Podział zamówienia

Zdecydowany nacisk na podział zamówień na części jest konsekwencją implementowania przepisów unijnych do polskiego systemu prawnego. Dzisiaj zamawiający w przypadku każdego zamówienia zastanawiają się w jaki sposób uzasadnić brak podziału. I nic w tym dziwnego, wszak w protokole postępowania o udzielenie zamówienia publicznego znajduje się miejsce do wpisania przyczyn braku podziału, a art. 96 ust. 1 pkt 11) Prawa zamówień publicznych z 29.01.2004 r. (Dz.U. z 2017 r. poz. 1579), dalej pzp, traktuje o obowiązku podania powodów niedokonania podziału zamówienia na części.

Czytając przepisy w ten sposób dochodzimy do zupełnie nieuzasadnionego wniosku, że każde zamówienie jest podzielne i w przypadku każdego zamówienia należy wyczerpująco i wiarygodnie podać przyczyny braku podziału. Weźmy przykład pierwszy z brzegu: zamówienie na usługę zaprojektowania budynku szkoły. Czy w takiej sytuacji zamawiający powinien podzielić to zamówienie na części według branż do zaprojektowania i w wyniku tak przeprowadzonego postępowania podpisać umowy np. z 6-cioma wykonawcami, z których każdy zaprojektuje jakąś część zamówienia ? Kto będzie w takiej sytuacji odpowiadał za integralność dokumentacji ? Czy zamawiający powinien, i czy w ogóle ma takie narzędzia by przymusić wykonawców do współpracy między sobą ?

O potrzebie dzielenia zamówienia na części w celu dostosowania ich do potrzeb małych i średnich przedsiębiorstw, dalej MSP traktuje motyw 78 Dyrektywy Parlamentu Europejskiego i Rady 2014/24/UE z 26.02.2014 r. w sprawie zamówień publicznych, uchylającą dyrektywę 2004/18/WE, dalej Dyrektywa.  Część motywu 78 Dyrektywy brzmi: „…aby zwiększyć konkurencję, instytucje zamawiające należy w szczególności zachęcać do dzielenia dużych zamówień na części. Podziału takiego można dokonać na zasadzie ilościowej, tak by wielkość poszczególnych zamówień lepiej odpowiadała możliwościom MSP, lub na zasadzie jakościowej, z uwzględnieniem różnych zaangażowanych branż i specjalizacji, tak by w większym stopniu dostosować treść poszczególnych zamówień do wyspecjalizowanych sektorów MSP, lub według różnych kolejnych etapów projektu”. Na podstawie tego zapisu powstał przepis art. 96 ust. 1 pkt 11) pzp. Przepis art. 96 ust. 1 pkt 11) pzp nie pozostawia zamawiającemu swobody, brzmi on zdecydowanie „W trakcie prowadzenia postępowania o udzielenie zamówienia publicznego zamawiający sporządza protokół, zawierający co najmniej: 11) powody niedokonania podziału zamówienia na części”. Niezależnie więc od tego, czy przedmiot zamówienia jest, czy nie jest podzielny zamawiający muszą wypełnić tą część w protokole. I co najważniejsze, zrobić to powinni jeszcze przed wszczęciem postępowania. Wskazuje na to zarówno miejsce w protokole, odnoszące się do ogólnych informacji o postępowaniu, jak i to, że kształt postępowania powinien być ustalony przez zamawiającego przed jego wszczęciem. Wówczas bowiem zamawiający wie jak ma prowadzić postępowanie – czy jako częściowe, czy nie. W praktyce część zamawiających ignoruje wstęp do przepisu brzmiący „w trakcie prowadzenia postępowania…” i robi protokół po zakończeniu postępowania, albo w momencie, gdy ktoś się go domaga. Wtedy, bez wcześniejszego przemyślenia kwestii podziału rzeźbią przyczyny nie podzielenia, niezależnie od tego, czy zamówienie podzielić się da, czy też nie. To zła praktyka i warto ją zmienić 🙂

Podział różnych rodzajowo zamówień

W praktyce możemy mieć do czynienia z zamówieniami o których traktują przepisy art. 5b i 5f pzp. Chodzi o konieczność podziału zamówień, do stosowania których mają zastosowanie różne przepisy ustawy pzp – roboty budowlane, usługi i dostawy. Przykładem, może być zamówienie na wybudowanie obiektu i wyposażenie budynku w meble. Mamy tu roboty budowlane i dostawę i o ile postępowanie jednego rodzaju nie jest częścią drugiego i z przyczyn technologicznych, technicznych, organizacyjnych, ekonomicznych, celowościowych, etc. mogą one zostać rozdzielone, należy to uczynić i przeprowadzić dwa postępowania. Przykładem, gdzie podział w takim przypadku nie jest jednak możliwy jest konieczność ujęcia przedmiotu dostawy, wykonywanego na wymiar, posiadającego określone parametry, w procesie technologicznym podczas wykonywania roboty budowlanej. Co do zasady jednak, oczywistość dzielenia zamówień różnych rodzajowo jest przesądzona.

Podział jednolitego zamówienia na części

Duże kłopoty powoduje jednak interpretowanie przepisów o podziale zamówienia jednorodnego. Co nas ratuje przed szaleństwem dzielenia wszystkiego i zawsze ? No właśnie przepisy tejże samej ustawy pzp. Nie bez powodu często nie stosujemy przepisów wprost, ale je interpretujemy. Mając na uwadze zasadę racjonalnego ustawodawcy, należy skorzystać z przepisu art. 36aa ust. 1 pzp, który traktuje o tym, że zamawiający ma uprawnienie do podziału zamówienia. Żaden przepis ustawy pzp wprost nie nakazuje podziału. Zamieszanie wprowadza jedynie art. 96 ust. 1 pkt 11) pzp, jednakże przepisu tego nie należy interpretować w oderwaniu od właściwego rozumienia intencji motywu 78 Dyrektywy.

Jak więc jest ?

Niektóre zamówienia nie będą w ogóle podlegały podzieleniu, bo są niepodzielne. Podział niektórych zaś nie będzie celowy ani nawet bezpieczny. Podzielenie na części (według branż) zamówienia na roboty budowlane, zagrażałoby prawidłowości ukończenia procesu budowlanego (lub w ogóle go uniemożliwiało), a podział na części (branże) usług projektowych dla projektu budowlanego zagrażałoby integralności takiej dokumentacji (Zamawiający nie dysponuje bowiem narzędziami prawnymi by zmusić różnych Wykonawców by na etapie projektowania poszczególnych branż współpracowali ze sobą). Zamawiający w każdym przypadku powinien najpierw ocenić więc, czy podział zamówienia jest możliwy, czy podział nie spowoduje dla niego poważnych, negatywnych konsekwencji (w postaci choćby np. utraty gwarancji z powodu naruszenia przez jednego wykonawcę przedmiotu zamówienia wykonanego przez  innego), czy podział zamówienia nie spowoduje nadmiernych kosztów po stronie zamawiającego (ekonomicznie dla zamawiającego byłoby, aby zamówienie wykonał jeden wykonawca). Brak podziału musi być związany z przyczyną istotną, zasadniczą, nie może zaś być spowodowany jedynie brakiem woli zamawiającego, czy jego wygodą. Podkreśla to Urząd Zamówień Publicznych w swojej opinii: „Należy zauważyć, że ustawodawca europejski za okoliczność uzasadniającą rezygnację z podziału na części uznał jedynie nadmierne trudności czy koszty oraz brak koordynacji, skutkujący poważną groźbą nieprawidłowej realizacji zamówienia. A contrario uznać należy, iż obawy związane z ewentualnymi niewielkimi trudnościami czy kosztami bądź nieznacznymi problemami z koordynowaniem działań wykonawców, a tym bardziej wygoda zamawiającego, nie powinny stanowić dostatecznej podstawy do zaniechania podziału zamówienia na części. Jednakże zastrzec należy, że ocena ta powinna być dokonywana każdorazowo z uwzględnieniem wszystkich okoliczności danego przypadku” (ww.uzp.gov.pl, Pytania i odpowiedzi dotyczące przepisów nowelizacji ustawy Pzp. Opinia nt. Podział zamówienia na części).

Mając na uwadze regułę reductio ad absurdum (sprowadzenie do absurdu; zaniechanie rozumowania w przypadku uzyskania nonsensownych wniosków) należy odrzucić taką interpretację motywu 78 Dyrektywy i art. 96 ust. 1 pkt 11) p.z.p., która prowadzi do absurdalnych konkluzji, że każde zamówienie jest podzielne i w przypadku każdego należy szczegółowo wyjaśniać brak podziału, a brak podziału skutkować będzie konsekwencjami dla Zamawiającego, w postaci choćby korekty finansowej. W niektórych sytuacjach powodem niedokonania podziału zamówienia na części będzie po prostu informacja o tym, że zamówienie jest niepodzielne.

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