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HomeMy WebLinkAbout5/16/2001 - STAFF REPORTS (2) DATE: May 16, 2001 TO: Community Redevelopment Agency FROM: City Engineer ELECTRICAL DISTRIBUTION SYSTEM FOR DECORATIVE LIGHT FIXTURES ON TAHQUITZ CANYON WAY RECOMMENDATION: That the Community Redevelopment Agency cancel Agreement No. 416C with MRC Associates,in the amount of$7,500.00, and award a design services contract to Dahl, Taylor and Associates, Inc., in the amount of$15,800,00, for the electrical engineering design of the decorative light fixtures on Tahquitz Canyon Way, between Indian Canyon Drive and Avenida Caballeros, City Project No. 00-36. SUMMARY: The Agency approved Resolution No. 1119 awarding a design contract to MRC Associates on March 21, 2001, however, after review by the City Attorney it was determined thattheAgency's award of that contract represents, arguably, a conflict of interest, a violation of Government Code Section 1090. This item provides for cancellation of the Agency's previous contract and award to an alternate consultant. BACKGROUND: The fiscalyear2000/01 Community RedevelopmentAgency budget includes funds to design and construct approximately 62 decorative light fixtures on Tahquitz Canyon Way between Indian Canyon Drive and Avenida Caballeros. The City Council and Tribal Council have expressed conceptual support for this project, and on March 14, 2001, the Planning Commission approved adoption of the standard plans for the decorative lighting. On December 21, 2000, staff issued a request for proposals for electrical engineering services for the design of the backbone electrical system for the proposed decorative lights. Included in the design will be the footings for the light poles. Five proposals were received from the following firms: 1. Turpin & Rattan Engineering, La Mesa 2. Bechard Long & Associates, Inc., San Diego 3. MRC Associates, Palm Springs 4. Dahl, Taylor &Associates, Inc., Santa Ana 5. Dream Engineering, Inc., Palm Desert A staff evaluation panel had reviewed the proposals with respect to the proposed approach to the project, firm and personnel qualifications, project schedule and project costs, and initially recommended award to MRC Associates. On March 21, 2001, the Agency concurred with staff's recommendation, and awarded contract to MRC Associates in the amount of $7,500.00, Agreement No. 416C. c oh - City Project No. 00-36, Tahquitz Canyon Decorative Lighting May 16, 2001 Page 2 Following the Agency's action, the City Attorney became aware that MRC Associates was owned and operated by Ralph Raya, a member of the Planning Commission, and could violate Government Code Section 1090. Government Code Section 1090 prohibits public officers and employees from having financial interests in contracts made by them, or by any Board or body of which they are members. Unlike conflict issues under the Political Reform Act, conflict issues under Section 1090 cannot be cured by abstaining-which Commissioner Raya did in this instance. The critical issue was the level of involvement of the Planning Commission in the Tahquitz Lighting program, and the City Attorney found that this situation was similar to other situations where courts have concluded that 1090 conflicts existed. The City Attorney's analysis is attached. In light of this opinion, staff recommends award of the contract to Dahl, Taylor & Associates, Inc. The firm is a corporation from Santa Ana, California, and its sole officer is Quang Vu. Sufficient funds are available in Community Redevelopment Agency account no. 812-8192-65130 (East Tahquitz Light Fixtures). VPRV� DAVID J. BARAKIAN JOHN S. RAYMOND City Engineer Director, `77 — — C munity Redevelopment Agency APPROVED:- Executive Director ATTACHMENTS: 1. Resolution 2. Agreement 3. Conflict Letter CITY OF PALM SPRINGS Engineering Department CONTRACT SERVICES AGREEMENT FOR DESIGN SERVICES OF THE DECORATIVE LIGHT FIXTURES ON TAHQUITZ CANYON WAY CITY PROJECT NO. 00-36 THIS CONTRACT SERVICES AGREEMENT (herein "Agreement") is made and entered into this_ day of , 2001, by and between the Community Redevelopment Agency of the City of Palm Springs, California, a public body, corporate and politic, (herein"City") and Dahl, Taylor and Associates, Inc., (herein "Contractor"). (The term Contractor includes professionals performing in a consulting capacity). NOW, THEREFORE, the parties hereto agree as follows: 1.0 SERVICES OF CONTRACTOR 1.1 Scope of Services. In compliance with all of the terms and conditions of this Agreement, the Contractor shall perform the work or services set forth in the "Scope of Services" attached hereto as Exhibit"A"and incorporated herein by reference. Contractor warrants that all work and services set forth in the Scope of Services will be performed in a competent, professional and satisfactory manner. 1.2 Compliance With Law. All work and services rendered hereunder shall be provided in accordance with all ordinances, resolutions, statutes, rules, and regulations of the City and any Federal, State or local governmental agency of competent jurisdiction. 1.3 Licenses, Permits, Fees and Assessments. Contractor shall obtain at its sole cost and expense such licenses, permits and approvals as may be required by law for the performance of the services required by this Agreement. 2.0 COMPENSATION 2.1 Contract Sum. For the services rendered pursuant to this Agreement, Contractor shall be compensated in accordance with the "Schedule of Compensation" attached hereto as Exhibit"B" and incorporated herein by this reference, but not exceeding the maximum contract amount of Fifteen Thousand Eight Hundred Dollars ($15.800.00) ("Contract Sum"). 2.2 Method of Payment. Provided that Contractor is not in default under the terms of this Agreement, Contractor shall be paid as outlined in Exhibit "B", Schedule of Compensation. 3.0 COORDINATION OF WORK 3.1 Representative of Contractor. Thomas L. Doyle is hereby designated as being the principal and representative of Contractor authorized to act in its behalf with respect to the work and services specified herein and make all decisions in connection therewith. F52@]fi\�9000\2(22M.2 m08/M95 Revucd 09/01/98 _1_ cep A 3 3.2 Contract Officer. City Engineer is hereby designated as being the representative the City authorized to act in its behalf with respect to the work and services specified herein and make all decisions in connection therewith ("Contract Officer"). The City Manager of City shall have the right to designate another Contract Officer by providing written notice to Contractor. 3.3 Prohibition Against Subcontracting or Assignment. Contractor shall not contract with any entity to perform in whole or in part the work or services required hereunder without the express written approval of the City. Neither this Agreement nor any interest herein may be assigned or transferred, voluntarily or by operation of law, without the prior written approval of City. Any such prohibited assignment or transfer shall be void. 3.4 Independent Contractor. Neither the City nor any of its employees shall have any control over the manner, mode or means by which Contractor, its agents or employees, perform the services required herein, except as otherwise set forth. Contractor shall perform all services required herein as an independent contractor of City and shall remain under only such obligations as are consistent with that role. Contractor shall not at any time or in any manner represent that it or any of its agents or employees are agents or employees of City. 4.0 INSURANCE AND INDEMNIFICATION 4.1 Insurance. The Contractor shall procure and maintain, at its sole cost and expense, in a form and content satisfactory to City, during the entire term of this Agreement including any extension thereof, the following policies of insurance: (a) Comprehensive General Liability Insurance. A policy of comprehensive general liability insurance written on a per occurrence basis in an amount not less than either(i) a combined single limit of$1,000,000.00 or(ii) bodily injury limits of $500,000.00 per person, $1,000,000.00 per occurrence and $1,000,000.00 products and completed operations and property damage limits of$500,000.00 per occurrence. If the Contract Sum is greater than $500,000.00, the policy of insurance shall be in an amount not less than $5,000,000.00 combined single limit. (b) Worker's Compensation Insurance. A policy of worker's compensation insurance in such amount as will fully comply with the laws of the State of California and which shall indemnify, insure and provide legal defense for both the Contractor and the City against any loss, claim or damage arising from any injuries or occupational diseases occurring to any worker employed by or any persons retained by the Contractor in the course of carrying out the work or services contemplated in this Agreement. (c) Automotive Insurance. A policyof comprehensive automobile liability insurance written on a per occurrence basis in an amount not less than either (i) bodily injury liability limits of $500,000.00 per person and $1,000,000.00 per occurrence and property damage liability limits of $250,000.00 per occurrence and $500,000.00 in the aggregate or (ii) combined single limit liability of$1.000.000.00. Said policy shall include FSZ27M099999-3000\Z(Y1203.2 m08/=95 RC6.0 09/01/99 _2_ coverage for owned, non-owned, leased and hired cars. (d) Additional Insurance: Policies of such other insurance, including Professional Liability Insurance, as may be required in the Scope of Services, Exhibit"A". All of the above policies of insurance shall be primary insurance and shall name the City, its officers, employees and agents as additional insureds, except that the City shall not be named as an additional insured for the Worker's Compenstation Insurance nor the Professional Liability Insurance. The insurer shall waive all rights of subrogation and contribution it may have against the City, its officers, employees and agents and their respective insurers. All of said policies of insurance shall provide that said insurance may not be amended or canceled without providing thirty (30) days prior written notice by registered mail to the City. In the event any of said policies of insurance are canceled, the Contractor shall, prior to the cancellation date, submit new evidence of insurance in conformance with this Section 4.1 to the Contract Officer. No work or services under this Agreement shall commence until the Contractor has provided the City with Certificates of Insurance or appropriate insurance binders evidencing the above insurance coverages and said Certificates of Insurance or binders are approved by the City. The Contractor agrees that the provisions of this Section 4.1 shall not be construed as limiting in any way the extent to which the Contractor may be held responsible for the payment of damages to any persons or property resulting from the Contractor's activities or the activities of any person or persons for which the Contractor is otherwise responsible. The insurance required by this Agreement shall be satisfactory only if issued by companies qualified to do business in California, rated "A"or better in the most recent edition of Best Rating Guide, The Key Rating Guide or in the Federal Register, and only if they are of a financial category Class VII or better, unless such requirements are waived by the City Manager or designee of the City due to unique circumstances. 4.2 Indemnification. Contractor agrees to indemnifythe City, its officers, agents and employees against, and will hold and save them and each of them harmless from, any and all actions, suits, claims, damages to persons or property, losses, costs, penalties, obligations, errors, omissions or liabilities, including paying any legal costs, attorneys fees, or paying any judgment (herein "claims or liabilities") that may be asserted or claimed by any person, firm or entity arising out of or in connection with the negligent performance of the work or services of Contractor, its agents, employees, subcontractors, or invitees, provided for herein, or arising from the negligent acts or omissions of Contractor hereunder, or arising from Contractor's negligent performance of or failure to perform any term, provision covenant or condition of this Agreement, but excluding such claims or liabilities to the extent caused by the negligence orwillful misconduct of the City. 5.0 TERM 5.1 Term. Unless earlier terminated in accordance with Section 5.2 below, this Agreement shall continue in full force until June 30, 2002. rs2\27Mo99999-J000=26 .2 m08/22195 Revved 09I01/98 -3- 5.2 Termination Prior to Expiration of Term. Either party may terminate this Agreement at any time, with or without cause, upon thirty (30) days' written notice to the other party. Upon receipt of the notice of termination, the Contractor shall immediately cease all work or services hereunder except as may be specifically approved by the Contract Officer. In the event of termination by the City, Contractor shall be entitled to compensation for all services rendered prior to the effectiveness of the notice of termination and for such additional services specifically authorized by the Contract Officer and City shall be entitled to reimbursement for any compensation paid in excess of the services rendered. 6.0 MISCELLANEOUS 6.1 Covenant Against Discrimination. Contractor covenants that, by and for itself, its heirs, executors, assigns and all persons claiming under or through them,that there shall be no discrimination against or segregation of, any person or group of persons on account of race, color, creed, religion, sex, marital status, national origin, or ancestry in the performance of this Agreement. Contractor shall take affirmative action to ensure that applicants are employed and that employees are treated during employment without regard to their race, color, creed, religion, sex, marital status, national origin or ancestry. 6.2 Non-liability of City Officers and Employees. No officer or employee of the City shall be personally liable to the Contractor, or any successor in interest, in the event of any default or breach by the City or for any amount which may become due to the Contractor or to its successor, or for breach of any obligation of the terms of this Agreement. 6.3 Conflict of Interest. No officer or employee of the City shall have any financial interest, direct or indirect, in this Agreement nor shall any such officer or employee participate in any decision relating to the Agreement which effects his financial interest or the financial interest of any corporation, partnership or association in which he is, directly or indirectly, interested, in violation of any State statute or regulation. The Contractor warrants that it has not paid or given and will not pay or give any third party any money or other consideration for obtaining this Agreement. 6.4 Notice. Any notice, demand, request, document, consent, approval, or communication either party desires or is required to give to the other party or any other person shall be in writing and either served personally or sent by prepaid, first-class mail, in the case of the City, to the City Manager and to the attention of the Contract Officer, CITY OF PALM SPRINGS, P.O. Box 2743, Palm Springs, California 92263, and in the case of the Contractor, to the person at the address designated on the execution page of this Agreement. 6.5 Interpretation. The terms of this Agreement shall be construed in accordance with the meaning of the language used and shall not be construed for or against either party by reason of the authorship of this Agreement or any other rule of construction which might otherwise apply. 6.6 Integration;Amendment. It is understood that there are no oral agreements between the parties hereto affecting this Agreement and this Agreement supersedes and cancels any and all previous negotiations,arrangements,agreements and understandings, if any, between the parties, and none shall be used to interpret this Agreement. This Agreement may be amended FS=76�3000\2(YL2693.2 .08/22195 Rcvucd 09/O1/98 -4- C� at any time by the mutual consent of the parties by an instrument in writing. 6.7 Severability. In the event that part of this Agreement shall be declared invalid or unenforceable by a valid judgment or decree of a court of competent jurisdiction, such invalidity or unenforceability shall not affect any of the remaining portions of this Agreementwhich are hereby declared as severable and shall be interpreted to carry out the intent of the parties hereunder unless the invalid provision is so material that its invalidity deprives either party of the basic benefit of their bargain or renders this Agreement meaningless. 6.8 Waiver. No delay or omission in the exercise of any right or remedy by a nondefaulting party on any default shall impair such right or remedy or be construed as a waiver. A party's consent to or approval of any act by the other party requiring the party's consent or approval shall not be deemed to waive or render unnecessary the other party's consent to or approval of any subsequent act. Any waiver by either party of any default must be in writing and shall not be a waiver of any other default concerning the same or any other provision of this Agreement. 6.9 Attorneys' Fees. If either party to this Agreement is required to initiate or defend or made a party to any action or proceeding in any way connected with this Agreement, the prevailing party in such action or proceeding, in addition to any other relief which may be granted, whether legal or equitable, shall be entitled to reasonable attorney's fees,whether or not the matter proceeds to judgment. 6.10 Corporate Authoritv. The persons executing this Agreement on behalf of the parties hereto warrant that (i) such party is duly organized and existing, (ii) they are duly authorized to execute and deliver this Agreement on behalf of said party, (iii) by so executing this Agreement, such party is formally bound to the provisions of this Agreement, and (iv)the entering into this Agreement does not violate any provision of any other Agreement to which said party is bound. IN WITNESS WHEREOF, the parties have executed and entered into this Agreement as of the date first written above. ATTEST: COMMUNITY REDEVELOPMENT AGENCY of the City of Palm Springs, California, a public body, corporate and politic By: Assistant Secretary Executive Director APPROVED AS TO FORM: City Attorney F5ZVM099999-JOOOV2�22693.2 m08/=95 Rcvieed 09/01/98 CA# -5- Check one: _Individual _ Partnership _Corporation CONTRACTOR: Dahl, Taylor and Associates, Inc. By: (Notarized Signature) Print Name&Title By: (Notarized Signature) Print Name&Title Mailing Address: 2960 Daimler Street Santa Ana, CA 92705-5824 (END OF SIGNATURES) (Corporations require two signatures: One from each of the Following: A. Chairman of Board, President, any Vice President. AND B Secretary, Assistant Secretary, Treasurer, Assistant Treasurer, or Chief Financial Officer). FS2\276\099999-3000\2022693.2 .09/22/95 Rcvued 09I01198 6 � �� EXHIBIT "A" SCOPE OF SERVICES TASK 1 1. Kick Off Meeting. 2. Gather as-built drawings, inventory maps, etc., from the City of Palm Springs (the City). Also, gather standards and previous similar documents that could be pertinent to this new work. Gather light poles and fixtures data. 3. Gather electronic files of topography base maps, backgrounds showing the proposed light poles and fixtures, existing utilities information from the City and decide what other information needs to be gathered before the electrical work can begin. 4. Coordinate with Southern California Edison (SCE) to determine circuit loading and utility points of connection. Also, coordinate with SCE on all existing and known future load requirements. 5. Develop existing and new single line diagrams as needed. Complete preliminary load calculations. Complete preliminary voltage drop calculations. Prepare preliminary site plans including photometric analysis of proposed light pole locations. 6. Coordinate with the City on easement locations and lay out a preliminary conduit and substructure plan. TASK 2 1. Prepare and submit preliminary (30%) plans (consistent with the conceptual design previously approved by the City) for review. This review includes construction documents and a preliminary construction cost estimate. Plans shall be on standard 24" by 36" City title block sheets. 2. Pick up comments and update backgrounds if needed. 3. Develop and prepare detailed conduit and substructure plans. Identify appropriate SCE electrical meter information depending on the quantity, type, etc., of meters required. 4. Develop and prepare details fortrenching,trench repair, pole light foundations, and all other appropriate construction information. FS2\27MO99999-300012022693.2 .09/22/95 Rcvued 09/01/98 A� EXHIBIT "A" SCOPE OF SERVICES (Continued) TASK 3 1. Prepare and submit preliminary (80%) plans for review. This review includes construction documents, specifications, and a preliminary construction cost estimate. Plans shall be on standard 24" by 36" City title block sheets. Specifications shall be written using City "boiler plate" documents in Microsoft Word Version 97. Specification format shall be provided by City. 2. Pick up comments. 3. Complete final coordination with SCE. Secure approval for the electrical design. 4. Complete a final coordination with the City to ensure that all electrical equipment complies with the City's standards. TASK 4 1. Prepare and submit final(100%) plans for approval and bidding. This includes all construction documents, specifications, and a final construction cost estimate. Plans shall be on standard 24" by 36" City title block sheets. Final plans shall also be provided in digital format (Autocad version R13), on 3Y2" floppy disc. Specifications shall be written using City "boiler plate" documents in Microsoft Word Version 97. Specifications shall also be provided in digital format on 3Y2" floppy disc. Specification format shall be provided by City. 2. Provide bidding assistance during the bidding phase of the project. This includes answering specific questions regarding the plans and specifications and attendance at a Pre-Construction Conference. Additional Insurance per Section 4.1d shall be required as follows: A policy of Professional Errors and Omissions Insurance, in an amount not less than $500,000.00 per claim and in the aggregate with respect to loss arising from the actions of the Contractor performing professional services hereunder on behalf of the City. PS2\276W99999-3000\202M93.2 .09122195 Re,i, 1d 9101/9B 44 Jeg #4 /O EXHIBIT "B" SCHEDULE OF COMPENSATION TASK 1 Lump sum fee of $ 1,580.00 TASK 2 Lump sum fee of $ 2,370.00 TASK 3 Lump sum fee of $ 7,900.00 TASK 4 Lump sum fee of $ 3,950.00 TOTAL Lump sum fee: $ 15,800.00 Lump sum fees are payable upon completion of each task. Task 1 shall be completed within 3 weeks of receipt of Notice To Proceed. Task 2 shall be completed within 1 month of approval of Task 1 by City. Task 3 shall be completed within 1 month of approval of Task 2 by City. Task 4 shall be completed within 1 week of approval of Task 3 by City. FS2\276\0999943000\202203 2 m08/2995 Rcviacd 09/01/98 LAW OFFICES BURKE, WILLIAMS& SORENSEN, LLP ORANGE COUNTY OFFICE 611 WEST SIXTH STREET SAN DIEGO COUNTY OFFICE 18301 VON KARMAN AVENUE,SUITE 1050 550 WEST"C"STREET,SUITE 1880 IRVINE,CALIFORNIA 92612 1009 SUITE 2500 SAN DIEGO,CALIFORNIA 92101 8583 Tel: (949)8633363 LOS ANGELES, CALIFORNIA 90017-3102 Tel: (619)615 6672 Fax: (949)8633350 Fax: (619)615 6673 Tel: (213) 236�0600 Fax: (213) 236-2700 RIVERSIDE COUNTY OFFICE www.bwslaw.com VENTURA COUNTY OFFICE 3403 TENTH STREET,SUITE 300 2310 EAST PONDEROSA DRIVE,SUITE 25 RIVERSIDE,CALIFORNIA 925013629 CAMARILLO,CALIFORNIA 93010.4747 Tel: (909)788 0100 Tel: (805)9873468 Fax: (909)7885785 Fax: (805)482 9834 Writer's Direct Dial: OUR FILE NO: 949-863-3363 04195.0012 daleshire@bwslaw.com April 27, 2001 I/A�0 David J. Barakian r .- City EngineerIti'�S City of Pahn Springs 3200 E. Tahquitz Canyon Way Palm Springs, California 92263 Re: Tahquitz Canyon Way Decorative Light Fixture Desien/Ralph Raya's Conflict of Interest Dear David: Pursuant to your request, this letter is to advise you on whether a potential conflict-of- interest issue arises out of MRC Associates' contract with Palm Springs Redevelopment Agency ("Agency") on the electrical engineering of the decorative light fixtures. 1. Relevant Facts It is our understanding that around seven or eight months ago, the Agency began discussions concerning development of decorative light fixtures on East Tahquitz Canyon Way. On or about December 6, 2000, Mr. Jerry Ougbum, the Project Manager, presented to the City's Planning Commission information regarding the location of the lights and the design of the lights. It is also our understanding that prior to Mr. Oughbum's presentation of the design to the Planning Commission, Mr. Oughburn and Mr. Raya were involved in some discussions regarding the design of the lights. On March 14, 2001, the Planning Commission adopted the standard for the type of light to be used on East Tahquitz Canyon Way and the location where the lights would be placed. It is also our understanding that Mr. Ralph Raya, a member of the Planning Commission, abstained from both the December 6, 2000 study session and the March 14, 2001 session. The Agency mailed out requests for proposals for the electrical engineering of the East Tahquitz Canyon Way Decorative Light Fixture Project ("Project") on or about December 22, 2000. The deadline to respond to the request for proposals was January 19, 2001. MRC Associates, a company wholly owned by Mr. Raya, submitted a proposal to enter into a contract LA#66999 vl David J. Barakian City Engineer April 27, 2001 Page 2 with the Agency in order to provide services for the electrical engineering of the Project. On or about March 21, 2001, the Agency approved MRC Associates' proposal to conduct the electrical engineering of the Project. The issue presented is whether the agency can proceed with the contract with MRC Associates without any violations of Government Code Section 1090, i.e., without violation of any conflicts-of-interest rules. II. Leaal Analysis Government Code Section 1090 prohibits public officers and employees from having financial interests in contracts made by them or by any Board or body of which they are members. Section 1090 applies in two basic situations. First, if the financially interested officer or employee is a member of a Board or other body that actually executes the contract [i.e., City Council Board of Directors], the potential conflict prohibits the Board from entering into the proposed contract, regardless of whether or not the officer participates in or abstains from the actual decision. Second, if a staff member has a financial interest in a contract with the Board, there's a conflict only if that staff member actually participates in the making of the contract'. It is important to note that the term "contract" is used very broadly and applies to any agreement between the Board and another party whether written or oral and whether formal or informal. Additionally, the prohibitions of Section 1090 apply equally to the Board members who vote on a written contract2, a member of an Advisory Board who makes a recommendations on a contract and to an employee who advises the council on a particular contract.4 However, when an Advisory Committee, merely advises on a contract, then the Advisory Committee may perform its responsibilities without violating Section 1090 provided that the interested member abstains and does not participate in the giving of advice.5 The purpose of the ' Frasier-Yamor Agency v. Count o Del Norte 1977 68 Cal.A M 201. See also, 1999 WL 604287, O . Cal. At 8 Y Y f ( ) PP� P g< Gen.No.99-304 2 Stigal v. City ofTaft(1962)58 Cal.2d 565 3 City Council v McKinley(1978)80 CalApp.3d 204 4 Schaefer v.Berinstein(1956) 140 Cal.App 2d 278. 5 See, 1999 WL 604287, Op Cal.Atty. Gen. No.99-304. David J. Barakian City Engineer April 27, 2001 Page 3 enactment of Section 1090 was "to remove or limit the possibility of any personal influence either directly or indirectly which might bear on an official's decision as well as to avoid contracts which are actually obtained through fraud or dishonest conduct.s6 Hence, "the critical test for determining whether Section 1090 has been violated is whether an officer or an employee has participated in the making [or letting] of a contract in his or her official capacity.s7 The "making" or "letting" of a contract has been defined to include the preliminary discussions, negotiations, compromises, reasoning, planning, drawing of plans and specifications and solicitations for bids.8 In City Council of San Diego v. McKinley, the court held that the execution of a contract between a landscape architectural firm, whose president and stockholder was also a member of the City's Park and Recreation Board, and the City Council for the design of a new City park would violate Section 1090.9 In McKinley, the president of the architectural fine did not abstain from participation when the City's Park and Recreation Board approved the design of a Japanese Garden for the City park. Subsequently, he submitted a proposal to the City Council for architectural and engineering of the City park. The City Manager, on advice of the City Attorney, refused to execute the agreement between the City Council and the landscape architectural firm based on violation of conflict-of-interest laws,per Section 1090. The City Council sought a writ of mandamus against the City Manager and the City Auditor Comptroller seeking to compel the execution of the agreement between the landscape architectural firm and the City for the design of the new Japanese Garden and the City park.10 The court held that public officers are obligated to discharge their responsibilities with integrity and fidelity. "The law of this state is that public officers shall not have a personal interest in any contract made in their official capacity"11 6 City Council of San Diego v.McKinley(1978)80 Cal.App.3d 204,213. 7 77 Op. Cal. Atty. Gen. 112, p.3, citing to, Millbrae Assn.for residential survival v. City of Millbrae (1968) 262 Cal.App.2d 222,237(emphasis added).;See also,Mckinley,80 Cal.App.3d at 212. 8 See, 77Op. Cal.Ally. Gen.at p.4;see also,McKinley, 80 Cal.App.3d at 212-213. 9 McKinley, 80 Cal.App.3d at 213-214. to Id.at208-210. 1 t Id.at 213. ezi oily David J. Barakian City Engineer April 27, 2001 Page 4 The court explained that "the Park and Recreation Board's conduct of extensive investigations and preparations of detailed proposals for the design of the Japanese Garden" within the City park was so closely related to that of the Council's operation that the Board could be viewed as having been involved in the exercising of the Council's own authority to some extent. The court went on to hold that "the above factors combined with the Board's advisory relationship to the City Manager (who executes any contract after it is approved by the City Council) compelled the conclusion that the Board was involved in `letting' of the contract.12 In another case, also, where the approval of the design services of an airport by the Art Commission was part of the terms and conditions of a contract with the City for engineering of the City's airport, the Attorney General found that an Art Commissioner on the Art Commission would violate Section 1090 if he were to enter into a contract with the city to design the airport.13 The Attorney General held that "if the contract for the design were examined in isolation up to the time of its award, we might conclude that the commissioner would not be in violation of this statute."14 Here, the approval of the design services by the commission is part of the original contract. The transaction may not be segmented into two steps. Although the contract was awarded by the airport commission is was not merely for design, but for satisfactory design. The Art Commission will in essence determine the ultimate terms and conditions of the contract, that is, what constitutes satisfactory design. As such, Art Commission members may be said to be participants in the making of the contract.15 The instant situation could be construed as distinguishable from McKinley and the Art Commission cases discussed above. Here, it could be argued that the engineering contract of the lights is not dependent on the approval of the design by the Planning Commission making the Planning Commission an advisory board, and that since Mr. Raya has abstained from participation in the sessions in which the Planning Commission discussed the design and the location of the lights, no violation of the Section 1090 would occur if the Agency proceeds with its contract with MRC Associates. It could be argued that unlike the Art Commission case, here 12 Id. at 212-213. 13 77 Op. Cal. Atty. Gen. 112,p.5. 14 Id. 15 Id. CkA .4 /s David J. Barakian City Engineer April 27, 2001 Page 5 the terms of the electrical engineering contract between MRC Associates and the Agency are not dependent on the approval of the design or location of the lights by the Planning Commission. However, it should be kept in mind that in McKinley, similar to this situation, the approval of the proposal for the City park was not dependant on the approval of the design of the Japanese Garden by the Park and Recreation Board either. In the present case, it is also important to keep in mind the proximity in time between the approval of the design and location of the lights by the Planning Commission on March 14, 2001 and the Agency's approval of MRC Associate's proposal on March 21, 2001, which means that MRC Associates actually submitted its proposal to the Agency during the same period of time that the Planning Commission was approving the design and location of the lights. Furthermore, here, although the Planning Commission has not participated in any preliminary discussions, negotiations, compromises, reasonings, and/or solicitation for bids of the electrical engineering contract at issue, like the McKinely case, it could be construed that they have in essence been involved in the "planning" and "draw of plans" for the contract, i.e., discussions of the design and location of the lights. More importantly, in the Contract at issue, the identification of the proposed design and location are listed as tasks under the scope of services. Hence, a court could conclude that, similar to McKinley, here, also, the Planning Commission's detailed discussions and "drawing of plans" regarding the design and location of the lights, which are part of the contract, may render the Planning Commission more than just an "advisory board" but may invlove in the "making" or "letting" of the contract, in which case, even though Mr. Raya has abstained from participation, the Agency is not able to proceed with the contract without violation of Section 1090. III. Conclusion Unfortunately, the case law in this area has taken the law beyond what might appear from a simple reading of the statute. We included discussion of some of the leading cases in this memo to demonstrate the complexity of the issue. The distinctions made by the cases are not necessarily clear, and any advice we give must be a matter of degree. The issue of conflict of interest is one of perception. Under the conflict of interest rules, the intentions and motivations behind your actions are not what is analyzed. What is assessed is the public perception of the potential for you to act either in your economic or personal interest to the detriment of your office. Although, as discussed above, the situation presented in this matter could be distinguished from the cases discussed in this memo, we can easily see how an etw 04A David J. Barakian City Engineer April 27, 2001 Page 6 argument could be made for a 1090 conflict. In the end, we cannot reach a conclusion with a high degree of confidence. In essence, the question comes down to how significant the Planning Commission's involvement was in the decision to proceed with the project. At this point, we can see that the issue is open to different interpretations. Therefore, perhaps the safer course of action is to not participate unless there are additional facts which bear on the issue. I am sorry that we could not be more definitive at this time. We would be happy to discuss the matter further at your convenience. Very truly yours, DAVID J. AtEgHIRE, City Attoney City of Palm Springs DJA/SKS:da cc: Mr. David Ready, City Manager Mr. Ralph Raya IM4 4 , RESOLUTION NO. 1125 OF THE COMMUNITY REDEVELOPMENT AGENCY OF THE CITY OF PALM SPRINGS, CALIFORNIA, CANCELLING AGREEMENT NO. 416C WITH MRC ASSOCIATES, IN THE AMOUNT OF $7,500.00, AND APPROVING A CONTRACT WITH DAHL, TAYLOR AND ASSOCIATES, INC., IN THEAMOUNT OF$15,800.00, FOR THE ELECTRICAL ENGINEERING DESIGN OF THE DECORATIVE LIGHT FIXTURES ON TAHQUITZ CANYON WAY, BETWEEN INDIAN CANYON DRIVE AND AVENIDA CABALLEROS, CITY PROJECT NO. 00-36 WHEREAS, the Community Redevelopment Agency awarded a design contract to MRC Associates, in the amount of$7,500.00 on March 21, 2001, as Agreement No. 416C; and WHEREAS, the City Attorney of the City of Palm Springs has reviewed the relevant facts regarding Agreement No. 416C; and WHEREAS, the City Attorney has rendered an opinion that argument can be made that MRC Associates' contract with the Community Redevelopment Agency represents a conflict of interest and a violation of Government Code Section 1090. NOW THEREFORE BE IT RESOLVED by the Community Redevelopment Agency of the City of Palm Springs, California, that Agreement No. 416C with MRC Associates, in the amount of$7,500.00, is hereby cancelled; that a contract with Dahl, Taylor&Associates, Inc., in the amount of $15,800.00, for the electrical engineering design of the decorative light fixtures on Tahquitz Canyon Way, between Indian Canyon Drive and Avenida Caballeros, City Project No. 00-36, is approved; and, that the Executive Director is hereby authorized to execute all documents relating to the implementation of this contract. ADOPTED this 16th day of May 2001. AYES: Members Hodges, Reller-Spurgin and Vice-Chairman Oden NOES: Member Jones ABSENT: Chairman Kleindienst ATTEST: COMMUNITY REDEVELOPMENT AGENCY By: Assistant Secretary Chairman REVIEWED & APPROVED: