Arkansas Administrative Code
Agency 168 - Arkansas Economic Development Commission
Rule 168.00.17-010 - Partnership for Public Facilities and Infrastructure Act Program
Current through Register Vol. 49, No. 9, September, 2024
I. Partnership for Public Facilities and Infrastructure Act
The Partnership for Public Facilities and Infrastructure Act (PPFIA), created by Act 813 of 20171, provides a framework by which public-private partnerships may be formed to expedite the timely and cost-efficient "development of"2 private projects for public infrastructure and government facilities. Specific legislative intent of the PPFIA is that:
* There is a public need for the timely acquisition, design, construction, improvement, renovation, expansion, equipping, maintenance, operation, implementation, and installation of public infrastructure and government facilities within the state that serve a public purpose;
* The public need for government facilities and public infrastructure may not be satisfied by existing methods of procurement or funding available to the state;
* There are inadequate resources to develop public infrastructure and government facilities for the benefit of citizens of the state, and there is demonstrated evidence that public-private partnerships can:
* promote the timely and cost-efficient development of public infrastructure and governmental facilities;
* provide alternative and innovative funding sources to governmental entities; and
* allow governmental entities to leverage and supplement the developmental cost of public infrastructure and governmental facilities through private funding and participation by the private sector in governmental incentive and tax programs that are not otherwise available to governmental entities; and
* The formation of public-private partnerships may result in the ability to develop private projects for public infrastructure and government facilities in a more cost-efficient and timely manner, resulting in increased benefits to the public safety and welfare of the citizens of the state and substantial cost benefits to the governmental entities and the public.
Only "responsible public entities (RPE)" 3 as designated by the Arkansas Economic Development Commission (AEDC) and the Arkansas Development Finance Authority (ADFA), may solicit "requests for proposals (RFP)"4 from "private entities" 5 for bids to develop "qualifying projects" 6 under the PPFIA. Unsolicited proposals will not be accepted for consideration under the PPFIA.
The summary below delineates the process (through execution of comprehensive agreements) that participants in the PPFIA shall follow as defined throughout these guidelines.
These guidelines have been developed to help public entities implement certain requirements of the PPFIA. The intent was to provide structure to the PPFIA without overly dictating process. In developing these guidelines, as required by § 22-10-502 18, the AEDC relied extensively on legislative intent specified in Act 813 of 2017, and best practices of other states which have implemented public-private partnership programs similar in nature to Arkansas's. Subsequent development of detailed rules, as required by § 22-10-503 19, which will implement application submittal, review, and approval procedures, will build upon these guidelines.
In the event that the PPFIA is amended in a manner that either conflicts with these guidelines or concerns material matters not addressed herein, the PPFIA shall solely govern. Projects initiated under these guideline must adhere to all current laws, rules, and guidelines.
The AEDC and ADFA may amend these guidelines, as necessary, under provisions of the Administrative Procedures Act, § 25-15-201 et seq.
Proposals which have technical, complex, or specialized information may require expert evaluation and review by third-party independent advisors and consultants to the RPE. The RPE may charge reasonable, nonrefundable fees to private entities to cover the costs of processing, reviewing, and evaluating any proposal under the PPFIA, including without limitation, reasonable attorney's fees and fees for financial, technical, or other advisors or consultants. RPEs shall ensure that advisors and consultants are licensed and certified to practice in good standing in Arkansas and have no fiduciary affiliation with the qualified project proposal submitted for review as evidenced by signed disclosure certifications.
Fees charged should not exceed the actual cost incurred by the RPE to conduct the necessary review of the proposal. RPEs must identify the fee or fee schedule to be applied, including methodologies used, in the PPFIA application and RFP solicitation to ensure that private entities considering an RFP response are aware of the fees associated with the review.
The RPE should perform a periodic cost review of their review fees and methodologies to ensure that they are accurate and reasonable. Data from public-private partnership projects in Arkansas and elsewhere in the United States may be utilized. Although specific costs to review individual PPFIA proposals will vary by project type, using a fee schedule based on quantitative data from historic projects should provide reliable guidance.
A private entity assumes all risks in submission of a proposal. An RPE shall not incur any obligation to reimburse a private entity for any costs, damages, or loss of property incurred in the creation, development, or submission of a proposal for a qualifying project.
The PPFIA specifically addresses certain legal issues that may arise during the development of a qualifying project. RPEs should consult with their legal counsel to confirm compliance with any legal issues arising during the development of PPFIA qualifying projects. Below are specific PPFIA references to some of these major issues.
A public entity may exercise its right of eminent domain under applicable law in connection with the development of a qualifying project. The power of eminent domain shall not be delegated to a private entity with respect to a qualifying project commenced or proposed under the PPFIA. Damages awarded to a third party in an eminent domain action may be included in the development budget for the qualifying project.
An RPE may dedicate any real or personal property interest, including land, improvements, and tangible personal property, through lease, sale, or otherwise, to the qualified respondent to facilitate a qualifying project if so doing will serve the public purpose of the PPFIA.
The PPFIA does not waive the sovereign immunity of a public entity or the officers or employees of the public entity under state law; or extend a public entity's sovereign immunity to any private entity.
This PPFIA does not abrogate the obligation of an RPE to comply with the Freedom of Information Act of 1967, ACA § 25-19-101 et seq. However, records that would otherwise be exempt from disclosure under the Freedom of Information Act, including without limitation confidential and proprietary information, remain exempt when in the custody or control of a public entity, the Chief Fiscal Officer (CFO) of Arkansas, or the Governor.
Records related to a qualifying project that are provided to or compiled or developed by a public entity, the CFO of Arkansas, or the Governor in furtherance of the entity's or officer's powers, duties, or obligations under the PPFIA are exempt under ACA § 25-19-105(b)(9)(A) as files that would give an advantage to competitors or bidders.
Private entities and RPEs may utilize any funding sources legally available to them including without limitation issuing debt, equity, or other securities or obligations, entering into leases, tax credits, operating revenues, accessing designated trust funds, and borrowing or accepting grants from any state, federal, or private source. However, any bonds issued by an RPE under the PPFIA:
The expenditure of state funds in support of an interim or comprehensive agreement requires legal appropriations prior to expenditure of funds.
Any comprehensive agreement entered into by an RPE may include terms and conditions specific to the procurement of services or materials related to the qualifying project. In selecting a qualified respondent, ACA § 19-11-801 et seq.20 applies. Competitive bidding shall not be used. Procurements related to the development of a qualifying project are exempt from any procurement laws that are not contained in the PPFIA or any rules promulgated under the PPFIA that would otherwise apply to the responsible public entity.
Any legal uncertainty or challenge to any aspect of the authorization and implementation of a public-private partnership seriously undermines the ability to attract private sector participation and impairs the timely implementation of public projects. A lawsuit brought concerning the validity of the PPFIA, bonds issued under the PPFIA, or the execution and delivery of an interim agreement or comprehensive agreement is of public interest and shall be advanced by the court and heard as a preferred cause of action. An appeal from a judgment or decree rendered in such a case shall be taken within thirty (30) calendar days after the judgment or decree is rendered.
The PPFIA is supplemental to all other powers conferred by law and does not restrict or limit any powers that a public entity has under any other law.
For more information, please contact:
Mike Preston, Executive Director
Arkansas Economic Development Commission
900 West Capitol, Suite 400
Little Rock, AR 72201
(501) 682-1121
II. Guidelines
Any public entity seeking approval of a proposed project to be developed under the PPFIA shall submit two (2) copies of the signed, completed Application to the AEDC. Public entities are encouraged to seek the advice of AEDC and ADFA regarding potential PPFIA projects as early as possible, preferably prior to or during development of the application. Public entities, however, are required to seek the advice and consent of AEDC and ADFA prior to issuing an RFP. Below are guidelines specific to the Application.
The project description must satisfy each of the following criteria.
"qualifying project" means a capital development or improvement of any nature that:
The chief officer or executive director of the public entity must acknowledge each required authorization, sign and date the application, and return two (2) original copies to the AEDC.
Any comments, reviews, approvals, or designation issued by the AEDC or ADFA shall not bind the RPE to proceed with the qualifying project.
The development of a detailed, comprehensive RFP package will ensure that RPEs will receive proposals that correspond to the scope, development, and feasibility of the qualifying project as envisioned.
A public entity may issue a Request for Qualifications (RFQ) prior to issuing an RFP. An RFQ is a step sometimes used in the formal process of procuring a product or service as a screening step to establish a pool of vendors (businesses or individuals to provide a product or service) that are then qualified, and thus eligible to submit responses to an RFP. If the RFQ is conducted separately from an RFP, then RFQ responses shall describe the company or individual's general qualifications to perform a service or supply a product.
Generally, RFPs should ascertain the proposer's capability to complete the proposed qualifying project in a timely manner and to ensure that proposed benefits will be derived throughout the life of the project. RFPs should also request a scope of work and financial plan, including anticipated revenues, to allow the RPE to thoroughly analyze the financial feasibility of competing proposals. Broad topical categories of the RFP should include:
* Capacity and capability to develop project
* Technical and structural feasibility of qualified project
* Integration of project with existing plans and future benefit
* Fiscal feasibility and financial sustainability
Significant detail to these broad categories can be augmented by incorporating specific criteria from Section II.B into the RFP solicitation.27
Prior to issuing an RFP for the qualifying project, the RPE shall:
The RFP must be published one (1) time per week for three (3) consecutive weeks in a newspaper of statewide circulation. The period of time between the date of initial publication and the RFP response deadline must be at least forty-five (45) calendar days but no more than 120 calendar days. The timeframe between the date of initial RFP publication and the RFP response deadline may be extended by the RPE up to an additional 120 days with the consent of AEDC.
If the RPE does not have an existing process to evaluate RFPs and select qualified respondents, it shall select an evaluation committee, subject to AEDC approval, to review, evaluate, and rank all RFP responses. All criteria to be used in the review, evaluation, and ranking of competing proposals for a qualifying project shall be determined by the evaluation committee prior to issuing an RFP. A scoring matrix can be weighted in any fair manner to adequately assess the critical elements of a proposal. There are several factors that may be used when evaluating and selecting a proposal, including without limitation, the following:
There are several public-private partnership models with varying levels of public and private responsibility and financial risk. It is imperative that the RPE conduct a thorough financial analysis, including a comprehensive risk assessment, to ensure that the partnership meets the fiscal needs of the RPE with an acceptable level of risk.
Components of the financial review and analysis of a proposal by the RPE may include several31 or all of the following prepared by or at the request of the RPE:
* Cost-benefit analyses*;
* Opportunity costs*;
* Analysis of lifecycle costs*;
* Nonfinancial benefits*;
* Consideration of the results of all studies and analyses related to the proposed qualifying project*;
* Risk assessment;
. Cash flow analysis;
* Evaluation of the public need for or benefit derived from the qualifying project;
* Evaluation of the estimated cost of the qualifying project for reasonableness in relation to similar facilities;
. Evaluation of the source(s) of funding for the project;
. Evaluation of risk sharing, including cost or completion guarantees, added value, or debt or equity investments by the private entity;
. Consideration of any increase in funding, dedicated revenue sources, or other economic benefits that would not otherwise be available; and
. Estimates of all revenues, including user fees and leases, projected to accrue to the project.
After the RFP response deadline has expired, the RPE shall rank the proposals in accordance with the criteria adopted by the evaluation committee. The RPE (not required to select the proposal with the lowest price offer) may consider price as one variable in evaluating the proposals. The RPE shall also decide whether it will engage independent advisors to assist (and not be a member of) the evaluation committee in its review of proposals. The RPE may charge a reasonable, nonrefundable fee to cover the cost of processing, reviewing, and evaluating a PPFIA proposal, including without limitation reasonable attorney's fees and fees for financial, technical, or other advisors or consultants. See Section I.D. of these guidelines for additional information.
During evaluation, the RPE may seek written clarification from any proposer regarding the contents of the proposer's response. A request for written clarification may be made when a proposer's response contains conflicting information or is so ambiguous that it is possible for a reasonable person to attribute different meanings to the ambiguous portion of the proposer's response. A request for written clarification may not be used for negotiation (i.e., request the private entity to revise or improve their response). Written clarifications received will become part of that proposer's response.
After ranking proposals, the evaluation committee shall make a recommendation to the chief officer or executive director of the RPE to begin the negotiation process with the qualified respondent based on the rankings. The RPE shall begin negotiations with the first ranked private entity. If the RPE and the first ranked private entity do not reach a comprehensive agreement or interim agreement in the time specified, then the RPE may conduct negotiations with the next ranked private entity. This process shall continue until the RPE either terminates the process or executes an interim or comprehensive agreement with a private entity.
At any time during the negotiation process, but before the execution of an interim or a comprehensive agreement, the RPE may, without liability to any private entity or third party, cancel the RFP or reject all proposals received in response to the RFP. Additionally, upon the RPE's entering into an interim agreement or a comprehensive agreement, the agreement shall govern the parties' obligations and liabilities.
Although a specific timeframe for selecting a qualified respondent is not mandatory, RPEs are encouraged to begin negotiations with qualified entities as soon as possible to ensure that a comprehensive agreement is executed within 180 calendar days. This deadline can be extended to up to 365 calendar days by mutual written agreement of both parties. The following section contains information regarding the development of interim agreements and comprehensive agreements.
Note: Public entities (other than the RPE) appropriating or authorizing funding for financing qualified projects shall be afforded an opportunity to review any proposed interim agreement or comprehensive agreement prior to execution.
Interim agreements are useful documents that are encouraged but are not required under the PPFIA. The PPFIA defines an interim agreement as a preliminary written agreement between a private entity and an RPE executed under ACA § 22-10-302 by which the development, scope, and feasibility of a qualifying project is identified.
An interim agreement will usually be less detailed than a comprehensive agreement and will leave open items for further negotiations to be included in the comprehensive agreement. An interim agreement may be used in situations where information is needed to further develop the concept of the qualifying project. Therefore, an interim agreement might be appropriate to have the selected private entity complete certain architectural and engineering (A/E) drawings and feasibility studies so that the RPE can determine how the final qualifying project might be developed or even if the project should proceed before entering into a more detailed comprehensive agreement.
An interim agreement may also be used to allow the private entity to start work on the A/E design and drawings as the comprehensive agreement is completed. An interim agreement could establish a process and timeframe for terminating the project if negotiations cease. This type of clause in the interim agreement would allow for termination of the agreement and provide for payment of agreed- upon compensation to the private entity for the work completed pursuant to the interim agreement.
An interim agreement may include, without limitation, any of the following items:
If municipal financing by an RPE is a component of the interim agreement, the RPE shall obtain a written evaluation of the proposed qualifying project from a municipal advisor registered with the United States Securities and Exchange Commission and the Municipal Securities Rulemaking Board.
The selected private entity and RPE shall enter into a comprehensive agreement which shall cover all developmental aspects of the qualifying project not previously covered in an interim agreement. (The AEDC and ADFA may consult in negotiations at the request of the RPE.) "Comprehensive agreement" means a final written agreement between a private entity (qualified respondent) and a responsible public entity governing the development of a qualifying project. It should fully detail the planning, design, development, ownership, financing, leasing, acquisition, installation, construction, operation, maintenance, expansion, and termination of a qualifying project.
The comprehensive agreement shall include without limitation the following items:
The comprehensive agreement may include other terms and conditions that the RPE determines will serve the public purpose of the PPFIA and to which the private entity and the RPE mutually agree, including, without limitation, provisions regarding unavoidable delays, liquidated damages, and provisions where the authority and duties of the private entity under the PPFIA shall transfer and the qualifying project is dedicated to the RPE for public use. Comprehensive agreements shall include a hand-back clause which specifies the terms and conditions governing the transfer of ownership from the private entity to the RPE upon expiration of the lease, term, or concession period.
The following expedited timeframe shall be followed for accelerated selection of prioritized projects. Days listed are calendar days.
Event |
Standard Timeframe |
Expedited Timeframe |
Affected local jurisdiction and other public entity notification prior to RFP issuance |
60 days |
30 days |
Submittal of RFP to AEDC prior to publication |
60 days |
30 days |
Duration of RFP publication from advertisement to response deadline |
45-120* days |
45-90* days |
Execution of Comprehensive Agreement |
180** days after RFP response deadline |
120 days** |
* May be extended by the RPE up to an additional 120 days with the consent of AEDC.
** This deadline may be extended to up to 365 calendar days by mutual written agreement of both parties.
Appendix A
Definitions
Attachment A
1 Codified at § 22-10-101 et seq.
2 Words and terms in quotation marks are defined in Appendix A. See definition (3) of Appendix A.
3 See definition (13) of Appendix A.
4 See definition (11) of Appendix A.22-
5 See definition (6) of Appendix A.
6 See definition (10) of Appendix A.
7 See definition (7) of Appendix A.
8 See definition (12) of Appendix A.
9 The PPFIA Application, guidelines, RFP notice, evaluation criteria, and any other documentation required to be made publically available in the guidelines or PPFIA rules promulgated under the Arkansas Administrative Procedure Act must be posted on a dedicated web page reserved exclusively by the RPE for the PPFIA project. The RPE may post additional, more detailed information when seeking proposals if deemed by the RPE to encourage competition. Multiple PPFIA projects may be posted simultaneously on the same web page as long as each project is clearly and separately delineated.
10 See definition (1) of Appendix A.
11 Identify all public entities that will be fiscally impacted by the project or who have statutory or constitutional authority relative to development of the qualifying project.
12 See definition (8) of Appendix A.
13 See definition (9) of Appendix A.
14 See definition (2) of Appendix A.
15 See definition (4) of Appendix A.
16 Revenue Bond Act of 1987.
17 Open Public Meeting requirements under the Freedom of Information Act of 1967.
18 § 22-10-502(b) specifies guidelines items.
19 § 22-10-503(a) specifies rules items.
20 Procurement of Professional Services.
21 Projects of the Arkansas Highway and Transportation Department (or successor name) are ineligible to submit projects.
22 Regional Mobility Authority Act.
23 See definition (5) of Appendix A.
24 See definition (16) of Appendix A.
25 See definition (14) of Appendix A.
26 See definition (15) of Appendix A.
27 The level of detail may differ significantly depending upon the degree to which the project has been defined by the RPE. See for example, Governing Magazine,Governing Guide to Financial Literacy Volume 3, Understanding the Risks and Rewards of Public-Private Partnerships, for a discussion of high-performance procurement vs. innovating early.
28 The PPFIA application, guidelines, RFP notice, evaluation criteria, and any other documentation required to be made publically available in the guidelines or PPFIA rules promulgated under the Arkansas Administrative Procedure Act must be posted on a dedicated web page reserved exclusively by the RPE for the PPFIA project. The RPE may post additional, more detailed information when seeking proposals if deemed by the RPE to encourage competition Multiple PPFIA projects may be posted simultaneously on the same web page as long as each project is clearly and separately delineated.
29 See definition (14) of Appendix A.
30 See definition (15) of Appendix A.
31 The items with * were delineated in the PPFIA as required review elements.
32 The Regional Mobility Authority Act, established by Act 389 of 2007.