HomeMy WebLinkAboutCC RESO 15,822RESOLUTION NO. 15,822
RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
NATIONAL CITY APPROVING CITY OF SAN DIEGO
METRO OVERCHARGE REFUND AGREEMENT, AND
AUTHORIZING AND DIRECTING THE MAYOR
TO EXECUTE SAID AGREEMENT
WHEREAS, the City of San Diego METRO overcharged METRO
participating agencies including the City of National City,
during the period FY 1980 through 1986; and
WHEREAS, this overcharge was inadvertent and was caused
by inaccurate metering; and
WHEREAS, interim adjustments have been made in the
past; and
WHEREAS, accurate metering equipment has now been
installed and proved; and
WHEREAS, the METRO is now proposing a compromise
agreement to finalize restitution for these excessive charges,
which agreement would provide for a payment by METRO of $390,163
into the National City Sewer Service Fund.
NOW, THEREFORE, BE IT RESOLVED by the City Council of
the City of National City that the Mayor is authorized and
directed to execute the agreement on behalf of the City, a copy
of which agreement is attached hereto as Exhibit "A".
PASSED and ADOPTED this 13th day of December, 1988.
ATTEST:
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LORI ANNE PEOPLES, CITY CLERK
APPROVED AS TO FORM:
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GEOR E H. EISER, III -CITY ATTORNEY
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GEORGE WATERS, MAYOR
Exhibit VIII
COMPROMISE AGREEMENT AND MUTUAL RELEASE
THIS AGREEMENT AND MUTUAL RELEASE is made by and between THE
CITY OF SAN DIEGO, a municipal corporation, herein called "San
Diego," and the CITY OF NATIONAL CITY
herein called " National City
a participating or later
participating agency pursuant to the Sewage Disposal Agreement of
1960 pertaining to the Metropolitan Sewerage System.
Nature and Effect of Agreement
1. This Agreement consists of a compromise and settlement
by each party of that party's claims against the other party, and
a release given by each party to the other relinquishing all
claims against the other. By executing this Agreement, each of
the parties intends to and does hereby extinguish certain
obligations heretofore existing between them. This Agreement is
not, and shall not be treated as, an admission of liability by
either party for any purpose.
2. Since 1979, member agencies have disputed figures for
"total actual quantity of sewage handled and treated" through the
Metropolitan System sewage treatment plant as referred to in
Section 11 of the Sewage Disposal Agreement of 1960. Billing for
administration, maintenance and operation of the Metro System is
based on the proportionate share of "total actual quantity" of
flow handled and treated in the Metro Sewage System. (including
infiltration generated by each member agency). It is, therefore,
essential that accurate total flow information be utilized in
order to determine the proportionate share for each member
agency.
Member agencies have maintained since 1979 that the total actual
quantity of flow through the treatment plant was, in fact, larger
than was being reported, with the result that member agencies
were collectively being charged with a greater -than -proportionate
share of administration, maintenance and operation expenses.
This agreement relates totally and exclusively to the matter of
proportionate distribution of Metro System administration,
maintenance and operation expenses.
This Agreement shall specifically exclude matters related to:
a. Treatment plant expansion and/or betterments,
b. Added operational costs resulting from failure to make
timely expansions to those treatment plant facilities not
built to designed capacity during the original construction
of the Metro System treatment plant.
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c. Individual disputes between parties to this Agreement
relative to the accuracy of measurements of the individual
member agency's flow into the Metropolitan Sewerage System.
Mutual Compromise Agreement
3. Each party, in consideration of the promises and
concessions made by the other, hereby compromises and settles any
and all past, present, or future claims, demands, obligations, or
causes of action, whether based on tort, contract, or other
theories of recovery, which that
party has (or which may later
accrue to or be acquired by that party) against the other party.
and the other party's predecessors and successors in
and assigns, as well as past, present, and future
directors, shareholders, agents, employees, arising
interest,
officers,
from the
subject matter of the actions described in Paragraph 2 of this
Agreement, on the following terms and conditions:
a. The City of San Diego agrees to refund to the
member agency the sum of $390,163.00 as a one-time cash
payment by February 15, 1989. If payment is not made by
said date then San Diego will pay interest on the above sum
from January 1, 1989 through the actual date of payment.
Interest shall be computed at the rate of 7.87 per cent.
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Interest payment shall be subject to execution and delivery
of this Agreement to the City of San Diego by the member
agency by December 15, 1988.
b. The member agency agrees to accept same in lieu of
pursuing arbitration or any other claim of relief arising
from the subject matter of the actions described in
paragraph 2 of this Agreement.
c. The City and the member agency agree that this
compromise and settlement shall constitute a bar to all
past, present and future claims arising out of the subject
matter of the actions described in Paragraph 2.
Mutual General Release
4. Each of the parties on behalf of administrators and
assigns hereby fully releases and discharges the other party and
that party's administrators and assigns from all rights, claims,
and actions which each party and the above -mentioned successors
now have against the other party and the above -mentioned
successors, stemming from their differences arising from the
subjects described in Paragraph 2.
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Unknown Claims
5. (a) Each party acknowledges and agrees that the release
it gives to the other party upon executing this Agreement applies
to all claims arising from the subject matter as set forth in
Paragraph 2, for -injuries, damages, or losses to its own
property, real or personal (whether those injuries, damages, or
losses are known or unknown, foreseen or unforeseen, patent or
latent) which it may have against the other party. Each party
waives application of California Civil Code Section 1542 relative
to the subject matter set forth in Paragraph 2.
(b) Each party certifies that its representative has
read the following provisions of California Civil Code Section
1542:
"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."
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(c) Each party understands and acknowledges that the
significance and consequence of this waiver of California Civil
Code Section 1542 is that even if it should eventually suffer
additional damages arising out of the facts referred to in
Paragraph 2, it will not be able to make any claim for those
damages. Furthermore, each party acknowledges that it
consciously intends these consequences even as to claims for
damages that may exist as of the date of this release but which
it does not know exist, and which, if known, would materially
affect its decision to execute this release, regardless of
whether its lack of knowledge is the result of ignorance,
oversight, error, negligence, or any other cause.
Advice of Attorney
6. Each party warrants and represents that in executing
this Agreement, it has relied upon legal advice from the attorney
of its choice; that the terms of this Agreement have been read
and their consequences (including risks, complications, and
costs) have been completely explained to it by that attorney; and
that it fully understands the terms of this Agreement. Each
party further acknowledges and represents that, in executing this
release, it has not relied on any inducements, promises, or
representations other than those stated herein.
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Entire Agreement
7. This Agreement contains the entire agreement between the
parties.
Effective Date
8. This Agreement shall become effective immediately upon
execution by the parties listed below.
Governing Law
9. This Agreement is entered into, and shall be construed and
interpreted in accordance with, the laws of the State of
California.
(A\FORMS\RELAGRE)
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IN WITNESS WHEREOF, the participating agency has caused this
Agreement to be executed by National City Mayor GEORGE WATERS
pursuant to Resolution No. /S Ya?1 , and by the CITY OF
SAN DIEGO, acting by and through the City Manager, pursuant to
Resolution No. of the City authorizing such
execution.
Dated this day of , 1988.
APPROVED AS TO FORM
George H. Eiser, III
City Atto; ney
WWWWWWWWWWW
THE CITY OF SAN DIEGO
By
City Manager
Participating/Later
Participating Agency
I HEREBY APPROVE the form and legality of the foregoing
Agreement this day of 1988.
WEH:jg
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(A\FORMS\RELAGRE.DOC)
JOHN W. WITT, City Attorney
By
Ted Bromfield
Chief Deputy City Attorney