v.
EBMUD et al, No. 727243-9 and Shapell Industries Inc. v. EBMUD et al., No. 727206-8, all
in Alameda County Superior Court (the "WSMP Lawsuits"), challenging the legal adequacy of
the EIR supporting the Water Supply Management Program.
E. On April 25, 1994, the Dougherty Valley Lawsuit was heard in Contra Costa
Superior Court before the Honorable David L. Allen. On May 26, 1994, the court issued its
ruling on the Lawsuit, holding that the 1992 Approvals were not legally adequate insofar as
they related to the provision of water. On September 23, 1994, The County, Windemere and
Shapell filed notices of appeal.
F. In January, 1995 the Board of EBMUD adopted the WSMP Action Plan for
potential use of American River water.
1
G. The parties desire to resolve these Lawsuits without further litigation, to
provide a framework for cooperation, to avoid future lawsuits, and to remove the pending
challenges to the WSMP and the 1992 Approvals. Accordingly, for good and valuable
consideration, it is hereby agreed as follows:
AGREEMENT
1. EARLY CONSULTATION BETWEEN EBMUD AND THE COUNTY
(a) The County and EBMUD desire to establish a cooperative mechanism
for early consultation and coordination of water.supply planning and land use planning.
EBMUD and the County recognize the County's responsibility for land use planning and
EBMUD's responsibility for water planning and delivery, including its responsibility to serve
existing customers and expected new customers within its existing service area, and to manage
the natural resources available to it without undue impacts on the environment.
(b) To facilitate consultation and coordination between the two agencies, the
Boards of the County and EBMUD shall continue the practice of holding joint meetings of the
Boards to discuss matters of mutual interest, such meetings to be held annually or as needed.
The meetings shall be scheduled by the County Administrator and the District's General
Manager.
(c) Designated staff from the County and EBMUD shall establish a regular
meeting schedule, with meetings to occur at least quarterly, for the purpose of carrying out the
consultation and coordination activities described herein.
(d) Exhibit A to this Agreement provides a process for the County's prompt
notification and consultation with EBMUD concerning development applications when
EBMUD may be considered a possible provider of water service. The purpose of notification
and consultation is to provide for early discussion and exchange of information related to the
water demand of such proposed new development, the timing of such new demand, the
availability of water supply and system capacity to meet the demand, and the impact, if any, of
such demand on service to existing customers taking into account other development projects
that are pending or proposed within the County. Where development outside the service area
of any water provider is under review by the County, early consultation will include
consideration of alternative providers.
(e) The County and EBMUD staff shall consult at the regularly scheduled
meetings or as needed with respect to the District's water supply planning. Consultation shall
.include discussion and exchange of information related to the availability of water supply
sources, additional storage capacity, and additional facilities to meet the needs of existing and
future customers in the County both inside and outside the District's existing service
boundary. Where the District is considering the approval or rejection of options for securing
additional water supply or capacity, consultation will include consideration and discussion of
feasible alternatives.
2
(f) County and District staff shall also consult at the regularly scheduled
meetings or as needed with respect to other topics of mutual interest, including but not limited
to each agency's long-range planning activities, projected near-term land development
projects, reclamation and conservation programs and opportunities, water quality issues, and
cooperation on development of new water supplies.
(g) The County and the District will also discuss at their meetings pending
legislative proposals for coordination of land use and water service planning, and will consult
as to possible agreement on proposals for joint support in the legislature.
2. CONFIRMATION OF SERVICE TO COUNTRY CLUB AT GALE RANCH
(a) EBMUD confirms that the Country Club at Gale Ranch ("CCGR")
project is located within its current district boundaries, and that the District will provide water
service to that project. Consistent with the Preliminary Work Agreement between EBMUD
and Shapell and with the County's 1994 approvals, facilities will be sized to serve CCGR
only. In planning facilities, EBMUD will follow standard engineering practices, and will not
design a system for the purpose of precluding future options for extension of service.
(b) EBMUD will not oppose annexation of the elementary school site
located adjacent to existing district boundaries, as shown on Exhibit B, with the understanding
that the property would be used only for school and/or park purposes. At the time that
construction of the middle school, as shown on Exhibit B, is being planned, the parties will
consult to discuss which water district would be the most logical provider for that site. After
such consultation, if it is determined that EBMUD would be the most logical provider for that
site, EBMUD would not oppose annexation of the site into the District with the understanding
that the property would be used only for school and/or park purposes.
3. DISMISSAL OF CHALLENGE TO WSMP
EBMUD is proceeding with its WSMP, including the WSMP Action Plan
which includes potential use of American River water. Within ten days following execution of
this Settlement Agreement, the County, Shapell and Windemere will dismiss with prejudice the
WSMP Lawsuits which would eliminate the challenge to implementation of the District's water
supply and storage alternatives contemplated therein. County, Shapell and Windemere further
agree not to file any lawsuit challenging the approval by EBMUD of actions implementing the
WSMP to the extent such actions are in substantial conformance with the WSMP as heretofore
approved by EBMUD, and so long as such actions are consistent with, and do not impair the
District's ability to carry out, this Agreement.
3
4. DESIGNATION OF DSRSD AS PREFERRED WATER PROVIDER
(a) Shapell and Windemere are using and will continue to use their best
efforts to secure permanent water service for that portion of the Dougherty Valley located
outside CCGR and the elementary school site (and, conditionally, the middle school site, as
described in paragraph 2), from the Berrenda Mesa Water District, and the Dublin San Ramon
Service District and/or Alameda County Zone 7. These efforts include negotiation of
contracts for the transfer, transmission and delivery of water, environmental review and
approval of the transfer and delivery of the water by applicable regulatory agencies, and
LAFCO.approval of annexation by DSRSD of the above-described portion of the Property.
The specific actions and approvals anticipated, and a timetable for their expected dates of
completion, are described in Exhibit C.
(b) Shapell and Windemere will provide EBMUD with all non-confidential
documents prepared in connection with the process described in Exhibit C for review and
monitoring. Shapell and Windemere agree that they will consult with EBMUD regarding any
concerns EBMUD may raise relating to that process. The purpose of this provision is to
assure that EBMUD's ability to develop adequate water supplies for existing customers and
future developments within the existing service area, and EBMUD's existing water rights or
its efforts to secure additional water supplies, are not adversely affected by the proposed water
transfer and delivery. EBMUD reserves the right to comment throughout the process, but will
not oppose implementation of the program nor file any legal challenge to any aspect of the
DSRSD/Berrenda Mesa water transfer and delivery program, including the adequacy of
environmental review and annexation of the Property into DSRSD, to the extent it is carried
out in substantial conformance with the program for the proposed water transfer as described
in the documents transmitted from Windemere to EBMUD on July 31, 1995. The foregoing
waiver shall not bar a legal challenge by EBMUD in the event that the environmental impact
report for the proposed water transfer discloses information not previously provided to
EBMUD involving potential adverse effects upon EBMUD's existing water rights or its
efforts to secure additional water supplies.
(c) In the event the proposed DSRSD/Berrenda Mesa water supply cannot
be secured, Shapell and Windemere will use best efforts to secure water from alternative
sources or suppliers. In so doing, Shapell and Windemere will consult with EBMUD
regarding alternative methods of securing and delivering water which do not involve primary
water service from EBMUD. The County, Shapell and Windemere shall not initiate
annexation proceedings to any other provider before completing this consultation. EBMUD
will not file any legal challenge to any aspect of any alternate program for provision of water
to the Property, including the adequacy of the environmental review and annexation into any
other district, unless and to the extent that EBMUD's ability to develop adequate water
supplies for existing customers and future developments within the existing service area, and
EBMUD's existing water rights or its efforts to secure additional water supplies would be
adversely affected by the alternative water transfer and delivery program.
4
(d) Accomplishment of "best efforts" as referred to in paragraphs 4(a) and
(c) above shall require that Shapell and Windemere undertake in good faith a diligent and
timely effort to initiate and complete each action, and each regulatory approval process that is
necessary to secure permanent water service for Dougherty Valley from DSRSD/Berrenda
Mesa, including the anticipated actions and approvals identified in Exhibit C, Section B
hereto. In addition, in the event that the foregoing method of providing water service cannot
be secured, accomplishment of "best efforts" shall include the diligent pursuit of the additional
steps set forth in Exhibit C, Section C. "Best efforts" shall also include a significant financial
investment as set forth in Exhibit C.
(e) Upon execution of this Agreement, the County will initiate.amendments
to the Dougherty Valley Specific Plan to designate DSRSD rather than EBMUD as the
preferred water provider outside of CCGR and, consistent with paragraph 2, the school sites.
Any reference to EBMUD as a potential water provider in the Specific Plan shall be consistent
with and include the conditions and limitations set forth in this Settlement Agreement. Prior to
action being taken by the County on the Specific Plan, EBMUD shall be given the opportunity
to review and comment upon the text of the proposed amendment in the manner specified in
paragraph 6(b) of this.Agreement. Action on the Specific Plan Amendment shall occur prior
to or contemporaneous with any action taken by the Board of Supervisors on the Development
Agreements and rezoning for the Property.
(f) Approval of tentative subdivision maps for the Project shall be
conditioned on verification of an adequate water supply for the subdivision, the condition to be
satisfied prior to recordation of the final map, by verification that capacity exists to serve the
specific project ("will serve letters") or comparable evidence of adequate water supply.
Where EBMUD is proposed to provide water service to the Property or a portion thereof
pursuant to the terms, conditions, and limitations set forth in this Agreement, EBMUD shall
not be obligated to provide such verification unless and until the applicable portion has been
annexed to EBMUD in conformance with the terms, conditions and limitations set forth in this
Agreement.
(g) Under the circumstances and subject to the terms; conditions and
limitations set forth herein, including without limitation the requirements of paragraph 4(h):
(i) No earlier than July 1, 1999, Shapell and Windemere may submit to
EBMUD a request to initiate preliminary planning work for water service from EBMUD.
Upon receipt of such request, EBMUD will undertake the activities for preparation of a
preliminary work agreement ("PWA") referenced as "PWA Development" on Exhibit D to this
Agreement, not including retention of the consultant and execution of the PWA. EBMUD,
Windemere and Shapell shall utilize best efforts to complete these activities by December 31,
1999. All work performed by EBMUD pursuant to this request shall be undertaken at
Shapell's and Windemere's sole expense, and undertaking such work shall provide no
assurance for the provision of water service unless and until the Property is annexed to
EBMUD as provided herein.
5
(ii) At Shapell's and/or Windemere's request made no earlier than
January 1, 2000, EBMUD will enter into a PWA with Shapell and/or Windemere, retain
consultants as necessary and perform the work included in the PWA, including project
development, environmental documentation, and project design as shown on the estimated
timetable in Exhibit D. Any such planning, project development and design work shall be
undertaken at Shapell's and Windemere's sole expense, and undertaking such work shall
provide no assurance for the provision of water service unless and until the property is
annexed to EBMUD as provided herein.
(iii) EBMUD, Windemere and Shapell shall cooperate through the
exercise of best efforts to conduct and complete the activities in (ii) above in a timely manner
which (following annexation, facilities construction and other required activities) will allow
commencement of hook-ups to the Property by January 1, 2002. The parties to the PWA shall
utilize all reasonably available techniques to reduce the estimated shortest time shown on
Exhibit D for performing the planning activities in (ii) above, including the use of outside
consultants at Windemere's and/or Shapell's expense, and phasing of planning and
construction; provided, however, nothing herein constitutes a commitment or guarantee by
EBMUD that, despite the use of best efforts, activities in (ii), above, and construction
activities can be completed in time to commence hook-ups by January 1, 2002.
(iv) Shapell and Windemere shall not submit an application to LAFCO
for annexation to EBMUD of the Property.outside of CCGR and the elementary school site
(and possibly the middle school site, as provided in paragraph 2), or any part thereof, prior to
July 1, 2000. EBMUD will cooperate beginning January 1, 2000 in providing in a timely
fashion information reasonably necessary for the preparation, submittal and processing of
such application. EBMUD agrees that it will not oppose any application for annexation of the
Property into the District filed on or after July 1, 2000, and (upon the successful completion of
annexation) will provide water service to the Property, but only upon the terms, conditions and
limitations set forth in paragraph (h) below. Any work done by EBMUD and any expense
incurred by Shapell and Windemere prior to commencement of annexation proceedings does
not relieve Shapell and Windemere from continuing their best efforts, as required in paragraph
4(h)(i), to secure an alternative water supply.
(v) EBMUD will not approve, or issue a request for bids for
construction of, EBMUD facilities to serve the Property prior to completion of annexation
proceedings and EBMUD will not provide hook-ups to the Property prior to January 1, 2002.
Upon successful completion of the annexation process, EBMUD will take all necessary steps
to complete the planning, review and implementation process needed for the provision of water
to the Property in a timely fashion. The anticipated specific actions and approvals required,
and an estimated timetable for completion of each based upon information currently known to
EBMUD, is attached hereto as Exhibit D. The parties to the PWA shall utilize all reasonably
available techniques to reduce the shortest estimated time shown on Exhibit D for performing
the planning, review and implementation process; provided, however, nothing herein
constitutes a commitment or guarantee by EBMUD that, despite the use of best efforts, the
6
planning, review and implementation process can be completed in time to commence hook-ups
by January 1, 2002.
(h) Shapell and Windemere agree that any annexation application, annexation,
and water service for the Property shall be subject to the terms, conditions and limitations set
forth below:
(i) Shapell and Windemere shall have worked through exercise of best
efforts as defined in Exhibit C to secure an alternative water supply for all or any portion of
the Property through Berrenda Mesa, DSRSD, Zone 7 or other providers, but without success.
Shapell and Windemere will not seek annexation for any portion of the Property for which a
permanent alternative water supply has been secured.
(ii) Until such time as a sufficient water supply is available to meet
demand in the EBMUD service area and the Property, as determined in the manner set forth in
Exhibit E, water service for any portion of the Property outside CCGR and the school sites
shown on Exhibit B shall be subject to an offset fee to fund the cost of conservation programs
or other methods necessary to offset additional water demand created by new hookups in the
development. The calculation for the offset fee, and provisions governing payment of the
offset fee are set forth in Exhibit F
(iii) The number of new water service hook ups per year would not
exceed 600. Any hook ups not used in any given year may be carried forward to future years,
but in no event shall the number of hookups in any given year exceed 750.
(iv) During any period in which the District has declared a drought
emergency pursuant to Water Code § 350, EBMUD would issue no new water service hook-
ups to the Property, and County, Windemere and Shapell would not submit an application to
LAFCO for annexation to EBMUD.and would request that LAFCO withhold decision on any
pending application for annexation to EBMUD.
(i) It is expressly understood and agreed that notwithstanding any other
provision of EBMUD policy or regulation, any amounts paid by Windemere and/or Shapell to
EBMUD for planning or design for water service to the Property pursuant to this .paragraph 4
shall be credited to and result in an equivalent reduction of the System Capacity Charge
applied to the development and shall not be refunded directly to Windemere and/or Shapell.
(j) If EBMUD determines, in its sole discretion, that it has adequate water
to serve new customers outside the District's boundaries, Shapell and/or Windemere may
apply to EBMUD for water service without the restrictions and limitations set forth in this
Agreement, and EBMUD will give impartial consideration to such application. However,
EBMUD does not contemplate allowing such applications at this time.
7
5. PROJECTS MUST BE DESIGNED TO ACCOMMODATE RECLAIMED
WATER
EBMUD and the County will require that the projects in the Dougherty Valley
be designed and built to accept and utilize reclaimed water for irrigation purposes in public
and semi-public areas. County, Shapell and Windemere will consult with EBMUD in order
that reclaimed water programs contemplated for the Dougherty Valley may be coordinated and
compatible with EBMUD's reclamation programs.
6. DEVELOPMENT AGREEMENTS TO BE CONSISTENT WITH THIS
AGREEMENT
(a) County, Shapell and Windemere agree that any development agreements
that may be adopted for the Property shall be consistent with and shall not abrogate or limit
compliance with or implementation of, the provisions of this Settlement Agreement.
Specifically, any development agreement adopted for the Property shall include the substance
of the following provisions:
(i) The Dougherty Valley project, including any subsequent
modifications, shall be subject to all terms and provisions of this Settlement Agreement; and
(ii) Nothing provided in any development agreement adopted for the
Property is intended to or does abrogate or limit the enforceability or effectiveness of this
Settlement Agreement. If there is conflict between any such development agreement, if such is
approved, and this Settlement Agreement, the terms of this Settlement Agreement shall
prevail.
(b) County, Shapell and Windemere agree that any preliminary data relating
to proposed development agreements which is submitted to the Dougherty Valley Oversight
Committee shall also be submitted to EBMUD at the same time. In addition, at least 15 days
prior to the presentation of such agreements to the County Board of Supervisors, the County,
Windemere and Shapell shall provide the text of the agreements to EBMUD for its review
with respect to the substance of the provision required by this paragraph. The County,
Windemere and Shapell shall make every reasonable effort to incorporate into such agreements
EBMUD's comments on the language of any provisions relating to the obligations set forth in
this paragraph.
(c) The County, Windemere, and Shapell agree not to seek or approve
revisions to any development agreement for the Property following its initial adoption in any
manner which limits, conditions, restricts, or abrogates any provision of this Settlement
Agreement. The County, Windemere and Shapell will submit any such proposed revisions to
EBMUD for comment in the manner specified in subparagraph (b) above.
8
7. RESOLUTION OF LAWSUIT RELATING TO THE 1992 APPROVALS
(a) The parties desire to resolve all disputes relating to the 1992 Approvals,
and to that end, all parties agree to take action jointly to accomplish by appropriate procedures
and with the appropriate court(s) the vacation, elimination or modification of the Judgment and
Writ of Mandate and/or dismissal of the Dougherty Valley Lawsuit, in order that the 1992
Approvals remain in effect. In the event that the settlement agreements in the case of Town of
Danville et al. v. County of Contra Costa et al. (C93-00231) are effectuated prior to the
effective date of this Settlement Agreement, the parties agree to join in the collective efforts of
all the parties to the two lawsuits to accomplish by appropriate procedures and with the
appropriate court(s) the vacation, elimination or modification of the Judgment and Writ of
Mandate and/or dismissal of the Dougherty Valley Lawsuit in order that the 1992 Approvals
and supporting EIR remain in effect. EBMUD further agrees not to file any action against the
approval of any Development Agreements, rezonings or Preliminary Development Plans for
the Property to the extent such approvals are in substantial conformance with the 1992
Approvals as modified to reflect the Country Club at Gale Ranch approvals, this Settlement
Agreement, and any other settlement agreements entered into to settle the lawsuit entitled
Town of Danville et al. v. County of Contra Costa et al... EBMUD retains the right to
oppose and file a legal challenge against such approvals, and any other subsequent approvals
for the Project, with respect to the subject of water availability or quality to the extent such
approval or approvals are not based upon or in substantial conformance with the 1992
Approvals as modified to reflect the Country Club at Gale Ranch approvals, this Settlement
Agreement, and any other settlement agreements entered into to settle the lawsuit entitled
Town of Danville et al. v. County of Contra Costa et al...
(b) Except as otherwise provided in paragraph 4(b) EBMUD retains its right
to comment upon and oppose future Dougherty Valley project-level applications (such as
tentative maps) and any future environmental impact reports that may be required, with respect
to the subject of water availability or quality. EBMUD also retains the right to oppose and
legally challenge any approvals which seek to designate EBMUD as the preferred water
provider or to annex any of the Property to EBMUD to the extent they are inconsistent with .
the provisions of this Settlement Agreement.
8. DISPUTE RESOLUTION PROCESS
(a) If a dispute arises relating to the interpretation of, enforcement of or
compliance with the terms and provisions of this Agreement, the parties to the dispute will
first attempt to resolve it through informal discussions, which may include designated-
representatives
esignatedrepresentatives of Shapell and Windemere, the County and EBMUD. Any party may convene
such discussions through written notice delivered by confirmed facsimile transmission or
overnight delivery to the other parties, providing at least ten days' notice, and setting a date,
time and place for such discussions. The convening party shall reasonably accommodate the
parties' schedules in selecting and/or altering the date and time of the discussions. In the
event a dispute cannot be resolved in this manner within twenty-one (21) days, upon
agreement among the parties, the dispute may be referred to a mediation process.
9
(b) The dispute resolution process described above shall be undertaken in
good faith and exhausted prior to judicial review; provided, however, that no party to this
Agreement hereby loses or waives its right to file an action to comply with any applicable
statute of limitations or loses or waives its right to assert the operation of any applicable
statute of limitations as an affirmative defense. In the event that an applicable statute of
limitations would expire during the pendency of the dispute resolution process described
above, the parties may agree in writing to toll such statute of limitations for such period as
may reasonably be necessary to complete the dispute resolution process.
9. RULES AND REGULATIONS GOVERNING WATER SERVICE TO
CUSTOMERS OF EBMUD; FRUSTRATION OF PURPOSE
Any water service provided to the Property by EBMUD pursuant to the terms,
conditions and limitations of this Agreement shall be subject to compliance by Windemere and
Shapell with the lawful and non-discriminatory application of the Rules and Regulations
Governing Water Service to Customers of EBMUD, and any amendments thereto that may be
adopted. In no event, however, shall any party to this Agreement take any action (whether by
the amendment of said Rules or otherwise) which has the purpose or effect of frustrating the
accomplishment of the purposes of this Agreement or the exercise of the rights conferred
under this Agreement; provided, however, that actions of the District to (a) modify its rates,
charges and fees, (b) adopt reasonable revisions to its engineering standards and practices, and
(c) provide for compliance with standards, requirements and regulations promulgated by
federal, state, and local authorities other than EBMUD shall not be deemed to frustrate the
accomplishment of the purposes of this Agreement.
10. GENERAL PROVISIONS
(a) * Each party expressly waives any rights or benefits available to it under
the provisions of Section 1542 of the California Civil Code, which provides as follows:
A general release does not extend to claims which the creditor
does not know or suspect to exist in his favor at the time of
executing the release, which if known by him must have
materially affected his settlement with the debtor.
(b) Each party represents that the contents of this Agreement have been
explained to it by its duly authorized counsel and that this Agreement is executed voluntarily,
with full knowledge of its significance and contents and with full authority.
(c) The terms and conditions of this Agreement shall be binding upon, and
inure to the benefit of, the parties to this Agreement and their respective successors and
assigns.
10
(d) This Agreement constitutes the entire Agreement among the parties with
respect to the subject matter hereof and supersedes any prior understandings or agreements
among the parties, whether oral or written. This Agreement may not be amended or modified
unless made in writing and signed by each of the parties. Where an amendment or
modification that would affect only one of the Property owners need not be approved by the
other Property owner.
(e) Neither the negotiation of this Agreement, nor any action taken to carry
out this Agreement, (i) is or may be construed or used as an admission or concession by or
against any party to this Agreement of any fault, wrongdoing or liability, or (ii) may be
offered or received in evidence in any action or proceeding against any Party to this
Agreement in or before any court, administrative agency or tribunal for any purpose;
provided, however, that this Agreement and its exhibits may be filed in the Lawsuit as
evidence thereof. The Parties to this Agreement further agree that the provisions of California
Evidence Code Sections 1152 and 1154 apply to all negotiations and settlement discussions
leading to, and all actions taken to carry out, this Agreement, and that such negotiations,
discussions and actions shall not be admissible for any purpose other than as necessary to
effectuate, enforce or defend the provisions of this Agreement.
(f) Shapell and Windemere will each pay to EBMUD attorneys fees in the
amount of$97,000, payable within five business days following disposition of the Dougherty
Valley Lawsuit pursuant to paragraph 7(a) of this Agreement. This obligation is several and
not joint. Except as provided herein, each party shall bear its own costs and fees incurred in
the Lawsuit and this Settlement Agreement.
(g) Shapell and Windemere agree and warrant that they will provide a copy
of this agreement to any purchasers, assignees or successors-in-interest of the Property who
will be affected and governed by the terms and conditions of this Agreement, prior to the
transfer of title. In the event of the failure to provide the foregoing notice, Windemere and
Shapell agree to defend, indemnify and hold EBMUD harmless from any and all loss or
expense incurred by EBMUD resulting therefrom, provided that the developer affected shall
have the right to assume the defense of any claim made or action brought against EBMUD on
the basis of which EBMUD makes a claim under this paragraph 10(g). In addition, the
County, Windemere and Shapell agree that the requirements of this Agreement shall be
incorporated into conditions of approval subsequently issued within the Property if EBMUD is
proposed to provide water service to the portion of the Property affected by the approval.
11
COUNTY OF CONTRA COSTA
Date: ' ?; 1995 By: ,A;yA % 4
hair of the B rd of Supervisors
Date: v V j ( 1995 EAST BAY MUNICIPAL UTILITY
DISTRICT
By: �y
sident of the Board of Directors
Date: 3 0 1995 SHAPELL INDUSTRIES OF
NORTHERN CALIFORNIA
By:
President
Date: 1995 WINDEMERE RANCH PARTNERS
By: WelmLow
Man4g Partner
12
EXHIBIT LIST
EXHIBIT A Process for notification and consultation concerning land use and water
service matters.
EXHIBIT B School Sites
EXHIBIT C DSRSD steps and timetable and "best efforts" steps.
EXHIBIT D Timeline for Planning/Design/Annexation/
Construction
EXHIBIT E Method for determination sufficiency of water supply system
EXHIBIT F Offset fee calculation and provisions governing payment
13
EXHIBIT A
PROCESS FOR NOTIFICATION AND CONSULTATION
CONCERNING LAND USE AND WATER SERVICE MATTERS
EBMUD and Contra Costa County are jointly committed to improving coordination of
Water Service planning with Land Use planning and decision making. To the end of
improving such coordination the Contra Costa Community Development Department
shall provide notification to EBMUD and shall consult with EBMUD concerning all
relevant applications for development which are filed with the County. Notification and
consultation shall occur in the manor below prescribed:
I. The County shall notify EBMUD of all applications for development within the
EBMUD current service boundary, sphere of influence boundary or where the county
anticipates EBMUD service might be requested or required either immediately or in the
future. Upon receipt by the County of application, a referral shall be sent within one
week to EBMUD with sufficient detail to enable determination of the water supply
implications to EBMUD. The County will supply additional information as reasonably
requested by EBMUD to evaluate the water supply implications.
II. For all applications outside the EBMUD service boundary where the County
anticipates EBMUD service might be required and for any application involving an
amendment to the County General Plan inside the service boundary which EBMUD
determines to have significant impact upon its ability to supply water service to existing
customers,the County and EBMUD will coordinate their review and approval processes
with the objective of resolving or removing those aspects which create significant impact
upon EBMUD's ability to supply water to existing customers. EBMUD shall have a
minimum of 30 working days to provide comment and request formal coordination
pursuant to this paragraph.
III. For all applications outside the EBMUD existing service boundary, the County
will insure that water supply planning and implications with respect to the EBMUD
existing and future customers within the existing EBMUD service area are integrated into
the land use planning and environmental documentation.
.s A
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EXHIBIT C
Efforts to Obtain Water Service from Source Other than EBMUD
Paragraph 4 of this Agreement provides as a condition to certain EBMUD
obligations that Shapell and Windemere will have exercised best efforts to secure an alternative
water supply (through DSRSD, Zone 7 or other providers). Windemere and Shapell have
undertaken or intend to undertake all reasonable and appropriate steps to obtain such water
including those set forth below. To the best of Windemere and Shapell's knowledge, the
activities, actions and approvals set forth below is a complete and accurate list of steps needed
to secure permanent water service from a supplier other than EBMUD. In the event that
additional activities, actions or approvals are subsequently identified which in the exercise of
diligence should be undertaken in securing alternative permanent water service, such additional
efforts will be diligently pursued as though they were included within this Exhibit C.
Windemere and Shapell will continue to exert all reasonable efforts in
furtherance of securing permanent water service from a supplier other than EBMUD until such
time as application is made for annexation to EBMUD pursuant to the terms, conditions and
limitations of paragraph 4 of this Agreement. Windemere and Shapell shall provide reports
three times per year to EBMUD describing the activities and accomplishments since the
previous report with regard to each of the activities; actions, and approvals set forth in this
Exhibit C. Each report also shall provide updated information concerning the schedule for
expected completion of each element in this Exhibit C and shall describe any newly identified
elements for addition to Exhibit C including the estimated dates for completion of the new
elements.
Windemere and Shapell shall be deemed to have used "best efforts" for the
purposes of this Agreement if and when:
• in addition to undertaking each of the actions specified in Sections A and B
below, they collectively have expended funds in the aggregate amount of
$500,000 or more in furtherance of such actions; and
• under the circumstances specified in Section C below, Windemere and Shapell
undertake the actions specified in Section C below and they collectively have
expended funds in the aggregate amount of$250,000 or more in furtherance of
such actions.
A. Initial Survey
For over two years, Windemere and Shapell have undertaken an extensive
search to identify viable sources of water as an alternative to EBMUD. Extensive discussions
with State Water Project contractors and other entities with claims to State Water Project
entitlements have occurred, including districts in San Joaquin, Calaveras, Amador, Stanislaus
and Kern counties. A variety of other potential sources were considered, including the
Mokelumne River and the American River. Through this process, entitlements held by
14
EXHIBIT C (page 2)
Berrenda Mesa Water District presented the most immediately practicable option for obtaining
a successful transfer that,would provide a permanent source of water for Dougherty Valley.
As a result, Windemere and Shapell have undertaken or intend to undertake the steps set forth
in Section B, below, to effectuate such a transfer.
B. Berrenda Mesa Water District
1. Water District Contracts
• Enter into a reimbursement agreement between DSRSD and Windemere for the
purchase of Berrenda Mesa water. (Complete)
• Obtain water purchase agreement between DSRSD and Berrenda Mesa
("Berrenda Mesa/DSRSD Contract"). (Complete)
• Confirm State Water Project Contractors' agreement to the Monterey
Principles, allowing for permanent transfers and making both agricultural and
municipal contractors subject to equitable reductions in water supply during
drought shortages. (Complete)
• Amend Berrenda Mesa/DSRSD Contract to add Shapell as party. (Complete)
• Obtain Kern County Water Agency approval of Berrenda Mesa/DSRSD
Contract. (Complete)
2. Zone 7
• Obtain DSRSD Board's formal request of Zone 7 to deliver, transport and store
water entitlements obtained from Berrenda Mesa ("DSRSD Request").
(Complete)
• Obtain Zone 7 Board approval of DSRSD Request after certification of the Final
EIR, as described in Section B.3, below. (Expected December 1995)
3. Complete environmental review for transfer, storage, treatment and conveyance
of water from Berrenda Mesa Water District to DSRSD. (Certification of Final
EIR expected December 1995)
4. LAFCO Actions
• File LAFCO application for annexation to DSRSD. (Expected December 1995)
15
EXHIBIT C (page 3)
• Obtain LAFCO approval of annexation of Dougherty Valley (other than CCGR
and school sites adjacent to CCGR) to DSRSD. (Expected January 1996)
5. Other Agencies
• Obtain Department of Water Resources approval of transfer of Berrenda Mesa
Water to DSRSD. (Expected February 1996)
C. Alternative Methods of Delivery and Sources of Water
Although Windemere and Shapell anticipate that all of the actions necessary for
the Berrenda Mesa transfer, conveyance, storage and delivery can be completed in a timely
manner, it is possible that unforeseen physical or fiscal constraints will prevent either the
contemplated method of delivery or the legal transfer of water rights from this particular
source. In such event, Shapell and Windemere will initiate other efforts to secure alternative
methods of delivery of water sources. As appropriate, these efforts will include the following:.
1. With respect to the method of delivery, it is possible that, although all other
steps necessary for the transfer may occur, use of Zone 7 facilities will prove infeasible. If
and when such an event occurs, but in no event later than July 1, 1996, Windemere and
Shapell will promptly commence and diligently pursue the following:
Initiate design work for construction of new DSRSD water treatment plant and
conveyance facilities.
• Study and initiate necessary contractual negotiations for storage alternatives,
such as Semitropic Water Storage District Groundwater Bank, New Melones
Reservoir or Los Vaqueros Reservoir.
0 Requesting DSRSD to initiate such actions as may be necessary for DSRSD to
become a contractor with the State Water Project.
2. If all actions necessary to accomplish the Berrenda Mesa transfer are not
completed by July 1, 1996, Windemere and Shapell at that time will promptly and diligently
pursue the following:
• Conduct a statewide search for water from other sources, including other State
Water Project contractors and entities previously contacted, and other holders of
contractual water supply entitlements and state-issued water rights.
• Initiate discussions with parties identified as potential sources through statewide
search.
16
EXHIBIT C (page 4)
• Make preliminary determinations regarding legal, financial and technical
feasibility of possible sources.
• Actively pursue negotiations with feasible candidate sources.
• If such negotiations are successfully progressing with respect to a potential
feasible source or sources, conduct preliminary engineering analysis and
environmental review and identify necessary governmental approvals.
• If the above steps are successful, complete engineering analysis, environmental
review and obtain necessary governmental approvals.
• Upon obtaining necessary governmental approvals, commence design and
construction work necessary to effectuate transfer and conveyance.
17
EXHIBIT E
METHOD AND STANDARD FOR DETERMINING THE SUFFICIENCY OF THE
EBMUD WATER SUPPLY SYSTEM FOR EXISTING AND FUTURE NEEDS BOTH
FOR THE DISTRICT'S SERVICE AREA AND THE PROPERTY
To determine the sufficiency of the District's water supply system to meet
current and future demand in the EBMUD service area and the Property, the District will
perform a computer analysis using its EBMUDSIM computer model. The water supply
system will be deemed sufficient if the analysis shows that the water supply system can meet
existing and future demand in the District's service area and the Property through the design
drought cycle without requiring rationing in excess of 25% as set forth in the District's
September 1993 Final Environmental Impact Report on its Updated Water Supply Management
Program ("WSMP").
Except as modified herein, all model assumptions contained in such analysis
shall be identical to those used to determine the 130 TAF Need for Water reported in the
WSMP. Assumptions regarding instream flow and reservoir operating criteria related to
fishery or other in-stream resource protection requirements will be modified to reflect the
District's offer of settlement to the Federal Energy Regulatory Commission ("FERC") and
will be subject to further modification based upon results of the State Water Resources Control
Board, FERC, or other regulatory proceedings with jurisdiction affecting EBMUD water
supplies which address these requirements. Assumptions regarding system capacity
components which reduce the need for water such as addition of a connection to the Folsom
South Canal, addition of storage to Pardee Reservoir, institution of a conjunctive use program,
water reclamation projects, water conservation programs or similar capacity components, will
be subject to modification. The capacity of Camanche Reservoir will be reduced from 430
A.F. to 413 A.F. to reflect recent survey data. Upon execution of this Agreement, a complete
set of computer printouts delineating the District's need for 130 TAF of additional capacity
will be delivered to the designated representative of Windemere and Shapell. Whenever the,
District makes a determination of system delivery capacity pursuant to this section, a complete
set of computer output will be delivered to the parties to this Agreement.
18
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EXHIBIT F
CALCULATION OF OFFSET FEE AND
PROVISIONS GOVERNING PAYMENT OF OFFSET FEE
The offset fee shall be 1.65 times the Future Water Supply ["FWS'] portion of
the System Capacity Charge ["SCC"] in effect at the time that the offset fee is paid and the
base amount of the FWS shall be credited against the SCC paid at the time of hook-up. The
Property shall constitute a separate SCC region. Water demand figures for residential and
commercial structures to be utilized in computing the offset fee will be calculated according to
the method utilized by EBMUD for its System Capacity Charge unit demand calculations, and
will take into account the following factors, among others: Actual use by households in the
area expected to exhibit similar potable water demand characteristics; Specific Plan restrictions
and other conditions of approval which have an impact on water usage, such as requirements
for xeriscaping, the use and availability of reclaimed water for public and semi-public areas,
and other relevant design features; and the varying lot sizes of each type of single family
residence. The water demand figures shall be determined prior to payment of the first offset
fee. Unit water demand will be recalculated based upon actual water use within the Property
measured beginning the second year following occupancy.
The offset fee shall be paid no less than one year prior to the issuance of the
water meter for the residential or commercial structure or other use. Within 30 days of the
date on which it is determined that EBMUD has developed a sufficient water supply (as
defined in Exhibit E), that portion of the offset fees which reflects .65 times the FWS portion
of the SCC shall be refunded for any units for which an offset fee has been paid but for which
no water meters have been issued. If construction on the Property is halted, at the request of
the payor(s), the offset fees for some or all of the units which have not been issued a water
meter shall be refunded,except that EBMUD shall retain .65 times the FWS for each such unit
and shall have no further obligation to Windemere and Shapell as to any such funds retained
by EBMUD. A halt in construction shall be defined as a six-month period during which no
water meters have been issued.
As an alternative to payment of the offset fee, until sufficient water is available
as determined in the manner set forth in Exhibit E, Windemere and Shapell may secure an
alternate source of water, of a quality and quantity satisfactory to EBMUD and not involving
water under consideration as a possible alternative source for EBMUD under its WSMP,
which EBMUD could purvey on an interim or permanent basis. EBMUD will reasonably
cooperate in the foregoing, subject to payment by Windemere and Shapell of all costs incurred
by EBMUD. .
\ebmud\set\016\ch
19
f
U' S� EAST BAY
MUNICIPAL UTILITY DISTRICT LYNELLE M.LEWIS
THE
SECRETARY Of THE DISTRICT
r
RECEIVE?
KE 2 X96 cum .
NOTICE �►�S Aco.MORS
i
This notice is to advise that at its regular business meeting on Tuesday, August 8,
19751, t1he Easi Bay Municipal Utility District Board of Directors will have on its
open meeting agenda consideration of a proposed agreement for settlement of-
East
£East Bay Municipal Utility District v. Contra Costa County et al. -
Contra Costa County Superior Court, No. C93-00235 (Dougherty
Valley Litigation).
A summary of the agreement terms to be considered is attached. Copies of the
agreement are available from the Office of the Secretary, 375 11th Street, Oakland,
CA 94607 (phone 510/287-0440).
Dated: August 1, 1995
Ly4ielle M. Lewis
Secretary of the District
375 ELEVENTH STREET. OAKLAND. CA 94607.4240. 15101 835.3000
BOARD OF DIRECTORS JOHN A.COLEMAN . KATY FOULKES .JOHN M.GIOIA
FRANK MELLON. NANCY J.NADEL. MARY SELKIRK. KENNETH H.SIMMONS
SUMMARY OF
AGREEMENT TO SETTLE LITIGATION RELATING TO
THE DOUGHERTY VALLEY GENERAL PLAN AMENDMENT,SPECIFIC PLAN
AND ENVIRONMENTAL IMPACT REPORT
AND RELATING TO THE WATER SUPPLY MANAGEMENT PROGRAM
AND ENVIRONMENTAL IMPACT REPORT
OF THE EAST BAY MUNICIPAL UTILITY DISTRICT
The Board of Directors of East Bay Municipal Utility District will be considering approval of a
proposed settlement agreement which sets forth the terms and conditions under which the district
would dismiss its lawsuit entitled EBMUD v.County Contra Costa et Al.,No. C93-00235,in Contra
Costa County Superior!'ourt,challenging the county's approval of a General Plan Amendment and
a Specific Plan for Dougherty Valley, and the environmental impact report on which such approval
was based. The settlement agreement also provides for dismissal of the lawsuit filed by Contra
Costa County,Windemere Ranch Partners,and Shapell Industries of Northern California challenging
the environmental impact report prepared by EBMUD for its Water Supply Management Program
adopted in October 1993. Provisions of the agreement are summarized as follows:
Section 1. EARL YCONSUL TATION BETWEEN EBMUD AAD THE COUNTY
Under the agreement, EBMUD and the county would establish a regular meeting schedule for the
purpose of coordinating activities related to water supply planning and land use planning. A
notification and consultation process would be established to provide for early discussion and
exchange of information related to water demand of proposed new development,the availability of
water supply and system capacity to meet the demand,the impact on service to existing customers,
and availability of water supply sources to meet the needs of existing and future customers in the
county.
Section 2. CONFIRMATION OF SERVICE TO COUNTRY CLUB AT GALE RANCH
The agreement would confirm the provision of water service to the Country Club at Gale Ranch,
which is located within the district's current service boundaries, and further confirms that water
supply facilities will be sized to serve the Country Club at Gale Ranch only. EBMUD would agree
not to oppose annexation of school sites located near the Country Club at Gale Ranch development
and adjacent to the existing EBMUD boundary,provided that such school sites would be used only
for school and/or park purposes.
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Section 3. DISMISSAL OF CHALLENGE TO WSMP
The agreement would provide for dismissal of the action filed by the county, Shapell and
Windemere,challenging the adequacy of the environmental impact report for adoption of EBMUD's
Water Supply Management Program.
Section 4. DESIGNATION OF DSRSD AS PREFERRED WATER PROVIDER
The agreement would require Shapell and Windemere to continue to use best efforts to secure
permanent water service for the Dougherty Valley from the Dublin San Ramon Services District,
as an alternative to seeking water service from EBMUD. These efforts include contracts for the
transfer and delivery of water from Berrenda Mesa Water District to DSRSD, environmental
documentation, approval by applicable regulatory agencies, and LAFCO approval of annexation of
the Dougherty Valley property to DSRSD. In the event the proposed DSRSD/Berrenda Mesa water
supply cannot be delivered using Zone 7 facilities, Shapell and Windemere will initiate efforts to
secure alternative methods of transfer and delivery,including design work for new DSRSD treatment
and conveyance facilities. If actions necessary to accomplish the Berrenda Mesa transaction are not
completed by July 1, 1996,Windemere and Shapell will pursue efforts to obtain a water supply from
other sources,including other State Water Project contractors. Best efforts also include a significant
financial investment of$750,000 in efforts to secure an alternative supply for Dougherty Valley.
Section 4 of the agreement specifies terms, conditions and limitations which would apply in the
event that Shapell and Windermere are unsuccessful in securing an alternative water supply for
Dougherty Valley(having worked to do so in accordance with the provisions of the agreement),and
seek annexation for any portion of the Dougherty Valley to EBMUD. The terms, conditions and
limitations which would apply to such application for annexation to EBMUD are summarized as
follows:
(a) Shapell and Windemere would not submit an application to LAFCO for annexation to
EBMUD of Dougherty Valley property prior to July 1, 2000. EBMUD would not oppose such
application for annexation subject to the following conditions:
1) Shapell and Windemere have completed best efforts, as defined in the
agreement,to secure an alternative water supply,but have been unsuccessful;
2) water service for any portion of Dougherty Valley would be subject to an
offset fee to fund the cost of conservation programs or other methods
necessary to offset additional water demand created by new hook-ups in the
development. The offset fee would be calculated at 1.65 times the Future
Water Supply portion of the EBMUD System Capacity Charge in effect at
the time of payment. The offset fee would be paid no less than one year prior
to the issuance of the water meter in order that programs to offset the new
demand can be implemented in advance;
-2-
r
3) the number of new water service hook-ups per year would not exceed 600;
4) during any period in which the district has declared a drought emergency
pursuant to Water Code section 350, EBMUD would issue no new water
service hook-ups to the property,and there would be no application made to
LAFCO for annexation to EBMUD;and
5) EBMUD would not provide water service hook-ups within the annexed
Dougherty Valley property any time prior to January 1,2002.
(b) In order to allow for planning of facilities necessary to commence delivery of water service
after January 1, 2002, planning work could be undertaken at Shapell and Windemere's expense,
commencing January 1,2000,but such work would provide no assurance for the provision of water
service unless and until the property is annexed to EBMUD subject to the terms, limitations and
conditions of the agreement.
Section S. PROJECTS MUST BE DESIGNED TO ACCOMMODATE RECLAIMED
WATER
The agreement would provide that EBMUD and the county will require that projects in Dougherty
Valley be designed and built to accept and utilize reclaimed water for irrigation purposes in public
and semi-public areas.
Section 6. DEVELOPMENT AGREEMENTS TO BE CONSISTENT WITH THE
SETTLEMENT AGREEMENT
The agreement would provide that any development agreements that may be adopted for Dougherty
Valley shall be consistent with the terms,conditions and limitations of the settlement agreement,and
any development agreement adopted for the property shall reference the tenors and provisions of the
settlement agreement.
Section 7. RESOLUTION OF LA WSUIT RELATING TO THE 1992 APPROVALS
Based upon the terms of the settlement agreement,the parties would jointly seek modification of the
judgment and writ of mandate and/or dismissal of the Dougherty Valley lawsuit,thereby leaving the
1992 General Plan Amendment and Specific Plan for Dougherty Valley in effect.
Section 8. DISPUTE RESOLUTIONPROCESS
This section would provide for an informal dispute resolution process,prior to initiation of litigation,
to resolve any dispute that may arise relating to the interpretation of,enforcement of, or compliance
with the terms of the settlement agreement.
-3-
Section 9. RULES AND REGULATIONS GOVERNING WATER SERVICE TO
CUSTOMERS OF EBMUD;FRUSTRATION OF PURPOSES
This section would specify that water service provided to Dougherty Valley by EBMUD,pursuant
to the terms,conditions and limitations of the settlement agreement,would be subject to compliance
by Windemere and Shapell with the rules and regulations governing water service to customers of
EBMUD. This section would further provide that no party shall take any action which has the
purpose or effect of frustrating the purposes of the agreement or the exercise of rights conferred
under the agreement.
Section 10. GENERAL PROVISIONS
Under section 10 of the agreement, Shapell and Windemere would pay EBMUD attorneys' fees in
the amount of$194,000.
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