HomeMy WebLinkAbout081225-6.6 BID PROTESTFROM:
TO:
RE:
"Small Town Atmosphere
Outstanding Quality of Life"
City Attorney
Town Council
Bid Protest on CIP Project C-055 Diablo Road Trail -Agenda Item 6.6
As described in the staff report for agenda item 6.6, a bid protest was filed by Bay Cities
Paving & Grading, LLC ("Bay Cities") challenging the proposed award of the contract
for CIP Project C-055. The staff report recommends that the protest be rejected and that
the contract be awarded to the apparent low bidder, Goodfellow Bros. California, LLC
("Goodfellow"). Subsequent to the staff report being prepared and provided to both Bay
Cities and Goodfellow, the attorney representing Bay Cities submitted a letter providing
further argument as to why the Bay Cities protest should be granted. (Letter attached as
Exhibit 1) While that letter does not change the conclusion of Town staff, this memo is
intended to provide a detailed legal and factual response in order to create a clear record
of the basis for the Town staff recommendation.
Factual Background
This summary is limited to facts relevant to the bid protest. As stated in the staff report,
Goodfellow was the apparent low bidder while Bay Cities was the second low bidder.
As part of the required bid submittal, each bidder was required to include the list of all
subcontractors (see copy of form attached hereto as Exhibit 1). The form has spaces to fill
in the name and other relevant information regarding each subcontractor as required by
Public Contract Code Section 4104.
Of relevance to the protest, the form also requires the bidder to list the "Bid Item No(s)."
and "percentage" for each subcontractor. Both of these lines include the direction to
"See Note Above." That Note reads, in relevant part, as follows:
"On the Subcontractor List you may either submit the bid item numbers, and the
percentage of each item subcontracted with your bid or email the information to
eng ineering@danville.ca. gov„
Goodfellows bid submittal fully complied with all subcontractor information with the
exception of the percentage of work to be done (sample page attached as Exhibit 2).
Rather than list the percentage of each bid item to be performed by each subcontractor
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August 12, 2025
Page 2
(for example, to indicate that a subcontractor would be performing 80% of the work on a
specific bid item), they used the percentage each subcontractor would be performing of
the entire bid amount (for example, in Exhibit 2, you will see that Evergreen Engineering
would be performing work equaling 1.64% of the entire bid amount). It should be noted
that Goodfellow was one of two bidders to complete the form in this manner.
After the bid protest was received from Bay Cities, Town staff forwarded a copy of the
protest to Goodfellow, a necessity to allow them the opportunity to respond and defend
themselves. The Town's Transportation Manager, Allan Shields, received a subsequent
phone call from a representative of Goodfellow who had questions regarding the protest.
Mr. Shields declined to answer questions in order to remain neutral, but did provide
Goodfellow with the bids from all bidders at thei request. The following day,
Goodfellow submitted a list of all subcontractors pursuant to the Note 011 the Town form
allowing bidders to email the information to the Town specifying the percentage of work
to be done for each bid item. (See Attachment E to staff report, attached here also as
Exhibit 3).
Legal Framework
Public Contract Code Section 4104 requires all bidders on public works contracts in
California to list the following information for each subcontractor that will be performing
more than 0.5% of the total bid amount:
• Name of subcontractor
• Location of their business
• California contractors license number
• California DIR registration number
• The "portion" of the work to be done by that subcontractor
With regard to the last point, the court of appeal in the case of Valley Crest Landscape v.
City Council (1996) 41 Cal.App.4th 1432, 1439, ruled that the requirement to state the
"portion" of work is satisfied by describing the type of work, it does not need to be
quantified as a percentage. Nonetheless, the Town and many other agencies require
percentages to be listed even though not required by state law. The reason for this is
simple: almost all public works contracts require the prime contractor (the bidder) to
perform a minimum percentage of the work themselves. Listing of percentages of
subcontractors allows this requirement to be easily and accurately verified. On this
contract, the Town required the prime contractor to perform a minimum of 30% of the
work.
The second part of the legal framework that is necessary to evaluate the bid protest is
how to review a bid that contains a mistake or error. While the results in different cases
will vary depending on the facts of the case, the following is a standard explanation of
how this type of situation is evaluated by the courts:
August 12, 2025
Page 3
"A basic rule of competitive bidding is that bids must conform to specifications, and that
if a bid does not so conform, it may not be accepted. [Citations.] However, it is further
well established that a bid which substantially conforms to a call for bids may, though it
is not strictly responsive, be accepted if the variance cannot have affected the amount of
the bid or given a bidder an advantage or benefit not allowed other bidders or, in other
words, if the variance is inconsequential. Ghilotti Construction v. City of Richmond (1996)
45 Cal.App.4th 897, 904.
Legal Analysis
Within this framework, Town staff analyzed the Goodfellow bid and the Bay Cities bid
protest in the following manner.
First, the Town believes that the Goodfellow bid does meet the specifications in the
request for bids. Referring back to the directions found in the "Note" on the
Subcontractor List, those directions read: "On the Subcontractor List you may either
submit the bid item numbers, and the percentage of each item subcontracted with your
bid or email the information to engineering@idanville.ca.gov" (italics added).
This language clearly gives the bidder two choices of how to provide the percentages of
work for each bid item. More importantly, the Note does not specify that if a bidder elects
the second option (emailing the information) when they must do so. If the Note gave a
specific deadline for that option, it might lead to a different conclusion. As an example
of this, in the case of DeSilva Gates Construction, LP v. Department of Transportation (2015)
242 Cal.App.4th 1409, 1413 (a case cited by the Bay Cities attorney), the court noted that
the Caltrans form for subcontractors included the following language: "On the
Subcontractor List you may either submit each subcontracted bid item number and
corresponding percentage with your bid or fax these numbers and percentages to (916) 227-
6282 within 24 hours after bid opening. Failure to do so results in a nonresponsive bid.
(italics included in original)" The Caltrans wording differs from the Town's in two ways:
1) there is a specific deadline to submit; and 2) failure to do so is specifically called out as
making the bid nonresponsive.
Finally, as stated above, the reason to require percentages of work to be performed by
subcontractors is to allow the Town to determine if the prime contractor will be
performing at least 30% of the overall bid. That could be determined by the original
submittal without reference to the additional percentage breakdown provided by
Goodfellow.
Second, assuming the manner in which Goodfellow submitted their bid did not comply
with the required specifications, it is then necessary to turn to the question of whether
the mistake was consequential. The courts look to the following factors:
August 12, 2025
Page 4
• Did the error affect the amount of the bid? No, it did not. The total Goodfellow bid
did not change based on the additional information submitted.
• Did it give Goodfellow an advantage or benefit not allowed other bidders? No, it did not.
As stated previously, the reason for this information is to determine that the prime
bidder is performing the required minimum amount of work. They are doing so
and Town staff was able to determine that on July 15, the date the bids were
opened. In addition, as stated above, Goodfellow was not the only bidder to
complete the form in this manner. Finally, unlike the Valley Crest case discussed
in more detail below, the Goodfellow bid did not provide a basis for Goodfellow
to seek relief from their bid under Public Contract Code Section 5103.
The legal argument submitted by Bay Cities relies on two cases, neither of which is
parallel to our current bid. The first case is the Valley Crest case, cited above. In that case,
the apparent low bidder listed subcontractors doing a total of 83% of the total job. This
presented a problem because the contract specifications called for the prime contractor to
perform a minimum of 50% of the work. After the second low bidder (Valley Crest)
pointed this out, the low bidder resubmitted their list of subcontractors, now showing
only 44.65% of the work being subcontracted. The court of appeal found that percentages
of subcontractors was a material element of the bid and that the numbers could not be
changed after the fact. The court also based its decision on the fact that because the low
bidder said their initial bid was a "mistake" they could have sought relief from the bid
pursuant to Public Contract Code Section 5103, thereby giving that bidder an advantage
over other bidders.
In our situation, Goodfellow did not change contractors or the bid items on which
subcontractors will work, did not claim that they had made a mistake and certainly made
no material changes in work as occurred in Valley Crest. All they did with their July 22
submittal (Exbibit 4) was to provide a different manner of looking at the numbers -a
percentage of the overall job or a percentage of each bid item to be subcontracted. The
table contained on page 4 of the letter from Bay Cities' attorney is a clear misstatement of
the facts. It implies that subcontractors who were listed in the bid at 1 or 2% of the work
are now doing 100% of the work. This is simply not the case and is thus fundamentally
different than the situation in the Valley Crest case.
The second case relied upon by Bay Cities is DeSilva Gates Construction, LP v. Department
of Transportation (2015) 242 Cal.App.4th 1409, but again that case factually has no bearing
on the Goodfellow bid. In DeSilva, the issue arose from DeSilva submitting a second list
of subcontractors within 24 hours after bids were opened and that list containing a
subcontractor that had not appeared on the initial list in the bid packet. That additional
subcontractor was not listed on the initial submittal because the amount of work they
were doing fell below the legal threshold. The court of appeal found that this was not a
legally adequate basis to disqualify the DeSilva bid.
August 12, 2025
Page 5
To summarize, the mistake in the Goodfellow bid, if any, was that in their bid submittal
they listed subcontractor percentages as a percent of the total bid rather than per bid item.
This did not provide them with any advantage over other bidders nor did it change the
amount of their bid nor prejudice any other bidder. Given all of that, Town staff
concludes that it is within the Town Council's discretion to reject the Bay Cities protest
and award the contract to Goodfellow.
The Town staffs analysis can be summed up by the following statement from the case of
Judson Pacific -Murphy Corp. v. Durkee (1956) 144 Cal.App. 2d 377, 383, a statement which
is still frequently cited in these types of cases: "It certainly would amount to a disservice
to the public if a losing bidder were to be permitted to comb through the bid proposal or
license application of the low bidder after the fact, [and] cancel the low bid on minor
technicalities, with the hope of securing acceptance of his, a higher bid. Such construction
would be adverse to the best interests of the public and contrary to public policy."
Exhibits: 1. Letter from Copeland Law Firm received 8/5/25
2. Subcontractor List (blank)
3. Subcontractor List submitted by Goodfellows with bid (page 1)
4. Subcontractor List submitted by Goodfellows 7/22/25
COPELAND LAW FIRM, APC
19201 Sonoma Hwy.. Suite 106
Sonoma. California 95476
August 5, 2025
Via Email & US Mail
Mr. Allan Shields
Town of Danville
500 La Gonda Way
Danville, CA 94526
ashields 4111111 \ ille.ca.aov
Dear Mr. Shields:
ofc: 424/234-9701
email: sbc@copelandlawpc.com
RE: Bay Cities Paving & Grading, Inc.'s Protest of Goofellow Bros.
of California, LLC's Bid on Contract C055
Please be advised this firm generally represents Bay Cities Paving & Grading, LLC. ("Bay Cities")
and has been forwarded the communications related to Bay Cities protest of Goodfellow Bros.
California, Inc.'s ("Goodfellow") bid on Contract C055 ("Project"). This letter serves as Bay
Cities' response to your email dated August 5, 2025.
There is no doubt that Goodfellow's bid was non-compliant with the Project bid requirements
insofar as Goodfellow's bid failed to accurately or compliantly list subcontractor percentages as
required in the bid documentation. Bay Cities' position in that regard is best set forth in Mr.
Manqueros' letter dated July 21, 2025, which I incorporate herein without the need to reassert those
contentions. What is now more concerning to me are the two City of Danville ("City") actions
since receiving Bay Cities' protest, both of which evidence further proof that Goodfellow's bid was
non-responsive and that since receiving that bid, the City has now granted favoritism to
Goodfellow which constitutes an unwaivable aspect of the non-responsive bid. Under both
circumstances, the City is obligated to either award the Project bid to Bay Cities or, alternatively,
to throw out all bids.
Controlling Law Holds Goodfellow's Bid Non -Responsive, and the City May Not Waive the
Mistake
Your email attached an undated Administrative Staff Report which claimed, among other things,
that Goodfellow's error was inconsequential and thus waivable by the City, despite Mr.
Manqueros' July 21, 2025 letter proving Goodfellow's bid was unwaivably non-responsive. The
City's Staff Report is absolutely an incorrect interpretation of both the law and the facts.
Public Contract Code §4104 expressly requires each trade of work subcontracted by Goodfellow
to have been listed in detail in its bid. And as if Section 4104 was not specific enough, the City
added requirements in Section 2-1.10 of the Project bid documents mandating all bidders list their
subcontractor's name, address, license number, public contracting registration number, and for the
portion of work each subcontractor was performing, to list the "Bid item numbers for the
subcontracted work ... [the] Percentage of the subcontracted work for each bid item listed ... [and
a] Description of the subcontracted work if the percentage of the bid item listed is less than 100
percent."
California courts have consistently thrown -out contracts issued by azencies to bidders who have
failed to list both the amount or the proper scope of a subcontractor, since both are violations
of the listing laws. As the court explained in Valley Crest Landscape, Inc. v. City Council, (1996)
41 Cal.App.4th 1432, "listing the subcontractor percentages is a material element of the bid"
which cannot be waived by the owner. And in the that case, the court found the agencv's award
of the contract to the low bidder to be illegal where the agency allowed the low bidder. "to
correct the mistake in stating the [subcontractor] percentages," as allowing that action gave the
low bidder an unfair advantage not allowed of the other bidders. Again, in DeSilva Gates
Construction, LP v. Department of Transportation, (2015) 242 Cal.App.4th 1409, the court
specifically held, "As part of a responsive bid, bidders on public construction contracts must
list subcontractors who will provide work above a certain threshold amount ... deceptive
[bids are ones which] indicated [a] ... shift of work from a subcontractor to [a different
contractor or a second-tier contractorl."
Under both Valley Crest Landscape, Inc. and under DeSilva Gates Construction, LP, Goodfellow's
failure to list the percentages according to the instructions makes Goodfellow's bid de -facto and
de jure non-responsive. Moreover, despite the City's requirement for contractors to issue a,
"Description of the subcontracted work if the percentage of the bid item listed is less than 100
percent," Goodfellow did not do so with its July 22, 2025 email. This is not a waivable bid
irregularity. If the City awards the contract to Goodfellow, the City is ignoring controlling caselaw
and a court will be called upon to throw out such an illegal award.
The City's decision to rely on the case of Ghilotti Construction v. City of Richmond, (1996) 45
Cal.App.4th 897 is evidence the City does not understand the controlling law cited above. The
issue in the Ghilotti case was whether the City of Richmond's specifications allowing for a higher
percentage of DBE subcontracting was in conflict with the incorporated Caltrans specifications on
the same issue and thus, whether the low bid which exceeded Caltrans' limits but not the City's
rendered the bid non-responsive. Those facts and the resulting holding are inconsequential to the
issue with Goodfellow's bid on this project. The case the City relies on is actually inapposite to
the facts here, which are instead controlled by the Valley Crest Landscape, Inc. and DeSilva Gates
Construction, LP cases whose facts and law are directly on point.
Goodfellow's mistake is not inconsequential and is not waivable as a matter of law. Moreover,
the mistake of failing to list the specific "Description of the subcontracted work if the percentage
of the bid item listed is less than 100 percent" has not been addressed by Goodfellow's July 22,
2025 email and cannot be corrected post -bid -deadline in any event.
Controlling Law Renders the City's Post -Bid Actions Illegal Favoritism Granted to
Goodfellow
As required by law, the bid gave all bidders a deadline to turn in all bid documentation — here, the
deadline was listed as July 15, 2025 by 2:00 pm. Despite this legal cutoff, a day after receiving
Bay Cities' protest letter, and undoubtedly as a result of that letter, the City then immediately
contacted Goodfellow with the content of Bay Cities' protest, with the City allowing Goodfellow
to then submit an email listing the correct information related to subcontracting percentages,
apparently still not complying with Section 2-1.10 as at no point did the email nor bid describe the
work being performed by the subcontractors for subcontracted work for any bid item less than 100
percent.
Yet by allowing for the attempted correction in the first place, the City absolutely granted
Goodfellow favoritism by allowing Goodfellow to correct its bid mistake ex post facto over a week
after the mandatory bidding deadline. In Goodfellow's July 22, 2025 email, it cited to "Section 2-
1.33A" as allowing for the submission of subcontractor percentages by email. That Section of the
Bid Documents does not allow for such submission after the mandatory bid cutoff, and the City's
allowance for Goodfellow to do so coupled with the City relying on that correction to determine
the bid is now responsive is illegal.
Under California law, a bid is non-responsive as a matter of law when either of the following is
present:
1. The irregularity in a bid gives that bidder an unfair advantage over other bids or if
it gives that bidder a last look at the other bids after the bid closing date in deciding
whether to honor the bid; or
2. Given that there is an irregularity in the low bid, waiving the irregularity would
constitute favoritism to the non-responsive bidder. See, Valley Crest Landscape,
Inc. v. City Council, (1996) 41 Cal.App.4th 1432; MCM Constr. v. City & County
of San Francisco, (1998) 66 Cal.App.4th 359; Ghilotti Constr. Co. v. City of
Richmond, (1996) 45 Cal.App.4th 897; Monterey Mechanical Co. v. Sacramento
Reg'l County Sanitation Dist., (1996) 44 Ca1.App.4th 1391.
It is in those second series of cases that the City's post bid conduct falls. As the court explained
in Valley Crest Landscape, Inc., a bid is non-responsive when it has "given the bidder an advantage
or benefit not allowed other bidders," and the court found the agency's award of the contract to
the low bidder to be illegal where the agency allowed the low bidder, "to correct the mistake" as
allowing that action gave the low bidder an unfair advantage not allowed of the other bidders.
Here, the City has admitted to allowing Goodfellow to correct its mistakes. The following is a
table showing the percentages subcontracted as listed in the bid versus the percentages listed in
the post -bid closing July 22, 2025 email:
SUBCONTRACTOR NAME BID ITEM PERCENTAGE LISTED IN BID PERCENTAGE LISTED IN EMAIL
All Commercial Fence Inc. 9a 2.44% 69.30%
9b 2.44% 100%
Case Pacific 18a 16.92% 33.70%
19 16.92% 27.70%
Dirt & Aggregate Interchange, Inc. 20 1% 100%
Evergreen Engineering &
Excavation 6 1.64% 100%
9a 1.64% 15.80%
7a 1.64% 77.60%
Farwest Safety 33 0.42% 100%
Golden Bay Fence 34 4.51% 100%
McGuire & Hester, Inc. 16 2.54% 41.80%
26a 2.54% 100%
26b 2.54% 100%
26c 2.54% 100%
26d 2.54% 100%
27 2.54% 100%
31 2.54% 100%
37 2.54% 100%
Pacific Northwest Oil 25a 1.88% 100%
Retainning Wall Co. 17 1.66% 100%
SSEC 8 0.15% 60%
28 0.15% 100%
29 0.15% 100%
TDW Construction Inc. 1 9.93% 6.40%
12a 9.93% 100%
12b 9.93% 85%
13a 9.93% 100%
13b 9.93% 100%
14a 9.93% l00%
14b 9.93% 100%
15 9.93% 2.50%
21 9.93% 68.20%
30
9.93% 100%
Very clearly, Goodfellow, with the City's blessing, changed the percentage of each and every item
of work for each and every listed subcontractor — a material change and one which the City has
granted as a favor to Goodfellow to determine the bid to be responsive. This is a clear violation
ofthe law and will not pass court muster. And yet even with that correction, there are 11 categories
where less than 100% of the work of a bid item is being performed by the listed subcontractor and
no description of the work being performed by those subcontractors is provided by Goodfellow in
its July 22, 2025 email, keeping its illegally corrected bid non-responsive.
Goodfellow's bid must be held non-responsive, and the correction of the mistakes therein may not
be accepted by the City post bid submission deadline.
Bay Cities' bid is the lowest responsive bid as Bay Cities stands by its commitment to perform the
Project work once the contract is awarded to Bay Cities.
Best regards,
COPELAND L
By.
Steven B. ". - an.
Subcontractor List
The Bidder shall list the name and address of each subcontractor to whom the Bidder proposes to
subcontract portions of the work in an amount in excess of one-half of one percent of the total bid or
$10,000, whichever is greater, in accordance with the Subletting and Subcontracting Fair Practices
Act, commencing with Section 4100 of the Public Contract Code, and as required by the provisions
in Section 2.1.01, "General," of the Special Provisions. In accordance with California Public Contract
Code Section 4104, State contractor licenses shall be listed for all subcontractors.
Note: Replace the second paragraph of Section 2-1.33A "General" of the Standard Specifications
with the following: "On the Subcontractor List you may either submit the bid item numbers,
and the percentage of each item subcontracted with your bid or email the information to
engineering@danville.ca.gov".
Subcontractor Business Name Subcontractor Business Name
Email address: Email address:
Street Address Street Address
City County City County
State Zip State Zip
Description of Work to be Subcontracted Description of Work to be Subcontracted
California State Contractor License No(s). California State Contractor License No(s).
DIR Registration No. DIR Registration No.
°/U
Bid Item No(s). Percentage Bid Item No(s).
(See Note Above) (See Note Above) (See Note Above)
Percentage
(See Note Above)
Subcontractor Business Name Subcontractor Business Name
Email address: Email address:
Street Address Street Address
City County City County
State Zip State Zip
Description of Work to be Subcontracted Description of Work to be Subcontracted
California State Contractor License No(s). California State Contractor License No(s).
DIR Registration No. DIR Registration No.
%
Bid Item No(s). Percentage Bid Item No(s). Percentage
(See Note Above) (See Note Above) (See Note Above) (See Note Above)
(Attach additional sheets if needed)
P-5
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EXHIBIT A
Subcontractor List
The Bidder shall list the name and address of each subcontractor to whom the Bidder proposes to
subcontract portions of the work in an amount in excess of one-half of one percent of the total bid or
$10,000, whichever is greater, in accordance with the Subletting and Subcontracting Fair Practices
Act, commencing with Section 4100 of the Public Contract Code, and as required by the provisions
in Section 2.1.01, "General," of the Special Provisions. In accordance with California Public Contract
Code Section 4104, State contractor licenses shall be listed for all subcontractors.
Note: Replace the second paragraph of Section 2-1.33A "General" of the Standard Specifications
with the following: "On the Subcontractor List you may either submit the bid item numbers,
and the percentage of each item subcontracted with your bid or email the information
to engineering a@danville.ca.gov".
We.V i`%('r fir)-1ireet2 (r<i y Cwvat-i On 1DvJ NIngizIAC-Vi On MC
Subcontractor Business Name Subcontractor Business Name
Email address:-� -S F Q,Vtt-oveel) - IAS PGi1. C'Itmail address: Liti i(t -{tr'VtltHOn
211- fa f-Oc(d
Street Address
than J oact i
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State Zip
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Description of Work to be Subcontracted
VAPID -4 IP
Street Address
C
County
C1465 D
California State Contractor License No(s).
ISM 043 -134 --
LIR Rcyistratiun NO.
`•
Bid Item I.1o(s). Percentage
(See Note Above) (See Note Above)
CrILAWA2Lf.C1I fella. Inc
Subcontractor Business Name
Email address:
Po Boy, lnG
et Address
f0E-d
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State
Ct
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County
Zip
Description of Work to be Subcontracted
co o3b
California State Contractor License No(s).
1o1)DC7-44`?-:? t9
DIR Registration No.
CIA-, 8
Bid Item No(s).
(See Note Above)
(Attach additional sheets
Percentage
(See Note Above)
if needed)
P-5
State Zip
1kndet ‘2ouhd
Description of Work to be Subcontracted
444 14
California State Contractor License No(s),
‘cO00Q5lP00
DIR Registration No.
I I l ISO, 1.93 %
Bid Item No(sF. YtA,t4%)IS. Percentage
(See Mk Above) LI, SD (See Note Above)
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Subcontractor Business Name
Email address:
cioo9 12Aii42oadROL
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County
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State Zip
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q57-3-9
California State Contractor License No(s).
100000005'5
DIR_Registration No.
l Lf;']] ►'� �a — 21713,
Bid Item No(s).
(See Note Above) SI
2.5`j' %
Percentage
(See Note Above)
•COM
C-055 DIABLO ROAD PEDESTRIAN TRAIL AND DRAINAGE IMPROVEMENTS PROJECT
Goodfellow Bros. California LLC
SUBCONTRACTOR LIST
SUBCONTRACTOR
BID ITEMS
% OF ITEMS SUBCONTRACTED
All Commercial Fence Inc.
9a, 9b
139.3, 100
Case Pacific
18a, 19
33.7, 27.7
Dirt & Aggregate Interchange Inc.
20
100
Evergreen Engineering & Excavation
6, 9a, 7a
100, 15.8, 77.6
Farwest Safety
33
100
Golden Bay Fence
34
100
McGuire & Hester
16, 26a, 26b, 26c, 26d, 27,
37, 31
41.8, 100, 100, 100, 100, 100, 100
Murga, Strange & Chalmers Inc
12b, 15, 35, 36
1.4, 59.9, 33.8, 100
Pacific Northwest Oil
25a
100
Retaining Walls Co
17
100
SSEC
8, 28, 29
60, 100, 100
TDW Construction Inc.
1, 12a, 12b, 13a, 13b, 14a.
14b, 15,
21,
30
6.4, 100, 85, 100, 100, 100, 100, 2.5,
68.2,
100
1/00;4