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OFFICE OF THE CLFY ATTORNEY
MEMORANDUM ~
TO: Rick Svehla, Deputy City Manager
FROM. Joe D. Morris, Assistant City Attorney
\ SUBJECT: Inlet Structure at Truman Harp Residence i
X111 DATE: October 30, 1990
We have received you memorandum of October 19, 1990 regarding Mr.
Harp's proposal to maka use of the drainage flume to access the
! back of his lot by placing grates over the inlet structure. The
grates would be placed and removed by Mr. Harp at his convenience.
You ask us to address any liability issues that we foresee in
allowing the use.
You indicate that the grates will not obstruct the street, but may
cause flooding if left in place during heavy rain. You also
believe that it is possible someone may accidentally drive up on
the inlet structure if the barricade is removed. Assuming these
possibilities, there are two potential areas of liability that we
would be concerned about.
First, if flooding occurs because of Mr. Harp's failure to remove
the grates during heavy rains, the city could be held liable for a
"damaging" of private property under the Texas Constitution. This
is so because the City's duty to maintain its streets and drainage
facilities is a nondelegable duty. The fact that the City relies
on a private person to perform an act concerning a public function
i does not relieve the City of liablity if the person fails to per-
form and a third party is injured as a resuit.
The second pos'eibility you foresee is that someone could run up
onto the inlet if the present barricade is removed to allow for the
use of the grates. The City's duty to maintain safe streets is not
limited to the travelled portion of the street. It also includes
any hazard or dangerous condition in close proximity to the street
co that it is foreseeable that someone may be injured by the con-
dition in the ordinary use of the street. If it is foreseeable
that someone may mistake the flume for a alley or public drive and
suffer personal injury, the City could be held liable for those
injuries.
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Rick Svehla
October 30, 1990
Page 2
If you have any questions or co=ents about this matter, please
call at your convenience.
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l J p. Norris
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inletstroctober 30, 1990
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W YeI DENWN, TEXAS MUNICIPAL BUILDING / DENTON, TEXAS 78201 / TELEPHONE (817) 586.8307
Office of the City Manager
M E M O R A H D U H
TO: Debra Drayovitch, City Attorney
FRO:l: Rick Svehla, Deputy City Manager
DATE: October 19, 1990
SUBJECT: Inlet Structure at the Truman Harp Residence at
2401 Robinwood
f Within the last week, Mr. Harp has again approached us with his
proposal to solve an access problem througi. our drainage
easement in his back and side yard. As you know, the problem
began in 1988 when we were rebuilding Glenwood and the
Mistywood drainage system in Mr. Harp's area. Mr. Harp's lot
contained a ten foot drainage easement that conveyed water from
the area and street in back of Mr. Harp's lot to Robinwood. We
i laid pipe under Robinwood which culminated in an inlet in this
f easement.
The problem for Mr. Harp and the city revolved around u3
needing to build an inlet at the junction of the drainage
easement and the street. Some time earlier than 1973, a flume
was built in the approximate location of this easement along
the southern boundary of Hr. Harp's property. It appears that
when that flume was built a turn out was made from it to allow
access to the backyard of the Harp residence. Thus, over the
years, Mr. Harp used this drainage flume as a second driveway
' to gain access to his backyard.
When the project began, we approached Mr. Harp to look for
alternatives to this access since there was a need for us to
build an inlet. We had already looked at building an
underground pipe along this easement and catching the water at
the backside of tor. Harp's lot. This alternative was rejected
since the cost would have been approximately $35,000. Instead,
we had talked to Mr. Harp's neighbor's that adjoined him at the
rear of his property about accessing Mr. Harp's property
through the easement that existed on the lot adjacent to the
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Debra Drayovitch
October 19, 1990
Page 2
back of Mr. Harp's property, end we had also suggested an
option to access the property on the north side of Mr. Harp's
house. Mr. Harp rejected both of those scenarios and said the
only way that he wanted access to his backyard was through the
existing flume.
We then looked at an alternative which would have built a new
drive access north of the existing drainage easement which
would have connected to the existing drainage easement/flume
and allowed Mr. Harp to access his property in that direction.
Mr. Harp also rejected that scenario, By this time, Mr. Harp
was threatening legal action so we took the item to Council in i
Executive Session to ask for guidance. At that time. Council
felt that Mr. Harp was being unreasonable since he had rejected
all of the alternatives and maintained that his only choice was
the existing flume. This access would have cost approximately
=35,000 as mentioned earlier. It should be pointed out that
the alternatives ranged in cost from $800 to $2,000 - $3,000.
The Council reviewed the situation. Since the existing
easement met the street, it was determined that there would be
j no problem in building the inlet. and since Mr. Harp was not
agreeable to any of the alternatives. Council decided to just
move ahead with the inlet and still offer funding up to a
$1,000 for an alternative if Mr. Harp wanted to pursue that.
We conveyed that to Mr. Harp. He did not want to pursue any of
the options and said he would be seeking an attorney.
Since that time, Mr. Harp has periodically come back to ask if
there was another way or if wa could do other kinds of
activities. in fact, we again went back to the Council to ask
about alternative plans where we would have built a grate inlet
along the existing drainage easement at a cost of $12,000 -
$14,000 that would allow Mr. Harp to have access. The Council
said that they would he agreeable to having those grates built
if Mr. Harp wanted to provide the difference in cost between
our alternates and his. Again, he declined.
After that, he contacted us about his contention that the
drainage easement was actually on the southern ten feet of his
lot and indeed the flume had been moved northward from the
property line approximately four feet, In fact, the easement
is along the southern boundary of the property and indeed the
flume does extend past the easement onto Mr. Harp's property
for two to four feet. It is my understanding that Mr. Harp was
advised by the Legal Department that if he wanted to remove
several feet of the flume that was certainly agreeable to us.
We think the flume was built on a handshake deal between
someone in the city and a previous owner somatime prior to
1973. The reason we say that is because there is a line
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Debra Drayovitch
October 19, 1990
Page 3
of trees along the south boundary line of Mr. Harp's property,
and it looku like the flume was moved to accommodate leaving
the trees upon the agreement of the landowner and the city. We
have no documentation of this only that the flume was built in
one piece and does not look like there have been any changes
made to it.
In the last several months. Mr. Harp has again contacted us
about a new design that he wanted to propose for the flume and
the inlet. He advised us that he would be sending the plan.
He did this by notifying the City Manager. i,loyd conveyed that
message to me. I waited approximately two months for the plan
and did not receive it. About a month ago. Mr. Harp came in
and asked if we had received the plan. I told him that we had
not. He advised that he had sent it in the mail and that he
had cn engineering firm here in town do the plan. I said that
I had not received it, and I would be happy to talk to the J
engineer that drew the plans and get new copy. He advised me 1
that Mr. Russell Bates of the Architectural Collective had
drawn a pair of "grates" to allow vehicular traffic to ramp up ;
over and back dow:: across the inlet. I contacted Mr. Bates at
the Architectural Cbllective: he advised me that he had not had
any contact with Mr. Harp and did not know of any plans or
conversations to build or design the grates. I contacted
Mr. Harp. He said he would be in with drawings and
consequently, about ten days ago, brought me a drawing which
appeared to be draftctd by him.
Essentially, the "grates" , ld very similar to a cattle guard
crossing. They would fit ra., top of the inlet and in the flume
itself or on top of the inlet and the gutter line of the curb
and allow vehicles to cross over the top of the inlet. The
problem with these structures is the same as the grates. The
do not allow very much water to flow through there. In fact.
our engineering Department has done calculations based on the
openings in the. drawings that Mr. Harp provided, and the
"grates" will allow approximately only 30% - 35% of the water
that is now going into the inlet to get into the inlet.
Therefore, the structure will not take near is much water as it
was initially designed for and there would be further flooding
in the street. The second problem we have with the "grates" is
the fact that they would then allow vehicular traffic on top of
the inles:. The tops of the inlets are only four inches thick.
This particular inlet happens to be ten foot long, and this
type of inlet design is not used in any load bearing type of
application where vehicular traffic would be traveling across
the top of the inlet, i.e. we doubt seriously the inlet would
be able to handle repeated vehicular traffic over the top of it
without collapsing.
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Debra D[ayovitch
O-Lobe[ 19, 1990
' page 4
to contat M[. Harp for the last well days our
c
I have attempted
advise hies of the results Of the calculations sinlet. I was
concern about the vehf4:30np.m. today. Mr. Harp was
able to 8o that at approximately
During upset about our concerns and advandd wehwould Da ssorty, up with
us." we were "breaking the law."
ieldicated that the "o:otes° would
the conve[sa . Mt. wHarp ould
only De temporary. He would put they in and take thcm out Only howe when accessing his backyard.
umbersome. Also.d we •s illvhaveer.
would be quite heavy and c
problem of traffic on top of the inlet. My first reaction to
'check
this was to check the design
question hwas n ift the sthe 1 inlet cot
carat traffiu- MY first 9 ord "grates" colollapse, who would be
the liabile, guard railn in Mfr nt oft the
accommodate this entrance. if the q
inlet (street andihetsithe einlet, who is liable nteFinallyflifethe
turn around g left in the inlet and it rained and
rates were inadvertently
flooding resulted. who would be liable. anticipate is
As I understand it, the Council did not want to p
any options other than the initial sooffers lution.t it might work.
However, since this is a temporary and how the Council
please advise roceedtbeforeb wet contact Mr. Harp with the final
pr
wishes us to
? answer,.
Rick 4ehl
Deputy city Manager
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INDUSTRIAL CONSTRUCTORS, INC. ""^MO w
121 Exposition Street cAwuu*ce Ir oAn
DENTON, TEXAS 76205
(817) 666.1899 e»rt.lo sr Del
FAX (817) 8981096
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CiTY w DENTON / 215 E. McKinney / Denson, Texas 76201
M E M O R A N D U M
T0: Catherine Tuck, Administrative Assistant
fRCf•1: Bill Angelo, Director of C i,-m sty Services
DATE: Septarber 4, 1990
SUBJECT: TRLMAN HARP COMPLAINT
A
I have attached fur your review Information related to solid waste
billing and a subsequent complaint from Mr. Truran Harp of 2401 Robin-
wood. Mr. Harp has discussed his concerns with Charlie Watkins and
m7self and is still unhappy with the bill he received for solid waste
service. In his last conversation with me, he stated he would be taking
this natter up with the City Manager.
In his complaint Mr. Harp made several allegations regarding the City's
Commercial Solid Waste Division, the most significant of which involved
his claim that he was quoted a much lower price for service than he was
charged. I have investigated each of his allegations and have found no
validity to his claims.
I Should you have any questions or camrents on this matter, please let ex;
know.
BiII Angelo
BA/sc
IAl/090490051
Attachments
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CITY of OIFNTON / 215 E. McKinney Dent°n, texas 16201
MEMORANDUM
i
ltY Services
8111 Angelo, Director of ComT'
T0: '
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Solid Wash Dlvts I
FROM: Charles Watkins, Superintendent,
DATE: August 31, 1990 ~I
SUBJECT: COMPLAINT FROM MR. TRl1MAN HARP i
s calCustomer Service this week relative to a biding can
Customer -
1 received
plaint from Mr. Truman Haro fora 30 cubic yard container
states that he was quoted $50 per t-"S'~Y b erf tlw cc to r~~' r'dS
Mr. Harp rs~ wi~'came y v~h
vhlchl he rented from the Litt by the p-
dell ~Od.- 410 spoke with Mr. Harp.
+ the person
:n._.;. fee, a
::r n+isor, del ier
Vince GaIIegos + Comnerclal Supe There Is a 554 container
said he Quoted the rates carrecar9
Vince of $152.70 each time the
552.50-eental fee per 30 days and
is emptied. n the container eras emptied
`
le present whe the name of Mr. Kam
Mr. Harp said there were oter ~tpeoP station. I obtained Bonam said he did l 4.1one. Mr. w1w could verify the $50 per vine
y~ was present and spoke to him over and Vince Ivit that athed use of
Bowen between Mr. harp he was considering t. ctnveton not hear the cost t sampt the container because n' approximately 5150.00 per emp
y
how much it cost to empty da15 I felt it was was one himself. Ve said vl ce OihehCam TSmer l rates every
Inasmuch as Vince with
especially after talking to Mr. Ba+en•
unlikely he misquoted, standing of chat the
1 Informed Mr. Harp that 1 was sorry there was a misunder declined to authorized
charges vpere but that I felt the charges were fair and
changing the bill.
Charles S. WaLklns
CSWIsc
1W2/083190010
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• INVOICEREQUISMON Copy
BILL TO'
TRIJ~AN WP 1630-6402 ~w r,ooo~~Mr Mr~
2401 RO KY00b $551.16 Amomml
TEXAS 76201 CUT CITY SERVICES/SOLID WASTE
osm
DENTON
JUNE 7 1990
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RENTAL FOP. (1) 30 YARD GPEN TOP: $ 7.00
f 4 DAYS a $1.75 ?ER DAY
50.00
DELIVERY CHARGE
CHARGES FOR EMPTYING OPEN TOP CONTAINER AS NEEDED: 151.70
6-1-90 152.70
6-1-90 .152.70
6-4-y0
SUB-TOTAL $515.10
7% TAX 36.06
1
$551.16
TOTAL
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TMC ABOVE HAS BEEN REVIEWED AND REWMMENDAT10N FOR BIUJNO IS MADE BY THE INIDERSH3NED.
lgMA11MK - II
Acoou~n+a APMOVU I
UT1' AMI~DVAL DIIlCMM OP P MCE APPMVAI _
YAM/OM
151/060190090/7
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CC AIMERCIAL COMMEACIAL
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PERSON RECEMNOCALL -5~"~gk_ PEI SONREVEMNOCALL •-C4
SERVICE AEOUESTEO BY: , SdF nESTEO BY: 1
NAME C~ PHONE LS_~ n y(j X. PHONE
SYrh 'ca
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ADDRESS D /tti~J DATE AODR iSS DATE-V
BILLFNO ADDRESS BILLIN 3 ADDRESS
TYPE SERVICERECO)CSTED: CCHECKONE) TV FES,R)LEAEOUESTED: tCHEC of 0,4E)
NEW SEFMCC -.-__CANCELLAPON NEW SERVICE
CANCELlA710N i
I -Eff'sPECLAL MKUP COMPLAINT ---!PECIAL PICKUP COMPLAINT
OTHER
-FNCRlOECR :TREK FIfCNOECA
ACCOUNT NUMBER DAYSSERY,CED I - AC"O'JNT l,KR f1 DAYSSEMICfO
TYPE CONTAtkER COYTAINfR NO. _ f 1'(PE CONTA).,Wi UST, CONTAINER NO.
MONTHLY CHARGE DELY:RYClFG. f"THLYCHA,IGE____+ DEUVSRYClFG, O, ~T
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NO.TWESWKSERv. I 2.3 1 S !3 'S"ECIALCHO. ~ 2~_-~ 11O.TWESMSEPV 1 Z 3 55 I -WECI ALC YS-
CUST.WIGNATUAE rEtocAil IWST.5K7NATURE Rac"rE -
DATE SERVICE RENDEREDANDjDRCCRR90TEL CAA!ESER'/ICfIiENDEffOANO/JRCOfgiECTED__"
COMMF,NTS:AND/OR OTHER Ti'; N: CO EIITS ANp/Or, OTHER IMF OAK rITKN1: y
SUPERINTENDEP+TAPPROV - it SU'ERNTENDENT APPAOV
DA E DATF _
FOREMAN'S SIONATUrtE Llrcu 'I FG EMAKS SMNATUFIE r~
GATE I-_ CIA FIE -jg!
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' COMMERCIAL
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PERSON RoiCEMHG CALL .~L.
SERVICER30UESTE08Y: _~D J/// l
PHONE 7(~ V
NAME
SERVICE
ADDRESS DATE {P I
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i &LItNOACDRESS
TYPE SERV CE REOUESTED. ICHECKONEI /
YEW SERVICE CA.VCELLAT*N
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_SPECIAL PICKUP` COMPLAINT
E
OTHER tN--R1DECA
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I{ ;ZCOVNT NyMAER DAYS SERVICED
TYPE OONTAJNER • COHTAWER W.
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MONTHLY CHAAGE pEL.NERY C?IQ yj.
f NO.TIMESWKSERV. 2 3 S S Q. •SKCULLCHQ 2~
~~TLRAE RELOCATE
I DATE SEPMERENDERED ANDfORCORRECTED
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COMMEN'S.- AND/OR OTHER INFORMATPOW
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SUPS Al NISN DENT APPROVAL I_ DATE I
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!234L
NO. C%0- 00~
AN ORDINANCE OF THE CITY OF DENTON ESTABLISHT.NG RATES FOR ,
RESIDENTIAL AND COMMERCIAL SANITATIM COLLECTION SERVICES AS
AUTHORIZED BY CHAPTER 12 OF 7AE CODE OF ORDINANCES OF THE CITY OF
pKy'TON; AND PROVIDING FOR AN EFFECTIVE DATE. I
THE COUNCIL OF THE CITY CF DENTON HEREBY ORDAINS:
SECTION I. that the charges for reaidential garbage collection
sarv cee as authorized by Section 12-19(b) of Article II of
Chapter 12 of the Code of Ordinances is hereby established in the
amount of Nine Dollars and 39/100 (=9.39) fcr each individual
family unit for a thirty day period.
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SECTION II. 1h3t the charges for commercial and institutional
garbage co ection services, established to accorda-ace with
Section 12-20 of Article III of Chapter 12 of the Code of
Ordinances, are hereby amended as follows:
A. DUHPS7fR5
Cubte Yards Kate
Collected Per Week Per 30 Days
1-3 e.42
4-6 6.53
7-10 6.28
11-25 6.15
26-50 6.10
51-100 5.93
101-125 5.68
126-150 5.59
151-175 5.33
176 or more 15.16
B. OPEN TOP CONTAINERS AND COMPACTORS
Type of Rent
Container Per 30 Days Service Charge
20 cubic yard open top 39.53 5.09 per cubic yard
30 cubic yard open top 52.50 5.09 per cubic yard
40 cubic yard open top 57.75 5.09 per cubic yard
12 cubic yard compactor " 87.15 5.09 per cubic yard
15 cubic yard compactor 89.25 5.09 per cubic yard
20 cubic yard compactor 115.50 5.09 per cubic yard
25 cubic yard compactor 115.50 5.09 per cubic yard
30 cubic yard compactor 157.50 5.09 per cubic yard
42 cubic yard compactor 1176.40 15,09 per cubic yard
l►
newecustomersefor open00topecontainersrandlc mpactors. to all
SECTION III That this ordinance shall become effective
.
imme ate y upon its passage and approval.
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PASSED AND APPROVED this the day of 1990.
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ATTEST: -
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APPROVED AS TO LEGAL FORM:
DEBRA ADAMI. DRAYOVITCHs CITY ATTORNEY
8Y: 1
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C044FRCIAL "ROLL-OFF" RATES
1990
EFFECTIVE JANUARY 2, 1990
A $50.00 delivery fce is to be charged to all new customers.
OPEN TOP RENT COST
CONTAINERS PER 30 DAYS PER PULL
20 cu. yd. $ 39.53 $101.80
30 cu. yd. 52.50'. 152.70
+ 40 cu. yd. 57.75 203.60
RENT COST
COMPACTORS PER 30 DAYS PER PULL
12 cu. yd. $ 87.15 $ 61.08
15 cu. yd. 89.25 76.35
20 cu. yd. 115.50 101.80
25 cu. yd. 115.50 127.25
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30 cu. yd. 157.50 152.70
42 cu. yd. 176.40 213.78
(Cost per pull = $5.09 x c/y size)
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1ST2S99316 (Rev. 1/2/90)