On April 29, 2025, The Imperial Company, a long-time roofing and restoration contractor based out of Cromwell that specializes in large commercial and public projects, protested a $4.1 million competitive bid award to replace the roof at the Lille B. Haynes Elementary School in East Lyme that they had won because they claimed the bidding process was not in the best interest of the taxpayers.

It was an unusual move for a contractor, who could have easily accepted the money – a combination of state and local funds – completed the roof replacement and moved on to other projects. Instead, Imperial is now in court, claiming the bidding process for East Lyme’s elementary school, like many other public school roofing projects across the state, is designed so that one manufacturing company gets all the business, costing taxpayers millions through higher prices.

“We are requesting a re-bid to allow the Town to receive multiple prices of equal product,” Imperial President Bruce Raulukaitis wrote in the May 14 letter to the East Lyme Board of Education. “The current enclosed specifications produced by the architect list ONLY (1) approved manufacturer. We are requesting this project goes out to re-bid with (3) industry standard equals. Imperial contacted the Architect Andrew Clair to inform him he only had (1) approved manufacturer, he informed us he wasn’t required to put more than one in.”

Unlike many bidding issues, this didn’t have to do with the contractor awarded the job; Imperial had come in as the lowest qualified bidder and was awarded the work in a fair and open process. They easily could have performed the work and walked away. 

Rather, this bidding issue had to do with which manufacturer would supply the materials to replace the roof, and allegations that school roofing project architects are steering business to only one manufacturing company – The Garland Company,  an Ohio-based commercial roofing system manufacturer that has been the subject of similar allegations in other states like California in 2010, and Minnesota in 2015.

According to a 2009 letter from the Minnesota Office of the State Auditor, a roofing project for the Stillwater School District raised red flags for several reasons, one being “the likelihood of proprietary specifications restricting the pool of contractors,” and found that “specifications were drafted to favor Garland products and exclude equivalent products of other manufacturers.”

The auditor found Garland had a hand in not only drafting the requirements for the project, but also ensuring any contractor selected would be required to use their products. Garland representatives even helped select the winning bidder.

“The Garland Company was involved in both sides of the School District contract,” wrote Minnesota Deputy State Auditor Celeste Grant. “The specifications used by the District for this roofing project were drafted by The Garland Company. Five pages of specifications were a Manufacturer’s Checklist that bidders were required to submit with their bids. Only contractors using Garland products submitted bids, and each bid included a Roofing Manufacturer Check List completed by a Garland representative. After the bids had been submitted, The Garland Company helped the District evaluate the bids.”

In both California and Minnesota, it really came down to the school district relying on past contractors and “taking the path of least resistance.”

“State officials don’t believe kickbacks or other misconduct are part of the problem,” Jill Tucker wrote for the Chronicle in 2010. “The noncompetitive bidding is more a result of taking the path of least resistance. Sales representatives with whom districts have a prior business relationship often volunteer to write bid specifications, thus saving time and money for district officials who would otherwise have to hire an architect to do it.”

This is the basis for a growing concern among some contractors for municipal projects in Connecticut: that project architects are either purposely writing project specifications into their plans based on proprietary Garland products or are not supplying the required industry standard equals required by state bidding rules so that the best product prices can be obtained by the contractor, thus saving the municipality and taxpayers money.

It’s not only Garland; other roofing companies have been implicated in bid-rigging schemes in other states, as well. 

In 2013, another roofing manufacturer, Tremco, and its parent company RPM International Inc., reached a $60.9 million settlement with the Department of Justice to resolve allegations that it had undermined “the integrity of the procurement process,” and created “an unfair advantage against companies that are playing by the rules.”

Essentially, the DOJ alleged – after Tremco’s former vice president blew the whistle on them – that Tremco knowingly withheld information about “changes in discounts to comparable commercial customers” and didn’t offer those discounts to the government.

“As a result, the government allegedly paid more than it should have for Tremco’s services and products,” the DOJ press release states. “In addition, Tremco allegedly improperly marketed generic products as a superior line of the same product and used a defective adhesive formula in its roofing systems.”

Big roofing projects mean big money, and Garland has been a roofing system manufacturer for millions of dollars’ worth of municipal roofing projects across the state involving both state and municipal taxpayer money, including projects in Danbury, Gales Ferry, Haddam, Westbrook, Ledyard, East Lyme and Ansonia. Even in cases where two alternative “equal” manufacturers were offered, the other manufacturers either didn’t meet the bid specifications or were located on the West Coast of the United States and didn’t do work in the Northeast.

And while Imperial may have protested their own contract award due to the lack of industry equals, other contractors are beginning to notice and cry foul, according to some recent court cases, which claim the cost for Garland products is driving up the overall cost of the projects and costing state and municipal taxpayers millions.

“Imperial is requesting this project goes out to re-bid to provide the Town and all parties involved fair bidding in the best interest of the taxpayers,” Raulukaitis wrote.

“A CLASSIC CASE OF BID RIGGING”

Typically, when a municipality undertakes a school roofing project, local officials will call in an architect who will draw up the specifications. If they are seeking state funding, those specifications have to be approved by the Department of Administrative Services (DAS) through the Office of School Construction and are reviewed by State Architect David Barkin. The town will then put out a request for proposals containing those specifications, and potential bidders will conduct an on-site walkthrough where they can inspect the property, ask questions, and draw up their bid proposals based on the architect’s specifications.  

In order to receive state school construction grants, the town must abide by all state competitive bidding rules to ensure taxpayers are getting the most out of their money; otherwise, they risk losing their funding. According to DAS’s Consultants Procedure Manual, if the architect names a particular manufacturer in the specifications, he or she must provide two other manufacturers who can provide similar products that can be used on the project – known as “equals.” 

If an architect only lists specifications and doesn’t name a manufacturer, those specifications must be general enough so as not to favor one company. This is all to prevent forms of bid rigging and favoritism.

“The Division of Construction Services, through the Consultants Procedures Manual, requires the design team to either specify a minimum of three reasonable equals, or to use a performance specification that does not include the manufacturer’s name,” said the DAS in its 2017 Bulletin regarding Procurement of Contractors for Purposes of School Construction. “An improper specification may result in the costs for that portion of the work being declared ineligible for reimbursement.” 

There are several different ways a company or companies can engage in bid-rigging when it comes to bidding on public projects; one of them is through creating a de facto sole-source procurement by limiting the ability to substitute other products through “restrictive specifications,” according to a 2011 report on price fixing and bid rigging by the Connecticut Attorney General’s Office. 

“The probability of collusion increases if other products cannot be easily substituted for the product in question or if there are restrictive specifications for the product being procured,” the antitrust primer says. 

Under state statute, sole source procurement is only allowable when a product is only available from a single supplier and is subject to approval by the commissioner of the Department of Administrative Services: “A requirement for a particular proprietary item does not justify a sole source procurement if there is more than one potential bidder or offerer for that item.”

However, according to several court cases involving major municipal school roofing projects, either Garland has been specifically named as the manufacturer to be used with no equals offered, or the architect has offered what are known as “dead equals.” Dead equals are companies that offer products that fall within the specified guidelines but don’t do business in the area, or offer similar products that, in reality, don’t meet the exact specifications. 

The result, according to court cases involving projects in Danbury, Ansonia, East Lyme and Ledyard, is a de facto sole source procurement, essentially circumventing the state’s bidding rules.

The Imperial Company filed a court complaint against the City of Ansonia in October of 2025, over the city’s roof replacement project at Ansonia High School in which the bid documents list Garland as the “acceptable manufacturer” for metal roof panels and the roofing membrane, and then went on to list further specifications, including a 30-year warranty and tensile strength, that allegedly apply directly to Garland products. 

Although the bid document indicates substitutions are allowed, those substitutions take time for contractors to find and must conform to specifications that generally only apply to Garland products and which are unnecessary to the project, according to court documents.

“Identifying a substitute product that meets a performance specification takes time. It involves a complicated analysis performed by the product manufacturer’s engineering team, which is required to ensure, among other things, that the manufacturer can issue the required warranty,” wrote Jay Lawlor, attorney for The Imperial Company wrote in the court complaint. 

“In addition, the Bid Documents unnecessarily include technical specifications (e.g. tensile strength), which only a Garland roof system can meet,” Lawlor continued. “This is what is known as a ‘locked’ specification in the construction industry. Although the owner provides bidders with a purported mechanism to submit substitutes, it is illusory in that there are no substitutes that meet the specifications. There is nothing unusual about the Project that would require the specified tensile strength (other than ostensibly that it is a feature unique to the Garland product).”

A similar court complaint was filed by Greenwood Industries, Inc., against the City of Danbury in June of 2025, showing the bid documents to replace the roof of the Ellsworth Avenue School listed Garland as the “basis of design,” and then offered two dead equals – AEP SPAN and Centria – for prospective bidders and did not allow for substitutions. AEP SPAN is located on the West Coast and doesn’t perform work in Connecticut, while Centria didn’t offer products that met the Garland specifications.

According to a May 15, 2025, addendum for the project, the City of Danbury addressed bidder questions, reaffirming that AEP SPAN and Centria “are equal,” and claiming architect Dean Petrucelli of Silver Petrucelli & Associates (SPA) “spoke to representatives of both companies and confirmed that their panel can be shipped to Connecticut.” The addendum specifically indicated the architect had spoken with Jeff Madeiros of AEP SPAN.

However, according to emails obtained by Inside Investigator, Madeiros wrote in an email to Greenwood Industries that, in no uncertain terms, their inclusion in the bid documents was a matter of bid rigging, that his company was bowing out of the project because they weren’t interested in having to ship their products and people to Connecticut, and that the Garland representative “conveniently” left two local manufacturers off the list.

“This is a school funded by taxpayer dollars. Taxpayers/we all want our tax dollars spent to the most efficient and best possible means,” Madeiros wrote in a May 16, 2025, email, in which he also pointed out that Centria products didn’t meet the project specifications. “It is glaringly obvious that the Garland rep purposefully listed other manufacturers they knew could not meet the spec or were across the country in order to limit a PUBLIC BID to their product. Additionally, the rep purposefully left off competitive local manufacturers with the exact same panel such as Taylor and Metal Sales and stated no substitutions to limit a public bid to one product.”

The extra costs from limiting contractors to a single manufacturer can be high: Madeiros indicates that even with the added costs of shipping their product across the country and putting inspectors up in hotels, they would still be one-third to half the cost of Garland. 

“This project is essentially a publicly bid locked project with the illusion that it is an open bid,” Madeiros wrote about the Danbury school project. “This is a classic case of bid rigging, and I am sure the taxpayers and District, if they knew what was going on, would be incredibly upset. Alternate local manufacturers will come in at 1/3 the price of the Garland panel and can meet the exact same performance and warranty requirements.”

Even after contractors pointed out that AEP SPAN and Centria were not equals, SPA continued to double down, according to project addendums contained in court documents.

“As it stands now in specifications, Garland is the only manufacturer that is approved with the listed specification and the other two manufacturers listed do not meet the requirements listed in the specification,” the contractors wrote. “State funded projects require 3 equal manufacturers for fair and competitive bidding purposes.”

“We disagree that Garland is the only Manufacturer to meet the specification,” SPA wrote. “This project was reviewed and approved by the State of Connecticut and we believe we have met/fulfilled all of their bidding/specifying requirements.”

Four days later, however, SPA offered two more manufacturers who did work in the area and supposedly offered equal products – Tremco and Holcim Elevate — and Greenwood came in as the lowest responsible bidder on the project using a Holcim product.

However, according to the court complaint, the city assistant engineer told Greenwood that using the Holcim product would “be a deviation” from what was approved and instead selected another company whose bid included Garland products. That bid was more than $800,000 more than Greenwood’s bid.

“Danbury has improperly engaged in a de facto sole-source procurement in violation of applicable law and without complying with applicable legal requirements by identifying at least three acceptable manufacturers in its Specifications that it now contends do not meet the requirements of its Specifications,” wrote Jared Cohane, attorney for Greenwood. “Danbury is clearly attempting to reject Greenwood’s bid on an improper basis under the pretextual guise of responsiveness, and in so doing, is violating Connecticut law putting bidders on unequal footing and in violation of the requirement for at least three manufacturers being listed (barring obtaining authorization for sole source procurement, which Danbury did not do).”

Ultimately, the whole thing was scrapped, the lawsuit dropped, and the city started over, according to Danbury Director of Public Works and City Engineer Antonio Iadarola, who was appointed to the School Building Projects Advisory Council by Gov. Ned Lamont in 2021.

“Due to the urgent need to remediate the leaking roof, the architect redesigned the roof in order to utilize readily-available roofing materials that were in stock on a shelf,” Iadarola wrote in response to questions from Inside Investigator. “The City categorically denies there was any bid rigging, any attempt to sole-source in favor of one roofing manufacturer, or any other improper conduct in this project.”

Iadarola says that Garland has been used on other Danbury projects and “is a popular manufacturer that is used for multiple building needs throughout the State of Connecticut by many municipalities and private companies.” 

“Not one Garland product was used in the completion of this project, which clearly demonstrates that these allegations of bid rigging, along with the damaging allegations made or inferred in your inquiries, are simply unfounded,” Iadarola wrote, adding the school roof was finished over the summer in time for kids to return to class. “We take our procurement process and professional reputations as public officials very seriously and safeguard them at all costs.”

In another lawsuit brought by Imperial against the Town of Ledyard, Garland products were once again specified in the bid documents for a school roof replacement that involved state funds and the same two dead equals from the Danbury project were listed by the same architect. Imperial claims in court documents that requiring Garland products increased the project cost by over $500,000.

“The specification of Garland roofing systems violates competitive bid law because its roofing systems are not necessary for the run-of-the-mill school roofing project at issue, and moreover, represent the most expensive roofing systems of the market – here costing the Town over half a million dollars more than other equally suitable products,” the court complaint says.

On December 9, 2025, Imperial filed a lawsuit against East Lyme over its bidding process for replacing the roof at the Lille B. Haynes Elementary School. Although Imperial had initially won the bid, the company and its owner had protested over the lack of equals and asked for a re-bid, which occurred in November. 

However, according to the court complaint, Garland was again the specified manufacturer, and when this was pointed out, the town issued an addendum, “which replaced the single-source specification with a performance-based specification, which does not identify an individual manufacturer by name but is predicated on the specifications for the Garland product.” 

The court complaint goes on to state that “upon information and belief,” a Garland representative “participated in key aspects of the bid process early on.”

“The Town is effectively and unnecessarily steering all prospective bidders to Garland at great additional expense to the general public,” the court complaint states. “The Town has no lawful right to deny Plaintiff an opportunity to bid on the Project by ‘locking’ the specification in favor of Garland.”

“BASIS OF DESIGN”

According to off-the-record conversations with architects who have worked on similar school roofing projects in Connecticut, part of the issue is that these large roofs are sold as proprietary systems by manufacturers so that all the parts work together. Those systems must be installed by a contractor licensed by the manufacturer to install that roof system and inspected by manufacturer representatives to ensure a 20- or 30-year warranty.

So, often an architect will use a particular product, like Garland, as the “basis of design,” because that product has all the elements desired by the municipality, including a warranty. Although technically a contractor can substitute different products through a formal process during the bidding phase, it would void the manufacturer’s warranty and shift the warranty responsibility over to the contractor instead.

“Referencing a manufacturer as the ‘basis of design’ is a common practice that design professionals use throughout the industry for multiple project materials and product needs,” Iadarola said. “Municipalities commonly use Basis of Design for school construction projects, which are processed and approved to go to bid by the Department of Administrative Services.”

State bidding rules do allow for specific manufacturers to be used as the basis of design, according to DAS’s Consultants Procedure Manual, provided that the architect provides two other equals.

“When naming multiple manufacturers within the Project Manual provide at least three manufacturers,” the DAS consultants manual states. “If a product is identified as the ‘basis of design’ then the other two products must be technically similar from a performance, size, aesthetic (if relevant) and quality perspective.”

Part of the issue, which can affect municipalities looking to get the best price for their roofing project, is that since a contractor must be licensed by the manufacturer to install their roofing system, it eliminates any companies who may not be licensed with that particular manufacturer; thus, providing equals allows for a larger pool of bidders and potentially a lower cost for materials. 

This is part of Imperial’s lawsuit over the Lille B. Haynes Elementary School Project.

Following several disputes with Garland over these exact issues and threats by Garland to revoke his installer license, Imperial’s owner, Bruce Raulukaitis, reportedly drove from Connecticut to Ohio to hand his installer’s license back to Garland’s president in protest. 

However, it also puts Imperial out of the running for municipal roofing jobs in which Garland is the named manufacturer and no equals are provided. It also means the municipality potentially misses out on a bid from a long-time roof installer who may be able to complete the job for less money by using products from other manufacturers.

As the Minnesota auditor’s office noted, specifying a specific proprietary system as the basis of design – while technically allowed – creates “the likelihood of proprietary specifications restricting the pool of contractors.” 

As indicated before, Imperial protested the bid they won because the architect only listed one manufacturer and, according to the protest letter, the architect said “he wasn’t required to put more than one in.” Interestingly, Imperial offered up the two additional manufacturers SPA added to the Danbury project – Tremco and Holcim – as manufacturers “who are present in the state and able to meet specifications.”

In some cases, however, providing those equals – dead or otherwise – just isn’t happening. 

In Ansonia, for example, Hibbard & Rosa Architects LLC listed only Garland as the “acceptable manufacturer,” and then listed, “or equal.” Similarly, the partial school roof replacement at John Trumbull Primary School in Watertown, also designed by Hibbard & Rosa, also lists only Garland as the “acceptable manufacturer” and includes “or approved equal.” 

According to one architect, listing two other equals alongside the “basis of design” in the bid specifications gives the impression that any product from that manufacturer is acceptable for the project, rather than having to meet the rigorous specifications under the basis of design. It’s like thinking any old window will do when, in fact, you need bulletproof glass. So, architects will sometimes put “or approved equal,” into the specifications.

According to DAS’s Consultants Procedure Manual, however, the architect is responsible for providing three equals and is not permitted to list “or approved equal” in the specifications.

“The use of ‘Or Approved Equal’ is not permitted within the technical specifications or on drawings,” the manual states. “It is the responsibility of the Consultant to identify at least three equal manufacturers, develop a performance specification or follow the request for single source process outlined above.”

Technically, a roofing contractor could find an equal on their own and go through the process of getting approved to use that product – even though providing the equals is the architect’s responsibility – but that process takes time they often don’t have. If the specifications name a proprietary product or system that must all work together, finding another roofing system that meets every specification of one particular manufacturer can be difficult.

For the Trumbull Primary School project in Watertown, DAS posted the request for proposals on May 11, 2024; held the walk through on May 14; had a deadline for substitutions of May 15, and the bid was due on May 24, according to an email from Imperial to Chief State Architect David Barkin and several other state officials at DAS.

“Substitutions closed less than 1 day from walkthrough 4 days from DAS posting, this timeline is equivalent to a Locked Specification,” Imperial wrote.

In an example of a proper bid specification offered up in court documents is the roof replacement performed by Imperial for the Capital Region Education Council’s University of Hartford Magnet School. The bid specifications listed three acceptable manufacturers – Garland, Tremco, and Ecology Roof Systems – and Imperial claims CREC saved $400,000 by allowing them to choose between the equals.

Failure to ensure state bidding rules are being followed can risk a municipality’s state funding, provided anyone is paying attention or enforcing the letter of the law. But, despite multiple court cases, emails, phone calls and warnings to officials at DAS and the Attorney General’s Office, no one at the state level appears concerned.

UNSUBSTANTIATED

Officials within DAS who oversee issues related to school construction are aware of these claims and allegations. As indicated before, Iadarola sits on the School Building Projects Advisory Council along with DAS Commissioner Michelle Gilman, and, according to emails and text messages obtained by Inside Investigator, Imperial has been reaching out to state officials, making them aware of the issue since at least 2024.

Emails to DAS, the Chief State’s Architect, and the Attorney General’s Office warning them of these practices and asserting it is driving up the costs for both municipalities and the state have either been met with silence or told it is the municipalities’ problem.

In April of 2024, one of the owners at Imperial reached out to Chief State Architect David Barkin via text message telling him that school roofing projects “are coming out with proprietary specifications,” and asking how this can be addressed.

Barkin, who has been listed as a durational project manager for DAS since 2023 and received $186,330 in 2025, responded that “procurement issues for municipal school construction is the responsibility of the municipality. We only get involved when a district seeks sole source through us. Your remedy resides with the municipality or district who is bidding the project.”

“The state is allowing the municipalities to use state funded money without following general state statutes,” the Imperial owner responded. “I was told by DAS you are the director of plan review to prevent these type of things.”

In July of 2024, Imperial again reached out via email to Barkin, DAS Grants Administration, Deputy Commissioner of Real Estate and Construction Services Darren Hobbs and cc’d the Attorney General’s Office with a “Confidential For Fear of Manufacturer Retribution” email.

Imperial raised concerns that the Garland warranty for the John Trumbull Elementary School project in Watertown did not actually meet the “basis of design” specifications, and neither the owner representative nor the architect would allow for an equal which, they claim, could have saved $200,000.

The email, which was sent from a general Imperial account, claimed that when Imperial raised these concerns to town officials, “Garland President Matt McDarment in corporate Ohio called me personally and threatened my installer license.” This alleged threat purportedly led to Raulataikis driving to Ohio and giving it back.

Imperial asked that the email be forwarded to the DAS director, the director of the Office of School Construction, and the entire School Building Advisory Council, although it is unknown at this time whether the recipient did so.

Another email in February of 2025 to Barkin had to do with a school roof replacement in Ashford and brought forward the same concerns about a lack of equals from the same architect.

“What policy does your department or DAS have in place to prevent this or report it?” Imperial wrote. “Towns and the State are spending a substantial amount in material verse and equal (They aren’t even aware they are allowed options). Towns and the State are spending a substantial amount in Freight with no real rate of return.”

Barkin again responded that it was the municipality’s problem. 

Inside Investigator reached out to Barkin regarding these issues and received comment back from DAS Spokesman Leigh Appleby, again stating that “school construction is the responsibility of local districts, who must ensure compliance with all state and local rules, laws, and regulations.”

“DAS clearly communicates the importance of following state procedures throughout the grant administration and plan review process and then verifies compliance with [state statute] during an audit,” Appleby wrote. “Each school building project grant is audited by DAS before the final payment is remitted. During the audit, districts must demonstrate compliance with proper bidding procedure. If a district fails to do so, it will be flagged in the audit report, making the district ineligible for certain reimbursements.”

It isn’t just DAS officials who don’t see a problem: the Department of Consumer Protection (DCP) purportedly investigated this issue in response to a complaint filed by Imperial based on the Ellsworth School project in Danbury. 

DCP investigator Kieth Lombardi wrote that Philip Cerrone, chair of the state’s Architectural Licensing Board, “did a review and found no bid rigging,” and the case was closed, according to a December 23, 2025, email. Cerrone did not respond to a request for comment.

None of the architects mentioned in this article responded to emails or phone calls requesting comment, but Dean Petrucelli of Silver & Petrucelli indicated in an emailed response to DCP in September 2025 that he believed the claims were unfair, inaccurate, and false.

“I hope your agency further investigates my response and the response of other architects as I understand that this particular company is unfairly targeting numerous Architects in CT regarding the same inaccurate claim/complaint,” Petrucelli wrote. “We are hopeful that your agency will look into this false claim by Imperial Roofing.”

In a letter Petrucelli sent to DCP, he noted that he supplied five manufacturers — the original three, plus the two when the contractors complained — that all his specification and plans were approved by DAS and city committees; that Imperial was the highest bidder and never stood a chance of being selected, so their complaint is “mute;” and finally the project was cancelled.

Petrucelli says Imperial is relying on an outdated DAS form and cites a new one that lists its revision date as June 27, 2025. The form says state statute “does not prohibit bid specification from identifying a specific manufacturer or requiring experience with the installation of specific name brand equipment,” but adds that in order for a town to be eligible for reimbursement it must comply with statutory requirements that a competitive bidding process take place.

“SPA takes exception to this claim that the specification was improperly written and we went well above the SCG requirements, specifying not 3, but 5 different manufacturers for the Contractors to choose from,” Petrucelli wrote. “It is preposterous to claim that SPA is favoring one manufacturer when we specified 5 to choose from.”

“We have been in touch with ICR regarding this matter but there is no reason or opportunity to resolve this matter amicably,” Petrucelli wrote, adding he feels his firm is being targeted. “Lastly the SCG process has many layers of oversight, as mentioned above, as there were 9 separate entities that reviewed the final plans & specification for conformance. Clearly, if any one of these entities felt that our specifications were incorrectly written or favoring one manufacturer, we would not have achieved final sign off and approval to bid.”

Tom Hibbard of Hibbard & Rosa Architects simply wrote that the “supporting documents are not for a project our firm had any involvement in,” and that the matter should be dismissed.

Lastly, in November of 2025, Imperial’s attorney Jay Lawlor emailed Deputy Associate Attorney General Nicole Demers, who is in charge of the Antitrust Section of the Connecticut Attorney General’s Office, and whose “overall responsibility is to maintain open and competitive markets in Connecticut.” Lawlor wrote to her of “a problematic and concerning trend in the form of sole source specifications favoring one particular roofing system manufacturer to the unnecessary exclusion of others.”

“The bottom line is that the specifications for these public projects represent de facto sole source specifications of a product, which is not superior to viable alternate products on the market in any meaningful or material way, but is hundreds of thousands of dollars more than other competitor products on the market. My client has attempted to vindicate its right to use other manufacturers on a one-off basis,” Lawlor wrote. 

“It is unfair, however, to place the responsibility for protecting the public interest on one contractor,” he continued. “This is quintessential bid rigging. It has been the subject of exposes in other states. It is costing state taxpayers millions of dollars. It deserves the attention of your office.”

“I DON’T LIKE THE WAY THEY DO BUSINESS”

At the June 6, 2025, meeting of the Watertown School Capital Project Committee, things didn’t appear to be going according to plan. The $4.8 million roofing project had $542,000 in change order applications; Imperial was the roofing contractor, and owner Raulukaitis and architect Thomas Hibbard of Hibbard & Associates were clashing over those change orders. The project appeared to be hitting some delays.

Both Imperial and Greenwood Industries were awarded contracting bids for the project, which specified Garland products, and Raulukaitis addressed the committee, saying that the details of the roofing project had all been changed. “That is a lot of change orders, a lot of work, and a lot of time,” Raulukaitis said, according to meeting minutes.

As indicated in Imperial’s 2024 email to Barkin, Garland was the only named manufacturer and there hadn’t been time to select another equal. It was the job that would end Imperial’s relationship with Garland.

“Garland materials are the most expensive you can buy on a roof, it cost a lot of money to do this job. There was a lot of things that were missed, copings were missed, side wall flashings that are missed and expansion joints that were missed,” Raulukaitis said to the committee. “With the way the relation is between Imperial and Garland, which is our last Garland job, I am afraid to do something (inaudible), I am not blaming anyone here.”

Although both Imperial and Greenwood claimed in court documents – and AEP SPAN in an email – that Garland products were more expensive, Danbury Director of Public Works Antonio Iadarola disagrees with making such a blanket statement; it depends on the circumstances and what the municipality wants.

“I disagree with claiming any manufacturer is vastly more expensive than others, as every project is unique and can have different requirements that may put manufacturers in a better position to provide pricing, warranties, and technical solutions than others,” Iadarola said. “Garland has been used on other City of Danbury projects as they are on a National Cooperative Contract available to public agencies for roofing and related services. In general, municipalities during the bid processes hope to secure reputable manufacturers in the industry, providing well-performing products and warranty coverages that are beneficial to building owners.”

However, despite the complicated specifications, numerous committee approvals, and various pots of taxpayer money that goes into a major municipal project worth millions, the base allegation leveled in these court cases is simple: some architects are either not supplying legitimate equals or are using “or approved equal,” in their specifications. That goes against the DAS Consultants’ Procedure Manual, and yet those plans are approved by DAS, which then awards state grant funding to those projects.

While the State Contracting Standards Board can investigate state bidding and procurement, their authority does not extend to the municipal level. There’s no quick place for Imperial or any other contractor to take their complaints other than to DAS, which has, thus far, placed responsibility back onto the municipalities, so towns end up in the court system and projects can be delayed.

It can all become expensive for towns and school districts that continue to clamor for more money, both from their residents and from the state; potentially paying hundreds of thousands of dollars more on a single roofing project by not properly following bidding rules can make a big difference. 

“Garland is your manufacturer, not our manufacturer,” Raulukaitis said to the Watertown School Capital Project Committee. “We were one of their bigger installers for twenty-eight years, we don’t get along with them anymore. We don’t like the way they do business; we are struggling with them right now.”

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