HomeMy WebLinkAboutAGENDA REPORT 2014 1217 CCSA REG ITEM 10H ITEM 10.H.
CITY OF MOORPARK,CALIFO
City Comaii Meeting
f -17-60117/
ACTION / z
MOORPARK CITY COUNCIL
AGENDA REPORT
L ,.
TO: Honorable City Council
FROM: Dave Klotzle, City Engineer/Public Works Director ,
Prepared by: Shaun Kroes, Senior Management lyst Ei
DATE: December 5, 2014 (CC meeting of 12/17/14)
SUBJECT: Consider Rejection of Bid for Two (2) 2014 or Newer 29-foot— 32-foot
Compressed Natural Gas Low Floor Buses; Consider Waiver of City
Purchasing Procedure Pursuant to Moorpark Municipal Code Section
3.04.120; and Consider Authorizing City Manager to Negotiate Final Bus
Design and Cost, and Issue a Purchase Order to Creative Bus Sales
and Execute Any Agreements Necessary to Effectuate the Purchase of
Two (2) Compressed Natural Gas Buses in an Amount Not to Exceed
$864,000.00.
SUMMARY
On November 5, 2014, the City of Moorpark(City) received one bid from Gillig LLC (Gillig)
in response to the City's Request for Bid (RFB) for two compressed natural gas (CNG)
buses, which will replace the City's two remaining diesel buses. Gililig's bid met the City's
requirements, including providing seating for 26 passengers. The City's two diesel buses
seat 25 passengers each. Gillig's bid of $1,051,369.10 is $187,369.10 higher than the
City's current budget of$864,000.00 for the bus procurement which includes $740,000 in
Prop 1B funds and $90,000 in Federal Transit Administration (FTA) funds. Staff has
identified an alternative bus procurement option through the California Association for
Coordinated Transportation (CaIACT)that would enable the City to purchase two, 32-foot
El Dorado EZ Rider II CNG buses that are similar to the City's existing CNG fleet of EZ
Rider II buses, including providing seating for 27 passengers. The two EZ Rider II buses
could be purchased within the City's existing budget of$864,000.00 and meets the needs
of the City's transit fleet. Staff is therefore requesting that the City Council consider
rejecting Gillig's proposal; consider waiving the City's purchasing procedure pursuant to
Moorpark Municipal Code (MMC) Section 3.04.120; and consider authorizing the City
Manager to negotiate final bus design and cost, and issue a purchase order to Creative
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Honorable City Council
December 17, 2014
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Bus Sales for the purchase of two EZ Rider II CNG buses in an amount not to exceed the
budgeted amount of $864,000.00.
BACKGROUND/DISCUSSION
On September 17, 2014, City Council approved a RFB for two CNG buses, which will
replace the City's two remaining diesel buses. The RFB was released on September 18,
2014, with an original bid submittal deadline of October 21, 2014. Based on comments
from potential bidders, the City extended the deadline for bid submittals to November 5,
2014. On November 5, 2014, the City received a bid from Gillig and a "No Bid Letter" from
Creative Bus Sales. The letter from Creative Bus Sales stated that although they
appreciated the opportunity to bid on the project, their bus manufacturer, El Dorado
National, was unable to meet the bid specifications. Although the proposal from Gillig met
the City's specifications and requirements, the total bid amount was for $1,051,369.10, or
$187,369.10 over the City's current budget of $864,000.00. City staff contacted the
Ventura County Transportation Commission about potential additional funding sources;
however, additional funding was not available.
After conferring with the City Attorney, staff contacted Gillig to determine if there was a
potential to reduce their proposed pricing to within the City's existing budget, without
changing the specifications in the City's RFB. Gillig was unable to reduce its pricing to
within budget. The City's RFB was modeled after the City of Thousand Oaks' (Thousand
Oaks) RFB released last year, with some adjustments made with the intention of the City's
bus to cost less than Thousand Oaks. As the City Council is aware, Thousand Oaks
maintains the City's bus fleet and the goal was to increase maintenance efficiencies by
both agencies having several of the same bus models, thereby reducing maintenance
costs. Further analysis of recent cost comparisons between the City's existing CNG fleet
and Thousand Oaks' fleet indicates that there would not be a significant maintenance
savings that would justify the higher up front cost of procuring Gillig buses. Gillig's bid is
not within the City's current budget of $864,000.00; consequently, staff is requesting that
the City Council reject the bid.
Although the City is unable to purchase replacement buses from Gillig, staff has identified
an existing bus procurement option through CalACT and the Morongo Basin Transit
Authority (MBTA), which the City can utilize to purchase El Dorado National EZ Rider II
buses, the same model of bus as the City's existing CNG buses. The buses have a base
price of $365,872.00 each. Options for the buses, taxes and fees will not exceed the City's
allowed budget of $864,000.00, or $432,000.00 per bus. The CalACT/MBTA agreement
meets the Federal Transit Administration's (FTA) requirements that allow FTA grantees
from within California to procure buses from its purchasing cooperative. The City, by being
a member of CalACT, can use the CalACT/MBTA purchasing cooperative to purchase two
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32-foot CNG buses that will be similar to the City's existing fleet. The buses would include:
• Two doors, which will allow passengers in wheelchairs to board the bus and secure
seating without the need for turning around in tight quarters.
• Air conditioning/heating vents distributed throughout the bus instead of rear
ventilation.
• Automated bus stop announcement system.
• Security camera system, including three inside cameras and one outdoor camera.
• Back up camera system that permits the driver to see what is behind the bus while
going in reverse.
• Buses will be assembled in Riverside, CA, which helps to keep jobs in the state.
As recommended by the City Attorney's office, staff is addressing Section 3.04.120 of the
MMC, which states, "In its discretion, the city council may at any time, by a majority vote
and without amending this chapter, waive the purchasing procedures or alter these
proceedings to fit a specific purchase, when such waiver is not in violation of state law."
There are two factors that justify waiving the City's purchasing procedures (which would
include going out to bid again with new specifications designed to match the EZ Rider II
bus model) for this bus procurement. The first is that the City did go through a formal bid
procedure for the procurement of two CNG buses and unfortunately the bids came in too
high. The second is that the procurement of two CNG buses through the CalACT/MBTA
purchasing cooperative did go through a competitive bid process.
The CalACT/MBTA purchasing cooperative also meets FTA requirements for other
agencies in California to purchase buses using the same agreement. Staff has attached a
letter from FTA, confirming that the CalACT /MBTA purchasing cooperative can be used by
other grantees in California.
Once the City completes its final bus design with Creative Bus Sales, the design is
submitted to CalACT for its review to confirm that the design and pricing meets the
requirements of the purchasing cooperative. The City would then receive a "Letter of
Assignment" from CalACT, confirming that it may purchase the specified buses. The Letter
of Assignment will include an "Assignment to Purchase Agreement" from CalAct confirming
the specific vehicle quantity and type with the original CalAct Agreement. The Assignment
to Purchase Agreement also includes language indemnifying CalAct from the City's
purchase of the buses. Upon receipt of the Letter of Assignment, the City would be able to
issue a purchase order for the two buses. The City will use a combination of Proposition
1 B (Prop 1 B) funds ($774,000) and FTA funds ($90,000) to fund the purchase of the two
CNG buses.
Table 1 (on the following page) provides a comparison of recent bus prices. Typically
speaking, every bus is different when comparing one transit agency to another. Buses ~re
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usually customized and have different features for each order. Consequently, the prices
are different for each bus detailed in Table 1; however, the table does provide Moorpark
with fair cost comparisons.
Table 1: Bus Cost (per-bus; all buses are low floor)
Moorpark Moorpark Simi Valley Thousand Oaks
2010 2014 2014 2013
32-foot CNG Bus 32-foot CNG Bus 35-foot CNG Bus 29-foot CNG Bus
El Dorado EZ Rider II El Dorado EZ Rider II New Flyer Gillig
27 Seats 27 Seats 32 Seats 26 Seats
$410,116 $432,000 $520,233 $503,072
As detailed above, bus prices can vary depending on the size of the bus as well as
features included in the bus design. Moorpark specifically has $432,000 per bus available
for the procurement of two CNG buses using the budgeted Prop 1 Band FTA funds.
FISCAL IMPACT
The FY 2014/15 Budget includes $740,000.00 in SB 1266-06 Transportation Bond Fund
(2611) and $90,000.00 in FTA 5307 Federal Grant Fund (5000), for a total of $864,000.00
for the procurement of two CNG buses.
STAFF RECOMMENDATIONS
1. Reject November 5, 2014, proposal by Gillig LLC for two (2) 2014 or newer 29-foot
-32-foot compressed natural gas low floor buses.
2. Waive City purchasing procedures for the procurement of two (2) 2014 or newer,
32-foot compressed natural gas low floor buses.
3. Authorize City Manager to negotiate final bus design and cost, and issue a
Purchase Order to Creative Bus Sales and execute any agreements necessary to
effectuate the purchase of two (2) compressed natural gas buses in an amount not
to exceed $864,000.00.
Attachment: FTA Letter Confirming Approval of CalACT/MBTA Purchasing Cooperative
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U.S. Department
of Transportation
Federal Transit
Administration
JAN 1 7 2014
Dear Colleague:
REGION IX
Arizona, California,
Hawaii, Nevada, Guam
American Samoa,
Northern Mariana Islands
201 Mission Street
Suite 1650
San Francisco, CA 94105-1839
415-744-3133
415-7 44-2726 (fax)
Re: California Association of Coordinated
Transportation (CalACT)-Morongo Basin
Transit Authority (MBT A) Purchasing
Cooperative
As you may know, last year, the Federal Transit Administration (FTA) issued several
dete1minations regarding large-quantity transit vehicle procurements and purchasing schedules to
ensure that FT A requirements related to joint procurement and fair and open competition were
followed. As a continuation of that effort, FT A initiated a review of the California Association of
Coordinated Transpmiation (CalACT)-Morongo Basin Transit Authority (MBTA) Purchasing
Cooperative. FT A has now concluded that review and the FTA Chief Counsel has issued the
enclosed determination. In summary, FTA has determined that grantees located within the State of
California may purchase vehicles through the cunent CalACT-MBT A Purchasing Cooperative.
Please review the enclosed dete1mination and circulate it to your project, procurement and legal
staff.
If you have any questions about this matter, please contact Renee Marler, Regional Counsel, at
(415) 744-2736 or Joonsik Maing, Assistant Regional Counsel, at (415) 744-2737.
Enclosure
144
U.S. Department
Of Transportation
Federal Transit
Administration
Joe Meer
General Manager
Morongo Basin Transit Authority
62405 Verbena Road
Joshua Tree, CA 92252
Dear Mr. Meer:
Chief Counsel
January 15, 2014
1200 New Jersey Avenue S.E.
Washinqton DC 20590
Last year the Federal Transit Administration (FTA) disallowed the use of several large-
quantity bus contracts by entities that are not parties to those agreements. Following
FTA's decision to disallow the use of these contracts, it asked the Morongo Basin Transit
Authority (MBTA) to pause use of the Purchasing Cooperative it established with the
California Association for Coordinated Transportation (CalACT) pending FTA review.
write to provide guidance on the ability of FTA grantees to use the MBT A-CalACT
Purchasing Cooperative to purchase vehicles, as well as general guidance on FTA's
procurement rules as they relate to State schedules, joint procurements and piggybacking.
For the reasons outlined below, I find that FTA grantees located within the State of
California may use your Purchasing Cooperative, as it is currently structured.
Background
Over the past several years, FT A has reviewed several large-quantity contracts to
determine whether they comply with FTA's procurement rules. Upon review, FTA
concluded that several of these contracts violate the requirement for full and open
competition.
Most recently, on July 8, 2013, FTA informed the State of Minnesota that grantees
outside the State of Minnesota do not enjoy the deference afforded the State by 49 C.F.R.
§ 18.36(a) and may not continue to use the Minnesota Cooperative Purchasing Venture to
purchase buses or other goods and services with Federal funds.
In March of 2013, my office completed a review of several large-quantity contracts
between a bus manufacturer and three transit agencies. Several dozen transit agencies,
many of which were not parties to the contracts, used these contracts to purchase buses.
After reviewing the contracts and the known purchases, FTA concluded that, to varying
degrees, the contracts failed to comply with federal procurement rules. In all of the
contracts, the parties contracted for quantities in excess of their current and reasonably
expected needs, and with the apparent purpose of assigning contract rights to others at a
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Letter to Joe Meer
later date, as was evidenced by numerous "piggyback" purchases. Two of the three
contracts were improperly styled as joint procurements, as many of the transit agencies
that purchased vehicles were not, in fact, parties to the contract. Following the review,
FT A disallowed the use of these contracts by all but the original and actual patties, and
only for the amount specified by each party in the contract.
On March 8, 2013, FTA Administrator Peter Rogoff issued a "Dear Colleague" letter on
the subject of large-quantity bus contracts. The Dear Colleague letter noted the
widespread enors in how FTA recipients were conducting joint procmements and
assigning options to others to purchase buses, and cautioned FT A grantees to "carefully
review [FTA] requirements before purchasing buses through a joint procurement or an
assignment of options." It did not directly address state and local purchasing agreements.
In 2011, FTA concluded that its grantees could not purchase assets with FTA assistance
from certain buying cooperatives like those developed and marketed by the National Joint
Powers Alliance (NJP A) and the Houston-Galveston Area Council (HGAC). The
decision was based on the absence of State participation, and the fact that neither
agreement identified a finite number of vehicles that was based on the parties' reasonably
anticipated needs. Thus, FTA rejected the NJP A and HGAC cooperatives as lacking full
and open competition.
FT A Procurement Rules
Recipients ofFTA financial assistance are required by both 49 U.S.C. § 5325(a) and the
common grant rule (49 C.F.R. § 18.36(c)) to use full and open competition when making
purchases. Usually a grantee fulfills this requirement by one of three ptocurement
methods: (1) conducting a stand-alone procurement for a finite number of vehicles; (2)
jointly procuring a finite number of vehicles with one or more grantees; or (3) accepting
the assignment of another grantee's contractual right to purchase a finite number of
vehicles (aka "piggybacking"). One common requirement in all methods is that the
number of vehicles to be purchased is based on the grantee's actual needs and is
advertised with the solicitation. Thus, all respondents to the solicitation can provide a bid
price based on the number of vehicles to be purchased as well as other salient factors
contained in the solicitation. When the contract is formed, the grantee commits to
purchasing vehicles at the agreed upon price and the vendor commits to furnishing the
vehicles at that price. A fourth procurement method-(4) State purchasing schedules-is
available to States only.
I. Stand-alone procurements
All stand-alone procurement transactions must be conducted in a manner providing full
and open competition consistent with the standards of 49 C.F.R. § 18.36. Grantees and
subgrantees will use their own procurement procedures, which reflect applicable State
and local laws and regulations provided that the procurements conform to applicable
Federal law and the standards identified in the Common Grant Rule. FTA's Third Party
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Letter to Joe Meer
Procurement Guidance, Circular 4220.1 F, elaborates upon the Common Grant Rule's
broad requirements.
2. Joint procurements
A joint procurement is "a method of contracting in which two or more purchasers agree
from the outset to use a single solicitation document and enter into a single contract with
a vendor."1 The parties to a joint procurement may be from more than one state. FTA
encourages the use of joint procurements when combining requirements into a larger
order can result in a more advantageous contract for the participating recipients. FT A's
current guidance does not require the needs of each joint procurement participant to be
separately written into the contract. And, as with regular procurements, a joint
procurement may take the form of an indefinite delivery/indefinite quantity contract
(ID/IQ) if it contains "total minimum and total maximum" terrns.2
Participation in a joint procurement does not relieve any recipient of the responsibilities it
would have if it were procuring goods or services by itself. 3 Recipients that participate in
a joint procurement must adhere to all applicable federal requirements, including the
prohibition against using federal money to procure unneeded items.
The Common Grant Rule requires that a recipient have procedures to "provide for a
review of proposed procurements to avoid purchase of unnecessary or duplicative
items,"4 including the acquisition of "quantities or options it does not intend to use or
whose use is unlikely."5 To prevent a recipient from purchasing unnecessary or
duplicative items, a recipient may contract "only for its current and reasonably expected
public transportation needs and may not add quantities or options to third-party contracts
solely to permit assignment to another party at a later date. "6 "In monitoring whether a
recipient has complied with its procedures to determine what property or services are
unnecessary, FTA bases its dete1minations on what would have been a recipient's
reasonable expectations at the time the recipient entered into the contract."
A joint procurement may not be used as an opportunity to improperly expand the scope
of a federally assisted contract. "A contract has been improperly expanded when excess
capacity has been added primarily to pennit assignment of those contract rights to
another entity."8
1 C. 4220.lF, ch. V § 3.
i C. 4220.lF, ch. V §§ 3, 7(a)(2)(b)(l).
3 C. 4220.lF, ch. IV§ l(c)(l).
4 49 C.F.R. § 18.36(b)(4).
5 C. 4220.lF, ch. IV§ l(b).
6 C. 4220.lF ch. IV§ l(b)(2}.
7 C. 4220.lF, ch. IV§ l(b).
8 C. 4220.lF, ch. V § 7(b)(l).
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Letter to Joe Meer
3. Assignment of options ("Piggybacking")
For reasons of economy, FTA pe1mits the assignment of unneeded contract rights,
sometimes called "piggybacking." FTA discourages the assignment of another
recipient's contract rights as a substitute for a stand-alone procurement.9 Assignments
are intended to be used only when a recipient has "inadve1iently acquired contract rights
in excess of its needs"10 due to "changed circumstances or honest mistakes. "11
Intentionally procuring excessive quantities using federal money is a violation of the
Common Grant Rule described above. Fmihermore, to the extent that an improper
assignment of contract rights enables an assignee to avoid otherwise required
procurement procedures, it also undennines the Common Grant Rule's general purpose
of full and open competition in federally assisted procurements.
4. State schedules
For reasons of federalism, States are accorded substantial deference under the Common
Grant Rule at 49 C.F.R. § l 8.36(a) in the policies and procedures used in state
procurements. By this authority, a State may follow the same policies and procedures it
uses for procurements from its non-Federal funds, so long as it ensures that every
purchase order or similar contract includes any clauses required by Federal law. Many
States use this authority to create purchasing schedules by which the State and its
subsidiaries may acquire goods.
Principles of federalism limit State powers, too. FT A grantees located outside of a
State's borders are not permitted to purchase from that State's schedule.12 Joint
procurements (and in limited circumstances piggybacking) are the only forms ofFTA-
funded contracts permitted among grantees from different states.
MBTA-CalACT Purchasing Cooperative
From 2006 to 2009, the California State Department of Transportation (Caltrans) and
other FTA grantees in the State of California used several contracts awarded by the
California Depaitment of General Services (DGS) to purchase transit vehicles. After
these contracts expired in 2009, DGS encountered problems that led it to discontinue the
use of DGS-sponsored State contracts for transit vehicles.13
In 2010, DGS and Cal trans authorized MBTA and CalACT to establish a "Purchasing
Cooperative" for use by Caltrans and other FTA grantees in the State of California.
9 c. 4220.lF, ch. V § 7(a)(2)(a).
10 c. 4220.lF, ch. V § 7(a)(2).
11 C. 4220.lF, ch. IV§ l(b)(2)(b).
12 C. 4220.lF, ch. V § 4.
13 August 13, 2013, letter from Mark Codey, Chief, Office of Federal Transit Grants, Division of Mass
Transportation, California Department of Transportation, to Dorval R. Carter, Jr., Chief Counsel, Federal
Transit Administration.
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Letter to Joe Meer
Following a competitive procurement process, MBT A and CAlACT awarded the most
recent Purchasing Cooperative contracts to A-Z Bus Sales, Inc. (Contract No. 7-12-23-
15-04) and Creative Bus Sales, Inc. (Contract No. 7-12-23-15-05). The parties to the
contract memorialized State approval for the contracts by entering into separate
California Participating Addenda in August 2012. These contracts are the only
mechanism available to Caltrans and other FTA grantees to purchase ce11ain types of
accessible transit vehicles. The contracts are restricted to FT A grantees geographically
located within the State of California.
Discussion
The purpose of this letter is to elaborate on FTA's March 8, 2013 Dear Colleague Letter
by providing guidance on the use of State schedules like the MBTA-CalACT Cooperative
Purchasing contracts.
The MBTA-CalACT Cooperative Purchasing contracts are not stand-alone or joint
procurements within the meaning of Federal law as discussed above, nor have MBTA or
CalACT assigned options to entities outside the State of California. The contracts are
unique agreements to which the State of California participates via "Participating
Addenda."
As explained above, FT A grants substantial deference to State procurement practices.
Thus, unlike stand-alone or joint procurement methods that must be restricted to a
defined minimum and maximum, State schedules may be open-ended if such a structure
is permitted by State law. However, although FTA permits intrastate entities to purchase
from a State contract, as FTA reiterated in its July 8, 2013 letter to New Flyer of
America, Inc., State schedules may not be used nationally by out-of-state FTA grantees.
The use of State schedules must be limited to entities located within the geographic
boundaries of the State.
Inasmuch as the State of California continues to enter into Participating Addenda with
MBTA and CalACT, the Purchasing Cooperative you have established appears to be a
valid State schedule. In accordance with the deference afforded States by 49 C.F.R. §
18.36(a), FIA grantees located within the State of California may continue to use
contracts established by the MBTA-CalACT Purchasing Cooperative.
If you would like to discuss this matter further, please contact Acting Assistant Chief
Counsel Jayme Blakesley at (202) 366-0304. S",/} ~4L(2
Chief Counsel
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