HomeMy WebLinkAbout1997-06-17; City Council; 14222; SETTLEMENT AGREEMENT BETWEEN CITY OF CARLSBAD, COUNTY OF SAN DIEGO AND COAST WASTE MANAGEMENTV
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MTG. nm CITY OF CARLSBAD, COUNTY OF SAN DIEGO CITY
DEPT. CM AND COAST WASTE MANAGEMENT CITY
RECOMMENDED ACTION:
97-99f Adopt Resolution No.
City of Carlsbad, the County of San Diego, and Coast Waste Management.
ITEM EXPLANATION
For many years, the City's authorized solid waste handler, Coast Waste Management ha
Palomar Transfer Station from the County. This lease was initially on a multi-year basi
year-to-year basis and, finally on a month-to-month basis. As regional solid waste issi
more volatile in 1994, the County of San Diego attempted to evict Coast Waste Managem
Palomar Transfer Station site. Coast Waste filed a suit against the County of San Diego
of trade. At that point, the City intervened and also initiated separate eminent domain 1
The City, the County and Coast Waste then agreed to suspend all litigation in an attempt
a mutually beneficial settlement agreement. In the interim, a revised lease extending the
until May 31, 1997 was executed.
In March 1997, the conditional use permit for the San Marcos Landfill was revoked by the
Marcos, and the landfill was closed. The capacity of the Palomar Transfer Station was I
800 tons per day (tpd), and the Station began processing and transferring waste from
jurisdictions to the Sycamore Landfill, near Santee, and secondarily, the Otay Landfill in
Throughout these events, all parties continued to negotiate the settlement agreement.
expectation that a final settlement agreement would be achieved.
The product of these negotiations is before you tonight for your consideration. Key F
settlement agreement are as follows:
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authorizing the Mayor to execute the settlement agreement
closure of San Marcos, all parties have operated under these deal points in good f;
Lease For Collection, Operation. Transfer and Related Solid Waste - The County Airp
will lease the facility to the City, and in turn, the City will sublease the facility to C
Management. Sublease terms will mirror the lease terms.
Transfer Operations - Carlsbad as lessee, and Coast Waste as sublessee shall have
conduct transfer and transport operations at the facility during the term of the lease/sul
Permits - The City shall consider issuing a conditional use permit for the Station's ope1
tpd (CUP approved March 5, 1997). Coast Waste shall obtain a solid waste fac
Pending issuance of the permit, current operations are pursuant to a notice and ord
the local enforcement agency. The County shall cooperate in assisting the permittins
Improvements - The County will fund and install $500,000 street and related improve1
facility, and Coast will effect other improvements at the site.
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amendment from the California Integrated Waste Management Board to operate
The use of the facility will be restricted on weekdays to commercial collection vehicles, v
and non-commercial users being accommodated on weekends. The buy-back operation \
with hours of use established via the CUP.
While no flow control is exercised by the County or the City, economic incentives ai
disposal at County landfills (primarily Sycamore Landfill, secondarily the Otay Landfill) is
most economically viable alternative. The tip fee at the Palomar Transfer Station g;
$38/ton. Of that $38, the County retains $17, and $21 goes to Coast Waste Transfer fo
transfer, transport, and disposal. Waste originating in Carlsbad which has been transferre
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Page Two
Station is assessed a reduced tip fee of $8/ton at Sycamore and $6/ton at Otay, leaving (
$13 - $15 for transfer and transport. Waste originating outside Carlsbad is given E $2.50/ton discount for disposal. The $2.50 discount is rebated to the City as a non-
processing fee.
All parties have agreed in concept to the terms outlined in the settlement agreement. TI
of the agreement will effectively dismiss previous litigation of the parties involved. Other ii
agreements which must also be executed include the lease, sublease, and transfer statio1
agreement between the City and Coast Waste.
FISCAL IMPACT
The operation of the Palomar Transfer Station since the closure of the San Marcos
resulted in the avoidance of tremendous direct-haul transport costs not only for Carlsbad
neighboring jurisdictions as well. This effectively retained waste in the County system 1
have likely otherwise been disposed of at out-of-county landfills. The execution of this ag
allow Carlsbad to continue to achieve stability in the solid waste rates charged to the re
business owners of Carlsbad. The non-jurisdictional processing fee will generate a1
$325,000 annually for Carlsbad.
EXHIBITS
1. Resolution No. y7-- gyf
2. Settlement Agreement between the City of Carlsbad, the County of San Diego, and C
Management
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RESOLUTION NO. 97-498 1
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF CARLSBAD, CALIFORNIA APPRQVING THE SETTLEMENT
AGREEMENT BETWEEN THE CITY OF CARLSBAD, THE COUNTY OF SAN DlEGO AND COAST WASTE MANAGEMENT AND AUTHORIZING ITS EXECUTION
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WHEREAS, the Palomar Transfer Station is owned by the County of San Diegc
for many years been leased by Coast Waste Management on a month-to-month basis;
WHEREAS, Coast Waste Management has operated the Palomar Transfer S
held a non-transferable solid waste facilities permit required and issued by the
Integrated Waste Management Board; and,
WHEREAS, the City of Carlsbad exercises land use authority over the Paloma
Station; and,
WHEREAS, all parties have determined it mutually beneficial and in the best
the residents and business owners of Carlsbad and San Diego County to cooper
continued operation of the Palomar Transfer Station; and,
WHEREAS, to that end, all parties hava negotiated the attached settlement agr
NOW, THEREFOR€, BE IT RESOLVED, BY THE City Council of the City of C
foltows:
1. The above recitations are true and correct.
2. The Settlement Agreement between the City of Carlsbad, the County of 3
and Coast Waste Management attached hereto is hereby approved.
3. The Mayor is hereby authorized to execute said Agreement on behalf of the
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PASSED, APPROVED AND ADOPTED by the City Council of the City of Carl:
, 1997, by the following vote regular meeting held on the day of
AYES:
NOES:
ABSENT:
CLAUDE A. LEWIS, Mayor
ATTEST:
ALETHA L. RAUTENKWNZ, City Clerk
(SEAL)
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SETTLEMENT AGREEMENT BETWEEN
THE CITY OF CARLSBAD
THE COUNTY OF SAN DIEGO
AND COAST WASTE MANAGEMENT
This Settlement Agreement and Mutual Release (“Agreement”) is made and entered into
this day of June, 1997, by and among the CITY OF CARLSBAD, California, a municipal
corporation (“Carlsbad”), COAST WASTE MANAGEMENT, INC., a California corporation
(“Coast”), and the COUNTY OF SAN DIEGO, a political subdivision of the State of California
(the “County”).
I.
RECITALS
A. The County owns the Palomar Transfer Station Site (the “Facility”) in Carlsbad,
California (County Real Property Parcel Numbers 84-0127-A & 86-0442-A1), which it leased to
Coast under County Contract No. 18 199 (the “1 984 Lease”).
B. During 1994, disputes arose among the parties as to their respective rights and
duties with respect to the Palomar Transfer Station, including the following litigation:
1. Coast Waste Management, Inc., et al. v. County of Sun Diego, et a].,
U.S. District Court No. 94-1823-IEG (a challenge by Coast and Carlsbad seeking to prevent the
County’s termination of Coast’s 1984 Lease).
2. City of Carlsbad v. County of Sun Diego, et al., San Diego Superior Cou
Case No. N664 15 (an eminent domain action seeking to acquire the Palomar Transfer Station
property from the County).
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FINAL SETTLEMENT AGREEMENT
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C. The San Diego Solid Waste Authority, a joint powers authority (the “Authority)’)
was a party defendant to Case No. 94-1823-IEG. However, upon motion by Coast, the Authorit
was dismissed from that action by order of the Court filed March 11, 1996.
D. In June 1996, the Parties filed a Stipulation for Settlement and Mutual Dismissals
Without Prejudice with the United States District Court; the Court entered an order on that
stipulation on September 6, 1996. The Stipulation provided that because of uncertainties over th
future operation of the San Marcos Landfill and the transition of assets to the Authority, the 1981
Lease to Coast was amended and extended for an “Interim Lease Period,” lasting until
May 3 1, 1997. The Stipulation further provided that during the Interim Lease Period, the parties
would agree to “meet, confer and negotiate in good faith with respect to the permanent, longer
term settlement.’’
E. On September 23, 1996, in County of San Diego v. City of SanMarcos, et al.,
Case No. 679514, the Superior Court upheld a City of San Marcos order that the San Marcos
landfill must cease receiving solid waste for disposal no later than March 11 , 1997.
F.
G.
The Authority has dissolved. The Authority is not a party to this Agreement.
The parties have now reached a full and complete agreement to convert the
dismissal in the Coast Waste, Inc., et al. v. County of Sun Diego, et al. Case referenced above to
a dismissal with prejudice, without any admission of legal fault, wrongdoing, or liability on the
part of any party, The Agreement is to be carried out through this Agreement, and through the
Leases described in section IV below (“the Leases”). It is the intent of the Parties that this be a
full, final, and complete settlement of the above-referenced litigation, except to the extent that an
party has expressly reserved rights in this Agreement and/or through the Leases.
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H. The Parties agree and find in executing this Agreement that (i) the County is a
participant in the market for solid waste disposal services; (ii) Carlsbad and the County are acting
as local agencies to make adequate provision for solid waste handling, both within their respectiv
jurisdictions and in response to regional needs, pursuant to the powers vested in them in Public
Resources Code Section 40002; and (iii) this Agreement and the Leases serve a legitimate public
purpose in connection with the safe and cost effective disposal of solid waste. The Parties agree
that this Agreement and its implementing Leases do not violate the federal Commerce Clause, tht
Sherman Anti-Trust Act, or any other similar provision of federal or state law. In consideration
for the payments, promises and conditions below, it is the mutual intention of the Parties to
release one another from these commerce clause, anti-trust, and similar claims.
I. The Parties acknowledge that they reached an agreement in principle prior to
March 12, 1997, and that, pending the completion and execution of this Agreement, all Parties
have acted in reliance on the Agreement which is now being memorialized herein.
J. To the extent that notice may be required pursuant to Public Resources Code
section 49520 in order for this Agreement to terminate in five years as provided herein, the Partit
acknowledge that such notice is deemed given. .
IT.
DEFINITIONS
A. Coast.
The term “Coast” shall mean COAST WASTE MANAGEMENT, INC., a California
corporation, and subject to the approval provisions of this Agreement set out in Section Q, its
approved successors and assigns, or such other entity or sublessee as Carlsbad shall authorize to
operate the Facility during the term of its use under this agreement.
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FINAL SETTLEMENT AGREEMENT
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B. ExDansion.
The term “Expansion” shall include any action to increase the handling capacity of the
Facility above the 800 tons per day currently permitted by the Carlsbad CUP.
C. Facility.
The term “Facility” shall mean the land, improvements, transfer station and related
facilities located on the property described in Exhibit A attached hereto.
D. Lease.
The term “Lease” shall mean (1) that certain Lease of real property and building space
which the County Airports Division, as Lessor, and Carlsbad, as Lessee, intend to execute
pursuant to this Agreement; and (2) the existing lease between the County Airports Division, as
Lessor, and Coast, as Lessee, which terminates by its terms on May 3 1, 1997. The existing lease
shall remain in effect until the new lease is signed except that the leased property shall include tht
full 10.70 acres described in section IV until new Leases are signed.
E. Leases.
The term “Leases” refers collectively to the Lease and the Sublease.
F. Sublease.
The term “Sublease” shall refer to the sublease between Carlsbad and Coast, the key deal
points of which are set forth in section IV and any subsequent sublease between Carlsbad and an
successor to Coast, to be executed by Carlsbad as Sublessor and Coast as Sublessee.
G. Recyclables.
The term “Recyclables” shall refer to those items collected and brought to the Palomar
Facility which are diverted for recycling, reclamation, or re-use and which are not sent to a landf
for disposal.
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FINAL SETTJXMENT AGFSEMEhT
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H. Countv Landfill.
The term “County Landfill” shall refer to the following landfills: Ramona Landfill,
Sycamore Landfill and Otay Landfill.
rn.
SETTLEMENT
A, Basic Structure.
1. Lease For Collection, Operation, Transfer and Related Solid Waste
Purposes. The County Arports Division will lease the Facility to Carlsbad for use as a collection
and operation center and for transfer and related solid waste purposes for a term of five years
beginning June 1, 1997. Carlsbad shall sublease the site to Coast on a “pass through” basis, i.e
Coast or a successor sublessee will operate and maintain the site, pay the rent, and otherwise
perform all of the obligations of the Lease and Sublease, and of this Agreement, with respect to th
site. Carlsbad will have a right of first refusal during the term of its Lease to acquire fee title to th
Facility on the same terms and conditions as any prospective purchaser or transferee receiving fee
title from the County should the County ever propose to sell or transfer the property. This right o
first refusal is effective only during the term of the Lease, and shall expire upon termination of thr
Lease. The County shall notify Carlsbad of any offer to purchase or proposal to transfer fee title t
the Facility and shall allow Carlsbad ninety (90) days after notice to exercise the option to acquirc
the Facility on the same terms and conditions. If Carlsbad fails to exercise the option to acquire
the property within such ninety (90) days, it shall be deemed to have declined to exercise its right
of first refusal.
2. Transfer Operations. Carlsbad as Lessee, and Coast as Sublessee, shall hay
the right to conduct transfer and transport activities at the Facility during the term of the Lease an
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F”AL SETTLEMENT AGREEMENT
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Sublease on the terms and conditions set forth herein and in conformance with all applicable
permits, laws, rules, and regulations, in addition to Coast’s right to continue its collection and
operations use of the Facility.
B. Permits and Processing.
1. Carlsbad. The parties acknowledge that the Carlsbad Planning Commissio
approved a CUP amendment for the project on March 5, 1997 to allow the Facility to operate at
its original design capacity of 800 tons per day. Carlsbad’s action on the CUP amendment
included CEQA compliance. The parties acknowledge and agree that on March 12,1997, the
Facility began operations at 800 tons per day in reliance on the CUP in anticipation of the final
execution of this Agreement.
2. Coast. Coast shall take any and all actions, provide information, and pay
any fees, to promptly process through the Local Enforcement Agency (“LEA”) and the Integrate
Waste Management Board (“IWMB”) an application to amend the Solid Waste Facilities Permit
(“SWFP”) permit to allow operation of the Facility at 800 tons per day.
3. County. The County Solid Waste Services and Airports Division, as land
owner, shall sign all permit applications giving their consent to processing and approval of the
requested amendments, and shall in all other respects assist the prompt processing of the CUP anc
SWFP permit amendments and any Interim Order that may be necessary to allow continued
operations at 800 tons per day.
C. Trash HandlinP and Transfer.
The parties have agreed that the Facility can and should be operated by Carlsbad/Coast at
its original design capacity of 800 tons per day, subject to CEQA clearance and approval of the
above-referenced SWFP permit amendments, that operation at this capacity by March 12, 1997,
was beneficial and important to the region, given that the San Marcos landfill was scheduled to
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FINAL SETTLEMENT AGREEMENT
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close, and did close, after March 1 1, 1997, and that the use of the Facility to service 800 tons per
day is an important part of the regional plan to provide safe, cost effective and environmentally
sound waste service post San Marcos closure.
portions of the agreement between the parties are:
Key aspects of the waste handling and transfer
1. Service Areas. The 800 tons of capacity shall be made available consistent
with any terms and conditions which may from time to time be set forth in the Carlsbad CUP and
in the SWFP permit.
2. Limitations on Use of Palomar Facility. With respect to transfer operations,
service at the Facility will be limited to:
(a) Commercial Users: First priority shall be given to commercial
waste haulers holding a County Waste Hauler’s Permit whose loads originate in any service area
which may from time to time be designated in the Carlsbad CUP. Second priority shall be given
to other permitted commercial waste haulers with compactors and/or mechanical off loading
devices. Third priority to all other users. At no time shall the per day tonnage limit set by
Carlsbad’s CUP or the SWFP be exceeded. In the event that a dispute as to priority of use of the
Facility should arise, the parties agree to meet and confer in good faith in an attempt to reach
agreement on how available capacity should be allocated. If the parties are unable to so agree
within 30 days, then Carlsbad shall have the right to make the final decision.
(b) Self-Haul: Non-commercial, self haul loads shall be accepted on
weekends only, or at such times, days and hours as may from time to time be set by Carlsbad.
Carlsbad shall have the right, through its CUP or by order of its City Manager, to impose
additional conditions and restrictions on weekend self haul use of the Facility if traffic, litter, or
other problems arise. The parties agree that Coast will carefully monitor its costs incurred in
providing self haul service on the weekends, and that during the month of September 1997 the
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parties shall meet and confer in good faith to review Coast’s actual costs incurred to that time in
providing this service, and Carlsbad and the County Solid Waste Services agree to adjust the rates
which the County may charge to self haul users as appropriate to cover Coast’s documented costs
and to provide a reasonable profit to Coast;
(c) Buy-Back: Recyclable buy back shall be permitted on the terms anc
at the days and hours as may from time to time be set by Carlsbad. Carlsbad shall have the right,
through its CUP or by order of its City Manager, to impose additional reasonable conditions and
restrictions on recyclable buy-back operations if traffic, litter, or other problems arise;
(d)
(e)
Hours and days of operations shall be as set in the Carlsbad CUP;
So long as Carlsbad is in good standing under its Lease, and Coast i:
in good standing under its Sublease, Coast may use the site for its non-transfer collection and othei
business activities within the restrictions of the Carlsbad General Plan, Zoning, City Code, and the
CUP.
3. Transfer and Transport. Coast, or a successor sublessee, shall transfer wastt
at the facility from the incoming vehicles and self haul loads, all in conformance with the CUP, the
SWFP, this Agreement, and applicable federal, state, and local laws, rules and regulations that may
from time to time apply. Carlsbad shall have the right to approve of any substitute or new operator
of the Facility besides Coast, pursuant to the approval provisions set forth below in Section Q,
which approval shall not be unreasonably withheld. In addition, the County Airports Division, as
landlord, shall have the right to approve the change in Sublessee, which approval shall not be
unreasonably withheld, in conformance with the terms of the Lease and Sublease.
4. Recycling. Coast shall have the right to recover recyclables from the waste
stream for reclamation, reuse, and resale. Loads entering the Facility that are 100 percent
recyclables, and which are in fact reclaimed and/or recycled and not sent for disposal, shall not be
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FINAL SETTLEMENT AGREEMENT
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subject to the fee payment structure set forth below applicable to all waste destined for disposal.
With respect to loads of mixed waste that enter the facility, cross the scales, and pay fees pursuant
to the schedule set forth below, a rebate or credit shall be given for any recyclables that are
subsequently removed and actually reclaimed, reused or recycled and not sent for disposal. As to
any such recyclables picked Erom the waste stream, recyclables SQ removed shall be re-weighed
across the scales and an appropriate credit given at the same rate as the charges imposed when the
material entered the Facility such that no fees shall be paid to the County Solid Waste services, or
its transferee, for materials that are actually diverted for recycling, reclamation, reuse and resale
and which do not end up in a disposal facility. Any fees that are collected by the County Solid
Waste Services, or its transferee, at the Facility gate at the time of entry of material which is later
determined to be recyclables within the meaning of this paragraph shall be paid over to Coast.
In accordance with Section m@) of the Fee Schedule’, Coast shall be responsible to
provide information upon request, on the source of the waste being processed at the Facility or
hauled to a landfill. If Coast willfully or negligently misrepresents the origin of the waste in a
manner that could result in a material2 improper reporting of waste volumes for any jurisdiction,
Coast will be subject to the administrative fees provided in the Fee Schedule.
‘The Fee Schedule is the schedule of fees set and published by the County for use of
County solid waste facilities and services. A copy of the relevant portion of the current edition of
the Fee Schedule is attached hereto for reference as Exhibit C.
2The parties recognize that waste from a variety of commercial haulers, as well as from
self haulers, will be entering the Facility and that these wastes may be commingled on the tipping
floor and packaged in larger vehicles for transfer and transport. To the extent that transfer loads
contain such commingled waste, Coast’s ability to accurately report the origin of waste in these
transfer loads is only as good as the information that non-Coast controlled haulers and self hauler:
give to the County Solid Waste Services, or its transferee, at the entry gate to the Facility,
although Coast retains a higher degree of responsibility for accuracy in reporting as to the origin
of waste in Coast controlled vehicles entering the Facility.
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In the event that Coast is found responsible for three or more violations of the recycling
provisions of this Agreement in any six (6) month period, in addition to the penalties provided
above, such finding of three violations in any six (6) month period shall constitute a material,
uncorrected, breach of this Agreement and of the Sublease entitling the County, or its transferee, c
Carlsbad, to exercise their rights for uncorrected material breach, including termination of Coast's
rights under this Agreement and termination of the Sublease.
5. No Flow Control. Carlsbad and Coast shall be free to direct waste to any
disposal site of their choosing. It is understood that disposal at a site not covered by the CEQA
review and certification issued incident to the Carlsbad Planning Commission's March 5,1997
CUP amendment approval will require additional environmental review in the form of an initial
study, negative declaration, EIR, or exemption.
6. Tip Fee at Palomar. The parties agree that beginning March 12, 1997, the
County was entitled to collect all fees for the placement or disposition of any solid waste at the
Facility, except recyclables as provided for herein. The County Solid Waste Services, or its
transferee, shall be entitled to collect such fees throughout the duration of the Lease. Coast and
Carlsbad acknowledge and accept the changes made bythe County to the fee booths and scales to
accommodate fee collection pursuant to this Agreement, and agree that the County may make such
further modifications as it deems necessary to the fee booths and scales, at its expense, to
accomodate fee collection. In consideration of this Agreement and the Leases, the County makes
the following guarantees.
(a) Fee at Facilitv Gate. Beginning March 12, 1997, and continuing
until May 3 1,2002, the total fee collected by the County Solid Waste Services, or its transferee,
for the processing, placement or disposition of solid waste at the Facility shall not exceed thirty
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eight ($38) per ton. Of that amount, County Solid Waste Services, or its transferee, shall retain
seventeen ($1 7) dollars per ton as additional rent for use of the Facility.
(b) Disposal Fees For Transferred Waste. Beginning March 12,1997,
the County Solid Waste Services has provided, and until May 3 1,2002, it or its transferee shall
continue to provide a basic reduced tip fee of eight ($8) dollars per ton for waste transferred from
the Palomar Facility to a County disposal facility (currently the Sycamore Landfill). Although no
currently contemplated, if in the future waste from the Facility is directed to the Otay Landfill the
basic reduced tip fee at Otay shall be six ($6) dollars per ton.
(c) Disposal Fees for Waste in Excess of that Generated within the ciQ
of Carlsbad. Beginning March 12, 1997, the County Solid Waste Services has provided, and it or
its transferee shall continue to provideuntil May 3 1,2002, a further reduction in the tip fee at the
landfill for waste transferred from the Palomar Facility which is in excess of the average daily
tonnage of waste generated within the City of Carlsbad (Carlsbad’s trash) and disposed of in
County facilities3. All waste up to 800 tons per day minus the waste generated within the city of
Carlsbad and disposed.of in County Facilities will receive a further reduction of $2.50 per ton. AI
waste between 800 and 1,000 tons per day, minus Carlsbad’s trash disposed of in County
Facilities, will receive a further reduction of $3.25 from the basic tip fee of $8. The parties
31n computing the amount of waste generated within the City of Carlsbad and disposed of
at County facilities, the parties agree that all waste generated within the corporate limits of the
City of Carlsbad which is disposed of in County facilities shall be counted, whether it is
transferred and transported through the Palomar Facility, through direct haul, or otherwise, so
long as it is disposed of in a County facility. The Parties further agree that the beginning number
to be used as “Carlsbad’s trash” under this Agreement shall be based upon measurements of
actual volumes received at the Facility from March 12, 1997 to April 12, 1997 and a starting
baseline shall be set based on such measurements effective as of March 12, 1997 , and that
Carlsbad’s actual tonnage shall be measured every six months thereafter and the baseline adjusted
to reflect the actual figures. Further, the parties agree that adjustments will be made retroactively
at each six month interval with appropriate additional charges to Carlsbad, or credits, as the case
may be..
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recognize that the capacity of the Facility is currently limited to 800 tons per day and that any
increase above that level will require further applications to Carlsbad, the County Local
Enforcement Agency, and the IWMB, and will be required to undergo appropriate environmental
and other reviews. The purpose of the pricing provisions set forth herein respecting daily tonnage
over 800 tons per day is only to confirm the agreement of the parties with respect to pricing shoulc
such additional tonnages ever be permitted in the future.
(d) Transfer and Transport Fees to Coast. Beginning on March 12,
1997, the County Solid Waste Services has credited, and it or its transferee shall continue until
May 3 1,2002, to credit and pay to Coast twenty one ($21) per ton of the Thirty Eight dollars per
ton collected at the gate. This shall constitute payment in full to Coast for transfer and transport oj
waste to County landfills under this Agreement. However, in the event that waste is ever directed
to the Otay Landfill for disposal rather than the Sycamore Landfill, Coast shall receive the
additional two dollars as provided above in subsection (b).
Coast’s compensation shall be adjusted to reflect any unusual changes in fuel prices
incurred by Coast during the term of this Agreement related to the transport of waste from the
Facility to a County Landfill. An “unusual change in fuel price” shall be defined as a 15 percent 01 ba?& seoc;yR, (mrz
greater change in the cost of fuel to Coast as set forth in the A
up or down, within any 6 month period. E the 15 percent threshhold is met, then Coast and the
County shall share evenly in such increase, or decrease in fuel cost incurred during that 6 month
period. If the parties cannot agree on the application of this fuel price change sharing provision
with respect to a particular situation, any party may invoke the dispute resolution provisions of
section 0 of this Agreement. In addition, if Coast believes that, as a direct result of entering into
this Agreement, Coast experiences unavoidable material increases in its insurance costs, Coast
shall be entitled to present a request for what it believes to be an appropriate adjustment in its
w Index, either
12 F~\CLIEhTS\CITCAD\COASTWST\DOCUMENT\CTTC6.337 FINAL SETTLEMENT AGREEMENT
rl) e
compensation. If‘ Coast presents such a request, Coast, Carlsbad, and the County Solid Waste
Services, or its transferee, shall meet and confer in good faith to consider the basis for the request
If the Parties agree, an appropriate adjustment shall be made in Coast’s compensation. If the
Parties do not agree, Coast may invoke the dispute resolution provisions of Section 0 of this
Agreement.
(e) Coast Collection and Transmittal to Carlsbad of Monies for Excess
Tonnape Reductions. Beginning on March 12,1997, and continuing to May 3 1,2002, Coast has
collected, and shall continue to collect and transmit back to Carlsbad in cash, or in such other
manner as Carlsbad may from time to time direct, and at such intervals as Carlsbad may direct,
but not more than monthly, the amount of reduced tip fees for all waste disposed of in County
Landfills above Carlsbad’s trash as set forth above.
Iv.
LEASES
Under the prior Interim Settlement Agreement Coast currently has a one year lease from
the County Arports Division expiring on May 3 1,1997, for 7.226 acres. To accommodate
implementation of this Agreement the parties intend to enter into revised Leases increasing the
leased acreage from 7.226 acres to 10.70 acres. The parties contemplate that the following Lease:
will be executed on or before May 3 1, 1997, or as soon thereafter as possible. In the event that the
Leases are not able to be signed by May 3 1, 1997, the parties contemplate extension of the existinj
one-year interim lease by separate letter agreement, on a month-to-month basis, provided however
that the rent payable and acreage leased starting June 1, 1997, shall be as set forth below in N(A).
The Leases shall conform to the following basic deal points:
111
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13 F:\CJJENTS\CITCAD\COASTWSTWOCUME~ClTCAD6.337 FINAL SETTLEMENT AGREEMENT
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A.
There will be a master lease from the County Airports Division to Carlsbad. Key terms of
Master Lease From County to Carlsbad.
this lease include: 10 37s
1. Acreage: dG
2. Term: Five years, commencing June 1, 1997;
3. Rent: Starting June 1, 1997: $23&2H9 per month, adjusted up
or down to reflect the final agreed upon acreage, at the rate
of 3.375 cents per square foot per month, said final acreage
to be agreed upon and added to this Agreement by
Addendum within 10 days of the execution hereof; payable
to the County Airports Division;
d 23, 63V*?o*
4. Terms: Standard Airports Lease Terms as adjusted through
negotiations of the parties;
5. Termination: Quiet enjoyment to Carlsbad and subleases, early
termination for material breach of lease that remains
uncorrected after notice, or for material breach of
Settlement Agreement that remains uncorrected after notice;
6. Enforcement: Through standard lease enforcement; through Settlement
Agreement, including forfeiture for failure to cure material
breach after notice;
7. First Refusal: hght in favor of Carlsbad to first refusal to acquire title to
the fee interest in the property as set forth above in
paragraph IUA;
14 F~\CLIENTS\CITCAD\COASTWSTU)OCUMENnCITCA6.337
FWAL SETTLEMENT AGREEMENT
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B.
At $1 7 per ton (not including recyclables) commencing March 12, 1997, payable to
Additional Rent to Countv Solid Waste Services.
County Solid Waste Services, or its transferee.
C. Carlsbad to Coast Sublease.
There will be a Sublease from Carlsbad to Coast mirroring and passing through to Coast
day to day operational control and responsibility for the site. Key terms of the Sublease will
include:
1. Acreage: 10.70;
2. Rent: Coast will pay all rent due on the site directly to the County
Airports Division;
3. Operations: Carlsbad will impose such oversight provisions and
operating standards as it deems necessary to ensure that
Coast safely and properly operates the Facility, such terms
and provisions to reflect the negotiations of Coast and
Carlsbad yet to occur, the terms and conditions of this
Agreement, and of the CUP for the Facility. An operations
agreement may, in the discretion of Carlsbad, be separately
prepared and incorporated into the Sublease;
The Sublease shall ensure that any and all site related
obligations imposed on Carlsbad by the Lease are
passed through and become the obligation of Coast,
including rent payment, maintenance of the Facility,
etc., it being the intent that Coast will have the right
4. Other:
15 F:\CLIENTS\CTTCAD\COASTWS~OCUIvlE~CITCAD6.337
FINAL SETTLEMENT AGREEMENT
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to control and operate the Facility under its Sublease,
with a right of quiet enjoyment, so long as it
performs the site related obligations of the Lease, the
Sublease, the CUP, any operations agreement, and
this Agreement.
5. Term: Five years, commencing June 1, 1997.
6. Extension: If the County does not proceed with the divestiture of the
assets of the County Solid Waste System and instead decide
to retain control of the system, then the County, Carlsbad,
and Coast agree to meet and negotiate in good faith to reach
agreement on three additional consecutive five (5) year
option periods in the Leases (including the Sublease) for the
use of the Facility, subject to the right of Carlsbad if it
deems appropriate in its discretion to protect and promote
the public interest, to undertake competitive bidding or a
competitive proposal process with respect to Transfer and
Transport operations at the Facility at the end of the initial
five (5) year term.
D. Proiect Desim Enhancements.
The parties have agreed as an important part of this Agreement that the project design
enhancement measures set forth on Exhibit B hereto will be included in the project. These
measures are being incorporated into the project as part of project design, and are agreed to as a
contractual and settlement matter, independent of CEQA. The parties understand that these
16 F:\CLIENTS\CTTCAD\COASTWS~~~~CTTC~6.337
FINAL SETTLEMENT AGREEMENT
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measures will eliminate any potential adverse impacts or unusual circumstances that might
otherwise adversely affect the environment or Carlsbad and its residents arising incident to
increasing operations at the Palomar site to 800 tons per day of transfer activity.
The parties agree that these measures may be included as conditions of approval of the
CUP as well as part of the project description if Carlsbad so desires to ensure that they are
implemented. These measures, unless expressly stated otherwise, are to be funded by the County
Solid Waste Services.
E. Relationship of Apreement to CUP.
1. Settlement Agreement Controls.
The parties agree that to the extent there is any ambiguity or conflict between the
provisions of this Agreement and the CUP issued by Carlsbad, this Agreement shall control. The
CUP shall be interpreted and enforced according to law in a manner consistent with this
Agreement at all times.
2. Enforcement of CUP by Carlsbad.
With respect to the provisions of the CUP regarding enforcement by Carlsbad, and in
particular condition 9 of the CUP, the parties agree that all of the following shall apply:
(a) “Surrounding Properties” shall be defined in conformance with the
Carlsbad Planning Department standard practice as those nearby properties potentially affected by
the project, generally within Carlsbad’s standard notice distance of 600 feet of the boundaries of
the Facility and those properties directly abutting a truck route in the City of Carlsbad that will be
used by waste haul vehicles to access or exit the Facility, including collection vehicles and long-
haul transfer vehicles.
(b) “Negative effects” and/or “detrimental effects” shall not be found tc
exist by Carlsbad incident to any CUP enforcement action unless the effects are found, based on
17 F:\CLIENTS\ClTCAD\COASTWSTDOCUMENTClTCAD6.337
FINAL SETTLEMENT AGREEMENT
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substantial evidence in the record, to be substantial and adverse, and not occasional. “Negative
effects” and “detrimental effects” shall be limited to legitimate environmental, public health, and
public safety issues as prescribed by law such as litter, illegal dumping, noise, and traffic
disruption caused by the project.
(c) In the event that Carlsbad believes the project has caused or is
causing such effects, Carlsbad shall give notice to the County Solid Waste Services (with a copy tc
the Arports Division) and/or Coast, as appropriate to the circumstances, meet and confer in good
faith, and shall give a reasonable opportunity to cure. If the County Solid Waste Services and/or
Coast does not (1) attend a meet and confer session within 20 days of receiving notice thereof, or
(2) (a) correct the problem within 30 calendar days, or (b) make good faith progress towards
correction within 30 days, then Carlsbad may institute formal CUP enforcement proceedings.
Carlsbad may revoke the CUP only if it first complies with all of the above and finds, based on
substantial evidence in the record, that a material breach of the CUP has occurred which remains
uncorrected after notice and opportunity to cure.
The provisions of this subparagraph (D) were independently negotiated and agreed to as
part of this Settlement Agreement, are not a precedent as to any other project, and do not apply to
any other project.
V.
MUTUAL RELEASES AND DISMISSALS
A. Release of Claims.
The County, Carlsbad, Coast, and their respective heirs, executors, administrators,
trustors, trustees, beneficiaries, predecessors, successors, assigns, members, partners, joint
venturers, parents, subsidiaries, affiliated and related entities, officers, directors, shareholders,
18 F\CLIENTS\CITCAD\COASTWS~W”nCflCAE6.337
FINAL SETTLEMENT AGREEMENT
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principals, agents, servants, employees, representatives, insurers, sureties, attorneys, consultants,
and experts, and each of them hereby jointly and severally release each other fi-om any and liabilitj
for the claims, demands, controversies, actions, causes of action, obligations, liabilities, expenses,
costs, attorneys' fees and damages of whatever character, nature and kind, known and unknown,
which arise out of the Facility and matters related to possession (whether as tenant or otherwise)
of the Facility or any claim of right of access to or use of the Facility arising prior to the date of
this Agreement, including without limitation those claims which were or could have been asserted
in either of the lawsuits referenced above in Section I.B.
i
B.
Each party is aware that it may hereafter discover claims or facts in addition to or different
Waiver of Protection of Civil Code 6 1542.
from those it now knows or believes to be true with respect to the Claims described in Section A
hereof Nevertheless, it is the intention of the Parties to filly, finally and forever settle and release
all such matters, and all claims relating to them, which now exist or may have existed between
them, or which arise out of or relate to the Claims. In krtherance of this intention, the releases
given herein shall be and remain in effect as full and complete mutual releases of all such matters
notwithstanding the discovery or existence of additional or different claims or facts relating to
them. Moreover, Carlsbad, Coast and the County, acknowledge that they have been advised by
legal counsel, and that they are familiar with and specifically waive any and all rights and benefits
conferred upon them by the provisions of Civil Code section 1542, which provides:
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.
Ill
19 F:\CLIENTS\CITCAD\COASTWSl3DOCUMENnCnTC6.337 FMAL SETTLEMENT AGREEMENT
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VI.
NOTICES
Any notices to be given under this Agreement shall be addressed as set forth in this section.
Notices or documents sent to the County should be sent to:
Tim Walsh, Deputy Director, Airports Division
County of San Diego Department of Public Works
1960 Joe Crosson Drive
El Cajon, CA 92020
Joseph S. Minner
County Solid Waste Services
County Operations Center MS-0383
5 5 5 5 Overland Avenue
San Diego, CA 92123
With a copy to:
Ofice of the County Counsel
1600 Pacific Highway, Room 355
San Diego, CA 92101-2469
Attention: Diane Bardsley
Notices to the City should be sent to:
City Manager
City of Carlsbad
1200 Carlsbad Village Drive
Carlsbad, CA 92008
With a copy to:
Ron Ball, City Attorney
1200 Carlsbad Village Drive
Carlsbad, CA. 92008
Notices to Coast should be sent to:
Conrad Pawelski, President
Coast Waste Management, Inc.
5960 El Camino Real
Carlsbad, CA 92009
With a copy to:
White & Bright
355 W. Grand, Suite 2
Escondido, California 92025
Attention: Bruce White, Esq.
20 F:\CLIENTS\CITCAD\COASTWS~NW~C~C~.337
FINAL SETTLEMENT AGREEMENT
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Any party may change the person and/or the address to which notice to it shall be provided by
giving written notice to each of the other parties.
VII.
MISCELLANEOUS
A. Dismted Claims.
This Agreement represents the settlement of disputed claims and does not represent any
admission of liability on the part of any party, each of which expressly denies any liability or
responsibility.
B. Governing Law.
This Agreement has been negotiated and entered into in the County of San Diego, State o
California, and shall be governed by, construed and enforced in accordance with the internal laws
of the State of California, applied to contracts made in California by California domiciliaries to be
wholly performed in California.
C. Waiver and Amendment.
No breach of any provision hereof can be waived unless in writing. Waiver of any one
breach of any provision hereof shall not be deemed to be a waiver of any other breach of the Sam
or other provisions hereof. This Agreement may be amended only by a written agreement
executed by the parties-in-interest at the time of the modification.
D. Entire Agreement.
This Agreement, its exhibits, and the Leases into which the parties intend to enter as
provided in Section IV above, constitutes the entire agreement between the Parties hereto
pertaining to the subject matter hereof, hlly supersedes any and all prior understandings,
representations, warranties and agreements between the Parties hereto, or any of them, pertainin#
21 . F:\CLIENTS\CITCAD\COASTWST\DOCUMENnCTTCA6.337 F'INAL SETTLEMENT AGREEMEhT
0 0
to the subject matter hereof, and may be modified only by written agreement signed by all of the
Parties hereto.
E. Independent Advice of Counsel.
Each party to this Agreement represents that in executing this Agreement it relies solely
upon its own judgment, belief and knowledge, and the advice and recommendations of its own
independently selected counsel, concerning the nature, extent and duration of its rights and claims
and that it has not been influenced by any other party.
F. Voluntary Agreement.
Each party to this Agreement firther represents that it has carefklly read this Agreement,
understands its contents, and signs it freely and voluntarily.
G. Severabilitv.
If any provision or any part of any provision of this Agreement shall for any reason be helc
to be invalid, unenforceable or contrary to public policy or any law, then the parties shall meet and
confer in good faith in an effort to determine whether the Agreement and/or the Leases should
continue.
H. Attorneys’ Fees and Costs.
The parties hereto acknowledge and agree that each shall bear its own costs, expenses,
and attorneys’ fees arising out of or connected with the Action, the negotiation, drafting,
execution and enforcement of this Agreement, and all matters arising out of or connected
therewith, provided, however, that nothing herein shall supersede or replace the agreement
between Coast and Carlsbad with respect to reimbursement of fees and costs.
Ill
Iff
22 F:\CLLENTS\ClTCAD\COASTWST\DOCUMEhT!ClTCAD6.337
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I. Binding Effect.
This Agreement shall be binding upon and inure to the benefit of the parties, and their
respective heirs, executors, administrators, trustors, trustees, beneficiaries, predecessors,
successors, members, assigns, affiliates, partners, partnerships, parents, subsidiaries, and any
related entities, officers, directors, principals, agents, servants, employees, representatives, and all
firms, associations and/or corporations connected with each of them, including without
limitation, their respective insurers, sureties, attorneys, consultants, and experts. It is expressly
agreed that should the County sell or otherwise transfer some or all of the assets of its solid waste
system that the obligations of this Agreement shall be binding on any such successor to the
County’s interest to the full extent necessary to honor the terms and provisions hereof,
J. Warrantv of Authorized Signatures.
Each of the signatories hereto warrants and represents that he or she is competent and
authorized to enter into this Agreement on behalf of the party from whom he or she purports to
sign.
K. Recording.
The parties agree that this Agreement or an abstract thereof shall be recorded in the
Ofice of the County Recorder of San Diego, California on each of the parcels which comprise thc
Facility.
L. No Assignment of Claims.
Each party has not assigned, transferred, or granted, or purported to assign, transfer or
grant, any of the claims, demands, and causes of action disposed of by this Agreement.
/I/
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23 F\CJJENTS\CITCAD\COASTWSTIDOCUh4E~CITCAD6.337 FINAL SETTLEMENT AGREEMENT
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M. Counterparts.
This Agreement may be executed in two or more counterparts, each of which will be an
original, but all of which shall constitute one and the same instrument.
N. Assignabilitv.
The parties acknowledge that the County is considering whether to sell the landfills and
related solid waste disposal or processing components it owns. The parties hrther acknowledge
that the interest of the County Solid Waste Services in the Leases is an integral part of the
County’s solid waste system. Accordingly, the parties agree that the County Solid Waste
Services’ interest in the Leases, or any part thereof, may be assigned at the sole option of the
County to any such transferee(s), who will be bound by the terms and conditions of the Leases
and by this Agreement.
0. Dispute Resolution: Breach.
1. Dispute Resolution. Any dispute arising out of, or related to, this
Agreement shall be handled as follows:
(a) Meet and Confer: Step one in the dispute resolution process shall
be an informal meet and confer session at which the Parties discuss the dispute or problem. Any
Party to this Agreement may initiate the step one meet and confer process by giving written notice
thereof to the other Parties. The Parties shall conduct at least one meet and confer session within
30 calendar days of the date of mailing of the notice, or at such other time as the Parties may
agree. The meet and confer session may be continued, and additional meet and confer sessions
may be held, upon the agreement of all Parties.
(b) Other Remedies: The Parties shall retain their full rights to litigate,
at law or in equity, any issue arising out of, or related to, this Agreement, provided that no
24 F:\CLDENTS\ClTCAD\COASTWST\DOCLJME~ClTCAD6.337 FMAL SETTLEMENT AGREEMENT
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litigation shall be commenced until at least one meet and corder session has been held as provided
above. A meet and confer session shall be deemed to have been held in the event that a Party
gives notice of a meet and confer session and one or more of the other Parties fails to attend at
least one meet and confer session within the 30 day period.
2. Breach. Any breach of the terms of the Lease or the Sublease shall be
considered a breach of this Agreement, and any breach of this Agreement shall be considered a
breach of the Lease, the Sublease, or the Leases as the case may be.
(a) Notice of Alleged Breach: In the event that one or more Parties
believes that another Party or Parties has breached the terms of the Lease, the Sublease, or this
Agreement, that Party shall give notice of the alleged breach, explaining the nature of the alleged
breach and describing what the Party believes is reasonably required to cure the alleged breach.
(b) Right to Cure: Upon receipt of a notice of alleged breach, any Part:,
shall have the right to cure the alleged breach within 30 calendar days of the date of mailing of the
notice of alleged breach. In the event that the cure cannot reasonably be accomplished within said
30 day period, then the Party attempting to cure shall present evidence within said 30 day period
of its reasonable good faith progress towards cure, together with a proposed deadline by which
the cure will be completed. The proposed deadline shall in no event be later than 6 months from
the date of mailing of the notice of alleged breach, unless agreed otherwise by all Parties.
(c) Uncorrected Material Breach: With respect to any material breach
which is not cured within the time limits provided above, the Parties shall be entitled to
appropriate remedies at law or in equity as may be determined by a court of competent
jurisdiction, in addition to any specific remedies that may be stated herein or in the Lease or
Sublease. In the event that a dispute arises under this subparagraph O(2) as to whether or not an
25 F:\CLIENTS\CITCAD\COASTWSTU)OCUMENnCITCA6.337 m\JAL SETTLEMENT AGFSEMEhT
a 0
alleged notice of breach was appropriately given, whether the time requirements have been met,
whether the cure has been effective, or with respect to any other aspect of implementation of
these breach and cure provisions, the Parties shall utilize the dispute resolution process set forth
above in Section O( 1) prior to invoking any litigation remedy.
P. Dismissal of Litigation.
The Parties shall execute appropriate documents to dismiss, with prejudice, the litigation
referred to in Paragraph I(B)(l) of this Agreement and to report to the court that the prior interir
settlement has been converted to this permanent settlement. Notwithstanding, and if the Court is
willing and has jurisdiction to do so, the Parties shall request that the Court, with the Honorable
Magistrate Judge‘Louis Porter assigned, retain jurisdiction to mediate any disputes that may arise
under this Agreement and to enforce this Agreement as may be required.
Q.
No change in operator of the Facility and no assignment or transfer of Coast’s rights undei
this Agreement or under its Sublease shall be effective unless Coast first receives approval thereof
from the City of Carlsbad. Carlsbad shall not unreasonably withhold its approval and shall
consider the following factors in reviewing any proposed change in Facility operator or any
assignment or transfer of Coast’s rights under this Agreement or under the Sublease:
Change in Operator: Successors and Assigns to Coast; Approval.
1. The financial status and strength of the proposed successor/new operator,
to ensure that the proposed new operator or successor is at least as financially stable and
responsible as Coast was at the time this Agreement or the Sublease was executed and has the
ability to financially perform the obligations of this Agreement and of the Sublease.
2. The skill and experience of the proposed successor or new operator, to
ensure that the proposed successorloperator is at least as skilled and experienced as Coast was at
26 F\CLIENTS\CITCAD\COASTWSTlDOCW~ClTCAIX.337 FINAL SElTLEMENT AGREEMENT
9 0 0
the time this Agreement was executed and is fklly capable of (a) complying with this Agreement
and the Sublease; (b) complying with all applicable rules and regulations governing Facility
operations; and (c) has the skill and experience to provide high quality service into the fbture in
light of changing regulatory requirements.
3. The background and reputation of the proposed successor or new
operator, including background checks on key personnel, to ensure that the proposed successor
or new operator has a good reputation with respect to its other customers and service operations
and can demonstrate that it will provide reliable, high quality service as successor to Coast or as
Operator of the Facility.
4. The personnel and resources that the proposed successor or new operator
is prepared to commit to Facility operations in becoming the new Facility operator or successor t
Coast, including the management and operations personnel that will be assigned to the Facility,
their backgrounds, reliability, and skill.
5. The ability of the proposed successor or new operator to give local,
personalized service, including the ability of its local operations personnel to make decisions,
access resources from the company, and otherwise efficiently and effectively assume Coast’s role
or become the new Facility Operator and to provide local control and responsiveness comparabk
to that provided by Coast.
6. The ability and commitment of the proposed successor to abide by any
Operations Agreement governing the Facility operations and to abide by the permit conditions ar
restrictions, and City Code requirements, applicable to Facility operations.
27 F:\CLIENTS\CITCAD\COASTWS~KW~CITCAD6.337
FINAL SETTLEMENT AGREEMENT
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7. Such other factors as Carlsbad shall deem relevant at the time in order to
ensure that, overall, the proposed new Facility Operator or successor to Coast will perform this
Agreement and the Sublease at least as well as Coast.
8. Any requirements of the Lease and Sublease applicable to a proposed
assignment of the Sublease by Coast.
“Change of Operator of the Facility” or “Transfer or Assignment” for purposes of
triggering the approval requirements of this Paragraph Q shall include:
1. Any proposed voluntary assignment by Coast of its rights under this
Agreement andlor of its rights under the Sublease;
2. Any involuntary assignment of Coast’s rights under this Agreement and/or
under the Sublease by operation of law such as through foreclosure, bankruptcy, insolvency, or
other operation of law;
3. Any proposed merger of Coast with another entity wherein the other entity
assumes effective control of Coast’s affairs as they relate to this Agreement and the Sublease,
including any merger whereby Coast’s current shareholders do not retain majority voting rights
and decision-making authority with respect to this Agreement and the Sublease;
4. Any proposed sale, exchange, or other transfer of more than 50 percent of
the ownership/shares of stock in Coast to another person or entity; and
5. Any other agreement proposed to be entered into by Coast that would have
the effect of transferring control and decision making authority with respect to performance of
this Agreement and/or the Sublease by Coast to another person or entity during the period of this
ill
28 F:\CLlEhTS\CITCAD\COASTWSTlDOCUh‘fENl-lCITCAD6.337
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Agreement or the Sublease, such as an operations contract with a third party or other contractual
arrangement effectively transferring responsibility for Facility operations.
IN WITNESS WHEREOF, the parties hereto have executed this Agreement as of the datc
and year first noted above.
Dated: CITY OF CARSLBAD
By:
Claude E. Lewis, Mayor
Dated: COUNTY OF SAN DEGO
By:
Thomas Pastuszka, Clerk of the
Board of Supervisors
Dated: COAST WASTE MANAGEMENT, INC.
By:
Arie DeJong, President
29 F.\CLIENTS\CITCAD\COASTWST\DOCUMENTCITCAD6 337
FINAL SETTLEMENT AGREEMENT