Commento sentenza

Tar Campania, Napoli, sez. IV, 23/02/2017, n. 1093 

Natura giuridica del procedimento di verifica dell’offerta sospetta di anomalia.

Il competente Tar Napoli è adito in materia di gare pubbliche d’appalto e, nella sentenza in esame, ha modo di soffermarsi sul tema del procedimento di verifica dell’offerta sospetta di anomalia.Si tratta di un procedimento che, in linea di principio, è avulso da ogni formalismo ed è improntato alla massima collaborazione tra l’amministrazione e l’offerente, quale mezzo indispensabile per l’effettiva instaurazione del contraddittorio ed il concreto apprezzamento dell’adeguatezza dell’offerta.

 

L’art. 86 D.Lgs. n. 163 del 2006 disciplina due distinte ipotesi nelle quali la stazione appaltante procede alla verifica dell’anomalia dell’offerta: la prima è quella di cui al comma 2, secondo il quale il giudizio di congruità dell’offerta deve essere svolto al verificarsi di una situazione aritmetica, ossia al fatto che “sia i punti relativi al prezzo, sia la somma dei punti relativi agli altri elementi di valutazione, sono entrambi pari o superiori ai quattro quinti dei corrispondenti punti massimi previsti dal bando di gara”; la seconda ipotesi è quella di cui al successivo comma 3 che si limita a facultizzare la stazione appaltante a procedere alla verifica di anomalia sempre che l’offerta, pur in assenza delle condizioni indicate dal comma precedente, appaia in base ad elementi specifici anormalmente bassa (T.a.r. Lazio, Roma, sez. II, 14 giugno 2016, n. 6785).

Si richiama in sentenza il consolidato orientamento della giurisprudenza amministrativa secondo cui il sindacato giurisdizionale sulle valutazioni compiute in sede di verifica di anomalia delle offerte deve ritenersi circoscritto ai soli casi di manifesta e macroscopica erroneità o irragionevolezza, in considerazione della discrezionalità che connota dette valutazioni, in quanto tali riservate alla stazione appaltante, cui compete il più ampio margine di apprezzamento dell’interesse pubblico nel caso concreto.

Si è così ripetutamente affermato che il giudizio di anomalia ha natura globale e sintetica e deve risultare da un’analisi di carattere tecnico delle singole componenti di cui la proposta si compone e della relativa incidenza sull’offerta considerata nel suo insieme, al fine di valutare se l’anomalia delle dette componenti si traduca nell’inattendibilità dell’offerta complessiva stessa.

Non solo. Secondo l’adito Collegio giudicante occorre tenere conto anche del principio secondo cui anche un utile apparentemente modesto può comportare un vantaggio significativo sia per la prosecuzione dell’attività (in quanto il mancato utilizzo dei propri fattori produttivi è comunque un costo) che per la qualificazione, la pubblicità e l’accrescimento del curriculum dell’impresa risultata aggiudicataria ed esecutrice di un rilevante appalto pubblico.

Ne discende che nelle gare pubbliche non è possibile stabilire una soglia minima di utile al di sotto della quale l’offerta deve essere considerata anomala, al di fuori dei casi in cui il margine positivo risulti pari a zero o, addirittura, la commessa sia gestita in perdita (Consiglio di Stato, sez. III, 10.11.2015, n. 5128).

La materia in esame registra l’apporto di numerose pronunce della giurisprudenza amministrativa.

Tra queste è da segnalare la decisione dell’A.P. del Consiglio di Stato (29 novembre 2012, n. 36) secondo cui il concorrente, al fine di illustrare la propria offerta e dimostrarne la congruità, è ammesso a fornire spiegazioni e giustificazioni su qualsiasi elemento dell’offerta, e quindi anche su voci non direttamente additate dalla stazione appaltante come incongrue.

Precisa l’A.P.: <<ciò non vuol dire affatto che il concorrente in sede di verifica debba intendersi rigidamente limitato dalle specifiche voci indicate dalla stazione appaltante nella richiesta di giustificazioni, e non possa sponte fornire elementi informativi anche in ordine a qualsiasi altra voce o elemento costitutivo dell’offerta.

Pertanto, se un concorrente non è in grado di dimostrare l’equilibrio complessivo della propria offerta attraverso il richiamo di voci ed elementi diversi da quelli individuati nella richiesta di giustificazioni, in via di principio ciò non può essere mai ascritto a responsabilità della stazione appaltante per erronea o inadeguata formulazione della richiesta di giustificazioni>>.

Conclude, poi, il suo argomentare l’A.P. affermando il principio di diritto per cui: <<Nelle gara d’appalto da aggiudicare col criterio dell’offerta economicamente più vantaggiosa è legittima la verifica di anomalia dell’offerta eseguita, anziché dalla commissione aggiudicatrice, direttamente dal responsabile unico del procedimento avvalendosi degli uffici e organismi tecnici della stazione appaltante. Infatti, anche nel regime anteriore all’entrata in vigore dell’art. 121 del d.P.R. 5 ottobre 2010, nr. 207, è attribuita al responsabile del procedimento facoltà di scegliere, a seconda delle specifiche esigenze di approfondimento richieste dalla verifica, se procedere personalmente ovvero affidare le relative valutazioni alla commissione aggiudicatrice>>.

Ha osservato più di recente il Tar Lazio, Roma (n. 9182 del 2016): <<il corretto svolgimento del procedimento di verifica presuppone sì l’immodificabilità dell´offerta, ma la sicura modificabilità delle giustificazioni, nonché l’ammissibilità di giustificazioni sopravvenute e di compensazioni tra sottostime e sovrastime, purché l´offerta risulti nel suo complesso affidabile al momento dell´aggiudicazione e a tale momento dia garanzia di una seria esecuzione del contratto)>>.

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