Precision Environmental
4350 Transport St #109, Ventura, CA 93003
Email: [email protected]
Website: Precisionenv.com
Phone: 800-375-7786
DIR# 1000046051 - CSLB No. 480595
DOSH #1082 - SPCB PR7589 - NAT-21238-3
FORMAL RESPONSE TO BID
PROTEST - IFB No. 26-846 / City
Project No. 7859
City of Norwalk
Attn: Alex Hamilton, Deputy City Manager
12700 Norwalk Blvd Norwalk, CA 90650
Subject: Formal Response to Bid Protest – Precision Works, Inc. dba Precision Environmental PROJECT: Buildings Demolition Located at California Youth Authority Transit Village, 13200 Bloomfield Avenue, Norwalk, CA 90650; IFB No. 26-846 / City Project No. 7859
Dear Mr. Hamilton and City of Norwalk Purchasing Division:
Precision Works, Inc. dba Precision Environmental ("Precision Works") respectfully submits this formal response to the bid protest filed by Resource Environmental, Inc. ("REI") dated June 2, 2026 (received June 6, 2026).
Preliminary Matter: Consistent with applicable bid protest procedures, Precision Works respectfully requests that the City first determine whether REI's protest and supporting materials fully comply with all procedural requirements. This should be considered alongside the substantive issues below.
Precision Works fully complied with all requirements of the bidding process. This includes attendance at the mandatory pre-bid site visit, timely submission of all required forms and documentation, provision of the required bid bond, and accurate listing of subcontractors per the solicitation.
Prior to bid submission, Precision Works and its listed subcontractors thoroughly reviewed the bid documents, plans, specifications, and project requirements. Our bid was submitted in good faith and in strict accordance with the Instructions to Bidders, Contract Documents, and all applicable laws.
REI's protest is based largely on mistaken assumptions and speculative, hypothetical scenarios regarding post-bid modifications or allocations. Those assumptions are incorrect. Precision Works is not seeking to modify its bid, substitute subcontractors, revise pricing or scopes, claim self-performance in lieu of listed work, or cure any alleged defect. We stand firmly by our bid exactly as submitted and are fully prepared to perform the Project in accordance with the bid documents, subcontractor listings, and all statutory requirements.
Note on REI's Pattern: The City should be aware that REI has a practice of filing detailed but ultimately meritless bid protests against Precision Works and other low bidders on public demolition projects, often relying on hypothetical issues and strained interpretations of subcontractor listing and self-performance rules. Most recently, on the City of Commerce's Deconstruction of Commerce Refuse-to-Energy Facility (CREA) project (IFB 2026-BID1005), REI filed a similar protest on May 12, 2026. After review, City of Commerce staff (with City Attorney concurrence) and the City Council rejected REI's protest in full, determined Precision Works to be the lowest responsive and responsible bidder, and awarded the contract to Precision Works via Resolution No. 26-__ (June 23, 2026). REI's arguments here mirror those rejected in Commerce and should receive the same disposition. Accordingly, Precision Works maintains that its bid is both responsive and responsible and fully satisfies all requirements for contract award.
Attachment No. 3
Precision Environmental
4350 Transport St #109, Ventura, CA 93003
Email: [email protected]
Website: Precisionenv.com
Phone: 800-375-7786
DIR# 1000046051 - CSLB No. 480595
DOSH #1082 - SPCB PR7589 - NAT-21238-3
I. Precision Works' Bid is Fully Responsive
A. 50% Self-Performance Requirement (ITB § 33 & Form)
Precision Works fully complies. Our subcontractor listing form identifies subcontractors totaling approximately $1,276,863 (41.4% of the Total Bid). The remaining balance of approximately $1,837,437 (58.6%) will be self-performed with our own forces.
This self-performed work is fully authorized under our active CSLB licenses, including Class B (General Building) and C-21 (Building Moving and Demolition). The C-21 license specifically authorizes demolition, removal of structures, grading, and related work—precisely the scope required here. Our active DIR registration further supports lawful performance. The ITB does not require a line-by-line breakdown of self-performed work beyond the subcontractor listing. REI’s speculation regarding our capabilities and licensing is without merit.
B. Subcontractor Listing – JDK Demo (Pub. Contract Code §§ 4100–4114) On the subcontractor listing form, JDK Demo, Inc. is clearly listed for a defined and limited portion of the work:
“demolition, underground demolition and grading” at the specified amount/percentage, as permitted by the bid form. The balance of the demolition and deconstruction scope is properly reserved for self-performance under our C-21 license.
There is no overlap, ambiguity, or post-bid flexibility. The listing satisfies all requirements because JDK’s portion was clearly defined at bid opening. No bid shopping, improper substitution, or other violations of the Subletting and Subcontracting Fair Practices Act are occurring or intended.
Precision Works properly identified JDK Demo as the subcontractor for the designated portion of demolition and grading work to be subcontracted. The subcontractor designation does not represent that JDK will perform every demolition- or grading-related activity. Nor does it prohibit Precision Works from self-performing other work within those general trades using its own qualified workforce. Nothing in the bid documents required Precision Works to allocate every individual bid item exclusively between subcontracted and self-performed work at bid opening.
REI’s contention that Precision may later choose which work JDK performs (creating a “squeeze” or post-bid allocation) is entirely speculative and unsupported by the bid documents or law. Precision Works is not seeking to alter its subcontractor designation, increase or decrease JDK’s listed participation, substitute subcontractors, or modify its bid after opening. Our bid, as submitted, clearly identifies the subcontracted portion and demonstrates compliance with all applicable requirements.
C. Clerical Issues (Line Item 33 and ECTI DIR Registration) REI mischaracterizes minor, non-material clerical matters as defects.
The discrepancy in Line Item 33 was an obvious typographical error ($5.00 instead of $5,000.00). The bid documents expressly provide that, in the event of a discrepancy between words and figures, the amount written in words governs.
This is a classic minor irregularity waivable under Norwalk Municipal Code § 3.17.030(C)(4) and does not affect responsiveness or provide any competitive advantage.
FORMAL RESPONSE TO BID
PROTEST - IFB No. 26-846 / City
Project No. 7859
Precision Environmental
4350 Transport St #109, Ventura, CA 93003
Email: [email protected]
Website: Precisionenv.com
Phone: 800-375-7786
DIR# 1000046051 - CSLB No. 480595
DOSH #1082 - SPCB PR7589 - NAT-21238-3
The “N/A” entry for ECTI’s DIR number was an inadvertent clerical oversight. ECTI was properly registered with DIR at the time of bid submission, and its role is limited to transportation/hauling (not core construction work requiring listing under the threshold). Precision Works listed another qualified transportation subcontractor with full DIR details, confirming intent to comply. This does not violate Labor Code §§ 1725.5 or 1771.1 or render the bid nonresponsive.
These are not material variances affecting price, scope, or fairness. They do not trigger post-bid optionality under PCC § 5103 in a manner that advantages Precision Works.
II. Precision Works is a Responsible Bidder
Precision Works possesses the experience, equipment, personnel, financial capacity, bonding capacity, and licensing to successfully complete the Project. Founded in 1982, Precision Works has a long and successful history of performing comparable demolition, environmental remediation, and abatement projects for public agencies throughout California.
REI’s allegations regarding experience disclosure misread the solicitation, which required disclosure of public agency projects in excess of $500,000 that we are currently working on or have worked on in the past three years. We complied fully. We welcome any responsibility review or hearing and are prepared to provide detailed project references, safety records, financial statements, bonding documentation, and evidence of successful performance on similar work.
III. Conclusion
Precision Works submitted a clear, responsive, and highly competitive bid that fully complies with the Instructions to Bidders, Contract Documents, California law, and Norwalk Municipal Code.
The legal authorities cited by REI address situations involving material post-bid modifications or unfair advantages. Those authorities have no application here, as Precision Works has neither requested nor contemplated any such actions. The City’s evaluation must be based on the bid actually submitted—not on REI’s hypothetical scenarios.
For these reasons, Precision Works respectfully requests that the City reject REI’s protest, confirm Precision Works as the lowest responsive and responsible bidder (or, at minimum, properly evaluate all lower bids before considering REI), and proceed with contract award. We remain ready to execute the contract and furnish all required bonds and documentation immediately upon notice of award.
Christopher Ruiz
Vice President
Email: [email protected]
Cell: (949) 706-4234
Precision Works, Inc. dba Precision Environmental
Chris Ruiz
Chris Ruiz
Vice President
FORMAL RESPONSE TO BID
PROTEST - IFB No. 26-846 / City
Project No. 7859