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<br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br /> <br />SHOEMAKER A1\'"D '''TUAM <br />ATTORNEY!:; AT LAW <br />1421 COURT PLACE BUILDING <br />DE~'""ER, OOLORADO 80202 <br /> <br />W. JOSEPH $110EMAI'iER <br />ROBERT S. WHAM <br />EDwARD .J. KRISOR, JR. <br />RICHARD H. HILL. <br /> <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br />I <br /> <br />Mr. Ben Urbonas, P.E. <br />Page Two <br />March 20, 1978 <br /> <br />303_$:34_6386 <br /> <br />March 20, 1978 <br /> <br />Mr. Ben Urbonas, P.E. <br />Urban Drainage and Flood Control District <br />2480 West 26th Avenue. Suite 156-B <br />Denver, Colorado 80211 <br /> <br />Drainage law also generally follows the concept that <br />nature should be allowed to take its own course, and the natural <br />watercourses developed over the years are the best way to carry <br />off surface waters. In Hankins vs. Borland, 163 Colo. 575, <br />431 P.2d 1007, 1010 (1967), the Colorado Supreme Court stated: <br /> <br />Re: <br /> <br />Dry Gulch and North Dry Gulch <br /> <br />"Natural drainage conditions may be <br />altered by an upper proprietor pro- <br />vided the water is not sent down in <br />a manner or quantity to do more harm <br />than formerly." <br /> <br />The reverse is also true. The builder of an "improvement" to the <br />natural watercourse cannot build such an improvement so as to <br />obstruct the natural passage of the water. Further, once a <br />government has involved itself in the construction of drainage and <br />flood control improvements, it must see that such improvements are <br />maintained. <br /> <br />Dear Ben: <br /> <br />W. Joseph Shoemaker has received your letter of February 22, <br />1978, including the above-referenced report, and has requested <br />that I render a legal opinion as to the recommendations contained <br />in the report. I have read the report in its entirety and have <br />viewed the areas in question with you as my guide. As I see the <br />report, it i.s meant to be an engineering and plannin[ approach t.o <br />a particular drainageway in the District, and my comments cont.ained <br />in this letter are meant to raise and cover potential legal issues <br />and should not be interpreted as being critical of the report, nor <br />as substituting my judgment for yours or Sellards & Grigg, Inc. <br /> <br />Finally, on a general note, the least that can be accom- <br />plished by local government is to identify and then regulate the <br />use of the flood plain. So long as good engineering practices are <br />followed, a local government should not be liable because a par- <br />ticular parcel of land was not identified as being in the flood <br />plain. <br /> <br />1. General. <br /> <br />Generally, in my opinion, the City of Lakewood, the City and <br />County of Denver, and the District, who are paying for this report, <br />have no obligation to do anything about the dangerous conditions <br />which now exist, except perhaps to call to the attention of the <br />owners and dwellers in the Basin such conditions. Privat.e parties, <br />for the most part, have created the hazardous and potentially <br />hazardous conditions and in the event. of loss of life or property <br />such persons damaged would have their recourse against the tort <br />feasors. <br /> <br />In reviewing the alternatives discussed in the engi- <br />neer's report and finally the recommended alternatives, I have <br />based my opinions on the legal theory that an alternative is legally <br />acceptable if it does not increase damage from its present level in <br />time, space or amount upstream, downstream, or adjacent to the pro- <br />posed improvement. Of ~ourse, each alternative was looked at and <br />legally evaluated individually and in conjunction with the other <br />alternatives in the other reaches covered in the engineer's report. <br />Therefore, if any alternative or any recommended alternative <br />viewed in conjunction with other alternatives proposed to be <br />constructed increases damage from its present level in time, <br />space or amount upstream, downstream, or adjacent to the pro- <br />posed improvements, then that alternative shall be considered <br />legally unacceptable. <br /> <br />Although government has no obligat.ion to help solve these <br />man-made problems, if, for various reasons it chooses to do so, <br />which is the prerogative of the legislative bodies of each govern- <br />ment, then it must make certain that such assistance is carried out <br />in a non-negligent manner. I do not believe the law r~es local <br />governments to prevent or even solve drainage and flood control <br />problems. lbwever, if a government chooses to do so, it will be <br />held to the same standard of care as a private party. <br />