BILL ANALYSIS                                                                                                                                                                                                    






           SENATE TRANSPORTATION & HOUSING COMMITTEE       BILL NO: AB 2620
          SENATOR ALAN LOWENTHAL, CHAIRMAN               AUTHOR:  Eng
                                                         VERSION: 6/22/10
          Analysis by: Art Bauer                         FISCAL:  yes
          Hearing date: June 29, 2010







          SUBJECT:

          Department of Transportation: capital outlay support services

          DESCRIPTION:

          This bill changes the overhead rate that the Department of  
          Transportation (Caltrans), charges for reimbursed work it  
          performs for local agencies or private entities. 

          ANALYSIS:

          Existing law authorizes Caltrans to recover its direct and  
          indirect costs for capital outlay support services it performs  
          for local agencies or private entities, except when Caltrans  
          performs work on the State Transportation Improvement Program  
          (STIP). Existing law exempts STIP projects from being charged  
          indirect costs. 

           This bill  :

             1)   Defines "capital outlay support" to mean services  
               related to project development, including development of  
               specifications, preliminary engineering, prebid services,  
               preparation of project reports and the environmental  
               documents, design service, preparations of plans,  
               specifications and cost estimates, construction inspection  
               and management services, surveying and materials testing,  
               and related functions. 

             2)   Defines "indirect overhead cost" to mean the pro rata  
               share of existing administrative salaries and benefits,  
               rent equipment cost, utilities, and materials.





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             3)   Requires a public agency or a private entity to  
               reimburse Caltrans for staff salaries and benefits for  
               staff needed to perform capital outlay support (COS)  
               services, as well as for the cost of administration  
               directly related to the function, such as space, equipment,  
               and required materials. 

             4)   Denies Caltrans reimbursement for indirect overhead  
               costs unless the cost can be attributed solely to the  
               capital outlay support functions and would not exist if  
               Caltrans did not perform that function. 

             5)   Requires an agency or an entity to reimburse Caltrans  
               when Caltrans uses a contractor to provides capital outlay  
               support services for the cost of the contractor plus costs  
               directly associated with the contracted function, including  
               but not limited to, advertising and awarding the service  
               contract, inspection, supervision, and monitoring of the  
               contractor.
          
          COMMENTS:

              1)   Purpose  . According to the sponsors, the Professional  
               Engineers in California Government (PECG), Caltrans is  
               unnecessarily charging local and regional agencies overhead  
               and administrative costs that are not related to the  
               delivery of COS services associated with designing highway  
               improvements. PECG argues that for reimbursed work Caltrans  
               is currently charging local and regional authorities for  
               all Caltrans' administrative costs, including charges for   
               building depreciation, bond interest charges, audits, and  
               multiple other items unrelated to state highway project  
               delivery.   

              2)   Overhead rates  . Federal guidelines require that projects  
               funded with federal gas tax revenues are charged the  
               "functional" overhead rate and the rate for indirect costs.  
               The functional overhead costs are associated with a  
               specific function, such as COS.  Annually, the Department  
               of Finance and the Federal Highway Administration approve  
               Caltrans' direct and indirect overhead rates. When  
               performing COS services on projects funded with local  
               funds, Caltrans charges local agencies both the functional  
               rate, as well as for the indirect costs associated with  
               operating Caltrans. By not charging the indirect cost for  
               reimbursed work, the state would be subsidizing local  




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               agencies. Moreover, if Caltrans does not charge the rate  
               for indirect costs for reimbursed work, the federal  
               government will not reimburse the state for those costs. 

              3)   Costs are real money  . This bill exempts indirect costs  
               related to the overall management and operation of  
               Caltrans, including legal, personnel, civil rights, audits,  
               space charges, and other similar costs, from being charged  
               to public agencies or private entities if they contract  
               with Caltrans for COS services. It is a customary  
               accounting practice in any enterprise, public or private,  
               to allocate overhead costs across all functions of the  
               organization. By exempting public agencies or private  
               entities from paying the indirect costs, the bill offers an  
               incentive to those entities to retain Caltrans to provide  
               COS services and not to retain private engineering firms.  
               The exempted costs, however, do not go away. They are  
               charged to the other functions of Caltrans. 

               In end, this exemption reduces the amount of funds in the  
               State Highway Account that will be available to improve the  
               state's highway system. According to Caltrans, it received  
               nearly $66 million in reimbursements for indirect costs  
               associated with providing COS services in fiscal year  
               2008-2009. To exempt local agencies and a private entity  
               from reimbursing Caltrans for this cost means that the  
               State Highway Account will have to absorb the cost. State  
               highway funds are already at a premium. Caltrans indicates  
               that the minimum cost of performing rehabilitation work on  
               a state highway is approximately $240,000 per lane mile.  
               Failure to collect indirect overhead costs is equivalent to  
               approximately 275 line miles of highway not being  
               rehabilitated.  

              4)   Federal accounting issues  . The exemption from being  
               reimbursed for indirect costs may be contrary to federal  
               regulations governing cost allocation procedures for  
               agencies receiving federal highway revenues. If Caltrans is  
               out of conformity with federal accounting requirements,  
               remedial actions would have to be taken to bring the  
               department into conformity or the state not be reimbursed  
               for the costs. 

          Assembly Votes are not relevant.
               
          POSITIONS:  (Communicated to the Committee before noon on  




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          Wednesday, 
                     June 23, 2010)

               SUPPORT:  Professional Engineers in California Government  

               OPPOSED:  None receive.