HomeMy WebLinkAboutItem 7.9 Annexation of Camp Parks 1
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CITY OF DUBLIN
AGENDA STATEMENT
CITY COUNCIL MEETING DATE: October 8, 1984
SUBJECT Annexation of Camp Parks
EXHIBITS ATTACHED Memorandum dated May 29 , 1984 ; Agenda Statement dated
August 13 , 1984 ; Map of 150 acres to be surplused will
be available at City Council meeting
RECOMMENDATION Consider options and direct Staff to take appropriate
action
FINANCIAL STATEMENT: Undetermined
DESCRIPTION At the City Council meeting of August 13 , 1984 , the
City Council authorized the Mayor , City Manager and City Attorney to meet
with representatives from the Army and Federal Government to discuss the
potential annexation of Camp Parks . On September 11, 1984 , representatives
from the City met with representatives from the Department of the Army.
At that meeting, the City representatives explained the City' s goals with
respect to future growth and the need t.o not . only annex either all or a
portion of the Camp Parks property to the City of Dublin, but also to obtain
an access to construct a highway to the east through the Camp Parks
property. At that meeting, the Army representatives provided the City with
the following information:
1 . The Army representatives indicated that the southernmost 150 acres of
the Camp Parks property was in the process of being transferred to the
General Services Agency (GSA) which will be responsible for its disposal .
2 . Other lands on the Camp Parks site were presently being utilized and
were under the control of the Department of Justice and the National
Aeronautics and Space Administration ( NASA) . The Army representatives
indicated that the City should contact these other Federal agencies
directly.
3 . The City should initiate its request to annex lands under the control of
these Federal agencies by submitting a formal request to each agency. That
request should precisely identify the area which the City wishes to annex
and should also include a request for an easement to construct a public
roadway.
4 . The Army representatives indicated that the request to the Army should
be addressed initially to the Acting Commandant, Captain Wright at Camp
Parks Reserve Forces Training Area . Captain Wright would then forward the
City ' s request to the Presidio .
5 . The request to annex the 150 acres which is presently in transition from
the Army to GSA would be forwarded by the Army to GSA.
6 . The representatives from the Army also indicated that the Army was
looking at removing its exclusive jurisdiction at various bases throughout
the country. This would have an impact on local agencies which annexed or
had Army bases within their jurisdictions by requiring the local agency to
provide certain municipal services to that Army base where the exclusive
jurisdiction had been removed. At this time, the Army still has exclusive
jurisdiction for those services which the City would provide over the Camp
Parks base .
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COPIES TO: Captain Wright , Camp Parks
ITEM NO. 19
AGENDA STATEMENT; Annexation of Camp Parks
Page 2
ANNEXATION ALTERNATIVES
It appears that there are 2 basic alternatives which the City Council could
consider with respect to the amount of territory that it may wish to annex
to the City. The first alternative would be to annex the entire portion of
the Camp Parks base which is within Alameda County. The second alternative
would be to annex only the southernmost 150 acres of the Camp Parks site
which is presently being transferred to GSA.
If the City Council decides to pursue the first alternative, there is a
possibility that the City may have to provide services to the Camp Parks
facility should the Army remove its exclusive jurisdiction over that site.
The cost of providing those services is unknown at this time. However, the
annexation of the entire Camp Parks site is a much more comprehensive
approach in moving towards the City ' s ultimate sphere of influence
boundaries . This approach may also be much more expeditious in .getting more
territory within the City ' s jurisdiction, if the Army concurs with the
annexation. This is the case because the Army controls more than 750 of the
land within the proposed annexation area .
It is Staff ' s recommendation that the City Council identify which
alternative it wishes to pursue, and direct Staff to prepare a letter for
the Mayor ' s signature to the various Federal agencies involved requesting
their consideration of the City ' s annexation request . Upon receiving a
response from the Army, it is Staff ' s recommendation that the City Council
adopt a resolution petitioning LAFCO to annex the property to the City.
CITY OF DUBLIN
P.O. Box 2340
Dublin, CA 94568 (415) 829-4600
May 29, 1984
TO: City Manager
FROM: Michael R. Nave, City Attorney
RE: Annexation of .Camp Parks
You have asked whether the City can annex Camp Parks,
which is federally owned land, without the consent or approval
of the Federal Government. In my opinion the City can annex
Federal land without approval of the Federal government.
I. PROCEDURE FOR. ANNEXATION
The annexation of territory to Dublin would proceed
under MORGA (the Municipal Organization Act of 1977) , Government
Code §350.00 . et.,seg.
The procedure under MORGA for annexation of
unincorporated territory differs slightly depending on whether
the territory is inhabited (12 or more registered voters) or
uninhabited (fewer than 12 registered voters) . I will briefly
outline the procedure for an inhabited annexation and, where
relevant, point out the differences with respect to an
uninhabited annexation.
Annexation can be initiated by petition signed by
registered voters or landowners or by resolution of the City
Council (government—Code—S35100) . The resolution must contain
a plan for services (53,510 2) , including the services to be
extended, improvements to be made and financing thereof.
Revenue—and-Taxation. Co.de. 522.(b) requires the City and County to
agree to an exchange of property tax revenues prior to any
jurisdictional change, such as annexation. In addition
Californ.is ..Constitution .Art_icle. ,13B (Gann Initiative) requires
the City and the County to agree on a transfer of appropriate
tax limitations. These agreements must be reached before LAFCO
will proceed.
Once agreement on tax proceeds and limitations has
been reached, LAFCO then examines the petition or resolution for
sufficiency and, if sufficient, schedules a hearing. After the
hearing, LAFCO determines whether territory is inhabited or
uninhabited and, if it approves the annexation, designates the
conducting authority which, in this case, should be the City of
f
To: City Manager
From: Michael R. Nave, City Attorney
Re: nnexat.ion .of.,.Camp_Parks
May 29, 1984
Page Two
Dublin (§.�3.515.Q.(,h).,, .,35031) . The annexation of uninhabited
territory can proceed without hearing and election if all
landowners consent (S351.5
After LAFCO designates the City as the conducting
authority,. the City Council must adopt a resolution initiating
the proceedings and set a hearing on the proposed annexation
(53520 ) . At the hearing written protests can be filed. At the
close of the hearing for an jnhab_ited annexation, the Council
must adopt a resolution finding the value of the written
protests, and:
(a) terminate the proceedings if 50% or more of
registered voters protest;
(b) order the territory annexed subject to election
within the affected territory if 25% or more of
registered voters or 25% or more of owners of land
who own 25% or more of assessed value of land
protest; and
(c) order the territory annexed without election if,
neither of the above applies (53522 ) .
For an uninhabited annexation (53522 ) , the Council
must adopt a similar resolution:
(a) terminate the proceedings if protests are filed by
owners of more than 50% of land and improvements
within the territory; or
(b) order the territory annexed if protests are filed
by owners of less than 50% of land and
improvements within the territory.
The election to be called if inhabited territory is
annexed is only within the territory to be annexed unless the
assessed value of land in the territory to be annexed is
one-half (1/2) or more than than the assessed value of land
within the City, or the number of registered voters within the
territory to be annexed is one-half (1/2) or more than the
number of registered voters within the City ( 3� 523.7 ) .
After an election the territory is annexed if a
majority of votes favor annexation.
To: City Manager
From: Michael R. Nave, City Attorney
Re: Annexat, _-n of ,Camp_.,Par,ks
May 29, 1984
Page Three
II. ANNEXATION_._OF„_f Ep,ERAL.__LAND
Federal courts have upheld the annexation by a
municipality of Federal lands. Uoward..v.....Comm�,ss_i.oner.s, (1953) ,
U. S. 624 , 627 , 73 Sup.Ct. 465; Rhyne,
p. 33 . In the lgpwa.r d case, the United States Supreme _Court
upheld the annexation to the City of Louisville, Kentucky, of a
federally owned naval ordnance plant. The Supreme Court noted
that state courts have upheld the right to annex Federal land,
citing decisions by Texas and Virginia courts involving a
military reservation and a navy yard, respectively. More
recently, in gnited States v., ..Cty..of_ ,Bel l.ev.u__ ,._..�Tebraska,
(1971) , 334 F. Supp. 881, the U. S. District Court reaffirmed the
holding of Howard that the City of Bellevue had the power and
authority to annex federally owned land (344 F. Supp. at 884) .
However, because the Federal land involved was an U. S. Air Force
base which was the headquarters of the Strategic Air Command,
and because it was clear from the record that the only reason
the City wished to annex the air force base was to derive more
tax revenue, the court found the purported annexation invalid
under Nebraska law. In so holding the court relied on the
interests of national security and Nebraska law which prohibited
the annexation of territory for revenue purposes only. 334
F.Supp. at 887 . The Supreme Court in Howard did note that
exclusive jurisdiction of the federally owned property still
remains within the United States, except as modified by Federal
statute (344 US at 627 , 73 S.Ct. at 467) .
The question then becomes whether California law
prohibits the annexation of federally owned land or requires
consent of the Federal government for such an annexation. MORGA
contains no prohibition against annexation of property owned by
the Federal government. The Act merely provides that territory
may be annexed if it is located in the same county and is
contiguous to the city (Government Code §35011) . MORGA was
enacted in 1977 ; it replaced a number of annexation acts which
had not been revised for many years. Prior to 1977 , the
annexation laws specifically allowed annexation of territory
owned by a public agency (such as the county) with the consent
of the public agency (former Government Code §35003) .
Annexation of territory owned by the Federal government was also
allowed with the Federal government' s consent (former Government
Code 9§35470 and 3547.1) . It is important to note that the
requirement of county consent (former 535003) was added in 1951
(Stats. 1951, c. 1701) and the requirement of Federal consent to
an annexation was added in 1957 (Stats. 1957 , c. 1844) . Prior
to those dates there was no requirement that consent be obtained
for annexation of county or Federal territory.
l
To: City Manager
From: Michael R. Nave, City Attorney
Re: Annexation of Camp Parks
May 29, 1984
Page Four
In Aqua Caliente Bander Etc. v. City of Palm Springs,
(1972) , 347 F. Supp. 42, vacated and remanded in an unpublished
order on January 24, 1975, the court considered the legality of
including Indian lands within the City of Palm Springs upon its
incorporation. First, the Court noted that ". . . So long as the
law of the state in which the land lies permits the
incorporation or annexation of federally owned land, no Federal
consent is necessary. " (347 F. Supp. at 44 .) The question thus
becomes whether the law of California permits incorporation or
annexaton of Federal land. Although §§35470 and 35471, which
were in effect at the time, required consent of the Federal
government before federally owned land could be annexed, the
Court found that at the time Palm Springs was incorporated in
1938 there was no such requirement (§35470 and 35471 were
enacted in 1957) . The Court concluded that the Indian lands
were legally incorporated into the City of Palm Springs (347
F. Supp. at 46) .
As in the Aqua Caliente case, there is currently no
requirement in MORGA which requires consent for annexation of
federally owned lands. Since there is no statutory prohibition
against annexation of Federal property, the City may annex Camp
Parks pursuant to the statutorily prescribed procedures. This
conclusion is consistent with the Supreme Court' s reasoning that
". . .an annexation should not be declared invalid unless some
express statutory provision has been violated. " People v. City
of Palm Springs, (1958) , 331 P.2d 4, 9 . It must be remembered
that the City, in annexing Camp Parks, may exercise no control
over Federal property which interferes with the superior
authority of the Federal government.
MRN/jm
AGENDA STATEMENT
CITY COUh _ _L MEETING DATE: August 1- , 1984
SUBJECT Annexation of Camp Parks
EXHIBITS ATTACHED Memorandum from City Attorney dated May 29 , 1984
RECOMMENDATION Receive report and direct Staff to take further action
FINANCIAL STATEMENT: None
DESCRIPTION In accordance with the City ' s adopted Sphere of
Influence and the planning which the City Council has undertaken during the
General Plan process for those lands east of the City' s present boundaries,
the City Attorney and Staff have been reviewing those steps which would be
necessary to annex the land presently under the jurisdiction of the Army
( Camp Parks ) to the City of Dublin.
The City Attorney, in his memorandum, has outlined the process which the
City would have to follow if it were to annex the Camp Parks property into
the City of Dublin. The procedure which the City would follow would depend
on whether the annexation was an inhabited annexation or an uninhabited
annexation. Staff has determined through discussions with the County
Registrar of Voters that the Camp Parks property presently has 39 registered
voters living at Camp Parks . Thus , if the City were to annex the entire
Camp Parks property within Alameda County, the City would have to have the
approval of at least 500 of the registered voters living on the property.
If the City pursued an annexation which included only those areas of Camp
Parks that are presently uninhabited, the consent of the property owner
( Federal Government ) would be necessary. .
Staff has had preliminary discussions with the Camp Parks Commandant
regarding the City' s interest and ultimate plans for those lands to the east
of the City ' s present boundaries . - The local Commandant suggested that
representatives from the City meet with the Commandant , Legal Staff from the
Presidio and Army real estate personnel from Sacramento in order to explain
the City ' s goals prior to submitting a formal request to the Army for
annexation.
It is Staff ' s recommendation that the City Council authorize the City
Manager and the City Attorney to meet with representatives from the Army and
Federal Government regarding the City ' s intentions and the potential
annexation of Camp Parks and report back to the City Council regarding the
results of that meeting .