wayne county response to jail audit

7232019 Wayne County response to jail audit

httpslidepdfcomreaderfullwayne-county-response-to-jail-audit 160

1

Wayne County Memorandum

To Wayne County Legislative Auditor GeneralFrom Offices of the Wayne County ExecutiveSubject Response to Audit ReportDate September 4 2013

The following is in response to the Office of the Legislative Auditor Generalrsquos (ldquoOAGrdquo)Wayne County Consolidated Jail Facility Construction Cost report Wayne CountysResponse (ldquoCountyrdquo) is limited to the Working Draft that was provided on August 272013 and labeled August 16 2013 The Parties agree that certain findings were referredto the Wayne County Prosecutorrsquos Office for review

EXECUTIVE SUMMARYREPORT DETAIL

This section reviews scope methodology background and review Many of thestatements are misleading or factually incorrect Therefore the County would takeexception to such statements The OAG has stated that documentation regarding support

for such statements allegations will not be provided To date no supportingdocumentation has been provided The County has limited its responses to the draftstatements and where appropriate we have provided documentation We ask thecourtesy to respond more thoroughly to the OAG Report once supporting documentationhas been provided

OAG ResponseThe Office of the Legislative Auditor General (OAG) responses are written in red

The respondent began by stating that many of the findings in the report are misleading orfactually incorrect We began by stating that the purpose of the closing conference is to

correct any factually incorrect statements as it relates to ldquocondition andor causerdquo asstated in each finding However if the respondent is challenging conclusions reachedbased our examination of the conditions and or cause we are required by auditingstandards to make those corrections

In general the respondent questioned many of our conclusions andor opinions asopposed to being able to demonstrate a need to change the conditionsor cause as statedin the report Based on our overall review of the responses provided a large percentage



2

of the objections appear to be related to the conclusions and opinions reached by theOAG

In addition the respondent mentioned that no supporting documentation was provided Itis customary in the industry to not provide supporting documentation for

findingsrecommendations included in our report However at the closing conferenceworking papers and other documentation to support conclusions reached are discussed indetail as it relates to each findingrecommendation being challenged The administrationelected to provide written responses as opposed to allowing the OAG the opportunity todiscuss the support and documentation for each of the findings The opportunity for therespondent to discuss each finding and our support is still open and available if they wishto exercise that option

Our preliminary response regarding this matter will be addressed in each of theldquoFindingsrdquo or Recommendations provided by the OAG We will address statements inwhich we take issue and where we believe such statements are misleading We have also

provided you with a response on each of your recommendations Again this can only bea preliminary response since the OAG has indicated that he will not allow us to viewdocuments on which he has drawn his conclusions

OAG ResponseThe detail of our report layout states ldquowork performed and the results of workperformedrdquo This format is conducive to assisting the respondent in understanding whatwork was actually performed and the conclusions reached based on that work performedOur underlying working papers are designed to support the work actually performedThe auditing standards require the OAG to prepare and maintain working papers tosupport conclusions reached In essence the report itself identifies work performedresults of that work and conclusions reached

We would also question the OAG on their statements at the end of each finding titledldquoViews From Responsible Officialsrdquo We are assuming such headings are added as amatter of convenience It is the County through the Department of Management andBudget and for the benefit of the Wayne County Building Authority who sought andrequested that the OAG perform an audit on the Consolidated Jail Project Both partiesmust acknowledge that since the initial draft report was issued on August 13 2013 threeother revisions were then issued The County has been modifying its responses as eachnew version is submitted This Closing Conference will be the first opportunity for theCounty to effectively address these findings Again such responses must be limited sincethe OAG has indicated that he will not provide documentation We are assuming thatyou will either include our ldquoViewsrdquo or make a statement under each section that suchviews are listed in the appendix We would ask for written clarification regarding yourformat



3

OAG ResponseldquoViews from Responsible Officialrdquo is a term that is suggested by GAGAS under whichthis engagement is being performed

We agree the Wayne County Building Authority (WCBA) requested the OAG to perform

this engagement as an Agreed Upon Procedure Engagement and we complied with thatrequest We have held several meetings with the auditees during the course of thisengagement and they have been granted the opportunity on numerous occasions toprovide responses to findingsrecommendations as they were being developed by theOAG

It is customary to have several drafts of a document and the latest being dated August 162013 resulted from additional significant information that developed based oninformation submitted by the administration to the Wayne County Committee of theWhole on August 14 2013 This additional information was considered significant bythe OAG therefore the auditing standards required us to expand the scope of the

engagement for all significant activity pertaining to this subject matter up to the date ofour report which in this case is August 16 2013

Yes ndash your assumption is correct - the OAG will attach the respondentsrsquo comments in anAppendix B to our report

AGREED UPON PROCEDURES PERFORMED

EVALUATE INTERNAL CONTROLS

Control Environment

Philosophy and Style- pg 32Results of Work Performed pg 33

Points of Clarification

Ethics Policy- The WCBA did formally acknowledge that they are bound by theCountyrsquos Ethics Ordinance However we believe that it is important to note that all ofthe Countyrsquos Boards are bound by the Ethics Ordinance A formal resolution does notneed to be passed

OAG ResponseAlthough the approval action was in fact taken by the WCBA we were informed byWCBA Special Counsel that it was not necessary

Compensation- Compensation for Board members is not an eligible cost under a bondfinancing If there is a desire to compensate board members then it would need to come



4

as an allocation of general fund dollars The Commission would need to provide a yearlyallocation not only to the WCBA but to other boards

OAG ResponseThe OAG was able to identify $213000 in the general operating fund of the WCBA

audited financial statements as of September 30 2012 Management amp Budget (MampB)stated there will be an annual ldquoloan processing feerdquo of more than $14500 annually thatwill be received by the WCBA in future periods that can be used to offset administrativecost

Therefore their funding would not have to be paid from the Wayne County general fundas incorrectly stated by the respondent A more detailed discussion can be found in ourreport under the caption ldquo VII ndash Adoption and Approval of Budgets - General OperatingFundrdquo

Fiduciary Duties- We believe staff and board members have a fiduciary responsibility to

the County The choice to have a Project Manager report to the County the obligor of allissues on the Project should not be considered a flaw

OAG ResponseThe OAG is concerned that the Project Manager with all of the qualifications experienceand skill sets are reporting to someone other than the WCBA board of directors Thiscould result in decisions being made by someone other than those persons without theskill set and knowledge to meet the goals and objectives of the WCBA board Anydifferences that may exist between the WCBA board and the administration should beresolved at that level not at the expense of decisions being made by those without thenecessary qualifications and experience

Administration of LeadershipStrategic DirectionResults of Work Performed- 37

Results of Work Performed-pg 34 You have acknowledged that the former DCEO andChief Development Officer oversaw the Project in its early stages However inparagraph 1 you have not added that when the ad-hoc or Oversight Committee wasformed this committee included the Director of Buildings and a member the Office of theSheriff It is important that these individuals are also named as part of the committee inother sections We would ask that you remain consistent your presentation of facts inorder for the County to remain consistent in the responses it provides Additionally itshould be noted that this committee was not limited to the staff members you haveindicated At several meetings members from the Countyrsquos IT Department and the ChiefOperating Officer were also in attendance Furthermore this committee was not adecision making committee nor did it engage in such actions Instead it was a meetingheld where the Program Manager could inform the County on the progress of the Project



5

OAG ResponseAn email received from the Chief Administrative Officer (CAO) on July 18 2013identified ldquofour core members that made up the Oversight Committee

We understand there may have been other participants but we were concerned about the

key administrative team members Therefore no change is being considered

We are unclear as to the function of the committee if they were not a decision body thenwho made the day-to-day decisions for the period June 2012 ndash October 2012 when therewas no designated ownerrsquos representative Since we were informed that there were nominutersquos andor notes taken at those meeting we are unable to understand the role andfunction of the committee

Generate Savings- On page 37 you have indicated that you do not have documents basedon how savings would be generated from the consolidation Please note that thesedocuments are a matter of public record and were provided to the Wayne County

Commission during the different presentations provided by AECOM AECOMrepresented and it was accepted that a consolidation of services would create a reductionof staff and a reduction in the duplication of services Within other areas of your reportyou have indicated that you appropriately sought and received documents from AECOMYou have indicated that you have interviewed AECOM representatives on severaloccasions We are uncertain why you either did not ask or are not acknowledging thedocuments that were created by AECOM on the operational savings Attached aredocuments demonstrating what was previously provided Based on this information webelieve this section should be re-written See Exhibit A Presentations and Best Practices

OAG ResponseWe did request this information from Wayne County Sheriff Office (WCSO) personneland they informed us they did not have a comprehensive listing to support annual savingsprojected at $20 - 30 million

Although the information you have been provided is helpful our preliminary review hasdetermined that it still does not provide a comprehensive listing of savings by specificcategories If and when we are provided with a comprehensive listing with dollaramounts to support the $20 ndash $30 million in annual savings we will re-state theparagraph pertaining to annual savings

We requested and received a schedule of proposed cost savings from AECOM officialson September 12 2013 therefore we will amend our statement on page 37 of this report

Organizational Structure

The proposed flow chart indicates a recommendation of a ldquosuper-committeerdquo of threeboard members A committee structure is useful However creating a super committee



6

would not be advised One should attempt to create committees so that they can makerecommendations not decisions that would usurp the authority of the WCBA

OAG ResponseIf a super committee exists for the COBO Hall Regional Convention Authority ndash which is

a $279 million project and very successful - with a five member board and 3 members onthe capital improvement sub-committee - then why the same concept canrsquot be used for theWCBA This issue is being raised several times by the respondent but no viablealternatives are offered More importantly the oversight model the WCBA is currentlyusing has failed to meet their goals and objectives

Based on the narratives that you have provided a point of clarity needs to beacknowledged The WCBA has responsibilities beyond the creation of the newConsolidated Jail Facility It was prudent to create a position of a Chief AdministrativeOfficer within their organizational structure This CAO will always report directly to theWCBA Therefore any suggested change in how a specific project may be created

cannot change the fact that the CAO will be reporting directly to the WCBA not to acommittee

OAG ResponseIn the newly proposed organizational chart on page 39 of our report we support the

CAO reporting directly to the board but if a Capital Improvement Sub-committee isformed then we believe the CAO should report to that committee as it relates to thatactivity

More importantly the CAO is key to handling the administrative and financial affairs ofthe WCBA however rarely if ever do these individuals possess the skill sets or time tomanage daily on-site construction management and we believe those tasks should be leftto those who have the qualification experience and time like in this case the ProjectManager

Criteria- pg 40

Amendment of Bylaws- Special Counsel apologizes if former explanations left the OAGwith the idea that an amendment of the bylaws is all that is required for a committeestructure An amendment of the Articles with approval by the Commission is necessaryand prudent for the creation of Committee structures on any board Bylaws would thenidentify each of the differing committees that the WCBA may form

OAG ResponseWe recognize and appreciate the action that must be taken by Wayne CountyCommission however we have also been informed that initial action is required to betaken by the WCBA board in order for changes to be made to the articles of incorporationand by-laws

Recommendation 2013-01



7

Consider amending the bylaws- after receiving permission from the primarygovernment unit to provide for compensation on a per diem basis andreimbursement for parking expenses

View of Responsible Officials

Although the administration does not disagree with this finding in theory there are otheritems that must be taken into consideration The Wayne County Building Authority hasno funding source to which they can be compensated There currently is fund balancethat exists due to one-time revenue as a result of the sale of the parking lot but accordingto best practices (GFOA) one-time revenues should be used only for one-time expensesnot for ongoing operations particularly if there is a history of unsustainable use Refer tothe attached excerpt from Recommended Budget Practices A Framework for Improved

State and Local Budgeting

OAG ResponseThe Administration incorrectly states that ldquoboard compensation would have to comefrom general fund dollarsrdquo when in fact the OAG identified that $213000 currentlyexists in the WCBA general operating fund at September 30 2012 as well as another$14805 and $14675 projected for years 2013 and 2014 from loan processing fees anda similar amount thereafter Therefore the WCBA would not have to receive funds fromWayne County general fund as concluded by the administration

Adopt a Resolution to amend the by-laws to allow for sub-committees with one being thecapital improvement sub-committee with board members preferable with real estatedevelopment experience

We agree that the committee structure can be useful However this would require anamendment of the Articles of Incorporation and approval of the Wayne CountyCommission If there is a board of five members one cannot create a sub-committee ofthree That would create a super-majority and would place the power in the committeeinstead of the board Instead we believe a Committee structure that includes theCommission is useful This is an ad-hoc committee that would send recommendations tothe full board This is logical since the County is the sole funding source for the WCBAA committee that allows for Commission representation would ensure that there are nodisagreements regarding what information was made available to the Wayne CountyCommission on Capital Projects

OAG ResponseSee the same response at stated above in a previous paragraph



8

Governance and Board Independence

We believe there is merit and justification for this concern Meetings were canceled orrescheduled without written authorization from the Chair


In light of the fact the WCBA by-laws require one regular meeting to be held during thefirst week of each month ndash we recommend the WCBA consider revising its bylaws torestrict anyone other than the board chair or a board approved designee in their absenceto establish andor cancel meetings This would provide full transparency for itsdeliberations as a public body that is independent of the Wayne County Administrationand avoid any appearance of lacking independency

Views From Responsible Officials

The Administration agrees that a policy regarding cancellation of regular or specialmeetings should be developed We agree with a provision revising the bylaws limitingthe power of scheduling meetings However both should be developed according to theprovisions stated in the Open Meetings Act We disagree with the statement maderegarding transparency There are no documents that you have presented that wouldsupport a recommendation that the WCBA Board has not operated in a transparentmanner

OAG ResponseThe OAG believes that because the board meetings were canceled by the Administrationand not the WCBA this reduced oversight and transparency of the board

According to communication from the CAO the Oversight Committee generally met onWednesday of each week it stands to reason that this Committee met on a regular basiseven during the same period that the WCBA board meetings were canceled

Risk Management

Subject matter entitled Allegations of Fraud and Material Misrepresentation has beenremoved for this report This section is not addressed due to the request for aninvestigation

OAG ResponseYes ndash portions of this findingrecommendations has been forwarded as required by theWayne County Fraud Investigative Policy to the Wayne County Prosecuting AttorneyOffice for further review



9

Control Activities

Before addressing Recommendation 2013-04 it is important to address numerousinconsistencies facts and conclusions drawn by the Auditor General (AG) pertaining tothe request for proposal (RFP) for the construction manager at-risk (CMAR)

Results of Work PerformedThe Auditor General (AG) alleges on page 46ldquoWe had difficulty understanding the criteria used by the selection committee in theevaluation of the proposalshelliprdquoThis is an erroneous conclusion since both the request for proposals (RFP) and theevaluation forms listed that the criteria used to evaluate the proposals

1 General Information amp Qualifications2 Technical amp Specifications

In addition the AG clearly articulates the evaluation criteria later in its report on page 49Thus it is unclear as to why it is difficult to understand what criterion was used toevaluate the proposals

OAG ResponseSince the criterion was merely based on qualification and experience and excluded pricewe did find it difficult how committee members were able to objectively base theirselection merely on qualification and experience This is our opinion and we find no justification for the exclusion of price from the evaluation process Especially when ithad not been determined that it was even feasible to build a 2000 bed facility for $220million We see no evidence that will change our opinion as it relates to this matter

Price Eliminated as a FactorOn page 46 the AG misplaces the context of the Purchasing Directorrsquos quote regardingas to what factors are utilized in evaluating RFPs

An RFP is done when the County is requesting the vendor to propose a ldquosolutionrdquo andthere are other factors other than price to determine which vendor is the ldquomostresponsive and responsiblerdquo He further stated The other factors include experience and

qualifications solution work plan and price hellip Emphasis added

The AG utilizes this quote to intimate that ldquopricerdquo will always be a factor in RFPevaluations However this is incorrect since this quote was in response to the AGrsquosquestionldquoWhat primarily is the difference between a RFP and a RFQrdquoThe Purchasing Director responded by illustrating the difference between an invitationfor bid (IFB) RFP and request for qualifications (RFQ) In contrasting IFB (where priceis the only factor) with RFP the Purchasing Director provided a list of criteria that can beused to evaluate RFPs This list was not comprehensive and was provided only as anexample Thus the Purchasing Directorrsquos quote should not be utilized to conclude thatldquopricerdquo will always be a factor included in every RFP

Before addressing the issue of ldquoPricerdquo not being a factor it is necessary to discussthe role of Purchasing in acquisition planning prior to the issuance of a competitive



10

solicitation to properly understand why ldquoprice was not a factorrdquo According to theAmerican Bar Associationsrsquo textbook on ldquoState and Local Government Procurement1rdquoacquisition planning is defined asProcess by which the efforts of all personnel for an acquisition are coordinated andintegrated thorough a comprehensive plan for fulfilling an agency need in a timely

manner and at a reasonable cost

2

Emphasis addedIn preparing for issuing a solicitation purchasing officials should ldquoconsult with agencyexperts when developing procurement plans and preparing statements of work to ensureincorporation of relevant requirements in procurement planning documents and purchaserequestsrdquo

3

Accordingly Wayne County Building Authority employed the assistance ofldquoconstruction expertsrdquo which consisted of AECOMGHAFARI (program manager) KotzSangster (law firm) and Tony Parlovecchio (Owners Representative) to effectively planfor the solicitation of the construction manager for the new jail In additionrepresentative from EDGE Purchasing and Corporation Counsel were also involved

The decision for ldquopricerdquo not being considered a factor in the RFP was recommended bythe ldquoconstruction expertsrdquo based upon funding and bid documentation that was availableat that time Thus it was determined that guarantee maximum price (GMP) RFP was thebest process to procure the construction manager at-risk

OAG ResponseWe consulted with the most recently hired Project Manager and he too found it highlyunusual to exclude price from a large public capital improvement project In fact in anemail dated July 28 2013 he states ldquoIt is my understanding of the process for this projectwas that all bidders were advised that the cost to be bid was $220 million based upondocuments provided This is an unusual method of bidding - usually contractors aresimply provided a set of bidding documents and are requested to submit their proposalaccordinglyhelliphelliprdquo With emphasis placed on this is an unusual method of bidding

It is important to note that GMP contracts are an industry standard in construction relatedcontracts For instance an article in a New York Law Journal

4 titled ldquoDesign-Bid-Build

v Guaranteed Maximum Price Contracting The Basics for Owners Counselrdquo sets-forth apersuasive analysis for the use of GMP contracts and bid documents As it relates to theinclusion of ldquopricerdquo in the bid documents the article states

1

983108983137983150983145983141983148983148983141 983107983151983150983159983137983161 983123983156983137983156983141 983137983150983140 983116983151983139983137983148 983111983151983158983141983154983150983149983141983150983156 983120983154983151983139983157983154983141983149983141983150983156 (983107983144983145983139983137983143983151 983105983106983105 983123983141983139983156983145983151983150 983151983142 983116983151983139983137983148 983111983151983158983141983154983150983149983141983150983156983116983137983159 2012)

2 983113983140983137983156 9830942

3 983113983140 983137983156 9830943

4 See httpwwwhancocklawcomJEH_Articlepdf



11

ldquoBecause each project is essentially a prototype the cost to complete the overall project

generally cannot be known with great precision Many reputable cost estimating serviceproviders will not assure the accuracy of their estimates below a range of plus or minus10 percent For this reason it is difficult to know how competitive a given price is when

procuring construction services through other-than properly-administered competitive

bidding The variation in construction pricing can be significant when considering aproject costing tens of millions of dollars Even with competitive bids the range in prices

offered by the various bidders can reveal the inherent variability in construction pricinghelliprdquo Emphasis added

Accordingly it would have been very difficult to obtain comparable pricing due to thelimited bid documents available The vendors would have assumed a lot of differentinformation in order to provide a comparable price for the project In addition it wouldhave been very difficult to do an evaluation since each of the proposers was assumingdifferent information in determining price Thus price was not considered a factorIn addition the Auditor quotes the recently hired Project Manager on page 46 to concludethat ldquothis is an unusual method of biddingrdquo This statement is taken out of context since

the Project Manager was clear in its responses that it was ldquounusualrdquo but NOT incorrectdue to the bidding documents available at the time The Project Manager was clear thatprice could be a factor if ldquosufficient biddingrdquo documents were available at the time

OAG ResponseSee response as stated above with the full context of this conversation

Lastly the Auditor alleges on page 47 that since proposers could be disqualified that theprocess could be manipulated

Further we believe it is unusual when a RFP disqualifies a respondent forincluding price in their proposal We believe this is counterproductive to the

purpose of a competitive bid process and exposes the Authority to the risk of the

process being manipulated by key decision makers Emphasis added

While it is true that the RFP stated that the proposers could be disqualified for includingprice in their proposals the FACT is none of the proposers were disqualified Each of theproposers was given an opportunity for an interview and their proposals were reviewedand evaluated Thus the Auditorrsquos claim that the process was manipulated by keydecision makersrdquo is unwarranted since each and every proposal was evaluated and givenan equal opportunity

OAG ResponseIn an email dated July 28 2013 the Countyrsquos Project Manager stated ldquoI understand thatsome that were invited to bid declined to bid as they did not believe the construction costnumber provided was adequaterdquo

It is important to note that procurement standards allow vendors to be deemed ldquonon-responsiverdquo for failing to follow the requirement of solicitation5 There is no legal

5 983123983156983137983156983141 983137983150983140 983116983151983139983137983148 983111983151983158983141983154983150983149983141983150983156 983137983156 100



12

precedent that prevents the WCBA or Wayne County from disqualifying a proposerTherefore the allegation that disqualifying a vendor is considered ldquomanipulatedrdquo isuntrue and negates established procurement principles

OAG Response

In our opinion to disqualify a bidder for submitting a price does not appear it was theintent of this RFP to make it fair and competitive

Beginning on page 47 the AG has lengthy analysis to conclude that ldquoWayne County didnot allow for a for a fair and competitive bid processrdquo Before responding to thisallegation it is important to note the duty of an Auditor pursuant to American Institute ofCertified Public Accountants is to base their report on ldquosufficient evidence to provide a

reasonable basis for the conclusion that is expressed in the report6 rdquo This is critical since

the evidence relied on by the Auditor for this section is extremely questionable andpresumptuous

OAG ResponseWe felt that this lengthy analysis was necessary to support the conclusion reached by theOAG that the process was not fair and competitive

Furthermore Federal Courts in interpreting Federal Acquisition Rules provide guidanceregarding unfair competition

ldquoA significant potential conflict is one which provides the bidding party a substantial andunfair competitive advantage during the procurement process on information or data notnecessarily available to other biddershellip therefore requires mitigation of ldquosignificantpotential conflictsrdquo but does not require mitigation of other types of conflicts such asapparent or potential non-significant conflicts The contracting officer does haveconsiderable discretion in determining whether a conflict is significant Moreover theFAR provides a contracting officer with considerable discretion to conduct fact-specificinquiries of acquisition proposals to identify potential conflicts and to develop amitigation plan in the event that a significant potential conflict existshellip In sum the FARrequires that ldquo[e]ach individual contracting situation should be examined on the basis ofits particular facts and the nature of the proposed contract7hellip Emphasis added

The Federal Courts have also stated it will not conclude a contract was awarded

unfairly on ldquothe basis of a possibility and appearance of impropriety8 A protesting

bidder must identify hard facts not a mere inference based on suspicion or

innuendo9

983094 983105983113983107983120983105 983120983154983151983142983141983155983155983145983151983150983137983148 983123983156983137983150983140983137983154983140983155 (983114983157983150983141 1 2012) 98320710151

983095 983107983151983149983149983137983150983140 983117983137983150983137983143983141983149983141983150983156 983123983141983154983158983145983139983141983155 983113983150983139 983158 983125983150983145983156983141983140 983123983156983137983156983141983155 111 FedCl 279 (2013)

983096 983113983140

983097 983113983140



13

Consequently the Auditor has failed to provide direct evidence to demonstratethat process was unfair and provided an advantage to WalbridgeDCK Thus the AGrsquosconclusions are based upon inferencesThe Auditor claims that ldquoWayne County did not allow for a fair and competitive bid

processrdquo This is factually inaccurate since it fails to take into account following ndash facts

1 There were 8 addendums issued after the initial RFP that took into account all of thepotential proposerrsquos questions and concerns Some of the addendum resulted in changesto the RFP to address the proposerrsquos concerns If the RFP was written to favorldquoWalbridgeDCKrdquo then the concerns of the other proposers would have been irrelevantand the RFP requirements would not have changed2 6 proposers responded to the RFP including WalbridgeDCK If the RFP was not ldquofairand competitiverdquo it is highly unlikely that 6 proposers would have spent the time energyand funds (required bid bond) to sufficiently respond to the RFP10 3 No bid protest was filed after the award to WalbridgeDCK By law all proposers

responding to a competitive solicitation have the authority and discretion to file a bidprotest Each of the proposers could have obtained copies of all relevant documentationthrough the Freedom of Information Act

Instead of reviewing the totality of circumstances the Auditor bases its broad conclusionof the process was ldquodesigned to provide an unfair advantagerdquo on inferences from four (4)ldquofactsrdquo on page 47(which are summarize below)

1 MampB should have selected the Evaluation Committee and not EDGE since WCBAfalls under the authority of MampB2 Evaluation Committee should have included an engineer or architect as a ldquoscoringevaluatorrdquo However the Auditor does state that ldquogiven the nature of the project wequestion whether any county employee had the necessary experience3 Price was not a factor in the RFP4 A RFP from another reputable company could have met the budget of $220 Million byreducing the square footage by 100000 sq ft4 The former CDO may have unduly influenced her Deputy who was a scoringevaluator on the committee since she supervised the Deputy In addition another votingmember was a ldquoconfidant and friend of the CDOrdquo

None of the aforementioned statements directly demonstrate how the evaluation wasldquodesigned to provide an unfair advantagerdquo These are inferences and innuendos

First the AG claims that the County should have taken into account the proposalsubmitted by a ldquoreputable companyrdquo to reduce the square footage in the new jail in order

10 As a note all of the proposers were nationally known companies that have an expertise

in capital construction projects and would have objected to non-competitive RFP



14

to meet the $220 Million budget The evaluation committee did review this proposal todetermine if it was feasible If the County would have accepted this proposal it wouldhave required the County to reduce the number of jail beds (ie 2192) to accommodatethe reduction of the square footage The reduction of the beds would negate the AGrsquosrecommendation on page 8 that the new jail should have ldquoat least 2512rdquo jail beds

OAG ResponseAt the time of the bid obviously some of those invited to bid questioned if a 2000 bedfacility could be built for the price of $220 million in retrospect it appears thoseconcerns remain legitimate two years later

Nevertheless the reference to this ldquofactrdquo by AG does not clearly demonstrate how theRFP ldquodid not allow for a fair and competitive bid processrdquo How is the process ldquounfairrdquoby not accepting a vendorrsquos proposal to change the scope of work Procurementstandards allow municipalities to reject proposals that do not comport to the requirementsof a solicitation

Secondly the Auditor did NOT interview the former CDOrsquos Deputy to determinewhether he was unduly influenced by the former CDO or not Thus itrsquos questionablewhether the Deputy was ldquounduly influencedrdquo or not

OAG ResponseWe saw no benefit in interviewing the Deputy Chief Development Officer - merely theappearance of a lack of independency was enough to create questionable doubt

Furthermore the Auditor fails to take into account that ALL of the scoring evaluatorsoverwhelmingly scored WalbridgeDCK proposal higher than other proposals Besidestaking issue with the Deputy of EDGE for allegedly being ldquounduly influencedrdquo andquestioning the ldquofriendshiprdquo of one of the other voting members with the former CDOthe Auditor does not raise issues with the remaining evaluators The Auditor has notargued that the other evaluators were unduly influenced or controlled by the former CDOTherefore itrsquos highly incredulous to broadly assert that the process was not ldquofair andcompetitiverdquo and not provide evidence of the improper conduct

Lastly AG insinuates that the former CDO had the sole authority to select and approvethe evaluation committee for the construction manager RFP This is false since thePurchasing Director gives each and every department which issues an RFP the courtesyof recommending the members of the evaluation committee The Purchasing Directorreviews the list and ultimately has the final authority to approve or reject the list Thusthe process utilized is in compliance with section 120-35(i) since the Purchasing Directorhas the sole authority to select the members of the evaluation committee

OAG ResponseIn reality we questioned the role the Purchasing Director may have exercised in theselecting the evaluators on the committee We were informed that they were proposed bythe Chief Development Officer and none were rejected by the Purchasing Director



15

OBSERVATIONS

The AG correctly quotes the Purchasing Director on the bottom of page 48 regarding theprocess so select evaluation committees for RFPs However the AG intimates that

somehow the process violates the spirit of section 120-35(i) As previously stated aboveall departments initially make recommendations to the Purchasing Director of potentialevaluators for review Ultimately itrsquos the Purchasing Director who reviews and selectsthe evaluations committee for each and every RFP ldquoItrsquos a courtesy given to each andevery departmentrdquo since departments know their employees that are qualified to evaluateproposal

It is important to note that the process for selecting evaluation committees is thesame process utilized by Purchasing to select the external auditors on behalf of theAuditor General In the past the AG initially recommended the evaluation committeebut the final decision is made by the Purchasing Director Thus the process has not

violated the ldquospiritrdquo of section 120-35(i) in the past

CRITERIA

Since 2011 Purchasing has adopted all of the six (6) ldquobest practicesrdquo pertaining to publicprocurements listed by the AG on page 50 In addition the Ethics Ordinance andProcurement Ordinance were revised in 2012 and require all County employees todisclose all conflict of interests financial interests and familial interests ThusPurchasing is following best practices

Moreover the Auditor misquotes section 120-43(b) regarding exceptions to providingldquocost pricingrdquo data The Auditor claims that the Purchasing Director is required toprovide a ldquowritten waiverrdquo However the section provides numerous exceptions

1 The contract price is based on adequate price competition2 Contract price is based on established catalogue prices or market prices

3 The contract price is set by law or regulation or

4 The purchasing director determines that the requirements of subsection 120-43(a)hellipmay be waived and states the reasons in writing The Purchasing Director shallprovide a copy of each such written waiver to the county commission Emphasis added

Hence a written waiver is only required if the other three (3) exceptions are unavailable

In this case section 120-(b) (2) applied since AECOMGhafari established the cost of$220 Million by taking into account market prices and industry standard to complete a2100 bed Jail Facility

OAG ResponseThe OAG requested the research to establish the market price to complete a 2100 bedJail Facility but were not able to obtain In addition we believe any support for



16

establishing the cost of $220 million should be maintained within the PurchasingDivision as support for the RFP


a This is the current process and was the process utilized in 2011 All of the Countyrsquosevaluation committees do include individuals that have the necessary expertise to makean informed decision The Countyrsquos process mirrors the federal procurement law whichmakes clear that an evaluation team is to be ldquotailored for [each] particular acquisitionrdquoby including persons with ldquoappropriate contracting legal logistics technical and otherexpertise to ensure a comprehensive evaluation of offersrdquo11

b Purchasing is confused by the reference to an ldquoad-hocrdquo evaluation committee and itsrelationship in evaluating RFPs The current Procurement Ordinance currently allowsldquoexternal consultantsrdquo to serve as advisors The construction manager at-risk RFP did

include the program manager and owners representative as advisors as stated on

page 48 of the AGrsquos report

c The Ethics Ordinance and Procurement Ordinance were revised in 2012 to incorporatethis recommendation

d Purchasing does NOT concur with this recommendation since every Procurement isunique and to have a general rule that all RFPrsquos require a ldquopricerdquo component would notbe feasible These are a couple examples as to why every RFP does not include ldquoprice as afactor

1 Many RFPs issued pursuant to grant agreements do not include price as a factorUsually the RFP sets the price what the vendor will be paid since this is the amountlisted in the grant agreementbudget Failure of the County to utilize the entire proceedsof the grant for services would require the County to return the funds to the grantingagency

2 In addition price is not a factor in many of the Countyrsquos ldquorevenue contractsrdquo sincevendors are generating revenue for the County and there are no costs associated to theCounty

WCBA Procurement Policy-pg 51Results of Work Performed- pg 51

The statement that the AECOM Contract was not competitively bid is inaccurateAECOM was competitively bid and under contract when the County asked them toconsider reducing their scope from a Regional Justice Center (ldquoRJCrdquo) to a ConsolidatedJail In the absence of an approved Procurement Policy all boards including the WCBAhave a responsibility to follow the Countyrsquos Procurement Ordinance with few

11 983110983105983122 15303(983138)(1)



17

exceptions The County disclosed to the Commission that AECOM would continueworking on the Project in 2010 during Commission meetings Your statements arefactually incorrect and damaging to the County Such statements are not supported byany documentation and should be removed

OAG ResponseThe OAG feels that the administration still has not submitted convincing evidence thatpricing should not be a factor in large public capital improvement projects Againanother reputable contractor stated they could not build a 2000 bed jail for the price of$220 million however the key decision makers failed to take this into consideration Itis our opinion that price should always be a factor in all large public capital improvementprojects

Recommendation xx- pg 52

We recommend that the WCBA include a section within their Procurement Policy that

requires purchases to be initiated by a purchase order for all goods services and orconstruction related costs over a certain dollar amount or the WCBA may be able to use avoucher system for purchasing of goods and service of $100 or less


Typically WCBA has very few purchases of goods and services that would necessitate afull purchase order system This is the primary reason why the overall procurementpolicy did not specify the use of purchase orders In regards to the jail project WCBA didevaluate the feasibility of using purchase orders and concluded that since WCBA did nothave the financial system or the staff to administer the purchase order process it wouldbe more cost effective to use a voucher process in conjunction with the contracts Sincethe purchase order is a document equivalent to a contract that serves as a legal agreementbetween the buyer and seller WCBA used contracts in lieu of a purchase order

OAG ResponseThe OAG believes that because there are numerous contracts issued by the WCBA theuse of a purchase order could prevent the processor from exceeding the contract amountThis limitation does not exist with the use of a voucher system as being recommended bythe administration

BEST PRACTICES- PG 53

The Administration strongly disagrees with the statements that were made regarding theexclusion of the Sheriff in the design and programming of the jail Attached for yourreview is the Program Design Document that was reviewed and approved by the SheriffThis occurred in May of 2011 It is in direct contradiction to your statement that theSheriff was not involved As noted in the OAGrsquos report the Sheriff was part of the ad-hoc and Oversight Committee as of October of 2011 Additionally AECOM and theDirector of the Buildings Division met with AECOM on a regular basis to review designs



18

of the facility Also included in this Exhibit are certain meeting minutes showing thatSheriffrsquos Representatives were not only meeting with AECOM on a regular basis Thismisstatement of fact misleads the reader and your supports your conclusions that theSheriff had no responsibility in the design or programming of the facility See Exhibit BSheriff Program Approval Meeting Minutes

OAG ResponseIn our report on page 54 it states We questioned how involved the WCBA and or itsOwner Representative was involved in design cost evaluation construction phase andwhether they possessed the expertiserdquo We did not find any statement in this report thatimplied or stated that the Sheriff was not involved in the design and programming of the jail However we have documentation from Sheriff Officials that they were concernedthat the CEO was meeting with AECOM on the jail design and construction withoutparticipation from the Sheriffrsquos Office

In fact we acknowledge several times throughout our report the WCSOrsquos involvement

and participation in the construction of the jail Unless the respondent can specificallypoint to instances where we state the WCSO was not involved in the design and planningstages of this project we respectfully decline to make a change to the report


A The WCBA prior to beginning a major construction project stakeholdersunderstand and use recognized best practices in the construction industryincluding delivery method type of contract realistic budget and propertyoversight

B Leadership place greater reliance on organizations that understand the needsproblems and individual requirements of local correction agencies such as theNational Institute of Corrections

C The WCBA considers developing a website similar to the one being used bythe Detroit Regional Convention Facility Authority (DRCFA)

Views from Responsible Officials

A Prior to the request for a Resolution of Intent the County engaged AECOM tomeet with all of the stakeholders This included not only the Sheriff but theProsecutor Jail Medical and Public Defenders Concerns and requestsregarding programming and population management were all incorporated inAECOMrsquos final program See Exhibit B

The County relied on the Program Manager and the Architect regarding thedelivery method and the budget These terms are incorporated within theircontract When the County proceeds with the Project it will again rely on itsProgram Manager and Architect to recommend a budget and delivery method



19

B AECOM did employ Best Practice and demonstrated the use of nationallyrecognized organizations in its Programming Mistakes were made but therecord reflects that AECOM presented and the County relied upon itsexpertise

C The County utilized MITEN as a website for the construction of the Jail ThisMichigan bid system provides a way for local government agencies in Michigan to moreeffectively notify vendors of RFP and bid opportunities while using shared resources toincrease efficiency and reduce costs The procurement solution delivers supplierscentralized online location to view and receive Michigan RFPs and bid opportunities from over 100 Michigan local government agencies This is a national recognizedwebsite utilized by vendors wishing to bid on contracts Additionally the County hasdeveloped a website for the Building Authority wwwwaynecountycom We believe theuse of MITEN and the development of the website clearly addresses the issue listed inrecommendation C

Jail Design-Bed Capacity pg 60


We recommend the WCBA take into consideration the possibility of expanding thenumber of jail population beds to 2512 when reaching a decision regarding the future ofthis Project


We believe this is a decision of the Commission Executive and Sheriff It is not thedecision of the WCBA The capacity of the consolidated jail project of 2000 beds wasbased on conversations with the Wayne County Sheriff The Wayne County Sheriffattended Commission meetings regarding this capacity and did not object Additionallyprior to determining the capacity of the proposed facility AECOM presented the Sheriffthe Commission and County Staff with projections on population and cost Thisinformation led to the decision of 2000 bed capacity See Exhibit C AECOMProjections

As the County proceeds with the new project the same conversations will occur with theWayne County Sheriff Commission and other stakeholders If it is determined that a2500 bed facility is optimal that will be the decision of the Wayne County Commission

Information and Communication

Recommendation 2013-04- pg 63

The WCBA and the administration should explore the legal possibility of requiringdispute resolute clause to allow the owner the right to arbitration at their sole discretion



20

when there is a disagreementdispute and not have it predicated on work actuallyperformed and a claim filed


Disagree The Dispute Resolution Clause within the CMAR Contract is based onstandard construction terms The County could consider ldquomediationrdquo or other type ofresolution however it is doubtful that a contractor will assume the type of risk duringconstruction The OAGrsquos suggestion would mean a contractor would need to delayconstruction until the dispute is resolved Additionally delays that are caused orrequested by the Owner would then be costs that would be assumed by the County

OAG ResponseIt is our understanding that a unique approach was being used in construction of the jail ndashwe suggest why not take a unique approach to revising construction contract language to

benefit the county in situations when disputes may occur during the construction process

In regards to the Countyrsquos decision to hire an outside firm to assess the overall state ofthe project the County disagrees with this assessment The Hubbel Roth Report gave theCounty insight that was needed It was not limited to looking only at the CMAR assuggested in this recommendation We believe that the OAG has not viewed the factscorrectly

OAG ResponseWe contend that other means possibly could have been explored before $73000 wasspent and we still have not resolved the disputed differences The OAG maintains that theAdministrationrsquos decision to hire a professional engineering and architectural firm toperform an independent review of the claims for additional costs related to the jail was anexample of a waste of county funds Pursuant to the construction management at risk(CMAR) contract under Article 10 it allows the owner at its own discretion to elect to goto arbitration over claims disputes or other matters in question

Wayne County Building Authority Board of Commissioners ndash pg 64

We understand the assumption regarding the lack of authorization from the WCBA Itwas the responsibility of County Staff to ask for a recommendation or resolution Neitherwas provided to the WCBA We believe that is an unfair to profess that the WCBA isresponsible for this matter The WCBA trusted County staff to direct AECOM tocomplete these reports The lack of written reports should not be attributed to theWCBA This is a material weakness of the County Staff not the WCBA We would askthat you revise this section



21

OAG ResponseA recommendation was proposed by Special Counsel for the WCBA to allow a monthlyprogress report to forward to the Commission on specifically what percentage ofsubcontracts are to Wayne County businesses how far the project is in spending and howclose in construction There is no documented evidence that written reports were

prepared

We believe that the WCBA as the oversight body should have requested and receivedwritten reports on the status of the project as a matter of public record and failure to do somay have impaired their ability to carry out their fiduciary responsibilities Thereforewe see need to revise this section as requested by you


We recommend the WCBA prepare monthly written status reports as a matter of publicrecord to assist board members in carrying out their oversight responsibilities Also we

suggest a presentation be made and a status report filed with the Wayne CountyCommission on a semi-annual basis since Wayne County is the guarantor on the bonds

In addition we suggest that the WCBA develop informational material for publicdistribution and consult with the Department of Technology to develop a website similaro the one being used by The Cobo Hall Regional Authority


Monthly Reports We agree written monthly reports should be provided We wouldsuggest on large capital projects presentations should be made on a quarterly basis notsemi-annually As noted above the County has and will continue to utilize MITENAdditionally the County has developed a website for the Building Authoritywwwwaynecountycom

OAG ResponseThe OAG acknowledges managementrsquos concurrence with the recommendation

Monitoring pg 66

Throughout this section of the OAG report there appears to be a generalmisunderstanding regarding the responsibilities of the Countyrsquos Oversight CommitteePlease note the following

Building Authorities are only financing tools for the construction of public buildingsUnder the Contract of Lease it indicates that the operation maintenance and use of thefacility will be for the incorporating unit the County It is the County under the Contractof Lease that determines how the facility will be designed and used



22

At the onset of this Project the County issued an RFP to find a ProgramManagerArchitect that would operate as the Countyrsquos Ownerrsquos Representative on anRJC When the scope of this project was reduced it was logical that the County initiallyintended that the AECOM would operate as the Ownerrsquos Representative AfterParlovecchio Building was selected as the Ownerrsquos Representative weekly meetings

were held with the DCEO the Director of EDGE the Ownerrsquos Representative andAECOM

These weekly meetings were appropriate to keep the County informed regarding theprogress on the Project Issues and contracts were then taken to the WCBA for approvaland informational presentations were given at each meeting

In October of 2011 meetings were then scheduled with a committee of AECOM theOwnerrsquos Representative the CFO the COS Sheriffrsquos Representative the BuildingsDirector and Special Counsel These meetings went on to include representatives fromIT and the Countyrsquos Chief Operating Officer These Committee meetings often had as

many as 6-10 County employees in attendance regarding the progress on the Project

As the ultimate owner and user of the facility a venue needed to be created whereAECOM and the Ownerrsquos Representative could bring updates issues and progressreports to the County Ultimately this committee became known as the OversightCommittee AECOM NEVER REPORTED TO THE OVERSIGHT COMMITTEE ITGAVE REPORTS AND UPDATES TO THE OVERSIGHT COMMITTEE

The County needed to monitor the progress on this Project We would assume that if theCounty had not established such a committee that the OAG would have established afinding that the County was not monitoring the Project

As cited earlier in your report staff indicated to the WCBA that they wanted a structurewhere decisions were made by the WCBA not the Ownerrsquos Representative The OAGindicated in several areas an agreement that more decisions should have been made bythe WCBA

The creation of the Oversight Committee as a venue to ensure that information was givento the County on a weekly basis was a prudent decision The County acknowledged andexpected AECOM to operate as the Countyrsquos Ownerrsquos Representative We believe thisreport and specifically this section should not be written in a manner that would provideAECOM with justification for not fulfilling certain contractual duties

We are asking that the OAG reconsider the facts regarding this Project We do notbelieve providing narratives and conclusions that contractual duties that rested with theCountyrsquos vendors should be shifted and presented as the County is responsible for theseissues




23

We recommend that monitoring of the consolidated Jail Facility Project be entrusted toan Ownerrsquos Representative or its equivalent who should be an independent third partythat represents and reports directly to the WCBA


Hiring of Ownerrsquos Representative The OAG suggests that an Ownerrsquos Representativeshould be a direct hire of the WCBA We do not agree that this is a material weaknessAn Ownerrsquos Representative or Project Manager (such as Mr Newton) who is a direct hireof the County protects the Countyrsquos interests The WCBA should not have interests thatdiffer from the County

OAG ResponseThe WCBA is the owner of the Consolidated Jail Facility Project and as the owner thereare associated monitoring responsibilities Moreover while the Oversight Committeeclearly serves an important function it is not providing the day-to-day Project interface to

address the myriad of issues that may arise during a project of this complexity Also theOversight Committee does not possess the qualifications experience andor the skill setneeded to meet the goals and objectives of this project

We see no difference between the interest of the WCBA and the county ndash in simple termsone is the lessor and the other is the lessee Their combined goals and objectives are thesame - which is to build a 2000 bed jail facility within a given period of time

The CMAR contract in numerous instances makes reference to an OwnerrsquosRepresentative and that failure to provide a reputable one has consequences

COMPLIANCE WITH THE CONSTRUCTION CONTRACT THE DAVIS

BACON ACT ARRA COMPLIANCE DN THE BOND COVENANTS

Bond Issuance and Covenants

Contract of Lease

Point of Clarity- Pg 74

Section 2 is inaccurate Counsel did inform the OAG that the Waldbridge-dck contractwould need Commission approval if a change order exceeded the $220 Million Dollarauthorization given in August of 2011 This statement should be removed

OAG ResponseThe OAG based our comments on the following responses from Special Counselcontained in a July 22 2013 e-mail

ldquoThe Procurement Policy addresses this issue I am assuming you are referring to the $0change order As the chief administrative officer of the WCBA if a change order does



24

not entail a change in cost or a substantial change in scope then it can be treated as thesame as a small purchase It becomes an administrative duty

ldquoIt is the same issue with change orders for the Wayne County Commission Eventhough there is not a provision within the charter or some other document stating that

change orders must be approved by the Commission I could not support that logic I donot believe the WCBA could approve a change order that substantially changes the cost

or substantially changes the scope without going to the Commissionrdquo(Emphasis added)

Cause This term was not written by administration regarding the Contract of Lease andthe powers of a building authority to bond This term and the bond documents werewritten by nationally recognized bond Counsel using language that is necessary for theexecution of a Contract of Lease under the Building Authorities Act This statement ismisleading and should be removed

Criteria

OAG takes exception to standard clauses within the Contract of Lease document Thesedocuments are written by bond counsel and we assert that their language is correct andnecessary under the Building Authority statue Legally the WCBA makes the bondpayments Therefore it must receive an allocation from the County for such paymentsThis is currently being done during each yearrsquos budget hearings on ALL BuildingAuthority Bonds The creation of an IGA will not dismiss the requirement that theCounty must make these allocations under the statutory provision of a Contract of LeaseThese cannot be done by an IGA Furthermore for your review we are attaching an e-mail and memo that was provided to Commission Counsel regarding these provisions in2010 These responses were completed with the assistance of bond counsel and addressthe concerns you are noting See Exhibit D e-mail and Responses to CommissionCounsel

OAG ResponseThe OAG recognizes that under Public Act 31 (PA 31) a contract of lease is required tobe executed The required clauses may be standard within the Contract of Leasehowever the language written by bond Counsel is not ldquostandardrdquo but crafted specifically

for this Contract (Emphasis added)

PA 31 123961b Ordinance or Resolution Authorizing Issuance of Bonds

Adoption Contents Sec 11b requires aldquohellipresolution authorizing issuance of bondshelliprdquoThis requirement was satisfied by the WCBA as well as the Wayne County Commission

PA 31 12396 1f Additional Bonds Sec 11f states ldquoThe commission in the ordinanceor resolution authorizing the bonds may provide for issuance of 1 or more series ofadditional bonds to complete the project for which the bonds are issuedhelliprdquo

In November 2010 the WCBA passed a resolution authorizing the issuance of the Series2010 Jail Facilities Bonds Section 18 Additional Bonds states ldquoNothing contained in



25

this resolution shall be construed to prevent the Authority from issuing additional bonds

pursuant to Act 31 (a) to finance the construction of any new buildings or projects withinthe scope of its corporate powers hellipor (b) to complete repair or alter the Project asauthorized in the Contracthelliprdquo (Emphasis added) This resolution took into considerationand wrote into the Contract of Lease both sections of PA 31 referenced above

The Contract of Lease between the Wayne County Building Authority and the County ofWayne contained among other items the following

WHEREAS the COUNTY and the AUTHORITY have determined that all or partof the cost of phase one of the Project should be paid by the authorization andissuance of bonds in one or more series by the AUTHORITYhellipin the principalamount of not to exceed Three Hundred Million Dollars ($300000000) with thebalance of the cost if any of the Project to be paid out of moneys to be made

available by the COUNTY to the AUTHORITY as herein providedhelliprdquo (Emphasisadded)11 ldquoIn the event that it should be determined that for any reason there are not

sufficient funds to complete the acquisition of the Projecthellipit is agreed by theparties hereto that this Contract may be supplemented or amended to provide forthe issuance of additional bonds by the AUTHORITY to provide sufficient fundsto completehellipthe Project and also to increase the Cash Rental by an amount fullysufficient to pay all principal of and interest on the Bonds herein referred to andsuch additional bonds when duerdquo Emphasis added

Therefore the OAG is still of the opinion that a risk exists for the county despiteassurances provided by Special Counsel regarding concerns expressed by CommissionCounsel when the Contract of Lease was executed

As further evidence that the ldquostandardrdquo clauses were crafted specifically for this Contractthe OAG reviewed a Contract of Lease executed between the City-County BuildingAuthority and the County of Kent Michigan This contract was specific as to where allfunding would come from Specifically

ldquohellipthe Building Authority proposes in accordance with the authorizationcontained in Act 31 to provide for the issuance of building authority bonds in theaggregate principal amount of not to exceed Ninety-Five Million Dollars($95000000) hellipto defray a portion of the cost of the Project hellipandldquohellipthe balance of costs of the Project are expected to be paid through interestearnings on the proceeds of the Bonds and State of Michigan and federal grantfunds private contributions and funds contributed by the City of Grand RapidsDowntown Development Authority and the CAA (the ldquoOther Contributionsrdquo)hellip

Based on the above the OAG find no basis to amend our conclusions regarding thismatter




26

A Section 11 of the Current Contract of Lease be amended to mitigate this perceivedrisk to Wayne County

OAG ResponseSee all of the OAG comments above


We disagree The Building Authorityrsquos Resolution of Intent is for $300 Million TheWCBA did not have legal authority to issue bonds beyond its delegated authority Anybond issuance backed by the full faith and credit of the County needs Commissionapproval This statement did not legally divest the Commission of this approval BondCounsel confirmed that the issues regarding payments and the requirements under theContract of Lease must be met There is no legal means for the WCBA to issue bondswithout an amendment to the Contract of Lease or without County approval

B In addition an IGA should be established between the WCBA and the County ofWayne to reduce risk and provide clarity and understanding between the two localgovernments


The County does not disagree with the idea of an IGA However please understand thatsince Building Authorities are financing bodies the Contract of Lease is the documentthat will always usurp any other contract The Contract of Lease is created to addressoperational responsibilities and costs Additionally if an IGA were created it wouldneed the approval of Bond Counsel to ensure that we have not violated any of the termsof the Bond covenants

OAG ResponseThe OAG acknowledges managementrsquos disagreement with the recommendation

Davis Bacon Act-Compliance

American Recovery and Reinvestment ActCompliance with IRS Regulations


The board should refrain from entering into personal service contracts unless it is with anindividual that is registered as a company because it could expose the WCBA tounnecessary risk of incurring severe penalties if those individuals fail to file tax returnsfor the compensation received in any given year

Views From Responsible Individuals



27

MampB disagrees with this finding and is confident that County is not responsible forindividuals failing to file tax returns Utilizing personal service contracts can be a costeffective tool for obtaining professional services from individuals who offer specializedexpertise An independent contractor is an individual over whom the employer has theright to control or direct only the result of the work and not the means and methods of

accomplishing the result

Each independent contractor has a signed personal services contract with WCBA Thecontract explicitly defines the relationship between the individual and the WCBA insection 501 and discloses that no liability or benefits will be accrued by either party as aresult of the contract Upon MampBrsquos cursory review of the IRS 20 Rule Test forestablishing employment relationship the personal services contracts and the scope ofservices it is clear that each contractor is operating as an independent contractor and thatan employer-employee relationship does not exist

The contract further explains in section 1201 that WCBA will furnish information

returns including Form 1099 to the contractor and appropriate government entities bytheir required due dates and in accordance with applicable law The County properlyissued form 1099-MISC to each contractor and filed with the appropriate taxingauthorities However the County assumes no responsibility or liability for thecontractorrsquos reporting of income or payment of taxes to the IRS Each contractor isresponsible for filing and paying their own income taxes and self-employment tax

OAG ResponseThe OAGrsquos concern is the potential tax liability to the WCBA should the InternalRevenue Service deem these independent contractors to actually be employees of theWCBA The OAG has also reviewed the IRS 20 Rule Test for establishing anemployment relationship The OAG is of the opinion that some of the following IRS 20rules may apply to classifying the independent contractors as employees of the WCBA

bull Rule 6 ndash Continuing Relationships Continuing relationships between workersand employers indicate that employer-employee relationships exist

o One of the independent contractors was a WCSO retiree who performedbasically the same services as when he was an employee

bull Rule 8 ndash Full-time Required If workers must devote full time to employersrsquobusinesses employers have control over workersrsquo time Independent contractorsare free to work when and for whom they choose

o It is doubtful that these independent contractors worked for anyone other

than the WCBA

bull Rule 17 ndash Working for more than one firm at a time If workers performservices for a number of unrelated persons at the same time they are usuallyindependent contractors

o It is doubtful that these independent contractors performed services foranyone other than the WCBA



28

bull Rule 18 ndash Making services available to the general public Workers areusually independent contractors if they make their services available to thegeneral public on a regular and consistent basis

o It is doubtful that these independent contractors made their servicesavailable to the general public on a regular and consistent basis

The OAGrsquos recommendation is focused on avoiding any personal service contracts thatmay be deemed an employer-employee relationship by the IRS thus mitigating anypotential payroll tax liabilities

Record Retention ContractorsOwnerrsquos Representative

Point of Clarification Results of Work Performed The Director of Buildings was amember of the Oversight Committee The Director attended regular meetings and alsoattended weekly meetings with Walbridge

OAG ResponseWe acknowledge this clarification and will amend the report accordingly

Point of Clarification Pg 89 again the Director of Buildings was a key member of theOversight Committee who attended Oversight meetings The Director of Buildings alsoattended weekly meetings with Walbridge and AECOMPoint of Clarification Pg 88


The County disagrees with your first paragraph regarding a budget First we understandthat the OAG has relied upon Cost Projection Sheets not budgets That is understandableUpon reviewing such sheets carefully along with the board actions taken by theCommission and the WCBA you will see that the County has not authorized anycontracts that would allow the County to exceed the $300 Million Dollar allocationPlease review the attached schedule See Exhibit E Contracted Costs By February of2012 the County had only contracted for $272 Million Dollars Currently the Countyrsquoscontracted responsibilities continue to hover around that $270 Million Dollar numberThese figures include acquisition CMAR contract the AECOM contract and all knowncontractual responsibility

The County has a current disagreement with AECOM regarding their responsibilitiesunder the First Amendment This Amendment states that AECOM is to ensure theProject is programmed and designed to stay within the $300 Million Dollar allocation Ifthe OAG reviews the documents currently available this will demonstrate that the Countyhas consistently indicated to AECOM that they must comply with this term If the OAGcontinues to misstate the facts or imply that the County knew or somehow agreed that the$300 Million Dollar Allocation could be exceeded then AECOM will have a justification



29

not to adhere to their contract We would ask that the OAG consider revising suchstatements to ensure that accuracy is reflected in this report

OAG ResponseThe OAG relied upon documented ldquobudgetrdquo figures in support of our comments The

OAG comments in no way stated or inferred that these costs were already contractuallyobligated To eliminate any confusion the OAG will add the word ldquoestimatedrdquo in front ofldquoProject costrdquo Again we were speaking to the fact that total estimated Project costsexceeded the original ldquobudgetrdquo of $300 million This is not new information but has beena matter of public record for many months

The OAG is familiar with the requirements of the First Amendment to theAECOMGhafari contract We believe it is a stretch on the Administrationrsquos part to inferthat our comments could provide a reason for AECOMGhafari to breach their contractwith the WCBA since each contract must stand on its own merits and not conclusionsreached by the OAG


Have the current County Project Manager become a leased employee from WayneCounty to the WCBA with specific job descriptions duties and responsibilities that aretypical of an ownerrsquos representative or Issue a Request for Proposal for an ownerrsquosrepresentative who would be independent and report directly to the WCBA Board

In addition the WCBA Chair should form a capital improvement sub-committee of boardmembers similar to the COBO Hall Expansion Project The CAO and OwnerrsquosRepresentative would report to the sub-committee and in turn will report to the WCBAboard on a monthly basis



Agree in part and disagree in part We agree in Section A that any Project Managershould have a clear delegation of duties Additionally we would agree with what you areimplying regarding the ldquoleased employeerdquo It is important to note that the WCBA is acomponent unit of the County Neither staff nor the board should be in a position whereit can be perceived that their fiduciary duties are separate to their duties to the CountyThe WCBA exists in order to finance projects for Wayne County

OAG ResponseSince the goals and objectives of the WCBA and Wayne County are the same which is tobuild a 2000 bed jail facility and it is evident that WCBA are the owners of the projectwe fail to see how the Project Manager reporting directly to the board would createseparate interest unless Wayne Countyrsquos intent is to completely control the project



30

In regards to the recommendation for a sub-committee we would agree that such acommittee would be useful However as we stated above we believe that allowingCommission representation and creating an ad-hoc committee is a more transparent

manner in which to accomplish this issue Creating a sub-committee that would divestthe WCBA Board of its statutory powers would not be a prudent decision

OAG ResponseThe OAG believes that if a super committee exists for the COBO Hall RegionalConvention Authority (CHRCA) ndash which is a $279 million project and is very successful- with a five member board and 3 members on the capital improvement sub-committee -then why canrsquot the same concept be used for the WCBA This issue is being raisedseveral times to the administration but no viable alternatives are offered Moreimportantly the oversight model the WCBA is currently using has failed to meet theirgoals and objectives

No Bid Contracts

Results of Work Performed- pg 92

As stated previously this statement is inaccurate AECOM had been paid approximately$2 Million Dollars for the Regional Justice Center Study prior to the decision to decreaseits scope to a consolidated jail They had an approved contract that extended toDecember of 2011 They utilized the National Institute of Corrections Best Practicespresented their ideas to the County Commission and Administration and engaged innumerous meetings with staff from August of 2010 to December of 2010 Theydemonstrated a program and a proposed operational savings See Exhibit APresentations Best Practices See also Exhibit F Payment History of AECOM

Furthermore the Commission questioned the use of AECOM during Commissionmeetings prior to the issuance of the bonds The County was forthright in explaining theneed to retain them rather than starting the process over The County did not receiveobjections from the Commission We would have been pleased to present Commissionrecords of these meetings but we have been informed that the Commission erases itsvideo records Therefore minutes and discussions regarding this matter with the WayneCounty Commission meetings are not available

The OAG is suggesting that the County should have cancelled the AECOM Contractafter receiving the Bond Resolution and started the Project again Not only would thishave taken several months AECOM would have been precluded from bidding TheCounty acknowledged and presented the fact that AECOM was going to be kept on as theProgram Manager when it approached the Commission This decision would have costthe County several million dollars



31

OAG ResponseThe fact remains that AECOM was awarded a no bid contract on August 1 2010 It isirrelevant that AECOM had a contract that extended through 2010 because (1) an optionto renew was not exercised and (2) the scope and compensation of the original contract

was modified materially The OAG did not suggest that the AECOM contract shouldhave been cancelled The OAG merely pointed out that the contract was awarded withoutbid which is factually correct

However we did amend the report to state that the AECOM contract was originally bidin 2006 and the decision to continue the use of AECOM services were due to theAdministrationrsquos desire to save costs

Additionally it should be noted that the WCBA was bound by the Countyrsquos ProcurementOrdinance in absence of an adopted policy The County Procurement Ordinance allowsfor sole source contract The decision to hire Parlovecchio Building Inc was not

impermissible under the Countyrsquos procurement ordinance at the time A businessdecision was made to provide a sole source contract by the Deputy CEO This wasallowed under the Countyrsquos Procurement Ordinance

OAG ResponseThe OAG is aware of the Sole Source section in the Countyrsquos Procurement Ordinance asfollows

Sec 120-33 Sole SourceldquoAny request by an agency or department head that procurement be restricted toone potential source shall be accompanied by a letter from the using departmentsigned by the department head stating why no other source will be suitable oracceptable to meet the needs A contract may be awarded for a real propertysupply service or construction item without competition when the PurchasingDirector or his or her designee determines in writing that there is only one sourcefor the required property supply service or construction item or that theproposed award to a single source is a permitted non-competitive procurement asestablished herein

After verification of a sole source vendor or the justification of a sole sourcepurchase is warranted the Purchasing Director or hisher designee has theauthority to negotiate the price terms and conditions of the procurementrdquo

ldquoThe Purchasing Director may treat procurement as a Sole Source Procurementunder some documented circumstances where there are extremely limitedsuppliers of a given commodity upon documented evidence from the requestingdepartment that the comparable sources for the desired product are not in theCountyrsquos best interest Examples of this comparable source situation couldinclude but are not limited to software applications homeland securityequipment certain employee benefits or designated professional servicesrdquo



32

The OAG agrees that the WCBA was bound by the Countyrsquos Procurement Ordinance inabsence of an adopted policy as stated above by management However there is noevidence that the above two sections of the procurement ordinance were followed in theawarding of the Parlovecchio Building contract The rationale to hire Parlovecchio

Building was provided by Special Counsel to the WCBA at a May 5 2011 WCBA Boardmeeting

ldquohellipit came to our attention that Mr Parlovecchio had worked with the county forseveral years He also indicated to us several weeks ago that it was his decision toterminate his employment with Wayne CountyhellipAt the same time we had a lotof confidence and so did the team of AECOM and Ghafari in utilizing him as anownerrsquos rep on the Project So AECOM and Ghafari through negotiationshelliphasagreed to hire Parlovecchio Building as an ownerrsquos rep on behalf of theAuthorityhellip

ldquoWe think itrsquos important to disclose that for you because Mr Parlovecchio was anemployee of the countyhellipso we want everything above board We want to makesure the record reflects that hersquos being hired by AECOM that AECOM is goingforward with the Authority and that therersquos been complete disclosure oneverything that is going onhelliprdquo

On May 5 2011 the Special Counsel to the WCBA requested that ldquohellipthe BuildingAuthority contract directly with Parlovecchio Buildinghelliprdquo to become the ownerrsquosrepresentative

The OAG is of the opinion that the criteria for awarding this sole source contract was notmet and find it incredulous that Parlovecchio Building (an employee of EDGE whoresigned from the county less than one week before being awarded the contract) was theonly qualified person in all of Wayne County who could perform the duties of OwnerrsquosRepresentative

More importantly the CEO elected the option to terminate the contract with ParlovecchioBuilding Company in December 2011 stating because it was not originally put out forbid


The WCBA should amend the procurement policy to establish a clear threshold as to thedollar amount when contracts are required to be competitively bid


Agree We have no disagreement that a new section should be added to the WCBAProcurement Policy addressing Sole Source Comparative Source IFB and other



33

relevant procurement issues This would also include the WCBA being able to use theMIDEAL website


Contract Elements

Missing Dates

Addendum to Pre-Construction- We take note of the OAG concern but would add thatattached to this Addendum is a certification which indicates the dates However theOAG concern is justifiable

OAG ResponseWayne County Building Authority Resolutions are accompanied by a Certification that is

subscribed and sworn before a Notary Public The Certification states that ldquohelliptheattached resolution is a true correct and complete originalhelliprdquo

The Certifications do not contain specific contractual dates they do contain the date theWCBA Board approved the resolution

First Amendment to Program Management and Architectural Services- There are dateswritten on this agreement in its heading Proof of this issue is on the Wayne CountyBuilding Authorities website We would ask that the OAG review and remove thisconcern

OAG ResponseThe OAG obtained a copy of the agreement containing dates The OAG will remove thisconcern from the report

Pre-Construction Services with Walbridge- We agree that the date was not filled in onthis agreement This is an oversight since the anticipation was an August start dateHowever all contracts must be accompanied by a certification This addresses the termWe take note of the OAG concern

OAG ResponseWayne County Building Authority Resolutions are accompanied by a Certification that issubscribed and sworn before a Notary Public The Certification states that ldquohelliptheattached resolution is a true correct and complete originalhelliprdquo




34

CMAR Contract- The Commission originally planned an August approval date Weagree a correction should have been made Again the certifications of such contractsaddress the concern

Missing Signatures

Sub-Consulting Services- The contracts in our possession and on the website includeexecuted copies We are puzzled at your finding We would ask you review your recordsand remove this issue

OAG ResponseThe OAG obtained a copy of the agreement containing all applicable signatures TheOAG will remove this concern from the report


The WCBA as well as the Wayne County Commission should ensure that all requiredelements of a contract are present before approval is granted to execute the contract Inaddition a well defined scope of services is a critical element of a contract


All of the elements of each contract are included in each of the contracts All of thecontracts are executed by the necessary parties This provision should be removed andwe disagree with the implication that elements are not included

In regards to the Legal Service Contracts we agree There should have been a clearscope of service instead of a generalized scope provided


Contract Analysis

The OAG has misstated the facts Additionally the OAG has not engaged inconversations with counsel The OAG did send an e-mail request and Counselresponded with an answer An e-mail was sent to the OAG on July 23 2013 providingthe six different sections where an audit is allowed under the CMAR This e-mail isattached for reference See Exhibit G e-mail on Audit Provisions


We recommend the Wayne County Building Authority amend the Walbridge-dckcontracts well as all other contracts associated with the consolidated Jail Project tospecifically include a clause granting the owner or their representative the right to audit



35


We donrsquot disagree with the OAG we simply assert that the facts and conclusion aremisstated The OAGrsquos request for a generalized audit would not be sufficient in aconstruction contract This does not change the fact that construction agreements must

have the different audit provisions addressing different issues We will continue to utilizethe six different sections It should also be noted that Walbridge has indicated our rightto audit and we are working out a single audit for the close out of this contract If theOAG would like additional provisions we will consider any additional provision thatadds protection to the County However any additional provision should be writtenunder industry standards We would disagree that a generalized statement would besufficient in a construction contract The OAG has not produced contracts in which theright to audit is missing We would state that assuming and professing a deficiency insuch contracts is not constructive It is misleading and does not have any documentedsupport

OAG ResponseThe OAG did not misstate facts or conclusions

On July 20 2013 the OAG asked Special Counsel to the WCBA via e-mail thefollowing question

bull Does the Walbridge CMAR contract include a right to audit clause

On July 23 2013 Special Counsel replied as follows

bull Yes however since it is a construction project it is mentioned in severalplaces Article 71- Audits on profit and fees Section 713 Section audits

on subcontracted work 112 Audits on payments to subcontractors proofof payments 513 Audits on CCIP Under general conditions 836audits for delay Section 1434 Davis Bacon Audits

The OAG is not disputing the existence of these audit clauses rather the OAG has statedthe audit clauses are vague as to who has the right to perform the audits This isevidenced by the language in the audit clauses referenced above by Special Counsel

The following sections are contained in the GUARANTEED MAXIMUM PRICECONSTRUCTION MANAGEMENT AGREEMENT between the Wayne CountyBuilding Authority and Walbridge-dck Joint Venture dated February 9 2012

bull Section 513 ldquohellipThe final value of the credit shall be determined at theconclusion of the work through an audit of the project records and theGMP shall be adjusted accordinglyhelliprdquo (Emphasis added)

bull Section 71 ldquohellipCMAR Direct Costs are subject to audit to verify accuracyincluding that no element of profit or overhead is included in thesubmitted Direct Costshelliprdquo Emphasis added



36

bull Section 713 ldquoIf CMAR elects to subcontract any portion of the Workrequired as part of CMARrsquos Direct Costs CMAR shall not seek or obtainreimbursement for any overhead or profit on such costs these costs shallbe subject to audit as set out aboverdquo Emphasis added

bull Section 112 ldquohellipThe staffing levels and payments to joint venture partnersin the amounts of the Declared Interest will be determined by audit ofhours charged to the Project during and after the performance of theConstruction Work Initially this audit will be conducted together with theaudit of CMAR records for the purpose of confirming the Cost of theWork incurred and paid by CMAR however CMAR shall provide suchother and further documentation or proof of payments as may be requestedby Ownerrsquos Representative as deemed necessary in the sole discretion ofOwnerrsquos representative for the completion of the audit of joint ventureinterests staffing and distributionshelliprdquoEmphasis added

The OAG is still of the opinion that the above ldquoauditrdquo clauses are vague as to who willperform the audit

An example of the right to audit clause language is contained in the OwnerArchitectAgreement between the Wayne County Building Authority and AECOM services ofMichigan Inc for Program Management and Architectural Services for the creation of anew Wayne County Justice Center

Section 1282 ldquoOwner has the right to examine and audit all books records documentsand other supporting data as Owner deems necessary of the Program ManagerArchitect

or any sub consultants or agents performing services under this Agreement whetherdirect or indirect that will permit adequate evaluation of the services performed by theProgram ManagerArchitect and any subconsultants Program ManagerArchitect mustinclude a similar covenant allowing for Owner audit in any agreement it has with asubconsultant or agent related to this Agreement Owner may delay payment to theProgram ManagerArcitect pending the results of any such auditrdquo (Emphasis added)

The following sections are contained in the General Condiitons of the GuaranteedMaximum Price Construction Management Agreement for the Wayne CountyConsolidated Jail Facility for the Wayne County Building Authority

bull

Section 836 ldquoClaims of CMAR for costs and damages resulting from theOwnerrsquos suspension delay or interruption of the Work shall be determined inaccordance with the following hellipThese costs shall be subject to audit by theOwnerrsquos Representativerdquo (Emphasis added)

bull Section 1434 ldquoCMAR consents to an audit of its books and records by theOwner for the purposes of verifying compliance with Davis-Bacon and RelatedActshelliprdquo



37

Upon further review the OAG agrees that the above ldquoauditrdquo clauses are specific as towho will perform the audit

Sheriffrsquos Transition Team

Point of Clarification 03 indicates that the Oversight Committee was involved inthe hiring of the Sheriffrsquos Transition Team including interviews This is inaccurate TheSheriff selected his team members and informed County staff of his selections

Additionally it is a misstatement that Oversight Members were not responsive TheSheriff was a member of the Oversight Committee We are unaware of the issues that arenow being raised Of more importance would be a request of a document thatdemonstrates that the Sheriff believed $25-$30 Million more was needed for the ProjectWe have provided you with the document demonstrating that in May of 2011 the Sheriff

signed off on the Programming of the new jail Additionally attached are documentsdemonstrating not only the Sheriffrsquos participation but also the attendance of Sheriff staffmembers at the weekly meetings with AECOM Both documents along with theacknowledgement that the Sheriff and his team attended Oversight Meetings demonstratetheir involvement See Exhibit B

The OAG should also recognize that in March of 2012 AECOM presented a CostProjection Sheet demonstrating the Countyrsquos ability to complete the Project for $300Million See Exhibit H March Cost Project Sheet In May and June of 2012 the Sheriffapproached members of the Oversight Committee and indicated that he desired to haveAECOM explore the possibility of expanding the facility and increasing capacity toapproximately 2400 beds This request delayed construction but was a reasonablerequest to explore These actions demonstrate an active involvement by the Sheriff in allaspects of planning and development of the facility

OAG ResponseThe statement that the Oversight Committee participated in the selection of the JailTransition Team is based on statements from Sheriff Officials as stated in the report

We were not able to find in the report that the Oversight Committee members were notresponsive The report stated that Sheriff Officials had several concerns regarding the jailconstruction which was voiced to the Oversight Committee and has continued to do so inongoing communication As stated by Sheriff Officials $25-30 million was needed Wewere not able to find in this section of the report where we state that Sheriff Officialswere not involved

Jail Design and Capacity

RECONCILE CONSTRUCTION COST AND CASH BLANCES RECORDED IN

THE GENERAL LEDGER



38


We recommend that PMampA and the WCBA accounting personnel independently verifytheir respective bond proceeds control ledger balances with the WCTO cash sub-ledgerreport on a monthly basis and maintain a copy of that information in their files as part oftheir books and records This will validate the bond proceeds control ledger balances arein agreement with the ledger balances being carried by the Treasurer

In addition the QuickBooks general ledger should be reconciled to the WCBArsquos generalledger on a monthly basis and any adjustments be identified and corrected each month ona timely basis

Views of Responsible Officials

Wayne County Treasurerrsquos Office (WCTO) maintains a cash ledger in RESIQ2 at thecash pool level and not at the individual fund level in the general ledger The WCTO cashbalance for the Building Pool includes cash balances of multiple funds within JDEdwards (JDE) Therefore PMampA can not reconcile the jail project cash total (fundlevel) to the WCTO cash ledger (Pool) balance The jail project cash account in JDE isonly one of the cash accounts that makes up the total cash balance in the Building PoolMampB is responsible for the monthly reconciliation of the individual fund cash accounttotals from JDE to the appropriate cash ledger (Pool) balances from WCTO PMampA relyon this process The $127886 reconciling item referenced in the conclusion section onPage 9 of the OAGrsquos report is a result of a timing difference between recording thesheriffrsquos transition team costs in the jail fund for June 2013 and the settlement of cash inJuly 2013

OAG Response

With the assistance of the Wayne County Treasurer Office (WCTO) we were able toconfirm with them the bond proceeds cash balance being carried by them at the end ofeach month

We are suggesting the cash bond proceeds recorded by the WCBA QuickBooks and theWCTO bond proceeds cash balance all agree with each other at the end of each monthWe were in fact able to perform this procedure for several periods and noted there was anin transit transaction in the amount of $127866 at June 2013 If this reconciliationprocess had not been completed for the month of June 2013 the $127866 differencewould not have been corrected on a timely basis

There are three separate accounting systems in which the jail bond proceeds are recordedOur recommendation is for Pierce Monroe and Associates (PMampA) who has delegated



39

authority to maintain the books and records over the jail bond proceeds and MampB torequest on a monthly basis from the WCTO a cash balance confirmation report from theirRESIQ2 system to ensure the actual cash balance reported by the WCTO reconciles toboth the recorded cash balance reported in the QuickBooks and the countyrsquos generalledger

Maintaining the WCTO cash-sub ledger reports within their reconciliation files willvalidate all three accounting systems are in balance as of the indicated date

Therefore since the Administration was able to perform this reconciliation process forthe periods we tested we find it difficult to understand a reluctance to agree with ourrecommendation to confirm bond proceeds cash balances at the end of each month for allthree sets of books and records

Payment-Drawdown Schedule

IV SUSTANTIVE TESTING TO VERIFY CONSRTUCTION COST

INCURRED THROUGH AUGUST 16 2013

No Authorized Signatures

Allowable Mark-up Formalized


We recommend the WCBA immediately execute an amendment to the agreementbetween the sub-consultant and AECOM to ensure all allowable mark-ups for sub-contractors are in accordance with the amended contract


Mark Up AECOM and the County agree If the County were proceeding with thiscontract we would implement this provision Please note this would be an amendment tothe AECOM Agreement We cannot amend AECOMrsquos agreement with its sub-consultants

OAG ResponseThe OAG agrees with managementrsquos corrective actions to amend the AECOM agreementfor sub-contractors mark-up allowances

Invoices Processed Prior to Pierce Monroe amp Associates

Lack of Control over Payroll Processing

Recommendation 2013-17 ndash Control Deficiency



40

Adopt Wayne County payroll policy and procedures to standardize time reportingby all independent contractors and employees working on the jail constructionprojectEnhance procedures for the accounting firm when validating requests for paymentand payroll expenditures so that additional reliability can be placed on jail

construction project costs recordedEnsure payroll expenditures are in accordance with allowable percentages ofannual wages that can be charged against jail bond proceedsEnsure a written signature be utilized by all supervisors approving time activitysheets and that pay rates be reviewed before time activity reports are approved forpayment andEstablishing a time reporting requirement for the submission of time reports fromindividuals and independent contractors working on the jail construction project


The WCBA does not have employees therefore a timekeeping policy is notrequired to be adopted The County employees provide services to WCBA andfollow the payroll policies and procedures of County The three findings outlinedon page 115 of the report are addressed below

Law Clerk time reporting ndash The Department of Corporation Counsel provided two lawclerks who worked exclusively on the jail project The law clerks follow the Countypayroll policy and procedures and their time is inputted and tracked in People SoftHowever we agree with the OAGrsquos recommendation that the supporting documentationfrom Corporation Counsel should be more formal

Sheriff Transition Team time reports and Authorization signatures- We agree with theOAGrsquos recommendation We will ensure that sheriff transition teamrsquos time requests aresubmitted to WCBA on a monthly basis Further investigation by MampB Accountingindicated that although there was a stamp being used initially for the months Aprilthrough September 2012 that practice has been eliminated Therefore we view thisfinding as an isolated incident

We agree with OAGrsquos recommendation and will establish standardized procedures fortime reporting to address the following

bull Timely submission of payment and reimbursement requests

bull Uniform time reporting formats

bull

Signature authorization requirements for Wayne County employees andindependent contractors

OAG ResponseThe OAG concurs with managementrsquos intended corrective actions to standardize thetimekeeping procedures for all county employees providing services to the WCBAThese measures should provide consistency and uniformity when reviewing andapproving reported work hours by county employees We also would encourage the



41

WCBA Board to adopt through resolution the countyrsquos Time Reporting Policyespecially given the fact it adopted the countyrsquos Ethicrsquos Policy

However management did not address the recommendation to ensure allowablepercentages of employees salaries that are charged against jail bond proceeds are

validated by the external accounting firm responsible for payment The OAGrecommends the accounting firm establish a mechanism to validate submitted payrollrequests from county departments and not place reliance on the department to submitaccurate payroll requests for their county employees

Factors Contributing to Cost Overruns

There are points of clarification that must be made on each of these assumptions

First we question if you have inadvertently used the wrong dates in your report You

have indicated that in April of 2011 cost increases were reported to the County Webelieve you may be referring to an April 2012 projection This would be logical since

OAG ResponseAs noted in the comparative schedule column ldquoCost Increase (Decrease) from April2011rdquo the cost increases occurred between April 2011 through February 2012 The OAGacknowledges the reference period ldquoas of April 2011rdquo will be changed in the draft reportIn addition the OAG will be inserting a new column in the chart titled ldquoProjectedEstimated Project Cost - August 25 2011rdquo to reflect the estimated project cost as of thisdate

In addition based on estimated project cost schedules provided by the Program Managerfor the periods of August 25 2011 and February 1 2012 while estimated total projectcosts were $342 million for both periods the OAG will be revising some line itemswithin the chart presented in the draft report (Ref AECOM Budget Narrative

document)

1 The price for the site acquisition was not finalized in April of 2011 Estimates andbeliefs regarding final acquisition cost were possibly known However therecould be no cost projection sheet that would demonstrate this type of cost Thepurchase agreement and cost for the property was completed in May andapproved in July an agreement for the cost of the property had not been agreedupon by April of 2011

2 Again estimates regarding site remediation costs on the site were probablyproject however the County had not acquired the property and had not startedremediation This occurred in August of 2011 You have listed a specific dollaramount that was not known in April of 2011



42

OAG ResponseThe OAG was able to identify from two separate sources the purchase amount for thenew jail site The OAG reviewed the WCBA board minutes of April 7 2011 At thismeeting Special Counsel discussed the Ratification of Option-Exchange Agreement andasked board members to ratify the agreement which he indicated had been signed by

Greektown officials and the CEO The WCBA issued resolution 11- 009 that identifiedthe new jail site property being conveyed to the Authority with an ascribed value of $14million (Ref WCBA Resolution 11-009 and April 7 2011 meeting minutes)

The Program Manager provided a budget narrative as of May 2011 that stated ldquothecounty reached an agreement to purchase the Mudd site in April 2011hellipFinal purchaseprice as negotiated was $145 million hellipCost of remediation was preliminary estimatedat $5 million and added to the project budget The Program Manager determined anadditional $195 million could not be absorbed in the construction costs and thereforeadded these items to the budgetrdquo (Ref AECOM Updated Budget Narrative - May2011)

3 A training budget was neither adopted nor even presented to the County until thesummer of 2012 Furthermore the Sheriff represented that training funds wouldvery likely be financed from grants specifically from the National Institute ofCorrections

OAG ResponseBased on a subsequent review of the Program Managerrsquos budget documents theOAG will revise the February 2012 Estimated Project Cost schedule line item relatedto training costs for the Sheriffrsquos Office While nominal training costs were identifiedin January 2012 of approximately $65000 for the Sheriffrsquos Office the OAG concurthe training cost for the Sheriffrsquos Office was more accurately projected in August2012 (Ref AECOM Meeting Memorandum dated Aug 15 2012 ndash Sheriff

Transition Basic)

4 The County had neither agreed nor accepted a price for CCIP until after theContract was negotiated and the CMAR had started seeking bids based on theexecuted agreement There are no documents to support this line item from Aprilof 2011 The CMAR had not even been selected There could not be a documentthat identifies a CCIP from April when the County had not selected or evendetermined which type of insurance program it would utilize

OAG ResponseThe OAG partially agrees with managementrsquos comments related to the CMAR ControlInsurance Program (CCIP) insurance cost For clarity the CCIP insurance cost isreflected as of February 2012 and not April 2011 The OAG agrees the county had notexecuted the CMAR contract however the Program Manager delegated responsibility tokeep the new jail construction cost project within budget identified in its Projected CostSummary schedule as of August 25 2011 a projected estimate of the CCIPBuildersRisk insurance costs in the amount of $51 million The CCIP cost along with other



43

identified insurance cost of $1 million totaled $61 million at August 25 2011 Thisamount will be reflected in a revised OAG Estimated Cost Schedule (Ref AECOM

Exhibit C1- Project Cost Summary)

5 The Transition Team and its requested budget was not even brought to the

WCBA until the spring of 2012 again we are unaware of where you havedeveloped these numbers

OAG ResponseThe OAG was able to identify from the Program Managerrsquos Project Cost Summaryschedule the projected cost related to the Transition Team The Program Manageridentified as of August 25 2011 a line item in its Projected Cost Summary schedule $18million in projected transition costs for the Sheriff Team

The OAG relied upon this information in its projection In addition the $18 million costfor the Sheriff Transition Team was also identified in the Final GMP that was presented

to the county administration in June 2013 and has been consistently reported from August2011 until June 2013

6 You have identified a Jail Management System of $39 Million This is not aneligible cost Additionally this JMS system was scheduled to be purchased animplemented in the current facilities This was never an approved cost within theCountyrsquos allocation and should not be reported as such

OAG ResponseBased on a subsequent review of the Program Managerrsquos projected costs schedules theOAG will revise the Estimated Project Cost schedule as of February 2012 for the lineitem ldquoOther Project Related Costsrdquo This revision will remove any cost associated withthe Jail Management System

You have indicated that AECOM has provided you with this spread sheet Weunderstand that AECOM has a strong desire to mitigate its responsibility for the issuesthat have occurred on this Project We would ask the OAG to demonstrate that this was aCost Projection Sheet that was given to the County in April of 2011 We suspect that theOAG has relied upon a document that was created several months later If such adocument does not exist verifying that these numbers were presented to the formerDCEO EDGE Director or the Ownerrsquos Representative in April of 2011 then leaving it inthis current report is misleading and damaging to the County

OAG ResponseDuring the course of our review we requested and received various Estimated ProjectCost documents from the Program Manager which had delegated responsibility to keepthe jail construction project within estimated cost The numerous project cost documentswere dated from November 2010 until the suspension period in June 2013



44

The OAG relied upon the information received from the Program Manager as the mostreliable given the fact we were provided evidence that the information was discussedwith county officials overseeing the project and the WCBA board members throughoutthe indicated time periods

Within the Countyrsquos possession and as previously provided to the OAG are costallocation sheets dated May of 2011 This sheet indicates a $321 Million dollars Thesesheets and their numbers remained consistent for several months For the sake of claritythe County will address the projected costs identified in these sheets excluding the City ofDetroit in the Project These sheets identify the following

$6 Million is attributable to ineligible costs that could not be covered by bond financingthese included the demolition of County Buildings A Project Contingency of $17 MillionAn unallocated reserve of approximately $5 Million

A total of these costs allowed the County to remain below the $300 Million Dollar

allocation

During your engagement the County has cooperated fully with providing you withdocuments We have provided for your review the project cost allocations sheets thatwere created by AECOM in the fall of 2010 You will note that in these sheets AECOMidentified site acquisition remediation and other costs that are now being reported byAECOM as costs that were not included in the original cost projections We would askthat you look at the following in the exhibits See Exhibit C AECOM Projections

Site Acquisition- AECOM and the County engaged in very frank discussions in the fall of2010 regarding the acquisition of the current ldquomudrdquo lot where the Consolidated Jail iscurrently being constructed You will see that AECOM included differing costs for siteacquisition and preparation in their 2010 cost projections Additionally we have alsoprovided you with the presentation that AECOM presented to the Wayne CountyCommission in a closed session in October of 2010 This presentation demonstrated aproposal for both the Sheriffrsquos administration building and the ldquomudrdquo lot A closedsession was necessary due to the negotiations for the acquisition AECOM representedand the County relied upon such representations that acquisition of the mud lot would notcreate additional costs AECOM represented that since the size and footprint of this lotwas larger than a phased demolition of the Sheriffrsquos Administration Building acquisitionwould produce some savings It should be noted that Wayne County Commissionersquestioned AECOM on whether the acquisition of the Mud lot would result in additionalProject Costs AECOM responded no The acquisition provided a larger footprint forconstruction therefore acquiring the mud lot would be cost beneficial or a ldquono costrdquo to theCounty Since the Commission erases such records we cannot provide you with thediscussions on this matter

OAG ResponseThe OAG reviewed Exhibit A ldquoPresentation and Best Practicesrdquo dated February 13 2011and a PowerPoint presentation to the Commission dated April 5 2011 on the new jail



45

project As noted on page 18 of the presentation anticipated Project Budget totaled $267million which does not include the $33 million in bond issuance cost The OAG alsoreviewed Exhibit C ldquoAECOM Price Projectionrdquo which contained an E-mail datedSeptember 9 2010 from the Program Manager that identified various projectconstruction housing models which range in project cost from $1735 million up to

$2897 million

However we were unable to locate any evidence related to the countyrsquos acquisition of theldquomudrdquo lot and remediation costs within the two Exhibits Further we are aware that the$267 million estimated project cost was signed and executed by the Program Manager onDecember 22 2010 in its ldquoCertificate of Program Managerrdquo that was used for theissuance and sale of $200 million in WCBA bonds

Cause

The OAG has stated within this provision that neither the Commission nor the WCBA

were made aware of the potential costs on the project For the sake of clarity the Countywill respond to the documents that existed at the time which indicated that the projectcosts were potentially $321 Million Dollars without the City of Detroit As explainedabove these costs included ineligible bond costs and project contingencies that wouldkeep the budget below $300 Million

OAG ResponseWe fail to understand what difference it makes whether the costs are being paid from thebond proceeds or other sources We believe this cost still should be reported as part ofthe jail construction overall projected costs

We have also provided clear documentation that the County did not execute contractsabove $272 Million Dollars Attached for your review are two spread sheets Oneshowing the executed agreements which include legal site acquisition CMARAECOM etc These were costs incurred by February of 2012 The second exhibitshows the current executed contracts See Exhibit E Contracted Costs

OAG ResponseWe agree with your assertion that actual contract costs are less than $300 million to-datehowever it still does not negate the fact that the current budget for the construction of a2000 bed facility is projected to be at least $342 million in August 2011 and February2012

County officials never exceeded their delegated authority Additionally the Countywrote into the First Amendment of the AECOM Contract that AECOM was bound todesign the new facility within the budget

OAG ResponseThe OAG reviewed the First Amendment to the Program Managerrsquos contract Exhibit Aand found as of May 17 2011 estimated project costs totaled $321 million of which



46

$64 million was considered ineligible cost Therefore estimated project cost netted to$315 million which exceeds the authorized $300 million in bond proceeds at this time Inaddition the Amendment requested the Program Manager to include construction costestimated at $17 million for including the city of Detroit Processing Center Adding thecityrsquos construction costs to the total estimated project costs the project totaled $332

million Based on comments from the Assistant CEO it was not until May 2012 that theCounty was informed by City officials that they would not be partnering with the county

In March of 2012 AECOM provided a Cost Project Sheet to the County that they couldcontinue to meet the $300 Million Dollar allocation See Exhibit H

Finally in November of 2012 there is correspondence from the CFO that clearly statesthat regardless of the issues that may have arose the County was not releasing theCMAR or AECOM from constructing a facility within the $300 Million Dollarallocation See Exhibit I CFO Correspondence

All of these documents clearly demonstrate that the County expected and relied uponAECOM to stay within the $300 Million Dollar allocation

OAG ResponseDespite the expectation of the Administration the reality still exists that there iscommunication from both contractors AECOM and Walbridge-dck that the constructionof the jail could exceed the Countyrsquos cost expectations of $300 million as of August 2011and February 2012

It is inaccurate to state that a total budget should have been provided in August of 2011This issue was discussed It was represented to the Commission that the CMAR contractprovided that a total budget would be provided when the final GMP was completed It isa term written into the CMAR contract that was approved by the CommissionInformation was not withheld and should not be presented in manner that shifts theresponsibility from AECOM to the County

The implication is that County individuals had a belief that the project would exceed theBond allocation That is a misstatement of fact At the onset of any construction projectthere is a reasonable concern that final construction will exceed an AGREED UPONbudget In the Fall of 2010 County individuals prudently had this concern Theycontinued to have the same concerns when the CMAR contract was approve inSeptember of 2011 and February of 2012

OAG ResponseWe see no evidence that key administrative officials communicated to the governingbodies in either instance that the 2000 bed jail facility could exceed the $300 millionbased on projections from the Program Manager

But the facts do not demonstrate that these concerns were withheld from the WayneCounty Commission or the WCBA Instead the facts demonstrate that in March of 2012



47

AECOM was attempting to comply with the terms of its agreement and construct afacility that was within the $300 Million allocation

OAG ResponseThe OAG points to the fact that the CMAR contract presented to the Commission and

the WCBA on September 1 2011 was in the amount of $220 million This amount solelyrepresented the construction or ldquohardrdquo costs for constructing the jail

However as projected by the Program Manager and discussed with county officials thetotal (both hard and soft costs) estimated cost of the project at August 25 2011 was $342million The OAG maintains that the oversight bodies should have been i nformed thattotal cost to complete the jail was estimated at $342 million at that time based on theintended design of the jail and cost projections prior to a request to approve the CMARcontract which represented more than 73 of the total jail construction budget


The Approving boards should refrain from approving major capital improvementcontracts without requiring a budget be presented to construct the entire project not justthe brick and mortar


Agreed Despite the gross inaccuracies within this report the County believes thatbudgets should be created in a timely basis However we would again point to thedocuments that you were provided in your engagement and we have attached some ofthese to emphasize the facts The County consistently requested required and expectedAECOM to provide a final budget within the $300 Million Dollar allocation We wouldagree a more substantive policy regarding capital projects financing and budgets bedeveloped We would conclude that this would appropriately be developed within thecapital improvement plans that are submitted to the Wayne County Commission We donot disagree with submitting budgets in their entirety A budget was not available untilthe GMP was established in May of 2013


AECOM

Walbridge-dck Joint VentureLegal Fees

Point of Clarity pg 126 We disagree with the statement that AECOM reported to theOversight Committee and not the WCBA AECOM met and INFORMED the OversightCommittee regarding progress on the project The contract executed by AECOM clearlydemonstrates that they had a duty to report to the WCBA Providing information to the



48

Oversight Committee did not relinquish AECOM of its responsibility The County wasentitled to be kept informed on what was occurring on the Project We would suggestthat this statement be removed as it misleads the reader

OAG Response

The OAG disagrees with management presentation of the facts During the referencedtime period AECOM acted in the capacity as the Ownerrsquos Rep for the WCBA and as youacknowledge they had a duty to report to the WCBA The fact of the matter and theOAGrsquos assertion is that AECOM had a fiduciary responsibility as the Ownerrsquos Rep to tellthe WCBA that based on current drawings the project would be $42 million over budgetHowever the OAG will consider revising the sentence to read ldquo as OwnerrsquosRepresentative they held on-going discussions with the Oversight Committee on theprogress and cost of the jail project which included written projected cost estimates(Ref See AECOM Meeting Memorandums)rdquo

Point of Clarity pg 127 Area D was the area being planned for the City of Detroit AreaF was a request made by the Wayne County Sheriff to explore the possibility ofexpanding the new jail to a 2400 bed facility

OAG ResponseThe OAG agrees to make the revision to the report

Point of Clarity pg 130 We strongly disagree with your assertion that Bond Counselshould be considered part of the legal fees for project costs Bond Counsel is a Cost ofIssuance Their fees are paid and accounted for as part of the issuance costs This is apractice that cannot change You are asserting that they are part of the legal fee budgetwhen their fees have already been accounted for under the issuance costs We cannotcount them twice and we it would be fiscally irresponsible to attribute them to on-goinglegal fees

Correcting this issue within your report is important and certainly demonstrates that thelegal fee budget is different than reported

Please note that legal fees were anticipated to be front loaded Use of outside counsel forreal estate matters and construction contracts were anticipated to be relatively completeby the time the Initial GMP was completed Kotz Sangster invoices have beendramatically reduced since the creation of the Initial GMP Contract

Dawda Mann invoices are above expected projections due to the Parlovecchio lawsuitHowever as noted earlier in your report these are not being paid out of the bondallocation Therefore your number should be re-adjusted for Dawda Mann Contract

OAG ResponseThe OAG identified a line item budget for issuance costs that included expendituresmade to the law firm Miller Canfield Paddock amp Stone as bond counsel The OAG will



49

revise the draft report and remove the law firm from the legal fees analysis (Ref see

PMampA line item budget for Issuance cost amp supporting schedule)

The OAG will revise the legal fee schedule to reduce Dawda Mann legal costs by$42467 related to the on-going Ownerrsquos Representative lawsuit According to Special

Counsel to the WCBA these costs were paid from the WCBA General Operating Fundwhich was generated from parking lot proceeds prior to starting construction on the jail(Ref Litigation Cost section of report)

Recommendation 2013-19We recommend the WCBA execute a contract for all legal service to ensure the scope ofservices is specific to services to be performed and billed Also a purchase order shouldbe issued for all services rendered and charges be made against it


Legal Contracts 2013-11 and 2013-19 are the same issue We would stand behind ouranswers in direct response to the same concern

As previously noted in MampBrsquos response to Recommendation XX the WCBA deemed itwould be more cost effective to use a voucher process in conjunction with the contractsrather than using a purchase order system

OAG ResponseIt is important to note that WCBA has issued numerous contracts related to constructionof the jail and the use of a purchase order system prevents the processor from exceedingthe contract amount This limitation does not exist with the use of a voucher system asbeing recommended by the Administration

Accounting Fees

Recommendation 2013-20 Operating DeficiencyWe recommend the WCBArsquos Chief Administrative Officer consider executing a flat feecontractual arrangement for service contracts related to the Jail Facility ConstructionProject in order to better control costs

Views of Responsible OfficialsThe Chief Administrative Officer already had entered into discussions with PMampA for aflat fee engagement before this engagement as she understands the benefits that can bederived from such an arrangement Although these fees might seem higher at thebeginning of an engagement sometimes flat fee rates often come in lower than acomparable hourly rate particularly if the firm assumes all risks All discussions about afixed fee arrangement came to a halt with the suspension of the jail project Dependingon the plan for the jail project going forward the Chief Administrative Officer willresume those discussions with PMampA



50

OAG ResponseThe OAG concurs with the intended corrective actions and has no response tomanagementrsquos comments

Cost During Suspension Period


The Jail Project is at a critical stage and we recommend going forward that the WCBAas the Owner of the Project require written reports on the status of the construction of thenew jail facility as well as participate as decision makers in any other proposed actionsthat are currently being considered by the executive branch

Also we are suggesting that a separate accounting be maintained of all cost incurredduring the construction suspension period to determine if the cost is eligible to be paid

from bond proceeds


Written Status Reports This recommendation regarding written reports is similar to therecommendation in 2013-5 We would have you refer to that section In regards to thesecond clause regarding the WCBA remain as decision makers on the Project we do notdisagree but would clarify that under the Building Authority Act the participation andagreement of the Commission on certain items cannot be ignored pursuant to MichiganLaw

The jail project was suspended in early June 2013 and WCBA had not incurred anysuspension costs until the middle of July During this period WCBA administration wasstill in the process of discussing and formulating procedures on tracking and evaluatingsuspension costs for bond eligibility Since then specific procedures have beenestablished and separate accounts have been set up in Quickbooks (financial applicationfor the jail project) to track the suspension costs

OAG ResponseThe OAG has no response to managementrsquos comments

Options on Construction of Jail

Point of Clarity- pg 138 The County appreciates the OAGrsquos thoughts on howconstruction could possibly proceed However certain thoughts have not been fullyexplored by the OAG



51

bull The County is only considering a construction on an alternative site if a newcriminal court is included Therefore it should not be expressed that futureconstruction on a new site would not include a criminal court

bull Any public private partnership will be reviewed and approved by underwriterssimilar to a bond transaction We believe these options should be explored

However based on the City of Detroitrsquos bankruptcy and the Countyrsquos financialcondition it is extremely doubtful that the County could obtain a P3 arrangementwithout some assurance from the State to the private entity

bull The Sale Lease Back of 600 Randolph was similar to a P3 As stated above itwould be explored

bull CGL is an excellent company However the RFI that was issued was not specificto a P3 The OAG is suggesting that the County conduct a negotiation for a no-bid contract We could not support this conclusion

OAG ResponseIn the report the OAG stated the CGL proposal should be re-evaluated if the

administration decides to pursue a public-private partnership arrangement to build the jail The OAG did not suggest the county conduct negotiation for a no-bid contract

We share the same concerns expressed by Commissioern Price regarding the need for theAdministration to at least evaluate the CGL proposal to build 2600 bed facilityespecially since it appears to be consistent with the goals and objectives of the county

bull The OAG needs to re-consider its statements regarding the collection of propertytaxes and a lease Any lease the County executes would require it pay propertytaxes A prudent owner understands their expenses and would ask the tenant toassume such expenses This implied cost benefit would not be realized

OAG ResponseThe Wayne County Assessor cautioned us that this property is located in the DowntownDevelopment Authority (DDA) district therefore special tax incentives can be offered todevelopers by the city of Detroit Economic Development Corporation in which thecounty has no control over Consequently the situation could change in the future

bull The County as always will address the needs of a criminal court with theassistance of the Third Circuit We would disagree with the OAGrsquos assertion thatthe consent decree provides the court with certain decisions that currently restwith the County pursuant to Michigan Law We would ask that the OAG re-

examine these statements We are more than willing to engage in conversationsregarding this matter

OAG ResponseAlthough the Administration is now talking about a criminal court ndash there is no realevidence how it will be financed and when it will be actually built Therefore until plansare brought forth we contend this should be one of the major factors in determining



52

where the consolidated jail will be located At present the criminal court facility islocated directly across the street from the consolidated jail


The Commission and the WCBA should encourage the administration to perform afinancial feasibility study and in order to explore other means to finance the constructionof the jail in order for the Project to be completed at its existing site and avoid thenecessity to abandon the Project where over $533 million tax payers dollars are alreadyinvested and obligated over the next thirty years


The County does not disagree that any and all options should be considered in thecompletion of a new jail facility However due to financing restraints the County canonly proceed with assistance from the State of Michigan Therefore these options will

have to be explored through the State

OAG ResponseWe agree the county needs the State of Michigan assistance and approval however wesuggest in this instance as prudent decision makers the county needs to set its own goalsand objectives and independently evaluate if they are consistent with the State ofMichigan and proceed accordingly

REVIEW DOCUMENTS TO SUPPORT THE AUTHORIZATION AND

APPROVAL OF ALL CHANGE ORDERS BY THE PROJECT OWNERS


We recommend that formal change order policies and procedures be adopted by theWCBA to include but not be limited to those that may require Wayne CountyCommission approval before the change order is formally approved Also all changeorders should be evaluated to determine the impact they on the contractrsquos price and ifany the contract should be amended to reflect the change


Change Orders We Disagree A change order and its methodology is a contract term Itwill be different based on the size and the scope of the project If a change orderincreases the CMAR contract we agree by law its contract must be amended A policywill not change this issue

OAG ResponseWithout argument we are clear that a contract will supersede any policy that is adoptedby the Administration Policies and procedures are meant to outline administrative



53

directives and processes to be followed to accomplish a particular objective Policies andprocedures are primarily developed to provide for direction uniformity and consistencyin carrying out a particular function

We agree that a clearer role regarding Commission approval on Change Orders should

occur on capital improvement projects If change order reduced the scope of the facilitybut left the cost for such facility at the same contracted price this type of Change Ordershould be submitted to the Commission This would be a change in the CMAR contractAs each capital improvement project is approved by the Wayne County Commissionthere should be some agreement regarding change orders It would not be appropriate toexclude the Commission As stated earlier issues such as these are best addressedthrough the Countyrsquos Capital Improvement Plan that is presented to the CommissionThere can be policies created by the County either by ordinance or as adopted by thePurchasing Department that could create some parameters regarding this concernHowever we donrsquot want to mislead the OAG It is reasonable to expect that a Contractorwill want the change order process to be stated within the contract not by reference to a

policy

OAG ResponseIt is the Administrationrsquos responsibility to develop policies and procedures not theCommission However we acknowledge and appreciate that the Administration agreeswith the OAG ldquothat a clearer role regarding the Commission approval of changes shouldoccurrdquo

The OAG has stated within their report that this change order process is identified in thecontracts As stated on pages 141 and 142 of the OAG report the contract is clearregarding the process and steps that both the CMAR and the Program Manager must take

1 The CMAR was to submit documentation to the Program Manager2 The Program Manager was to review and ensure that appropriate documentationexisted regarding the request for such change order3 If the Program Manager believed such change order was justified based on thedocumentation the WCBArsquos approval would be needed

What is not documented within the Contract but exists pursuant to the Contract of Leaseis when change orders have to go back to the Commission for approval If a change orderincreased the cost of the CMAR contract it needed Commission approval The WCBAonly had delegated authority for a $220 Million Any change order exceeding $220Million would have needed Commission approval along with authorization for fundingWe believe addressing each of these issues in substantive manner prior to theauthorization of a capital project would be beneficial

OAG ResponseAfter reviewing the Contract of Lease the OAG could not confirm managementrsquosstatement regarding the Contract of Lease including language that allows for the changeorders having to go back for Commission approval Since management infers this



54

provision exists pursuant to the Contract of Lease Agreement the OAG wouldrecommend the Contract of Lease be amended and the Commission approval of changeorders be formalized into the contract

PERFORMANCE OF PROCEDURES DESIGNED TO IDENTIFY UNUSUAL

ANDOR QUESTIONABLE TRANSACTIONS

Litigation Costs

Unallocated Cost to the Jail Project

Point of Clarity Pg 145 Parlovecchio Building Inc has not sued the County they havesued the WCBA The County is not a named party

OAG ResponseWe agree the lawsuit is against the WCBA and not Wayne County and we will make thechange


We recommend the Department of Management and Budget establish a policy thatcounty employees working for the WCBA and on the Jail Facility Construction Projectrecord the hours worked and allocate their personnel cost to the WCBA in order to be incompliance with the OMB


Payment of County Personnel The County is not in violation of OMB Circular A-87 asit relates specifically to federal grants and contracts Currently the Department ofManagement and Budget is in the process of developing a policy that will addressservices provided to all component units and reimbursement to the county for thoseservices County personnel are keeping track of their hours For example SpecialCounsel to the WCBA tracks all of his time in the Countyrsquos Pro-law system

OAG Response

We noted that the county has over $90 million in federal grants and used ARRA(federally subsidized bonds) to finance the jail project with an interest subsidy of morethan $169 million

OMB Circular A-87 requires cost to be allocated on an equitable basis and be based onbenefit being derived Therefore since direct and indirect cost is allocated to federalgrants we believe the failure to properly allocate these costs posses the risk of the federalregulatory agencies determining our allocation plan does not allocate costs in an equitablemanner



55

The OAG concurs with the Department of Management Budget that developing a policyto address reimbursement to the county for services provided to component units bycounty employees including those working for the WCBA and on the Jail FacilityConstruction Project as they record their hours worked

ADOPTION AND APPROVAL OF BUDGETS


Require the Administration to prepare a written budget for WCBArsquos general operatingfund to be presented for adoption and approval by the board on an annual basisDevelop and adopt a realistic capital improvement budget for the construction of the jailand amend it whenever increasesdecreases become known or prior to expenditure beingmadeAdopt policies and procedures that require a capital improvement budget be required forprojects over a certain dollar threshold


The jail construction project is part of the WCBArsquos capital projectrsquos fund and not thegeneral operating fund The Michigan Uniform Budget manual does not require WCBAto adopt a budget for capital projects nor does the Governmental Accounting Auditingand Financial Reporting (Blue Book) The County believes the budget manual and BlueBook to be guidance on best practice

OAG ResponseAn email from the auditing firm of Plante Moran confirms that if there is a generaloperating fund balance in the Capital Project fund exists and it is not labeled underGASB 54 as ldquoCapital Projectsrdquo and any remaining activity in a fund reported as a generalfund should be budgeted in the future

12

However prior to the jail bond issuance a preliminary cost estimate was prepared byAECOM the program manager firm and presented to the Wayne County Commissionersand the WCBA Board During the course of the jail construction project this costestimate was regularly reviewed and revised by AECOM and later by the Jail OversightCommittee

OAG ResponseWe agree there were numerous jail construction estimated cost projections prepared bythe Program Manager over the construction period However from a practical viewpointwe believe a capital improvement budget should have been adopted for the jail and thiswould have identified any funding gaps early in the construction phase of the jail

12 983109983149983137983145983148 983142983151983154983149 983120983148983137983150983156983141 983117983151983154983137983150 983140983137983156983141983140 983105983157983143983157983155983156 983096 2013



56

This cost estimate served as a working budget and was never finalized However weagree with the OAGrsquos recommendations for adopting a general operating fund budgetalthough we do not agree that the general operating fund has $50 million available forbudgeting The revenue generated at September 30 2012 was $15 million We also

agree with establishing procedures that require capital improvement budget for certaindollar thresholds

OAG ResponseWe have stated that the WCBA government fund statements report an unrestrictedGeneral Operating Fund balance of $213000 as of September 30 2012 and theremainder is reflected as deferred revenue and other liabilities as of September 30 2012

Based on notes to the financial statements $492 million in deferred revenue representsthe future rent collections expected from the lease of certain facilities to othergovernmental agencies The audited financial statements state these funds will be used to

service the debt

13

Conclusion

We offer this conclusion only as a matter of clarity and not in response to the Auditorrsquostitled section regarding conclusion

The inaccuracies within this report and the manner in which they are presented aredamaging to the County The Countyrsquos Chief Financial Officer contacted and requestedthat the OAG review the Project This decision to engage the OAG was to be done inconjunction with an independent architectural firm who could provide reports on issuesthat occurred on the development of this Project The County CFO provided anengagement that requested the OAG to review financial issues associated with the Projectand assure the public that no fraudulent payments had been made and all public fundswere accounted for

OAG ResponseWe have gone through the entire memorandum submitted to the OAG alleging tonumerous inaccuracies and have found only a few instances where corrections arerequired to be made to the report And in the interest of accurately reporting the facts wehave gladly made those changes

The majority of the other changes were primarily due to opinions and conclusionsreached by the OAG and based on the information attached as exhibits did not meet ourcriteria to warrant a change to the findingsrecommendations

13 983127983107983106983105 983137983157983140983145983156983141983140 983142983145983150983137983150983139983145983137983148 983155983156983137983156983141983149983141983150983156 983140983137983156983141983140 983123983141983152983156983141983149983138983141983154 30 2012



57

It is true that the county CFO did enter into an Agreed Upon Procedure engagement withthe OAG and we did not find any fraudulent payments had been made and all publicfunds appear to be accounted for

The Hubbel Roth report is clear It provides an unbiased statement of responsibility and

identifies areas where the County must accept some responsibility It clearly states areaswhere the Countyrsquos vendors have not fulfilled their duties In comparison the CountyrsquosLegislative Auditor General provides a narrative report that clearly examines the issuesand then utilizes documents which shift the responsibility to the County

OAG ResponseThe OAG report followed GAGAS and AICPA auditing standards which are designed toprovide for an independent and objective opinion as it related to a review of internalcontrols compliance with laws and regulations construction cost incurred throughAugust 16 2013 and approval of change orders and budgetary issues

Because the auditing standards require the independent auditor to perform engagementsbased on risk it would violate the standards to not identify risk and perform work inthose related areas during the course of performing the engagement Therefore there arenumerous factors that determine the work being performed for a particular engagement

Even more disturbing the Auditor indicates that he will not allow the County to viewcomment or clarify such documents until a later date The County acknowledges that theOAG has provided Recommendations that the County believes would be useful Inaddition the County believes the Hubbell Roth report was extremely beneficial inidentifying areas and actions in which the County now can proceed to obtain a remedyfor the actions that were taken The facts and documents within the Auditorrsquos possessionclearly demonstrate that the County never exceeded their delegated authority Anoverview of the facts and documents are necessary

OAG ResponseIt is customary during the closing conference for the OAG to review the detail to supportfindings with the auditee however the Administration elected to provide a 37 pagememorandum with responses to the OAG and suggested they be reviewed and meet laterfor discussions if needed Because of their request there has been an opportunity toprovide detailed documentation to support those findings that are in question by theAdministration

The County had AECOM meet extensively with stakeholders in the fall of 2010 toascertain the programming for the facility These results were documented utilized andemployed best practices Presentations were given to the Commission The Sheriffsigned an MOA agreeing to a formula to demonstrate his need to create a cost savings onthe Project



58

OAG ResponseWe cannot comment on this assertion because since we were not provided with the MOAagreement

OAG Position The County did not complete its due diligence prior to the issuance of the

bonds

The County asks and receives Cost Allocation sheets It reviews such sheets and adds aterm to AECOMrsquos contract that it must design within the allocation It only authorizescontracts up to the $300 Million Dollar Allocation It receives a Cost Allocation Sheetdemonstrating that the Project can remain within budget in March of 2012 The CFOsends correspondence to AECOM and Walbridge in November of 2012 informing themof the need to design within the $300 Million Dollar Allocation

OAG ResponseWe agree there were attempts as well as contract language designed to keep the jail

construction under the $300 million threshold but the Administration was not successfulin this endeavor

Despite the efforts to control cost we believe the Administration lacked the experiencequalifications and skill sets required to successfully complete a public capitalimprovement project of this size Until recently there was no one on the Administrativeteam who possessed the skill set to effectively manage the consolidated jail project

OAG Position The Cost Allocation Sheets should be considered ldquonoticerdquo The Countyshould have stopped the project upon receiving these estimates The OAG also utilizes acost allocation sheet for April of 2011 that lists items that were not even known on thatdate OAG shifts the contractual obligation given to the Countyrsquos vendors and producesa report that places the responsibility on the County

OAG ResponseOur reference to the April 2011 date was in error and the OAG should have referencedAugust 25 2011 ndash this correction has been made in the report However it still does notrectify the fact that once a funding gap was identified key decision makers should havebeen timely notified

The WCBA is a financing entity allowed under Michigan Law It cannot exceed itsdelegated authority to bond or construct a facility beyond those duties that were given toit by its incorporating unit Michigan Law is clear regarding the limitations of a buildingauthority in its ability to finance

OAG ResponseDespite the statement being made by the Administration it still does not negate the factthat language exists in the contract of lease that states In the event there are not sufficientfunds the WCBA has the authority to issue additional bonds Also this same concern was



59

raised by Commission Counsel in a communication to the Administration in November2010

OAG Position The OAG prepares a report indicating that bond documents created andexplained by a nationally known bond firm were crafted in a manner to purposely expose

the County to risk and empower the WCBA to exceed their statutory duties

OAG ResponseSince there appears to be conflict between State law and the contract of lease we suggestthis difference between Section 11 of the document be correctly aligned with State law toaddress our concerns

4 The County ultimately has responsibility for the use of the facility and for theactions of the WCBA The County creates a committee of County staff to keep itselfinformed on the project and create venue for issues to be discussed

OAG ResponseThe creation of the Oversight Committee appears to be a good idea we are just concernthat notesminutes were not taken at these meetings and written reports were not sharedwith the WCBA board

OAG Position The Oversight Committee was an entity that purposefully attempted tousurp powers that were vested with the WCBA The OAG shifts the contractualresponsibilities of AECOM to review and present issues regarding change orders to theWCBA and suggests that the creation of a committee of County staff impeded AECOMrsquoscontractual responsibilities We question whether the OAG would have found a negativefinding in the alternative if the County had not created a committee in which to ensurethey were being kept informed on the project The report portrays the OversightCommittee of somehow directing AECOM not to fulfill its contractual duties

OAG ResponseSince we found instances in which written status reports resulting from the OversightCommittee meetings were not timely shared with the WCBA board it leads one toconclude as to the motive why transparency and open dialogue did not exist between thecommittee and the board Also we still contend it was the responsibility of the OversightCommittee and AECOM to keep the WCBA board informed as to the various issues andchallenges with the jail construction project

At Commission Meetings WCBA meetings and the Commission Jail Task ForceCounty staff remained cooperative and open regarding any and all communication orinformation on the Project County staff additionally met with Commissioners to discussthe possibility of expanding the facility to a larger scope A recommendation the OAGalso asks to be considered

OAG Position The OAG implies that staff members purposely wanted to withholdinformation It is obvious that there is no apparent gain for any staff member to withhold



information Instead as stated repeatedly the County never waivered its expectation nordid it engage in any behavior that exceeded the delegated authority

OAG ResponseSince this matter is under investigation by the PAO we must refrain from commenting

on it at this time

We would respectfully ask that the OAG look at these issues and the facts presented fromthe Countyrsquos prospective There are recommendations provided by the OAG that are abenefit to the County However the narratives leading to these recommendationsdefinitively present an outlook that damages the Countyrsquos ability to enforce its rights andremedies under its contracts

OAG ResponseIt is our intent to report that facts based on work performed and we have no desire to

impair the countyrsquos right and remedies under its contract

The County has provided documents and explanations that clearly demonstrate that staffmembers consistently enforced the terms of the contract and did not exceed the $300Million Dollar allocation in its contractual obligations



2

of the objections appear to be related to the conclusions and opinions reached by theOAG

In addition the respondent mentioned that no supporting documentation was provided Itis customary in the industry to not provide supporting documentation for

findingsrecommendations included in our report However at the closing conferenceworking papers and other documentation to support conclusions reached are discussed indetail as it relates to each findingrecommendation being challenged The administrationelected to provide written responses as opposed to allowing the OAG the opportunity todiscuss the support and documentation for each of the findings The opportunity for therespondent to discuss each finding and our support is still open and available if they wishto exercise that option

Our preliminary response regarding this matter will be addressed in each of theldquoFindingsrdquo or Recommendations provided by the OAG We will address statements inwhich we take issue and where we believe such statements are misleading We have also

provided you with a response on each of your recommendations Again this can only bea preliminary response since the OAG has indicated that he will not allow us to viewdocuments on which he has drawn his conclusions

OAG ResponseThe detail of our report layout states ldquowork performed and the results of workperformedrdquo This format is conducive to assisting the respondent in understanding whatwork was actually performed and the conclusions reached based on that work performedOur underlying working papers are designed to support the work actually performedThe auditing standards require the OAG to prepare and maintain working papers tosupport conclusions reached In essence the report itself identifies work performedresults of that work and conclusions reached

We would also question the OAG on their statements at the end of each finding titledldquoViews From Responsible Officialsrdquo We are assuming such headings are added as amatter of convenience It is the County through the Department of Management andBudget and for the benefit of the Wayne County Building Authority who sought andrequested that the OAG perform an audit on the Consolidated Jail Project Both partiesmust acknowledge that since the initial draft report was issued on August 13 2013 threeother revisions were then issued The County has been modifying its responses as eachnew version is submitted This Closing Conference will be the first opportunity for theCounty to effectively address these findings Again such responses must be limited sincethe OAG has indicated that he will not provide documentation We are assuming thatyou will either include our ldquoViewsrdquo or make a statement under each section that suchviews are listed in the appendix We would ask for written clarification regarding yourformat



3









Control Environment








4












5














6









Criteria- pg 40






7











8









Risk Management





9

Control Activities













10



2


3







1

983108983137983150983145983141983148983148983141 983107983151983150983159983137983161 983123983156983137983156983141 983137983150983140 983116983151983139983137983148 983111983151983158983141983154983150983149983141983150983156 983120983154983151983139983157983154983141983149983141983150983156 (983107983144983145983139983137983143983151 983105983106983105 983123983141983139983156983145983151983150 983151983142 983116983151983139983137983148 983111983151983158983141983154983150983149983141983150983156983116983137983159 2012)

2 983113983140983137983156 9830942

3 983113983140 983137983156 9830943




11
















5 983123983156983137983156983141 983137983150983140 983116983151983139983137983148 983111983151983158983141983154983150983149983141983150983156 983137983156 100



12


OAG Response











innuendo9

983094 983105983113983107983120983105 983120983154983151983142983141983155983155983145983151983150983137983148 983123983156983137983150983140983137983154983140983155 (983114983157983150983141 1 2012) 98320710151

983095 983107983151983149983149983137983150983140 983117983137983150983137983143983141983149983141983150983156 983123983141983154983158983145983139983141983155 983113983150983139 983158 983125983150983145983156983141983140 983123983156983137983156983141983155 111 FedCl 279 (2013)

983096 983113983140

983097 983113983140



13













14











15

OBSERVATIONS





CRITERIA











16













11 983110983105983122 15303(983138)(1)



17













18














19














20












21


prepared









Monitoring pg 66





22














23











Contract of Lease







24






Criteria










25














26
















27











than the WCBA





28













29














30




No Bid Contracts







31












32














33



Contract Elements

Missing Dates












34


Missing Signatures









Contract Analysis






35
















36








bull





37



Point of Clarification Page 103 indicates that the Oversight Committee was involved inthe hiring of the Sheriffrsquos Transition Team including interviews This is inaccurate TheSheriff selected his team members and informed County staff of his selections








THE GENERAL LEDGER



38






OAG Response






39



















40










bull





41










document)





42






Transition Basic)





43














44





allocation






45


$2897 million


Cause










46













47










AECOM





48


OAG Response











49










Accounting Fees





50






from bond proceeds









51
















52

















53




policy








54




Litigation Costs








OAG Response





55








12



12 983109983149983137983145983148 983142983151983154983149 983120983148983137983150983156983141 983117983151983154983137983150 983140983137983156983141983140 983105983157983143983157983155983156 983096 2013



56





service the debt

13

Conclusion





13 983127983107983106983105 983137983157983140983145983156983141983140 983142983145983150983137983150983139983145983137983148 983155983156983137983156983141983149983141983150983156 983140983137983156983141983140 983123983141983152983156983141983149983138983141983154 30 2012



57











58



bonds











59















on it at this time







3









Control Environment








4












5














6









Criteria- pg 40






7











8









Risk Management





9

Control Activities













10



2


3







1

983108983137983150983145983141983148983148983141 983107983151983150983159983137983161 983123983156983137983156983141 983137983150983140 983116983151983139983137983148 983111983151983158983141983154983150983149983141983150983156 983120983154983151983139983157983154983141983149983141983150983156 (983107983144983145983139983137983143983151 983105983106983105 983123983141983139983156983145983151983150 983151983142 983116983151983139983137983148 983111983151983158983141983154983150983149983141983150983156983116983137983159 2012)

2 983113983140983137983156 9830942

3 983113983140 983137983156 9830943




11
















5 983123983156983137983156983141 983137983150983140 983116983151983139983137983148 983111983151983158983141983154983150983149983141983150983156 983137983156 100



12


OAG Response











innuendo9

983094 983105983113983107983120983105 983120983154983151983142983141983155983155983145983151983150983137983148 983123983156983137983150983140983137983154983140983155 (983114983157983150983141 1 2012) 98320710151

983095 983107983151983149983149983137983150983140 983117983137983150983137983143983141983149983141983150983156 983123983141983154983158983145983139983141983155 983113983150983139 983158 983125983150983145983156983141983140 983123983156983137983156983141983155 111 FedCl 279 (2013)

983096 983113983140

983097 983113983140



13













14











15

OBSERVATIONS





CRITERIA











16













11 983110983105983122 15303(983138)(1)



17













18














19














20












21


prepared









Monitoring pg 66





22














23











Contract of Lease







24






Criteria










25














26
















27











than the WCBA





28













29














30




No Bid Contracts







31












32














33



Contract Elements

Missing Dates












34


Missing Signatures









Contract Analysis






35
















36








bull





37











THE GENERAL LEDGER



38






OAG Response






39



















40










bull





41










document)





42






Transition Basic)





43














44





allocation






45


$2897 million


Cause










46













47










AECOM





48


OAG Response











49










Accounting Fees





50






from bond proceeds









51
















52

















53




policy








54




Litigation Costs








OAG Response





55








12



12 983109983149983137983145983148 983142983151983154983149 983120983148983137983150983156983141 983117983151983154983137983150 983140983137983156983141983140 983105983157983143983157983155983156 983096 2013



56





service the debt

13

Conclusion





13 983127983107983106983105 983137983157983140983145983156983141983140 983142983145983150983137983150983139983145983137983148 983155983156983137983156983141983149983141983150983156 983140983137983156983141983140 983123983141983152983156983141983149983138983141983154 30 2012



57











58



bonds











59















on it at this time







4












5














6









Criteria- pg 40






7











8









Risk Management





9

Control Activities













10



2


3







1

983108983137983150983145983141983148983148983141 983107983151983150983159983137983161 983123983156983137983156983141 983137983150983140 983116983151983139983137983148 983111983151983158983141983154983150983149983141983150983156 983120983154983151983139983157983154983141983149983141983150983156 (983107983144983145983139983137983143983151 983105983106983105 983123983141983139983156983145983151983150 983151983142 983116983151983139983137983148 983111983151983158983141983154983150983149983141983150983156983116983137983159 2012)

2 983113983140983137983156 9830942

3 983113983140 983137983156 9830943




11
















5 983123983156983137983156983141 983137983150983140 983116983151983139983137983148 983111983151983158983141983154983150983149983141983150983156 983137983156 100



12


OAG Response











innuendo9

983094 983105983113983107983120983105 983120983154983151983142983141983155983155983145983151983150983137983148 983123983156983137983150983140983137983154983140983155 (983114983157983150983141 1 2012) 98320710151

983095 983107983151983149983149983137983150983140 983117983137983150983137983143983141983149983141983150983156 983123983141983154983158983145983139983141983155 983113983150983139 983158 983125983150983145983156983141983140 983123983156983137983156983141983155 111 FedCl 279 (2013)

983096 983113983140

983097 983113983140



13













14











15

OBSERVATIONS





CRITERIA











16













11 983110983105983122 15303(983138)(1)



17













18














19














20












21


prepared









Monitoring pg 66





22














23











Contract of Lease







24






Criteria










25














26
















27











than the WCBA





28













29














30




No Bid Contracts







31












32














33



Contract Elements

Missing Dates












34


Missing Signatures









Contract Analysis






35
















36








bull





37











THE GENERAL LEDGER



38






OAG Response






39



















40










bull





41










document)





42






Transition Basic)





43














44





allocation






45


$2897 million


Cause










46













47










AECOM





48


OAG Response











49










Accounting Fees





50






from bond proceeds









51
















52

















53




policy








54




Litigation Costs








OAG Response





55








12



12 983109983149983137983145983148 983142983151983154983149 983120983148983137983150983156983141 983117983151983154983137983150 983140983137983156983141983140 983105983157983143983157983155983156 983096 2013



56





service the debt

13

Conclusion





13 983127983107983106983105 983137983157983140983145983156983141983140 983142983145983150983137983150983139983145983137983148 983155983156983137983156983141983149983141983150983156 983140983137983156983141983140 983123983141983152983156983141983149983138983141983154 30 2012



57











58



bonds











59















on it at this time







5














6









Criteria- pg 40






7











8









Risk Management





9

Control Activities













10



2


3







1

983108983137983150983145983141983148983148983141 983107983151983150983159983137983161 983123983156983137983156983141 983137983150983140 983116983151983139983137983148 983111983151983158983141983154983150983149983141983150983156 983120983154983151983139983157983154983141983149983141983150983156 (983107983144983145983139983137983143983151 983105983106983105 983123983141983139983156983145983151983150 983151983142 983116983151983139983137983148 983111983151983158983141983154983150983149983141983150983156983116983137983159 2012)

2 983113983140983137983156 9830942

3 983113983140 983137983156 9830943




11
















5 983123983156983137983156983141 983137983150983140 983116983151983139983137983148 983111983151983158983141983154983150983149983141983150983156 983137983156 100



12


OAG Response











innuendo9

983094 983105983113983107983120983105 983120983154983151983142983141983155983155983145983151983150983137983148 983123983156983137983150983140983137983154983140983155 (983114983157983150983141 1 2012) 98320710151

983095 983107983151983149983149983137983150983140 983117983137983150983137983143983141983149983141983150983156 983123983141983154983158983145983139983141983155 983113983150983139 983158 983125983150983145983156983141983140 983123983156983137983156983141983155 111 FedCl 279 (2013)

983096 983113983140

983097 983113983140



13













14











15

OBSERVATIONS





CRITERIA











16













11 983110983105983122 15303(983138)(1)



17













18














19














20












21


prepared









Monitoring pg 66





22














23











Contract of Lease







24






Criteria










25














26
















27











than the WCBA





28













29














30




No Bid Contracts







31












32














33



Contract Elements

Missing Dates












34


Missing Signatures









Contract Analysis






35
















36








bull





37











THE GENERAL LEDGER



38






OAG Response






39



















40










bull





41










document)





42






Transition Basic)





43














44





allocation






45


$2897 million


Cause










46













47










AECOM





48


OAG Response











49










Accounting Fees





50






from bond proceeds









51
















52

















53




policy








54




Litigation Costs








OAG Response





55








12



12 983109983149983137983145983148 983142983151983154983149 983120983148983137983150983156983141 983117983151983154983137983150 983140983137983156983141983140 983105983157983143983157983155983156 983096 2013



56





service the debt

13

Conclusion





13 983127983107983106983105 983137983157983140983145983156983141983140 983142983145983150983137983150983139983145983137983148 983155983156983137983156983141983149983141983150983156 983140983137983156983141983140 983123983141983152983156983141983149983138983141983154 30 2012



57











58



bonds











59















on it at this time







6









Criteria- pg 40






7











8









Risk Management





9

Control Activities













10



2


3







1

983108983137983150983145983141983148983148983141 983107983151983150983159983137983161 983123983156983137983156983141 983137983150983140 983116983151983139983137983148 983111983151983158983141983154983150983149983141983150983156 983120983154983151983139983157983154983141983149983141983150983156 (983107983144983145983139983137983143983151 983105983106983105 983123983141983139983156983145983151983150 983151983142 983116983151983139983137983148 983111983151983158983141983154983150983149983141983150983156983116983137983159 2012)

2 983113983140983137983156 9830942

3 983113983140 983137983156 9830943




11
















5 983123983156983137983156983141 983137983150983140 983116983151983139983137983148 983111983151983158983141983154983150983149983141983150983156 983137983156 100



12


OAG Response











innuendo9

983094 983105983113983107983120983105 983120983154983151983142983141983155983155983145983151983150983137983148 983123983156983137983150983140983137983154983140983155 (983114983157983150983141 1 2012) 98320710151

983095 983107983151983149983149983137983150983140 983117983137983150983137983143983141983149983141983150983156 983123983141983154983158983145983139983141983155 983113983150983139 983158 983125983150983145983156983141983140 983123983156983137983156983141983155 111 FedCl 279 (2013)

983096 983113983140

983097 983113983140



13













14











15

OBSERVATIONS





CRITERIA











16













11 983110983105983122 15303(983138)(1)



17













18














19














20












21


prepared









Monitoring pg 66





22














23











Contract of Lease







24






Criteria










25














26
















27











than the WCBA





28













29














30




No Bid Contracts







31












32














33



Contract Elements

Missing Dates












34


Missing Signatures









Contract Analysis






35
















36








bull





37











THE GENERAL LEDGER



38






OAG Response






39



















40










bull





41










document)





42






Transition Basic)





43














44





allocation






45


$2897 million


Cause










46













47










AECOM





48


OAG Response











49










Accounting Fees





50






from bond proceeds









51
















52

















53




policy








54




Litigation Costs








OAG Response





55








12



12 983109983149983137983145983148 983142983151983154983149 983120983148983137983150983156983141 983117983151983154983137983150 983140983137983156983141983140 983105983157983143983157983155983156 983096 2013



56





service the debt

13

Conclusion





13 983127983107983106983105 983137983157983140983145983156983141983140 983142983145983150983137983150983139983145983137983148 983155983156983137983156983141983149983141983150983156 983140983137983156983141983140 983123983141983152983156983141983149983138983141983154 30 2012



57











58



bonds











59















on it at this time







7











8









Risk Management





9

Control Activities













10



2


3







1

983108983137983150983145983141983148983148983141 983107983151983150983159983137983161 983123983156983137983156983141 983137983150983140 983116983151983139983137983148 983111983151983158983141983154983150983149983141983150983156 983120983154983151983139983157983154983141983149983141983150983156 (983107983144983145983139983137983143983151 983105983106983105 983123983141983139983156983145983151983150 983151983142 983116983151983139983137983148 983111983151983158983141983154983150983149983141983150983156983116983137983159 2012)

2 983113983140983137983156 9830942

3 983113983140 983137983156 9830943




11
















5 983123983156983137983156983141 983137983150983140 983116983151983139983137983148 983111983151983158983141983154983150983149983141983150983156 983137983156 100



12


OAG Response











innuendo9

983094 983105983113983107983120983105 983120983154983151983142983141983155983155983145983151983150983137983148 983123983156983137983150983140983137983154983140983155 (983114983157983150983141 1 2012) 98320710151

983095 983107983151983149983149983137983150983140 983117983137983150983137983143983141983149983141983150983156 983123983141983154983158983145983139983141983155 983113983150983139 983158 983125983150983145983156983141983140 983123983156983137983156983141983155 111 FedCl 279 (2013)

983096 983113983140

983097 983113983140



13













14











15

OBSERVATIONS





CRITERIA











16













11 983110983105983122 15303(983138)(1)



17













18














19














20












21


prepared









Monitoring pg 66





22














23











Contract of Lease







24






Criteria










25














26
















27











than the WCBA





28













29














30




No Bid Contracts







31












32














33



Contract Elements

Missing Dates












34


Missing Signatures









Contract Analysis






35
















36








bull





37











THE GENERAL LEDGER



38






OAG Response






39



















40










bull





41










document)





42






Transition Basic)





43














44





allocation






45


$2897 million


Cause










46













47










AECOM





48


OAG Response











49










Accounting Fees





50






from bond proceeds









51
















52

















53




policy








54




Litigation Costs








OAG Response





55








12



12 983109983149983137983145983148 983142983151983154983149 983120983148983137983150983156983141 983117983151983154983137983150 983140983137983156983141983140 983105983157983143983157983155983156 983096 2013



56





service the debt

13

Conclusion





13 983127983107983106983105 983137983157983140983145983156983141983140 983142983145983150983137983150983139983145983137983148 983155983156983137983156983141983149983141983150983156 983140983137983156983141983140 983123983141983152983156983141983149983138983141983154 30 2012



57











58



bonds











59















on it at this time







8









Risk Management





9

Control Activities













10



2


3







1

983108983137983150983145983141983148983148983141 983107983151983150983159983137983161 983123983156983137983156983141 983137983150983140 983116983151983139983137983148 983111983151983158983141983154983150983149983141983150983156 983120983154983151983139983157983154983141983149983141983150983156 (983107983144983145983139983137983143983151 983105983106983105 983123983141983139983156983145983151983150 983151983142 983116983151983139983137983148 983111983151983158983141983154983150983149983141983150983156983116983137983159 2012)

2 983113983140983137983156 9830942

3 983113983140 983137983156 9830943




11
















5 983123983156983137983156983141 983137983150983140 983116983151983139983137983148 983111983151983158983141983154983150983149983141983150983156 983137983156 100



12


OAG Response











innuendo9

983094 983105983113983107983120983105 983120983154983151983142983141983155983155983145983151983150983137983148 983123983156983137983150983140983137983154983140983155 (983114983157983150983141 1 2012) 98320710151

983095 983107983151983149983149983137983150983140 983117983137983150983137983143983141983149983141983150983156 983123983141983154983158983145983139983141983155 983113983150983139 983158 983125983150983145983156983141983140 983123983156983137983156983141983155 111 FedCl 279 (2013)

983096 983113983140

983097 983113983140



13













14











15

OBSERVATIONS





CRITERIA











16













11 983110983105983122 15303(983138)(1)



17













18














19














20












21


prepared









Monitoring pg 66





22














23











Contract of Lease







24






Criteria










25














26
















27











than the WCBA





28













29














30




No Bid Contracts







31












32














33



Contract Elements

Missing Dates












34


Missing Signatures









Contract Analysis






35
















36








bull





37











THE GENERAL LEDGER



38






OAG Response






39



















40










bull





41










document)





42






Transition Basic)





43














44





allocation






45


$2897 million


Cause










46













47










AECOM





48


OAG Response











49










Accounting Fees





50






from bond proceeds









51
















52

















53




policy








54




Litigation Costs








OAG Response





55








12



12 983109983149983137983145983148 983142983151983154983149 983120983148983137983150983156983141 983117983151983154983137983150 983140983137983156983141983140 983105983157983143983157983155983156 983096 2013



56





service the debt

13

Conclusion





13 983127983107983106983105 983137983157983140983145983156983141983140 983142983145983150983137983150983139983145983137983148 983155983156983137983156983141983149983141983150983156 983140983137983156983141983140 983123983141983152983156983141983149983138983141983154 30 2012



57











58



bonds











59















on it at this time







9

Control Activities













10



2


3







1

983108983137983150983145983141983148983148983141 983107983151983150983159983137983161 983123983156983137983156983141 983137983150983140 983116983151983139983137983148 983111983151983158983141983154983150983149983141983150983156 983120983154983151983139983157983154983141983149983141983150983156 (983107983144983145983139983137983143983151 983105983106983105 983123983141983139983156983145983151983150 983151983142 983116983151983139983137983148 983111983151983158983141983154983150983149983141983150983156983116983137983159 2012)

2 983113983140983137983156 9830942

3 983113983140 983137983156 9830943




11
















5 983123983156983137983156983141 983137983150983140 983116983151983139983137983148 983111983151983158983141983154983150983149983141983150983156 983137983156 100



12


OAG Response











innuendo9

983094 983105983113983107983120983105 983120983154983151983142983141983155983155983145983151983150983137983148 983123983156983137983150983140983137983154983140983155 (983114983157983150983141 1 2012) 98320710151

983095 983107983151983149983149983137983150983140 983117983137983150983137983143983141983149983141983150983156 983123983141983154983158983145983139983141983155 983113983150983139 983158 983125983150983145983156983141983140 983123983156983137983156983141983155 111 FedCl 279 (2013)

983096 983113983140

983097 983113983140



13













14











15

OBSERVATIONS





CRITERIA











16













11 983110983105983122 15303(983138)(1)



17













18














19














20












21


prepared









Monitoring pg 66





22














23











Contract of Lease







24






Criteria










25














26
















27











than the WCBA





28













29














30




No Bid Contracts







31












32














33



Contract Elements

Missing Dates












34


Missing Signatures









Contract Analysis






35
















36








bull





37











THE GENERAL LEDGER



38





Wayne County Treasurerrsquos Office (WCTO) maintains a cash ledger in RESIQ2 at thecash pool level and not at the individual fund level in the general ledger The WCTO cashbalance for the Building Pool includes cash balances of multiple funds within JDEdwards (JDE) Therefore PMampA can not reconcile the jail project cash total (fundlevel) to the WCTO cash ledger (Pool) balance The jail project cash account in JDE isonly one of the cash accounts that makes up the total cash balance in the Building PoolMampB is responsible for the monthly reconciliation of the individual fund cash accounttotals from JDE to the appropriate cash ledger (Pool) balances from WCTO PMampA relyon this process The $127886 reconciling item referenced in the conclusion section on of the OAGrsquos report is a result of a timing difference between recording thesheriffrsquos transition team costs in the jail fund for June 2013 and the settlement of cash inJuly 2013

OAG Response






39



















40










bull





41










document)





42






Transition Basic)





43














44





allocation






45


$2897 million


Cause










46













47










AECOM





48


OAG Response











49










Accounting Fees





50






from bond proceeds









51
















52

















53




policy








54




Litigation Costs








OAG Response





55








12



12 983109983149983137983145983148 983142983151983154983149 983120983148983137983150983156983141 983117983151983154983137983150 983140983137983156983141983140 983105983157983143983157983155983156 983096 2013



56





service the debt

13

Conclusion





13 983127983107983106983105 983137983157983140983145983156983141983140 983142983145983150983137983150983139983145983137983148 983155983156983137983156983141983149983141983150983156 983140983137983156983141983140 983123983141983152983156983141983149983138983141983154 30 2012



57











58



bonds











59















on it at this time







10



2


3







1

983108983137983150983145983141983148983148983141 983107983151983150983159983137983161 983123983156983137983156983141 983137983150983140 983116983151983139983137983148 983111983151983158983141983154983150983149983141983150983156 983120983154983151983139983157983154983141983149983141983150983156 (983107983144983145983139983137983143983151 983105983106983105 983123983141983139983156983145983151983150 983151983142 983116983151983139983137983148 983111983151983158983141983154983150983149983141983150983156983116983137983159 2012)

2 983113983140983137983156 9830942

3 983113983140 983137983156 9830943




11
















5 983123983156983137983156983141 983137983150983140 983116983151983139983137983148 983111983151983158983141983154983150983149983141983150983156 983137983156 100



12


OAG Response











innuendo9

983094 983105983113983107983120983105 983120983154983151983142983141983155983155983145983151983150983137983148 983123983156983137983150983140983137983154983140983155 (983114983157983150983141 1 2012) 98320710151

983095 983107983151983149983149983137983150983140 983117983137983150983137983143983141983149983141983150983156 983123983141983154983158983145983139983141983155 983113983150983139 983158 983125983150983145983156983141983140 983123983156983137983156983141983155 111 FedCl 279 (2013)

983096 983113983140

983097 983113983140



13













14











15

OBSERVATIONS





CRITERIA











16













11 983110983105983122 15303(983138)(1)



17













18














19














20












21


prepared









Monitoring pg 66





22














23











Contract of Lease







24






Criteria










25














26
















27











than the WCBA





28













29














30




No Bid Contracts







31












32














33



Contract Elements

Missing Dates












34


Missing Signatures









Contract Analysis






35
















36








bull





37



Point of Clarification 3 indicates that the Oversight Committee was involved inthe hiring of the Sheriffrsquos Transition Team including interviews This is inaccurate TheSheriff selected his team members and informed County staff of his selections








THE GENERAL LEDGER



38






OAG Response






39



















40










bull





41










document)





42






Transition Basic)





43














44





allocation






45


$2897 million


Cause










46













47










AECOM





48


OAG Response











49










Accounting Fees





50






from bond proceeds









51
















52

















53




policy








54




Litigation Costs








OAG Response





55








12



12 983109983149983137983145983148 983142983151983154983149 983120983148983137983150983156983141 983117983151983154983137983150 983140983137983156983141983140 983105983157983143983157983155983156 983096 2013



56





service the debt

13

Conclusion





13 983127983107983106983105 983137983157983140983145983156983141983140 983142983145983150983137983150983139983145983137983148 983155983156983137983156983141983149983141983150983156 983140983137983156983141983140 983123983141983152983156983141983149983138983141983154 30 2012



57











58



bonds











59















on it at this time







11
















5 983123983156983137983156983141 983137983150983140 983116983151983139983137983148 983111983151983158983141983154983150983149983141983150983156 983137983156 100



12


OAG Response











innuendo9

983094 983105983113983107983120983105 983120983154983151983142983141983155983155983145983151983150983137983148 983123983156983137983150983140983137983154983140983155 (983114983157983150983141 1 2012) 98320710151

983095 983107983151983149983149983137983150983140 983117983137983150983137983143983141983149983141983150983156 983123983141983154983158983145983139983141983155 983113983150983139 983158 983125983150983145983156983141983140 983123983156983137983156983141983155 111 FedCl 279 (2013)

983096 983113983140

983097 983113983140



13













14











15

OBSERVATIONS





CRITERIA











16













11 983110983105983122 15303(983138)(1)



17













18














19














20












21


prepared









Monitoring pg 66





22














23











Contract of Lease







24






Criteria










25














26
















27











than the WCBA





28













29














30




No Bid Contracts







31












32














33



Contract Elements

Missing Dates












34


Missing Signatures









Contract Analysis






35
















36








bull





37











THE GENERAL LEDGER



38






OAG Response






39



















40










bull





41










document)





42






Transition Basic)





43














44





allocation






45


$2897 million


Cause










46













47










AECOM





48


OAG Response











49










Accounting Fees





50






from bond proceeds









51
















52

















53




policy








54




Litigation Costs








OAG Response





55








12



12 983109983149983137983145983148 983142983151983154983149 983120983148983137983150983156983141 983117983151983154983137983150 983140983137983156983141983140 983105983157983143983157983155983156 983096 2013



56





service the debt

13

Conclusion





13 983127983107983106983105 983137983157983140983145983156983141983140 983142983145983150983137983150983139983145983137983148 983155983156983137983156983141983149983141983150983156 983140983137983156983141983140 983123983141983152983156983141983149983138983141983154 30 2012



57











58



bonds











59















on it at this time







12


OAG Response











innuendo9

983094 983105983113983107983120983105 983120983154983151983142983141983155983155983145983151983150983137983148 983123983156983137983150983140983137983154983140983155 (983114983157983150983141 1 2012) 98320710151

983095 983107983151983149983149983137983150983140 983117983137983150983137983143983141983149983141983150983156 983123983141983154983158983145983139983141983155 983113983150983139 983158 983125983150983145983156983141983140 983123983156983137983156983141983155 111 FedCl 279 (2013)

983096 983113983140

983097 983113983140



13













14











15

OBSERVATIONS





CRITERIA











16













11 983110983105983122 15303(983138)(1)



17













18














19














20












21


prepared









Monitoring pg 66





22














23











Contract of Lease







24






Criteria










25














26
















27











than the WCBA





28













29














30




No Bid Contracts







31












32














33



Contract Elements

Missing Dates












34


Missing Signatures









Contract Analysis






35
















36








bull





37











THE GENERAL LEDGER



38






OAG Response






39



















40










bull





41










document)





42






Transition Basic)





43














44





allocation






45


$2897 million


Cause










46













47










AECOM





48


OAG Response











49










Accounting Fees





50






from bond proceeds









51
















52

















53




policy








54




Litigation Costs








OAG Response





55








12



12 983109983149983137983145983148 983142983151983154983149 983120983148983137983150983156983141 983117983151983154983137983150 983140983137983156983141983140 983105983157983143983157983155983156 983096 2013



56





service the debt

13

Conclusion





13 983127983107983106983105 983137983157983140983145983156983141983140 983142983145983150983137983150983139983145983137983148 983155983156983137983156983141983149983141983150983156 983140983137983156983141983140 983123983141983152983156983141983149983138983141983154 30 2012



57











58



bonds











59















on it at this time







13













14











15

OBSERVATIONS





CRITERIA











16













11 983110983105983122 15303(983138)(1)



17













18














19














20












21


prepared









Monitoring pg 66





22














23











Contract of Lease







24






Criteria










25














26
















27











than the WCBA





28













29














30




No Bid Contracts







31












32














33



Contract Elements

Missing Dates












34


Missing Signatures









Contract Analysis






35
















36








bull





37











THE GENERAL LEDGER



38






OAG Response






39



















40










bull





41










document)





42






Transition Basic)





43














44





allocation






45


$2897 million


Cause










46













47










AECOM





48


OAG Response











49










Accounting Fees





50






from bond proceeds









51
















52

















53




policy








54




Litigation Costs








OAG Response





55








12



12 983109983149983137983145983148 983142983151983154983149 983120983148983137983150983156983141 983117983151983154983137983150 983140983137983156983141983140 983105983157983143983157983155983156 983096 2013



56





service the debt

13

Conclusion





13 983127983107983106983105 983137983157983140983145983156983141983140 983142983145983150983137983150983139983145983137983148 983155983156983137983156983141983149983141983150983156 983140983137983156983141983140 983123983141983152983156983141983149983138983141983154 30 2012



57











58



bonds











59















on it at this time







14











15

OBSERVATIONS





CRITERIA











16













11 983110983105983122 15303(983138)(1)



17













18














19














20












21


prepared









Monitoring pg 66





22














23











Contract of Lease







24






Criteria










25














26
















27











than the WCBA





28













29














30




No Bid Contracts







31












32














33



Contract Elements

Missing Dates












34


Missing Signatures









Contract Analysis






35
















36








bull





37











THE GENERAL LEDGER



38






OAG Response






39



















40










bull





41










document)





42






Transition Basic)





43














44





allocation






45


$2897 million


Cause










46













47










AECOM





48


OAG Response











49










Accounting Fees





50






from bond proceeds









51
















52

















53




policy








54




Litigation Costs








OAG Response





55








12



12 983109983149983137983145983148 983142983151983154983149 983120983148983137983150983156983141 983117983151983154983137983150 983140983137983156983141983140 983105983157983143983157983155983156 983096 2013



56





service the debt

13

Conclusion





13 983127983107983106983105 983137983157983140983145983156983141983140 983142983145983150983137983150983139983145983137983148 983155983156983137983156983141983149983141983150983156 983140983137983156983141983140 983123983141983152983156983141983149983138983141983154 30 2012



57











58



bonds











59















on it at this time







15

OBSERVATIONS





CRITERIA











16













11 983110983105983122 15303(983138)(1)



17













18














19














20












21


prepared









Monitoring pg 66





22














23











Contract of Lease







24






Criteria










25














26
















27











than the WCBA





28













29














30




No Bid Contracts







31












32














33



Contract Elements

Missing Dates












34


Missing Signatures









Contract Analysis






35
















36








bull





37











THE GENERAL LEDGER



38






OAG Response






39



















40










bull





41










document)





42






Transition Basic)





43














44





allocation






45


$2897 million


Cause










46













47










AECOM





48


OAG Response











49










Accounting Fees





50






from bond proceeds









51
















52

















53




policy








54




Litigation Costs








OAG Response





55








12



12 983109983149983137983145983148 983142983151983154983149 983120983148983137983150983156983141 983117983151983154983137983150 983140983137983156983141983140 983105983157983143983157983155983156 983096 2013



56





service the debt

13

Conclusion





13 983127983107983106983105 983137983157983140983145983156983141983140 983142983145983150983137983150983139983145983137983148 983155983156983137983156983141983149983141983150983156 983140983137983156983141983140 983123983141983152983156983141983149983138983141983154 30 2012



57











58



bonds











59















on it at this time







16













11 983110983105983122 15303(983138)(1)



17













18














19














20












21


prepared









Monitoring pg 66





22














23











Contract of Lease







24






Criteria










25














26
















27











than the WCBA





28













29














30




No Bid Contracts







31












32














33



Contract Elements

Missing Dates












34


Missing Signatures









Contract Analysis






35
















36








bull





37











THE GENERAL LEDGER



38






OAG Response






39



















40










bull





41










document)





42






Transition Basic)





43














44





allocation






45


$2897 million


Cause










46













47










AECOM





48


OAG Response











49










Accounting Fees





50






from bond proceeds









51
















52

















53




policy








54




Litigation Costs








OAG Response





55








12



12 983109983149983137983145983148 983142983151983154983149 983120983148983137983150983156983141 983117983151983154983137983150 983140983137983156983141983140 983105983157983143983157983155983156 983096 2013



56





service the debt

13

Conclusion





13 983127983107983106983105 983137983157983140983145983156983141983140 983142983145983150983137983150983139983145983137983148 983155983156983137983156983141983149983141983150983156 983140983137983156983141983140 983123983141983152983156983141983149983138983141983154 30 2012



57











58



bonds











59















on it at this time







17













18














19














20












21


prepared









Monitoring pg 66





22














23











Contract of Lease







24






Criteria










25














26
















27











than the WCBA





28













29














30




No Bid Contracts







31












32














33



Contract Elements

Missing Dates












34


Missing Signatures









Contract Analysis






35
















36








bull





37











THE GENERAL LEDGER



38






OAG Response






39



















40










bull





41










document)





42






Transition Basic)





43














44





allocation






45


$2897 million


Cause










46













47










AECOM





48


OAG Response











49










Accounting Fees





50






from bond proceeds









51
















52

















53




policy








54




Litigation Costs








OAG Response





55








12



12 983109983149983137983145983148 983142983151983154983149 983120983148983137983150983156983141 983117983151983154983137983150 983140983137983156983141983140 983105983157983143983157983155983156 983096 2013



56





service the debt

13

Conclusion





13 983127983107983106983105 983137983157983140983145983156983141983140 983142983145983150983137983150983139983145983137983148 983155983156983137983156983141983149983141983150983156 983140983137983156983141983140 983123983141983152983156983141983149983138983141983154 30 2012



57











58



bonds











59















on it at this time







18














19














20












21


prepared









Monitoring pg 66





22














23











Contract of Lease







24






Criteria










25














26
















27











than the WCBA





28













29














30




No Bid Contracts







31












32














33



Contract Elements

Missing Dates












34


Missing Signatures









Contract Analysis






35
















36








bull





37











THE GENERAL LEDGER



38






OAG Response






39



















40










bull





41










document)





42






Transition Basic)





43














44





allocation






45


$2897 million


Cause










46













47










AECOM





48


OAG Response











49










Accounting Fees





50






from bond proceeds









51
















52

















53




policy








54




Litigation Costs








OAG Response





55








12



12 983109983149983137983145983148 983142983151983154983149 983120983148983137983150983156983141 983117983151983154983137983150 983140983137983156983141983140 983105983157983143983157983155983156 983096 2013



56





service the debt

13

Conclusion





13 983127983107983106983105 983137983157983140983145983156983141983140 983142983145983150983137983150983139983145983137983148 983155983156983137983156983141983149983141983150983156 983140983137983156983141983140 983123983141983152983156983141983149983138983141983154 30 2012



57











58



bonds











59















on it at this time







19














20












21


prepared









Monitoring pg 66





22














23











Contract of Lease







24






Criteria










25














26
















27











than the WCBA





28













29














30




No Bid Contracts







31












32














33



Contract Elements

Missing Dates












34


Missing Signatures









Contract Analysis






35
















36








bull





37











THE GENERAL LEDGER



38






OAG Response






39



















40










bull





41










document)





42






Transition Basic)





43














44





allocation






45


$2897 million


Cause










46













47










AECOM





48


OAG Response











49










Accounting Fees





50






from bond proceeds









51
















52

















53




policy








54




Litigation Costs








OAG Response





55








12



12 983109983149983137983145983148 983142983151983154983149 983120983148983137983150983156983141 983117983151983154983137983150 983140983137983156983141983140 983105983157983143983157983155983156 983096 2013



56





service the debt

13

Conclusion





13 983127983107983106983105 983137983157983140983145983156983141983140 983142983145983150983137983150983139983145983137983148 983155983156983137983156983141983149983141983150983156 983140983137983156983141983140 983123983141983152983156983141983149983138983141983154 30 2012



57











58



bonds











59















on it at this time







20












21


prepared









Monitoring pg 66





22














23











Contract of Lease







24






Criteria










25














26
















27











than the WCBA





28













29














30




No Bid Contracts







31












32














33



Contract Elements

Missing Dates












34


Missing Signatures









Contract Analysis






35
















36








bull





37











THE GENERAL LEDGER



38






OAG Response






39



















40










bull





41










document)





42






Transition Basic)





43














44





allocation






45


$2897 million


Cause










46













47










AECOM





48


OAG Response











49










Accounting Fees





50






from bond proceeds









51
















52

















53




policy








54




Litigation Costs








OAG Response





55








12



12 983109983149983137983145983148 983142983151983154983149 983120983148983137983150983156983141 983117983151983154983137983150 983140983137983156983141983140 983105983157983143983157983155983156 983096 2013



56





service the debt

13

Conclusion





13 983127983107983106983105 983137983157983140983145983156983141983140 983142983145983150983137983150983139983145983137983148 983155983156983137983156983141983149983141983150983156 983140983137983156983141983140 983123983141983152983156983141983149983138983141983154 30 2012



57











58



bonds











59















on it at this time







21


prepared









Monitoring pg 66





22














23











Contract of Lease







24






Criteria










25














26
















27











than the WCBA





28













29














30




No Bid Contracts







31












32














33



Contract Elements

Missing Dates












34


Missing Signatures









Contract Analysis






35
















36








bull





37











THE GENERAL LEDGER



38






OAG Response






39



















40










bull





41










document)





42






Transition Basic)





43














44





allocation






45


$2897 million


Cause










46













47










AECOM





48


OAG Response











49










Accounting Fees





50






from bond proceeds









51
















52

















53




policy








54




Litigation Costs








OAG Response





55








12



12 983109983149983137983145983148 983142983151983154983149 983120983148983137983150983156983141 983117983151983154983137983150 983140983137983156983141983140 983105983157983143983157983155983156 983096 2013



56





service the debt

13

Conclusion





13 983127983107983106983105 983137983157983140983145983156983141983140 983142983145983150983137983150983139983145983137983148 983155983156983137983156983141983149983141983150983156 983140983137983156983141983140 983123983141983152983156983141983149983138983141983154 30 2012



57











58



bonds











59















on it at this time







22














23











Contract of Lease







24






Criteria










25














26
















27











than the WCBA





28













29














30




No Bid Contracts







31












32














33



Contract Elements

Missing Dates












34


Missing Signatures









Contract Analysis






35
















36








bull





37











THE GENERAL LEDGER



38






OAG Response






39



















40










bull





41










document)





42






Transition Basic)





43














44





allocation






45


$2897 million


Cause










46













47










AECOM





48


OAG Response











49










Accounting Fees





50






from bond proceeds









51
















52

















53




policy








54




Litigation Costs








OAG Response





55








12



12 983109983149983137983145983148 983142983151983154983149 983120983148983137983150983156983141 983117983151983154983137983150 983140983137983156983141983140 983105983157983143983157983155983156 983096 2013



56





service the debt

13

Conclusion





13 983127983107983106983105 983137983157983140983145983156983141983140 983142983145983150983137983150983139983145983137983148 983155983156983137983156983141983149983141983150983156 983140983137983156983141983140 983123983141983152983156983141983149983138983141983154 30 2012



57











58



bonds











59















on it at this time







23











Contract of Lease







24






Criteria










25














26
















27











than the WCBA





28













29














30




No Bid Contracts







31












32














33



Contract Elements

Missing Dates












34


Missing Signatures









Contract Analysis






35
















36








bull





37











THE GENERAL LEDGER



38






OAG Response






39



















40










bull





41










document)





42






Transition Basic)





43














44





allocation






45


$2897 million


Cause










46













47










AECOM





48


OAG Response











49










Accounting Fees





50






from bond proceeds









51
















52

















53




policy








54




Litigation Costs








OAG Response





55








12



12 983109983149983137983145983148 983142983151983154983149 983120983148983137983150983156983141 983117983151983154983137983150 983140983137983156983141983140 983105983157983143983157983155983156 983096 2013



56





service the debt

13

Conclusion





13 983127983107983106983105 983137983157983140983145983156983141983140 983142983145983150983137983150983139983145983137983148 983155983156983137983156983141983149983141983150983156 983140983137983156983141983140 983123983141983152983156983141983149983138983141983154 30 2012



57











58



bonds











59















on it at this time







24






Criteria










25














26
















27











than the WCBA





28













29














30




No Bid Contracts







31












32














33



Contract Elements

Missing Dates












34


Missing Signatures









Contract Analysis






35
















36








bull





37











THE GENERAL LEDGER



38






OAG Response






39



















40










bull





41










document)





42






Transition Basic)





43














44





allocation






45


$2897 million


Cause










46













47










AECOM





48


OAG Response











49










Accounting Fees





50






from bond proceeds









51
















52

















53




policy








54




Litigation Costs








OAG Response





55








12



12 983109983149983137983145983148 983142983151983154983149 983120983148983137983150983156983141 983117983151983154983137983150 983140983137983156983141983140 983105983157983143983157983155983156 983096 2013



56





service the debt

13

Conclusion





13 983127983107983106983105 983137983157983140983145983156983141983140 983142983145983150983137983150983139983145983137983148 983155983156983137983156983141983149983141983150983156 983140983137983156983141983140 983123983141983152983156983141983149983138983141983154 30 2012



57











58



bonds











59















on it at this time







25














26
















27











than the WCBA





28













29














30




No Bid Contracts







31












32














33



Contract Elements

Missing Dates












34


Missing Signatures









Contract Analysis






35
















36








bull





37











THE GENERAL LEDGER



38






OAG Response






39



















40










bull





41










document)





42






Transition Basic)





43














44





allocation






45


$2897 million


Cause










46













47










AECOM





48


OAG Response











49










Accounting Fees





50






from bond proceeds









51
















52

















53




policy








54




Litigation Costs








OAG Response





55








12



12 983109983149983137983145983148 983142983151983154983149 983120983148983137983150983156983141 983117983151983154983137983150 983140983137983156983141983140 983105983157983143983157983155983156 983096 2013



56





service the debt

13

Conclusion





13 983127983107983106983105 983137983157983140983145983156983141983140 983142983145983150983137983150983139983145983137983148 983155983156983137983156983141983149983141983150983156 983140983137983156983141983140 983123983141983152983156983141983149983138983141983154 30 2012



57











58



bonds











59















on it at this time







26
















27











than the WCBA





28













29














30




No Bid Contracts







31












32














33



Contract Elements

Missing Dates












34


Missing Signatures









Contract Analysis






35
















36








bull





37











THE GENERAL LEDGER



38






OAG Response






39



















40










bull





41










document)





42






Transition Basic)





43














44





allocation






45


$2897 million


Cause










46













47










AECOM





48


OAG Response











49










Accounting Fees





50






from bond proceeds









51
















52

















53




policy








54




Litigation Costs








OAG Response





55








12



12 983109983149983137983145983148 983142983151983154983149 983120983148983137983150983156983141 983117983151983154983137983150 983140983137983156983141983140 983105983157983143983157983155983156 983096 2013



56





service the debt

13

Conclusion





13 983127983107983106983105 983137983157983140983145983156983141983140 983142983145983150983137983150983139983145983137983148 983155983156983137983156983141983149983141983150983156 983140983137983156983141983140 983123983141983152983156983141983149983138983141983154 30 2012



57











58



bonds











59















on it at this time







27











than the WCBA





28













29














30




No Bid Contracts







31












32














33



Contract Elements

Missing Dates












34


Missing Signatures









Contract Analysis






35
















36








bull





37











THE GENERAL LEDGER



38






OAG Response






39



















40










bull





41










document)





42






Transition Basic)





43














44





allocation






45


$2897 million


Cause










46













47










AECOM





48


OAG Response











49










Accounting Fees





50






from bond proceeds









51
















52

















53




policy








54




Litigation Costs








OAG Response





55








12



12 983109983149983137983145983148 983142983151983154983149 983120983148983137983150983156983141 983117983151983154983137983150 983140983137983156983141983140 983105983157983143983157983155983156 983096 2013



56





service the debt

13

Conclusion





13 983127983107983106983105 983137983157983140983145983156983141983140 983142983145983150983137983150983139983145983137983148 983155983156983137983156983141983149983141983150983156 983140983137983156983141983140 983123983141983152983156983141983149983138983141983154 30 2012



57











58



bonds











59















on it at this time







28













29














30




No Bid Contracts







31












32














33



Contract Elements

Missing Dates












34


Missing Signatures









Contract Analysis






35
















36








bull





37











THE GENERAL LEDGER



38






OAG Response






39



















40










bull





41










document)





42






Transition Basic)





43














44





allocation






45


$2897 million


Cause










46













47










AECOM





48


OAG Response











49










Accounting Fees





50






from bond proceeds









51
















52

















53




policy








54




Litigation Costs








OAG Response





55








12



12 983109983149983137983145983148 983142983151983154983149 983120983148983137983150983156983141 983117983151983154983137983150 983140983137983156983141983140 983105983157983143983157983155983156 983096 2013



56





service the debt

13

Conclusion





13 983127983107983106983105 983137983157983140983145983156983141983140 983142983145983150983137983150983139983145983137983148 983155983156983137983156983141983149983141983150983156 983140983137983156983141983140 983123983141983152983156983141983149983138983141983154 30 2012



57











58



bonds











59















on it at this time







29














30




No Bid Contracts







31












32














33



Contract Elements

Missing Dates












34


Missing Signatures









Contract Analysis






35
















36








bull





37











THE GENERAL LEDGER



38






OAG Response






39



















40










bull





41










document)





42






Transition Basic)





43














44





allocation






45


$2897 million


Cause










46













47










AECOM





48


OAG Response











49










Accounting Fees





50






from bond proceeds









51
















52

















53




policy








54




Litigation Costs








OAG Response





55








12



12 983109983149983137983145983148 983142983151983154983149 983120983148983137983150983156983141 983117983151983154983137983150 983140983137983156983141983140 983105983157983143983157983155983156 983096 2013



56





service the debt

13

Conclusion





13 983127983107983106983105 983137983157983140983145983156983141983140 983142983145983150983137983150983139983145983137983148 983155983156983137983156983141983149983141983150983156 983140983137983156983141983140 983123983141983152983156983141983149983138983141983154 30 2012



57











58



bonds











59















on it at this time







30




No Bid Contracts







31












32














33



Contract Elements

Missing Dates












34


Missing Signatures









Contract Analysis






35
















36








bull





37











THE GENERAL LEDGER



38






OAG Response






39



















40










bull





41










document)





42






Transition Basic)





43














44





allocation






45


$2897 million


Cause










46













47










AECOM





48


OAG Response











49










Accounting Fees





50






from bond proceeds









51
















52

















53




policy








54




Litigation Costs








OAG Response





55








12



12 983109983149983137983145983148 983142983151983154983149 983120983148983137983150983156983141 983117983151983154983137983150 983140983137983156983141983140 983105983157983143983157983155983156 983096 2013



56





service the debt

13

Conclusion





13 983127983107983106983105 983137983157983140983145983156983141983140 983142983145983150983137983150983139983145983137983148 983155983156983137983156983141983149983141983150983156 983140983137983156983141983140 983123983141983152983156983141983149983138983141983154 30 2012



57











58



bonds











59















on it at this time







31












32














33



Contract Elements

Missing Dates












34


Missing Signatures









Contract Analysis






35
















36








bull





37











THE GENERAL LEDGER



38






OAG Response






39



















40










bull





41










document)





42






Transition Basic)





43














44





allocation






45


$2897 million


Cause










46













47










AECOM





48


OAG Response











49










Accounting Fees





50






from bond proceeds









51
















52

















53




policy








54




Litigation Costs








OAG Response





55








12



12 983109983149983137983145983148 983142983151983154983149 983120983148983137983150983156983141 983117983151983154983137983150 983140983137983156983141983140 983105983157983143983157983155983156 983096 2013



56





service the debt

13

Conclusion





13 983127983107983106983105 983137983157983140983145983156983141983140 983142983145983150983137983150983139983145983137983148 983155983156983137983156983141983149983141983150983156 983140983137983156983141983140 983123983141983152983156983141983149983138983141983154 30 2012



57











58



bonds











59















on it at this time







32














33



Contract Elements

Missing Dates












34


Missing Signatures









Contract Analysis






35
















36








bull





37











THE GENERAL LEDGER



38






OAG Response






39



















40










bull





41










document)





42






Transition Basic)





43














44





allocation






45


$2897 million


Cause










46













47










AECOM





48


OAG Response











49










Accounting Fees





50






from bond proceeds









51
















52

















53




policy








54




Litigation Costs








OAG Response





55








12



12 983109983149983137983145983148 983142983151983154983149 983120983148983137983150983156983141 983117983151983154983137983150 983140983137983156983141983140 983105983157983143983157983155983156 983096 2013



56





service the debt

13

Conclusion





13 983127983107983106983105 983137983157983140983145983156983141983140 983142983145983150983137983150983139983145983137983148 983155983156983137983156983141983149983141983150983156 983140983137983156983141983140 983123983141983152983156983141983149983138983141983154 30 2012



57











58



bonds











59















on it at this time







33



Contract Elements

Missing Dates












34


Missing Signatures









Contract Analysis






35
















36








bull





37











THE GENERAL LEDGER



38






OAG Response






39



















40










bull





41










document)





42






Transition Basic)





43














44





allocation






45


$2897 million


Cause










46













47










AECOM





48


OAG Response











49










Accounting Fees





50






from bond proceeds









51
















52

















53




policy








54




Litigation Costs








OAG Response





55








12



12 983109983149983137983145983148 983142983151983154983149 983120983148983137983150983156983141 983117983151983154983137983150 983140983137983156983141983140 983105983157983143983157983155983156 983096 2013



56





service the debt

13

Conclusion





13 983127983107983106983105 983137983157983140983145983156983141983140 983142983145983150983137983150983139983145983137983148 983155983156983137983156983141983149983141983150983156 983140983137983156983141983140 983123983141983152983156983141983149983138983141983154 30 2012



57











58



bonds











59















on it at this time







34


Missing Signatures









Contract Analysis






35
















36








bull





37











THE GENERAL LEDGER



38






OAG Response






39



















40










bull





41










document)





42






Transition Basic)





43














44





allocation






45


$2897 million


Cause










46













47










AECOM





48


OAG Response











49










Accounting Fees





50






from bond proceeds









51
















52

















53




policy








54




Litigation Costs








OAG Response





55








12



12 983109983149983137983145983148 983142983151983154983149 983120983148983137983150983156983141 983117983151983154983137983150 983140983137983156983141983140 983105983157983143983157983155983156 983096 2013



56





service the debt

13

Conclusion





13 983127983107983106983105 983137983157983140983145983156983141983140 983142983145983150983137983150983139983145983137983148 983155983156983137983156983141983149983141983150983156 983140983137983156983141983140 983123983141983152983156983141983149983138983141983154 30 2012



57











58



bonds











59















on it at this time







35
















36








bull





37











THE GENERAL LEDGER



38






OAG Response






39



















40










bull





41










document)





42






Transition Basic)





43














44





allocation






45


$2897 million


Cause










46













47










AECOM





48


OAG Response











49










Accounting Fees





50






from bond proceeds









51
















52

















53




policy








54




Litigation Costs








OAG Response





55








12



12 983109983149983137983145983148 983142983151983154983149 983120983148983137983150983156983141 983117983151983154983137983150 983140983137983156983141983140 983105983157983143983157983155983156 983096 2013



56





service the debt

13

Conclusion





13 983127983107983106983105 983137983157983140983145983156983141983140 983142983145983150983137983150983139983145983137983148 983155983156983137983156983141983149983141983150983156 983140983137983156983141983140 983123983141983152983156983141983149983138983141983154 30 2012



57











58



bonds











59















on it at this time







36








bull





37











THE GENERAL LEDGER



38






OAG Response






39



















40










bull





41










document)





42






Transition Basic)





43














44





allocation






45


$2897 million


Cause










46













47










AECOM





48


OAG Response











49










Accounting Fees





50






from bond proceeds









51
















52

















53




policy








54




Litigation Costs








OAG Response





55








12



12 983109983149983137983145983148 983142983151983154983149 983120983148983137983150983156983141 983117983151983154983137983150 983140983137983156983141983140 983105983157983143983157983155983156 983096 2013



56





service the debt

13

Conclusion





13 983127983107983106983105 983137983157983140983145983156983141983140 983142983145983150983137983150983139983145983137983148 983155983156983137983156983141983149983141983150983156 983140983137983156983141983140 983123983141983152983156983141983149983138983141983154 30 2012



57











58



bonds











59















on it at this time







37











THE GENERAL LEDGER



38






OAG Response






39



















40










bull





41










document)





42






Transition Basic)





43














44





allocation






45


$2897 million


Cause










46













47










AECOM





48


OAG Response











49










Accounting Fees





50






from bond proceeds









51
















52

















53




policy








54




Litigation Costs








OAG Response





55








12



12 983109983149983137983145983148 983142983151983154983149 983120983148983137983150983156983141 983117983151983154983137983150 983140983137983156983141983140 983105983157983143983157983155983156 983096 2013



56





service the debt

13

Conclusion





13 983127983107983106983105 983137983157983140983145983156983141983140 983142983145983150983137983150983139983145983137983148 983155983156983137983156983141983149983141983150983156 983140983137983156983141983140 983123983141983152983156983141983149983138983141983154 30 2012



57











58



bonds











59















on it at this time







38






OAG Response






39



















40










bull





41










document)





42






Transition Basic)





43














44





allocation






45


$2897 million


Cause










46













47










AECOM





48


OAG Response











49










Accounting Fees





50






from bond proceeds









51
















52

















53




policy








54




Litigation Costs








OAG Response





55








12



12 983109983149983137983145983148 983142983151983154983149 983120983148983137983150983156983141 983117983151983154983137983150 983140983137983156983141983140 983105983157983143983157983155983156 983096 2013



56





service the debt

13

Conclusion





13 983127983107983106983105 983137983157983140983145983156983141983140 983142983145983150983137983150983139983145983137983148 983155983156983137983156983141983149983141983150983156 983140983137983156983141983140 983123983141983152983156983141983149983138983141983154 30 2012



57











58



bonds











59















on it at this time







39



















40










bull





41










document)





42






Transition Basic)





43














44





allocation






45


$2897 million


Cause










46













47










AECOM





48


OAG Response











49










Accounting Fees





50






from bond proceeds









51
















52

















53




policy








54




Litigation Costs








OAG Response





55








12



12 983109983149983137983145983148 983142983151983154983149 983120983148983137983150983156983141 983117983151983154983137983150 983140983137983156983141983140 983105983157983143983157983155983156 983096 2013



56





service the debt

13

Conclusion





13 983127983107983106983105 983137983157983140983145983156983141983140 983142983145983150983137983150983139983145983137983148 983155983156983137983156983141983149983141983150983156 983140983137983156983141983140 983123983141983152983156983141983149983138983141983154 30 2012



57











58



bonds











59















on it at this time







40










bull





41










document)





42






Transition Basic)





43














44





allocation






45


$2897 million


Cause










46













47










AECOM





48


OAG Response











49










Accounting Fees





50






from bond proceeds









51
















52

















53




policy








54




Litigation Costs








OAG Response





55








12



12 983109983149983137983145983148 983142983151983154983149 983120983148983137983150983156983141 983117983151983154983137983150 983140983137983156983141983140 983105983157983143983157983155983156 983096 2013



56





service the debt

13

Conclusion





13 983127983107983106983105 983137983157983140983145983156983141983140 983142983145983150983137983150983139983145983137983148 983155983156983137983156983141983149983141983150983156 983140983137983156983141983140 983123983141983152983156983141983149983138983141983154 30 2012



57











58



bonds











59















on it at this time







41










document)





42






Transition Basic)





43














44





allocation






45


$2897 million


Cause










46













47










AECOM





48


OAG Response











49










Accounting Fees





50






from bond proceeds









51
















52

















53




policy








54




Litigation Costs








OAG Response





55








12



12 983109983149983137983145983148 983142983151983154983149 983120983148983137983150983156983141 983117983151983154983137983150 983140983137983156983141983140 983105983157983143983157983155983156 983096 2013



56





service the debt

13

Conclusion





13 983127983107983106983105 983137983157983140983145983156983141983140 983142983145983150983137983150983139983145983137983148 983155983156983137983156983141983149983141983150983156 983140983137983156983141983140 983123983141983152983156983141983149983138983141983154 30 2012



57











58



bonds











59















on it at this time







42






Transition Basic)





43














44





allocation






45


$2897 million


Cause










46













47










AECOM





48


OAG Response











49










Accounting Fees





50






from bond proceeds









51
















52

















53




policy








54




Litigation Costs








OAG Response





55








12



12 983109983149983137983145983148 983142983151983154983149 983120983148983137983150983156983141 983117983151983154983137983150 983140983137983156983141983140 983105983157983143983157983155983156 983096 2013



56





service the debt

13

Conclusion





13 983127983107983106983105 983137983157983140983145983156983141983140 983142983145983150983137983150983139983145983137983148 983155983156983137983156983141983149983141983150983156 983140983137983156983141983140 983123983141983152983156983141983149983138983141983154 30 2012



57











58



bonds











59















on it at this time







43














44





allocation






45


$2897 million


Cause










46













47










AECOM





48


OAG Response











49










Accounting Fees





50






from bond proceeds









51
















52

















53




policy








54




Litigation Costs








OAG Response





55








12



12 983109983149983137983145983148 983142983151983154983149 983120983148983137983150983156983141 983117983151983154983137983150 983140983137983156983141983140 983105983157983143983157983155983156 983096 2013



56





service the debt

13

Conclusion





13 983127983107983106983105 983137983157983140983145983156983141983140 983142983145983150983137983150983139983145983137983148 983155983156983137983156983141983149983141983150983156 983140983137983156983141983140 983123983141983152983156983141983149983138983141983154 30 2012



57











58



bonds











59















on it at this time







44





allocation






45


$2897 million


Cause










46













47










AECOM





48


OAG Response











49










Accounting Fees





50






from bond proceeds









51
















52

















53




policy








54




Litigation Costs








OAG Response





55








12



12 983109983149983137983145983148 983142983151983154983149 983120983148983137983150983156983141 983117983151983154983137983150 983140983137983156983141983140 983105983157983143983157983155983156 983096 2013



56





service the debt

13

Conclusion





13 983127983107983106983105 983137983157983140983145983156983141983140 983142983145983150983137983150983139983145983137983148 983155983156983137983156983141983149983141983150983156 983140983137983156983141983140 983123983141983152983156983141983149983138983141983154 30 2012



57











58



bonds











59















on it at this time







45


$2897 million


Cause










46













47










AECOM





48


OAG Response











49










Accounting Fees





50






from bond proceeds









51
















52

















53




policy








54




Litigation Costs








OAG Response





55








12



12 983109983149983137983145983148 983142983151983154983149 983120983148983137983150983156983141 983117983151983154983137983150 983140983137983156983141983140 983105983157983143983157983155983156 983096 2013



56





service the debt

13

Conclusion





13 983127983107983106983105 983137983157983140983145983156983141983140 983142983145983150983137983150983139983145983137983148 983155983156983137983156983141983149983141983150983156 983140983137983156983141983140 983123983141983152983156983141983149983138983141983154 30 2012



57











58



bonds











59















on it at this time







46













47










AECOM





48


OAG Response











49










Accounting Fees





50






from bond proceeds









51
















52

















53




policy








54




Litigation Costs








OAG Response





55








12



12 983109983149983137983145983148 983142983151983154983149 983120983148983137983150983156983141 983117983151983154983137983150 983140983137983156983141983140 983105983157983143983157983155983156 983096 2013



56





service the debt

13

Conclusion





13 983127983107983106983105 983137983157983140983145983156983141983140 983142983145983150983137983150983139983145983137983148 983155983156983137983156983141983149983141983150983156 983140983137983156983141983140 983123983141983152983156983141983149983138983141983154 30 2012



57











58



bonds











59















on it at this time







47










AECOM





48


OAG Response











49










Accounting Fees





50






from bond proceeds









51
















52

















53




policy








54




Litigation Costs








OAG Response





55








12



12 983109983149983137983145983148 983142983151983154983149 983120983148983137983150983156983141 983117983151983154983137983150 983140983137983156983141983140 983105983157983143983157983155983156 983096 2013



56





service the debt

13

Conclusion





13 983127983107983106983105 983137983157983140983145983156983141983140 983142983145983150983137983150983139983145983137983148 983155983156983137983156983141983149983141983150983156 983140983137983156983141983140 983123983141983152983156983141983149983138983141983154 30 2012



57











58



bonds











59















on it at this time







48


OAG Response











49










Accounting Fees





50






from bond proceeds









51
















52

















53




policy








54




Litigation Costs








OAG Response





55








12



12 983109983149983137983145983148 983142983151983154983149 983120983148983137983150983156983141 983117983151983154983137983150 983140983137983156983141983140 983105983157983143983157983155983156 983096 2013



56





service the debt

13

Conclusion





13 983127983107983106983105 983137983157983140983145983156983141983140 983142983145983150983137983150983139983145983137983148 983155983156983137983156983141983149983141983150983156 983140983137983156983141983140 983123983141983152983156983141983149983138983141983154 30 2012



57











58



bonds











59















on it at this time







49










Accounting Fees





50






from bond proceeds









51
















52

















53




policy








54




Litigation Costs








OAG Response





55








12



12 983109983149983137983145983148 983142983151983154983149 983120983148983137983150983156983141 983117983151983154983137983150 983140983137983156983141983140 983105983157983143983157983155983156 983096 2013



56





service the debt

13

Conclusion





13 983127983107983106983105 983137983157983140983145983156983141983140 983142983145983150983137983150983139983145983137983148 983155983156983137983156983141983149983141983150983156 983140983137983156983141983140 983123983141983152983156983141983149983138983141983154 30 2012



57











58



bonds











59















on it at this time







50






from bond proceeds









51
















52

















53




policy








54




Litigation Costs








OAG Response





55








12



12 983109983149983137983145983148 983142983151983154983149 983120983148983137983150983156983141 983117983151983154983137983150 983140983137983156983141983140 983105983157983143983157983155983156 983096 2013



56





service the debt

13

Conclusion





13 983127983107983106983105 983137983157983140983145983156983141983140 983142983145983150983137983150983139983145983137983148 983155983156983137983156983141983149983141983150983156 983140983137983156983141983140 983123983141983152983156983141983149983138983141983154 30 2012



57











58



bonds











59















on it at this time







51
















52

















53




policy








54




Litigation Costs








OAG Response





55








12



12 983109983149983137983145983148 983142983151983154983149 983120983148983137983150983156983141 983117983151983154983137983150 983140983137983156983141983140 983105983157983143983157983155983156 983096 2013



56





service the debt

13

Conclusion





13 983127983107983106983105 983137983157983140983145983156983141983140 983142983145983150983137983150983139983145983137983148 983155983156983137983156983141983149983141983150983156 983140983137983156983141983140 983123983141983152983156983141983149983138983141983154 30 2012



57











58



bonds











59















on it at this time







52

















53




policy








54




Litigation Costs








OAG Response





55








12



12 983109983149983137983145983148 983142983151983154983149 983120983148983137983150983156983141 983117983151983154983137983150 983140983137983156983141983140 983105983157983143983157983155983156 983096 2013



56





service the debt

13

Conclusion





13 983127983107983106983105 983137983157983140983145983156983141983140 983142983145983150983137983150983139983145983137983148 983155983156983137983156983141983149983141983150983156 983140983137983156983141983140 983123983141983152983156983141983149983138983141983154 30 2012



57











58



bonds











59















on it at this time







53




policy








54




Litigation Costs








OAG Response





55








12



12 983109983149983137983145983148 983142983151983154983149 983120983148983137983150983156983141 983117983151983154983137983150 983140983137983156983141983140 983105983157983143983157983155983156 983096 2013



56





service the debt

13

Conclusion





13 983127983107983106983105 983137983157983140983145983156983141983140 983142983145983150983137983150983139983145983137983148 983155983156983137983156983141983149983141983150983156 983140983137983156983141983140 983123983141983152983156983141983149983138983141983154 30 2012



57











58



bonds











59















on it at this time







54




Litigation Costs








OAG Response





55








12



12 983109983149983137983145983148 983142983151983154983149 983120983148983137983150983156983141 983117983151983154983137983150 983140983137983156983141983140 983105983157983143983157983155983156 983096 2013



56





service the debt

13

Conclusion





13 983127983107983106983105 983137983157983140983145983156983141983140 983142983145983150983137983150983139983145983137983148 983155983156983137983156983141983149983141983150983156 983140983137983156983141983140 983123983141983152983156983141983149983138983141983154 30 2012



57











58



bonds











59















on it at this time







55








12



12 983109983149983137983145983148 983142983151983154983149 983120983148983137983150983156983141 983117983151983154983137983150 983140983137983156983141983140 983105983157983143983157983155983156 983096 2013



56





service the debt

13

Conclusion





13 983127983107983106983105 983137983157983140983145983156983141983140 983142983145983150983137983150983139983145983137983148 983155983156983137983156983141983149983141983150983156 983140983137983156983141983140 983123983141983152983156983141983149983138983141983154 30 2012



57











58



bonds











59















on it at this time







56





service the debt

13

Conclusion





13 983127983107983106983105 983137983157983140983145983156983141983140 983142983145983150983137983150983139983145983137983148 983155983156983137983156983141983149983141983150983156 983140983137983156983141983140 983123983141983152983156983141983149983138983141983154 30 2012



57











58



bonds











59















on it at this time







57











58



bonds











59















on it at this time







58



bonds











59















on it at this time







59















on it at this time









on it at this time





wayne county response to jail audit

Documents