Loading...
HomeMy WebLinkAbout3/17/2010 - STAFF REPORTS Law Officos Of Woodruff, Spradlin & Smart A Professional Corporation MEMORANDUM TO: Hon Mayor Pougnet and Members of the City Council FROM: Douglas Holland, City Attorney DATE: March 16, 2010 RE: Supplemental Materials; City Council Agenda Item 2-1-— Disposition of Bid Protest for the Palm Springs Animal Care Facility, City Project 07-24 As part of your agenda materials on the above agenda item, the City Council received a copy of Parkwest's protest of W.E. O'Neil's apparent low bid for the construction of the Palm Springs Animal Care Facility and a copy of my letters to Parkwest and O'Neil indicating that this Office would recommend that the Council that the protest be denied and that O'Neil's bid be found to be the lowest responsible bid. Attached for your information is a copy of letter dated March 10, 2010, from the law firm of Monteleone & McCrory, the attorneys for Parkwest, supporting the Parkwest protest, and a letter dated March 15, 2010 from the law firm of Hunt Ortman, the attorneys representing W,E, O'Neil Construction, urging the denial of the protest. This Office has reviewed the attached correspondence and considered the arguments presented. It remains our opinion that the failure of O'Neil to comply with the instructions regarding the entry of the "base bid amount" in numbers and written form for the "base bid price" is not a material error that provides O'Neil with an unfair . competitive advantage. Although the City certainly would prefer that bids be error free, it is not always possible to secure such results. The courts recognize that bids are not required to be flawless and as a general rule an error that does not affect the amount of the bid or provides a bidder with an advantage or benefit that was not available to other bidders can be waived. The bid instructions clearly slate that the controlling bid is the "adjusted base bid" and not the "base bid amount." O'Neil fully complied with all requirements regarding the "adjusted base bid" amount. We recommend that the City Council deny the protest and determine that the error in the O'Neil bid was not material and that O'Neil's adjusted base bid of $6,529,000.00 is the lowest responsible bid. No other action is required at this time and the actual award of the contract will be presented to the City Council for consideration at a later date. $rEPHCN MONTCLCONE Mowrgi,coNL+ & Mt Cit ox Y P oHANOr rou NTY orrlcr 11606•I9621 LAWYGRB 200 WLST 'SAWA ANA 0W0. 50TE l99 ni.Co • nlNGunn SANTA ANA, 4ALIFORRIP 9N0I imC Woixc venr6ait]xni^C Oprnnnglx} 725 SOUTH YIOUCNOA STREET SUITE 3200 TELEPHONE _ LOS ANOCLCS. CALIYOIiNu fl0017•B446 I1I91 S05-JI70 TCLCWNONe I21JI 612 9900 rAC$IMILE I'ARIIIJ IiSP FACSIMILE 121JV 61r^. 9990 PI41 y05•J104 nNINI N March 10, 2010 OUR FILE NUMBER 6929-16185 VIA FACSIMS•LE (714) 835-7787 AND U.S. MAIL Douglas C. Holland, Esq_ Woodruff, Spradlin & Smart 555 Anton Boulevard, Suite 1200 Costa Mesa, California 92626-7670 Re: Bid Protest of Parkwest Construction Company City of Palm Springs Project No. 07-24 (Anima]. Care Facility) Dear Mr, Holland: This firm represents Parkwest Construction Company in connection with its bid protest submitted to the City of Palm Springs (the "City" ) on February 25, 2010 . Parkwest submitted the second low bid on the project identified as the Palm Springs Animal Care Facility Project No. 07-24 (the "Project") . The apparent low bidder on the Project was W.E. O'Neil Construction ("WEOC11) . As discussed below, California law clearly and unequivocally points to the conclusion that the error contained in the WEOC bid is material and provided WEOC with an unfair competitive advantage. The error committed by WEOC goes to the most essential term of any bid -- price. The City cannot Simply label the error as "not material" and award the Project to WEOC. The error in the bid of WEOC requires that the City treat the bid as non-responsive. Accordingly, Parkwest respectfully requests that the WEOC bid be rejected by the City and the Project awarded to Parkwest as the lowest resloagive bidder, We have had an opportunity to review the bid submitted by WEOC and your March 8, 2010 letter, As you acknowledge in your letter, the bid documents require that the written base bid figure provided by WEOC ($6, 000, 420) take precedence over the numerical base bid figure ($6, 420, 000) . Because of the LAW PF FiCCS PIONTFULOnr & MCCRaer, LLP Douglas C. Holland, Esq. March 10 , 2010 Page 2 conflict, and the explicit rules set forth in the bid documents issued by the City, the Adjusted Base Bid Amount of WEOC must be calculated using the lower figure of $6, 000, 402 , not $6,402, 000. If the City follows its own bidding guidelines and calculates the bid of WEOC using the written base bid figure, then WEOC would have the ability to argue the bad contained a material mistake and seek to avoid being bound by its bid. This is the very situation California law prohibits. Stated differently, the failure of WEOC Cc submit a definitive bid amount leads to the conclusion that WEOC did not submit a ' bid" capable of acceptance by the City. Because WEOC failed to include a material term of the proposed agreement, the City was not presented with an offer the City could accept to form a binding contract. Because of its mistake, and assuming the City follows its own bid guidelines, WEOC can seek relief from its bid under Public Ccntr'act Cade section 5103 . Alternatively, the City may not have the ability to bind WEOC to its lower bid figure since WEOC did not make an offer capable of acceptance. As a result, WEOC has provided itself with a convenient escape route and, in turn, gained an unfair advantage over competitors such as Parkwest . California case law is clear on this point . If a bidder gains an unfair advantage over competitors as a result of its mistakes in filling out the bid form, the bid must be rejected as non-responsive. As the Court stated in valley Crest LandSC pe Inc v City Councij, of the City of ❑avis (1996) 41 Cal .App.4th 1432, 49 Cal .Rptr.2d 184 : "... M e conclude [the successful bidder] had an unfair advantage because it could have withdrawn its bid. Misstating the correct percentage of work to be done by a subcontractor is In the nature of a typographical or arithmetical error. It makes the bid materially different and is a mistake in filling out the bid. As such, under Public Contract Code section 5103 , [the successful bidder] could have sought relief by giving the City notice of the mistake within five days of the opening of the bid. That fth2 successful bidderl did not seek relief is of no moment . The key point is that such relief was available. Thus, [the successful bidder] had a benefit LAW or ri C.e. Mc �re(.(suti(. & mcclumY, I'Ll, Douglas C. Holland, Esq. March 10, 2010 Page 3 not available to the other bidders, it could have backed out . Its mistake _.could not be corrected by waiving an "irregularity. " Id. at 190 (emphasis added) . WEOC clearly enjoyed a benefit not available to its competitors. WEOC had the ability to obtain relief from its bid if WEOC determined its bid was too low. Because of the ootenti 1 for abuse, California Courts strictly enforce the competitive bidding laws. In Konica Svsiness Machines !IS& v. The Regent of the I7 iversity of, California (1988) 206 Ca1 .App. 3d 449, 253 Cal . Rptr. 591 , the court summarized both the purpose of the competitive bidding laws and the role of the courts in their interpretation as follows : "Because of the potential for abuse arising from deviations from strict adherence to standards which promote these public benefits, the letting of public contracts universally receives close judicial scrutiny and contracts awarded without strict compliance with bidding requirements will be set aside. This pre enZative_annroach is applied avan where it is gertain there was in fagt no corr d o r adverao pffec ipqn the bidding prQcpgs and the deviations would save the entity monev . The importance of maintaining the integrity in government, and the ease with which policy goals underlying the requirement for open competitive bidding may be surreptitiously undercut, mandate strict compliance with bidding requirements." Id, at 4S6 (emphasis added) . While the bid of WEDC must be rejected, we see no reason why the Project should not be awarded to Parkwest_ Parkwest has quoted a fair price - a price just a few percent higher than the bid of WEOC and significantly lower than all other bidders. Parkwest complied with the bid proposal of the City and is ready, willing and able to commence work. This crucial public works project should not be delayed simply because WEOC submitted a grossly non-responsive bid. More importantly, the City will not he exposed to any legal action if the bid of WEOC is rejected as non-responsive. LAW 011FICC` MONTIiIXP NE & MCCROI Y, UP Douglas C. Holland, Esq. March 10, 2010 Page 4 The City was not presented with an offer from WEOC capable of acceptance. The City is under absolutely no legal obligation to unravel the problems created by the failure of WEOC to submit a responsive bid. The bid of WEOC must be rejected and the Project should be awarded to the lowest responsive, responsible bidder, Parkwest . If the City fails to act properly with respect to the bid of WEOC, Parkwest will take the appropriate legal action. Thank you in advance for your careful consideration of this matter. if you have any questions, please call. Very truly yours, MONTELEONE & MCCRORY, LLP By REY a5 JSH/sr DALE A.OFUMANN Bunt Ortmann Hunt &mgil;pi(tpgnU tt hanl6nmRntt.cum Palfty oxs2.00t OPtmann Nkyes LuUkq Atcomeys At Law ���.�9 Darling E Mnh, Inc. March 15,2010 YIA E-MAIL FAX AND U.S. MAIL Douglas C. Holland,Esq. Woodruff, Spradlin& Smart 555 Anton Boulevard, Suite 1200 Costa Mesa,CA 92626-7670 Ile: City,of Palm Springs Animal Care Facility City Project No. 07-24 Our Client: W.F. O'Neil Construction Co. of California Dear Mr,Holland: The undersigned represents W.E, O'Neil Construction Co, of California ("WEO"), We are responding to the March 10, 2010 correspondence of Jeffrey Hurst which was submitted in support of a bid protest by Parkwest Construction Company ("Parkwest"). In said letter, Parkwest contends that there was a material error in the WEO bid, and specifically contends that the difference between the vrtztten base bid figure ("six million four hundred twenty dollars") and the numerical base bid figure("$6,420,000.00'�was a material error. WEO disagrees, The WEO bid cannot reasonably be construed as containing a material error. We are aware of the fine print below the base bid price section that states, "In the case the words and figures do not match, the words shall govern and the figures shall be disregarded,' Importantly, this same language appears below the adjusted base bid section, in which WEO indicates consistently, both in numbers and words, an adjusted base bid amount of$6,529,000. Moreover, an itemized breakdown of this amount appears on the adjusted base bid worksheet, which reflects a base bid amount of $6,420,000, and the itemized additive and deductive alternates which mathematically confirm that the adjusted base bid amount is $6,529,000, and is derived from the base bid amount of$6,420,000. Further, the contract for work under this bid proposal is required to be awarded to the lowest adiusted base bid and not the lowest base bid, "The lowest responsive bid shall be determined by adjusting the Base Bid Price by subtracting all the deductive alternates and adding all the additivc alternates to achieve the Adjusted Base Bid," 311472 1 DAn 0232,001 1 301 North LAO Amm.701 Fioor,PRsndenn,CA 91101 - Phone.626-440-5200 - ryx:626-796-0101 • ftimat mfpQ6unmxtmnnn.rom Douglas C. Holland, Rsq. March 15,2010 page 2 For the adjusted base bid, WEO entered the amount of"six million five hundred twenty nine thousand dollars and no cenrs"and'$6,529,000.00,"amounts which do not conflict, The WEO bid is therefore clear, unequivocal and responsive: the base bid was S6,420,000 and the adjusted base bid is $6,529,000. Because the WSO bid was unequivocal, there was clearly no unfair competitive bidding advantage, WE-0 could not have obtained relief from its bid under Public Contract Code Section 5103, and could not have plausibly argued that its base bid amount was$6,000,420 when the base bid clearly was$6,420,000. In Vallcy Crest Landscape, Inc. v. City Council of the 00) of Davis (1996) 41 Cal.App 4th 1432,the Court of Appeals stated: "However, it is further well established that a bid which substantially conforms to a eall for bids may, though it is not strictly responsive,be accepted if the variance cannot have affected the amount of the bid or given the bidder an advantage or benefit not allowed other bidders, or in other words, if the variance is inconsequential" Id at 1440. 1441, Under Konica BzWness Machines USA, Inc. v. Regents of the University of California (1988) 206 Cal.App. 3d 449, a variance is allowed if it was minor such that there was no advantage to the awarded bidder to the detriment of other bidders. For all of the foregoing reasons, W.E. O'Neil Construction Co, of California requests that the bid protest of Parkwest be declined, that the City determine that the error in the WEO bid was not material, and the WEE adjusted base bid of$6,529,000 is the lowest responsible bid, and the contract should be awarded on this basis Thank you. very truly yours, ICI I Dale A. Ortmann DAO:Id cc: W.B. O'Neil Construction Company(via e-mail) 311472.1 DAD D232-ODI I 0 Parkwest ConstTuction Company March. 12, 2010 City of Palm Springs 3200 East Tahquitz Canyon Way Palm Springs, CA 92262 Dear Chris Mills, We are forwarding copies of our protest letter regarding the Palm Springs Animal Care Facility project, the City's attorney's answer and our attorney's rebuttal letter in preparation for Wednesday's board meeting. Sincerely, Ron Moore President Lifetime industries,Incorporated DBA:Parkwest Construction Company P_O.Box 790,Redlands,CA 92373 Phone 909-798-1333 Fax 909-793-2485 Lic.k 580133. �oIGC l7lo/'�vr i rtiT�`�wl' Par kivest COnstrUC tiOxd Company lohner) 4 lzy of PAM Springs Procurement & C:nniractin, %Lana>>cr 3200 Lam !ahgnit7Car1yon 'kay Pals: Springs, CA 92362 Am)- Craig L Glnddern, C.P.M. Rv Palm Springs Animal Carc Facilily Project No. 07-24, Sk Corner of Mesquite. Rd, 8c Vella Rd, Parkwest Construction formally prolcsls and appeals the appawnt low hid of ICE! (broil C'onstrucdov, on the ahnve rctcrenced project. The appeal/protest is submitted bated on errors node by WE Uncil on the bid fnrtn, page 16, "Aatse Aid Price". The price in words and the }trice in figures are nol the saran am+rani. T�Itich estabii-4hcd errors to occur on page 20, "Adjusted Fsaic Rid %k(wkshcct-. 1%bid documents are ver, clear regarding figures and words of the numbers as eaiird out in the InforntatiLTI no me,,&,ra item 8, Aid Schedule - pace 16 and Adjusted [aid Workshe t—pa e 20 clearly state "In ease the l ords and litnurcs do not agree. The V• orJ,shall =o%ern an,i the ti >uri,.brill he disregardcd,­ See thattached pages. At',L-.. Uncsl Construction's Base Bid Price on page 16 fo� n Kcrepanc) hetuOen the MOM anti tit+ores. This LteulLl cause AN A4justcd Rase Bid to he incorrect I'here are ;ela:r discrepancies liar ahcrzttttc I- there am taut numbers in woids: one is typed (\incwcn thousand) nor lined out and nut acknowrlcdged, the other Jwenty thousand) i5 hand written,and the typed figure{$19,000) is imed out hat not acknowledged. Due to the numerical errors made in the bid documents submitted by W.F.. Oneil Coustrucitttn, we request That the Cily of Pahn ,Springs reject MO. Oncil Construction's bid proposal as non-responsive, and a%ard the contract tv ParkwuNt Construction Company as tic lowest responsive and responsible bidder. Please fuel tree to contact me if you creed any additional infonatation ill support 01 our protest, and please keep us informed of the City of Palm Springs' decision rcgardinvg Allis matter Ron ,Moore Pre:idem I..ifeunee Inductnea_ hicorporaled DBA, Pdrk'MCNI l:ir71,5lruvuon Ckmpa l� V.U, I;o�790 lwdlund.i,VA 92373 Phone 90-798-1333 1 ac%9-7930$85 IN A 5ROI 33 rlu TI io lill`[S updn `vhlrh Ihr +Vcl1, Is to rHT cmI If,d Ili=• rights-of-way arrl =ascingnl;, f<Jr ,c,Cps themto A11,J "'llef lands rjes''pr"Bled Ill Isr' h;r I`nC GCInt'2.ClC'1 In p^T'nrrtllrt_l the Work Are Idr'ntlhi-'d I[i thla (:.1n1171d Docljfile-ni' All a'id d Ion2l IFl, do and c,,-I r',511'Crrtn rqq Jll6u f;l iV"I. r,lr, rpnstruCi.orl larlhtlr. rr at fi aqe ci ma ter iai. and arr. Ir ..I. Irnl rl,;r I,_ Ili . CDn;,acln' Cr, It I I t 51r„ctl.nvs or perin;Jnen( changes in east!%q i•Ir 4f'l.'ES .1nI Cte ",7L,llv] a'F: .I . )• :he L.li, J'le -I"1_•.:ijr. :1'O,IGCL' m i`d: l,Gnir ail Duci.11llona 5 n' -d: t..".PI';. Fl• -P['1.._ ' ';-I'. ry ri, ese ntat'c'• 't.r I:,r;,:V ih,=' ula.:..'.• 1 :1, , •-•71;+r27 %it'- .r •_f' •L fF' A,-.h . ..I'hr . .: I :II ' LI . J�=111591.+ :1 �^ uilc I. ,I,r---: 7, �- .. 1.r.., .. . "; d ,. .�=r I•'_.. 'I r I . .� ,..-IIIq.,�_ °l:',..el'L.,� �r r ..:. - .- .- �Jrlc, .].I-.i rL_'-I , 'h:; l.G IL+I-, ., w lha.:1-.6 -,C. r'n�l �•Ll"..,I1Y;11i^ .- ; - -... r '1 '•i 4L_ r1i1+. r,a;I 'C I;ld!ca:r 3' ' .JI .�� ,-_ __ IC1-I_ C . . „ ,r'rl -4np,l or.- -.'peg - .air-: ,r Lr^. !4.r 5 INTERPRETATIONS - -- -- _st ens �_-..: _ ..1 �"l'a t r __ ., ;,,,r ,"1': ..-_ . D•= Crn=,r: .;,. }_ ss,na Llt Aca_•1Ca r'lo L[;' nr .,,;I` h` di _a't 1�5 -aC:rCe'J ❑, rr-;g14n'rLIC' i1r1- ,5'niy 'JJ�Sif'i c r?C� .'.IS"' F':'Cn1::• 1 _., r'!'i`. not Oe ar15:;ereJ Drily CII,,''(11n5 thai Ina"c oecr` 'P5o'!e" '•, t'1rnlC i.rr'ien =,�.Cf:L'�� '.c. oc? 1"IPI:{I'', �l•n' nnC ]i'lPf 3'I`IC.",(IOn1, :I'' 6- 'BID SECURITY, BONDS, AND INSURANCE - L:ol-h Bid shall oe al-col'Ipaniil by a ccrilfic'd or cashier'o rr).x:k or moroved Bid Bono in the ;inleurn stated in Ihr- Nonce lnvrtinq Bids Said check or bnnd Shun hp made p2w.11 r u, Ihr•: lily and shall he' gn'en a:• a Lryuarantee 111a1 the Blhdor If a'rrnrrieri Ine N!ork, Will enter Into nn Agreement mth lht. City Ind v'.'TII turnnsh thr, necessary Insurrince crrlifiralc`; Rlymonl Bonci, and Por-forrnanr.<: Bunci. leech o'sald bonds and insurance cerl mcates shall nu 111 the amounts 512I6,ld III trip-: Supplementary General Gunditicms In case of refusal or 1�111urr G` the successful Bidder In enter into said aureunlrnl (ill,, Chdc.k or Bih buno ors Ihe: casu may be shell ;)(l fur;eole.n to thr. C,Iv If Ihe- f31r1r1oi rn:I:1F In flJmish a Rid Rnnll as ITc S?Curdv tho Blddar `hall n,p Ili:• [air; Bond fern hF'rC In nr Or'- rinfrpl;Ilflrl 'u7°,I"irllinlly 1n 111'l r RETURN OF BID SECURITY - %t ilnin 1.1 :r'lzl ...,,: a „r ills: corll'ac.t Ill, +�uy :a1'I return eI on secimne> c..c�rnp ;nelny s„tn cif inc, B ci_ plat°r= rat ul '1),,) 11p .t;d a`.yar7 Al,c,ha' Dr:_,ec...rd a.s All! tr:' Tl9id urtd tr' . P'4rcr=nt has ��Cr'n '.nolh, •.>:el.utco Tn l :.III 'hen ni- db rnoD , , °he ,,SCIId-' Clci-:=— -hnse Bids S BtD FORM - 'hr. BI:' . 'ra ,race r" irl � rr , _ ^is �_..r ..,au• Jr o''-_ .. ;, nrnvae" u- � ' _ --•rnc 'Jrj—o nj':'r1,; B,a r. J,_ _.-,-.. tl,z'e .Inc-F).•. &�:hedua 3r:ur=' 1a�,•, LIB u'l nu uric I:.u.a! :in �';y .:-fiGli ia:IL ;+ruiu CS .,' llel'� a,[ ^.p�2r 9�'� :'Vrir..r.' pn lilrl'C2:a. 'f1 [',e BI❑ .L7'lp_rn�n's rl iq . = urn': n1 C"IB �Yc'r•'- '.' an; ,,!1PV"'�iri cC:l.;'r ;Fp rl.cm3 2nd the �/o'rS Si"ll'OD'Je.11'�f^, an'.ahpa a II'=51[1C [hr ;2a'C!t -is sfla; by O'a'th+ nary F,d ;he LCreLc -nanG BIC F,✓? .,dr., tlt s c. Yi•� C=rlr,?,,-.i or'•. .'rr ., 1 ''C'F "AI. of n,V:-..r ,^,e adr`.ress •..'la'c- [h,, I,o a Tarc ,- . tr. ale, IrIE 9a1,_ al',, In,+,- u' IJLenmg Of =5 fT,u BId CerJrav shin' n,a �,rirlo5emG In Ihr Sdrn-w Br,:'erina "IrI"1 in Blo 9. SUBMITTAL OF BIDS - 1'Jli Bids alit+ 1 Le dcllv1:Ir2'.I u', IPIc brie end lu tln; pl,l,.r. soll nl the Notrcc; Inviting Bids. It is the Biddci'!; sl rD responsibl"alty to k:ee Thal us Bid i\rnceiveu It, prupel 11111u Bid', wfll lilt oe accepted afliir the oppoinn�-d timo Ifni-opc'niny ni bids no matter what the reason- 10 DISCREPANCIES IN BIDS - In the evenl that tlicra I mom. than one Bid !tom in trip. find Schedule the Biddci shall famish a princ `or nll Rid Iliad" In the sch:=Jule Lind f"311 Jrc lu no so vJ11 'LndLr the Bln is non-re:sporislve and mJy uauar, ila ;election In the avant 'hat Ihe'e' ars u-it p,rl;e Bid .I•-•ms 'n o Bid Schedue and the 'amount' uidiceted for a unll mice Bic Item dory Inc; rq,Jr,l the product c- the ,!nil {,rcr, pint quanti$j I;sied the unit price sha11 eovern and the announl val Ge GOr^]CY.C ')cLU' {Ir,gly and "tic, Comracl sh,a, '"0 ny such car®':nnri 'unleet la th= =)rovis;rns o- SP:unn Wil -.- ' n`?hv ..a4lnr nl.d Pub''t7 Contract C;•..., Ill flip ,]veni 'h"l t"c'rr ' o-.oru lhrll', Cre B-1 IF, F. Bi,; S`'rned4'7 an p t i-i :7L', ,nrl:a[9: I-,'7h^-. ;M2 S L'e CC'es r ., �;LT ,,wi !I-9 e'JI'1 cf Jrir^_, CrC ill 'nr. In'Iv+)Uc .Fans ih'r ..10 01 ,'le - ,.:•..r^.r�.I7, )`, ill, l 1,.. _;'•I s.o..�.;_C_i ... , y} . Ine C.,;Intr r a-,.GPB 14 QUANTITIES OF WORK •. _+:,ri"r r�•,• I),F11 r'a +',I- '_ , 1 I• •'} srn.; F-�' 12. WITHDRAWAL OF BID - T-,r- on r-'c ,r. .:rr r`:I{ . Bic-er r'r,i r� u 11L: 1:::..+... . • 1;� r7�,?r y fin it iu'IL. tG'e5en:a tr•.-. u,. .. marl ,e .'C _S1 r1'u5' :c o'e" eJ tU 0 p-1 il,L^U alcc I', .,ilncry',Ids yi..%,,:d�Ilr, s,,;lla::�l�d :Iasinl 'imr `CI' r.lrzjct '-B:Gs 93. MODIFICATIONS AND UNAUTHORIZED ALTERNATIVE BIDS - Ura'.lthcnz•su corrddions nrnitstloru o' pr'a'n ns stter m -n• -rd, ta election as : ing win-ruspunsi�c The compieiecmI' Bid `orm, shall oe '•Ithout 1mr;rUnvallons. alteraoons nr rn,lires Alterrra6ve BIOS 'Adl not be consnderac unless e�pre551y Called for In tna WcUrc Inviting Bins Oral FAX PJleuraphic nr telapnane Bn.ls; or nttaJitic2ions w16' not hi. c;n in51d,srsd BID SCHEDULE Llnli Sc.ir' r"'ICe TC of CITY OF PAUM SPRINGS ANINIAL CARE FACILITY PPP) iECT No 07 - 24 it o_,i�- Sprlrg_ ...;bfn•nls Description: Providte ill materials, sul)plle� services equipment and ma:npcwer necessary to crir= piote the grading, londscapirig, irrigation fenclnq. lighting. street Improvements and general bullclugl construction woik, Fonds and Inaurr-irc.e for the Palm Spri=s Animal Care F.ic:dity prolecl ;,; detailed in gtrp P1ars & Spec:ifica7iom', r*Mdled City of alrn Spr'mgs Arnmal (:arc F8dlily Cily Prolec+ Nn (7."1 ' BASE BID PRICE for tl-e I= SLIM, ,f. r in do case the e^.rinds :arid fiqureiE do nol mai.h the w,)rCq hall govorn and the 1lquia aha9 iie disrcy_,irCJud ME ' �ALTERNiATE BID PRICES Bidders are advised that aIP of the following alternates Must be riced for the bid to be considered responsive. The lowest responsive hid shall be determined by adjusting the BASE BM ERiCE by subtracting all of "the Deductive Afternates and adding aH or the Additive Alternates to achieve an ADJUSTED BASE BID. IL Should be noted chat the City reserves r_he right artEr determining the responsive low bidder to accept all, a portion of, or none of the Alternate pricing. In case the words and figures do not agree, the words shall govern Ind the floures shall be disregarded- NOTE: � Bidders are acvlsed than the f u!I descriptions of the alternates and related work can be found in Speoiflcat�or SecTion 01230 or on Plan sheet A0.-50. Deductive Alternate 1: ❑Veie Sc,uTr' F'I:nt r= fC th.; I-Js-IP SLfvl PR, CL Ji- Dedurt S 00nce in Rgprr 'l - - -- -- (PnCe in Words) i c ADJUSTED BASE BID V,/ORKSHEET Bidders shall transfer the Base Bid and the Alternate Bids to this worksheet to determine the final ADJUSTED BASE BID AMOUNT- Th1e Lowest Responsible Bidder snail Lie acternlned using the Adjusted Base Bid Amount Se El J i.11^ls C'6GJCi'Vp; �,{IPfI'�?? CS I i.''nL's Je:-u�L�2 yli�.'rl'c ii; � lea i f;lln L'S aQ'�LICtI`JB HIiF,rn AtQ 5 l Minus Dcduclivc Alternate= l5 Mmus Deductive Nternnfe 5 Plus Addltivc Aliernate G 3 Minus DeduCtivo Altpma:e 7 (5 Minus Deductive 4ltcrnale 2 (S I fA mi.s D&ducti`dc 411er'TI r, I' P,'i,nus Deductive lvfn,is Dacueti,.:,41t�' ra±e: 1 1 lllrnus Decuctiv9 17 'S k1c,Adrimve. Altcmaae i„ J J 6Ou LI� Add Additive Altematal-' 5501:'JJ(nll10 Minus" Deductive Alttirnratc 15 ADJUSTED BASE BiD s (Price in ,Figures) (Price In Words) Ir n-..YYJS n:ii o,_r'•. 4 C I..r,diryH 'hy..,r:Is shell a v..rl jr Ly s`12' I)-'I r'Iv.a arrle.rtl !, 5lDD^^ LAW OFHCES Or WOODRUFF, SPRADLIN & SMART A PROFESSIONAL CORPORATION 555 ANTO'11101A.GVARD,SUITR 1200 X COSTA MP,SA,CA 92626.7670 (714)558-7000 E FAX(714)835-7787 DIRECT•DIAL:C1 I4)d L5.1 N2 O1RL'CI FAX (714)415.1142 E-MAIL:PHOLLANn@WSS.LAW COM March 8, 2010 VIA E-MAIL AND FIRST CLASS MAIL Ron Moore President Lifetime Industries, Incorporated DBA' Parkwest Construction Company P.O. Sax 790 Redlands, CA 92373 Re: City of Palm Springs Animal Care Facility City Project No. 07-24 Dear Mr. Moore: Thank you for your protest letter of February 25, 2010, discussing W.B. O'Neil's error in its bid to the City, W.E. O'Neil, the apparent low bidder, provided the amount of "$6,420,000.00" as the "Price in figures" for the base bid amount. For the 'Trice in words" for the base bid amount, however, W.E. O'Neil wrote "six million four hundred and twenty dollars and no cents,"an amount that is$419,580.00 less than the amount in figures. This Office has reviewed your protest and the relevant portions of the bid schedule and related documents. The bid documents expressly provide that "Bid price shall be shown in words and figures, and in the event Of any conflict between the words and figures, the words shall govern." Nevertheless, the contract for work under this bid proposal is required to be awarded to the lowest adjusted base bid and not the lowest base bid. "The lowest responsive bid shall be determined by adjusting the BASE BID PRICE by subtracting all the Deductive Alternates and adding all the Additive Alternatives to achieve the ADJUSTED BASE BID." For the adjusted base bid, W.E. O'Neil entered the amount of"Six Million Five Hundred Twenty Nine Thousand Dollars and No Cents"and"$6,529,000.00,"amounts which do not conflict. This Office in consultation with the Purchasing Division will recommend to the City Council that the Council set the protest aside, determine that the error in the O'Neil bid in the "base bid price" is not a material error, and the adjusted base bid of$6,529,000.00 .from W.E, O'Neil is the lowest responsible bid. Please now that the City Council will make the final BEN AMMERJdAN 11 TERRY(-ANDRUS■EDWABD L.BERTRAND■M.LOIS BOBAK N CARCIMEA.BYRNE N PATRICKM DESMOND JAMESM-DONICN■CHRiSTINAM.DOYLE m JAMES H.EGGART E CRAIOG.FARRBIGTON M JO,¢FMW.'FORAATH Y RiCiAR LACER BRA➢LEYSL HOGIN■DDUGLAS C.HOtiA.NO■OAVRDE,1(ENS1O u CYNTHiA W,KOLE■EDWARD2,K07t.IN■ROBERTAAKRAUS MAGDALVALONA•WIANr ■JASONM.Mc EWEN■MARKM MONACFIRIO■1AURA A.MORGAN•TIIOMAS F.MXCFN 11 JENMrER L.RAlDAICti STEVENL.RADER F BARBARA RAiLPANU■ANNA R,8ALVSKY■OMAR SANDO'VAL a DIEGO SANTANA■JOHNR.SHAW(OFCOUNSEL) GREGORYF—MMONIAN■KENNARDR SMART,JR.•DAMP,LK.SPRADLR4•ALYSONC SUH■THOMAS L.WOODRUFF(OFCOUNSEI.) 673485.1 Ran Moore March 8, 2010 Page 2 decision on this matter. In addition, we will also note that the Council also has the authority to reject all bids for any reason and not approve any agreement with any bidder. The City will advise you of the date and time of the Council's meeting on the award of any construction agreement on this project. Very truly yours, WOODRU F, SPRADI,IN& SMART A 1'rofcs al Cnrpor Ii DOi} AS C,I3OLLANA ACH:nI fi73dS5,1 MONTELLONL: & .MtTi io, LLP 9TEPHEN MONTELEONE ORANGE COUNTY OFFICE (166619621 u�iv u xp LAWYERS xrxP ZOO wCiY ANA. RLVO �UqE •00 ICO t SANTA AN A. CALinUFORrv1A ):)OI onG • n✓Ounnpmr Tee bOurM n10uL"MOA SYUCCT SUlrC ]200 TELECNONg f>Iwl e61­3170 LOS ANGELES CALII'ORNIA 90017 SA4U TELEPHONE 12131 G12 9900 FACSIMILE JU11 k�1V Is ❑I,kh, FACSIMILE RI31 612 9930 (2141 565.3194 PAN 1'NI R March 10, 2010 OUR RILC NUMBER 6929-16165 VIA FACSSMSLE (714) 935-7787 AND D.S. MAIL Douglas C. Holland, Esq. Woodruff, Spradlin & Smart 5155 Anton Boulevard, Suite 1200 Costa Mesa, California 92626-7670 Re : Bid Protest of Parkwest Construction Company City of Palm Springs Project No. 07-24 (Animal Care Facility) Dear Mr. Holland: This firm represents Parkwest Construction Company in connection with its bid protest submitted to the City of Palm Springs (the "City" ) on February 25, 2010 . Parkwest submitted the second low bid on the project identified as the Palm Springs Animal Care Facility Project No. 07-24 (the "Project") . The apparent low bidder on the Project was W-E. O'Neil Construction ( "WEOC") . As discussed below, California law clearly and unequivocally points to the conclusion that the error contained in the WEOC bid is material and provided WEOC with an unfair competitive advantage. The error committed by WEOC goes to the most essential term of any bid -- price. The City cannot simply label the error as "not material" and award the Project to WEOC. The error in the bid of WEOC requires that the City treat the bid as non-responsive. Accordingly, Parkwest respectfully requests that the WEOC bid be rejected by the City and the Project awarded to Parkwest as the lowest responsive bidder. We have had an opportunity to review the bid submitted by WEOC and your March 6, 2010 letter. As you acknowledge in your letter, the bid documents require that the written base bid figure provided by WEOC ($6, 000, 420) take precedence over the numerical base bid figure ($6, 420, 000) _ Because of the LAW OI F11=E5 MONTELEONE & MCCRORY, LLP ® Douglas C. Holland, 6sq. March 10 , 2010 Page 2 conflict, and the explicit rules set forth in the bid documents issued by the City, the Ad7ust'ed base Sid Amount of WEOC must be calculated using the lower figure of $6, 000, 402, not $6, 402 , 000 . If the city follows its own bidding guidelines and calculates the bid of WEOC using the written base bid figure, then WEOC would have the ability to argue the bid contained a material mistake and seek to avoid being bound by its bid_ This is the very situation California law prohibits . Stated differently, the failure of WEOC to submit a definitive bid amount leads to the conclusion that WEOC did not submit a "bid" capable of acceptance by the City. Because WEOC failed to include a material term of the proposed agreement, the City was not presented with an offer the City could accept to form a binding contract _ Because of its mistake, and assuming the City follows its own bid guidelines, WEOC can seek relief from its bid under Public Contract Code section 5103 . Alternatively, the City may not have the ability to bind WEOC to its lower bid figure since WEOC did not make an offer capable of acceptance. As a result, WEOC has provided itself with a convenient escape route and, in turn, gained an unfair advantage over competitors such as Parkwest . California case law as clear on this point . If a bidder gains an unfair advantage over competitors as a result of its mistakes in filling out the bid form, the bid must be rejected as non-responsive- As the Court stated in Valley Crest Landscape, Inc , v_ _City Council of the City of Davis (1596) 41 Cal .App.4th 1432, 49 Cal .Rptr.2d 184 : "__. [w] e conclude [the successful bidder] had an unfair advantage because it could have withdrawn its bid. Misstating the correct percentage of work to be done by a subcontractor is in the nature of a typographical or arithmetical error_ It makes the bid materially different and is a mistake in filling out the bid. As such, under Public Contract Code section 5103 , [the successful bidder] could have sought relief by giving the City notice of the mistake within five days of the opening of the bid. That fthe successful bidder] did not seek reli f is of no moment. The key ooinL is that such relief was available. Thus, [the successful bidder] had a benefit IAW Or FICES MONTrLrONE & ,McCRoRY. L L P Douglas C. Holland, Esq. March 10 , 2010 Page 3 not available to the other bidders, it could have backed out . Its mistake ...could not be corrected by waiving an "irregularity. " Id. at 190 (emphasis added) _ WECC clearly enjoyed a benefit not available to its competitors. WECC had the ability to obtain relief from its bid if WEOC determined its bid was too low. Because of the potential for abuse, California courts strictly enforce the competitive bidding laws . In Konica Business Machines USA v_ The Regents of the University of California (1988) 206 Cal .App. 3d 449, 253 Cal .Rptr. 591, the court summarized both the purpose of the competitive bidding laws and the role of the courts in their interpretation as follows: "Because of the potential for abuse arising from deviations from strict adherence to standards which promote these public benefits, the letting of public contracts universally receives close judicial scrutiny and contracts awarded without strict compliance with bidding requirements will be set aside. This preventative aporoach_is applied even where it is certain there was in fact no corruption or adverse effect upon the bidding process, and the deviations would save the entice money The importance of maintaining the integrity in government, and the ease with which policy goals underlying the requirement for open competitive bidding may be surreptitiously undercut, mandate strict compliance with bidding requirements _" Id. at 456 (emphasis added) . While the bid of WEOC must be rejected, we see no reason why the Project should not be awarded to Parkwest . Parkwest has quoted a fair price -- a price just a few percent higher than the bid of WEOC and significantly lower than all other bidders. Parkwest complied with the bid proposal of the City and is ready, willing and able to commence work. This crucial public works project should not be delayed simply because WEOC submitted a grossly non-responsive bid_ More importantly, the City will not be Exposed to any legal action if the bid of WEOC is rejected as non-responsive_ �nw or-r iC L'S DOuglas C. Holland, Esq. March 10 , 2010 Page 4 The City was not presented with an offer from WEOC capable of acceptance . The City is under absolutely no legal obligation to unravel the problems created by the failure of WEOC to submit a responsive bid. The bid of WEOC must be rejected and the Project should be awarded to the lowest responsive, responsible bidder, Parkwest . If the City fails to act properly with respect to the bid of WEOC, Parkwest will take the appropriate legal action. Thank you in advance for your careful consideration of this matter. If you have any questions, please call . Very truly yours, MONTELEONE & MCCRORY, LLP Sy RE S . RS_ JSH/sr