Water System:
Plan of Action for
Completion and Restitution
Jim Davis, October 16, 2001

INTRODUCTION:

Since the installation phase of the water and telephone system ended in the spring of 2000, our contractor, OPEC, has used every opportunity to avoid completion. This process culminated in their notification to the water committee that they were filing an arbitration request to avoid fulfilling their contract. To our knowledge, they have yet to file for arbitration. After separate consultations with independent engineers, an experienced water system contractor, contract attorneys and litigation attorneys over the past two weeks, the Santa Fe Trail Ranch Water Committee makes the following recommendation to the Santa Fe Trail Ranch Metropolitan District Board, and so advises the Santa Fe Trail Ranch POA and its membership.

PLAN OF ACTION:

  1. Immediately commence an independent engineering evaluation of what is necessary to complete the water system, as is, and bring it to the point of operation (final leak testing, sanitization and State Health Department approval). It is recommended that Clyde Young and Associates be engaged for this evaluation, based on their current knowledge of the system, their bid previously received and the recommendation of the Colorado Rural Water Association.
  2. Based on the evaluation, recommendation and specifications of the engineering company, obtain bids from qualified contractors to complete the work required and render the system operational. The resulting completion plan will be based on the factual findings of the third party experts we consult and hire.
  3. Make a determination of the total cost to complete and test the system. Simultaneously research all possible sources of funding for both the completion work and subsequent litigation, should it be warranted.
  4. Develop a time table specific as to when work shall be commenced and completion achieved with the engineer and contractor chosen.
  5. Notify the bonding company, OPEC and its parent company of our findings and intention to proceed with completion of the project and to give them a final opportunity to agree to perform the balance of their responsibilities under the existing contracts and bonds by the same specific date.
  6. Upon determination of whether or not the bonding company and/or OPEC intend to fulfill their respective responsibilities, either initiate a completion agreement with them as an addendum to the original contract or execute a new contract with the chosen bidder to proceed. It is our recommendation, if the original parties do not perform, that the Metropolitan District initiate law suits against OPEC, its parent company, the bonding company and any contributing entities to protect the financial investment of the property owners and recover the costs incurred to complete.
  7. If a new contract is required, submit a recommendation to the Metropolitan District of a plan of financing for the completion of the project. The Metropolitan District will submit a proposal to the POA Board, along with a request for a vote of the membership, if required, for approval of the plan.
  8. If the bonding company and/or OPEC decide to carry out their responsibilities, the completion agreement will commit them to the terms of the original contracts and bonds and require completion by a specified date.