HomeMy WebLinkAboutMINUTES - 09172013 - SD.1RECOMMENDATION(S):
1. APPROVE and AUTHORIZE the County Administrator, or designee, to sign a conditional settlement agreement
among the County, Chevron USA and Chevron Corporation, the County Assessor, and the City of Richmond,
settling Chevron’s pending property tax claims, appeals, and litigation for 2004-2013, following approval as to the
form of the final agreement by County Counsel.
2. AUTHORIZE the County Counsel, or designee, to file stipulations for dismissal of pending litigation in the Contra
Costa County Superior Court following execution of the settlement agreement by all parties and full compliance with
its terms, including resolution by the Assessment Appeals Board of Chevron’s assessment appeals for tax years
2010-2012 as provided in the settlement agreement.
FISCAL IMPACT:
Avoidance of future litigation costs.
APPROVE OTHER
RECOMMENDATION OF CNTY ADMINISTRATOR RECOMMENDATION OF BOARD COMMITTEE
Action of Board On: 09/17/2013 APPROVED AS RECOMMENDED OTHER
Clerks Notes:
VOTE OF SUPERVISORS
AYE:John Gioia, District I Supervisor
Candace Andersen, District II Supervisor
Mary N. Piepho, District III Supervisor
Karen Mitchoff, District IV Supervisor
Federal D. Glover, District V Supervisor
Contact: Rebecca Hooley, Deputy County
Counsel (925) 335-1854
I hereby certify that this is a true and correct copy of an action taken and entered on the
minutes of the Board of Supervisors on the date shown.
ATTESTED: September 17, 2013
David Twa, County Administrator and Clerk of the Board of Supervisors
By: Chris Heck, Deputy
cc: David Twa, County Administrator, Gus Kramer, County Assessor, Robert Campbell, Auditor-Controller
SD.1
To:Board of Supervisors
From:Sharon L. Anderson, County Counsel
Date:September 17, 2013
Contra
Costa
County
Subject:APPROVE CONDITIONAL SETTLEMENT OF PROPERTY TAX DISPUTES CONCERNING CHEVRON’S
RICHMOND REFINERY
BACKGROUND:
HISTORICAL BACKGROUND
Property taxes are based on the assessed value of property owned by a taxpayer. When a taxpayer disagrees with the
value that the Assessor’s Office has placed on a property, the taxpayer may appeal the property valuation to the
county assessment appeals board. Since at least 2004, Chevron has annually filed property tax appeals with the
Contra Costa County Assessment Appeals Board (“AAB”) challenging the assessed value of its Richmond Refinery.
In 2009, the AAB reached a decision concerning Chevron’s assessment appeal applications for 2004, 2005 and 2006,
awarding it a $17.8 million refund of property taxes it paid for those years. The money to pay Chevron’s refund
came from property taxes that otherwise would have gone to the County, its cities, schools, special districts and other
taxing agencies. Chevron subsequently challenged the AAB’s 2009 decision in Chevron USA Inc., et al. v. Contra
Costa County, Contra Costa Superior Court, Case No. MSC10-01390, and a trial on the matter is scheduled for
December 2013.
In 2012, the AAB issued a decision concerning Chevrons’ assessment appeal applications for 2007-2009, requiring
Chevron to pay approximately $25 million more in property taxes for the Richmond Refinery than it would have
been required to pay based on the valuation by the Assessor’s Office for those years. All of the taxing agencies that
lost revenue due to the earlier refund received a proportional share of the extra money from Chevron’s additional tax
payment. Chevron again appealed the AAB’s decision to the Contra Costa County Superior Court in Chevron USA
Inc., et al. v. Contra Costa County, Contra Costa Superior Court, Case No. MSC12-02368, as well as a subsequent
AAB decision related to taxable value of the Refinery for 2007 through 2009, Chevron USA Inc., et al. v. Contra
Costa County, Contra Costa Superior Court, Case No. MSC13-00743. Those cases are currently pending, although
no trial date has been scheduled in either matter.
Chevron also filed assessment appeals with the AAB challenging the Assessor’s 2010, 2011, and 2012 valuations of
the Richmond Refinery. Those appeals are currently pending before the AAB.
SETTLEMENT TERMS
For the last 18 months, while the County and Assessor were defending Chevron’s assessment appeals and the related
litigation, the Assessor’s Office has been working with Chevron representatives to settle the disputes. The parties
now believe they have reached a proposed global resolution of Chevron’s claims for years 2004 through January 1,
2013. Because Chevron USA and Chevron Corp., the County, the City of Richmond and the Assessor are named in
the Superior Court litigation, they are also parties to the proposed settlement agreement.
Under the terms of the settlement agreement, Chevron and the Assessor’s Office will ask the AAB to approve the
enrolled values of the Richmond Refinery for 2010 and 2011. Chevron and the Assessor will present evidence to the
AAB that there should be a reduction in the taxable value of the Richmond Refinery for 2012 from $3.87 billion to
$3.28 billion. If the AAB approves this reduction, the effect will be that Chevron will have overpaid property taxes
for 2012. Ordinarily, this means that Chevron would be entitled to a refund of approximately $8 million. But one of
the conditions of the settlement is that Chevron gives up its right to receive a refund of those property taxes, meaning
that the County’s taxing agencies will not lose any additional property tax money to pay for a refund to Chevron.
If the AAB approves settlement of the pending assessment appeals, the parties will dismiss with prejudice the cases
that are currently pending in the Contra Costa County Superior Court: Chevron USA Inc., et al. v. Contra Costa
County, Contra Costa Superior Court, Case No. MSC10-01390; Chevron USA Inc., et al. v. Contra Costa County,
Contra Costa Superior Court, Case No. MSC12-02368; and Chevron USA Inc., et al. v. Contra Costa County, Contra
Costa Superior Court, Case No. MSC13-00743.
The settlement does not prevent Chevron from filing future claims, litigation or appeals concerning the value of the
Richmond Refinery nor, with limited exceptions does it limit the issues that can be raised in future disputes. The
settlement does prevent challenges to the historical base year values (Proposition 13 value) of the Richmond
Refinery; the values enrolled for the Richmond Refinery for any year up to and including January 1, 2013 or any
previous AAB decisions regarding the value of that refinery, unless (1) the AAB changes the enrolled value of the
Refinery for any period on or before January 1, 2013; or (2) the Assessor issues assessments for property at the
Richmond Refinery for any period on or before January 1, 2013. It also contains mutual releases.
The purpose of the settlement is to give the Assessor and Chevron the opportunity to avoid the time and expense
involved in litigating these property tax appeals. Going forward, Chevron and the Assessor’s Office will annually
meet and confer regarding the value of the Richmond Refinery, as was the custom prior to 2004. If Chevron
disagrees with property tax assessments in the future, the Assessor’s Office and Chevron will mediate the claims
before asking the AAB to hold a hearing to adjudicate the property tax dispute.
CONSEQUENCE OF NEGATIVE ACTION:
Failure to take the recommended action will expose the County to continuing litigation concerning Chevron’s claim
for property tax refunds for years 2004 through January 1, 2013, as well as the costs associated with defending such
challenges, such as attorney’s and expert’s fees and costs.
CHILDREN'S IMPACT STATEMENT:
Not applicable.
CLERK'S ADDENDUM
Rollie Katz, representing Public Employees Union Local One - confirmed the finance agreement. All Supervisors
expressed their appreciation for those involved in the long, arduous process of this settlement, and the positive
effects it brings to the County.