Philips Bros. Electrical Contractors, Inc. v. Pennsylvania Turnpike Commission

DISSENTING OPINION BY

Judge SMITH-RIBNER.

I strongly dissent from the majority’s decision to dismiss as premature Philips Brothers Electrical Contractors’ (Philips Brothers) petition for review of the final determination by the Pennsylvania Turnpike Commission denying as unripe Philips Brothers’ protest to notice of the planned solicitation for bids to construct the Commission’s Plymouth Meeting Maintenance Facility (Facility). Although the majority *947agrees that the matter is adequately developed for judicial review, it nevertheless dismisses the petition for review because in its view Philips Brothers will suffer no harm if review is delayed until bids are solicited and a second protest is filed in accordance with the Commonwealth Procurement Code, 62 Pa.C.S. § 1711.1. The Commission correctly treated Philips Brothers as a prospective bidder under Section 1711.1(a), (b), requiring protests to be filed prior to a bid opening date or proposed bid receipt date. It also treated the protest as ripe for purposes of discussing the merits and ruling against Philips Brothers.

In the determination denying the protest, the Commission’s Deputy Chief Counsel described the wholesale relocation of the Facility from its present location next to the Plymouth Meeting Mall to a more remote area more easily connected to the Pennsylvania Turnpike. The Facility will consist of a building to house an office, a lunchroom and employee restroom/locker room; a vehicle repair area; a separate building for storage of materials used by tradesmen; a salt dome and mixing area; a truck garage; and a gas fueling area. In its September 14, 2007 letter to counsel for Philips Brothers, the Commission stated that the “bid for [the proposed construction] is for a single, general contractor because the buildings to be constructed under this contract are not public buildings.” Reproduced Record at 28a. The Commission acknowledged that bids will be solicited in the last quarter of 2008. Based on its notice of the $20 million project, Philips Brothers protested that the proposed construction bidding process was in violation of the Separations Act, 71 P.S. § 1618, inasmuch as the proposed construction included erection of public buildings, and separate bids for prime contractors were required by law.

In analyzing the matter, the Deputy Chief Counsel stated that the first question to be answered in determining whether the Separations Act applies is whether the proposed construction is on Commonwealth owned property, and if the answer is yes then the next question to be answered is whether the construction is for a “public building.” The Deputy Chief Counsel noted that the Separations Act did not define the term public building, and he then resorted to review and interpretation of prior decisions (Tragesser v. Cooper, 318 Pa. 10, 169 A. 876 (1933), and Mechanical Contractors Association v. Senior Citizen Health Care Council, 674 A.2d 752 (Pa. Cmwlth.1996)) to conclude that the Facility, albeit to be funded with $20 million of taxpayer dollars, is not a public building because among other things “the public is not encouraged nor invited to stop. Having the public in and around the facility is an invitation to trouble and even injury. Even the signs to the yards note that access is via ‘Private Drive.’” Deputy Chief Counsel’s Decision, at 5. He indicated that there are some buildings owned by the Commission and opened to the public, such as service plazas or police barracks, but eventually all interchange buildings will not be public buildings.

Despite having concluded that the proposed $20 million construction would not include “public buildings,” the Commission held that the protest should be denied because Philip Brothers’ claim was not ripe and even if its claim was ripe it lacked merit based upon the conclusion already reached by the Commission. Under these circumstances, there is absolutely no logical basis for holding that this matter is not ripe for review by the Court when the Commission has decided the merits going to the very heart of the protest, i.e., that the Separations Act does not apply as the $20 million proposed construction does not include public buddings. Section 1618 of *948the Separations Act mandates that when the entire cost of the construction of any public building exceeds $4000 “it shall be the duty of the architect, engineer, or other person preparing such specifications, to prepare separate specifications for the plumbing, heating, ventilating, and electrical work; and it shall be the duty of the person or persons authorized to enter into contracts for the erection, construction ... of such public buildings to receive separate bids upon each of the said branches of work, and to award the contract for the same to the lowest responsible bidder for each of said branches.” The Commission has determined based on its interpretation that it can avoid the Separations Act and can proceed to solicit single, general contractor bids for the project.

Requiring Philips Brothers to file a second protest after a solicitation would be mere formality and a waste of agency and judicial time and energy. I readily agree that the ripeness doctrine is intended to avoid judicial involvement in abstract disagreements, Gardner v. Commonwealth of Pennsylvania, Department of Environmental Resources, 658 A.2d 440 (Pa. Cmwlth.1995), but the doctrine is not to be applied to avoid ruling on the merits of a matter where the issues are sufficiently formulated and concrete so as to allow for judicial review. Philip Brothers’ position “has crystallized to the point at which [the] court can identify [the] relatively discrete dispute.” Texas Keystone Inc. v. Pennsylvania Department of Conservation and Natural Resources, 851 A.2d 228, 239 (Pa. Cmwlth.2004). The majority has erred in ruling otherwise.

The Pennsylvania Supreme Court’s recent reversal of this Court in Township of Derry v. Pennsylvania Department of Labor and Industry, 593 Pa. 480, 932 A.2d 56 (2007), should offer some guidance when deciding whether to dismiss petitions for review as unripe. In Township of Derry this Court dismissed as unripe the appellant’s petition for review challenging the Department of Labor and Industry’s regulations that implemented an overly broad construction of the term “state-owned buildings” to include the buildings at the Milton S. Hershey Medical Center located in the township. The appellant argued that the regulations along with application of the Pennsylvania Construction Code Act, Act of November 10, 1999, P.L. 941, as amended, 35 P.S. §§ 7201.101— 7201.1103, effectively displaced the ability of municipalities to review and to approve construction plans, to issue budding permits and to collect fees with regard to the construction of certain non-Commonwealth buildings. The appellant identified particular construction projects at the Medical Center where local ordinances had not been followed. This Court declined to address issues raised in preliminary objections filed by the Department and the Medical Center based on application of the ripeness doctrine. It then dismissed the appellant’s petition for review with prejudice.

The Supreme Court reversed. It agreed - with this Court’s statement in Township of Derry that when determining whether a matter is ripe for judicial review courts generally consider whether the issues are adequately developed and whether hardship will ensue to the parties if review is delayed. This Court also stated that under the hardship analysis, it might nonetheless address the merits even when a case is not as fully developed as the Court would like where declining to address the merits could place a demonstrable hardship upon a party, citing Alaica v. Ridge, 784 A.2d 837 (Pa.Cmwlth.2001). Notwithstanding its agreement with this statement of the ripeness doctrine, the Supreme Court held that this Court erred in dismissing the petition on ripeness grounds where allegations of the appellant’s petition reflect an actual and ongoing *949controversy and in considering hardship it is enough that the appellant has alleged major, ongoing construction activity being conducted within its borders outside of the local ordinance process.

I cite another reversal by the Supreme Court in Insurance Federation of Pennsylvania, Inc. v. Commonwealth of Pennsylvania, Insurance Department, 586 Pa. 268, 893 A.2d 69 (2006). In its original decision in the case, a majority of this Court dismissed the petition for review challenging an Insurance Department notice interpreting sections of the law regarding mandates against group health plans to provide certain treatment to patients who receive certification and referral from a licensed physician or psychologist. A majority of this Court concluded that adequate post-enforcement statutory review process existed and that the dispute was not ripe for judicial intervention. The dissent disagreed that the matter was not ripe for review, and on appeal from the dismissal the Supreme Court vacated this Court’s order and remanded the case for this Court to consider the merits.

The Supreme Court’s reversals of this Court along with observation of the appropriate standard of review in Township of Derry make it evident that the Commission’s determination of Philip Brothers’ protest is ripe for judicial review. An actual and ongoing controversy exists inasmuch as the Commission determined that the proposed $20 million construction will not involve public buildings and that it will proceed with solicitation of bids from single, general contractors rather than solicitations as mandated under the Separations Act. There are no disputed facts; rather, the matter merely requires application of case law to determine whether the Commission was correct in its self-created definition of “public buildings” to avoid application of the Separations Act. Also, the determination harms Philips Brothers, a public works electrical contractor, because it cannot bid on the project under any circumstance. It is not a general contractor.

As the Supreme Court acknowledged in Township of Derry the harm occasioned there was the ongoing construction activity in the municipality outside of the local ordinance process. Here, the demonstrable harm to Philips Brothers is clear. I note also that putting off for another day resolution of the merits will only generate unnecessary litigation and added costs to the taxpayers. Thus because an actual and ongoing controversy exists, Philips Brothers properly filed its protest as allowed under Section 1711.1(b) and it will be demonstrably harmed by the Court’s failure to decide the merits, I strongly dissent from the decision to dismiss the petition for review as unripe.