ERMUSR Misc 10-10-2006~//
Elk River
Municip al Utilitie s
13069 Orono Parkway
Elk River. MN 55330
October 3, 2006
To: Elk River Municipal Utilities Commission
Jerry Takle
Jim Tralle
John Dietz
From: Bryan Adams
Subject: Miscellaneous Issues
phone: 763.441.2020
Fax: 763.441.8099
Enclosed is the packet for the Tuesday, October 10, 2006, commission meeting at 4:00 pm.
The electric department continues to make good progress on the large construction projects.
The water department is shifting in the maintenance mode with hydrant and distribution valve
repair and preparing the system for cold weather. Administration is spending a lot of time on
the budgeting process as well as preparing for next years projects.
Attached is a feature article from MMUA's Resource on Elk River as Energy City. Some of
the numerical statistics are incorrect, but the point of the article is good.
In 2004, a young driver was killed when her car went off the road and hit a utility pole. We are
named in a suit along with Sherburne County and Connexus Energy. Attached is a copy of the
wrongful death complaint. I have turned this issue over to the League of Minnesota City for
they provide our liability insurance.
Previously, staff mentioned to the commission the raising issue of "utility boxes" in right of
way or utility easements. The city council has received some complaints from residents about
excessive "utility boxes". Attached is my response addressing this issue. Do you have any
comments that would provide further insight into this issue?
/ ~ +/
Elk River
Municipal Utilities
13069 Orono Parkway
F.lk River, MN 55330
September 27, 2006
To: Scott Clarlc -Community Development Director
From: Bryan Adams, P.E. -General Manager, Elk River Municipal Utilities
Subject: Utility Facilities in Public Right of Way
phone: 763.441.2020
Fax: 763.941.8099
ySit
On September 25, 2006, we discussed the subject of utility facilities better known as "utility
boxes" in public Right of Way and utility easements. There have recently been some
complaints from Elk River residents about excessive "utility boxes'' in front of their homes or
in sight from their homes.
This perception by residences in some cases is understandable. The number of "utility
boxes" is increasing with the deregulation of telecommunication industry, and the desire for
more products and services such as telephone, cable television and Internet sesviees (voice,
video, data). Years ago, electric and telecommunication utility systems were placed on
above ground poles and the equipment was much smaller due to air insulation. As
technology advanced and the public prefers not seeing overhead wires, many of these
systems are now being placed underground with termination points above ground in "utility
boxes". The equipment has become larger because the air insulation is replaced with
material or oil insulation. Technology advances in the telecommunication industry require
what was copper wire system to be supplemented with fiber optic systems. Even a wireless
system required a fiber optic system as a backbone.
Currently there are 3 telecommunications companies in Elk River. They are Qwest, North
Star Access, and Charter Communications. They all operate both a copper and fiber optic
system. The Elk River lvlunicipal Utilities operates and maintains the electrical system in
Elk River. We utilize 3 different electrical systems, 600 amp and 200 amp high voltage
systems and a secondary system (120v) for street lights and power to homes.. The 3 electrical
systems are connected together with "utility boxes". The telecommunication and electric
"utility boxes" are tied together for grounding purposes per the National Electric Code which
is the reason the telecommunications boxes are located close to the electric "utility boxes".
These "utility boxes" may include service pedestals, conductor junction boxes, conductor
splice boxes, transformers, fuse cabinets, signal injection points, electrical service points to
telecommunication facilities and an occasional sewer lift station. These "utility boxes" are
located above ground for the following reasons:
a) Burying high voltage equipment creates safety concerns with persoiulel in confined
space.
b) With secondary voltage equipment being buried, water, dirt and animal
contamination does lead to equipment failure and service interruption.
c) Finding buried mairlloles or handholes is al~~~ays a challenge. In the winter, gaining
access is a problem due to frozen ground.
The possibility of different utilities sharing `'utility boxes" thereby reducing the number of
"utility boxes" has been looked at. Shared "utility boxes" between different companies
creates serious safety and liability concerns.
The utility system of buried conductor with equipment and terminations above ground has
evolved because it works from a safety code, operations and maintenance perspective. The
down side is there will be "utility boxes" above ground. Technology, economics and quality
of reliable service has not provided any reasonable alternatives.
STATE OF MINNESOTA
COUNTY OF SHERBURNE
David Lorenz, as Trustee for the Next-Of-Kin of
Kristin Lorenz,
Plaintiff,
v.
Sherburne County, a Minnesota Municipal
Corporation; Elk River Municipal Utilities, a
Minnesota Municipal Utility; Connexus Energy,
a Minnesota Corporation; and John Doe,
Defendants.
COMPLAINT
Plaintiff, for his Complaint against the Defendants above-named, states and
alleges as follows:
GENERAL ALLEGATIONS
That David Lorenz is the father of decedent Kristin Lorenz, whose date of birth
was May 27, 1988, and whose wrongful death occurred on or about October 2, 2004 in
the City of Elk River, County of Sherburne, State of Minnesota.
That David Lorenz is the Trustee of the next-of-kin of Kristin Lorenz, having been
duly appointed as such by Order of the Hennepin County District Court, Fourth Judicial
DISTRICT COURT
TENTH JUDICIAL DISTRICT
Case Type: Wrongful Death
Case No:
District of Minnesota, dated September 18, 2006.
That Defendant Sherburne County (hereinafter "the County") is, based upon
information and belief, a Minnesota Municipal Corporation which maintains its principal
offices at the Sherburne County Government Center, 13880 Highway 10, Elk River,
Minnesota 55330, and the activities of which are managed by the Sherburne County
Board of Commissioners.
IV.
That, based upon information and belief and at all times material hereto, the
County was responsible to ensure the safe condition of County State-Aid Highway 33
(hereinafter "CSAH 33") and adjacent lands, including the safe and proper placement of
the utility poles in relation to the roadway, the safe and proper design of the highway
and adjacent lands, the use of safe and proper guarding and barricades, the posting of
appropriate traffic signals, markings and signage, and the safe and proper construction,
inspection, restoration, repair, and maintenance of the roadway, guarding, barricades,
signage, and adjacent lands.
V.
That Defendant Elk River Municipal Utilities (hereinafter "Elk River") is, based
upon information and belief, a Minnesota Municipal Utility with its principal offices
located at 13069 Orono Parkway, Elk River, Minnesota 55330, and the activities of
which are managed by the Elk River Utilities Commission.
VI.
That, based upon information and belief and as of October 2, 2004, Elk River
was the owner of, or was responsible for the condition of the subject utility pole and was
2
responsible for the safe and proper placement of the utility pole in relation to the
roadway, and for ensuring the safe and proper condition, construction, inspection,
replacement, restoration, repair and maintenance of the subject pole and surrounding
area.
VII.
That, based upon information and belief, Defendant Connexus Energy
(hereinafter "Connexus") is a Minnesota Corporation which maintains its principal
headquarters and place of business at 14601 Ramsey Boulevard, Ramsey, Minnesota
55303, and which is the successor to or which was formerly known as Anoka Electric
Cooperative.
VIII.
That, based upon information and belief, Connexus determined the placement of
the subject utility pole prior to the date on which the pole was acquired by Elk River, and
was responsible for the safe and proper placement of the utility pole in relation to the
roadway, and for ensuring the safe and proper condition, construction, inspection,
replacement, restoration, repair and maintenance of the subject pole and surrounding
area.
IX.
That Defendant John Doe is a corporation, municipal corporation, or other entity
that is presently unknown to Plaintiff which was responsible for the placement of the
subject utility pole, or which was responsible to safely and properly design the highway,
utilize safe and proper guards and barricades, traffic signals, markings and signage, or
3
to safely and properly maintain the utility pole, roadway, or surrounding areas and
lands.
X.
That on or about October 2, 2004, at approximately 11:15 p.m., Kristin Lorenz
was driving the 2000 Pontiac Grand Am owned by her parents and was proceeding in
generally a westbound direction on CSAH 33 in the City of Elk River, County of
Sherburne, State of Minnesota.
XI.
That at the above-referenced time and while proceeding through a curved
section of CSAH at a point approximately 1012 feet east of the intersection with Watson
Street, the vehicle driven by Kristin Lorenz was caused to leave the roadway and collide
with the subject utility pole which was located on the north side of the roadway.
XII.
That Kristin Lorenz died as a result of the traumatic injuries sustained in the
collision with the utility pole, and that her wrongful death was a direct and proximate
result of the actions and inactions of the Defendants in failing to properly and safely
place the subject utility pole in relation to the roadway, in failing properly and safely
design the highway and adjacent lands, in failing to utilize safe and proper guarding and
barricades, in failing to utilize safe and proper traffic signals, markings and signage, and
in failing to ensure the proper and safe construction, inspection, replacement,
restoration, repair and maintenance of the subject pole, guarding, signage, and the
roadway and surrounding lands.
4
XIII.
That as a direct and proximate result of the aforesaid negligent, careless and
unlawful conduct of the Defendants which caused the wrongful death of Kristin Lorenz,
Plaintiff has incurred damage as set forth more fully herein.
FIRST CAUSE OF ACTION
XIV.
For his first cause of action, Plaintiff realleges and incorporates herein the
allegations set forth in Paragraphs I. through XIII.
XV.
That the County was required to safely and properly design, construct, inspect,
restore, repair and maintain CSAH 33 and the adjacent lands in a safe condition, and to
utilize safe and proper guarding, barricades, traffic signals, markings and signage.
XVI.
That the County was negligent and failed to exercise due care, which negligence
introduced or permitted the continued existence of dangerous and unreasonably
hazardous conditions, and which negligence included, without limitation, the negligent
and improper design and construction of CSAH 33 and adjacent lands; the failure to
utilize safe and proper guarding and barricades along the roadway; the failure to utilize
safe and proper traffic signals, markings or signage; the failure to properly and safely
inspect, restore, repair or maintain CSAH 33 and the adjacent lands; and/or the failure
to comply with applicable standards, regulations or conventions pertaining to safe and
proper highway design, construction, inspection, restoration, repair, maintenance, or the
utilization of safe and proper guarding, barricades, traffic signals, markings and signage.
5
XVII.
That the negligent and improper acts of the County, as described above, were a
direct and proximate cause of the wrongful death of Kristin Lorenz, and in addition have
caused Plaintiff to incur expenses for the last treatment and funeral expenses of the
decedent and to sustain pecuniary loss within the meaning of Minn. Stat. § 573.02. The
total damage sustained by Plaintiff as a direct and proximate result of the negligent and
improper acts of the County is in excess of Fifty-Thousand Dollars ($50,000.00).
SECOND CAUSE OF ACTION
XVIII.
For his second cause of action, Plaintiff realleges and incorporates herein the
allegations set forth in Paragraphs I. through XVII.
XIX.
That the Defendants, and each of them, were required to safely and properly
place the utility pole in relation to the roadway, and to ensure the safe and proper
condition, construction, inspection, replacement, restoration, repair and maintenance of
the subject pole and surrounding area.
XX.
That the Defendants were negligent and failed to exercise due care, which
negligence introduced or permitted the continued existence of dangerous and
unreasonably hazardous conditions, and which negligence included, without limitation,
the unsafe and improper placement of the utility pole so that it was too close to the
roadway; the failure to properly inspect, replace, restore, repair and maintain the pole
6
and surrounding area; and/or the failure to comply with applicable standards,
regulations or conventions pertaining to the placement, construction, inspection,
replacement, restoration, repair or maintenance of the subject utility pole and
surrounding area.
XXI .
That the negligent and improper acts of the Defendants, as described above,
were a direct and proximate cause of the wrongful death of Kristin Lorenz, and in
addition have caused Plaintiff to incur expenses for the last treatment and funeral
expenses of the decedent and to sustain pecuniary loss within the meaning of Minn. Stat.
§ 573.02. The total damage sustained by Plaintiff as a direct and proximate result of the
negligent and improper acts of the County is in excess of Fifty-Thousand Dollars
($50,000.00).
WHEREFORE, Plaintiff demands judgment against the Defendants and each of
them jointly and severally in an amount in excess of Fifty Thousand and no/100 Dollars
($50,000.00), together with the costs, disbursements, interest and reasonable attorney's
fees incurred in pursuing this action, and such other relief as the Court deems appropriate.
ROBER~P. C~HRISTENSEN, P. A.
Dated: gY~ ~
Robert I'. hristensen (#16597)
6601 Lyndale Avenue South, Suite 320
Minneapolis, MN 55423
(952) 925-4147 Telephone
(952) 925-1926 Fax
7
SELTZ &SELTZ
George Seltz (#099077)
6601 Lyndale Avenue South, Suite 320
Minneapolis, MN 55423
(952) 925-4147 Telephone
(952) 925-1926 Fax
ATTORNEYS FOR PLAINTIFF
8
ACKNOWLEDGEMENT
The undersigned hereby acknowledges that appropriate sanctions may be
imposed against the parties and/or their attorneys pursuant to Minn.Stat. § 549.211 if
the Court determines that the claims, defenses or other legal contentions contained
herein are presented for an improper purpose, unwarranted by existing law, frivolously
presented, without evidentiary support, not reasonably based upon knowledge,
information and belief or made without rem able in iry.
ROBERT I~CJ~iRISTENSEN, P. A.
Dated: ~ ~ 7. ~ • ~~
Robert R. Christensen (#165`7)
6601 Lyndale Avenue South, Suite 320
Minneapolis, MN 55423
(952) 925-4147 Telephone
(952) 925-1926 Fax
SELTZ &SELTZ
George Seltz (#099077)
6601 Lyndale Avenue South, Suite 320
Minneapolis, MN 55423
(952) 925-4147 Telephone
(952) 925-1926 Fax
ATTORNEYS FOR PLAINTIFF
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