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HomeMy WebLinkAboutR-2000-033 Disadvantaged Business Enterprise (DBE) Program and Annual Aspirational Goal (re: transportation funding requirement by DOT & FTA [Federal Transit Administration])RESOLUTION NO. R-2000- 33 A RESOLUTION approving and adopting a Disadvantaged Business Enterprise Program and authorizing submittal of said Program with the United States Department of Transportation, the Federal Transit Administration, and all other appropriate federal and state agencies for review and approval. WHEREAS, the City of Yakima receives funds from the United States Department of Transportation ("DOT") for certain public works projects and from the Federal Transit Administration ("FTA"), an agency of the DOT, regarding the operation of City Transit Division; and WHEREAS, federal DOT regulations require the City to adopt a Disadvantaged Business Enterprise ("DBE") Program with regard to contracts/projects that are funded in whole or part by DOT or FTA; WHEREAS, attached hereto for City Council consideration and potential adoption is a proposed DBE Program that was developed with the assistance of the Yakima Valley Conference of Governments ("YVCOG") and is largely based upon a model DBE Program provided by DOT; and WHEREAS, the City Council deems it to be in the best interest of the City of Yakima to approve and adopt the attached DBE Program and authorize submission of said Program to DOT and FTA, now, therefore, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF YAKIMA: The attached and incorporated Disadvantaged Business Enterprise Program is hereby approved and adopted and City representatives are hereby authorized to submit said Program with the United States Department of Transportation, the Federal Transit Administration, and all other appropriate federal and state agencies for review and approval. ADOPTED BY THE CITY COUNCIL this 4th day of April, 2000. 244 ry Place, Mayor ATTEST: City Clerk (1.k1Puh6c \\ orks/DEE Program/2000/pm TEA -21 - Fact Sheet: Disadvantaged Business Enterprise TEA -21 - Transportation Equity Act for the 21st Century Moving Americans into the 21st Century Fact Sheet TEA -21 Home I DOT Home I Fact Sheet Index Page 1 of 1 DISADVANTAGED BUSINESS ENTERPRISE Program Purpose The Disadvantaged Business Enterprise (DBE) program ensures equal opportunity in transportation contracting markets, addresses the effects of discrimination in transportation contracting, and promotes increased participation in Federally funded contracts by small, socially and economically disadvantaged businesses, including minority and women owned enterprises. The statute provides that at least 10% of the amounts made available for any Federal -aid highways, mass transit, and transportation research and technology program be expended with certified DBEs. Key Continuing Provisions Sustains the applicability to the Federal Highway, Mass Transit, and Transportation Research programs (Titles 1,111, and V) [1101 (b)(1)] Defines small business concerns and socially and economically disadvantaged individuals as in Sections 3 and 8(d) of the Small Business Act. [1101 (b)(2)(B)] Preserves the inclusion of women in the presumptively disadvantaged category [1101 (b)(2)(B)] Reaffirms the administratively determined business size limitation for qualifying as a small business at $16 6 million in annual gross receipts averaged over the preceeding 3 fiscal years [1101 (b)(2)(A)] Maintains an annual survey and listing by State of the firms certified and their locations [1101 (b)(3)] Requires a minimum uniform certification criteria for State Governments [1101 (b)(4)] Key Modifications Expands DBE program applicability to include the National Recreational Trails projects [1101 (b)(1)] Ensures a State's continuing eligibility to receive federal funds if a Federal court issues a final order rendering the application of the State's DBE Program to be unconstitutional [1101 (b)(5)] Requires the General Accounting Office, within 3 years following enactment, to conduct a nationwide review encompassing 11 specific subject areas. The study will include a comparison of DBE and non -DBE firms, and will report findings and conclusions on the impact of the DBE program to the Congress [1101 (b)(6)] September 14, 1998 TEA -21 Home I DOT Home I Fact Sheet Index United States Department of Transportation http.//wwv .fhwa.dot.gov/tea21/factsheets/dbe.htm 03/23/2000 Public Notice The City of Yakima has established a Disadvantaged Business Enterprise (DBE) program in accordance with regulations of the U.S. Department of Transportation (DOT), 49 CFR Part 26. For the purpose of this DBE program, the City of Yakima proposes to set its overall goal utilizing all information available to it, including information provided by statistical evidence in the community and public comment. The City of Yakima proposes that 10% of all DOT funds it will expend in DOT - assisted contracts for fiscal year 2000 (October 1, 1999 to September 30, 2000) will be let to certified DBE firms that are available, willing, and able. The proposed goal and the basis for its rationale are available for public inspection for 30 days during regular business hours, 8 A.M. to 5 P.M., Monday through Friday, in the Purchasing Manager's Office located at City Hall, 129 North 2nd Street Yakima, Washington 98901. The City of Yakima and DOT will accept public comment on the goal for 45 days from the date of this notice. The fiscal year 2000 goal may be adjusted from comments or information received in the next 45 days. Substantial written comments should be addressed to: Purchasing Manager, DBELO City of Yakima 129 North 2nd Street Yakima, Washington 98901 FOR PUBLICATION: Thursday, January 20, 2000 (one day only) Please read the following: An Affidavit of Publication is required. Please send an affidavit of publication to: John A. Haddix - Phone # 575-6005 Transit Planner 2301 Fruitvale Boulevard Yakima, WA 98902 Please bill Yakima Transit, the billing number is 10947 CITY of YAKIMA DBE PROGRAM Definition of Terms The terms used in this program have the meanings defined in 49 CFR 26.5. Objectives /Policy Statement (26.1, 26.23) The City of Yakima, hereinafter referred to as the City, has established a Disadvantaged Business Enterprise (DBE) program in accordance with regulations of the U.S. Department of Transportation (DOT), 49 CFR Part 26. The City receives Federal financial assistance from the Department of Transportation, and as a condition of receiving this assistance, the City has signed an assurance that it will comply with 49 CFR Part 26. It is the policy of the City to ensure that DBEs, as defined in 49 CFR Part 26, have an equal opportunity to receive and participate in DOT -assisted contracts. It is also the City's policy: • To ensure nondiscrimination in the award and administration of DOT assisted contracts; • To create a level playing field on which DBEs can compete fairly for DOT assisted contracts; • To ensure that the DBE Program is narrowly tailored in accordance with applicable law; • To ensure that only firms that fully meet 49 CFR Part 26 eligibility standards are permitted to participate as DBEs; • To help remove barriers to the participation of DBEs in DOT assisted contracts; and • To assist the development of firms that can compete successfully in the market place outside the DBE Program. The City's Purchasing Manager is designated the DBE Liaison Officer (DBELO). In this capacity, the Purchasing Manager is responsible for implementing all aspects of the DBE program. Implementation of the DBE program is accorded the same priority as compliance with all other legal obligations incurred by the City in its financial assistance agreements with the Department of Transportation. The Yakima City Council adopted this policy statement which is disseminated to City Departments, officers, and employees. The City also distributed this statement to DBE and non -DBE business enterprises performing work as needed on DOT - assisted contracts by publishing it in the Yakima Herald -Republic and on the City's official web site. Date: Richard A. Zais, Jr., City Manager Nondiscrimination. (26.7) The City will never exclude any person from participation in, deny any person the benefits of, or otherwise discriminate against anyone in connection with the award and performance of any contract covered by 49 CFR Part 26 on the basis of race, color, sex, or national origin. In administering its DBE program, the City will not directly or through contractual or other arrangements use criteria or methods of administration that have the effect of defeating or substantially impairing accomplishment of the objectives of the DBE program with respect to individuals of a particular race, color, sex, or national origin. DBE Program Updates (26.21) The City will continue to carry out this program until all funds from DOT financial assistance are expended. The City will provide to DOT updates representing significant changes in the program. Quotas (26.43) In accordance with 49 CFR Part 26 and rulings of the U.S. Federal Courts, the City does not use quotas in the administration of this DBE program. DBE Liaison Officer (DBELO) (26.45) The City believes it is the obligation of the entire city staff to see that the DBE program is fully implemented and successful. To that end, every city staff member involved with the administration of DOT -assisted projects is obligated to carry out this policy. However, for the purpose of coordinating city staff, the City designates the Purchasing Manager as the DBELO: Sue Ownby, Purchasing Manager 129 North 2nd Street Yakima, Washington 98901 Phone (509) 576-6695 FAX (509) 576-6394 E-mail sownby@ci.yakima.wa.us In this capacity, the Purchasing Manager is responsible for implementing all aspects of the DBE program and ensuring that the City complies with all provisions of 49 CFR Part 26. The Purchasing Manager has direct, independent access to the City Manager concerning DBE program matters. The DBELO has a staff of 2 professional employees assigned to the Purchasing Division on a full-time basis and who devote a portion of their time to this program. An organization chart displaying the DBELO's position in the organization is found in Attachment A to this program. 03/30/00 8:40 AM 2 The responsibility for developing, implementing, and monitoring the DBE program shall be a coordinated effort with .other appropriate city staff members and officials.° Some of the duties and responsibilities of the various city staff members may include the following: • Gathers and reports statistical data and other information as required by DOT; • Reviews third party contracts and purchase requisitions for compliance with this program; • Works with all city departments to set overall annual goals; • Ensures that bid notices and requests for proposals are available to DBEs in a timely manner; • Identifies contracts and procurements so that DBE goals are included in solicitations (both race -neutral methods and contract specific goals) and monitors results; • Analyzes City's progress toward goal attainment and identifies ways to improve progress; • Participates in pre-bid meetings; • Advises the CEO/governing body on DBE matters and achievement; • Participates with legal counsel and project managers to determine contractor compliance with good faith efforts; • Provides DBEs with information and assistance in preparing bids, obtaining bonding and insurance; , • Plans and participates in DBE training seminars; • Certifies DBEs according to the criteria set by DOT and acts as liaison to the Uniform Certification Process in Washington State; • Provides outreach to DBEs and community organizations to advise them of opportunities; and • Maintains the City's updated directory on certified DBEs. Federal Financial Assistance Agreement Assurance (26.13) The City has signed the following assurance, applicable to all DOT -assisted contracts and their administration: The City shall not discriminate on the basis of race, color, national origin, or sex in the award and performance of any DOT assisted contract or in the administration of its DBE Program or the requirements of 49 CFR part 26. The recipient shall take all necessary and reasonable steps under 49 CFR part 26 to ensure nondiscrimination in the award and administration of DOT assisted contracts. The recipient's DBE Program, as required by 49 CFR part 26 and as approved by DOT, is incorporated by reference in this agreement. Implementation of this program is a legal obligation and failure to carry out its terms shall be treated as a violation of this agreement. Upon notification to the City of its failure to carry out its approved program, the Department may impose sanctions as provided for under part 26 and may, in appropriate 03/30/00 8.40 AM 3 cases, refer the matter for enforcement under 18 U.S.C. 1001 and/or the Program Fraud Civil Remedies Act of 1986 (31 U.S.C. 3801 et seq.). DBE Financial Institutions It is the policy of the City to investigate the full extent of services offered by financial institutions owned and controlled by socially and economically disadvantaged individuals in the community, to make reasonable efforts to use these institutions, and to encourage prime contractors on DOT -assisted contracts to make use of these institutions. The City has surveyed banking, savings and loan, mortgage organizations, the small business administration and the chamber of commerce to determine their knowledge of any DBE institutions. The City has not identified any DBE financial institutions in the community. As information on the availability of DBE financial institutions becomes known, it may be obtained from the DBELO. Directory (26.25) The City has never maintained an independent directory identifying all the firms eligible to participate as DBEs but rather has relied on the State of Washington's list of certified DBEs. The Washington State Office of Minority and Women's Business Enterprises maintains the Directory. The Internet address for accessing the State's Directory is http://www.wsdot.wa.gov/omwbe. As part of complying with DOT policy guidelines, the City shall begin putting together a directory listing DBEs working for the City. The directory will list the firm's name, address, phone number, date of most recent certification, and the type of work the firm has been certified to perform as a DBE. The City shall revise the Directory annually (once each calendar year). The Directory will be made available by contacting the Purchasing Manager at City Hall, 129 North 2nd Street, Yakima, Washington 98901. Overconcentration (26.33) At this time, the City has not identified over concentrations of DBEs in any particular area of contractors used by the City. Business Development Programs (26.35) At this time, the City does not have a business development or mentor -protege program. 03/30/00 8.40 AM 4 Required Contract Clauses (26.13, 26.29) Contract Assurance The City shall ensure that the following clause is placed in every DOT -assisted contract and subcontract: The contractor or subcontractor shall not discriminate on the basis of race, color, national origin, or sex in the performance of this contract. The contractor shall carry out applicable requirements of 49 CFR part 26 in the award and administration of DOT assisted contracts. Failure by the contractor to carry out these requirements is a material breach of this contract, which may result in the termination of this contract or such other remedy, as the recipient deems appropriate. Prompt Payment The City shall include the following clause in each DOT -assisted prime contract: The prime contractor agrees it is important to pay each subcontractor promptly under this prime contract for satisfactory performance and failure to due so may exclude DBE subcontractors from participating in City contracts. Therefore, the contractor agrees to bill the City for each subcontractor's satisfactory performance of work on at least a biweekly basis, and pay each subcontractor under this prime contract for satisfactory performance of its contract no later than fourteen days from the receipt and an approval of an invoice from the prime contractor. The prime contractor agrees further to return retainage payments to each subcontractor within fourteen days after the subcontractor's work is satisfactorily completed. Any delay or postponement of payment from the above referenced time frame may occur only for good cause following written approval of the City. This clause applies to both DBE and non -DBE subcontractors. Monitoring and Enforcement Mechanisms (26.37) The City will bring to the attention of the Department of Transportation any false, fraudulent, or dishonest conduct in connection with the program, so that DOT can take the steps (e.g., referral to the Department of Justice for criminal prosecution, referral to the DOT Inspector General, action under suspension and debarment or Program Fraud and Civil Penalties rules) provided in 26.109. The City also will consider similar action under our own legal authorities, including responsibility determinations in future contracts in events of non-compliance with DBE regulation by a participant in our procurement activities. 03/30/00 8.40 AM 5 Overall Goals (26.45) Amount of Goal The City established an overall goal of 10% for Federal FY 2000 for the Federal financial assistance the City will expend in DOT -assisted contracts (exclusive of FTA funds to be used for the purchase of transit vehicles, real estate procurement). Given the amount of DOT -assisted contracts the City expects to let during this federal fiscal year/project, which is $ , this means that City have set a goal of expending $ with DBEs during this federal fiscal year/project. Method The following is a brief summary of the method the City used to calculate its goal: [Note - This summary need not be as extensive as the actual overall goal submission, which is a separate document. It should address the following points: • The method used to calculate the relative availability of DBEs ("base figure') for "Step I" of the process (see 26.45(c)). The base figure is a percentage figure calculated by dividing a number representing available DBEs by a number representing all available firms. For example, theprogram would state which of Examples 1-4 from 26.45 (or which variation or alternative approach) the recipient is using. • The data source(s) used to derive the numerator an<<. denominator in the calculation (e.g., , for a recipient that used Example 1, there were X DBEs in our Directory and Y total firms in the following SIC codes and following Counties found in the Census Bureau's CBP database). • The relative availability percentage. • The data sources used in implementing "Step 2" (see 26.45(d)). This step is intended to adjust the "base figure" percentage from Step 1 so that it reflects as accurately as possible the DBE participation the recipient would expect in the absence of discrimination. For example, this portion of the program could "Our history of DBE achievements was %, our disparity study showed that availability of DBEs was %, we have the following summarized information about barriers to entry or competitiveness of DBEs in our programs from the following sources"). 03/30/00 8.40 AM 6 • From this data, we have adjusted our base percentage as follows: [Describe reasoning process that led to your particular adjustment from the Step 2 data you have] Transit Vehicle Manufacturers (26.49) The City requires transit vehicle manufacturers as a condition of being authorized to bid or propose on FTA -assisted transit vehicle procurements to certify they have complied with the requirements of this section. Alternatively, the City may, at its discretion and with FTA approval, establish project -specific goals for DBE participation in the procurement of transit vehicles in lieu of Transit Vehicle Manufacturers complying with this program element. Process The City will begin the process of submitting its overall goal to DOT on or about May 15 of each year. The actual goal will be submitted to the FTA on or about August 1 of each year. The City will consult each year with the State of Washington's Office of Minority and Women's Business Enterprises and local community building and trades groups to obtain information concerning the availability of disadvantaged and non - disadvantaged businesses, the effects of discrimination on opportunities for DBEs, and the City's efforts to establish a level playing field for the participation of DBEs before establishing the City's overall goal. Following consultation, the City will publish a notice of the proposed overall goal, informing the public that the proposed goal and its rationale are available for inspection at the Purchasing Manager's Office, Yakima City Hall, during normal business hours for 30 days following the date of the notice. The notice shall inform the public that the City and DOT will accept comments on the overall goal for 45 days from the date of issuing the notice. The City will normally publish the notice of the proposed overall goal in the Yakima Herald -Republic and on the City's Official Web Site on or about June 1 of each year. The notice shall include the addresses to which comments may be sent and the addresses (including office and web site) where the proposal may be reviewed. The City's overall goal submission to DOT will include a summary of information and any significant comments received during the public participation process and any City's responses. The City will begin using its overall goal on October 1 of each year, unless it has received other instructions from DOT. 03/30/00 8 40 AM 7 Break-out of Estimated Race -Neutral and Race -Conscious Participation The City will meet the maximum feasible portion of its overall goal by using race - neutral means of facilitating DBE participation. The City will use the following race -neutral means to increase DBE participation: • Develop a DBE list as extensively as possible, • Send notices of projects to contractors on the City's DBE list, • Provide prime contractors a list of DBEs to partner with or provide subcontract services, and • Advertise using available minority media the projects that could accommodate small business. Note: Race -neutral means the City will outreach, technical assist, and revise the procurement process to insure increased opportunities for all small businesses, not just for DBEs. The City will meet the maximum feasible portion of its overall goal by using race - neutral means of facilitating DBE participation. Race -neutral DBE participation includes: • Any time a DBE wins a prime contract through customary competitive procurement procedures, • Any time a DBE is awarded a subcontract on a prime contract that does not carry a DBE goal, Or, even if there is a DBE goal, • Any time a DBE wins a subcontract from a prime contractor that did not consider its DBE status in making the award (e.g., a prime contractor that uses a strict low bid system to award its subcontracts). Race -neutral means include, but are not limited to, the following: • Arranging solicitations, times for the presentation of bids, quantities, specifications, and delivery schedules in ways that facilitate DBE and other small businesses participation (e.g., unbundling large contracts to make them more accessible to small businesses, requiring or encouraging prime contractors to subcontract portions of work that they might otherwise perform with their own forces); • Providing assistance in overcoming limitations such as inability to obtain bonding or financing (e.g., by such means as simplifying the bonding process, reducing bonding requirements, eliminating the impact of surety costs from bids, and providing services to help DBEs, and other small businesses, obtain bonding and financing); 03/30/00 8 40 AM 8 • Providing technical assistance and other services; • Carrying out information and communications programs on contracting' procedures and specific contract opportunities (e.g., ensuring the inclusion of DBEs, and other small businesses, on recipient mailing lists for bidders; ensuring the dissemination to bidders on prime contracts of lists of potential subcontractors; provision of information in languages other than English, where appropriate); • Implementing a supportive services program to develop and improve immediate and long-term business management, record keeping, and financial and accounting capability for DBEs and other small businesses; • Providing services to help DBEs, and other small businesses, improve long- term development, increase opportunities to participate in a variety of kinds of work, handle increasingly significant projects, and achieve eventual self- sufficiency; • Assist in establishing a program to assist new, start-up firms, particularly in fields in which DBE participation has historically been low; • Ensuring distribution of our DBE directory, through print and electronic means, to the broadest range of potential prime contractors; and • Assisting DBEs, and other small businesses, to develop their capability to utilize emerging technology and conduct business through electronic media The City estimates that to meet its overall goal of 10%, it will obtain 5% from race - neutral participation and 5% through race -conscious measures. The City will adjust the estimated breakout of race -neutral and race -conscious participation as needed to reflect actual DBE participation (see 26.51(f)) and track and report race -neutral and race -conscious participation separately. For reporting purposes, race -neutral DBE participation includes, but is not necessarily limited to, the following: • DBE participation through a prime contract a DBE obtains through customary competitive procurement procedures; • DBE participation through a subcontract on a prime contract that does not carry a DBE goal; • DBE participation on a prime contract exceeding a contract goal; and • DBE participation through a subcontract from a prime contractor that did not consider a firm's DBE status in making the award. It is the City's goal to reduce the percentage of the overall goal obtained by race conscious methods as the Program and the number of available DBEs further develops. 03/30/00 8.40 AM 9 Contract Goals (26.51) The City will use contract goals to meet any portion of the overall goal the City does not project being able to meet using race -neutral means. Contract goals are established so that, over the period to which the overall goal applies, they will cumulatively result in meeting any portion of our overall goal that is not projected to be met through the use of race -neutral means. The City will establish contract goals only on those DOT -assisted contracts that have subcontracting possibilities. The City need not establish a contract goal on every such contract, and the size of contract goals will be adapted to the circumstances of each such contract (e.g., type and location of work, availability of DBEs to perform the particular type of work). The City will express its contract goals as a percentage of the federal share of a DOT -assisted contract. Good Faith Efforts (26.53) Information to be submitted The City treats bidder/offerors' compliance with good faith effort requirements as a matter of responsibility. Each solicitation for which a contract goal has been established will require the bidders/offerors to submit the following information • The names and addresses of DBE firms that will participate in the contract; • A description of the work that each DBE will perform; • The dollar amount of the participation of each DBE firm participation; • Written and signed documentation of commitment to use a DBE subcontractor whose participation it submits to meet a contract goal; • Written and signed confirmation from the DBE that it is participating in the contract as provided in the prime contractor's commitment; and • If the contract goal is not met, evidence of good faith efforts. Demonstration of good faith efforts The obligation of the bidder/offeror is to make good faith efforts. The bidder/offeror can demonstrate that it has done so either by meeting the contract goal or documenting good faith efforts. Examples of good faith efforts are found in Appendix A to 49 CFR Part 26. The Purchasing Manager is responsible for determining whether a bidder/offeror who has not met the contract goal has documented sufficient good faith efforts to be regarded as responsible. 03/30/00 8:40 AM 10 The Purchasing Manager will ensure that all information is complete and accurate and adequately documents the bidder/offeror's good faith efforts before committing. to the performance of the contract by the bidder/offeror. Administrative reconsideration Within 15 days of being informed by the City that they (bidder/offeror) are not a responsible bidder/offeror because they did not document sufficient good faith efforts, a bidder/offeror may request administrative reconsideration. Bidder/offerors should make their request in writing to the following reconsideration official: Glenn K. Rice Assistant City Manager 129 North 2nd Street Yakima, Washington, 98901. The reconsideration official will not have played any role in the original determination that the bidder/offeror did not document sufficient good faith efforts. As part of this reconsideration, the bidder/offeror will have the opportunity to provide written documentation or argument concerning the issue of whether it met the goal or made adequate good faith efforts to doso. The bidder/offeror will have the opportunity to meet in person with our reconsideration official to discuss the issue of whether they met the goal or made adequate good faith efforts to do. The City will send the bidder/offeror a written decision on reconsideration, explaining the basis for finding that the bidder did or did not meet the goal or make adequate good faith efforts to do so. The result of the reconsideration process is not administratively appealable to the Department of Transportation. Good Faith Efforts when a DBE is replaced on a contract The City requires that a contractor make good faith efforts to replace any DBE that is terminated or has otherwise failed to complete its work on a contract with another certified DBE, to the extent needed to meet the contract goal. The City requires the prime contractor to immediately notify the DBELO of any DBE's inability or unwillingness to perform the work and provide reasonable documentation. In this situation, the City shall require the prime contractor to obtain prior approval of the substitute DBE and to provide copies of new or amended subcontracts or documentation of good faith efforts. If the contractor fails or refuses 03/30/00 8 40 AM 11 to comply within the time specified, the City shall issue a stop order stopping all or part of payment/work until satisfactory action is taken. If the contractor still fails to comply, the City may issue a termination for default proceeding. Counting DBE Participation (26.55) The City will count DBE participation toward overall and contract goals as provided in 49 CFR 26.55. Certification (26.61 - 26.91) The City will use the certification standards of Subpart D of part 26 and the certification procedures of Subpart E of part 26 to determine the eligibility of firms to participate as DBEs in DOT -assisted contracts. A firm must meet all certification eligibility standards to be certified as a DBE. The City will make its certification decisions decision based on the facts as a whole. Process / Unified Certification Program The State of Washington Office of Minority and Women's Business Enterprises has a unified certification program. This agency also conducts certifications, re - certifications, and decertification. Certification Appeals Any firm or complainant may appeal the City's decision in a certification matter to DOT. Such appeals may be sent to: Department of Transportation Office of Civil Rights Certification Appeals Branch 400 7th St., SW, Room 2104 Washington, DC 20590 The City will promptly implement any DOT certification appeal decisions affecting the eligibility of DBEs for its DOT -assisted contracting (e.g., certify a firm if DOT has determined that our denial of its application was erroneous). "No Change" Affidavits and Notices of Change The City requires all DBEs to inform the City by written affidavit of any change in circumstances affecting a DBE's ability to meet size, disadvantaged status, ownership or control criteria of 49 CFR part 26 or of any material changes in the information provided with its application for certification. 03/30/00 8.40 AM 12 City also requires owners of all DBEs it has certified to submit on the anniversary date of their certification a "no change" affidavit meeting the requirements of 26.83(j). The text of this affidavit is as follows: I swear (or affirm) that there have been no changes in the circumstances of [name of DBE firm] affecting its ability to meet the size, disadvantaged status, ownership, or control requirements of 49 CFR part 26. There have been no material changes in the information provided with [name of DBE]'s application for certification, except for any changes about which you have provided written notice to the [City] under 26.83(i). [Name of firm] meets Small Business Administration (SBA) criteria for being a small business concern and its average annual gross receipts (as defined by SBA rules) over the firm's previous three fiscal years do not exceed $16.6 million. The City requires DBEs to submit with this affidavit documentation of the firm's size and gross receipts. Personal Net Worth The City will require all disadvantaged owners of applicants and of currently certified DBEs whose eligibility under 49 CFR part 26 City review, to submit a statement of personal net worth. Information Collection and Reporting Bidders List The City will create a bidders list consisting of information about all DBE and non - DBE firms that bid or quote on DOT -assisted contracts. The purpose of this requirement is to allow use of the bidders list approach to calculating overall goals. The Bidders List will include: • The Bidders name • Address • DBE/non-DBE status • Age, and • Annual gross receipts of firms. The City will collect this information by inserting a contract clause requiring prime bidders to report name/addresses and other information of all firms that provide a quote to them. 03/30/00 8.40 AM 13 Monitoring Payments to DBEs The City will require prime contractors to maintain records and documents of payments to DBEs for three years following the performance of their contract and to make these records available for inspection upon request by any authorized representative of the City or DOT. This reporting requirement also extends to any certified DBE subcontractor. The City will keep a running tally of actual payments to DBE firms for work committed to them at the time of contract award and perform interim audits of contract payments to DBEs. The audit will review payments to DBE subcontractors to ensure that the actual amount paid to DBE subcontractors equals or exceeds the dollar amounts stated in the schedule of DBE participation. Reporting to DOT DBE participation is reported to DOT as follows: • The City will report DBE participation quarterly using DOT Form 4630. • Reports will reflect payments actually made to DBEs on DOT assisted contracts. Confidentiality The City will safeguard from disclosure to third parties information that may reasonably be regarded as confidential business information consistent with federal, state, and local law. Notwithstanding any contrary provisions of state or local law, the City will not release personal financial information submitted in response to the personal net worth requirement to a third party (other than DOT) without the written consent of the submitter. Attachments Attachment A: City of Yakima Organizational Chart. Attachment B: Actual Overall Goal Submission Developed by YVCOG A copy of 49 CFR Parts 23 and 26; Final Rule 03/30/00 8 40 AM 14 Attachment A: Organizational Chart Assistant City Manager Central Supply Purchasing Surplus Property Attachment B: Overall Goal Submission DOCUMENTATION Methodology for Setting Goals for Participation of Disadvantaged Business Enterprises (DBE) in Federal Transit Administration Assisted Contracts Review of Yakima Transit Contracts The Yakima Valley Conference of Governments (YVCOG) staff contacted the City of Yakima's Purchasing Office and requested copies of all contract bids or quotes where Yakima Transit was a substantial recipient in the current federal fiscal year and in the previous four federal fiscal years. For the purposes of this documentation, substantial recipient is deemed to mean receiving at least 15 percent of the product or benefit of the contract. The YVCOG received bid lists for contracts let between March 1994 to February 1999 and biyearly Disadvantaged Business Enterprise (DBE) reports from January 1994 to September 1999. The City of Yakima also provided a compiled list of minority vendors that contained 281 vendor firms. A review of the City of Yakima's minority vendor's list revealed seven firms that were certified by Washington State Office of Minority and Women's Business Enterprises (OMWBE) as Minority Business Enterprise or Women's Business Enterprise (MBE/WBE). Of these seven firms, five were further certified as DBE firms. A listing of firms on the City's minority vendor's list that are certified as MBEs/WBEs or DBEs in other states was not available. A review of contracts let during Federal Fiscal Year (FFY) of 1999 showed three contracts let for bid in which Yakima Transit was a substantial recipient. A total of five bids or quotes were received on these contracts and, of the five firms bidding, one bidder was listed by the City of Yakima and certified by the OMWBE as a DBE contractor. One contract for $47,765 was awarded to a business owned by a DBE. A review of biyearly DBE reports and bid tabulation and comparison sheets for FFY 1994 through FFY 1998 showed no participation by Yakima Transit in contracts awarded in FFY 1994 and only marginal participation in contracts awarded in FFY 1995 and 1996. In FFY 1997 and 1998 Yakima Transit was a substantial recipient of goods or services for five contracts awarded. A total of sixteen bids were received on these contracts and of the 16 firms bidding, the City of Yakima listed two bidders as DBE contractors. One contract for $11,216 was awarded to a DBE business. Determination of Base Percentage Figure Guidance for determination of goals for participation by DBEs in Department of Transportation (DOT) programs (Chapter 49, Combined Federal Regulations, Part 26.45) suggests four methodologies for determining a base percentage goal for participation of ready, willing and able DBEs in DOT -assisted contracts. One methodology is to determine the; number ()treacly, willing, and able DBEs in the local market from locally or regionally compiled lists of DBEs. The number of DBEs can then be divided by the number of all ready, willing, and able businesses in the local market listed in the Census Bureau's County Business Patterns to determine the base percentage of DBEs in the local market. Another suggested methodology is to use the results of a locally administered disparity study to determine a base percentage goal for DBE participation in DOT -assisted contracts. A third suggested methodology is to use the goal of another DOT recipient, adjusted for your market. A fourth suggested methodology is to use a bidders list, taking the number of DBEs which have bid or quoted on DOT -assisted contracts in the previous year and divide that number by the number of all businesses which have bid or quoted on DOT - assisted contracts in the same time period. Due to the small number of contracts participated in by Yakima Transit in any year reviewed, it was determined by YVCOG staff that this fourth methodology would be the most effective in periodic updates of the DBE goals. Disadvantage Business Enterprise Bids on Yakima Transit Contracts Federal Fiscal Year 1995 to 1999 Year Contracts Bids DBE Bids %DBE Bidders Total Amount Awarded ,., , Amount Awarded to DBEs % Amount Awarded to DBEs 1997 ; 1 3 0 i 0% i See $0 0% Notes' 1998 4 13 2 1 15% $31,839 $11,216 35% 1999 3 5 1 20% $216,672 $47,766 22% Total (2 8 21 3 12% $248,511 $58,982 19% Notes: None of the contracts awarded during Federal Fiscal Years 1995 and 1996 identified Yakima Transit as a significant participant. (1) A contract was awarded for dial -a -ride paratransit services based on the contractor being reimbursed on a per passenger rate for each passenger transported. (2) Averages are the average of the three Federal Fiscal Years when contracts were awarded on behalf of Yakima Transit. Taking the FFY 1998 and 1999 figures from the table above, YVCOG staff determined that the percentage of DBEs which are interested in and willing to participate in contracting opportunities in Yakima Transit's market is between 15 and 20 percent of all available businesses. 2 Adjustment of Base Figure The ;:.iidance in 49 CFR, Part 26.45, paragraph (d) states: "Once you have calculated a figure, you must examine all of the evidence available in your jurisdiction to determine what adjustment, if' any, is needed to the base figure in order to arrive at your overall goal." The guidance further states in paragraph (d), subsections (i), (ii), and (iii) that the types of evidence that must be considered includes: "(i) The current capacity of DBEs to perform work in DOT -assisted contracting programs, as measured by the volume of work DBE's have performed in recent years; (ii) Evidence from disparity studies conducted anywhere within your jurisdiction and not already accounted for in your base figure; and, (iii) If your base figure is the goal of another, you must adjust it for differences in your local market and your contracting program." Only evidence of DBEs capacity to perform work on DOT -assisted contracts was used because no disparity studies have been conducted in the City of Yakima and the goal of another DOT recipient was not used. As noted in the review section of this document, bid tabulation and comparison sheets from the City of Yakima Purchasing Office to Yakima Transit show that of five contracts let between FFY 1997 and 1998 in which Yakima Transit was a significant participant, one DBE contractor was awarded a contract for $11,216, or 35 percent of the total dollars awarded in contracts let FFY 1998 in which Yakima Transit was a substantial recipient. YVCOG Recommendation of Base Goal Adjustment Noting the significant year-to-year fluctuation in the number and dollar amounts of contracts let in which Yakima Transit is a participant, the limited availability of DBEs, and the small amount of Federal Transit Administration funds being contracted out, YVCOG staff recommends Yakima Transit adopt a three-year rolling average goal of 10 percent DBE participation in DOT -assisted contracts. This matches the FTA's national goal of 10 percent. Overall Goal of Yakima Transit DBE Program The guidance indicates once an overall goal has been determined, recipients of Federal Transit Administration (FTA) funds should express their overall goal as a percentage of all FTA funds (exclusive of FTA funds to be used for the purchase of transit vehicles) that the recipients will expend in FTA -assisted contracts in the forthcoming fiscal year. Therefore, Yakima Transit's overall goal for FFY 2000 is the following: a three-year rolling average of 10 percent of the financial assistance expended in FTA -assisted contracts (exclusive of FTA funds used for the purchase of transit vehicles). 3 Basis of Goal Calculations and Adjustments, YVCOG staff based these calculations on copies of bid documents, biyearly participation reports, the City of Yakima's minority vendor's list, which were provide to YVCOG staff by Sue Ownby, City Purchasing Manager and DBE Liaison Officer; and on the directory of DBE certified firms maintained by the Washington State Office of Minority and Women's Business Enterprises (OWMBE). The Internet address for accessing the State's Directory is http://www.wsdot.wa.gov/omwbe. 4 Attachment C: AMR M. IM 11M, d=111111111 .m. MEL BIM•MI 1. AIM /MM. 1111 11111 MMIMMIMMIL MIEMMINMEMIk — M. MN US IN Am RiM Mk MI MI M NM im, NM mom Tuesday February 2, 1999 Part 11 Department of Transportation Office of the Secretary 49 CFR Parts 23 and 26 Participation by Disadvantaged Business Enterprises in Department of Transportation Programs; Final Rule 5096 Federal Register /Vol. 64, No. 21 /Tuesday, February 2, 1999 / Rules and Regulations DEPARTMENT OF TRANSPORTATION Office of the Secretary 49 CFR Parts 23 and 26 [Docket OST -97-2550; Notice 97-5] RIN 2105-AB92 Participation by Disadvantaged Business Enterprises in Department of Transportation Programs AGENCY: Office of the Secretary, DOT. ACTION: Final rule. SUMMARY: This final rule revises the Department of Transportation's regulations for its disadvantaged business enterprise (DBE) program. The DBE program is intended to remedy past and current discrimination against disadvantaged business enterprises, ensure a "level playing field" and foster equal opportunity in DOT -assisted contracts, improve the flexibility and efficiency of the DBE program, and reduce burdens on small businesses This final rule replaces the former DBE regulation. which now contains only the rules for the separate DBE program for airport concessions, with a new regulation The new regulation reflects President Clinton's policy to mend. not end affirmative action programs It modifies the Department's DBE program in light of developments in case law recuirir.a-narrow tailoring" of such orograms and last year's Congressional debate concernir., the continuation of the DBE program It responds to comments or. the Department's December 1992 notice of proposed rulemaking (NPRM) and its May 1997 supplemental notice of proposed rulemaking (SNPRM) DATES: This rule is effective March 4, 1999 Comments on Paperwork Reduction Act matters should be received by April 5, 1999: however, late - filed comments will be considered to the extent practicable. ADDRESSES: Persons wishing to comment on Paperwork Reduction Act matters (see discussion at end of preamble) should send comments to Docket Clerk, Docket No OST -97-2550, Department of Transportation, 400 7th Street, SW . Room 4107, Washington, DC 20590 We emphasize that the docket is open only with respect to Paperwork Reduction Act matters, and the Department is not accepting comments on other aspects of the regulation We request that, in order to minimize burdens on the docket clerk's staff, commenters send three copies of their comments to the docket. Commenters wishing to have their submissions acknowledged should include a stamped, self-addressed postcard with their comments. The docket clerk will date stamp the postcard and return it to the commenter. Comments will be available for inspection at the above address from 10 a.m. to 5:00 p.m.. Monday through Friday. FOR FURTHER INFORMATION CONTACT: Robert C. Ashby, Deputy Assistant General Counsel for Regulation and Enforcement, Department of Transportation, 400 7th Street, SW., Room 10424, Washington, DC 20590, phone numbers (202) 366-9306 (voice), (202) 366-9313 (fax), (202) 755-7687 (TDD), bob.ashby@ost.dot.gov (email): or David J. Goldberg. Office of Environmental, Civil Rights and General Law, Department of Transportation, 400 7th Street, SW . Room 5432, Washington, DC 20590, phone number (202) 366-8023 (voice), (202) 366-8536 (fax) SUPPLEMENTARY INFORMATION: Background The Department has the important responsibility of ensuring that firms competing for DOT -assisted contracts are not disadvantaged by unlawful discrimination For eighteen years, the Department's most important tool for meeting this responsibility has been its Disadvantaged Business Enterprise (DBE) program. This program began in 1980 Originall\ the program was a minority/women s business enterprise program established by regulation under the authority of Title VI of the Civil Rights Act of 1964 and other nondiscrimination statutes that apply to DOT financial assistance programs. See 49 CFR part 23 In 1983, Congress enacted, and President Reagan signed, the first statutory DBE provision. This statute applied primarily to small firms owned and controlled by minorities in the Department's highway and transit programs. Firms owned and controlled by women, and the Department's airport program, remained under the original 1980 regulatory provisions. In 1987, Congress enacted. and President Reagan signed. statutes expanding the program to airports and to women -owned firms In 1991 (for highway and transit programs) and 1992 (for airport programs), Congress enacted, and President Bush signed, statutes reauthorizing the expanded DBE program. After each statutory amendment, and at other times to resolve program issues, the Department amended part 23 The result has been that part 23 has become a patchwork quilt of a regulation. In addition, years of interpretation by various grantees and different DOT offices has created confusion and inconsistency in program - administration. These problems, particularly in the area of certification, were criticized in General Accounting Office reports. The Department's desire to improve program administration and make the rule a more unified whole led to our publication of a December 1992 notice of proposed rulemaking (NPRM). The Department received about 600 comments on this NPRM. The Department carefully reviewed these comments and. by early 1995, had prepared a draft final rule responding to them. However, in light of the Supreme Court's June 1995 decision in Adarand v. Pena and the Administration's review of affirmative action programs, the Department conducted further review of the DBE program. As a result, rather than issuing a final rule, we issued a supplemental notice of proposed rulemaking (SNPRM) in May 1997 This SNPRM incorporated responses to the comments on the 1992 NPRM and__ proposed further changes in the program, primarily in response to the "narrow tailoring" requirements of Adarand. We received about 300 comments on the SNPRM The Department has carefully considered these comments, and the final rule responds to them The final rule also specifically complies with the requirements that the courts ha'e established for a narrowly tailored affirmative action program. At the same time that the Department was working on this final rule. Congress once again considered reauthorization of the DBE program. In both the House and the Senate, opponents of affirmative action sponsored amendments that would have effectively ended the program. In both cases, bipartisan majorities defeated the amendments The final highway/transit authorization legislation, known as the Transportation Equity Act for the 21st Century (TEA - 21), retains the DBE program. In shaping this final rule. the Department has listened carefully to what both supporters and opponents of the program have said in Congressional debates. Key Points of the Final Rule This discussion reviews and responds to the SNPRM comments and the Congressional debates on certain key issues. Congressional debate references are to the Congressional Record for March 5 and 6, 1998, for the Senate debate and April 1, 1998, for the House debate, unless otherwise noted. i1i:I;YS ' d Federal Register /Vol. 64, No. 21 /Tuesday ,yebruary 2, 1999 / Rules and Regulations 5097 1. Quotas and Set -Asides SNPRM Comments: Most comments on this issue came from non -DBE contractors, who argued that the program was a de facto quota program. Many of these contractors said that recipients insisted that they meet numerical goals regardless of other considerations, and that the recipients did not take showings of good faith efforts seriously. Some non -DBE contractor organizations argued, in addition, that the program was a quota program because it was based on a statute that had a 10 percent target for the use of businesses defined by a racial classification. Congressional Debate: Opponents of the DBE program generally asserted that it created quotas or set -asides. Senator McConnell described the entire program, particularly the provision that "not less than 10 percent" of authorized funds go to DBEs, as ' * * a $17.3 billion quota. In other words, if the government decides that you are the preferred race and gender, then you are able to compete for $17 3 billion of taxpayer - funded highway contracts But, if you are the wrong race and gender, then—too bad—you can't compete for that $17 billion pot. (S1936) The "not less than 10 percent" language also led opponents. such as Sena:or Asncroft, to label the program a "set- aside " (S1405'), a terra also employed in test,,--,onv pro\ ided 'ov a law professor from Caiifor o'. ho said that the statute "imposes a set-aside that's required regardless of the availability of race - neutral solutions " (S1407) Senator Gorton said that the DBE statute provides that "those not defined as disadvantaged in our society are absolutely barred and prohibited from getting certain governmental contracts." (S1415) On the other hand, supporters of the program were adamant that it was not a quota program. Senator Baucus argued that the program, as implemented by DOT, allows substantial flexibility to recipients and contractors. Recipients could have an overall goal other than 10 percent under current rules, he pointed out. Senator Kerry of Massachusetts added that what the statute does is to "set a national goal. And it is appropriate in this country to set national goals for what we will do to try to break down the walls of discrimination. * * *" (S1408) He also alluded to the flexibility of the Secretary to permit overall goals of less than 10 percent. Senator Robb stated. I want to stress at the outset that this program is not a "quota program," as some have suggested There is a great difference [between] an aspiratibitSl goal and a rigid numerical requirement. Quotas utilize rigid nurnerical requirements as a means of implementing a program. The DBE program uses aspiratiorial goals. (S1425)r.iw With respect to individual contract goals, Senator Baucus said. "once a goal is established for a contract, each contractor must make a good -faith effort to meet the goal—not mathematically required, not quota required. but a good faith effort to meet it." (S1402). Senator Baucus pointed to provisions of the SNPRM concerning overall goals, means of meeting them, and good -faith efforts as further narrowly tailoring the program. The SNPRM confirms, he said, that "contract goals are not binding. If a contractor makes good faith efforts to find qualified women or minority- owned subcontractors, but fails to meet the goal. there is no penalty." (S1403). Senator Robb added that "Contract goals are not operated as quotas because they require that the prime contractor make 'good faith efforts' to find DBEs If a prime contractor cannot find qualified and competitive DBEs. the goal can be waived." (S1425) One of the Senators who addressed the quota/set-side issue in the most detail was Senator Domenici He concluded that ' 1 do not agree that this minority business prograrn we have in this ISTEA bill before us is a program that mandates cuctas and mandates set - asides (51-125) He made this statement. in par:. on the basis of March 5 1998. iette- to n:m signed b% Secretary of Transportation Rodney Slater and Attorney General Janet Reno In relevant part, this letter (which Senator Domenici inserted into the record) read as follows. The 10 percent figure contained in the statute is not a mandatory set aside or rigid quota. First, the statute explicitly provides that the Secretary of Transportation may waive the goal for any reason * * * Second, in no way is the 10 percent figure imposed on any state or locality * * * Moreover, state agencies are permitted to waive goals when achievement on a particular contract or even for a specific year is not possible. The DBE program does not set aside a certain percentage of contracts or dollars for a specific set of contractors. Nor does the DBE program require recipients to use set -asides. The DBE program is a goals program which encourages participation without imposing rigid requirements of any type. Neither the Department's current nor proposed regulations permit the use of quotas. The DBE program does not use any rigid numerical requirements that would mandate a fixed number of dollars or contracts for DBEs. (S1427) The debate in the House proceeded in similar terms Opponents of the DBE program, such as Representative Roukema (H2000), Representative Cox (H2004) and Speaker Gingrich (H2009) said the legislation constituted a quota, while proponents, such as Representatives Tauscher (H2001), Poshard (H2003). Bonior (H2004) and Menendez (H2004) said the program did not involve quotas or set -asides. DOT Response: The DOT DBE program is not a quota or set-aside program, and it is not intended to operate as one. To make this point unmistakably clear, the Department has added explicitly worded new or amended provisions to the rule. Section 26.41 makes clear that the 10 percent statutory goal contained in ISTEA and TEA -21 is an aspirational goal at the national level. It does not set any funds aside for any person or group. It does not require any recipient or contractor to have 10 percent (or any other percentage) DBE goals or participation. Unlike former part 23, it does not require recipients to take any special administrative steps (e.g , providing a special justification to DOT) if their annual overall goal is less than 10 percent. Recipients must set goals consistent with their own circumstances (see § 26 45) There is no direct link between the national 10 percent aspirational goal and the way a recipient operates its program. The Department will use the 10 percent goal as a means of evaluating the overall performance of the DBE program nationwide For example, if nationwide DBE participation were to drop precipitously, the Department would reevaluate its efforts to ensure nondiscriminatory access to DOT - assisted contracting opportunities. Section 26 43 states flatly that recipients are prohibited from using quotas under any circumstances. The section also prohibits set -asides except in the most extreme circumstances where no other approach could be expected to redress egregious discrimination. Section 26 45 makes clear that in setting overall goals, recipients aspire to achieving only the amount of DBE participation that would be obtained in a nondiscriminatory market. Recipients are not to simply pick a number representing a policy objective or responding to any particular constituency Section 26 53 also outlines what bidders must do to be responsive and responsible on DOT -assisted contracts having contract goals. They must make good faith efforts to meet these goals. Bidders can meet this requirement either by having enough DBE participation to meet the goal or by documenting good faith efforts, even if those efforts did not actually achieve the 5098 Federal Register /Vol. 64, No. 21 /Tuesday, February 2, 1999 / Rules and Regulations goal. These means of meeting contract goal requirements are fully equivalent. Recipients are prohibited from denying a contract to a bidder simply because it did not obtain enough DBE participation to meet the goal. Recipients must seriously consider bidders' documentation of good faith efforts. To make certain that bidders' showings are taken seriously, the rule requires recipients to offer administrative reconsideration to bidders whose good faith efforts showings are initially rejected. These provisions leave no room for doubt: there is no place for quotas in the DOT DBE program. In the Department's oversight, we will take care to ensure that recipients implement the program consistent with the intent of Congress and these regulatory prohibitions. 2. Sanctions for Recipients Who Fail To Meet Overall Goals SNPRM Comments: The issue of sanctions for recipients who fail to meet overall goals was not a subject of comments on the SNPRM. Since the Department has never imposed such sanctions, this absence of comment is not surprising Congressional Debate. DBE program opponents asserted, in connection with their argument that the DBE program is a quota program, that the Department could .moose sanctions for failure to meet goals "The goals have requirements and the real threat of San.t_C Sena:Or McConnell said. S1.1.88; Citing a provision of a Federal High'.vav Administration (FHWA) manual saying that if "a state has violated or failed to comply with Federal laws or * * * regulations," FHWA could withhold Federal funding, Senator McConnell said, In other words, there are sanctions. The same threats appear in * * the Federal transportation regulations * * * When the Federal government is wielding that kind of weapon from on high, it does not have to punish them. A 10 percent quota is still a quota, even if the States always comply and no one is formally punished. (Id.) Defenders of the DBE program pointed out that the Department had never punished a recipient for failing to meet an overall goal (e g., Rep Tauscher, H2001, Senator Boxer, 51433) Senator Domenici asked Secretary Siater and Attorney General Reno whether there are sanctions, penalties, or fines that may be (or ever have been) imposed on a recipient who does not meet DBE program goals. He entered the following reply in the record. No state has ever been sanctioned by DOT for not meeting its goals Nothing in the statute or regulations imposes sanctions on any state recipient that has attempted in good faith, but failed. to meet its self-imposed goals. (S1427). Senator Lieberman added that if states fail to meet their own goals, "there is no Federal sanction or enforcement mechanism." (S1493). DOT Response: The Department has never sanctioned a recipient for failing to meet an overall goal. We do not intend to do so. -To eliminate any confusion, we have added a new provision (S 26 47) that explicitly states that a recipient cannot be penalized, or treated by the Department as being in noncompliance with the rule, simply because its DBE participation falls short of its overall goal. For example, if a recipient's overall goal is 12 percent. and its participation is 8 percent, the Department cannot and will not penalize the recipient simply because its actual DBE participation rate was less than its goal. Overall goals are not quotas. and the Department does not sanction recipients because their participation levels fall short of their overall goals Of course, if a recipient does not have a DBE program, does not set a DBE goal, does not implement its DBE program in good faith, or discriminates in the way it operates its program it can be found in noncompliance Eut its noncompliance would never ..e ha .rg failed to ' make a number 3 Econcnic Disad'.'anrage SNPRM Cornmenrs. Some commenters favored eliminating the presumption of economic disadvantage, saying that applicants should have to prove their economic disadvantage. Other commenters favored obtaining additional financial information from applicants so that, even if the presumption remained in force, recipients would have a better idea of whether applicants really were disadvantaged. The question of the standard for determining disadvantage generated substantial comment, with some commenters favoring, and others objecting to, the proposed use of a personal net worth standard to assist recipients in determining whether an applicant was economically disadvantaged. There was also disagreement among commenters concerning the level at which such a standard should be set (e g , $750,000, or something higher or lower). These comments, and the Department's response to them, are further discussed in the section -by -section analysis for § 26.67. Congressional Debate The Congress debated the topic of who is regarded as economically disadvantaged under the statute. DBE opponents. including Senators Ashcroft (S1405) and McConnell (S1418) and Representative Cox (H2004), asserted that outrageously rich people could be eligible to participate as DBEs, frequently using the Sultan of Brunei as an example. The basic thrust of their argument was that if the program does not exclude wealthy members of the designated groups— meaning those who are not. in fact, disadvantaged—then it is "overinclusive" and therefore not narrowly tailored. Senator McConnell added that, because the Department's SNPRM did not include a specific dollar amount for a cap on personal net worth, it would not be effective. (S1486). On the other hand. DBE program supporters cited the SNPRM's proposed net worth cap as an effective device to stop wealthy people from participating in the program. These included Minority Leader Daschle (with a reference to a letter from the Associate Attorney General, S1413), Senator Baucus (S1414, S1423), Senator Lieberman (S1493), Senator Boxer (S1433), and Senator Moseley -Braun, who responded to the Sultan of Brunei example by noting that the program was directed primarily at U S citizens (S1420) DOT Response. The final rule (§26 67) specifically imposes a personal net worth cap of S750,000 This means that, regardless of race. gender or the size of their business, any individual whose personal net worth exceeds S750,000 is not considered economically disadvantaged and is not eligible for the DBE program. The provision also makes it much easier for recipients to determine whether an individual's net worth exceeds the cap Applicants will have to submit a statement of personal net worth and supporting documentation to the recipient with their applications. If the information shows net worth above the cap. the recipient would rebut the presumption based on the information in the application itself and the individual would not be eligible for the program In such a case, it would not be necessary for a third party to challenge the economic disadvantage of an applicant in order to rebut the presumption. While there have been very few documented cases of wealthy individuals seeking to take advantage of the Department's program, the revised provisions of part 26 virtually eliminate even the possibility of this type of abuse. 4. Social Disadvantage SNPRM Comments. A few commenters suggested that the 'Y"' ,. "1.ndt a-:'F'tS.'. Federal Register / Vol. 64, No. 21 / Tuesday,; -February 2, 1999 / Rules and Regulations 5099 presumption of social disadvantage, as well as that of economic disadvantage, be eliminated, so that applicants would have to demonstrate both elements of disadvantage. Any presumption of disadvantage tied to a racial classification, in the view of some of these commenters, undermined the constitutionality of the program. Other commenters noted that persons who are not members of the presumptively disadvantaged groups can be eligible and, in some cases, suggested that the criteria for evaluating such applications be clarified. Congressional Debate: The presumption of social disadvantage drew fire from DBE program opponents because it was allegedly overinclusive. For example, Senator McConnell produced a map illustrating the over 100 countries of origin leading to inclusion in one of the presumed socially disadvantaged groups. pointing out that people from some countries (e:g , Pakistan) are presumed to be socially disadvantaged while those from other countries (e g , Poland) are not. (S1418) Senator McConnell said that there was no basis for selecting this definition over any other. (Id.) Senator Hatch also listed the countries from which Asian -Pacific Americans and Subcontinent Asian -Americans can originate, suggesting that it was inappropriate to create "all kinds of specia: interest groups who are vying for these programs " (5141 i) DBE proponents responded that discrimination against minorities and women in general, and against specific minorities in particular (e.g , African Americans) was very real and formed a basis for the presumption of social disadvantage (see discussion below concerning the existence of discrimination) Senator Baucus also noted that this presumption could be overcome. (S1402). Opponents also charged that the presumption of social disadvantage was underinclusive, that is, "you underinclude people who have a right to be included in the bid process " (Senator McConnell, S1399) The people who are not included who have a right to be, in the view of opponents, are white males (e.g., Senator Sessions' reference to testimony from Adarand Constructors' owner, S1400) Senator Kennedy disagreed with this assertion, saying Of course, this program doesn't just help women and minorities. It extends a helping hand to firms owned by white males. as well. They can be certified to [participate] if they prove that they have been disadvantaged. Just ask Randy Pech—owner of the Adarand Construction Firm 'because he is currently seeking certification. (S1482). Senator Domenici was interested in the same question,.and entered,into the record the following response from Secretary Slater and Attorney General Reno. Any individual owning a business may demonstrate that he is socially and economically disadvantaged, even If that individual is not a woman or a minority. Both the current and proposed regulations provide detailed guidance to recipients to assist them in making individual determinations of disadvantaged status, And, in fact, businesses owned by white males have qualified for DBE status. (S1427). DOT Response: By having passed the DBE statutory provision. after lengthy and specific debate, Congress has once again determined that members of the designated groups should be presumed socially disadvantaged. All of these groups are specifically incorporated by reference in the legislation that Congress debated and approved. This presumption (i.e., a determination that it is not necessary for group members to prove individually that they have been the subject of discrimination or disadvantage) is based on the understanding of Members of Congress about the discrimination that members of these groups have faced The presumption is rebuttable in the DOT program If a recipient or third'party determines that there is a reasonable basis for concluding that an individual from one of the designated groups is not socially disadvantaged it can pursue a proceeding under § 26 87 to remove the presumption. Likewise, a white male, or anyone else who is not presumed to be disadvantaged. can make an individual showing of social and economic disadvantage and participate in the program on the same basis as any other disadvantaged individual (see § 26 67). 5 The "Low -Bid System" SNPRM Comments. Non -DBE contractors expressed concern that a variety of provisions under the program and the SNPRlv1 adversely affected the low -bid system, including contract goals, evaluation credits, and good faith efforts guidance concerning prime contractors' handling of subcontractor prices and consideration of other 'bidders' success in meeting goals. Congressional Debate: Opponents of the DBE program assert that the program results in white male contractors not receiving contracts they would otherwise expect to receive. Senator Sessions cited the statement of the Adarand company to this effect. (S1400) Senator Ashcroft said that "if two bids come in from two subcontractors, one owned by a white male and the other by a racial minority, and the bids are the same, or even close, the job'will go to the minority-owned company, not the low bidder." (S1405) Senator Gorton inserted into the record letters from a Spokane subcontractor asserting that, in a number of cases, it had lost subcontracts to DBE firms despite having a lower quote. (SI415- 16). Representative Roukema also cited examples of firms who made similar assertions. (H2000). In contrast. DBE program proponents argued that the program was about leveling the playing field for DBEs. Senator Moseley -Braun cited letters from her constituents for the point that * ' ' the DBE program is not about taking away contracts from qualified male -owned businesses and handing them over to unqualified female -owned firms. The program is not about denying contracts to Caucasian low bidders in favor of higher bids that happen to have been submitted by Hispanics or African Americans or Asians or women. (S1420) Without such a program, her constituents' letters said, they would lose the chance to compete. (Id.) Citing testimony from a Judiciary Committee hearing. Senator Kennedy noted that it was the experience of some DBEs that white male prime contractors had accepted higher bids from other firms to avoid working with DBEs (S1430) tt by would a general contractor accept a higher bid? it doesn't make sense unless you remember that the traditional business network doesn t include women or minorities * * * [A woman business owner testified] that some general contractors would rather lose money than deal with female contractors. (Id.) DOT Response. For the most part, statutory low -bid requirements exist only at the prime contracting level. That is, state and local governments, in awarding prime contracts, must select the low bidder in many procurements (there may be exceptions in some types of purchases) Nothing in this regulation requires, under any circumstances, a recipient to accept a higher bid for a prime contract from a DBE when a non - DBE has presented a lower bid. This rule does not interfere with recipients' implementation of state and local low - bid legislation. The selection of subcontractors by a prime contractor is typically not subject to any low -bid requirements under state or local law Prime contractors have unfettered discretion to select any subcontractor they wish. Price is clearly a key factor, but nothing legally compels a prime contractor to hire the subcontractor who makes the lowest quote Other factors, such as the prime 5100 Federal Register /Vol. 64, No. 21 /Tuesday. February 2, 1999 /Rules and Regulations contractor's familiarity and experience with a subcontractor, the quality of a subcontractor's work, the word-of- mouth reputation of the subcontractor in the prime contracting community, or the prime's comfort or discomfort with dealing with a particular subcontractor can be as or more important than price in some situations. It is in this context that § 26.53 requires that prime contractors make good faith efforts to achieve DBE contract goals. The rule does not require that recipients ignore price or quality, let alone obtain a certain amount of DBE participation without regard to other considerations. The good faith efforts requirements are intended to ensure that prime contractors cannot simply refuse to consider qualified, competitive DBE subcontractors. At the same time. the good faith efforts waiver of contract goals serves as a safeguard to ensure that prime contractors will not be forced into accepting an unreasonable or excessive quote from a DBE subcontractor 6. Constitutionality SItiPRM Comments. Non -DBE contractors and their groups argued that the SNPRM proposals, particularly with respect to overall goals and the use of race -conscious measures. failed to meet the Adarand narrow tailoring test. Many of these commenters said that the o'-era:i goals were suspect because they did not adequately consider the capacity of DEEs to perform contracts and 4.darnnd requires that race -conscious measures may be used only after a recipient has demonstrated that race - neutral means have failed. The use of presumptions based on racial classifications was viewed as intrinsically unconstitutional by these commenters, many of whom cited the language of Judge Kane's decision in the Adarand remand to this effect. Some commenters also contended that, absent recipient -specific findings of compelling need, the program could not be constitutional They said that existing information alleging compelling interest -such as various disparity studies or information compiled by the Department of Justice -was inadequate to meet the compelling interest test. DBEs and recipients who commented defended the constitutionality of the program, often citing experience with discrimination in the marketplace and contending that the SNPRM succeeded in narrowly tailoring the program. Congressional Debate: Proponents and opponents of the DBE program extensively debated the constitutionality of the DBE statutory provision and the entire DBE program. Generally, opponents argued that the Supreme Court and District Court decisions in Adarand rendered the program unconstitutional, while proponents said that the decisions did not have that effect. Proponents and opponents of the DBE program agreed that the Supreme Court's Adarand decision established a two-part test for the constitutionality of a program that uses a racial classification. The program must be based on a compelling governmental interest and be narrowly tailored to further that interest (e.g., Senator McConnell, S1396, Senator Baucus, S1403). Opponents relied on the finding of a Colorado district court on remand that the program was not narrowly tailored and was thus unconstitutional (Senator McConnell, S 1396; Senator Ashcroft, S1405). Proponents replied that the remand decision represented the views of only one district court (Senator Baucus, S1403), that it failed to properly apply the reasoning of the Supreme Court decision with respect to narrow tailoring (Senator Domenici, 51425), and that the Department's forthcoming regulations would ensure that the program was narrowly tailored (see discussion below). A. Compelling Interest (1) Existence of Discrimination. Proponents (and some opponents) of the DBE provision said that discrimination and/or disadvantage with respect to minorities and/or women persists. In the House, these included Representative Roulema (H2000-01), Representative Norton (H2003), Representative Poshard (H2003), Representative Menendez (H2004), Representative Davis of Illinois (H2005), Representative Boswell (H2005), Representative Lampson (H2006), Representative Kennedy (H2006), Representative Jackson -Lee (H2006), Representative Edwards (H2007), Representative Andrews (H2007), Representative Rodriguez (H2008), Representative Towns (H2010), Representative Dixon (H2010), and Representative Millender-McDonald (H2011). DBE opponents typically remained silent on this point. neither affirming nor denying the existence of discrimination against women and minorities. There was a similar pattern in the Senate debates Opponents typically did not address the present existence of discrimination or disadvantage with respect to minorities and women or its continuing effects, spoke of such discrimination as something that existed in the past (Senator.Sessions, S1399, Senator Hatch, 51411), or asserted that race -based disadvantage or discrimination no longer exists (Senator Ashcroft, S1406) The Senators who said that such discrimination persists included Senator Baucus (S1403, S1413, S1496), Senator Warner (S1403), Senator Kerry (S1408), Senator Wellstone (S1410), Senator Moseley -Braun (S1419-20), Senator Robb (S1422); Senator Brownback (S1423-24), Senator Domenici (S1425-26), Senator Kennedy (S1429-30, S1482), Senator Specter (S1485), Senator McCain (S1489), Senator Lautenberg (S1490), Senator Durbin (S1491), Senator Daschle (S1492), Senator Lieberman (S1493), Senator Bingaman (S1494), Senator Murray (S1495), and Senator Dorgan (S1495). (2) Evidence of discrimination or disadvantage. In comments on the passage of the TEA -21 conference report in the Senate. Senator Chafee noted a Colorado Department of Transportation disparity study that found a disproportionately small number of women- and minority-owned contractors participating in that state's highway construction industry. More than 99 percent of contracts went to firms owned by white men. (Congressional Record, May 22, 1998, S5413) In the House discussion of the conference report, Representative Norton presented an extensive summary of relevant evidence of discrimination forming the basis for a compelling need for the DBE program. (H3957) Throughout the debate, the Members who affirmed the existence of discrimination and/or disadvantage asserted a number of factual bases for concluding that the DBE program was necessary This information is Iargely drawn from the Senate debate, the briefer House debate contains less, detail. Senator Baucus cited disparities between the earnings of women and men and between the percentage of small businesses women own and the percentage of Federal procurement dollars they receive. He also noted that minorities make up 20 percent of the population, own 9 percent of construction businesses, and get only 4 percent of construction receipts. (S1403) Finally, Senator Baucus, via a letter from the Associate Attorney General, cited to numerous Congressional findings concerning the effects of discrimination in the construction industry and in DOT - assisted programs. (S1413). Senator Kerry added that women own 9 2 percent of the nation's construction firms but their companies earn only about half of what is earned by male - owned firms (S1409) Senator Robb Federal Register/ Vol. 64, No. 21 /Tuesday, -,February 2, 1999 / Rules and Regulations 5101 commented that the evidence of racially based disadvantage is "compelling and disturbing." He continued, stating that, "White -owned construction firms receive 50 times as many loan dollars as African-American owned firms that have identical equity." (S1422). Senator Kennedy said that the playing field for women and minorities and other victims of discrimination was still not level. Job discrimination against minorities and the "glass ceiling" for women still persisted, he said, adding that "Nowhere is the deck stacked more heavily against women and minorities than in the construction industry " (S1429) He cited a number of instances in which minority or female contractors encountered overt discrimination in trying to get work. (51429-30). Senator Lautenberg said that, for transportation -related contracts, minority-owned firms get only 61 cents for every dollar of work that white male - owned businesses receive The comparable figure for women -owned firms was 48 cents. He also mentioned that "women -owned businesses have a lower rate of loan delinquency, yet still have far greater difficulty in obtaining loans." (S1490) He then spoke of the continuing effects of past discrimination Jim Crow laws were wiped off the books over 3C years ago However, their pernicious effects on :he construction industry remain. Transportation construction has historically relied on the old boy network which. u ,;_1 the last decade :as almost exclusively a white, old boy network. ' ` ' This is an tr.dustr' that relies heavily on business friendships and relationships established decades. sometimes generations, ago—years before minority-owned firms were even allowed to compete. (Id.) Senator Durbin referred to recent studies concerning job bias against minorities and women. (S1491) Senator Lieberman referred generally to previous Congressional committee findings and testimony concerning still - existing barriers to full participation for minorities and women. (S1493) He also cited the May 1996 Department of Justice survey of discrimination and its effects in business and contracting He referred to a recent study in Denver showing that African Americans were 3 times, and Hispanics 1 5 times, more likely than whites to be rejected for business loans Senator Daschle summed up by saying, "[tlhere is clearly a compelling interest in addressing the pervasive discrimination that has characterized the highway construction industry " (S1492) Throughout the portion of the debate described above, many of the Members stressed that goal -based programs like the DBE program were the only effective way to combat the continuing effects of discrimination. Senator Baucus cited the experience of Michigain;''in` which DBE'participation in the state -funded portion of the highway program fell to zero in a nine- month period after the state terminated its DBE program, while the Federal DBE program in Michigan was able to maintain 12.7 percent participation. (S1404). Senator Kerry also raised the Michigan example, and went on to cite similar sharp decreases in DBE participation when Louisiana, Hillsborough County, Florida, and San Jose, California, eliminated affirmative action programs covering state- and locally -funded programs. Senator Kerry asked rhetorically: * * * is that just the economy of our country speaking, an economy at one moment that is capable of having 12 percent and at another moment, where they lose the incentive to do so, to drop down to zero, to drop down by 99 percent, to drop down by 80 percent. to have 4 at the State level while at the Federal level there are 12 percent? You could not have a more compelling interest if you tried. * * * (S1409-10) Senator Moseley -Braun added the examples of Arizona, Arkansas, Rhode Island, and Delaware to the jurisdictions cited by other members where state - funded projects without a DBE program have significantly less DBE participation than Federally funded projects subject to the DBE program. She added, "Where there are no DBE programs women- and minority-owned small businesses are shut out of highway construction." (S1420-21) Senator Kennedy added Nebraska, Missouri, Tampa and Philadelphia to the list of jurisdictions that experienced precipitous drops in DBE participation after goals programs ended. (S1429-30: S1482). He also cited comments from DBE companies that goal programs were needed to surmount discrimination -related barriers. (S1482). Senator Domenici repeated many of the same points as previous DBE proponents concerning the basis for concluding that the program was needed (S1426). as did Senator Kempthorne. (51494) Senator Robb emphasized that the DBE program was essential to combating discrimination and ensuring economic opportunity, explicitly linking the fall- off in DBE participation to continuing discrimination. Where DBE programs at the State level have been eliminated, participation by qualified women and qualified minorities in government transportation contracts has plummeted. There is no way to know whether this discrimination is intentional or subconscious, but the effect is the same. This experience demonstrates the sad but inescapable truth that. when it comes to providing economic opportunities to women and minorities, passivity equals inequality (S1422). 3. Narrow tailoring.—DBE proponents cited the Department's proposed DBE rule as the vehicle that would ensure that the DBE program would be narrowly tailored. They cited features of the SNPRM including a new mechanism for calculation of overall goals, giving priority to race -neutral measures in meeting goals, a greater emphasis on good faith efforts, DBE diversification, added flexibility for recipients, net worth provisions, ability to challenge presumptions of social and economic disadvantage, and flexibility in goal - setting. In comments on the Senate consideration of the TEA -21 conference report, Senator Baucus concluded by saying: As I explained in my statements during the debate cn the McConnell amendment ' * * the program is narrowly tailored, both under the current and the new regulations. which emphasize flexible goals tied to the capacity of firms in the local market, the use of race - neutral measures. and the appropriate use of waivers for good faith efforts. (Congressional Record, May 22. 1998; S5414) Following Senator Baucus' remarks, Senator Chafee, Chairman of the committee of jurisdiction, requested that he be associated with Senator Baucus' remarks on constitutionality (S5414) DBE opponents denied that regulatory change could result in a narrowly tailored program. Senator Smith said "The administration s attempt to comply with the Court's decision by fiddling around with the DOT regulations does not meet the constitutional litmus test." (S1398) The most frequent argument against the efficacy of regulatory change was that a racial classification is inherently unable to be narrowly tailored. (Senator Sessions, 51399-1400: Senator Ashcroft, S 1407) DOT Response: The 1998 debate over DBE legislation was the most thorough in which Congress has engaged since the beginning of the program The record of this debate clearly supports the Department's view that there is a compelling governmental interest in remedying discrimination and its effects in DOT -assisted contracting Congress clearly determined that real, pervasive, and injurious discrimination exists. Congress backed up that determination with reference to a wide range of factual material, including private and public contracting. DOT -assisted and state -and locally -funded programs and the financing of the contracting industry By retaining the DBE statutory provisions 5102 Federal Register /Vol. 64, No. 21 /Tuesday, February 2, 1999 /Rules and Regulations against this factual background, Congress clearly found that there was a compelling governmental interest in having the program. The courts, including the court in the Adarand Constructors Inc. v. Pena, 965 F.Supp. 1556 (D Colo., 1997) and the court in In re: Sherbrooke Sodding, 6- 96—CV-41 (D. Minn. 1998), agree that Congress has the power to legislate on a nationwide basis to address nationwide problems. Congress has a unique role as the national legislature to look at the whole of the United States for the basis to find a compelling governmental interest supporting the use of race -based remedies. Congress is not required to make particularized findings of discrimination in individual localities to which a nationwide program may apply. Nor is Congress required to find that the Federal government itself has discriminated before applying a race -conscious remedy (Id. at 1573) Having reviewed the extensive evidence of discrimination and its relationship to DOT -assisted contracting, the District Court in Adarand determined that current and previous DBE provisions were a "considered response by Congress to the effects of discrimination on the ability of minorities to participate in the mainstream of federal contracting " (Id. at 1576) The court stated that "Congress has a strong basis in evidence for enacting the challenged statutes, which thus serve a compelling governmental interest ' ' (Id. at 1577) The extensive Congressional debate and information supporting the enactment of the 1998 DBE provision significantly strengthens the existing basis for declaring that this program serves a compelling governmental interest. The basis for District Court's view that the program at issue in Adarand is unconstitutional is stated most clearly in the following passage Contrary to the [Supreme] Court's pronouncement that strict scrutiny is not fatal in fact,' I find it difficult to envisage a race -based classification that is narrowly tailored. By its very nature, such [a] program is both underinclusive and overinclusive. (Id. at 1580) By underinclusive, the court said it meant that caucasians and members of non -designated minority groups are excluded. By overinclusive, it said it meant that all the members of the designated groups are presumed to be economically and/or socially disadvantaged, without Congress having inquired whether a particular entity seeking a racial preference has suffered from the effects of past discrimination (citing the Supreme Court's Croson decision, which concerned the powers of state and local governments to use race -based remedies). (Id.) As Senator Domenici pointed out (S1425), the key words in the District Court's opinion are "Contrary to the [Supreme] Court's pronouncement. * * *" The District Court's analysis departs markedly from the controlling decision of the Supreme Court on this issue (Adarand v. Pena, 515 U.S. 200 (1995)). The Supreme Court's language with which the District Court disagreed is the following: Finally, we wish to dispel the notion that strict scrutiny is "strict in theory. but fatal in fact." [citation omitted} The unhappy persistence of both the practice and the lingering effects of racial discrimination against minority groups in this country is an unfortunate reality, and government is not disqualified from acting in response to it * * * When race -based action is necessary to further a compelling interest. such action is within constitutional constraints if it satisfies the "narrow tailoring" test this Court has set out in previous cases. (515 U.S. at 237) The Supreme Court evidently considers the "not fatal in fact" language to have continuing vitality, having cited it in a subsequent case (U S. v. Virginia, 518 U S. 515, note 6 (1996)) Under the District Court's analysis, Congress could never use a race -based classification, no matter how compelling the need. because any such classification would intrinsically fail to be narrowly tailored. This approach effectively moots the determination of whether there is a compelling governmental interest. The Supreme Court's approach, by contrast, permits a racial classification to be used, given the existence of a compelling interest, if it is narrowly tailored. What is the test for narrow tailoring? As set forth in United States v. Paradise, 480 U S 149, 171 (1987), the test includes several factors: "the necessity for relief and the efficacy of alternative remedies; the flexibility and duration of the relief, including the availability of waiver provisions, the relationship of the goals to the relevant labor market; and the impact of the relief on the rights of third parties." In Adarand, the Supreme Court specifically invited inquiry into whether there was any consideration of the use of race -neutral means to increase minority business participation (related to the efficacy of alternative remedies) and whether the program was appropriately limited so that it will not last longer than the discrimination it is designed to eliminate (related to the duration of relief) (515 U.S at 238) This final rule successfully addresses each element of this test: • The necessity of relief. Throughout the debate on the compelling governmental interest. the bipartisan majority of both houses of Congress repeatedly described the necessity of the DBE program's goal -based approach to remedying the effects of discrimination in DOT -assisted contracting. The most significant evidence demonstrating the necessity of a goal -oriented program is the evidence cited of the fall-off in DBE participation in state contracting when goal -oriented programs end, compared to participation rates in the Federal DBE program. • Efficacy of alternative remedies. This element of the narrow tailoring standard is related to the Supreme Court's inquiry concerning race -neutral programs. Under § 26.51 of this rule, recipients are required to meet the maximum feasible portion of their overall goals by using race -neutral measures. Recipients are not required to have contract goals on each contract. Instead. they are instructed to use contract goals only for any portion of their overall goal they cannot meet through race -neutral measures. Contract goals are intended as a safety net to be used when race -neutral means are not effective to ensure that a recipient can achieve "level playing field." Moreover, the regulations provide that recipients must reduce the use of contract goals when other means are sufficient to meet their overall goals This ensures that race -conscious relief is used only to the extent necessary and is rerlaced by race -neutral as quickl\ .)ssible • Flexibility of relies ..bility is built into the program ariety of ways. Recipients set ti^ x n goals, based on local market _ __tions; their goals are not imposed _ federal government nor do rec.,_ .:pts have to tie them to any uniform national percentage. (§ 26 45) Recipients also choose their own method for goal setting and can choose to base the goal on the evidence that they believe best reflects their market conditions. (§ 26.45) Recipients have broad discretion to choose whether or not to use a goal on any given contract, and if they do choose to use a contract goal, they are free to set it at any level they believe is appropriate for the type and location of the specific work involved. 626.51). The rule also ensures flexibility for contractors by requiring that any contract goal be waived entirely for a prime contractor that demonstrates that it made good faith efforts but was still unable to meet the goal. (§ 26.53). The rule also allows recipients that believe they can achieve equal opportunity for DBEs through different approaches to get waivers releasing Federal Register /Vol. 64, No. 21 / Tuesday, =February 2, 1999 / Rules and Regulations 5103 them from almost any of the specific requirements of the rule. (§ 26.103). Recipients can also get exemptions from the rule if they have unique circumstances that make complying with the rule impractical. (§ 26.103). • Duration of relief. The TEA -21 DBE program will end in 2004 unless reauthorized by the Congress. In each successive reauthorization bill for the surface transportation and airport . programs. Congress will have the opportunity to examine the current state of transportation contracting and determine whether the DBE program statutes are still necessary to remedy the continuing effects of discrimination. In addition. the duration of relief for individuals and firms are limited by the personal net worth threshold and business size caps. When an individual's personal wealth grows beyond the threshold, he or she will lose the presumption of disadvantage. (5 26 67) Similarly. when a firm's receipts grows beyond the small business size standards, it loses its eligibility to participate in the program. (5 26 65) Finally, to ensure that race - conscious remedies are not used any longer than absolutely necessary, 5 26 51 requires recipients to reduce the use of contract goals and rely cn race - neutral measures to the extent that they are effective • Re!auonshid of goais to the relevant marker The overall goal setting provisions of § 26 45 require that recipient set overall goals based on demonstrable evidence of the relative availability of ready, willing and able DBEs ir. the areas from which each recipient obtains contractors. These provisions ensure that there is as close a fit as possible between the goals set by each recipient and the realities of its relevant market. When a recipient sets contract goals, § 26.51 provides that these goals are to be set realistically in relation to the availability of DBEs for the type and location of work involved. • Impact of relief on the rights of third parties. The legitimate interests of third parties (e.g . prime contractors, non -DBE subcontractors) are only minimally impacted by the DBE program, since the program is aimed at replicating a market in which there are no effects of discrimination and the program affects only a relatively small percentage of total federal -aid funds The design of the overall and contract goal provisions ensures that the use of race -conscious remedies having the potential to affect the interests of third parties is limited to the extent necessary to counter the effects of discrimination Individual prime contractors are further protected from suffering any undue burdens by § 26.51, which prevents a prime contractor from losing a contract if it made good faith efforts but was still unable to meet a goal. Non -DBE firms are also protected by § 26.33, which directs recipients to take appropriate steps to address areas of overconcentration of DBE firms in certain types of work that could unduly burden non -DBE firms seeking the same type of work. • Inclusion of appropriate beneficiaries. The certification provisions of Subparts D and E, and particularly the social and economic disadvantage provisions of § 26 67, ensure that only firms owned and controlled by individuals who are in fact socially and economically disadvantaged can participate in the program. Eligibility provisions guard against overinclusiveness by ensuring that individuals with too great net worth are not presumed disadvantaged and by permitting the recipient—on its own initiative or as the result of a complaint—to follow procedures to rebut the presumption of social and/or economic disadvantage -They guard against underinclusiveness by permitting any business owner, including a white male, to demonstrate social and economic disadvantage on an individual basis Section -by -Section Analysis Section 26 1 What Are the Obiecrives of This Part' There were relatively few comments on this section of the SNPRNI, most of which agreed with the proposed language. We have adopted the suggestion of some commenters that specific reference be made to the role of the DBE program in helping DBEs overcome barriers (e.g , access to capital and bonding) to equal participation. We have also added a specific reference to the role of the program in creating a level playing field on which DBEs can compete fairly for DOT -assisted contracts. Some non -DBE contractors urged that language be added to explicitly oppose "reverse discrimination " The rule clearly states that nondiscrimination is the program's first objective and the Department reiterates here that it opposes unlawful discrimination of any kind. Section 26 3 To Whom Does This Part Apply? This provision is unchanged from the SNPRIvI, except for references to the new TEA -21 statutory provisions. A few commenters wanted this provision to apply to Federal Railroad Administration (FRA) programs, as did the original version of former part 23 However, FRA does not have specific statutory authority for a DBE,program parallel to the TEA -21 language. One commenter asked if the language saying that DBE requirements do not apply to contracts without any DOT funding is inconsistent with Federal Transit Administration (FTA) guidance on applicability While the structure of the FTA program is such that FTA funds are commingled with local funds in many transit authority contracts (e.g.. any contract involving FTA operating assistance funds), to which DBE requirements would apply. a contract which is funded entirely with local funds—and without any Federal funds—would not be subject to requirements under this rule. Section 26.5 What Do The Terms Used in This Part Mean? There were relatively few comments on the definitions proposed in the SNPRM One commenter wanted to substitute the term "historically underutilized business" for DBE. Given the continued use of the DBE term in Congressional consideration of the program. the continued use of the "socially and economically disadvantaged individuals" language in the statute, and the familiarity of concerned parties with the DBE term, we do not believe changing the term would be a good idea. A few commenters asked for additional definitions or elaboration of existing definitions (e g . "form of arrangement." "financial assistance program," "commercially useful function") These terms are either already defined sufficiently or are best understood in context of the operational sections in which they are embedded, and abstract definitions in this section would not add much to anyone's ability to make the program work well. Consequently, we are not adding them. Otherwise the final rule adopts the SNPRM proposals for definitions with only minor editorial changes The Department has added, for the sake of clarity and consistency with other Federal programs. definitions of the terms Alaskan native, Alaskan native corporation (ANC), Indian tribe, immediate family member, Native Hawaiian, Native Hawaiian organization, principal place of business, primary industry classification, and tribally -owned concern. These definitions are taken from the SBA's new small disadvantaged business program regulation (13 CFR § 124 3) The definitions of the designated groups included in the definition of "socially 5104 Federal Register /Vol. 64, No. 21 /Tuesday, February 2, 1999 / Rules and Regulations and economically disadvantaged individual" also derive from the SBA regulations, as the Departments DBE statutes require. We believe these will be useful terms of art in implementing the DBE program. A few commenters requested definitions for the terms "race - conscious" and "race -neutral," and we have provided definitions. A race - conscious program is one that focuses on. and provides benefits only for. DBEs. The use of contract goals is the primary example of a race -conscious measure in the DBE program. A race - neutral program is one that, while benefiting DBEs, is not solely focused on DBE firms. For example. small business outreach programs, technical assistance programs, and prompt payment clauses can assist a wide variety of small businesses, not just DBEs. Section 26 7 What Discriminatory Actions Are Forbidden? One commenter wanted to add prohibitions of discrimination based on age. disability and religion. The Department is not doing so, because discrimination on these grounds is already prohibited by other statutes (e g , the Americans with Disabilities Act with respect to disability) .Also, statutes which forrn the basis for this f ule focus on race cc or, national origin, and sex Congress determined that remedial action focused on these areas is necessarn•. These grounds for discrimination are also most relevant to problems in the DBE program that have been alleged to exist (e g., disparate treatment of DBE certification applicants by race or sex) Some opponents of the program said that the DBE program discriminates against non - DBEs. However, the Department believes that the program is constitutional and does not violate equal protection requirements. A reference to DOT Title VI regulations has been deleted as unnecessary; otherwise, this provision is the same as in the SNPRvl. Section 26 9 How Does the Department Issue Guidance and Interpretations Under This Parr? Commenters, most of whom were recipients, focused on two issues in this section. First, a majority of the comments favored the "coordination :mechanism" concept for ensuring consistent DOT guidance and interpretations The few that disagreed with this approach did so out of a concern that the mechanism would add delays to the process. These commenters favored additional training or an 800 number hot line to speed up the process. We believe that proper coordination of interpretations and guidance is vital to the successful implementation of this rule. As the preambles to the 1992 and 1997 proposed rules mentioned, inconsistent implementation of part 23 has been a continuing problem, which has been criticized by a General Accounting Office report and which has created unnecessary difficulty for recipients. contractors, and the Department itself. A process for ensuring that the Department speaks with one voice on DBE implementation matters, and for letting the public know when DOT has spoken, will greatly improve the service we give our customers. We do not believe this coordination process will result in significant delays in providing guidance. Nor will it inhibit the ability of DOT staff and customers to communicate with one another For example, the process does not apply to informal advice provided by staff to recipients or contractors over the phone or in a letter or e-mail. It does maintain, however, the important distinction between informal staff assistance on one hand and a binding institutional position on the other For clarity in the process, we have modified the language of the rule text to make clear that .nterpretanons and guidance are binding, official Departmental positions if the Secretary signs :hem or if the document includes a statement that they have been reviewed and approved by the General Counsel The General Counsel will consult fully with all concerned offices as part of this review process. We intend to post significant guidance documents and interpretations on the Department's web site to make them widely and quickly available. As some commenters suggested, we are also continuing to consider forming an advisory committee (or working group of an existing committee) to facilitate customer input into DBE program matters. This is separate from the coordination mechanism, however, which is an internal DOT process. The rule's provisions regarding exemptions and waivers, previously found in the SNPRM's § 26.9 (c) and (d), are now included as a separate section at §26.15 Section 26 11 What Records do Recipients Keep and Report? The Department asked, in the SNPRM, whether it would be advisable to have one standard reporting form for information about the DBE program. Currently, each operating administration (OA) has its own reporting form and requirements. Virtually all the commenters that addressed this issue favored a single. DOT -wide reporting form. Commenters also had a wide variety of suggestions for what data should be reported. formats, and retention periods. The Department is adopting the suggestion of having a single reporting form. which we believe will reduce administrative burdens for recipients, particularly those who receive funds from more than one OA. Because we do not want to delay the issuance of this rule while a form is being developed, we are reserving the date on which this single form requirement will go into effect. We will take comments on the specifics of reporting into account and consult with interested parties as we devise the form, which will be published subsequently in Appendix B to this rule. The Appendix will also address the issues of reporting frequency and record retention periods. Meanwhile, recipients will continue to report as directed by the concerned OA(s), using existing reporting forms. The rule is also adding a requirement that recipients develop and maintain a "bidders" list. The bidders list is intended to be a count of all firms that are participating, or attempting to participate, on DOT -assisted contracts The list must include all firms that bid on prime contracts or bid or quote subcontracts on DOT -assisted projects, including both DBEs and non -DBEs Bidders lists appear to be a promising method for accurately determining the availability of DBE and non -DBE firms and the Department believes that developing bidders data will be useful for recipients. Creating and maintaining a bidders list will give recipients another valuable way to measure the relative availability of ready, willing and able DBEs when setting their overall goals. (See § 26.45) We realize that identifying subcontractors. particularly non -DBEs and all subcontractors that were unsuccessful in their attempts to obtain contracts, may well be a difficult task for many recipients. Mindful of that potential burden, the rule will not impose any procedural requirements for how the data is collected. Recipients are free to choose whether or not they wish to gather this data through their existing bidding and reporting processes. Recipients are encouraged to make use of all of the data already available to them and all methods of reporting and communication with their contracting community that they already have in place. In addition, the Department suggests that recipients consider using a widely publicized public notice or a Federal Register/Vol. 64, No. 21 / Tuesday,,,,February 2, 1999 /Rules and Regulations 5105 widely disseminated survey to encourage all firms that have bid or quoted contracts to make themselves known to recipients. Once recipients have created the list of bidders. they will have to supplement that information with the age of each firm (since establishment) and the annual gross receipts of the firm (or an average of its annual gross receipts) Recipients can gather this additional information by sending a questionnaire to the firms on the list, or by any other means that the recipient believes will yield reliable information. The recipient's plan for how to create and maintain the list and gather the required information must be included in its DBE program. Section 26.13 What Assurances Must Recipients and Contractors Make? There were few comments on this section. Most of these supported the proposal. One comment suggested specific mention of prompt payment, but in view of the substantive requirements on this subject, we do not believe such a mention is needed. Some commenters favored requiring additional public participation as part of the assurance for recipients Again, given substantive provisions of this rule concerning public participation, we do not believe that repetition here is needed One commenter said that incorporating the requirements of part 25 in the contract was confusing, since many pr o\. sons of part 26 apply only to recipients We have rewritten the assurance for contractors in response to this concern. specifying that contractors are responsible only for carrying out the requirements of part 26 that apply to them. Section 26 15 How Can Recipients Apply for Exemptions or Waivers? There has been some confusion as to this rule's distinction between exemption and waiver Put simply, exemptions are for unique situations that are most likely not to be either generally applicable to all recipients or to have been contemplated in the rulemaking process. If such a situation occurs and it makes it impractical for a particular recipient to comply with a provision of part 26, the recipient should apply for an exemption from that provision. The waiver provision, by contrast, is not designed for extraordinary circumstances where a recipient may not be able to comply with part 26 Waiver is for a situation where a recipient believes that it can better accomplish the objectives of the DBE program through means other than the specific provisions of part 26 There were a number of comments about the proposed program waiver provision. Most commenters on this issue favored'the proposal; believing it could add flexibility to the way recipients implement the DBE program. A few commenters were concerned that too liberal use of the waiver provision might undermine the goals of the rule. The Department believes that the waiver provision is an important aspect of the DBE program. The provision ensures that the Department and a recipient can work together to respond to any unique local circumstances. Recipients are encouraged to carefully review the circumstances in their own jurisdictions to determine what mechanisms are best suited to achieving compliance with the overall objectives of the DBE program. If a recipient believes it is appropriate to operate its program differently from the way that a provision of Subpart B or C provides, including, but not limited to, any provisions regarding administrative requirements, overall or contract goals, good faith efforts or counting provisions, it can apply for a waiver. For example. waiver requests could pertain to such subjects as the use of a race - conscious measure other than a contract goal, different ways of counting DBE participation in certain industries, use of separate overall or contract goals to address demonstrated discrimination against specific categories of socially and economically disadvantaged individuals, the use or \A ording of assurances, differences in information collection requirements and methods, etc. The Department will, of course, carefully review any applications for waivers to make sure that innovative state or local programs are able to meet the objectives of the statutes and regulation. Decisions on waiver requests are made by the Secretary This authority has not been delegated to other officials The waiver provision, which the Department believes will help assist recipients to "narrowly tailor" the program to state and local circumstances and ensure nondiscrimination, remains in the final rule. Section 26 21 Who Must Have a DBE Program? The only substantive comment concerning this provision asked that Federal Railroad Administration (FRA) programs be included. The Department is not including FRA programs under this rule because FRA does not have a specific DBE program statute parallel to those covering the Federal Aviation Administration (FAA). FTA, and FHWA. FRA could consider issuing a rule similar to part 26 under its own, separate statutory authority. The Department shortened paragraph (b) (1) to make it easier to understand. Within 180 days of the effective date of this rule. all recipients with existing programs must submit revised programs to the relevant OA for approval. The only changes from existing programs that recipients would have to make are changes needed to accommodate differences between former part 23 and part 26. Future new recipients would, of course, submit a DBE program as part of the approval process for financial assistance. Section 26.23 What is the Requirement for a Policy Statement? Section 26.25 What is the Requirement for a Liaison Officer? Section 26.27 What Efforts Must Recipients Make Concerning DBE Financial Institutions? There were no substantive comments concerning §526 23-26.27, and the Department is adopting them as proposed. Section 26 29 What Prompt Payment Mechanisms Must Recipients Have? There was substantial comment on the issue of prompt payment. A majority of commenters supported the concept of prompt payment provisions Some recipients pointed out that they already had prompt payment provisions on the books DBEs generally supported mandating prompt payment provisions though they, as well as other commenters, recognized that slow payment is a problem affecting many subcontractors, not just DBEs. Some of these comments suggested making prompt payment requirements applicable to subcontracts in general, not just DBE subcontracts. Some recipients were concerned about getting in the middle of disputes between prime contractors and subcontractors. Some commenters wanted the Department to mandate prompt payment provisions, while others preferred that their use by recipients remain optional. Having considered the variety of views expressed on this subject, the Department believes that prompt payment provisions are an important race -neutral mechanism that can benefit DBEs and all other small businesses Under part 26, all recipients must include a provision in their contracts requiring prime contractors to make prompt payments to their subcontractors, DBE and non -DBE alike. It is clear that DBE subcontractors are significantly—and, to the extent that 5106 Federal Register /Vol. 64, No. 21 /Tuesday, February 2, 1999 /Rules and Regulations they tend to be smaller than non -DBEs, disproportionately—affected by late payments from prime contractors. Lack of prompt payment constitutes a very real barrier to the ability of DBEs to compete in the marketplace. It is appropriate for the Department to require recipients to take reasonable steps to deal with this barrier. We recognize that delayed payments do not affect only DBE contractors; a prompt payment requirement applying to all subcontracts is an excellent example of a race -neutral measure that will assist DBEs, and we are therefore requiring that recipients' prompt payment mechanisms apply to all subcontracts on Federally -assisted contracts. Paragraph (a) of this section requires recipients to put into their DBE programs a requirement for a prompt payment contract clause. This clause would appear in every prime contract on which there are subcontracting possibilities, and it would obligate the prime contractor to pay subcontractors within a given number of days from the receipt of each payment the recipient makes to the prime contractor. Payment is required only for satisfactory completion of the subcontractor's work The clause would also apply to the return of retainage from the prime to the subcontractor Retainage ould have to be returned within a given number of days from the time the subcontractor's work had been satisfactorily completed, even if the prime contract had not yet been completed. A majority of commenters on the retainage issue favored a requirement of this kind. The number of days involved would be selected by the recipient, subject to OA approval as part of the recipient's DBE program. In approving these time frames, the OAs will consider whether they are realistic and sufficiently brief to ensure genuinely prompt payment. Recipients who already operate under prompt payment statutes may use their existing authority in implementing this requirement. It may be necessary to add to existing contract clauses in some cases (e g , if existing prompt payment requirements do not cover retainage). Paragraph (b) lists a series of additional measures that the regulation authorizes, but does not require, recipients to use. These include alternative dispute resolution, holding of payments to primes until subcontractors are paid, and other mechanisms that the recipient may devise All these mechanisms could be made part of the recipient's DBE programs Section 26.31 What Requirements Pertain to the DBE Directory? Recipients maintain directories listing certified DBEs. The issue most discussed by commenters on this section was whether the directory should include material concerning the qualifications of the firm to do various sorts of work. For example, has the firm been pre -qualified by the recipient? Can it do creditable work? What kinds of work does the firm prefer to do? Some commenters also asked that the directory should list the geographical areas in which the firm is willing to work. Other commenters opposed the idea of including this kind of information in the directory. The Department believes that the directory and the certification process are closely intertwined. The primary purpose of the directory is to show the results of the certification process. Consequently. the directory should list all firms that the recipient has certified, along with basic identifying information for the firm. Since certification under this rule pertains to the various kinds of work a firm's disadvantaged owners can control, it is important to list those kinds of work in the directory For example, if a firm seeks to work in fields A, B. and C, but the recipient has determined that its disadvantaged owners can control its operations only with respect to A and B, then the directory would recite that the firm is certified to perform work as a DBE in fields A and B The focus of the directory is intended to be eligibility. A directory is a list of firms that have been certified as eligible DBEs, with sufficient identifying information to permit interested firms to contact the DBEs We do not intend to turn a recipient's directory into a comprehensive business resource manual. For example, information about firms' qualifications, geographical preferences for work, performance track record, capitalization. etc. are not required to be part of the directory Some commenters favored including one or more of these elements, but we are concerned that other business information—however useful in its own right—could clutter up the directory and dilute its focus on certification. Section 26 33 What Steps Must a Recipient Take to Address Overconcentration of DBEs in Certain Types of Work? For some time. the Department has heard allegations that DBEs are overconcentrated in certain fields of highway construction work (e.g., guardrail, fencing, landscaping, traffic control. striping). The concern expressed is that there are so many DBEs in these areas that non -DBEs are frozen out of the opportunity to work. In an attempt to respond to these concerns, the SNPRM asked for comment on a series of options for "diversification" mechanisms, various incentives and disincentives designed to shift DBE participation to other types of work. The Department received a great deal of comment on these proposals. almost all of it negative. There were few comments suggesting that overconcentration was a serious problem, and many comments said that the alleged problem was not real. Some FTA and FAA recipients said that if there was a problem with overconcentration, it was limited to the highway construction program. As a general matter, recipients said that the proposed mechanisms were costly, cumbersome. and too prescriptive. Prime contractors opposed the provisions because they would make it more difficult for them to find DBEs with which to meet their goals, while DBEs opposed them because they felt the provisions would penalize success and force them out of areas of business in which they were experienced Many commenters suggested using outreach or business development plans as ways of assisting DBEs to move into additional areas of work. The Department does not have data from commenters or other sources to support a finding that "overconcentration" is a serious, nationwide problem. However, as part of the narrow tailoring of the DBE program, we believe it would be useful to give recipients the authority to address overconcentration problems where they may occur In keeping with the increased flexibility that this rule provides recipients, we give recipients discretion to identify situations where overconcentration is unduly burdening non -DBE firms. If a recipient finds an area of overconcentration, it would have to devise means of addressing the problem that work in their local situations Possible means of dealing with the problem could include assisting prime contractors to find DBEs in non-traditional fields or varying the use of contract goals to lessen any burden on particular types of non -DBE specialty contractors. While recipients would have to obtain DOT approval of determinations of overconcentration and measures for dealing with them, the Department is not prescribing any specific mechanisms:for doing so. Federal Register /Vol. 64, No 21 /Tuesday, February 2, 1999 / Rules and Regulations 5107 Section 26.35 What Role do Business Development and Mentor -Protege Programs Have in the DBE Program? In the SNPRM, both mentor -protege programs and business development programs (BDPs) were cast as tools to use for diversification. They still may be used for that purpose, as noted in § 26.33. However, the Department believes that they may have a broader application, and their use in the final rule is not limited to diversification purposes. BDPs, in particular. are good examples of race -neutral methods recipients can use to promote the participation of DBEs and other small businesses in their contracting programs. There were few comments on these provisions. Recipients wanted flexibility, and suggested that these kinds of programs should be optional. Their comments said that such programs were resource -intensive, and that Federal financial assistance for them would be welcome One contractors' organization offered its own mentor -protege plan as a model. A few comments voiced suspicion of mentor - protege plans, on the basis that they allowed fronts and frauds into the program. The final rule makes the use of BDPs and mentor-proteg , programs optional for recipients operating, administration can direct a particular recipient to institute a BDP, but BDPs are not mandatory across the board. The operating administration would negotiate with the recipient before mandating a BDP One feature added to this provision allows recipients to establish a kind of mini -graduation requirement for firms that voluntarily participate in BDPs. One of the purposes of a BDP is to equip DBE firms to compete in the market outside the DBE program. Therefore, a recipient could ask BDP participants to agree—as a condition of receiving BDP assistance—to agree to leave the DBE program after a certain number of years, or after certain business development objectives had been achieved. Standing alone, mentor -protege programs are not an adequate substitute for the DBE program. While they can be an important tool to help selected firms, they cannot be counted on to level the playing field for DBEs in general. An effective mentor -protege program requires close monitoring to guard against abuse, which further limits the number of DBEs they can assist. Even with these limits, a mentor -protege program that has safeguards to prevent large non -DBE firms from circumventing the DBE program can be a useful component of a recipient's overall strategy to ensure equal opportunities for DBEs. The final rule includes safeguards intended to prevent the misuse of mentor -protege programs. Only firms that a recipient has already certified as DBEs (necessarily including a determination that they are independent firms) can participate as proteges. This is intended to preclude non -DBE firms from creating captive DBE firms to serve as proteges. A non -DBE mentor firm cannot get credit for more than half its goal on any contract by using its own protege. Moreover, a non -DBE mentor firm cannot get DBE credit for using its own protege on more than every other contract performed by the protege. That is, if Mentor Firm X uses Protege Firm Y to perform a subcontract, X cannot get DBE credit for using Y on another subcontract until Y had first worked on an intervening prime contract or subcontract with a different prime contractor. To make mentor -protege relationships feasible, the rule provides that mentors and proteges are not treated as affiliates of one another for size determination purposes. Mentor -protege programs and BDPs must be approved by the concerned operating administration before they take effect. Recipients who already have such programs in: place would make them par: of their revised DBE programs sent to the concerned OA within 180 days of :he effective date of par: 26 Section 26 37 What Are a Recipient's Responsibilities for Monitoring rhe Performance of Other Program Participants? The few comments on this section asked for more detail and clarification In the interest of flexibility, the Department is reluctant to be prescriptive in the matter of monitoring and enforcement mechanisms What we are looking for is a strong and effective set of monitoring and compliance provisions in each recipient's DBE program. These mechanisms could be most anything available to the recipient under Federal, state, or local law (e.g . liquidated damages provisions, responsibility determinations, suspension and debarment rules, etc.) One of the main purposes of these provisions is to make sure that DBEs - actually perform work committed to them at contract award. The results that recipients must measure consist of payments actually made to DBEs, not just promises at the award stage. Credit toward goals can be awarded only when payments (including, for example. the return of retainage payments) are actually made to DBEs. Under the final rule, recipients would keep a running tally of the extent to which,on each contract, performance had matched promises. Prime contractors whose performance fell short of original commitments would be subject to the compliance mechanisms the recipient had made applicable. Section 26.41 What 1s the Role of the Statutory 10 Percent Goal in This Program? This is a new section, intended to explain what role the 10 percent statutory goal plays in the DBE program. Under former part 23, the 10 percent figure derived from the statute had a role in the setting of overall goals by recipients. For example. if recipients had a goal of less than 10 percent, the rule required them to make a special justification. This section makes clear that the 10 percent goal is an aspirational goal that applies to the Department of Transportation on a national level, not to individual recipients. It is a goal that the Department can use to evaluate its overall national success in achieving the objectives that Congress has established for this program. However, the national 10 percent goal is not tied to recipients' goal -setting decisions Recipients set goals based on what will achieve a level playing field for DBEs in their own programs. without regard to the national goal Recipients are not required to set their overall or contract goals at 10 percent or any other particular level. Recipients are no longer required to make a special justification if their overall goals are less than 10 percent. As discussed in connection with the Congressional debate on the TEA -21 DBE provision, Congress viewed flexibility concerning the statutory 10 percent goal as an important feature of narrow tailoring and made clear that it was setting a national goal, not a goal for any individual recipient. The Department wants to ensure that state and local programs have sufficient flexibility to implement their programs in a narrowly tailored way This section is part of the Department's effort toward that end Section 26 43 Can Recipients Use Quotas or Set -Asides as Parr of This Program? The DBE program has often been labeled as a "quota" or "set-aside" program, especially, though not exclusively. by its opponents. This label is, and always has been, incorrect. Fifteen years ago, in the preamble to the Department's first rule implementing a DBE statute. the Department carefully 5108 Federal Register /Vol. 64, No. 21 /Tuesday, February 2, 1999 /Rules and Regulations specified that neither quotas nor set - asides were required (see 48 FR 33437- 38, July 21, 1983). This remains true today. However, in light of Adarand and this year's Congressional debates on the DBE statutes, we believe this point deserves additional emphasis. This regulation prohibits quotas under any circumstances and makes clear that set - asides can only be used as a means of last resort for redressing egregious discrimination. A number of non -DBE contractors and their organizations continued to assert, in comments on the SNPRM, that the DBE program operates as a quota program. This section makes clear that recipients cannot use quotas on DOT - assisted contracts under any circumstances. A quota is a simple numerical requirement that a recipient or contractor must meet, without consideration of other factors. For example, if a recipient sets a 12 percent goal on a particular contract and refuses to award the contract to any bidder who does not have 12 percent DBE participation, either refusing to look at showings of good faith .efforts or arbitrarily disregarding them, then the recipient has used a quota The Department's regulations have never endorsed this practice. The issue of good faith efforts is discussed further below in connection with ? 26 51 A set-aside is a ver' specific tool: A contracting agents sets a contract aside for DEEs if .t permits no one but DBEs to compete for the contract Firrns other than DBEs are not eligible to bid The Department's DEE program has never required the use of set -asides and has allowed recipients to use set -asides only under very limited circumstances. Under the SNPRM, a recipient could use a set-aside on a DOT -assisted contract only if other methods of meeting overall goals were demonstrated to be unavailing and the recipient had legal authority independent of part 26 Comments were divided concerning the use of set -asides A number of non -DBE contractors opposed the use of set -asides, some of them saying that set -asides might be something they could live with if their use were balanced by the elimination of DBE contract goals on other contracts in the same field. Some recipients and DBEs said, however, that set -asides were a useful tool to achieve goals, particularly for start-up contractors or shall contracts. The Department has carefully reviewed these comments and continues to believe that set -asides should not be used in the DBE program unless they are absolutely necessary to address a specific problem when no other means would suffice. If a recipient has been unable to remedy the effects of egregious discrimination through other means, it may, as a last resort, make limited use of set -asides to the extent necessary to resolve the problem. Section 26.45 How Do Recipients Sec Overall Goals? Since its inception, the recipient's overall goal has been the heart of the DBE program. Responding to Adarand, DOT clarified the theory and purpose of the overall goal in the SNPRM. In the proposed rule, the Department made clear that the purpose of the overall goal—and, in fact, the DBE program as a whole—is to achieve a "level playing field" for DBEs seeking to participate in federal -aid transportation contracting. To reach a level playing field, recipients need to examine their programs and their markets and determine the amount of participation they would expect DBEs to achieve in the absence of discrimination and the effects of past discrimination. The focus of the goal section of the SNPRM was to propose ways to measure what a level playing field would look like and to seek input on the availability of data to make such a measurement. The Proposed Rule and Comments The Department proposed several options that recipients might use for setting overall goals, including three alternative formulas for measuring the availability of ready sviiling and able DBEs in local markets The specific formulas will be discussed below, but generally. they each called for setting a goal that reflected the percentage of locally available firms that were DBEs (i.e dividing the number of DBEs by the number of all businesses). On all of the alternatives, the SNPRM sought comments on both the feasibility and practical value of the options, as well as the prospects for combining any of the approaches and the question of whether to mandate a single approach or allow each recipient to choose amongst the options. We invited commenters to propose changes to any of the details of the options or to devise entirely new ones. Finally, we asked commenters for their input on the availability of reliable data for use with each of the options. Hundreds of commenters of all types—including DBEs and non -DBEs, prime and subcontractors, state and local recipients, industry and interest groups and private individuals— responded with a wealth of feedback, opinions and data. It is an understatement to say that there was no consensus among commenters as to the best way to set overall goals Support for the proposed options was almost evenly spread over the choices presented, with many commenters firmly against all of the options. Still more suggested that the current, non -formulaic method was the best way to ensure the flexibility to respond to local market conditions Similarly, among those who expressed an opinion, commenters were split between the propriety of choosing a single "best" method and imposing it on all recipients and allowing recipients to choose amongst all the options. One of the few universal themes in the goal - setting comments was the problem of the availability of reliable data on the number of DBE and non -DBE contractors. There were a few common threads that different groups of commenters tended to apply to all of the formulas. Among recipients, many comments focused on the lack of data about non - DBE contractors, especially subcontractors Recipients often noted that they would not have the information needed for the denominator of any of the formulas (i.e. the total number of available businesses). Non - DBE contractors—and industry groups representing them—generally believed that there should be a capacity measure built into any goal setting mechanism Finally, DBEs—and their industry associations—were concerned that all of the formulas would create goals based only on the current number of DBEs, locking in the effects of past discrimination In ignoring the fact that the lack of opportunities in the past has suppressed the number of DBE firms available today Under the proposed rule's Alternative 1, recipients would calculate the percentage of DBE firms in their directories among all firms available to work on their DOT -assisted contracts Under Alternative 2. recipients would - calculate the percentage of all minority - and women -owned firms in certain SIC codes in their areas among all firms in these SIC codes in the same areas. Under Alternative 3, recipients would calculate a percentage based on the average number of DBE firms that had worked on their DOT -assisted contracts in recent years divided by the average number of all firms that had worked on their DOT -assisted contracts in the same period. The SNPRM also proposed that recipients could use other means, such a disparity studies or goals developed by other recipients serving the same area, as a basis for their goals. Each of the three proposed alternatives received some support, though this was often the rather tepid endorsement of commenters who felt that one or another alternative was the Federal Register /Vol. 64, No. 21 /Tuesday, February 2, 1999 / Rules and Regulations 5109 best of a bad lot. Non -DBE contractors often claimed that the alternatives would unfairly increase goals, while DBE contractors often claimed that the same proposals would unfairly decrease goals. Commenters said that data for determining the denominators of the equations in Alternatives 1 and 2, as well as the numerator in Alternative 2, did not exist and that it would be a major, time-consuming job to begin to obtain the data. Adaptation of existing information from other sources (e.g., Census data) was said to have significant statistical difficulties. The difficulty of getting data on out-of-state firms was emphasized in some comments Commenters looked on the alternatives as cumbersome, creating unreasonable administrative burdens, and as producing statistical results that were skewed in various ways. The use of DBE directories as the source of the numerator in Alternative 1 was criticized on the basis that directories may contain firms that never actually participate in DOT -assisted contracts. It was suggested that the number of firms bidding rather than the number of firms certified would be a more reliable guide, but it was also pointed out that, because subcontractors seldom formallv bid for work, this data would be hard to obtain Some commenters proposed adding overall population statistics to the mix. A significant number of commenters—primarily non -DEE contractors but including some recipients and other commenters as well—emphasized the need to take "capacity" into account. Most popular among these comments was using a capacity version of Alternative 3 These comments did not propose a method of determining the capacity of the firms contracting with the recipient. The Final Rule In view of the complexity and importance of the goal setting process and the many issues raised by commenters, the Department has decided to adopt a two step process for goal setting The process is intended to provide the maximum flexibility for recipients while ensuring that goals are based on the availability of ready, willing and able DBEs in each recipient's relevant market. The Department believes that this approach is critical to meeting our constitutional obligation to ensure that the program is narrowly tailored to remedy the effects of discrimination. The first step of the process will be to create a baseline figure for the relative availability of ready, willing and able DBEs in each recipient's market. The second step will be to make adjustments from the base figure, relying on an examination of additional evidence, past experience, local expertise and anticipated changes in DOT -assisted contracting over the coming year. Step 1: Determining a Base Figure for the Overall Goal The base figure is intended to be a measurement of the current percentage of ready, willing and able businesses that are DBEs. Ensuring that this figure is based on demonstrable evidence of each recipient's relevant market conditions will help to ensure that the program remains narrowly tailored. To be explicit. recipients cannot simply use the 10 percent national goal, their goal from the previous year. or their DBE participation level from the previous year as their base figure. Instead, all recipients must take an actual measurement of their marketplace, using the best evidence they have available, and derive a base figure that is as fair and accurate a representation as possible of the percentage of available businesses that are DBEs There are many different ways to measure the contracting market and assess the relative availability of DBEs. As discussed abo\ e the SNPRNI proposed three ai:e-nate forrnulas,to measure relative a\ailabil.ty, none of which were par ticuiarl popular v ith commenters in Cris final rule, the Department is plac.--ig primary emphasis on the principles underlying the measurement. mandating only that a measurement of the relative availability of DBEs be made on the basis of demonstrable evidence of relevant market conditions, rather than requiring that any particular procedure or formula be used. The final rule contains a number of examples of how to create a base figure which recipients are free to adopt in their entirety or to use as guidelines for how to devise their own measurement. There are several reasons we have taken this approach. First, the Department is aware of the differences in available data in various markets across the nation. The flexibility inherent in this approach will ensure that all recipients can use the procedure to set a reasonable goal and allow each recipient to use the best data available to it. As discussed in another section, this rule will also provide for the development of more standard data for future goal setting Second, for many recipients, setting goals in this way will be a new exercise. By fixing only the basic principle, but allowing the methodology to change, recipients will have the opportunity to fine tune the process each year as their experience grows and the data available to them improve. Finally. the rule makes sure that every recipient will have at least one reasonable and practical goal setting method available to them. The first example for setting a base figure relies on data sources that are immediately available to all recipients. their DBE directories. and a Census Bureau database that DOT and the Census Bureau will make available to all recipients that wish to use it. This example has its roots in the first two goal setting formulas proposed in the SNPRM. Recipients would first assess the number of ready, willing and able DBEs based on their own directories. For some recipients this will be as simple as counting the number of firms in their directory. For others, particularly those using directories maintained by other agencies, the directories will have to be "filtered" for firms involved in transportation contracting. The resulting number of DBEs would become the numerator. The denominator would then be derived from the Census Bureau's County Business Pattern (CBP) database. We will provide user-friendly electronic access to the database via the Internet to allow recipients to input the geographic area and SIC cedes in which they contract and receive a number for the availability of all businesses There are several issues that must be addressed when comparing numbers derived from two different data sources, some of which were raised in the comments on the SNPRM Recipients will need to ensure that the scope of businesses included in the numerator is as close as possible to the scope included in the denominator Using as close as possible to the same SIC codes and geographic base is very important. A recipient using its own DBE directory, particularly one that contains only firms in the fields in which it contracts, will still need to determine what fields it will use for the denominator when sorting through the CBP database. The best way to do this would be to examine their contracting program and determine the SIC codes in which they let the substantial majority of their contracts and subcontracts The geographic area used for both the numerator and the denominator should cover the area from which the recipient draws the substantial majority of its contractors. While it may be sufficient for some state recipients to use their state borders as their contracting area, local transit and airport recipients will rarely have such an obvious choice. Those recipients will need to more carefully examine the 5110 Federal Register/Vol. 64, No. 21/Tuesday, February 2, 1999/Rules and Regulations geographic area from which they draw contractors and base their calculation of both the numerator and denominator of the equation on the same area. The Department and the Census Bureau will make the CBP data available in a format that gives recipients as much flexibility as possible to tailor the data to their contracting programs. Recipients will be able to extract the data in one block for all of the SIC codes they expect to contract in, or by individual SIC codes, allowing them to weight the relative availability of DBEs in various fields, giving more weight to the fields in which they spend more money. For example, let us assume a recipient estimates that it will expend 10% of its federal aid funds within SIC code 15, 40% in SIC code 16. 25% in SIC code 17, and the remaining 25% on contracting spread over SIC codes 07, 42 and 87. The recipient could separately determine the relative availability of DBEs for each of the three major construction SIC codes (i.e., 15, 16 and 17) and the relative availability of DBEs in the other three SIC codes grouped together and weight each according to the amount of money to be spent in each area. In this example, the recipient could calculate its weighted base figure by first determining the number of DBEs in its directory for each of the groups, then extracting the availability of CBP businesses for the same groups. It would then perform the following calculation to arrive at a base figure for step one of the goal setting process: Base _(DBEs in SIC 15) (DBEs in 16) (DBEs in 17) (DBEs in 07,42,87)1 Figure— •10 x 100 CBPs in SIC 15 CBPs in 16 CBPs in 17 CBPs in 07,42,87 As has been stated generally. this formula is offered only as an example of a way that a recipient could choose to use the CBP database. Recipients using the CBP data should choose whether to weight their calculation. and whether to do so by individual SIC codes or by groups of SIC codes, based on their own assessment of what method will best fit their spending pattern 1 Finally, there is still the question of the propriety of comparing data from two sources as different as DBE directories and the CEP As mentioned aboN. e some commenters asserted that the directories may contain firms that do rot nor nail` perform DOT -assisted contracts, This problem is greatest, of course. for directories maintained by ether agencies for purposes beyond DOT -assisted contracting We believe that the recipient s knowledge of its contracting needs and the contents of its DBE directory will allow it to solve this problem by sorting the directories by SIC code to extract only the firms likely to be interested in DOT -assisted contracting Any remaining effect from DBEs that are certified in the relevant SIC codes but still do not intend to compete for DOT -assisted contracts will be more than offset by the hurdles involved in actually becoming a DBE. It is important to note here that the certification process itself, with its paperwork, review and on-site inspection, create a filter on the number of existing firms that will be counted in the numerator without there being any equivalent filter culling firms out of the denominator. Ultimately, the Department chose these two data sources for the example because; while they may not be perfect. they represent while it is not statistically necessary CO account for _00% of program dollars when performing this type of weighting, the greater the percentage accounted for, the more accurate the resulting calculation will be. the best universally available current data on both the presence of DBEs and the presence of all businesses in local markets. Any recipient that believes it has available to it better sources of local data from which to make a similar calculation for its base figure is encouraged to use them. The second example for calculating a base figure is using a bidders list to determine the relative availability of DBEs The concept is similar to the one described above The recipient would divide the number of available ready, willing and able DEEs by the number for all firms The d.ffere-'ce is that instead of measuring availability. by DBE certifications and Census data the recipient would measure availability by the nurrbe- cf firms that have directly participated in, or attempted to participate in, DOT -assisted contracting in the recent past. This approach has its roots in Alternative 3 from the SNPRM. Of fundamental importance to this approach is that the recipient would need to include all firms that have sought DOT -assisted contracts. regardless of whether they did so by bidding on a prime contract or quoting a job as a subcontractor. Because most DOT recipients derive the substantial majority of their DBE participation through subcontracting, it is absolutely essential that all DBE and non -DBE firms that quote subcontracts be included in the bidders list.2 Bidders lists are a very focussed measure of ready, willing and able firms because they filter the pool of available firms by requiring a demonstration of their ability to participate in the process through tracking and identifying 2To prevent any confusion, it is important to note that the DBE program does not use the so-called "benchmarking system employed in direct Federal procurement. The benchmarking system relies on a unique database created specifically for use in the federal procurement program. contracting opportunities, understanding the requirements of a particular job and assembling a bid for it. Another attractive feature of the bidding "filter" is that it applies equally to both DBEs and non -DBEs. The third example included in the final rule for setting a base figure is using data derived from a disparity study. As was discussed in the SNPRM, the Department is not requiring recipients to do a disparity study, but is only making clear that use of disparity study data by recipients that have them or choose to conduct them is a valid means of setting a goal. Disparity studies generally contain a wide array of statistical data. as well as anecdotal data and analysis that can be particularly useful in the goal setting process We list disparity studies here, not because they are needed to justify operating the DBE program—Congress has already established the compelling need for the DBE program—but because the data a good disparity study provides can be an excellent guide for a recipient to use to set a narrowly tailored goal. The Department will not set out specific requirements for what data or analysis is required before a disparity study can be used for setting a goal, because we believe that the design and conduct of the study is best left to the Local officials and the professional organizations with which they contract to conduct the studies. Instead, we again offer simple general principles that should apply to all studies used for goal setting. Any study data relied on in the goal setting process should be as recent as possible and be focussed on the transportation contracting industry. When setting the goal, first use the study's statistical evidence to set a base figure for the relative availability of DBEs. Other study information, whether it is anecdotal data, analysis or statistical information about related Federal Register /Vol. 64, No. 21 / Tuesday, February 2, 1999 /Rules and Regulations 5111 fields. should be included when making adjustments to the base figure (discussed in more detail below), but not included in the base figure for the relative availability of DBEs. The last specific example included in the rule is using the goal of another recipient as the base figure for goal setting. This option was also included in the SNPRM. It is intended to avoid duplicative work and to lighten the burden the goal setting process might put on smaller recipients. It is important to note that a recipient could only use another recipient's goal if it was set in accordance with this rule and the other recipient performed similar contracting in a similar market area. Using another recipient's approved goal would only satisfy the first step of the goal setting process. It would serve as the base figure, and could not be used to skip over step two of the process. The recipient would need to examine the same additional evidence it would otherwise use to determine whether to adjust its goal from the base figure, as well as being required to make adjustments to account for differences in its local market or contracting program. The final rule also maintains the option of devising an alternative method of calculating a base figure for the goal setting, process Explicitly listing this option ser% es to emphasize the point that the options in the rule are examples mean: as guidelines intended to ensure maximum flexibility for recipients Recipients can use this option to take advantage of their unique expertise or any unique source of data that they have that may not be available to other recipients The concerned operating administration will review and approve the proposals of recipients that believe they can calculate a base figure that will better reflect their relevant market than any of the examples provided in this rule. Approval will be contingent on the proposals following the same principles that apply to any recipient: the methodology must be based on demonstrable data of relevant market conditions and be designed to reach a goal that the recipient would expect DBEs to achieve in the absence of discrimination Step 2• Adjusting the Base Figure As alluded to above, measuring the relative availability of DBEs to derive a base figure is only the first step of the goal setting process. To ensure that they arrive at goals that truly and accurately reflect the participation they would expect absent the effects of discrimination. recipients must go beyond the formulaic measurement of current availability to account for other evidence of conditions affecting DBEs. To accomplish this second step, recipients must first survey their: jurisdiction to determine what types of relevant evidence is available to them. Then, relying on their own knowledge of their contracting markets they must review the evidence to determine whether either an up or down adjustment from the base figure is needed. One universally available form of evidence that all recipients should consider is the proven capacity of DBEs to perform work on DOT -assisted contracts. All recipients have been tracking and reporting the dollar volume of work that is contracted and subcontracted to DBEs each year Viewed in isolation, the past achievements of DBEs do not reflect the availability of DBEs relative to all available businesses, but it is an important and current measure of the ability of DBEs to perform on DOT - assisted contracts Though not universally available, there are hundreds of existing disparity studies that contain a wealth of statistical and anecdotal evidence on the utilization cf disadvantaged businesses In addition to being a possible source of data for Step 1 of the goal setting process, disparity studies should be - considered during Step 2 of the process The base figure from Step 1 is intended to deter:rine the relative availability of DBEs The data and analysis in a disparity study can help a recipient determine whether those existing businesses are under- or over -utilized If a recipient has a study with disparity ratios showing that existing DBEs are receiving significantly less work than expected, an upward adjustment from the base figure is called for Similarly, if the disparity ratio shows overutilization, a downward adjustment to the base figure would be warranted. The anecdotal evidence and analysis of contracting requirements and conditions that may have a discriminatory impact on DBEs are also important sources that should be examined when determining what adjustment to make to the base figure 3 Finally, disparity studies that are conducted within a recipient's jurisdiction should be examined even if they were not done specifically for the recipient. For example, a state highway agency may find useful data and 3 It is important to note that adjusting the goal is only part of the response a recipient should make to evidence of discriminatory barriers for DBEs. All recipients have a primary responsibility to ensure non-discrimination in their proerms and should act aggressively to remove any discriminatory barriers in their programs. analysis in either a statewide disparity study covering other agencies or in a disparity study examining contracting in a county or city within the state. If a recipient uses another recipient's goal as its base figure under Step 1 of the goal setting process, it will have to make additional adjustments to ensure that its final goal is narrowly tailored to its market and contracting program. For example, if a local transit or airport authority adopts a statewide goal as its base figure, it must determine the extent that local relative availability of DBEs differs from the relative availability of DBEs in the contracting area relied on by the state. The local recipient would also need to examine the differences in the type of contracting work in its program and determine whether there are significant differences in the relative availability of DBEs in any fields that are unique to its program—or unique to the program of the other recipient. Similarly, if one local recipient used the goal of another local recipient in the same market as its base figure, it would also need to adjust for differences in the contracting fields used by the two programs Finally, the rule contains a brief list of other types of data a recipient could consider when adjusting its base figure to arrive at an overall goal The list is by no means intended to be exhaustive Instead, it is meant as a guide to the types of information a recipient should look for in Step 2 of the goal setting process There is a wide array of relevant local, regional and national information about the utilization of disadvantaged businesses Recipients are encouraged to cast as wide a net as they can to carefully examine their contracting programs and the public and private markets in which they operate. Additional Goal Setting Issues The Department proposed, in both the 1992 NPRM and the 1997 SNPRM. that overall goals be calculated as a percentage of DOT funds a recipient expects to expend in DOT -assisted contracts This is different from the existing part 23 rule, which asked recipients to set overall goals on the basis of all funds, including state and local funds, to be expended in DOT - assisted contracts This change is for accounting and administrative convenience and is not intended to have a substantive effect on the program. While not the subject of many comments, those who did comment on the proposal favored the change The final rule adopts this approach. A few recipients commented that public participation concerning goal setting was bothersome Nevertheless, 5112 Federal Register /Vol. 64, No. 21 / Tuesday, February 2, 1999 / Rules and Regulations we view it as an essential part of the goal setting process. There are many stakeholders involved in setting goals, and it is reasonable that they should be involved in the process and have an opportunity for comment. The part 23 provision requiring getting a state governor's approval of a goal of less than 10 percent has been eliminated, both because overall goals are no longer tied to the national 10 percent goal and to reduce administrative burdens. The goal setting provision of the final rule continues to direct recipients to set one annual overall goal for DBEs, rather than group -specific goals separating minority and women -owned businesses. Section 26.47 Can Recipients Be Penalized for Failing To Meet Overall Goals? This is a new section of the regulation, the purpose of which is to clarify the Department's views on the situations in which it is appropriate to impose sanctions on recipients with respect to goals The provision states explicitly what has long been the Department's policy no recipient is sanctioned, or found in noncompliance. simply because it fails to meet its overall goal. In fact, through the history of the DBE program, the Department never has sanctioned a recipient for failing to obtain a particular amount of DEE participation On the other hand, if a recipient fails to set an overall goal which the concerned operating administration approves, or fails to operate its program in good faith toward the objective of meeting the goal, it is subject to a finding of noncompliance and possible sanctions. For example, if a recipient refuses to establish a goal or, having established one, does little or nothing to work toward attaining it, it would be reasonable for the Department to find the recipient in noncompliance. Like all compliance provisions of the rule, this provision is subject to the "court order" exception recently created by statute (see §26 101(b)) Section 26 49 How Are Overall Goals Established for Transit Vehicle Manufacturers? This provision basically continues in effect the existing transit vehicle manufacturer (TVM) provisions of the rule The SNPRM proposed to change the existing rule in two respects FHWA or FAA recipients could avail themselves of similar provisions. if they chose The final rule retains this flexibility Also, it was proposed that FTA, rather than manufacturers, would set TVM goals The few comments we received on this section objected to the latter change. Consequently, we will not adopt the proposed change and will continue to require the TVMs themselves to set their own goals based on the principles outlined in § 26.45 of this rule. Section 26.51 What Means Do Recipients Use To Meet Overall Goals? One of the key points of both the SNPRM and this final rule is that, in meeting overall goals, recipients have to give priority to race -neutral means. By race -neutral means (a term which, for purposes of this rule. includes gender neutrality), we mean outreach, technical assistance, procurement process modification, etc.—measures which can be used to increase opportunities for all small businesses, not just DBEs. and do not involve setting specific goals for the use of DBEs on individual contracts. Contract goals, on the other hand, are race -conscious measures In the context of these definitions, it is important to note that awards of contracts to DBEs are not necessarily race -conscious actions Whenever a DBE receives a prime contract because it is the lowest responsible bidder, the resulting DBE participation was achieved through race -neutral means. Similarly, when a DBE receives a subcontract on a project that does not have a contract goal, its participation was also achieved through race -neutral means Finally. even on projects that do carry contract goals, when a prime awards a particular subcontract to a DBE because it has proven in the past that it does the best or quickest work, or because it submitted the lowest quote, the resulting DBE participation has, in fact, been achieved through race -neutral means. We also note that the use of race - neutral measures (e g., outreach, technical assistance) specifically to increase the participation of DBEs does not convert these measures into race - conscious measures A number of non -DBE contractors commented that race -neutral measures should not only be given priority, but must be tried and fail before any use of contract goals can occur. This, they asserted, is essential for a program to be narrowly tailored. The law on this point is fairly clear, and does not support the commenters' contention. The extent to which race -neutral alternatives were considered and deemed inadequate to remedy the problem is the relevant narrow tailoring question Both in past legislation and when considering TEA - 21, Congress did consider race -neutral alternatives In fact, as described above, throughout the debate, Member after Member gave examples of how state and local race -neutral programs without goals fail to overcome the discriminatory barriers that face DBEs. Congress' careful consideration and conclusion that race -neutral means are insufficient, buttressed by this rule's emphasis on achieving as much of the goal as possible through race -neutral means, satisfies this part of the narrow tailoring requirement. No one opposed the use of race - neutral means, though a number of DBEs and recipients stressed that these means, standing alone, were insufficient to address discrimination and its effects. Most recipients and non -DBE contractors supported the use of race - neutral measures, though some recipients said that increased use of these measures would require additional resources. The relationship between race - conscious and race -neutral measures in the final rule is very important. The recipient establishes an overall goal. The recipient estimates, in advance, what part of that goal it can meet through the use of race -neutral means This projection. and the basis for it, would be provided to the concerned operating administration at the same time as the overall goal, and is subject to OA approval The requirement of the rule is that the recipient get the maximum feasible DBE participation through race -neutral means The recipient uses race - conscious measures (e.g., sets contract goals) to get the remainder of the DBE participation it needs to meet the overall goal If the recipient expects to be able to meet its entire overall goal through race -neutral means, it could, with OA approval, implement its program without any use of contract goals. For example, suppose Recipient X establishes an 11 percent overall goal for Fiscal Year 2000 This is the amount of DBE participation that X has determined it would have if the playing field were level. Recipient X projects that, using a combination of race -neutral means, it can achieve 5 percent DBE participation. Recipient X then sets contract goals on some of its contracts throughout the year to bring in an additional 6 percent DBE participation. Recipients would keep data separately on the DBE participation obtained through those contracts that either did or did not involve the use of contract goals. Recipients would use this and other data to adjust their use of race - neutral means and contract goals during the remainder of the year and in future years For example, if Recipient X projected being able to attain 5 percent DBE participation through race -neutral measures, but was only able to obtain 1 percent from the race -neutral measures Federal Register /Vol. 64, No. 21 / Tuesday,,' February 2, 1999 /Rules and Regulations 5113 it used, Recipient X would increase its future use of contract goals. On the other hand, if Recipient X exceeded its prediction that it would get 5 percent DBE participation from race -neutral measures and actually obtained 10 percent DBE participation from the contracts on which there were no contract goals, it would reduce its future use of contract goals. A recipient that was consistently able to meet its overall goal using only race -neutral measures would never need to use contract goals Most recipients and non -DBE contractors agreed with the SNPRM's proposal that (contrary to the part 23 provision on this subject) contract goals not be required on all contracts. This provision is retained in the final rule. We believe that this provision provides recipients the ability to achieve the objective of a narrowly tailored program. The rule also reiterates that the contract goal need not be set at the same level as the overall goal. To express this more clearly, let us return to the above example of Recipient X. Just because Recipient X has an overall goal of 11 percent, it does not have to set a contract goal on each contract. Nor does it have to establish an 11 percent goal on each contract on which it does set a contract goal Indeed, since X has projected that it can achieve almost half of its overall goal through race -neutral means it most likely set contract goals cn some contracts but not on others On contracts with a contract goal. the goal might be 4 percent one time, 18 percent another time, 9 percent another time, depending on the actual work involved in each contract, the location of the work and the subcontracting opportunities available. The idea is for X to set contract goals that, cumulatively over the year, bring in 6 percent DBE participation, which, added to the 5 percent participation X projects achieving from race -neutral measures, ends up meeting the 11 percent overall goal. The SNPRM asked for comment on evaluation credits as an additional race - conscious measure that recipients could use to meet overall goals The vast majority of the many comments on this subject opposed the use of evaluation credits, on both legal (e g., as contrary to narrow tailoring) and policy (e.g., as confusing and subjective) grounds. A smaller number of commenters favored at least giving recipients discretion to use this tool. While the Department does not agree with the contention that evaluation credits are legally suspect, we do agree with much of the sentiment against using them in the DBE program, particularly the practical difficulties they might involve when applied to subcontracting (which constitutes the main source of DBE participation in the program). As a result, the final rule does not contain an evaluation credits provision. The SNPRM proposed certain mechanisms for determining when it was appropriate to ratchet back the use of contract goals. Most commenters said they found these particular mechanisms complicated and confusing. The Department believes that, as a matter of narrow tailoring, it is important to have concrete mechanisms in place to ensure that race -conscious measures like contract goals are used only to the extent necessary to ensure a level playing field. The final rule contains examples of four such mechanisms. The first mechanism applies to a situation in which a recipient estimates that it can meet its overall goal exclusively through the use of race - neutral goals. In this case. the recipient simply does not set contract goals during the year The second mechanism takes this approach one step further. If the recipient meets its overall goal two years in a row using only race -neutral measures, the recipient continues to use only race -neutral measures in future years, without having to project each year how much of its overall goal it anticipates meeting through race -neutral and race -conscious means, respectively However, if in any year the recipient does not meet its overall goal, the recipient must make the projection for the following year, using race -conscious means as needed to meet the goal The third mechanism applies to recipients who exceed their overall goals for two years in a row while using contract goals. In the third year, when setting their overall goal and making their projection of the amount of DBE participation they will achieve through race -neutral means, they would determine the average percentage by which they exceeded their overall goals in the two previous years. They would then use that percentage to reduce their reliance on contract goals in the coming year, as noted in the regulatory text example. The rationale for this reduction is that the recipient's overall goal represents its best estimation of the participation level expected for DBEs in the absence of discrimination. By exceeding that goal consistently, the recipient may be relying too heavily on race -conscious measures Scaling back the use of contract goals—while keeping careful track of DBE participation rates on projects without contract goals—will ensure that the recipient's DBE program remains narrowly tailored to overcoming the continuing effects of discrimination The fourth mechanism operates within a given year If a recipient determines part way through the year that it will exceed (or fall short of) its overall goal, and it is using contract goals during that year, it would scale back its use of contract goals (or increase it use of race -neutral means and/or contract goals) during the remainder of the year to ensure that it is using an appropriate balance of means to meet its "level playing field" objectives. There were also a number of comments on how contract goals should be expressed. Most favored continuing the existing practice of adding together the Federal and local shares of a contract and expressing the contract goal as a percentage of the sum because it works well and avoids confusion. A few comments favored expressing contract goals as a percentage of only the Federal share of a contract. Ultimately, we believe that it is not necessary for the Department to dictate which method to use Recipients may continue to use whichever method they feel works best and allows them to accurately track the participation of DBEs in their program. Recipients need only ensure that they are consistent and clearly express the method they are using. and report to the Department the total federal aid dollars spent and the federal aid dollars spent with DBEs As a last note on this topic. FAA recipients are reminded that funds derived from passenger facility charges (PFCs) are not covered by this part and should not be counted as part of the Federal share in any goal calcuiation If a recipient chooses to express its contract goals as a percentage of the combined Federal and local share, it may include the PFC funds as part of the local share. Section 26 53 What Are the Good Faith Efforts Procedures Recipients Follow in Situations Where There Are Contract Goals? There was little disagreement about the main point of this section. When a recipient sets a contract goal, the basic obligation of bidders is to make good faith efforts (GFE) to meet it. They can demonstrate these efforts in either of two ways, which are equally valid. First, they can meet the goal, by documenting that they have obtained commitments for enough DBE participation to meet the goal. Second, even though they have not met the goal, they can document that they have made good faith efforts to do so The Department emphasizes strongly that this requirement is an important and serious one A refusal by a recipient to accept valid showings of 5114 Federal Register /Vol. 64, No. 21 /Tuesday, February 2, 1999 / Rules and Regulations good faith is not acceptable under this rule. Appendix A discusses in greater detail the kinds of good faith efforts bidders are expected to make. There was a good deal of comment concerning its contents. Non -minority contractors recited that good faith efforts standards should be "objective, measurable, realistically achievable, and standardized." Not one of these comments provided any examples or suggestions of what "objective, measurable, realistically achievable, and standardized" standards would look like, however. Certainly a one -size -fits - all checklist is neither desirable nor possible. What constitutes a showing of adequate good faith efforts in a particular procurement is an intrinsically fact -specific judgment that recipients must make Circumstances of procurements vary widely, and GFE determinations must fit each individual situation as closely as possible. The proposed good faith efforts appendix suggested that one of the factors recipients could take into account is the behavior of bidders other than the apparent successful bidder For example, if the latter failed to meet the contract goal, but other bidders did, that could suggest that the apparent successful bidder had not exerted suffic_ent efforts to get DBE parti:_paticn Recipients who commented on this issue favored the concept. non -DBE contractors opposed 1: The final rule s Appendix A makes clear that recipients are not to use a "conclusive presumption" approach, in which the apparent successful bidder is summarily found to have failed to make good faith efforts simply because another bidder was able to meet the goal. However, the track record of other bidders can be a relevant factor in a GFE determination, in more than one way If other bidders have met the goal, and the apparent successful bidder has not, this at least raises the question of whether the apparent successful bidder's efforts were adequate. It does not, by itself. prove that the apparent successful bidder did not make a good faith effort to get DBE participation, however On the other hand. if the apparent successful bidder—even if it failed to meet the goal—got as much or more DBE participation than other bidders, then this fact would support the apparent successful bidder's showing of GFE. The revised Appendix makes these points The proposed good faith efforts appendix also expanded on language in part 23 concerning price -based decisions by prime contractors The existing language provides that a recipient can use, as evidence of a bidder's failure to make good faith efforts, the recipient's rejection of a DBE subcontractor's "reasonableprice" offer. The SNPRM added that a recipient could set a price differential from 1-10 percent to evaluate bidders' efforts. If a bidder did not meet the goal and rejected a DBE offer within the range, the recipient could view the bidder as not making good faith efforts. This was an attempt to provide additional, quantified, guidance to recipients on this issue. Comment was mixed on this issue. Non -DBE prime contractors generally opposed the price differential idea, saying that it encouraged deviations from the traditional low bid system. It should be noted, however, that subcontracts are typically awarded outside any formal low bid system. Some recipients thought that it was a bad idea to designate a range, because it would limit their discretion, while others liked the additional definiteness of the range. Most recipients supported the "reasonable price" concept in general, even if they had their doubts about the value of a range. Some DBE organizations favored the range approach. Taking all the comments into consideration. the Department has decided to retain language similar to that of part 23 without reference to anv specific range Appendix A now provides that the fact that some additional costs may be invol\•ed in finding and using DBEs is not in itself sufficient reason for a bidder's failure to meet a DEE contract goal, as long as such costs are reasonable Along with this emphasis on the reasonableness of the cost necessarily comes the fact that prime contractors are not expected to bear unreasonable costs. The availability of a good faith efforts waiver of the contract goal helps to ensure that a prime contractor will not be in a position where it has to accept an excessive or unreasonable bid from a DBE subcontractor. At the same time, any burden that a non -DBE subcontractor might face is also limited by the reasonableness of competing bids. This approach retains flexibility for recipients while avoiding the concerns commenters expressed about a particular range. The SNPRM proposed that recipients would have to provide for an administrative review of decisions that a bidder's GFE showing was inadequate. The purpose of the provision was to ensure that recipients did not arbitrarily dismiss bidders' attempts to show that they made good faith efforts. The provision was meant to emphasize the seriousness with which the Department takes the GFE requirement and to help respond to allegations that some recipients administered the program in a quota -like fashion. The SNPRM also asked whether such a mechanism should be operated entirely by the recipient or whether a committee including representatives of DBE and non -DBE contractors should be involved. A number of recipients. and a few contractors. opposed the idea on the basis of concern about administrative burdens on recipients and potential delays in the procurement process. A greater number of commenters, largely non -DBE contractors but also including recipients and DBEs, supported the proposal as ensuring greater fairness in the process. A significant majority of all commenters said that the recipient should operate the system on its own. because a committee would make the process more cumbersome and raise conflict of interest issues. The Department will adopt this proposal, which should add to the fairness of the system and make allegations of de facto quota operations less likely. The Department intends that reconsideration be administered by recipients. The regulation does not call for a committee involving non -recipient personnel. The Department intends that the process be informal and timely The recipient could ensure that the process be completed within a brief period (e g , 5-10 days) to minimize any potential delay in procurements. The bidder would have an opportunity to meet with the reconsideration official, but a formal hearing is not required. To ensure fairness, the reconsideration official must be someone who did not participate in the original decision to reject the bidder's showing. The recipient would have to provide a written decision on reconsideration, but there would be no provision for administrative appeals to DOT. A point raised by several non -DBE commenters was that DBEs should have to make good faith efforts (even when they were not acting as prime contractors). The commenters suggested things like providing capacity statements and documenting that they have bid on contracts. This point is unrelated to the subject of this section, which has to do with what efforts bidders for prime contracts have to make to show that they have made to obtain DBE subcontractors. It is difficult to see what purpose the additional paperwork burdens these commenters' requests would serve. One of the most hotly debated issues among commenters was whether DBE 5124 Federal Register /Vol. 64, No. 21 /Tuesday, February 2, 1999 /Rules and Regulations commenters wanted a time limit for DOT consideration of appeals. We have added a provision saying that if DOT takes longer than 180 days from the time we receive a complete package, we will write everyone concerned with an explanation of the delay and a new target date for completion. Some commenters thought a different time limit for appeals to the Department (e.g., 180 days) would be beneficial. We believe that 90 days is enough time for someone to decide whether a decision of a recipient or UCP should be appealed and write a letter to DOT. This time period starts to run from the date of the final recipient decision on the matter. DOT can accept late -filed appeals on the basis of a showing of good cause (e.g.. factors beyond the control of the appellant). Some recipients thought that more time might be necessary to compile an administrative record, so we have permitted DOT to grant extensions for good cause. Generally, however, the Department will adhere to the 90 -day time period in order to prevent delays in the appeals process. As a clarification, we have added a provision that all recipients involved must provide administrative record material to DOT when there is an appeal. For example. State A has relied on the information gathered IDN, State B to certify Firm X. A competitor files an ineligibility complaint with State A, which decertifies the firm. Firm X appeals to the Department. Both State A and State B mus: provide their administrative record materials to DOT for purposes of the appeal. (The material would be provided to the Departmental Office of Civil Rights.) Section 26 91 What Actions Do Recipients Take Following DOT Certification Appeal Decisions? There were few comments concerning this section. Some comments suggested DOT appeal decisions should have mandatory nationwide effect. That is if DOT upheld the decertification action of Recipient A. Recipients B, C. D. E, etc. should automatically decertify the firm. This approach is inconsistent with the administrative review of the record approach this rule takes for appeals to DOT A DOT decision that A's decertification was supported by substantial evidence is not a DOT decision that the firm is ineligible. It is only a finding that A had enough evidence to decertify the firm. Other results might also be supported by substantial evidence. Nevertheless, when the Department takes action on an appeal. other recipients would be well advised to review their own decisions to see if any new proceedings are appropriate. One comment suggested the Department should explain a:refusal to accept a complaint. This is already the Department's practice. The SNPRM included a proposal to permit direct third -party complaints to the Department. There were few comments on this proposal, which would have continued an existing DOT practice. Some of these comments suggested dropping this provision. saying it made more sense to have all certification matters handled at the recipient level in the first instance. Others raised procedural issues (e.g., the possibility of the Department holding de novo hearings). The Department has reconsidered this proposal, and we have decided to delete it. We believe it will avoid administrative confusion and simplify procedures for everyone if all certification actions begin at the recipient level, with DOT appellate review on the administrative record. Subpart F—Compliance and Enforcement There were very few comments concerning this subpart, which we are adopting as proposed. One section has been added to reflect language in TEA - 21 that prohibits sanctions against recipients for noncompliance in' situations %.here compliance is precluded by a final Federal court order finding the program unconstitutional DBE Participation in Airport Concessions The Department proposed a number of changes to its airport concessions DBE program rule in the 1997 SNPRM. We received a substantial number of comments on these proposals The Department is continuing to work on its responses to these comments, as well as on refinements of the rule to ensure that it is narrowly tailored. This work is not complete. Rather than postpone issuance of the rest of the rule pending completion of this work, we are not issuing final concessions provisions at this time. The existing concessions provisions of 49 CFR part 23 will remain in place pending completion of the revised rule. Regulatory Analyses and Notices Executive Order 12866 This rule is a significant rule under Executive Order 12866, because of the substantial public interest concerning and policy importance of programs to ensure nondiscrimination in Federally - assisted contracting It also affects a wide variety of parties, including recipients in three important DOT financial assistance programs and the DBE and non -DBE contractors that work for them. It has been reviewed by the Office of Management and Budget. It is also a significant rule for purposes of the Department's Regulatory Policies and Procedures. We do not believe that the rule will have significant economic impacts. however. In evaluating the potential economic impact of this rule, we begin by noting that it does not create a new program. It simply revises the rule governing an existing program. The economic impacts of the DBE program are created by the existing regulation and the statutes that mandate it, not by these revisions. The changes that we propose in this program are likely to have some positive economic impacts. For example, "one-stop shopping" and clearer standards in certification are likely to reduce costs for small businesses applying for DBE certification. as well as reducing administrative burdens on recipients The rule's "narrow tailoring" changes are likely to be neutral in terms of their overall economic impact. These could have some distributive impacts (e.g., if the proposed goal -setting mechanism results in changes in DBE goals, a different mix of firms may work on recipients' contracts), but there would probably not be net gains or losses to the econorm There could be some short- term costs to recipients owing to changes in program administration resulting from "narrow tailoring," however In any event, the economic impacts are quite speculative and appear nearly impossible to quantify Comments did not provide. and the Department does not have, any significant information that would allow the Department to estimate any such impacts. Regulatory Flexibility Act Analysis The DBE program is aimed at improving contracting opportunities for small businesses owned and controlled by socially and economically disadvantaged individuals. Virtually all the businesses it affects are small entities There is no doubt that a DBE rule always affects a substantial number of small entities. This rule, while improving program administration and facilitating DBE participation (e g., by making the certification process clearer) and responding to legal developments, appears essentially cost -neutral with respect to small entities in general (as noted above, the one-stop shopping feature is intended to benefit small entities seeking to participate) It does Federal Register/Vol. 64, No. 21 /Tuesday, February 2, 1999 /Rules and Regulations 5125 not impose new burdens or costs on small entities, compared to the existing rule. It does not affect the total funds or business opportunities available to small businesses that seek to work in DOT financial assistance programs. To the extent that the proposals in this rule (e.g., with respect to changes in the methods used to set overall goals) lead to different goals than the existing rule, some small firms may gain, and others lose. business There is no data of which the Department is aware that would permit us, at this time, to measure the distributive effects of the revisions on various types of small entities. It is likely that any attempt to gauge these effects would be highly speculative. For this reason, we are not able to make a quantitative, or even a precise qualitative, estimate of these effects. Paperwork Reduction Act A number of provisions of this rule involve information collection requirements subject to the Paperwork Reduction Act of 1995 (PRA) One of these provisions, concerning a report of DBE achievements that recipients make to the Department, is the subject of an existing OMB approval under the PRA. With one exception, the other information collection requirements of the rule continue existing part 23 requirements, major elements of the DBE program that recipients and contractors have been implementing since 1980 cr 1983. While the final rule modifies these recuiremencs in some ways, the Department believes the overall burden of these requirements will remain the same or shrink. These requirements are the following: • Firms applying for DBE certification must provide information to recipients to allow them to make eligibility decisions. Currently certified firms must provide information to recipients to allow them to review the firms' continuing eligibility (After the UCP requirements of the rule are implemented, the burdens of the certification provisions should be substantially reduced.) • When contractors bid on prime contracts that have contract goals, they must document their DBE participation and/or the good faith efforts they have made to meet the contract goals. (Given the final rule's emphasis on race -neutral measures, it is likely the burden in this area will be reduced ) • Recipients must maintain a directory of certified DBE firms (Once UCPs are implemented, there will be 52 consolidated directories rather than the hundreds new required, reducing burdens substantially ) • Recipients must calculate overall goals and transmit them to the Department for approval. (The process of setting overall goals is more flexible, but may also be more complex, than under part 23. As they make their transition to the final rule's goal -setting process during the first years of implementation. recipients may temporarily expend more hours than in the past on information -related tasks.) • Recipients must have a DBE program approved by the Department. (The final rule includes a one-time requirement to submit a revised program document making changes to conform to the new regulation.) The Department estimates that these program elements will result in a total of approximately 1.58 million burden hours to recipients and contractors combined during the first year of implementation and approximately 1.47 million annual burden hours thereafter. The final rule also includes one new information collection element. It calls for recipients to collect and maintain data concerning both DBE and non -DBE bidders on DOT -assisted contracts. This information is intended to assist recipients in making more precise determinations of the availability of DBEs and the shape of the "level playing field" the maintenance of which is a major objective of the rule The Department estimates that this requirement will add 254.595 burden hours in the first year of implementation This figure is projected to decline to 193,261 hours in the second year and to 161.218 hours in the third and subsequent years. Both as the result of comments and what the Department learns as it implements the DBE program under part 26, it is possible for the Department's information needs and the way we meet them to change. Sometimes the way we collect information can be changed informally (e.g , by guidance telling recipients they need not repeat information that does not change significantly from year to year) In other circumstances, a technical amendment to the regulation may be needed. In any case, the Department will remain sensitive to situations in which modifying information collection requirements becomes appropriate. As required by the PRA, the Department has submitted an information collection approval request to OMB. Organizations and individuals desiring to submit comments on information collection requirements should direct them to the Department's docket for this rulemaking You may also submit copies of your comments to the Office of Information and Regulatory Affairs (OIRA). OMB. Room 10235, New Executive Office Building, Washington, DC, 20503; Attention: Desk Officer for U.S. Department of Transportation. The Department considers comments by the public on information collections for several purposes: • Evaluating the necessity of information collections for the proper performance of the Department's functions, including whether the information has practical utility. • Evaluating the accuracy of the Department's estimate of the burden of the information collections, including the validity of the methods and assumptions used. • Enhancing the quality, usefulness, and clarity of the information to be collected. • Minimizing the burden of the collection of information on respondents. including through the use of electronic and other methods. The Department points out that, with the exception of the bid data collection. all the information collection elements discussed in this section of the preamble have not only been part of the Department's DBE program for many years, but have also been the subject of extensive public comment following the 1992 NPRM and 1997 SNPRM. Among the over 900 comments received in response to these notices were a number addressing administrative burden issues surrounding these program elements In this final rule. the Department has responded to these comments. OMB is required to make a decision concerning information collections within 30-60 days of the publication of this notice. Therefore, for best effect, comments should be received by DOT/ OMB within 30 days of publication. Following receipt of OMB approval, the Department will publish a Federal Register notice containing the applicable OMB approval numbers. Federalism The rule does not have sufficient Federalism impacts to warrant the preparation of a Federalism assessment. While the rule concerns the activities of state and local governments in DOT financial assistance programs, the rule does not significantly alter the role of state and local governments vis-a-vis DOT from the present part 23 The availability of program waivers could allow greater flexibility for state and local participants. however. List of Subjects 49 CFR Part 23 Administrative practice and procedure, Airports, Civil rights, gwtY 5126 Federal Register /Vol. 64, No. 21 / Tuesday,i February 2, 1999 /Rules and Regulations Concessions, Government contracts. Grant programs -transportation, Minority businesses, Reporting and recordkeeping requirements. 49 CFR Part 26 Administrative practice and procedure, Airports, Civil rights, Government contracts, Grant programs -transportation, Highways and roads, Mass transportation, Minority businesses. Reporting and recordkeeping requirements. Issued this 8th day of January, 1999, at Washington, DC. Rodney E. Slater,, Secretary of Transportation. For the reasons set forth in the 1 preamble, the Department amends 49 CFR subtitle A as follows: PART 23 -PARTICIPATION BY DISADVANTAGED BUSINESS ENTERPRISE IN AIRPORT CONCESSIONS 1. Revise the heading of 49 CFR part 23 as set forth above - 2. Revise the authority citation for 49 CFR part 23 to read as follows' Authority 42 U.S C. 200d et seq., 49 U.S C 47107 and 47123, Executive Order 12138, 3 CFR. 1979 Como , p. 393 Subparts A, C, D, and E -[Removed and Reserved] 3 Remove and reserve subparts A, C. D, and E of part 23 § 23.89 [Amended] 4 Amend § 23 89 as follows• a. In the definition of "disadvantaged business," remove the words "§ 23 61 of subpart D of this part" and add the words "49 CFR part 26", and remove the words "§ 23 61" in the last line of the definition and add the words "49 CFR part 26" b In the definition of "small business concern," paragraph (b), remove the words "523 43(d)" and add the words "5 23.43(d) in effect prior to March 4, 1999 (See 49 CFR Parts 1 to 99 revised as of October 1, 1998 )" c. In the definition of "socially and economically disadvantaged individuals," remove the words "5 23.61 of subpart D of this part" and add "49 CFR part 26- §23.93 6"§23.93 (Amended] 5 Amend § 23 93(a) introductory text by removing the words "5 23.7" and adding the words "5 26 7". § 23.95 (Amended] 6 Amend § 23 95(a)(1) by removing the words "based on the factors listed in §23.45(g)(5)" and adding the words "consistent with the process for setting overall goals set forth in 49 CFR 26.45". 7. In addition, amend § 23.95 as follows: a. In paragraph (0(1), remove the. words "523.51" and add the words "49 CFR part 26, subpart E"; b. In paragraph (f)(2), remove the words "Except as provided in § 23.51(c) , each" and add "Each"; c. Remove paragraph (f)(5): d. In paragraph (g)(1), remove the words "523.53" and add the words "49 CFR part 26, subpart D". § 23.97 [Amended] 8. Amend § 23 97 by removing the words "523.55" and adding the words "49 CFR 26.89". §23.11 [Removed] 9 Remove § 23 111. 10. Add a new 49 CFR part 26, to read as follows. PART 26 -PARTICIPATION BY DISADVANTAGED BUSINESS ENTERPRISES IN DEPARTMENT OF TRANSPORTATION FINANCIAL ASSISTANCE PROGRAMS Subpart A -General Sec. 26 1 What are the objectives of this,par:? 26 3 To whom does this part apply? 26 5 What do the terms used in this part mean" 26 7 What discriminatory actions are forbidden? 26 9 How does the Department issue guidance and interpretations under this part? 26.11 What records do recipients keep and report? 26 13 What assurances must recipients and contractors make? 26.15 How can recipients apply for exemptions or waivers' Subpart B -Administrative Requirements for DBE Programs for Federally -Assisted Contracting 26.21 Who must have a DBE program? 26.23 What is the requirement for a policy statement' 26.25 What is the requirement for a liaison officer? 26 27 What efforts must recipients make concerning DBE financial institutions? 26.29 What prompt payment mechanisms may recipients have? 26 31 What requirements pertain to the DBE directory? 26 33 What steps must a recipient take to address overconcentration of DBEs in certain types of work? 26.35 What role do business development and mentor -protege programs have in the DBE program' 26.37 What are a recipient's responsibilities for monitoring the performance of other program participants? Subpart C -Goals, Good Faith Efforts, and Counting 26.41 What is the role of the statutory 10 percent goal in this program? 26.43 Can recipients use set -asides or quotas as part of this program? 26.45 How do recipients set overall goals? 26.47 Can recipients be penalized for failing to meet overall goals? 26.49 How are overall goals established for transit vehicle manufacturers? 26.51 What means do recipients use to meet overall goals? 26.53 What are the good faith efforts procedures recipients follow in situations where there are contract goals? 26.55 How is DBE participation counted toward goals? Subpart D --Certification Standards 26.61 How are burdens of proof allocated in the certification process? 26.63 What rules govern group membership determinations? 26.65 What rules govern business size determinations? 26.67 What rules govern determinations of social and economic disadvantage? 26.69 What rules govern determinations of ownership? 26 71 What rules govern determinations concerning control? 26.73 What are other ruies affecting certification? Subpart E -Certification Procedures 26 81 What are the requirements for Unified Certification Programs? 26 83 What procedures do recipients folio \.% in making certification decisions' 26 85 W'nat rules govern recipients' denials of initial requests for certification? 26 87 What procedures does a recipient use to remove a DBE's eligibility? 26 89 What is the process for certification appeals to the Department of Transportation? 26.91 What actions do recipients take following DOT certification appeal decisions? Subpart F -Compliance and Enforcement 26.10I What compliance procedures apply to recipients? 26.103 What enforcement actions apply in FHWA and FTA programs? 26 105 What enforcement actions apply in FAA Programs? 26 107 What enforcement actions apply to firms participating in the DBE program? 26 109 What are the rules governing information, confidentiality, cooperation, and intimidation or retaliation? Appendix A to part 26 -Guidance Concerning Good Faith Efforts Appendix B to part 26 -Forms (Reserved[ Appendix C to part 26 -DBE Business Development Program Guidelines Appendix D to part 26 -Mentor -Protege Program Guidelines Appendix E to part 26 -Individual Determinations of Social and Economic Disadvantage Authority: 23 U.5 C 324; 42 U.S.C. 2000d et seq ): 49 U.S,C 1615, 47107, 47113. 47123.. Federal Register/Vol. 64, No. 21 /Tuesday. February 2, 1999 /Rules and Regulations 5127 Sec. 1101(b), Pub. L. 105-178, 112 Stat. 107, 113. Subpart A—General § 26.1 What are the objectives of this part? This part seeks to achieve several objectives. (a) To ensure nondiscrimination in the award and administration of DOT - assisted contracts in the Department's highway. transit, and airport financial assistance programs: (b) To create a level playing field on which DBEs can compete fairly for DOT -assisted contracts; (c) To ensure that the Department's DBE program is narrowly tailored in accordance with applicable law; (d) To ensure that only firms that fully meet this part's eligibility standards are permitted to participate as DBEs; (e) To help remove barriers to the participation of DBEs in DOT -assisted contracts; (f) To assist the development of firms that can compete successfully in the marketplace outside the DBE program; and (g) To provide appropriate flexibility to recipients of Federal financial assistance in establishing and providing opportunities for DBEs § 26.3 To whom does this part apply? (ai If you are a recipient of any of the follow. ing types of funds, this part applies to you. (1) Federal -aid highway funds authorized under Titles I (other than Part B) and V of the Intermodal Surface Transportation Efficiency Act of 1991 (ISTEA), Pub L 102-240, 105 Stat. 1914, or Titles I, III, and V of the Transportation Equity Act for the 21st Century (TEA -21), Pub L. 105-178, 112 Stat. 107 (2) Federal transit funds authorized by Tides I, III, V and VI of ISTEA, Pub. L. 102-240 or by Federal transit laws in Tide 49, U.S. Code, or Titles I, III. and V of the TEA -21, Pub. L. 105-178 (3) Airport funds authorized by 49 USC 47101, et seq. (b) (Reserved' (c) If you are letting a contract, and that contract is to be performed entirely outside the United States, its territories and possessions, Puerto Rico. Guam, or the Northern Marianas Islands, this part does not apply to the contract. (d) If you are letting a contract in which DOT financial assistance does not participate, this part does not apply to the contract. 26.5 What do the terms used in this part mean'? Affiliation has the same meaning, the term has in the Small Business Administration (SBA) regulations, 13 CFR part 121. (1) Except as otherwise provided in 13 CFR part 121, concerns are affiliates of each other when, either directly or indirectly: (i) One concern controls or has the power to control the other; or (ii) A third party or parties controls or has the power to control both; or (iii) An identity of interest between or among parties exists such that affiliation may be found. (2) In determining whether affiliation exists, it is necessary to consider all appropriate factors. including common ownership, common management, and contractual relationships. Affiliates must be considered together in determining whether a concern meets small business size criteria and the statutory cap on the participation of firms in the DBE program. Alaska Native means a citizen of the United States who is a person of one- fourth degree or more Alaskan Indian (including Tsimshian Indians not enrolled in the Metlaktla Indian Community). Eskimo, or Aleut blood,, -or a combination of those bloodlines. The term includes. in the absence of proof of a minimum blood quantum, any citizen whom a Native village or Native group regards as an Alaska Native if their father or mother is regarded as an Alaska Native Alaska Native Corporation (ANC) means anv Regional Corporation, Village Corporation, Urban Corporation. or Group Corporation organized under the laws of the State of Alaska in accordance with the Alaska Native Claims Settlement Act, as amended (43 U.S.C. 1601, et seq ) Compliance means that a recipient has correctly implemented the requirements of this part. Contract means a legally binding relationship obligating a seller to furnish supplies or services (including, but not limited to, construction and professional services) and the buyer to pay for them. Contractor means one who participates, through a contract or subcontract (at any tier), in a DOT - assisted highway, transit, or airport program. Department or DOT means the U.S. Department of Transportation, including the Office of the Secretary, the Federal Highway Administration (FHWA), the Federal Transit Administration (FTA), and the Federal Aviation Administration (FAA). Disadvantaged business enterprise or DBE means a for-profit small business concern— (1) That is at least 51 percent owned by one or more individuals who are both socially and economically disadvantaged or, in the case of a corporation, in which 51 percent of the stock is owned by one or more such individuals; and (2) Whose management and daily business operations are controlled by one or more of the socially and economically disadvantaged individuals who own it. DOT -assisted contract means any contract between a recipient and a contractor (at any tier) funded in whole or in part with DOT financial assistance, including letters of credit or loan guarantees. except a contract solely for the purchase of land. Good faith efforts means efforts to achieve a DBE goal or other requirement of this part which, by their scope, intensity. and appropriateness to the objective, can reasonably be expected to fulfill the program requirement. Immediate family member means father, mother, husband, wife, son, daughter, brother, sister, grandmother, grandfather, grandson, granddaughter. mother-in-law, or father-in-law. Indian tribe means any Indian tribe, band. nation, or other organized group or community of Indians, including any ANC, \\ high is recognized as eligible for the special programs and services provided by the United States to Indians because of their status as Indians, or is recognized as such by the State in which the tribe, band, nation, group, or community resides. See definition of "tribally -owned concern" in this section Joint venture means an association of a DBE firm and one or more other firms to carry out a single, for-profit business enterprise, for which the parties combine their property, capital. efforts, skills and knowledge, and in which the DBE is responsible for a distinct, clearly defined portion of the work of the contract and whose share in the capital contribution, control, management. risks, and profits of the joint venture are commensurate with its ownership interest. Native Hawaiian means any individual whose ancestors were natives, prior to 1778, of the area which now comprises the State of Hawaii. Native Hawaiian Organization means any community service organization serving Native Hawaiians in the State of Hawaii which is a not-for-profit organization chartered by the State of Hawaii, is controlled by Native Hawaiians, and whose business activities will principally benefit such Native Hawaiians. 5128 Federal Register/Vol. 64, No. 21/Tuesday.,~;February 2, 1999/Rules and Regulations Noncompliance means that a recipient has not correctly implemented the requirements of this part. Operating Administration or OA means any of the following parts of DOT. the Federal Aviation Administration (FAA), Federal Highway Administration (FHWA), and Federal Transit Administration (FTA). The "Administrator" of an operating administration includes his or her designees. Personal net worth means the net value of the assets of an individual remaining after total liabilities are deducted. An individual's personal net worth does not include: The individual's ownership interest in an applicant or participating DBE firm; or the individual's equity in his or her primary place of residence. An individual's personal net worth includes only his or her own share of assets held jointly or as community property with the individual's spouse. Primary industry classification means the four digit Standard Industrial Classification (SIC) code designation which best describes the primary business of a firm. The SIC code designations are described in the Standard Industry Classification IvlanLial. As the North American Industrial Classification System (NAICS) replaces the SIC system, references to SIC codes and the SIC Manual are deemed to refer to the NAICS manual and applicable codes The SIC Manual and the NAICS Manual are available through the National Technical Information Service (NTIS) of the U S Department of Commerce (Springfield, VA. 22261). NTIS also makes materials available through its web site (www ntis.gov/naics) Primary recipient means a recipient which receives DOT financial assistance and passes some or all of it on to another recipient. Principal place of business means the business location where the individuals who manage the firm's day-to-day operations spend most working hours and where top management's business records are kept. If the offices from which management is directed and where business records are kept are in different locations, the recipient will determine the principal place of business for DBE program purposes. Program means any undertaking on a recipient's part to use DOT financial assistance, authorized by the laws to which this part applies. Race -conscious measure or program is one that is focused specifically on assisting only DBEs, including women - owned DBEs. Race -neutral measure or program is one that is, or can be, used to assist all small businesses. For the purposes of this part, race' -neutral includes gender - neutrality Recipient is any entity, public or private. to which DOT financial assistance is extended, whether directly or through another recipient, through the programs of the FAA, FHWA, or FTA, or who has applied for such assistance. Secretary means the Secretary of Transportation or his/her designee. Set-aside means a contracting practice restricting eligibility for the competitive award of a contract solely to DBE firms. Small Business Administration or SBA means the United States Small Business Administration. Small business concern means, with respect to firms seeking to participate as DBEs in DOT -assisted contracts. a small business concern as defined pursuant to section 3 of the Small Business Act and Small Business Administration regulations implementing it (13 CFR part 121) that also does not exceed the cap on average annu-al gross receipts specified in § 26 65(b) Socially and economically disadvantaged individual means any individual who is a citizen (or lawfully admitted permanent resident) of the United States and who is— .rS, (1) Any individual v. ho a recipient finds to be a socially and economically disadvantaged individual on a case-by- case basis (2) Any individual in the following groups, members of which are rebuttably presumed to be socially and economically disadvantaged. (i) "Black Americans," which includes persons having origins in any of the Black racial groups of Africa; (ii) "Hispanic Americans," which includes persons of Mexican, Puerto Rican, Cuban, Dominican, Central or South American, or other Spanish or Portuguese culture or origin, regardless of race, (iii) "Native Americans," which includes persons who are American Indians, Eskimos, Aleuts, or Native Hawaiians, (iv) "Asian -Pacific Americans," which includes persons whose origins are from Japan., China, Taiwan, Korea, Burma (Myanmar), Vietnam, Laos, Cambodia (Kampuchea), Thailand, Malaysia, Indonesia, the Philippines, Brunei, Samoa, Guam, the U.S. Trust Territories of the Pacific Islands (Republic of Palau), the Commonwealth of the Northern Marianas Islands, Macao, Fiji, Tonga, Kirbati, Juvalu, Nauru, Federated States of Micronesia, or Hong Kong; (v) "Subcontinent Asian Americans," which includes persons whose origins are from India. Pakistan, Bangladesh, Bhutan, the Maldives Islands. Nepal or Sri Lanka; (vi) Women; (vii) Any additional groups whose members are designated as socially and economically disadvantaged by the SBA. at such time as the SBA designation becomes effective. Tribally -owned concern means any concern at least 51 percent owned by an Indian tribe as defined in this section. You refers to a recipient, unless a statement in the text of this part or the context requires otherwise (i.e., 'You must do XYZ' means that recipients must do XYZ). § 26.7 What discriminatory actions are forbidden? (a) You must never exclude any person from participation in. deny any person the benefits of, or otherwise discriminate against anyone in connection with the award and performance of any contract covered by this part on the basis of race, color, sex, or national origin. (b) In administering your DBE program, you must not, directly or through contractual or other arrangements use criteria or methods of administration that have the effect of defeating or substantially impairing accomplishment of the objectives of the program with respect to individuals of a particular race, color. sex, or national origin § 26.9 How does the Department issue guidance and interpretations under this part? (a) This part applies instead of subparts A and C through E of 49 CFR part 23 in effect prior to March 4, 1999. (See 49 CFR Parts 1 to 99, revised as of October 1, 1998.) Only guidance and interpretations (including interpretations set forth in certification appeal decisions) consistent with this part 26 and issued after March 4, 1999 have definitive, binding effect in implementing the provisions of this part and constitute the official position of the Department of Transportation. (b) The Secretary of Transportation, Office of the Secretary of Transportation, FHWA, FTA, and FAA may issue written interpretations of or written guidance concerning this part. Written interpretations and guidance are valid and binding, and constitute the official position of the Department of Transportation, only if they are issued over the signature of the Secretary of Transportation or if they contain the following statement. Federal Register /Vol. 64, No. 21 /Tuesday, February 2, 1999 / Rules and Regulations 5129 The General Counsel of the Department of Transportation has reviewed this document and approved it as consistent with the language and intent of 49 CFR part 26. § 26.11 What records do recipients keep and report? (a) [Reserved] (b) You must continue to provide data about your DBE program to the Department as directed by DOT operating administrations. (c) You must create and maintain a bidders list, consisting of all firms bidding on prime contracts and bidding or quoting subcontracts on DOT -assisted projects. For every firm, the following information must be included: (1) Firm name, (2) Firm address: (3) Firm's status as a DBE or non -DBE; (4) The age of the firm; and (5) The annual gross receipts of the firm. § Section 26.13 What assurances must recipients and contractors make? (a) Each financial assistance agreement you sign with a DOT operating administration (or a primary recipient) must include the following assurance, The recipient shall not discriminate on the basis of race, color, national origin. or sex in the av, and and performance of any DOT- assis-ed contract or in the administration of its DEE program or the requirements of 49 CFR part 26 The recipient shall take all necessar. and reasonable steps under 49 CFR part 25 to ensure nondiscrimination in the award and administration of DOT -assisted contracts. The recipient's DBE program, as required by 49 CFR part 26 and as approved by DOT, is incorporated by reference in this agreement. Implementation of this program is a legal obligation and failure to carry out its terms shall be treated as a violation of this agreement. Upon notification to the recipient of its failure to carry out its approved program; the Department may impose sanctions as provided for under part 26 and may, in appropriate cases, refer the matter for enforcement under 18 U.S C 1001 and/or the Program Fraud Civil Remedies Act of 1986 (31 U.S C 3801 et seq.) (b) Each contract you sign with a contractor (and each subcontract the prime contractor signs with a subcontractor) must include the following assurance The contractor, sub recipient or subcontractor shall not discriminate on the basis of race, color, national origin, or sex in the performance of this contract. The contractor shall carry out applicable requirements of 49 CFR part 26 in the award and administration of DOT -assisted contracts Failure by the contractor to carry out these requirements is a material breach of this contract, which may result in the termination of this contract or such other remedy as the recipient deems appropriate. § 26.15 How can recipients apply for exemptions or waivers? (a) You can apply for an exemption from any provision of this part. To apply. you must request the exemption in writing from the Office of the Secretary of Transportation, FHWA, FTA, or FAA. The Secretary will grant the request only if it documents special or exceptional circumstances, not likely to be generally applicable, and not contemplated in connection with the rulemaking that established this part, that make your compliance with a specific provision of this part impractical. You must agree to take any steps that the Department specifies to comply with the intent of the provision from which an exemption is granted. The Secretary will issue a written response to all exemption requests. (b) You can apply for a waiver of any provision of Subpart B or C of this part including, but not limited to, any provisions regarding administrative requirements, overall goals, contract goals or good faith efforts. Program waivers are for the purpose of authorizing you to operate a DBE program that achieves the objectives of this part by means that may differ from one or more of the requirements of Subpart B or C of this part. To receive a program waiver, you must follow these procedures (1) You must apply through the concerned operating administration. The application must include a specific program proposal and address how you will meet the criteria of paragraph (b) (2) of this section. Before submitting your application, you must have had public participation in developing your proposal, including consultation with the DBE community and at least one public hearing Your application must include a summary of the public participation process and the information gathered through it. (2) Your application must show that— (i) There is a reasonable basis to conclude that you could achieve a level of DBE participation consistent with the objectives of this part using different or innovative means other than those that are provided in subpart B or C of this part; (ii) Conditions in your jurisdiction are appropriate for implementing the proposal; (iii) Your proposal would prevent discrimination against any individual or group in access to contracting opportunities or other benefits of the program; and (iv) Your proposal is consistent with applicable law and program requirements of the concerned operating administration's financial assistance program. (3) The Secretary has the authority to approve your application. If the Secretary grants your application, you may administer your DBE program as provided in your proposal, subject to the following conditions: (i) DBE eligibility is determined as provided in subparts D and E of this part, and DBE participation is counted as provided in §26.49, (ii) Your level of DBE participation continues to be consistent with the objectives of this part; (iii) There is a reasonable limitation on the duration of your modified program; and (iv) Any other conditions the Secretary makes on the grant of the waiver. (4) The Secretary may end a program waiver at any time and require you to comply with this part's provisions. The Secretary may also extend the waiver, if he or she determines that all requirements of paragraphs (b)(2) and (3) of this section continue to be met. Any such extension shall be for no longer than period originally set for the duration of the program. Subpart B—Administrative Requirements for DBE Programs for Federally -Assisted Contracting §26.21 Who must have a DBE program? (a) If you are in one of these categories and let DOT -assisted contracts, you must have a DBE program meeting the requirements of this part' (1) All FHWA recipients receiving funds authorized by a statute to which this part applies. (2) FTA recipients that receive $250,000 or more in FTA planning, capital. and/or operating assistance in a Federal fiscal year; (3) FAA recipients that receive a grant of $250,000 or more for airport planning or development. (b) (1) You must submit a DBE program conforming to this part by August 31, 1999 to the concerned operating administration (OA). Once the OA has approved your program, the approval counts for all of your DOT - assisted programs (except that goals are reviewed and approved by the particular operating administration that provides funding for your DOT -assisted contracts) (2) You do not have to submit regular updates of your DBE programs, as long as you remain in compliance. However, you must submit significant changes in the program for approval. (c) You are not eligible to receive DOT financial assistance unless DOT has 5130 Federal Register /Vol. 64, No. 21 1Tuesday, `February 2, 1999 / Rules and Regulations approved your DBE program and you are in compliance with it and this part. You must continue to carry out your program until all funds from DOT financial assistance have been expended. § 26.23 What is the requirement for a policy statement? You must issue a signed and dated policy statement that expresses your commitment to your DBE program, states its objectives, and outlines responsibilities for its implementation. You must circulate the statement throughout your organization and to the DBE and non -DBE business communities that perform work on your DOT -assisted contracts. § 26.25 What is the requirement for a liaison officer? You must have a DBE liaison officer, who shall have direct, independent access to your Chief Executive Officer concerning DBE program matters The liaison officer shall be responsible for implementing all aspects of your DBE program. You must also have adequate staff to administer the program in compliance with this part. 26.27 What efforts must recipients make concerning DBE financial institutions? You must thcroughl„ investigate the full extent of services offered by financial institutions owned and controlled b, soc:aiiv and economicall; disadvanta,ed' individuals in your community and make reasonable efforts to use these institutions You must also encourage prime contractors to use such institutions § 26.29 What prompt payment mechanisms must recipients have? (a) You must establish, as part of your DBE program. a contract clause to require prime contractors to pay subcontractors for satisfactory performance of their contracts no later than a specific number of days from receipt of each payment you make to the prime contractor This clause must also require the prompt return of retainage payments from the prime contractor to the subcontractor within a specific number of days after the subcontractor's work is satisfactorily completed. (1) This clause may provide for appropriate penalties for failure to comply, the terms and conditions of which you set. (2) This clause may also provide that any delay or postponement of payment among the parties may take place only for good cause, with your prior written approval (b) You may also establish, as part of your DBE program, any of the following additional mechanisms to ensure prompt payment: (1) A contract clause that requires prime contractors to include intheir subcontracts language providing that prime contractors and subcontractors will use appropriate alternative dispute resolution mechanisms to resolve payment disputes. You may specify the nature of such mechanisms. (2) A contract clause providing that the prime contractor will not be reimbursed for work performed by subcontractors unless and until the prime contractor ensures that the subcontractors are promptly paid for the work they have performed. (3) Other mechanisms. consistent with this part and applicable state and local law, to ensure that DBEs and other contractors are fully and promptly paid. § 26.31 What requirements pertain to the DBE directory? You must maintain and make available to interested persons a directory identifying all firms eligible to participate as DBEs in your program. In the listing for each firm, you must include its address, phone number, and the types of work the firm has been certified to perform as a DBE You must revise vour director:, a: -east annually and make updated inforrriatton available to contractors and :he public on request. § 26.33 What steps must a recipient take to address overconcentration of DBEs in certain types of work? (a) If you determine that DBE firms are so overconcentr ated in a certain type of work as to unduly burden the opportunity of non -DBE firms to participate in this type of work, you must devise appropriate measures to address this overconcentration. (b) These measures may include the use of incentives, technical assistance, business development programs, mentor -protege programs, and other appropriate measures designed to assist DBEs in performing work outside of the specific field in which you have determined that non -DBEs are unduly burdened You may also consider varying your use of contract goals, to the extent consistent with § 26 51, to unsure that non -DBEs are not unfairly prevented from competing for subcontracts. (c) You must obtain the approval of the concerned DOT operating administration for your determination of overconcentration and the measures you devise to address it. Once approved. the measures become part of your DBE program § 26.35 What role do business development and mentor -protege programs have In the DBE program? (a) You may or, if an operating administration directs you to, you must establish a DBE business development program (BDP) to assist firms in gaining the ability to compete successfully in the marketplace outside the DBE program. You may require a DBE firm, as a condition of receiving assistance through the BDP, to agree to terminate its participation in the DBE program after a certain time has passed or certain objectives have been reached. See Appendix C of this part for guidance on administering BDP programs. (b) As part of a BDP or separately, you may establish a "mentor -protege" program, in which another DBE or non - DBE firm is the principal source of business development assistance to a DBE firm. (1) Only firms you have certified as DBEs before they are proposed for participation in a mentor -protege program are eligible to participate in the mentor -protege program. (2) During the course of the mentor - protege relationship, you must: (i) Not award DBE credit to a non -DBE mentor firm for using its own protege firm for more than one half of its goal on anti contract let by the recipient. and (ii) Not award DBE credit to a non - DBE mentor firm for using its own protege firm for more than every other contract performed by the protege firm. (3) For purposes of making determinations of business size under this part, you must not treat protege firms as affiliates of mentor firms, when both firms are participating under an approved mentor -protege program. See Appendix D of this part for guidance concerning the operation of mentor - protege programs. (c) Your BDPs and mentor -protege programs must be approved by the concerned operating administration before you implement them. Once approved. they become part of your DBE program. §26.37 What are a recipient's responsibilities for monitoring the performance of other program participants? (a) You must implement appropriate mechanisms to ensure compliance with the part's requirements by all program participants (e.g., applying legal and contract remedies available under Federal, state and local law) You must set forth these mechanisms in your DBE program. (b) Your DBE program must also include a monitoring and enforcement mechanism to verify that the work committed to DBEs at contract award is Federal Register /Vol. 64, No. 21 /Tuesday, February 2, 1999 /Rules and Regulations 5131 actually performed by the DBEs. This mechanism must provide for a running tally of actual DBE attainments (e.g., payments actually made to DBE firms) and include a provision ensuring that DBE participation is credited toward overall or contract goals only when payments are actually made to DBE firms. Subpart C—Goals, Good Faith Efforts, and Counting §26.41 What is the role of the statutory 10 percent goal in this program? (a) The statutes authorizing this program provide that, except to the extent the Secretary determines otherwise, not less than 10 percent of the authorized funds are to be expended with DBEs. (b) This 10 percent goal is an aspirational goal at the national level, which the Department uses as a tool in evaluating and monitoring DBEs' opportunities to participate in DOT - assisted contracts (c) The national 10 percent goal does not authorize or -require recipients to set overall or contract goals at the 10 percent level, or any other particular level, or to take any special administrative steps if their goals are above or below 10 percent. § 26.43 Can recipients use set -asides or quotas as part of this program? (a) `t cu are not permitted to use quotas for DBEs on DOT -assisted contracts subject to this part. (b' You may not set-aside contracts for DBEs on DOT -assisted contracts subject to this part, except that. in limited and extreme circumstances, you may use set -asides when no other method could be reasonably expected to redress egregious instances of discrimination. § 26.45 How do recipients set overall goals? (a) You must set an overall goal for DBE participation in your DOT -assisted contracts (b) Your overall goal must be based on demonstrable evidence of the availability of ready, willing and able DBEs relative to all businesses ready, willing and able to participate on your DOT -assisted contracts (hereafter, the "relative availability of DBEs") The goal must reflect your determination of the level of DBE participation you would expect absent the effects of discrimination. You cannot simply rely on either the 10 percent national goal, your previous overall goal or past DBE participation rates in your program without reference to the relative availability of DBEs in your market. (c) Step 1. You must begin your goal setting process by determining a base figure for the relative availability of DBEs. The following are examples of approaches that you may take toward determining a base figure. These examples are provided as a starting point for your goal setting process. Any percentage figure derived from one of these examples should be considered a basis from which you begin when examining all evidence available in your jurisdiction These examples are not intended as an exhaustive list. Other methods or combinations of methods to determine a base figure may be used, subject to approval by the concerned operating administration. (1) Use DBE Directories and Census Bureau Data. Determine the number of ready, willing and able DBEs in your market from your DBE directory. Using the Census Bureau's County Business Pattern (CBP) data base, determine the number of all ready, willing and able businesses available in your market that perform work in the same SIC codes. (Information about the CBP data base may be obtained from the Census Bureau at their web site. www.census gov/epcd/cbp/view/ cbpview html) Divide the number of DBEs by the number of all businesses to derive a base figure for the relative availability of DEEB in _your market. (2) Use a bidders list Determine the number of DEEB :ha: r aye 'bid or quoted on your DOT -assisted prime contracts or subcontracts in the previous year Determine the number of all businesses that have bid or quoted on prime or subcontracts in the same time period Divide the number of DBE bidders and quoters by the number for all businesses to derive a base figure for the relative availability of DBEs in your market. (3) Use data from a disparity study Use a percentage figure derived from data in a valid, applicable disparity study (4) Use the goal of another DOT recipient. If another DOT recipient in the same, or substantially similar, market has set an overall goal in compliance with this rule, you may use that goal as a base figure for your goal (5) Alternative methods. Subject to the approval of the DOT operating administration. you may use other methods to determine a base figure for your overall goal. Any methodology you choose must be based on demonstrable evidence of local market conditions and be designed to ultimately attain a goal that is rationally related to the relative availability of DBEs in your market. (d) Step 2 Once you have calculated a base figure, you must examine all of the evidence available in your jurisdiction to determine what adjustment, if any. is needed to the base figure in order to arrive at your overall goal. (1) There are many types of evidence that must be considered when adjusting the base figure. These include. ' (i) The current capacity of DBEs to perform work in your DOT -assisted contracting program, as measured by the volume of work DBEs have performed in recent years; (ii) Evidence from disparity studies conducted anywhere within your jurisdiction, to the extent it is not already accounted for in your base figure; and (iii) If your base figure is the goal of another recipient, you must adjust it for differences in your local market and your contracting program. (2) You may also consider available evidence from related fields that affect the opportunities for DBEs to form, grow and compete. These include, but are not limited to: (i) Statistical disparities in the ability of DBEs to get the financing, bonding and insurance required to participate in your program, (ii) Data on employment, self- employment, education, training and union apprenticeship programs, to the extent you can relate it to the opportunities for DBEs to perform in your program. (3) If you attempt to make an adjustment to your base figure to account for the continuing effects of past discrimination (often called the "but for" factor) or the effects of an ongoing DBE program, the adjustment must be based on demonstrable evidence that is logically and directly related to the effect for which the adjustment is sought. (e) Once you have determined a percentage figure in accordance with paragraphs (c) and (d) of this section. you should express your overall goal as follows (1) If you are an FHWA recipient, as a percentage of all Federal -aid highway funds you will expend in FHWA- assisted contracts in the forthcoming fiscal year; (2) If you are an FTA or FAA recipient. as a percentage of all FTA or FAA funds (exclusive of FTA funds to be used for the purchase of transit vehicles) that you will expend in FTA or FAA -assisted contracts in the forthcoming fiscal year. In appropriate cases, the FTA or FAA Administrator may permit you to express your overall goal as a percentage of funds for a particular grant or project or group of grants and/or projects 5132 Federal Register/Vol. 64, No. 21 / Tuesda}r "•February 2, 1999 /Rules and Regulations (f) (1) If you set overall goals on a fiscal year basis, you must submit them to the applicable DOT operating administration for review on August 1 of each year, unless the Administrator of the concerned operating administration establishes a different submission date. (2) If you are an FTA or FAA recipient and set your overall goal on a project or grant basis, you must submit the goal for review at a time determined by the FTA or FAA Administrator. (3) You must include with your overall goal submission a description of the methodology you used to establish the goal. including your base figure and the evidence with which it was calculated, and the adjustments you made to the base figure and the evidence relied on for the adjustments. You should also include a summary listing of the relevant available evidence in your jurisdiction and, where applicable, an explanation of why you did not use that evidence to adjust your base figure. You must also include your projection of the portions of the overall goal you expect to meet through race - neutral and race -conscious measures. respectively (see § 26 51(c)) (4) You are not required to obtain prior operating administration concurrence with the your overall goal. However, if the operating administration s review suggests that your overall goal has not been correctly calculated, or that our method for calculating goals is inadequate the operating administration may after consulting with you adjust your overall goal or require that you do so The adjusted overall goal is binding on you. (5) If you need additional time to collect data or take other steps to develop an approach to setting overall goals, you may request the approval of the concerned operating administration for an interim goal and/or goal -setting mechanism. Such a mechanism must: (i) Reflect the relative availability of DBEs in your local market to the maximum extent feasible given the data available to you, and (ii) Avoid imposing undue burdens on non -DBEs. (g) In establishing an overall goal, you must provide for public participation. This public participation must include (1) Consultation with minority, women's and general contractor groups, community organizations, and other officials or organizations which could bt expected to have information concerning the availability of disadvantaged and non -disadvantaged businesses. the effects of discrimination on opportunities for DBEs, and your efforts to establish a level playing field for the participation of DBEs (2) A published notice announcing your proposed overall goal. informing the public that the proposed goal and its rationale are available for inspection during normal business hours at your principal office for 30 days following the date of the notice. and informing the public that you and the Department will accept comments on the goals for 45 days from the date of the notice. The notice must include addresses to which comments may be sent. and you must publish it in general circulation media and available minority -focused media and trade association publications. (h) Your overall goals must provide for participation by all certified DBEs and must not be subdivided into group - specific goals. §26.47 Can recipients be penalized for failing to meet overall goals? (a) You cannot be penalized. or treated by the Department as being in noncompliance with this rule, because your DBE participation falls short of your overall goal. unless you have failed to administer your program in good faith. (b) If you do not have an approved DBE program or overall goal. or if you fail to implement your program in good faith, you are in noncompliance with this part. §26.49 How are overall goals established for transit vehicle manufacturers? (a) If you are an FTA recipient. you must require in your DBE program that each transit vehicle manufacturer, as a condition of being authorized to bid or propose on FTA -assisted transit vehicle procurements. certify that it has complied with the requirements of this section You do not include FTA assistance used in transit vehicle procurements in the base amount from which your overall goal is calculated. (b) If you are a transit vehicle manufacturer, you must establish and submit for FTA's approval an annual overall percentage goal. In setting your overall goal, you should be guided, to the extent applicable. by the principles underlying § 26.45 The base from which you calculate this goal is the amount of FTA financial assistance included in transit vehicle contracts you will perform during the fiscal year in question. You must exclude from this base funds attributable to work performed outside the United States and its territories, possessions, and commonwealths. The requirements and procedures of this part with respect to submission and approval of overall goals apply to you as they do to recipients (c) As a transit vehicle manufacturer, you may make the certification required by this section if you have submitted the goal this section requires and FTA has approved it or not disapproved it. (d) As a recipient, you may. with FTA approval. establish project -specific goals for DBE participation in the procurement of transit vehicles in lieu of complying through the procedures of this section. (e) If you are an FHWA or FAA ,recipient, you may, with FHWA or FAA approval. use the procedures of this section with respect to procurements of vehicles or specialized equipment. If you choose to do so, then the manufacturers of this equipment must meet the same requirements (including goal approval by FHWA or FAA) as transit vehicle manufacturers must meet in FTA -assisted procurements § 26.51 What means do recipients use to meet overall goals? (a) You must meet the maximum feasible portion of your overall goal by using race -neutral means of facilitating DBE participation. Race -neutral DBE participation includes any time a DBE wins a prime contract through customary competitive procurement procedures, is awarded a subcontract on a prime contract that does not cam' a DBE goal, or even if there is a DBE goal, wins a subcontract from a prime contractor that did not consider its DBE status in making the award (e g. a prime contractor that uses a strict low bid system to award subcontracts) (b) Race -neutral means include, but are not limited to, the following: (1) Arranging solicitations, times for the presentation of bids, quantities, specifications, and delivery schedules in ways that facilitate DBE, and other small businesses, participation (e g , unbundling large contracts to make them more accessible to small businesses. requiring or encouraging prime contractors to subcontract portions of work that they might otherwise perform with their own forces) . (2) Providing assistance in overcoming limitations such as inability to obtain bonding or financing (e.g., by such means as simplifying the bonding process, reducing bonding requirements, eliminating the impact of surety costs from bids, and providing services to help DBEs, and other small businesses, obtain bonding and financing), (3) Providing technical assistance and other services, (4) Carrying out information and communications programs on contracting procedures and specific Federal Register/Vol. 64, No. 21 /Tuesday, February 2, 1999 /Rules and Regulations 5133 contract opportunities (e.g., ensuring the inclusion of DBEs, and other small businesses, on recipient mailing lists for bidders; ensuring the dissemination to bidders on prime contracts of lists of potential subcontractors; provision of information in languages other than English. where appropriate); (5) Implementing a supportive services program to develop and improve immediate and long-term business management, record keeping, and financial and accounting capability for DBEs and other small businesses; (6) Providing services to help DBEs. and other small businesses, improve long-term development, increase opportunities to participate in a variety of kinds of work, handle increasingly significant projects, and achieve eventual self-sufficiency; (7) Establishing a program to assist new, start-up firms, particularly in fields in which DBE participation has historically been low; (8) Ensuring distribution of your DBE directory, through print and electronic means, to the widest feasible universe of potential prime contractors, and (9) Assisting DBEs, and other small businesses, to develop their capability to utilize emerging technology and conduct business through electronic media. (c) Each time you submit your overall roall for review by the concerned operating administration. you must alsc submit "our projection of the portion of the goal :hat you expect to meet through race -neutral means and your basis for that projection. This projection is subject to approval by the concerned operating administration, in conjunction with its review of your overall goal. (d) You must establish contract goals to meet any portion of your overall goal you do not project being able to meet using race -neutral means. (e) The following provisions apply to the use of contract goals (1) You may use contract goals only on those DOT -assisted contracts that have subcontracting possibilities (2) You are not required to set a contract goal on every DOT -assisted contract. You are not required to set each contract goal at the same percentage level as the overall goal. The goal for a specific contract may be higher or lower than that percentage level of the overall goal. depending on such factors as the type of work involved, the location of the work, and the availability of DBEs for the work of the particular contract. However, over the period covered by your overall goal, you must set contract goals so that they will cumulatively result in meeting any portion of your overall goal you do not project being able to meet through the use of race -neutral means. (3) Operating administration approval of each contract goal is not necessarily required. However, operating administrations may review and approve or disapprove any contract goal you establish. (4) Your contract goals must provide for participation by all certified DBEs and must not be subdivided into group - specific goals. (1) To ensure that your DBE program continues to be narrowly tailored to overcome the effects of discrimination, you must adjust your use of contract goals as follows: (1) If your approved projection under paragraph (c) of this section estimates that you can meet your entire overall goal for a given year through race - neutral means, you must implement your program without setting contract goals during that year. Example to Paragraph (t)(1)• Your overall goal for Year I is 12 percent. You estimate that you can obtain 12 percent or more DBE participation through the use of race -neutral measures, without any use of contract goals. In this case, you do not set any contract goals for the contracts that will be performed in Year I (2) If, during the course of any year in which you are using contract goals, you determine that you will exceed your - overall goal you must reduce or eliminate the use of contract goals to the extent necessary to ensure that the use of contract goals does not result in exceeding the overall goal If you determine that you will fail short of your overall goal, then you must make appropriate modifications in your use of race -neutral and/or race -conscious measures to allow you to meet the overall goal Example to Paragraph (f)(2) In Year II, your overall goal is 12 percent. You have estimated that you can obtain 5 percent DBE participation through use of race -neutral measures. You therefore plan to obtain the remaining 7 percent participation through use of DBE goals. By Septernber, you have already obtained 11 percent DBE participation for the year For contracts let during the remainder of the year, you use contract goals only to the extent necessary to obtain an additional one percent DBE participation. However, if you determine in September that your participation for the year is likely to be oniv 8 percent total, then you would increase your use of race -neutral and/or race -conscious means during the remainder of the year in order to achieve your overall goal. (3) If the DBE participation you have obtained by race -neutral means alone meets or exceeds your overall goals for two consecutive years, you are not required to make a projection of the amount of your goal you can meet using such means in the next year. You do not set contract goals on any contracts in the next year. You continue using only race - neutral means to meet your overall goals unless and until you do not meet your overall goal for a year. Example to Paragraph (1)(3): Your overall goal for Years I and Year II is 10 percent. The DBE participation you obtain through race - neutral measures alone is 10 percent or more in each year. (For this purpose, it does not matter whether you obtained additional DBE participation through using contract goals in these years.) In Year III and following years, you do not need to make a projection under paragraph (c) of this section of the portion of your overall goal you expect to meet using race -neutral means. You simply use race - neutral means to achieve your overall goals. However, if in Year VI your DBE participation falls short of your overall goal, then you must make a paragraph (c) projection for Year VII and, if necessary, resume use of contract goals in that year (4) If you obtain DBE participation that exceeds your overall goal in two consecutive years through the use of contract goals (i.e., not through the use of race -neutral means alone), you must reduce your use of contract goals proportionately in the following year. Example to Paragraph (0(4) In Years I and II, your overall goal is 12 percent, and you obtain 14 and 16 percent DBE participation, respectively You have exceeded your goals over the two-year period by an average of 25 percent. In Year III, your overall goal is again 12 percent. and your paragraph (c) projection estimates that you will obtain 4 percent DBE participation through race -neutral means and 8 percent through contract goals. You then reduce the contract goal projection by 25 percent (i.e., from 8 to 6 percent) and set contract goals accordingly during the year If in Year III you obtain I 1 percent participation, you do not use this contract goal adjustment mechanism for Year IV, because there have not been two consecutive years of exceeding overall goals. (g) In any year in which you project meeting part of your goal through race - neutral means and the remainder through contract goals, you must maintain data separately on DBE achievements in those contracts with and without contract goals, respectively You must report this data to the concerned operating administration as provided in § 26 11 § 26.53 What are the good faith efforts procedures recipients follow in situations where there are contract goals? (a) When you have established a DBE contract goal, you must award the contract only to a bidder/offeror who makes good faith efforts to meet it. You must determine that a bidder/offeror has made good faith efforts if the bidder/ 5134 Federal Register/Vol. 64, No. 21 /Tuesday,' February 2, 1999 / Rules and Regulations offeror does either of the following things: (1) Documents that it has obtained enough DBE participation to meet the goal: or (2) Documents that it made adequate good faith efforts to meet the goal, even though it did not succeed in obtaining' enough DBE participation to do so. If the bidder/offeror does document adequate good faith efforts, you must not deny award of the contract on the basis that the bidder/offeror failed to meet the goal. See Appendix A of this part for guidance in determining the adequacy of a bidder/offeror's good faith efforts. (b) In your solicitations for DOT - assisted contracts for which a contract goal has been established, you must require the following: (1) Award of the contract will be conditioned on meeting the requirements of this section, (2) All bidders/offerors will be required to submit the following information to the recipient. at the time provided in paragraph (b) (3) of this section. (i) The names and addresses of DBE firms that will participate in the contract; (ii) A description of the work that each DEE will perform, (iii) The dollar amount of the participation of each DBE firm participatine tA r it:en documentation of the bidder/offeror's commitment to use a DBE subcontractor whose participation it submits to meet a contract goal, (v) Written confirmation from the DBE that it is participating in the contract as provided in the prime contractor's commitment; and (vi) If the contract goal is not met, evidence of good faith efforts (see Appendix A of this part), and (3) At your discretion, the bidder/ offeror must present the information required by paragraph (b) (2) of this section— (i) Under sealed bid procedures, as a matter of responsiveness, or with initial proposals, under contract negotiation procedures; or (ii) At any time before you commit yourself to the performance of the contract by the bidder/offeror, as a matter of responsibility. (c) You must make sure all information is complete and accurate and adequately documents the bidder/ offeror's good faith efforts before committing yourself to the performance of the contract by the bidder/offeror. (d) If you determine that the apparent successful bidder/ offeror has failed to meet the requirements of paragraph (a) of this section, you must, before awarding the contract, provide the bidder/offeror an opportunity for administrative reconsideration. (1) As part of this reconsideration, the bidder/offeror must have the opportunity to provide written documentation or argument concerning the issue of whether it met the goal or made adequate good faith efforts to do so. (2) Your decision on reconsideration must be made by an official who did not take part in the original determination that the bidder/offeror failed to meet the goal or make adequate good faith efforts to do so. (3) The bidder/offeror must have the opportunity to meet in person with your reconsideration official to discuss the issue of whether it met the goal or made adequate good faith efforts to do so. (4) You must send the bidder/offeror a written decision on reconsideration, explaining the basis for finding that the bidder did or did not meet the goal or make adequate good faith efforts to do so. (5) The result of the reconsideration process is not administratively appealable to the Department of Transportation. (e) In a "design -build" or "turnkey" contracting situation. in which the recipient lets a master contract tb a contractor, who in turn lets subsequent subcontracts for ,'.ori. of the project, a recipient may establish a goal for the project. The master contractor then establishes contract goals, as appropriate, for the subcontracts it lets Recipients must maintain oversight of the master contractor's activities to ensure that they are conducted consistent with the requirements of this part. (f)(1) You must require that a prime contractor not terminate for convenience a DBE subcontractor listed in response to paragraph (b)(2) of this section (or an approved substitute DBE firm) and then perform the work of the terminated subcontract with its own forces or those of an affiliate, without your prior written consent. (2) When a DBE subcontractor is terminated, or fails to complete its work on the contract for any reason, you must require the prime contractor to make good faith efforts to find another DBE subcontractor to substitute for the original DBE. These good faith efforts shall be directed at finding another DBE to perform at least the same amount of work under the contract as the DBE that was terminated, to the extent needed to meet the contract'goal you established for the procurement. (3) You must include in each prime contract a provision for appropriate administrative remedies that you will invoke if the prime contractor fails to comply with the requirements of this section. (g) You must apply the requirements of this section to DBE bidders/offerors for prime contracts. In determining whether a DBE bidder/offeror for a prime contract has met a contract goal. you count the work the DBE has committed to performing with its own forces as well as the work that it has committed to be performed by DBE subcontractors and DBE suppliers. §26.55 How is DBE participation counted toward goals? (a) When a DBE participates in a contract, you count only the value of the work actually performed by the DBE toward DBE goals. (1) Count the entire amount of that portion of a construction contract (or other contract not covered by paragraph (a) (2) of this section) that is performed by the DBE's own forces. Include the cost of supplies and materials obtained by the DBE for the work of the contract. including supplies purchased or equipment leased by the DBE (except supplies and equipment the DBE subcontractor purchases or leases from the prime contractor or its affiliate) (21 Count the entire amount of fees or commissions charged by a DBE firm for providing a bona fide service, such as professional. technical, consultant, or managerial services, or for providing bonds or insurance specifically required for the performance of a DOT -assisted contract. toward DBE goals. provided you determine the fee to be reasonable and not excessive as compared with fees customarily allowed for similar services. (3) When a DBE subcontracts part of the work of its contract to another firm, the value of the subcontracted work may be counted toward DBE goals only if the DBE's subcontractor is itself a DBE. Work that a DBE subcontracts to a non - DBE firm does not count toward DBE goals. (b) When a DBE performs as a participant in a joint venture, count a portion of the total dollar value of the contract equal to the distinct, clearly defined portion of the work of the contract that the DBE performs with its own forces toward DBE goals. (c) Count expenditures to a DBE contractor toward DBE goals only if the DBE is performing a commercially useful function on that contract. " (1) A DBE performs a commercially useful function when it is responsible for execution of the work of the contract and is carrying out its responsibilities Federal Register /Vol. 64, No. 21 /Tuesday, February 2, 1999 / Rules and Regulations 5135 by actually performing, managing, and supervising the work involved. To perform a commercially useful function, the DBE must also be responsible, with respect to materials and supplies used on the contract, for negotiating price, determining quality and quantity, ordering the material, and installing (where applicable) and paying for the material itself. To determine whether a DBE is performing a commercially useful function, you must evaluate the amount of work subcontracted, industry practices, whether the amount the firm is to be paid under the contract is commensurate with the work it is actually performing and the DBE credit claimed for its performance of the work, and other relevant factors. (2) A DBE does not perform a commercially useful function if its role is limited to that of an extra participant in a transaction, contract, or project through which funds are passed in order to obtain the appearance of DBE participation. In determining whether a DBE is such an extra participant, you must examine similar transactions, particularly those in which DBEs do not participate. (3) If a DBE does not perform or exercise responsibility for at least 30 percent of the total cost of its contract with its own work force, or the DBE subcontracts a greater portion of the work of a contract than evould be expected on the basis of normal industry practice for the type of work involved, you must presume that it is not performing a commercially useful function. (4) When a DBE is presumed not to be performing a commercially useful function as provided in paragraph (c) (3) of this section, the DBE may present evidence to rebut this presumption. You may determine that the firm is performing a commercially useful function given the type of work involved and normal industry practices. (5) Your decisions on commercially useful function matters are subject to review by the concerned operating administration, but are not administratively appealable to DOT (d) Use the following factors in determining whether a DBE trucking company is performing a commercially useful function. (1) The DBE must be responsible for the management and supervision of the entire trucking operation for which it is responsible on a particular contract, and there cannot be a contrived arrangement for the purpose of meeting DBE goals. (2) The DBE must itself own and operate at least one fully licensed, insured, and operational truck used on the contract. (3) The DBE receives credit for the total value of the transportation services it provides on the contract using trucks it owns. insures, and operates using drivers it employs. (4) The DBE may lease trucks from another DBE firm, including an owner - operator who is certified as a DBE. The DBE who leases trucks from another DBE receives credit for the total value of the transportation services the lessee DBE provides on the contract. (5) The DBE may also lease trucks from a non -DBE firm, including an owner -operator. The DBE who leases trucks from a non -DBE is entitled to credit only for the fee or commission it receives as a result of the lease arrangement. The DBE does not receive credit for the total value of the transportation services provided by the lessee, since these services are not provided by a DBE. (6) For purposes of this paragraph (d), a lease must indicate that the DBE has exclusive use of and control over the truck. This does not preclude the leased truck from working for others during the term of the lease with -the consent of the DBE, so long as the lease gives the DBE absolute priority for use of the leased truck. Leased trucks must display the name and identification number of the DBE. (e) Count expenditures with DBEs for materials or supclies toward DBE goals as provided in the following (1) (i) If the materials or supplies are obtained from a DBE manufacturer, count 100 percent of the cost of the materials or supplies toward DBE goals (ii) For purposes of this paragraph (e)(1), a manufacturer is a firm that operates or maintains a factory or establishment that produces. on the premises. the materials, supplies, articles, or equipment required under the contract and of the general character described by the specifications. (2) (1) If the materials or supplies are purchased from a DBE regular dealer, count 60 percent of the cost of the materials or supplies toward DBE goals. (ii) For purposes of this section, a regular dealer is a firm that owns, operates, or maintains a store, warehouse, or other establishment in which the materials. supplies, articles or equipment of the general character described by the specifications and required under the contract are bought. kept in stock, and regularly sold or leased to the public in the usual course of business. (A) To be a regular dealer, the firm must be an established, regular business that engages, as its principal business and under its own name, in the purchase and sale or lease of the products in question. (B) A person may be a regular dealer in such bulk items as petroleum products. steel, cement, gravel, stone, or asphalt without owning, operating, or maintaining a place of business as provided in this paragraph (e)(2)(ii) if the person both owns and operates distribution equipment for the products. Any supplementing of regular dealers' own distribution equipment shall be by a long-term lease agreement and not on an ad hoc or contract -by -contract basis. (C) Packagers, brokers, manufacturers' representatives, or other persons who arrange or expedite transactions are not regular dealers within the meaning of this paragraph (e)(2). (3) With respect to materials or supplies purchased from a DBE which is neither a manufacturer nor a regular dealer, count the entire amount of fees or commissions charged for assistance in the procurement of the materials and supplies, or fees or transportation charges for the delivery of materials or supplies required on a job site, toward DBE goals, provided you determine the fees to be reasonable and not excessive as compared with fees customarily allowed for similar services. Do not count any portion of the cost of the materials and supplies themselves toward DBE goals. however (f) If a firm is not currently certified as a DBE in accordance with the standards of subpart D of this part at the time of the execution of the contract, do not count the firm's participation toward any DBE goals. except as provided for in § 26 87(i)). (g) Do not count the dollar value of work performed under a contract with a firm after it has ceased to be certified toward your overall goal. (h) Do not count the participation of a DBE subcontractor toward the prime contractor's DBE achievements or your overall goal until the amount being counted toward the goal has been paid to the DBE. Subpart D—Certification Standards § 26.61 How are burdens of proof allocated in the certification process? (a) In determining whether to certify a firm as eligible to participate as a DBE, you must apply the standards of this subpart. (b) The firm seeking certification has the burden of demonstrating to you, by a preponderance of the evidence, that it meets the requirements of this subpart concerning group membership or individual disadvantage, business size, ownership, and control. (c) You must rebuttably presume that members of the designated groups 5136 Federal Register/Vol. 64, No. 21 /Tuesday;' February 2, 1999 /Rules and Regulations identified in §26.67(a) are socially and economically disadvantaged. This means that they do not have the burden of proving to you that they are socially and economically disadvantaged. However, applicants have the obligation to provide you information concerning their economic disadvantage (see § 26.67). (d) Individuals who are not presumed to be socially and economically disadvantaged, and individuals concerning whom the presumption of disadvantage has been rebutted, have the burden of proving to you. by a preponderance of the evidence, that they are socially and economically disadvantaged. (See Appendix E of this part.) (e) You must make determinations concerning whether individuals and firms have met their burden of demonstrating group membership, ownership, control, and social and economic disadvantage (where disadvantage must be demonstrated on an individual basis) by considering all the facts in the record, viewed as a whole. § 26.63 What rules govern group membership determinations? (a) If you have reason to question whetner an individual is a member of a group that is presumed to be socially and economically disadvantaged. you must require the individual to - demonstrate. by a preponderance Of the evidence, that he or she is a member of the group (b) In making such a determination. you must consider whether the person has held himself out to be a member of the group over a long period of time prior to application for certification and whether the person is regarded as a member of the group by the relevant community You may require the applicant to produce appropriate documentation of group membership (1) If you determine that an individual claiming to be a member of a group presumed to be disadvantaged is not a member of a designated disadvantaged group, the individual must demonstrate social and economic disadvantage on an individual basis (2) Your decisions concerning membership in a designated group are subject to the certification appeals procedure of §26.89. § 26.65 What rules govern business size determinations? (a) To be an eligible DBE, a firm (including its affiliates) must be an existing small business, as defined by Small Business Administration (SBA) standards You must apply current SBA business size standard(s) found in 13 CFR part 121 appropriate to the type(s) of work the firm seeks to perform in DOT -assisted contracts. "f°4 (b) Even if it meets the requirements of paragraph (a) of this section, a firm is not an eligible DBE in any Federal fiscal year if the firm (including its affiliates) has had average annual gross receipts, as defined by SBA regulations (see 13 CFR 121.402), over the firm's previous three fiscal years, in excess of $16.6 million. The Secretary adjusts this amount for inflation from time to time. § 26.67 What rules determine social and economic disadvantage? (a) Presumption of disadvantage. (1) You must rebuttably presume that citizens of the United States (or lawfully admitted permanent residents) who are women, Black Americans, Hispanic Americans, Native Americans, Asian - Pacific Americans. Subcontinent Asian Americans, or other minorities found to be disadvantaged by the SBA, are socially and economically disadvantaged individuals. You must require applicants to submit a signed, notarized certification that each presumptively disadvantaged owner is, in fact, socially and economically disadvantaged (2) (i) You must require each.; .. individual owner of a firm applying to participate as a DBE whose ownership and control are relied upon for DBE Ce`tiflcatiOn to subrn: a si_r.e'd notarized statement of personal net worth, with appropriate supporting documentation. (ii) In determining net worth, you must exclude an individual's ownership interest in the applicant firm and the individual's equity in his or her primary residence (except any portion of such equity that is attributable to excessive withdrawals from the applicant firm) A contingent liability does not reduce an individual's net worth. The personal net worth of an individual claiming to be an Alaska Native will include assets and income from sources other than an Alaska Native Corporation and exclude any of the following which the individual receives from any Alaska Native Corporation. cash (including cash dividends on stock received from an ANC) to the extent that it does not, in the aggregate, exceed S2,000 per individual per annum, stock (including stock issued or distributed by an ANC as a dividend or distribution on stock), a partnership interest: land or an interest in land (including land or an interest in land received from an ANC as a dividend or distribution on stock); and an interest in a settlement trust. (b) Rebuttal of presumption of disadvantage. (1) If the statement of personal net worth that an individual submits under paragraph (a)(2) of this section shows that the individual's personal net worth exceeds $750,000, the individual's presumption of economic disadvantage is rebutted. You are not required to have a proceeding under paragraph (b) (2) of this section in order to rebut the presumption of economic disadvantage in this case. (2) If you have a reasonable basis to believe that an individual who is a member of one of the designated groups is not, in fact, socially and/or economically disadvantaged you may. at any time, start a proceeding to determine whether the presumption should be regarded as rebutted with respect to that individual. Your proceeding must follow the procedures of § 26.87. (3) In such a proceeding, you have the burden of demonstrating. by a preponderance of the evidence. that the individual is not socially and economically disadvantaged. You may require the individual to produce information relevant to the determination of his or her disadvantage (4) When an individual's presumption of social and/or economic disadvantage has been rebutted, his or her ownership and control of the firm in question cannot be used for purposes of DBE eligibility under this subpart unless and until he or she makes an individual showing of social and/or economic disadvantage. If the basis for rebutting the presumption is a determination that the individual's personal net worth exceeds S750,000, the individual is no longer eligible for participation in the program and cannot regain eligibility by making an individual showing of disadvantage (c) 8(a) and SDB Firms. If a firm applying for certification has a current, valid certification from or recognized by the SBA under the 8(a) or small and disadvantaged business (SDB) program (except an SDB certification based on the firm's self -certification as an SDB), you may accept the firm's 8(a) or SDB certification in lieu of conducting your own certification proceeding, just as you may accept the certification of another DOT recipient for this purpose. You are not required to do so, however (d) Individual determinations of social and economic disadvantage. Firms owned and controlled by individuals who are not presumed to be socially and economically disadvantaged (including individuals whose presumed disadvantage has been rebutted) may apply for DBE Federal Register/Vol. 64, No. 21 /Tuesday, February 2. 1999 /Rules and Regulations 5137 certification. You must make a case-by- case determination of whether each individual whose ownership and control are relied upon for DBE certification is socially and economically disadvantaged. In such a proceeding, the applicant firm has the burden of demonstrating to you, by a preponderance of the evidence, that the individuals who own and control it are socially and economically disadvantaged. An individual whose personal net worth exceeds $750,000 shall not be deemed to be economically disadvantaged. In making these determinations, use the guidance found in Appendix E of this part. You must require that applicants provide sufficient information to permit determinations under the guidance of Appendix E of this part. § 26.69 What rules govern determinations of ownership? (a) In determining whether the socially and economically disadvantaged participants in a firm own the firm, you must consider all the facts in the record, viewed as a whole. (b) To be an eligible DBE, a firm must be at least 51 percent owned by socially and economically disadvantaged individuals. (1) In the case of a corporation, such individuals must own at least 51 percent of the each class of voting stock outstanding. and 51 percent of the aggregate of all stock outstanding (2) In the case of a partnership, 51 percent of each class of partnership interest must be owned by socially and economically disadvantaged individuals Such ownership must be reflected in the firm's partnership agreement. (3) In the case of a limited liability company, at least 51 percent of each class of member interest must be owned by socially and economically disadvantaged individuals. (c) The firm's ownership by socially and economically disadvantaged individuals must be real, substantial, and continuing, going beyond pro forma ownership of the firm as reflected in ownership documents. The disadvantaged owners must enjoy the customary incidents of ownership, and share in the risks and profits commensurate with their ownership interests, as demonstrated by the substance, not merely the form, of arrangements. (d) All securities that constitute ownership of a firm shall be held directly by disadvantaged persons. Except as provided in this paragraph (d), no securities or assets held in trust. or by any guardian for a minor, are considered as held by disadvantaged persons in determining the ownership of a firm. However, securities or assets held in trust are regarded as held by a disadvantaged individual for purposes of determining ownership of the firm, if— (1) The beneficial owner of securities or assets held in trust is a disadvantaged individual, and the trustee is the same or another such individual; or (2) The beneficial owner of a trust is a disadvantaged individual who, rather than the trustee, exercises effective control over the management, policy- making, and daily operational activities of the firm. Assets held in a revocable living trust may be counted only in the situation where the same disadvantaged individual is the sole grantor, beneficiary, and trustee. (e) The contributions of capital or expertise by the socially and economically disadvantaged owners to acquire their ownership interests must be real and substantial. Examples of insufficient contributions include a promise to contribute capital. an unsecured note payable to the firm or an owner who is not a disadvantaged individual, or mere participation in a firm's activities as an employee Debt instruments from financial institutions or other organizations that lend funds in the normal course of their business do not render a firm ineligible, even if the debtor's ownership interest is security for the loan (f) The following requirements apply to situations in which expertise is relied upon as part of a disadvantaged owner's contribution to acquire ownership (1) The owner s expertise must be— (i) In a specialized field: (ii) Of outstanding quality; (iii) In areas critical to the firm's operations, (iv) Indispensable to the firm's potential success, (v) Specific to the type of work the firm performs: and (vi) Documented in the records of the firm. These records must clearly show the contribution of expertise and its value to the firm (2) The individual whose expertise is relied upon must have a significant financial investment in the firm. (g) You must always deem as held by a socially and economically disadvantaged individual, for purposes of determining ownership, all interests in a business or other assets obtained by the individual— (1) As the result of a final property settlement or court order in a divorce or legal separation, provided that no term or condition of the agreement or divorce decree is inconsistent with this section, or (2) Through inheritance, or otherwise because. of the death of the former owner. (h) (1) You must presume as not being held by a socially and economically disadvantaged individual, for purposes of determining ownership. al' interests in a business or other assets ootained by the individual as the result of a gift, or transfer without adequate consideration, from any non -disadvantaged individual or non -DBE firm who is— (i) Involved in the same firm for which the individual is seeking certification, or an affiliate of that firm; (ii) Involved in the same or a similar line of business; or (iii) Engaged in an ongoing business relationship with the firm, or an affiliate of the firm, for which the individual is seeking certification. (2) To overcome this presumption and permit the interests or assets to be counted, the disadvantaged individual must demonstrate to you, by clear and convincing evidence, that— (i) The gift or transfer to the disadvantaged individual was made for reasons other than obtaining certification as a DBE: and (ii) The disadvantaged individual actually controls the management, policy, and operations of the firm, notwithstanding the continuing participation of a non -disadvantaged individual who provided the gift or transfer (i) You must apply the following rules in situations in which marital assets form a basis for ownership of a firm. (1) When marital assets (other than the assets of the business in question), held jointly or as community property by both spouses, are used to acquire the ownership interest asserted by one spouse, you must deem the ownership interest in the firm to have been acquired by that spouse with his or her own individual resources, provided that the other spouse irrevocably renounces and transfers all rights in the ownership interest in the manner sanctioned by the laws of the state in which either spouse or the firm is domiciled. You do not count a greater portion of joint or community property assets toward ownership than state law would recognize as belonging to the socially and economically disadvantaged owner of the applicant firm (2) A copy of the document legally transferring and renouncing the other spouse's rights in the jointly owned or community assets used to acquire an ownership interest in the firm must be included as part of the firm's application for DBE certification. 5138 Federal Register /Vol. 64, No. 21 /Tuesday;'3February 2, 1999 / Rules and Regulations (j) You may consider the following factors in determining the ownership of a firm. However, you must not regard a contribution of capital as failing to be real and substantial. or find a firm ineligible, solely because— (1) A socially and economically disadvantaged individual acquired his or her ownership interest as the result of a gift, or transfer without adequate consideration, other than the types set forth in paragraph (h) of this section, (2) There is a provision for the co - signature of a spouse who is not a socially and economically disadvantaged individual on financing agreements, contracts for the purchase or sale of real or personal property, bank signature cards, or other documents, or (3) Ownership of the firm in question or its assets is transferred for adequate consideration from a spouse who is not a socially and economically disadvantaged individual to a spouse who is such an individual. In this case, you must give particularly close and careful scrutiny to the ownership and control of a firm to ensure that it is owned and controlled, in substance as well as in form, by a socially and economically disadvantaged individual. §26.71 What rules govern determinations concerning control? (a) In determining whether socially and economicaildisadvantaged owners control a firm, you must consider all the facts in the record, vie'.ved as a v hole (b) Oni;. an independent business may be certified as a DBE. An independent business is one the viability of which does not depend on its relationship with another firm or firms. (1) In determining whether a potential DBE is an independent business, you must scrutinize relationships with non - DBE firms, in such areas as personnel, facilities, equipment, financial and/or bonding support, and other resources. (2) You must consider whether present or recent employer/employee relationships between the disadvantaged owner(s) of the potential DBE and non -DBE firms or persons associated with non -DBE firms compromise the independence of the potential DBE firm. (3) You must examine the firm's relationships with prime contractors to determine whether a pattern of exclusive or primary dealings with a prime contractor compromises the independence of the potential DBE firm. (4) In considering factors related to the independence of a potential DBE firm, you must consider the consistency of relationships between the potential DBE and non -DBE firms with normal industry practice. (c) A DBE, firm must not be subject to any formal or''informal restrictions which limit the customary discretion of the socially and economically disadvantaged owners. There can be no restrictions through corporate charter provisions, by-law provisions, contracts or any other formal or informal devices (e.g . cumulative voting rights. voting powers attached to different classes of stock. employment contracts, requirements for concurrence by non - disadvantaged partners, conditions precedent or subsequent, executory agreements, voting trusts, restrictions on or assignments of voting rights) that prevent the socially and economically disadvantaged owners, without the cooperation or vote of any non - disadvantaged individual, from making any business decision of the firm. This paragraph does not preclude a spousal co -signature on documents as provided for in §26.69(j)(2) (d) The socially and economically disadvantaged owners must possess the power to direct or cause the direction of the management and policies of the firm and to make day-to-day as well as long- term decisions on matters of management, policy and operations (1) A disadvantaged owner must hold the highest officer position in the company (e g chief executive officer or president) (2) In a corporation. disadvantaged owners must control the board of directors (3) In a partnership, one or more disadvantaged owners must serve as general partners. with control over all partnership decisions (e) Individuals who are not socially and economically disadvantaged may be involved in a DBE.firm as owners, managers, employees, stockholders, officers, and/or directors. Such individuals must not, however, possess or exercise the power to control the firm, or be disproportionately responsible for the operation of the firm. (f) The socially and economically disadvantaged owners of the firm may delegate various areas of the management, policymaking, or daily operations of the firm to other participants in the firm, regardless of whether these participants are socially and economically disadvantaged individuals. Such delegations of authority must be revocable, and the socially and economically disadvantaged owners must retain the power to hire and fire any person to whom such authority is delegated. The managerial role of the socially and economically disadvantaged owners in. the firm's overall affairs must be such that the recipient can reasonably conclude that the socially and economically disadvantaged owners actually exercise control over the firm's operations, management. and policy. (g) The socially and economically disadvantaged owners must have an overall understanding of, and managerial and technical competence and experience directly related to, the type of business in which the firm is engaged and the firm's operations. The socially and economically disadvantaged owners are not required to have experience or expertise in every critical area of the firm's operations, or to have greater experience or expertise in a given field than managers or key employees. The socially and economically disadvantaged owners must have the ability to intelligently and critically evaluate information presented by other participants in the firm's activities and to use this information to make independent decisions concerning the firm's daily operations, management. and policymaking Generally, expertise Limited to office management, administration, or bookkeeping functions unrelated to the principal business activities of the firm is insufficient to demonstrate control. (h) If state or local law. requires the persons to have a particular license or other credential in order to own and/or control a certain type of firm, then the socially and economically disadvantaged persons who own and control a potential DBE firm of that type must possess the required license or credential. If state or local law does not require such a person to have such a license or credential to own and/or control a firm, you must not deny certification solely on the ground that the person lacks the license or credential. However, you may take into account the absence of the license or credential as one factor in determining whether the socially and economically disadvantaged owners actually control the firm (i) (1) You may consider differences in remuneration between the socially and economically disadvantaged owners and other participants in the firm in determining whether to certify a firm as a DBE. Such consideration shall be in the context of the duties of the persons involved, normal industry practices, the firm's policy and practice concerning reinvestment of income, and any other explanations for the differences proffered by the firm. You may determine that a firm is controlled by its socially and economically disadvantaged owner although that Federal Register /Vol. 64, No. 21 /Tuesday, February 2, 1999 / Rules and Regulations 5139 owner's remuneration is lower than that of some other participants in the firm. (2) In a case where a non - disadvantaged individual formerly controlled the firm, and a socially and economically disadvantaged individual now controls it. you may consider a difference between the remuneration of the former and current controller of the fine as a factor in determining who controls the firm, particularly when the non -disadvantaged individual remains involved with the firm and continues to receive greater compensation than the disadvantaged individual. (j) In order to be viewed as controlling a firm, a socially and economically disadvantaged owner cannot engage in outside employment or other business interests that conflict with the management of' the firm or prevent the individual from devoting sufficient time and attention to the affairs of the firm to control its activities. For example, absentee ownership of a business and part-time work in a full-time firm are not viewed as constituting control. However, an individual could be viewed as controlling a part-time business that operates only on evenings and/or weekends, if the individual controls it all the time it is operating (k)(1) A socially and economically disadvantaged individual may control a firm even though one or more of the individual s immediate family members (who themselves are not socially and economically disadvantaged individuals) participate in the firm as a manager. employee, owner, or in another capacity Except as otherwise provided in this paragraph, you must make a judgment about the control the socially and economically disadvantaged owner exercises vis-a-vis other persons involved in the business as you do in other situations, without regard to whether or not the other persons are immediate family members. (2) If you cannot determine that the socially and economically disadvantaged owners—as distinct from the family as a whole—control the firm, then the socially and economically disadvantaged owners have failed to carry their burden of proof concerning control, even though they may participate significantly in the firm's activities. (1) Where a firm was formerly owned and/or controlled by a non - disadvantaged individual (whether or not an immediate family member), ownership and/or control were transferred to a socially and economically disadvantaged individual, and the non -disadvantaged individual remains involved with the firm in any capacity. the disadvantaged individual now owning the firm must demonstrate to you, by clear and convincing evidence, that: (1) The transfer of ownership and/or control to the disadvantaged individual was made for reasons other than obtaining certification as a DBE; and (2) The disadvantaged individual actually controls the management, policy, and operations of the firrn, notwithstanding the continuing participation of a non -disadvantaged individual who formerly owned and/or controlled the firm. (m) In determining whether a firm is controlled by its socially and economically disadvantaged owners. you may consider whether the firm owns equipment necessary to perform its work. However. you must not determine that a firm is not controlled by socially and economically disadvantaged individuals solely because the firm leases, rather than owns, such equipment, where leasing equipment is a normal industry practice and the lease does not involve a relationship with a prime contractor or other party that compromises the independence of the firm. (n) You must grant certification to a firm only for specific types of work in which the socially and economically disadvantaged .owners have the ability to control the firm. To become certified in an additional type of w ork the firm need demonstrate to you only that its socially and economically disadvantaged owners are able to control the firm with respect to that type of work. You may not, in this situation, require that the firm be recertified or submit a new application for certification, but you must verify the disadvantaged owner's control of the firm in the additional type of work. (o) A business operating under a franchise or license agreement may be certified if it meets the standards in this subpart and the franchiser or licenser is not affiliated with the franchisee or licensee. In determining whether affiliation exists, you should generally not consider the restraints relating to standardized quality, advertising, accounting format, and other provisions imposed on the franchisee or licensee by the franchise agreement or license, provided that the franchisee or licensee has the right to profit from its efforts and bears the risk of loss commensurate with ownership Alternatively, even though a franchisee or licensee may not be controlled by virtue of such provisions in the franchise agreement or license, affiliation could arise through other means, such as common management or excessive restrictions on the sale or transfer of the franchise interest or license. (p) In order for a partnership to be controlled by socially and economically disadvantaged individuals, any non - disadvantaged partners must not have the power, without the specific written concurrence of the socially and economically disadvantaged partner(s), to contractually bind the partnership or subject the partnership to contract or tort liability. (q) The socially and economically disadvantaged individuals controlling a firm may use an employee leasing company. The use of such a company does not preclude the socially and economically disadvantaged individuals from controlling their firm if they continue to maintain an employer- employee relationship with the leased employees. This includes being responsible for hiring, firing. training, assigning. and otherwise controlling the on-the-job activities of the employees, as well as ultimate responsibility for wage and tax obligations related to the employees § 26.73 What are other rules affecting certification? (a)(1) Consideration of whether a firm performs a commercially useful function or is a regular dealer pertains solely to counting toward DBE goals the participation of firms that have already been certified as DBEs Except as provided in paragraph (a) (2) of this section, you must not consider commercially useful function issues in any way in making decisions about whether to certify a firm as a DBE. (2) You may consider, in making certification decisions, whether a firm has exhibited a pattern of conduct indicating its involvement in attempts to evade or subvert the intent or requirements of the DBE program. (b) You must evaluate the eligibility of a firm on the basis of present circumstances. You must not refuse to certify a firm based solely on historical information indicating a lack of ownership or control of the firm by socially and economically disadvantaged individuals at some time in the past, if the firm currently meets the ownership and control standards of this part. Nor must you refuse to certify a firm solely on the basis that it is a newly formed firm. (c) DBE firms and firms seeking DBE certification shall cooperate fully with your requests (and DOT requests) for information relevant to the certification process. Failure or refusal to provide such information is a ground for a denial or removal of certification. 5140 Federal Register /Vol 64, No. 21 /Tuesday, February 2, 1999 / Rules and Regulations (d) Only firms organized for profit may be eligible DBEs. Not-for-profit organizations. even though controlled by socially and economically disadvantaged individuals, are not eligible to be certified as DBEs. (e) An eligible DBE firm must be owned by individuals who are socially and economically disadvantaged. Except as provided in this paragraph. a firm that is not owned by such individuals, but instead is owned by another firm—even a DBE firm—cannot be an eligible DBE. (1) If socially and economically disadvantaged individuals own and control a firm through a parent or holding company, established for tax, capitalization or other purposes consistent with industry practice, and the parent or holding company in turn owns and controls an operating subsidiary, you may certify the subsidiary if it otherwise meets all requirements of this subpart. In this situation, the individual owners and controllers of the parent or holding company are deemed to control the subsidiary through the parent or holding company (2) You may certify such a subsidiary only if there is cumulatively 51 percent ownership of the subsidiary by socially and economically disadvantaged individuals The following examples illustrate hov, this cumulative ownership provision works Example' Social, and econor icall:. disadvantaged individuals own 100 percent of a holding company • which has a wholly- owned subsidiary The subsidiary may be certified, if it meets all other requirements. Example 2.' Disadvantaged individuals own 100 percent of the holding company, which owns 51 percent of a subsidiary The subsidiary may be certified, if all other requirements are met. Example 3. Disadvantaged individuals own 80 percent of the holding company. which in turn owns 70 percent of a subsidiary In this case, the cumulative ownership of the subsidiary by disadvantaged individuals is 56 percent (80 percent of the 70 percent) This is more than 51 percent, so you may certify the subsidiary, if all other requirements are met. Example 4. Same as Example 2 or 3, but someone other than the socially and economically disadvantaged owners of the parent or holding company controls the subsidiary. Even though the subsidiary is owned by disadvantaged individuals, through the holding or parent company, you cannot certify it because it fails to meet control requirements. Example 5 Disadvantaged individuals own 60 percent of the holding company, which in tum owns 51 percent of a subsidiary In this case, the cumulative ownership of the subsidiary by disadvantaged individuals is about 31 percent. This is less than 51 percent. so you cannot certify the subsidiary Example 6. The holding company, in addition to the subsidiary seeking certification, owns several other. companies. The combined'gross receipts df the"holding companies and its subsidiaries are greater than the size standard for the subsidiary seeking certification and/or the gross receipts cap of § 26.65(b). Under the rules concerning affiliation, the subsidiary fails to meet the size standard and cannot be certified. (f) Recognition of, a business as a separate entity for tax or corporate purposes is not necessarily sufficient to demonstrate that a firm is an independent business, owned and controlled by socially and economically disadvantaged individuals. (g) You must not require a DBE firm to be prequalified as a condition for certification unless the recipient requires all firms that participate in its contracts and subcontracts to be prequalified. (h) A firm that is owned by an Indian tribe, Alaska Native Corporation, or Native Hawaiian organization as an entity, rather than by Indians, Alaska Natives, or Native Hawaiians as individuals, may be eligible for certification. Such a firm must meet the size standards of § 26 65 Such a firm must be controlled by socially and economically disadvantaged individuals as provided in § 26 71 Subpart E—Certification Procedures § 26.81 What are the requirements for Unified Certification Programs? (a You and all other DOT recipients in your state must participate in a Unified Certification Program (UCP) (1) Within three years of March 4, 1999, you and the other recipients in your state must sign an agreement establishing the UCP for that state and submit the agreement to the Secretary for approval. The Secretary may, on the basis of extenuating circumstances shown by the recipients in the state, extend this deadline for no more than one additional year (2) The agreement must provide for the establishment of a UCP meeting all the requirements of this section The agreement must specify that the UCP will follow all certification procedures and standards of this part, on the same basis as recipients. that the UCP shall cooperate fully with oversight, review, and monitoring activities of DOT and its operating administrations, and that the UCP shall implement DOT directives and guidance concerning certification matters. The agreement shall also commit recipients to ensuring that the UCP has sufficient resources and expertise to carry out the requirements Of this part. The agreement shall include an implementation schedule ensuring that the UCP is fully operational no later than 18 months following the approval of the agreement by the Secretary. (3) Subject to approval by the Secretary. the UCP in each state may take any form acceptable to the recipients in that state. (4) The Secretary shall review the UCP and approve it, disapprove it. or remand it to the recipients in the state for revisions. A complete agreement which is not disapproved or remanded within 180 days of its receipt is deemed to be accepted. (5) If you and the other recipients in your state fail to meet the deadlines set forth in this paragraph (a), you shall have the opportunity to make an explanation to the Secretary why a deadline could not be met and why meeting the deadline was beyond your control. If you fail to make such an explanation, or the explanation does not justify the failure to meet the deadline, the Secretary shall direct you to complete the required action by a date certain. If you and the other recipients fail to carry out this direction in a timely mariner, you are collectively in noncompliance with this part. (b) The UCP shall make all certification decisions on behalf of all DOT recipients in the state with respect to participation in the DOT DBE Program. (1) Certification decisions by the UCP shall be binding on all DOT recipients within the state. (2) The UCP shall provide "one-stop shopping" to applicants for certification, such that an applicant is required to apply only once for a DBE certification that will be honored by all recipients in the state. (3) All obligations of recipients with respect to certification and nondiscrimination must be carried out by UCPs, and recipients may use only UCPs that comply with the certification and nondiscrimination requirements of this part. (c) All certifications by UCPs shall be pre -certifications, i.e., certifications that have been made final before the due date for bids or offers on a contract on which a firm seeks to participate as a DBE. (d) A UCP is not required to process an application for certification from a firm having its principal place of business outside the state if the firm is not certified by the UCP in the state in which it maintains its principal place of business. The "home state" UCP shall share its information and documents concerning the firm with other UCPs that are considering the firm's application Federal Register /Vol. 64, No. 21 /Tuesday, February 2, 1999 /Rules and Regulations 5141 (e) Subject to DOT approval as provided in this section. the recipients in two or more states may form a regional UCP. UCPs may also enter into written reciprocity agreements with other UCPs. Such an agreement shall outline the specific responsibilities of each participant. A UCP may accept the certification of any other UCP or DOT recipient. (f) Pending the establishment of UCPs meeting the requirements of this section, you may enter into agreements with other recipients, on a regional or inter jurisdictional basis, to perform certification functions required by this part. You may also grant reciprocity to other recipient's certification decisions. (g) Each UCP shall maintain a unified DBE directory containing, for all firms certified by the UCP (including those from other states certified under the provisions of this section), the information required by § 26.31. The UCP shall make the directory available to the public electronically, on the internet, as well as in print. The UCP shall update the electronic version of the directory by including additions, deletions, and other changes as soon as they are made. (h) Except as otherwise specified in this section, all provisions of this subpart and subpart D of this part pertaining to recipients also apply to UCPs § 25.83 What procedures do recipients follow in making certification decisions? (a) You must ensure that only firms certified as eligible DBEs under this section participate as DBEs in your program. (b) You must determine the eligibility of firms as DBEs consistent with the standards of Subpart D of this part. When a UCP is formed, the UCP must meet all the requirements of subpart D of this part and this subpart that recipients are required to meet. (c) You must take all the following steps in determining whether a DBE firm meets the standards of subpart D of this part: (1) Perform an on-site visit to the offices of the firm. You must interview the principal officers of the firm and review their resumes and/or work histories You must also perform an on- site visit to job sites if there are such sites on which the firm is working at the time of the eligibility investigation in your jurisdiction or local area. You may rely upon the site visit report of any other recipient with respect to a firm applying for certification. (2) If the firm is a corporation, analyze the ownership of stock in the firm, (3) Analyze the bonding and financial capacity of the firm; (4) Determine the work history of the firm, including contracts it has received and work it has completed, (5) Obtain a statement from the firm of the type of work it prefers to perform as part of the DBE program and its preferred locations for performing the work, if any; (6) Obtain or compile a list of the equipment owned by or available to the firm and the licenses the firm and its key personnel possess to perform the work it seeks to do as part of the DBE program; (7) Require potential DBEs to complete and submit an appropriate application form. (i) Uniform form. [Reserved] (ii) You must make sure that the applicant attests to the accuracy and truthfulness of the information on the application form. This shall be done either in the form of an affidavit sworn to by the applicant before a person who is authorized by state law to administer oaths or in the form of an unsworn declaration executed under penalty of perjury of the laws of the United States. (iii) You must review all information on the form prior to making a decision about the eligibility of the firm. (d) When another recipient, in connection with its consideration of the of a firm makes a written request for certification information you have obtained about that firm (e g including appiication materials or the report of a site visit. if you have made one to the firm), you must promptly make the information available to the other recipient. (e) When another DOT recipient has certified a firm, you have discretion to take any of the following actions. (1) Certify the firm in reliance on the certification decision of the other recipient: (2) Make an independent certification decision based on documentation provided by the other recipient, augmented by any additional information you require the applicant to provide, or (3) Require the applicant to go through your application process without regard to the action of the other recipient. (f) Subject to the approval of the concerned operating administration as part of your DBE program, you may impose a reasonable application fee for certification. Fee waivers shall be made in appropriate cases. (g) You must safeguard from disclosure to unauthorized persons information gathered as part of the certification process that may reasonably be regarded as proprietary or other confidential business information, consistent with applicable Federal. state, and local law. (h) Once you have certified a DBE, it shall remain certified for a period of at least three years unless and until its certification has been removed through the procedures of § 26.87. You may not require DBEs to reapply for certification as a condition of continuing to participate in the program during this three-year period, unless the factual basis on which the certification was made changes. (i) If you are a DBE, you must inform the recipient or UCP in writing of any change in circumstances affecting your ability to meet size, disadvantaged status, ownership, or control requirements of this part or any material change in the information provided in your application form. (1) Changes in management responsibility among members of a limited liability company are covered by this requirement. (2) You must attach supporting documentation describing in detail the nature of such changes. (3) The notice must take the form of an affidavit sworn to by the applicant before a person who is authorized by state law to administer oaths or of an unsworn declaration executed under penalty of perjury of the laws of the United States You must provide the written notification within 30 days of the occurrence of the change If you fail to make timely notification of such a change, you will be deemed to have failed to cooperate under § 26.109(c) 0) If you are a DBE, you must provide to the recipient, every year on the anniversary of the date of your certification, an affidavit sworn to by the firm's owners before a person who is authorized by state law to administer oaths or an unsv. orn declaration executed under penalty of perjury of the laws of the United States. This affidavit must affirm that there have been no changes in the firm's circumstances affecting its ability to meet size, disadvantaged status, ownership, or control requirements of this part or any material changes in the information provided in its application form, except for changes about which you have notified the recipient under paragraph (i) of this section. The affidavit shall specifically affirm that your firm continues to meet SBA business size criteria and the overall gross receipts cap of this part, documenting this affirmation with supporting documentation of your firm's size and gross receipts. If you fail to provide this affidavit in a timely manner, you will be 5142 Federal Register /Vol. 64, No. 21 /Tuesday, February 2, 1999 /Rules and Regulations deemed to have failed to cooperate under §26.109(c). (k) If you are a recipient, you must make decisions on applications for certification within 90 days of receiving from the applicant firm all information required under this part. You may extend this time period once, for no more than an additional 60 days, upon written notice to the firm, explaining fully and specifically the reasons for the extension. You may establish a different time frame in your DBE program, upon a showing that this time frame is not feasible. and subject to the approval of the concerned operating administration. Your failure to make a decision by the applicable deadline under this paragraph is deemed a constructive denial of the application, on the basis of which the firm may appeal to DOT under § 26 89 § 26.85 What rules govern recipients' denials of initial requests for certification? (a) When you deny a request by a firm, which is not currently certified with you, to be certified as a DBE, you must provide the firm a written explanation of the reasons for the denial. specifically referencing the evidence in the record that supports each reason for the denial. Ali documents and other information on v` hich the denial is based must be made available to the applicant. on request. (b) \\ hen a firm is denied certification you roust establish a time period of no more than twelve months that must elapse before the firm may reapply to the recipient for certification You may provide. in your DBE program, subject to approval by the concerned operating administration, a shorter waiting period for reapplication. The time period for reapplication begins to run on the date the explanation required by paragraph (a) of this section is received by the firm. (c) When you make an administratively final denial of certification concerning a firm, the firm may appeal the denial to the Department under ,§26 89. § 26.87 What procedures does a recipient use to remove a DBE's eligibility? (a) Ineligibility complaints. (1) Any person may file with you a written complaint alleging that a currently - certified firm is ineligible and specifying the alleged reasons why the firm is ineligible You are not required to accept a general allegation that a firm is ineligible or an anonymous complaint. The complaint may include any information or arguments supporting the complainant's assertion that the firm is ineligible and should not continue to be certified. Confidentiality of complainants' identities must be protected as,provided in §26.109(b). (2) You must review your records concerning the firm, any material provided by the firm and the complainant, and other available information. You may request additional information from the firm or conduct any other investigation that you deem necessary. (3) If you determine, based on this review, that there is reasonable cause to believe that the firm is ineligible, you must provide written notice to the firm that you propose to find the firm ineligible, setting forth the reasons for the proposed determination. If you determine that such reasonable cause does not exist, you must notify the complainant and the firm in writing of this determination and the reasons for it. All statements of reasons for findings on the issue of reasonable cause must specifically reference the evidence in the record on which each reason is based. (b) Recipient -initiated proceedings. If, based on notification by the firm of a change in its circumstances or other information that comes to your attention, you determine that there is reasonable cause to believe that a currently certified firm is ineligible you must provide written notice to the firm that you propose to find the firm ineligible, setting forth the reasons for the proposed determination The statement of reasons for the finding of reasonable cause must specifically reference the evidence in the record on which each reason is based (c) DOT directive to initiate proceeding (1) If the concerned operating administration determines that information in your certification records, or other information available to the concerned operating administration, provides reasonable cause to believe that a firm you certified does not meet the eligibility criteria of this part, the concerned operating administration may direct you to initiate a proceeding to remove the firm's certification. (2) The concerned operating administration must provide you and the firm a notice setting forth the reasons for the directive, including any relevant documentation or other information (3) You must immediately commence and prosecute a proceeding to remove eligibility as provided by paragraph (b) of this section (d) Hearing When you notify a firm that there is reasonable cause to remove its eligibility, as provided in paragraph (a), (b), or (d) of this section, you must give the firm an opportunity for an informal hearing. at which the firm may respond to the reasons for the proposal to remove its eligibility in person and provide information and arguments concerning why it should remain certified. (1) In such a proceeding, you bear the burden of proving, by a preponderance of the evidence, that the firm does not meet the certification standards of this part. (2) You must maintain a complete record of the hearing, by any means acceptable under state law for the retention of a verbatim record of an administrative hearing If there is an appeal to DOT under § 26.89, you must provide a transcript of the hearing to DOT and, on request. to the firm. You must retain the original record of the hearing. You may charge the firm only for the cost of copying the record. (3) The firm may elect to present information and arguments in writing, without going to a hearing In such a situation. you bear the same burden of proving by a preponderance of the evidence, that the firm does not meet the certification standards. as you would during a hearing (e) Separation of functions. You must ensure that the decision in a proceeding to remove a firm's eligibility is made by an office and personnel that did not take part in actions leading to or seeking to implement the proposal to remove the firm's eligibility and are not subject. \vith respect to the matter, to direction from the office or personnel who did take part in these actions. (1) Your method of implementing this requirement must be made part of your DBE program. (2) The decisionmaker must be an individual who is knowledgeable about the certification requirements of your DBE program and this part. (3) Before a UCP is operational in its state, a small airport or small transit authority (i e , an airport or transit authority serving an area with less than 250,000 population) is required to meet this requirement only to the extent feasible. (f) Grounds for decision. You must not base a decision to remove eligibility on a reinterpretation or changed opinion of information available to the recipient at the time of its certification of the firm. You may base such a decision only on one or more of the following: (1) Changes in the firm's circumstances since the certification of the firm by the recipient that render the firm unable to meet the eligibility standards of this part: Federal Register/Vol. 64, No. 21/Tuesday, February 2, 1999/Rules and Regulations 5143 (2) Information or evidence not available to you at the time the firm was certified; (3) Information that was concealed or misrepresented by the firm in previous certification actions by a recipient; (4) A change in the certification standards or requirements of the Department since you certified the firm; or (5) A documented finding that your determination to certify the firm was factually erroneous. (g) Notice of decision. Following your decision. you must provide the firm written notice of the decision and the reasons for it. including specific references to the evidence in the record that supports each reason for the decision. The notice must inform the firm of the consequences of your decision and of the availability of an appeal to the Department of Transportation under § 26 89. You must send copies of the notice to the complainant in an ineligibility complaint or the concerned operating administration that had directed you to initiate the proceeding. (h) Status of firm during proceeding. (1) A firm remains an eligible DBE during the pendancy of your proceeding to remove its eligibility (2) The firrn does not become ineligible until the issuance of the notice provided for in paragraph (g) of this section. (i) Effects of removal of eligibility When you remove a firm's eligibility, you must take the following action (1) When a prime contractor has made a commitment to using the ineligible firm, or you have made a commitment to using a DBE prime contractor. but a subcontract or contract has not been executed before you issue the decertification notice provided for in paragraph (g) of this section. the ineligible firm does not count toward the contract goal or overall goal. You must direct the prime contractor to meet the contract goal with an eligible DBE firm or demonstrate to you that it has made a good faith effort to do so (2) If a prime contractor has executed a subcontract with the firm before you have notified the firm of its ineligibility, the prime contractor may continue to use the firm on the contract and may continue to receive credit toward its DBE goal for the firm's work. In this case, or in a case where you have let a prime contract to the DBE that was later ruled ineligible, the portion of the ineligible firm's performance of the contract remaining after you issued the notice of its ineligibility shall not count toward your overall goal, but may count toward the contract goal (3) Exception: If the DBE's ineligibility is caused solely by its having exceeded the size standard during the performance of the contract, you may continue to count its participation on that contract toward overall and contract goals. (j) Availability of appeal. When you make an administratively final removal of a firm's eligibility under this section, the firm may appeal the removal to the Department under § 26.89. § 26.89 What is the process for certification appeals to the Department of Transportation? (a) (1) If you are a firm which is denied certification or whose eligibility is removed by a recipient, you may make an administrative appeal to the Department. (22) If you are a complainant in an ineligibility complaint to a recipient (including the concerned operating administration in the circumstances provided in § 26.87(c)), you may appeal to the Department if the recipient does not find reasonable cause to propose removing the firm's eligibility or, following a rernoval of eligibility proceeding, determines that the firm is eligible. (3) Send appeals to the following address Department of Transportation, Office of Civil Rights 400 7th Street, SW, Room 2401 '\,`. ash,neton. DC 20590 (b) Pending the Department's decision in the :natter, the recipient's decision remains in effect The Department does not stay the effect of the recipient's decision while it is considering an appeal. (c) If you want to file an appeal, you must send a letter to the Department within 90 days of the date of the recipient's final decision, including information and arguments concerning why the recipient's decision should be reversed. The Department may accept an appeal filed later than 90 days after the date of the decision if the Department determines that there was good cause for the late filing of the appeal. (1) If you are an appellant who is a firm which has been denied certification, whose certification has been removed, whose owner is determined not to be a member of a designated disadvantaged group, or concerning whose owner the presumption of disadvantage has been rebutted. your letter must state the name and address of any other recipient which currently certifies the firm, which has rejected an application for certification from the firm or removed the firm's eligibility within one year prior to the date of the appeal, or before which an application for certification or a removal of eligibility is pending. Failure to provide this information may be deemed a failure to cooperate under §26 109(c). (2) If you are an appellant other than one described in paragraph (c) (1) of this section, the Department will request, and the firm whose certification has been questioned shall promptly provide, the information called for in paragraph (c)(1) of this section. Failure to provide this information may be deemed a failure to cooperate under § 26.109(c). (d) When it receives an appeal, the Department requests a copy of the recipient's complete administrative record in the matter. If you are the recipient, you must provide the administrative record, including a hearing transcript, within 20 days of the Department's request. The Department may extend this time period on the basis of a recipient's showing of good cause. To facilitate the Department's review of a recipient's decision, you must ensure that such administrative records are well organized, indexed, and paginated. Records that do not comport with these requirements are not acceptable and will be returned to you to be corrected immediately. If an appeal is brought concerning one recipient's certification decision concerning a firm, and that recipient relied on the decision and/or administrative record of another recipient. this requirement applies to both recipients involved (e) The Department makes its decision based solely on the entire administrative record. The Department does not make a de novo review of the matter and does not conduct a hearing The Department may supplement the administrative record by adding relevant information made available by the DOT Office of Inspector General, Federal, state, or local law enforcement authorities; officials of a DOT operating administration or other appropriate DOT office; a recipient; or a firm or other private party. (f) As a recipient, when you provide supplementary information to the Department, you shall also make this information available to the firm and any third -party complainant involved, consistent with Federal or applicable state laws concerning freedom of information and privacy. The Department makes available, on request by the firm and any third -party complainant involved, any supplementary information it receives from any source. (1) The Department affirms your decision unless it determines, based on the entire administrative record, that your decision is unsupported by ey 5144 Federal Register /Vol. 64, No. 21 /Tuesday, February 2, 1999 / Rules and Regulations substantial evidence or inconsistent with the substantive or procedural provisions of this part concerning certification. (2) If the Department determines, after reviewing the entire administrative record, that your decision was unsupported by substantial evidence or inconsistent with the substantive or procedural provisions of this part concerning certification, the Department reverses your decision and directs you to certify the firm or remove its eligibility, as appropriate. You must take the action directed by the Department's decision immediately upon receiving written notice of it. (3) The Department is not required to reverse your decision if the Department determines that a procedural error did not result in fundamental unfairness to the appellant or substantially prejudice the opportunity of the appellant to present its case. (4) If it appears that the record is incomplete or unclear with respect to matters likely to have a significant impact on the outcome of the case, the Department may remand the record to you with instructions seeking clarification or augmentation of the record before making a finding. The Department may also remand a case to you for further proceedings consistent with Deppartrnent instructions concerning the proper application of the provisions of this part The Department does no: Lphcld Your decision based on grounds no: specified in your decision (6) The Department s decisicn is based on the status and circumstances of the firm as of the date of the decision being appealed. (7) The Department provides written notice of its decision to you, the firm, and the complainant in an ineligibility complaint. A copy of the notice is also sent to any other recipient whose administrative record or decision has been involved in the proceeding (see paragraph (d) of this section). The notice includes the reasons for the Department s decision, including specific references to the evidence in the record that supports each reason for the decision. (8) The Department's policy is to make its decision within 180 days of receiving the complete administrative record. If the Department does not make its decision within this period. the Department provides written notice to concerned parties, including a statement of the reason for the delay and a date by which the appeal decision will be made (g) All decisions under this section are administratively final, and are not subject to petitions for reconsideration. § 26.91 What actions do recipients take following DOT certification appeal decisions? . (a) If you are the recipient'from whose action an appeal under § 26.89 is taken, the decision is binding. It is not binding on other recipients. (b) If you are a recipient to which a DOT determination under § 26.89 is applicable, you must take the following action: (1) If the Department determines that you erroneously certified a firm, you , must remove the firm's eligibility on receipt of the determination. without further proceedings on your part. Effective on the date of your receipt of the Department's determination, the consequences of a removal of eligibility set forth in § 26.87(i) take effect. (2) If the Department determines that you erroneously failed to find reasonable cause to remove the firm's eligibility, you must expeditiously commence a proceeding to determine whether the firm's eligibility should be removed, as provided in § 26 87 (3) If the Department determines that you erroneously declined to certify or removed the eligibility of the firm, you must certify the firm, effective on the date of your receipt of the written notice of Department's determination. (4) If the Department determines that you erroneously determined that the presumption of social and economic disadvantaee either should or should not be deemec rebutted you must take appropriate corrective action as determined b' the Department. (5) if the Department affirms your determination, no further action is necessary (c) Where DOT has upheld your denial of certification to or removal of eligibility from a firm, or directed the removal of a firm's eligibility, other recipients with whom the firm is certified may commence a proceeding to remove the firm's eligibility under § 26 87 Such recipients must not remove the firm's eligibility absent such a proceeding Where DOT has reversed your denial of certification to or removal of eligibility from a firm, other recipients must take the DOT action into account in any certification action involving the firm. However, other recipients are norrequired to certify the firm based on the DOT decision. Subpart F—Compliance and Enforcement § 26.101 What compliance procedures apply to recipients? (a) If you fail to comply with any requirement of this part, you may be subject to formal enforcement action under § 26.103 or § 26.105 or appropriate program sanctions by the concerned operating administration, such as the suspension or termination of Federal funds. or refusal to approve projects, grants or contracts until deficiencies are remedied. Program sanctions may include, in the case of the FHWA program, actions provided for under 23 CFR 1.36; in the case of the FAA program, actions consistent with 49 U.S C. 47106(d). 47111(d), and 47122; and in the case of the FTA program, any actions permitted under 49 U.S.C. chapter 53 or applicable FTA program requirements. (b) As provided in statute, you will not be subject to compliance actions or sanctions for failing to carry out any requirement of this part because you have been prevented from complying because a Federal court has issued a final order in which the court found that the requirement is unconstitutional. § 26.103 What enforcement actions apply in FHWA and FTA programs? The provisions of this section apply to enforcement actions under FHWA and FTA programs. (a) Noncompliance complaints. Any person who believes that a recipient has failed to comply with its obligations under this part may file a written complaint v ith the concerned operating administration s Office of Civil Rights If you want to file a complaint, you must do so no later than 180 days after the date cf the alleged violation or the date on which you learned of a continuing course of conduct in violation of this part. In response to your written request, the Office of Civil Rights may extend the time for filing in the interest of justice, specifying in writing the reason for so doing The Office of Civil Rights may protect the confidentiality of your identity as provided in § 26 109(b) Complaints under this part are limited to allegations of violation of the provisions of this part. (b) Compliance reviews. The concerned operating administration may review the recipient's compliance with this part at any time, including reviews of paperwork and on-site reviews, as appropriate The Office of Civil Rights may direct the operating administration to initiate a compliance review based on complaints received. (c) Reasonable cause notice If it appears, from the investigation of a complaint or the results of a compliance review, that you, as a recipient, are in noncompliance with this part, the appropriate DOT office promptly sends you, return receipt requested, a written notice advising you that there is reasonable cause to find you in Federal Register /Vol. 64, No. 21 /Tuesday, February 2, 1999 / Rules and Regulations 5145 noncompliance. The notice states the reasons for this finding and directs you to reply within 30 days concerning whether you wish to begin conciliation. (d) Conciliation. (1) If you request conciliation, the appropriate DOT office shall pursue conciliation for at least 30, but not more than 120, days from the date of your request. The appropriate DOT office may extend the conciliation period for up to 30 days for good cause, consistent with applicable statutes. (2) If you and the appropriate DOT office sign a conciliation agreement, then the matter is regarded as closed and you are regarded as being in compliance. The conciliation agreement sets forth the measures you have taken or will take to ensure compliance. While a conciliation agreement is in effect, you remain eligible for FHWA or FTA financial assistance. (3) The concerned operating administration shall monitor your implementation of the conciliation agreement and ensure that its terms are complied with If you fail to carry out the terms of a conciliation agreement, you are in noncompliance. (4) If you do not request conciliation, or a conciliation agreement is not signed within the time provided in paragraph (d) (1) of this section, then enforcement proceedings begin (e) Enforcement actions. (1) Enforcement actions are taken as provided in this subpart. (2) Applicable findings in enforcement proceedings are binding on all DOT offices § 26.105 What enforcement actions apply in FAA Programs? (a) Compliance with all requirements of this part by airport sponsors and other recipients of FAA financial assistance is enforced through the procedures of Title 49 of the United States Code. including 49 U.S C 47106(d), 47111(d), and 47122, and regulations implementing them. (b) The provisions of § 26.103(b) and this section apply to enforcement actions in FAA programs. (c) Any person who knows of a violation of this part by a recipient of FAA funds may file a complaint under 14 CFR part 16 with the Federal Aviation Administration Office of Chief Counsel. § 26.107 What enforcement actions apply to firms participating in the DBE program? (a) If you are a firm that does not meet the eligibility criteria of subpart D of this part and that attempts to participate in a DOT -assisted program as a DBE on the basis of false, fraudulent, or deceitful statements or representations or under circumstances indicating a serious lack of business integrity or honesty, the Department may initiate suspension or debarment proceedings against you under 49 CFR part 29. (b) If you are a firm that, in order to meet DBE contract goals or other DBE program requirements. uses or attempts to use, on the basis of false, fraudulent or deceitful statements or representations or under circumstances indicating a serious lack of business integrity or honesty, another firm that does not meet the eligibility criteria of subpart D of this part. the Department may initiate suspension or debarment proceedings against you under 49 CFR part 29. (c) In a suspension or debarment proceeding brought under paragraph (a) or (b) of this section, the concerned operating administration may consider the fact that a purported DBE has been certified by a recipient. Such certification does not preclude the Department from determining that the purported DBE, or another firm that has used or attempted to use it to meet DBE goals, should be suspended or debarred. (d) The Department may take enforcement action under 49 CFR Part 31, Program Fraud and Civil Remedies. against any participant in the DBE program v: hose conduct is subject to such action under 49 CFR part 31 (el The Department may refer to the Department of Justice, for prosecution under 18 U S C 1001 or other applicable provisions of law, any person who makes a false or fraudulent statement in connection with participation of a DBE in any DOT - assisted program or otherwise violates applicable Federal statutes § 26.109 What are the rules governing information, confidentiality, cooperation, and intimidation or retaliation? (a) Availability of records. (1) In responding to requests for information concerning any aspect of the DBE program, the Department complies with provisions of the Federal Freedom of Information and Privacy Acts (5 U S C 552 and 552a) The Department may make available to the public any information concerning the DBE program release of which is not prohibited by Federal law (2) If you are a recipient, you shall safeguard from disclosure to unauthorized persons information that may reasonably be considered as confidential business information, consistent with Federal, state, and local law (b) Confidentiality of information on complainants. Notwithstanding the provisions of paragraph (a) of this section, the identity of complainants shall be kept confidential, at.their election. If such confidentiality will hinder the investigation, proceeding or hearing, or result in a denial of appropriate administrative due process to other parties, the complainant must be advised for the purpose of waiving the privilege. Complainants are advised that, in some circumstances, failure to waive the privilege may result in the closure of the investigation or dismissal of the proceeding or hearing. FAA follows the procedures of 14 CFR part 16 with respect to confidentiality of information in complaints. (c) Cooperation. All participants in the Department's DBE program (including, but not limited to, recipients. DBE firms and applicants for DBE certification, complainants and appellants, and contractors using DBE firms to meet contract goals) are required to cooperate fully and promptly with DOT and recipient compliance reviews, certification reviews, investigations, and other requests for information. Failure to do so shall be a ground for appropriate action against the party involved (e g., with respect to recipients, a finding of noncompliance, with respect to DBE firms denial of certification or removal of eligibility and/or suspension and debarment: with respect to a complainant or appellant, dismissal of the complaint or appeal, with respect to a contractor which uses DBE firms to meet goals, findings of non - responsibility for future contracts and/ or suspension and debarment). (d) Intimidation and retaliation. If you are a recipient. contractor. or any other participant in the program, you must not intimidate, threaten, coerce, or discriminate against any individual or firm for the purpose of interfering with any right or privilege secured by this part or because the individual or firm has made a complaint, testified, assisted, or participated in any manner in an investigation, proceeding, or hearing under this part. If you violate this prohibition, you are in noncompliance with this part. Appendix A to Part 26—Guidance Concerning Good Faith Efforts I. When. as a recipient, you establish a contract goal on a DOT -assisted contract, a bidder must, in order to be responsible and/ or responsive, make good faith efforts to meet the goal. The bidder can meet this requirement in either of two ways. First, the bidder can meet the goal, documenting commitments for participation by DBE firms sufficient for this purpose. Second, even if it doesn't meet the goal, the bidder can document adequate good faith efforts. This means that the bidder must show that it took 5146 Federal Register/Vol. 64, No. 21 /Tuesday, February 2, 1999 /Rules and Regulations all necessary and reasonable steps to achieve a DBE goal or other requirement of this part which, by their scope, intensity, and appropriateness to the objective. could reasonably be expected to obtain sufficient DBE participation, even if they were not fully successful. II. In any situation in which you have established a contract goal, part 26 requires you to use the good faith efforts mechanism of this part. As a recipient. it is up to you to make a fair and reasonable judgment whether a bidder that did not meet the goal made adequate good faith efforts. It is important for you to consider the quality, quantity, and intensity of the different kinds of efforts that the bidder has made. The efforts employed by the bidder should be those that one could reasonably expect a bidder to take if the bidder were actively and aggressively trying to obtain DBE participation sufficient to meet the DBE contract goal. Mere pro forma efforts are not good faith efforts to meet the DBE contract requirements. We emphasize, however, that your determination concerning the sufficiency of the firm's good faith efforts is a judgment call. meeting quantitative formulas is not required. III. The Department also strongly cautions you against requiring that a bidder meet a contract goal (i.e., obtain a specified amount of DBE participation) in order to be awarded a contract, even though the bidder makes an adequate good faith efforts showing. This rule specifically prohibits you from ignoring bona fide good faith effects It The fol:ow:ng is a list of :vpes of actions which you should consider as part of the bidder s good faith efforts to obtain DBE parac.pat:on it is not intended to be a mandator checklist. nor is it intended tc be exciusi•'e or exhaustive Other factors cr types of efforts ma:. be relevant in appropriate cases. A. Soliciting through all reasonable and available means (e.g. attendance at pre-bid meetings, advertising and/or written notices) the interest of all certified DBEs who have the capability to perform the work of the contract. The bidder must solicit this interest within sufficient time to allow the DBEs to respond to the solicitation. The bidder must determine with certainty if the DBEs are interested by taking appropriate steps to follow up initial solicitations. B Selecting portions of the work to be performed by DBEs in order to increase the likelihood that the DBE goals will be achieved. This includes, where appropriate, breaking out contract work items into economically feasible units to facilitate DBE participation, even when the prime contractor might otherwise prefer to perform these work items with its own forces. C. Providing interested DBEs with adequate information about the plans, specifications, and requirements of the contract in a timely manner to assist them in responding to a solicitation. D. (1) Negotiating in good faith with interested DBEs. It is the bidder's responsibility to make a portion of the work available to DBE subcontractors and suppliers and to select those portions of the work or material needs consistent with the available DBE subcontractors and suppliers, so as to facilitate DBE participation. Evidence of such negotiation includes the names, addresses. and telephone numbers of DBEs that were considered: a description of the information provided regarding the plans and specifications for the work selected for subcontracting; and evidence as to why additional agreements could not be reached for DBEs to perforrn the work. (2) A bidder using good business judgment would consider a number of factors in negotiating with subcontractors. including DBE subcontractors, and would take a firm's price and capabilities as well as contract goals into consideration. However, the fact that there may be some additional costs involved in finding and using DBEs is not in itself sufficient reason for a bidder's failure to meet the contract DBE goal, as long as such costs are reasonable. Also. the ability or desire of a prime contractor to perforrn the work of a contract with its own organization does not relieve the bidder of the responsibility to make good faith efforts. Prime contractors are not, however, required to accept higher quotes from DBEs if the price difference is excessive or unreasonable. E. Not rejecting DBEs as being unqualified without sound reasons based on a thorough investigation of their capabilities. The contractor's standing within its industry, membership in specific groups, organizations, or associations and political or social affiliations (for example union.vs non- union employee status) are not legitimate causes for :he rejection or non -solicitation of bids in the contractor s efforts to meet the project goal 'laking efforts to assist interested DBEs in obtaining bonding, lines of credit. or insurance as required by the recipient or contractor G Making efforts to assist interested DBEs in obtaining necessary equipment, supplies, materials, or related assistance or services. H. Effectively using the services of available minority/women community organizations, minority/women contractors' groups. local, state, and Federal minority/ women business assistance offices, and other organizations as allowed on a case-bv-case basis to provide assistance in the recruitment and placement of DBEs V In determining whether a bidder has made good faith efforts, you may take into account the performance of other bidders in meeting the contract. For example, when the apparent successful bidder fails to meet the contract goal, but others meet it, you may reasonably raise the question of whether, with additional reasonable efforts, the apparent successful bidder could have met the goal. If the apparent successful bidder fails to meet the goal, but meets or exceeds the average DBE participation obtained by other bidders, you may view this, in conjunction with other factors, as evidence of the apparent successfui bidder having made good faith efforts Appendix B to Part 26—Forms [Reserved] Appendix C to Part 26—DBE Business Development Program Guidelines The purpose of this program element is to further the development of DBEs, including but not limited to assisting them to move into non-traditional areas of work and/or compete in the marketplace outside the DBE program, via the provision of training and assistance from the recipient. (A) Each firm that participates in a recipient's business development program (BDP) program is subject to a program term determined by the recipient. The term should consist of two stages: a developmental stage and a transitional stage. (B) In order for a firm to remain eligible for program participation. it must continue to meet all eligibility criteria contained in part 26. (C) By no later than 6 months of program entry. the participant should develop and submit to the recipient a comprehensive business plan setting forth the participant's business targets. objectives and goals. The participant will not be eligible for program benefits until such business plan is submitted and approved by the recipient. The approved business plan will constitute the participant's short and long term goals and the strategy for developmental growth to the point of economic viability in non- traditional areas of work and/or work outside the DBE program. (D) The business pian should contain at least the following -- (1) an analysis of market potential. competitive environment and other business analyses estimating the program participant s prospects for profitable operation during the tern; of program participation and after graduation from the program. (2) An analysis of the firm s strengths and weaknesses, with particular attention paid to the means of correcting any financial, managerial, technical, or labor conditions which could impede the participant from receiving contracts other than those in traditional areas of DBE participation. (3) Specific targets, objectives. and goals for the business development of the participant during the next two years. utilizing the results of the analysis conducted pursuant to paragraphs (C) and (D)(1) of this appendix: (4) Estimates of contract awards from the DBE program and from other sources which are needed to meet the objectives and goals for the years covered by the business plan; and (5) Such other information as the recipient may require. (E) Each participant should annually review its currently approved business plan with the recipient and modify the plan as may be appropriate to account for any changes in the firm's structure and redefined needs The currently approved plan should be considered the applicable plan for all program purposes until the recipient approves in writing a modified plan. The recipient should establish an anniversary date for review of the participant's business plan and contract forecasts. Federal Register /Vol, 64, No. 21 /Tuesday, February 2, 1999 /Rules and Regulations 5147 (F) Each participant should annually forecast in writing its need for contract awards for the next program year and the succeeding program year during the review of its business plan conducted under paragraph (E) of this appendix. Such forecast should be included in the participant's _ business plan. The forecast should include: (1) The aggregate dollar value of contracts to be sought under the DBE program, reflecting compliance with the business plan, (2) The aggregate dollar value of contracts to be sought in areas other than traditional areas of DBE participation; (3) The types of contract opportunities being sought. based on the firm's primary line of business: and (4) Such other information as may be requested by the recipient to aid in providing effective business development assistance to the participant. (G) Program participation is divided into two stages; (1) a developmental stage and (2) a transitional stage. The developmental stage is designed to assist participants to overcome their social and economic disadvantage by providing such assistance as may be necessary and appropriate to enable them to access relevant markets and strengthen their financial and managerial skills. The transitional stage of program participation follows the developmental stage and is designed to assist participants to overcome, insofar as practical. their social and economic disadvantage and to prepare the participant for leaving the program. (H) The length of service in the program tern should nct be a pre-set time frame for either the developmental or transitional stages but should be figured on the number cf years considered necessary in normal progression cf achieving the firm s established goals and objectives. The setting of such time could be factored on such items as, but not limited to, the number of contracts, aggregate amount of the contract received. years in business, growth potential, etc. (I) Beginning in the first year of the transitional stage of program participation. each participant should annually submit for inclusion in its business plan a transition management plan outlining specific steps to promote profitable business operations in areas other than traditional areas of DBE participation after graduation from the program. The transition management plan should be submitted to the recipient at the same time other modifications are submitted pursuant to the annual review under paragraph (E) of this section. The plan should set forth the same information as required under paragraph (F) of steps the participant will take to continue its business development after the expiration of its program term. (1) When a participant is recognized as successfully completing the program by substantially achieving the targets, objectives and goals set forth in its program term, and has demonstrated the ability to compete in the marketplace, its further participation within the program may be determined by the recipient. (K) In determining whether a concern has substantially achieved the goals and objectives of its business plan, the following factors, among others, should be considered by the recipient: (I) Profitability; (2) Sales, including improved ratio of non- traditional contracts to traditional -type contracts; (3) Net worth, financial ratios, working capital, capitalization, access to credit and capital; (4) Ability to obtain bonding; (5) A positive comparison of the DBE's business and financial profile with profiles of non -DBE businesses in the same area or similar business category; and (6) Good management capacity and capability (L) Upon determination by the recipient that the participant should be graduated from the developmental program, the recipient should notify the participant in writing of its intent to graduate the firm in a letter of notification. The letter of notification should set forth findings, based on the facts, for every material issue relating to the basis of the program graduation with specific reasons for each finding. The letter of notification should also provide the participant 45 days from the date of service of the letter to submit in writing information that would explain why the proposed basis of graduation is not warranted. (M) Participation of a DBE firm in the program may be discontinued by the recipient prior to expiration of the firm's program term far good cause due to the failure of the firm to engage in business practices that will promote its competitiveness within a reasonable period of tirne as evidenced b., among other indicators, a pattern of inadequate performance or unjustified delinquent performance. Also, the recipient can discontinue the participation of a firm that does not actively pursue and bid on contracts. and a firm that, without justification, regularly fails to respond to solicitations in the type of work it is qualified for and in the geographical areas where it has indicated availability under its approved business plan. The recipient should take such action if over a 2 -year period a DBE firm exhibits such a pattern. Appendix D to Part 26—Mentor-Protege Program Guidelines (A) The purpose of this program element is to further the development of DBEs, including but not limited to assisting them to move into non-traditional areas of work and/ or compete in the marketplace outside the DBE program, via the provision of training and assistance from other firms. To operate a mentor -protege program. a recipient must obtain the approval of the concerned operating administration. (B)(1) Any mentor -protege relationship shall be based on a written development plan, approved by the recipient, which clearly sets forth the objectives of the parties and their respective roles, the duration of the arrangement and the services and resources to be provided by the mentor to the protege. The formal mentor -protege agreement may set a fee schedule to cover the direct and indirect cost for such services rendered by the mentor for specific training and assistance to the protege through the life of the agreement. Services provided by the mentor may be reimbursable under the FTA, FHWA, andFAA programs. (2) To be eligible for reimbursement, the mentor's services provided and associated costs must be directly attributable and properly allowable to specific individual contracts. The recipient may establish a line item for die mentor to quote the portion of the fee schedule expected to be provided during the life of the contract. The amount claimed shall be verified by the recipient and paid on an incremental basis representing the tirne the protege is working on the contract. The total individual contract figures accumulated over the life of the agreement shall not exceed the amount stipulated in the original mentor/protege agreement. (C) DBEs involved in a mentor -protege agreement must be independent business entities which meet the requirements for certification as defined in subpart D of this part. A protege firm must be certified before it begins participation in a mentor -protege arrangement. If the recipient chooses to recognize mentor/protege agreements, it should establish formal general program guidelines. These guidelines must be submitted to the operating administration for approval prior to the recipient executing an individual contractor/ subcontractor mentor - protege agreement. Appendix E to Part 26—Individual Determinations of Social and Economic Disadvantage The following guidance is adapted, with minor modifications, from SBA regulations concerning social and economic disadvantage determinations (see 13 CFR 124 I03(c) and 124 104) Social Disadvantage I. Socially disadvantaged individuals are those who have been subjected to racial or ethnic prejudice or cultural bias within American society because of their identities as members of groups and without regard to their individual qualities. Social disadvantage must stem from circumstances beyond their control. Evidence of individual social disadvantage must include the following elements: (A) At least one objective distinguishing feature that has contributed to social disadvantage, such as race, ethnic origin, gender, disability, long-term residence in an environment isolated from the mainstream of American society, or other similar causes not common to individuals who are not socially disadvantaged, (B) Personal experiences of substantial and chronic social disadvantage in American society. not in other countries; and (C) Negative impact on entry into or advancement in the business world because of the disadvantage. Recipients will consider any relevant evidence in assessing this element. In every case, however, recipients will consider education, employment and business history, where applicable, to see if the totality of circumstances shows disadvantage in entering into or advancing in the business world. 5148 Federal Register/Vol. 64, No. 21 /Tuesday, February 2, 1999 /Rules and Regulations (1) Education. Recipients will consider such factors as denial of equal access to institutions of higher education and vocational training, exclusion from social and professional association with students or teachers, denial of educational honors rightfully earned, and social patterns or pressures which discouraged the individual from pursuing a professional or business education. (2) Employment. Recipients will consider such factors as unequal treatment in hiring, promotions and other aspects of professional advancement. pay and fringe benefits, and other terms and conditions of employment; retaliatory or discriminatory behavior by an employer or labor union; and social patterns or pressures which have channeled the individual into non-professional or non- business fields. (3) Business history The recipient will consider such factors as unequal access to credit or capital, acquisition of credit or capital under commercially unfavorable circumstances, unequal treatment in opportunities for government contracts or other work, unequal treatment by potential customers and business associates, and exclusion from business or professional organizations. II. With respect to paragraph I.(A) of this appendix, the Department notes that people with disabilities have disproportionately low incomes and high rates of unemployment. Many physical and attitudinal barriers remain to their full participation in education, employment. and business opportunities available to the genera! public The .americans with Disabilities Act (ADA) was passed in recognition of the discrimination faced by people 'r.ith disabilities. It is plausible that many individuals with disabilities—especially persons with severe disabilities (e.g , significant mobility, vision, or hearing, impairments)—may be socially and economically disadvantaged. III. Linder the laws concerning social and economic disadvantage, people with disabilities are not a group presumed to be disadvantaged: Nevertheless, recipients should look carefully at individual showings of disadvantage by individuals with disabilities, making a case-by-case judgment about whether such an individual meets the criteria of this appendix. As public entities subject to Title II of the ADA. recipients must also ensure their DBE programs are accessible to individuals with disabilities. For example. physical barriers or the lack of application and information materials in accessible formats cannot be permitted CO thwart the access of potential applicants to the certification process or other services made available to DBEs and applicants. Economic Disadvantage (A) General. Economically disadvantaged individuals are socially disadvantaged individuals whose ability to compete in the free enterprise system has been impaired due to diminished capital and credit opportunities as compared to others in the same or similar line of business who are not socially disadvantaged. (B) Submission of narrative and financial information. (1) Each individual claiming economic disadvantage must describe the conditions which are the basis for the claim in a narrative statement, and must submit personal financial information. (2) When married, an individual claiming economic disadvantage also must submit separate financial information for his or her spouse. unless the individual and the spouse are legaliv separated (C) Factors ro be ccnsidered. In considering diminished capital and credit opportunities, recipients will examine factors relating to the personal financial condition of any individual claiming disadvantaged status, including personal income for the past two years (including bonuses and the value of company stock given in lieu of cash), personal net worth, and the fair market value of all assets, whether encumbered or not. Recipients will also consider the financial condition of the applicant compared to the financial profiles of small businesses in the same primary industry classification, or. if not available, in similar lines of business, which are not owned and controlled by socially and economically disadvantaged individuals in evaluating the individual's access to credit and capital. The financial profiles that recipients will compare include total assets, net sales. pre-tax profit. sales/ working capital ratio. and net worth. (D) Transfers within two years. (1) Except as set forth in paragraph (D)(2) of this appendix, recipients will attribute to an individual claiming disadvantaged status any assets which that individual has transferred to an immediate family member, or to a trust, a beneficiary of which is an immediate family member, for less than fair market value. within two years prior to a concern's application for participation in the DBE program, unless the individual claiming disadvantaged status can demonstrate that the transfer is to or on behalf of an immediate family member for that individual's education, medical expenses. or some other form of essential support. (2) Recipients will not attribute to an individual claiming disadvantaged status any assets transferred by that individual to an immediate family member that are consistent with the customary recognition of special occasions, such as birthdays, graduations, anniversaries, and retirements. (3) in determining an individual's access to capital and credit, recipients may consider any assets that :he individual transferred within such two-year period described by paragraph (D) (1) of this appendix that are not considered in evaluating the individual's assets and net worth (e g., transfers to charities) [FR Doc. 99-1033 Filed 1-29-99: 11.00 arn] BILLING CODE 4910-62-P Federal Register /Vol. 64, No. 123 / Monday, June 28, 1999 /Rules and Regulations 34569 procedure for processing "9-1-1" calls. Such procedure must recognize when a "9-1-1" call is made and, at such time, must override any programming in the mobile unit that determines the handling of a non -911 call and permit the call to be handled by other analog carriers. This special procedure must incorporate any one or more of the 9- 1-1 call system selection processes endorsed or approved by the Commission. [FR Doc. 99-16484 Filed 6-25-99; 8:45 am] BILUNG CODE 6712-01-P DEPARTMENT OF TRANSPORTATION Office of the Secretary 49 CFR Parts 23 and 26 [Docket OST -97-2550] RIN 2105-AB92 Participation by Disadvantaged Business Enterprises in Department of Transportation Programs AGENCY: Office of the Secretary, DOT. ACTION: Final rule; correction. SUMMARY: In its final disadvantaged business enterprise (DBE) rule, the Department intended to ensure the confidentiality of personal financial information submitted to recipients by owners of DBE firms. The Department inadvertently omitted the regulatory text language on this point. This correction document remedies this omission. In addition, this document corrects minor omissions concerning the threshold for Federal Transit Administration recipients to establish DBE programs and a requirement for transit vehicle manufacturers to have DBE programs, removes a potentially confusing word from the rule's provisions concerning DOT review of recipients' overall goals, clarifies language concerning the certification and personal net worth of airport concessionaires and others, and clarifies that a lease is viewed as a contract for purposes of the rule. DATES: This rule is effective June 28, 1999 FOR FURTHER INFORMATION CONTACT: Robert C Ashby, Deputy Assistant General Counsel for Regulation and Enforcement, Department of Transportation, 400 7th Street. SW., Room 10424, Washington, DC 20590, phone numbers (202) 366-9306 (voice), (202) 366-9313 (fax), (202) 755-7687 (TDD), bob.ashby@ost.dot.gov (email) SUPPLEMENTARY INFORMATION: Privacy In discussing the requirement of the DBE final rule that owners of DBE firms submit a statement of personal net worth, with supporting documentation, the Department addressed commenters' concerns about the confidentiality of the information. The preamble to the rule said the following: One of the primary concerns of DBE firms commenting about submitting personal financial information is ensuring that the information remains confidential. In response to this concern. the rule explicitly requires that this material be kept confidential. It may be provided to a third party only with the written consent of the individual to whom the information pertains. This provision is specifically intended to pre- empt any contrary application of state or local law (e.g., a state freedom of information act that might be interpreted to require a state transportation agency to provide to a requesting party the personal income tax retum of a DBE applicant who had provided the return as supporting documentation for his PNW statement) There is one exception to this confidentiality requirement. If there is a certification appeal in which the economic disadvantage of an individual is at issue (e.g., the recipient has determined that he or she is not economically disadvantaged and the individual seeks DOT review of the decision), the personal financial information would have to be provided to DOT as part of the administrative record. The Department would treat the information as confidential. (64 FR 5117, Februar, 2. 1999) Unfortunately. through editorial error on the Department s part. the regulatory text provision referred to was omitted from the final rule. We regret any confusion that this omission may have caused. and we are correcting the error by inserting the language in a new paragraph (a) (2) (iii) of § 26.67 of the rule. FTA Requirements for DBE Programs In §26.21(a)(2) of the rule, the Department states that FTA recipients who receive more than $250,000 in various forms of FTA assistance must have a DBE program. The phrase "exclusive of transit vehicle purchases" was inadvertently omitted from this paragraph This omission has raised questions from some recipients, and we are reinserting the omitted language to avoid confusion. In addition, this provision did not make explicit that transit vehicle manufacturers must have DBE programs. so we are adding language to make this clear Review of Overall Goals While operating administrations review recipients' overall goal submissions, recipients are not required to obtain prior concurrence by operating administrations with their overall goals (see § 26.45(f)(4)) However, as the result of an editorial oversight. § 26.21(b) (1) of the rule makes a reference to overall goals being "approved" by operating administrations. Because prior concurrence is not required, this reference is incorrect and could be misleading. Therefore, we are removing it. Concessionaires In the February 2, 1999, final DBE rule, the Department removed all of former part 23 except the portion concerning airport concessionaires. The airport concession provisions were modified for consistency with the new 49 CFR part 26. In one respect, however, the amendment of the airport concessions provision failed to delete language concerning certification procedures that referred to the (now deleted) certification provisions of former part 23. While we have provided guidance to airports that they should follow part 26 procedures, we believe it would be useful to delete the language referring to former part 23's procedures. Therefore, this rule eliminates two paragraphs in § 23.95 Recipients should follow part 26 certification procedures for concessionaires as well as for other contractors. Airports have expressed concern that the rule is unclear concerning the application to concessionaires of the 5750.000 personal net worth (PNW) cap and PNW statement requirements of § 26 67. The Department is currently working to complete a final rule concerning airport concessions. The PNW cap applicable to concessionaires is one of the matters being considered in this rulemaking. The PNW cap amount that the Department applies to concessionaires may or may not be S750,000. Pending completion of the final rule on airport concessions, the Department believes it best to resolve the current uncertainty by making the $750.000 cap amount and PNW statement requirement of § 26.67 inapplicable to airport concessionaires. We are amending § 26.67(a)(2)(i) to specify that disadvantaged owners of airport concessionaires are not required to submit PNW statements. Consequently. the rebuttal of the presumption of economic disadvantage based on a PNW statement an individual is required to submit (see § 26.67(b)(1)) also does not apply to airport concessionaires. Definition of "Contract" The 49 CFR part 23 definition of "contract" specified that a lease was 34570 Federal Register /Vol. 64, No. 123 / Monday, June 28, 1999 / Rules and Regulations viewed as a contract. The part 26 definition inadvertently omitted this sentence. To avoid any potential confusion on this point, this correction document adds a sentence on leases. Clarification Concerning Personal Net Worth Documentation The Department has received a number of questions and expressions of concern about the documentation it is appropriate for recipients to require in ascertaining the personal net worth of owners of DBE firms. The Department believes that it is important to clarify the rule to state that this documentation, and the PNW statement itself, should not be unduly lengthy, burdensome or intrusive. The Department uses the Small Business Administration's implementation of its PNW requirements as a model for recipients' practices. SBA requires a two-page form, supported by two years' of personal and business tax returns With respect to the information routinely collected from applicants or owners of currently certified DBEs for purposes of ascertaining PNW, the Department believes that recipients should not exceed the information sought by SBA in its programs Consequently, while recipients are not required to use the SBA, form verbatim, they should use a form of similar length and content. Recipients may appropriately collect and retain copies of two .ears' of the individuals personal and business tax returns On the other hand, the Department regards as unduly lengthy, burdensome, or intrusive such practices as using a form significantly longer or more complex than the SBA form (e.g., a multipage PNW form), requiring inventories of personal property or appraisals of real property Such practices are contrary to part 26 Regulatory Analyses and Notices This set of amendments correcting part 26 is not a significant rule under Executive Order 12866 or the Department's Regulatory Policies and Procedures. The Department certifies that the amendments will not have significant economic impacts on a substantial number of small entities. This is because the amendments are technical corrections that will not impose costs on entities, regardless of their size. They do not have Federalism impacts sufficient to warrant the preparation of a Federalism impact statement. They do not impose information collection requirements These amendments relate to regulatory provisions that have already been the subject of notice and comment (as part of the Department's May 1997 supplemental notice of proposed rulemaking concerning the DBE program) . Because the amendments merely correct accidental omissions from the regulatory text or remove a potentially confusing reference, we do not believe that additional notice and comment would be productive. Therefore, the Department has determined that further notice and comment would be impracticable, unnecessary, and contrary to the public interest. The Department has good cause to make the corrections effective immediately in order to avoid confusion and any adverse effects on DBEs or recipients from the absence of the omitted language. List of Subjects 49 CFR Part 23 Administrative practice and procedure, Airports, Civil rights, Concessions, Government contracts, Grant programs—transportation, Minority businesses. Reporting and recordkeeping requirements. 49 CFR Part 26 Administrative practice and procedure Airports. Civil rights, Government contracts, Grant ^' programs—transportation, Highways and roads, Mass transportation, Minot -in, businesses. Reporting and recordlceeping requirements Issued this 1 lth day of June, 1999, at Washington, D C Rodney E. Slater, Secretary of Transportation. For the reasons set forth in the preamble, the Department amends 49 CFR parts 23 and 26 as follows. PART 23—[AMENDED] 1 The authority citation for part 23 continues to read as follows. Authority: 42 U.S C. 200d et seq., 49 U.S C 47107 and 47123. Executive Order 12138. 3 CFR. 1979 Comp , p. 393 § 23.95 [Amended] 2 In § 23.95. remove and reserve paragraphs (f) (2) and (f)(3). PART 26—[AMENDED] 3 The authority citation for part 26 is revised to read as follows Authority: 23 U.S.C. 324. 42 U.S.C. 2000d, et seq.; 49 U.S C 1615, 47107, 47113, 47123, Sec. 1101(b), Pub L. 105-178, 112 Stat. 107, 113. 4 In the definition of the term "Contract" in § 26 5, add a sentence at the end of the definition, to read as follows. §26.5 What do the terms used in this part mean? * * * * * Contract * * * For purposes of this part, a lease is considered to be a contract. * * * * 5. In § 26.21, revise paragraph (a)(2) to read as follows. §26.21 Who must have a DBE program? (a) * * * (2) FTA recipients that receive $250,000 in FTA planning, capital, and/ or operating assistance in a Federal fiscal year, exclusive of transit vehicle purchases. and transit vehicle manufacturers who must submit an overall goal under § 26 49. * * * * * § 26.21 [Amended] 5. In § 26 21(b)(1), in the parenthetical phrase, remove the words "and approved" following the word "reviewed". § 26.45 [Amended] 6 In § 26.45(c) (5), remove the words "Subject to the approval of the DOT operating administration, you" and add "You" in its place 7 Amend § 26 67 as follows a. Revise paragraph (a) (2) (i) , and b Redesignate paragraph (a) (21(ii) as paragraph (a) (21(iia and add a new paragraph (a) (2)(ii), to read as follows § 26.67 What rules determine social and economic disadvantage? (a) . * * (2) (i) You must require each individual owner of a firm applying to participate as a DBE (except a firm applying to participate as a DBE airport concessionaire) whose ownership and control are relied upon for DBE certification to submit a signed, notarized statement of personal net worth, with appropriate supporting documentation. This statement and documentation must not be unduly lengthy, burdensome, or intrusive (ii) Notwithstanding any provision of state law, you must not release an individual's personal net worth statement nor any documentation supporting it to any third party without the written consent of the submitter. Provided, that you must transmit this information to DOT in any certification appeal proceeding under § 26.89 in which the disadvantaged status of the individual is in question. * * * * * (FR Doc. 99-15866 Filed 6-24-99: 8.45 am] BILLING CODE 491D -62-P ITEM TITLE: SUBMITTED BY: BUSINESS OF THE CITY COUNCIL YAKIMA, WASHINGTON AGENDA STATEMENT Item No. 1p For Meetmg Of 4/04/00 Adoption of Disadvantaged Business Enterprise Program and Annual Aspirational Goal Chris Waarvick, Director of Public Works John A. Haddix, Acting Transit Manager CONTACT PERSON/TELEPHONE: John A. Haddix / 575-6005 SUMMARY EXPLANATION: Submitted for Council approval is the Disadvantaged Business Enterprise (DBE) program with documented methodology to establish a 10% aspirational goal. Originally estimated at 12%, a lower 10% goal is recommended for adoption by the Council Transit Committee. This recommendation is based on what is believed Transit can realistically achieve and the fact that Council already has an adopted citywide policy setting 10% as a reasonable goal. This is also the national goal set by the Federal Transit Administration. Under the new federal rule, the City must "narrowly tailor" its DBE program by annually setting an overall goal representing a "level playing field" in the amount of DBE participation the City can realistically expect in the absence of discrimination This goal must be based on demonstrable evidence of the availability of ready, willing, and able DBE's to participate in awarded United States Department of Transportation (DOT) -assisted contracts The proof the City shall use for determining if a DBE is ready, willing, and able is whether or not the DBE is State certified Yakima Transit requested Yakima Valley Conference of Governments (COG) assistance in developing a realistic goal. The law gives DOT funding recipients substantial flexibility in choosing a method for goal setting. The COG staff reviewed the new DOT guidance documents and Transit contract opportunities over the past three years. The methodology used and the justification for establishing a 10% goal for Transit is provided as Attachment B: Overall Goal Submission in the City of Yakima DBE Program. Resolution X Ordinance Other (Specify) Pubhc Notice, DBE Program, Federal Register Contract Mail to (name and address)• Phone: Funding Source APPROVED FOR SUBMITTAL. City Manager STAFF RECOMMENDATION: Approve Resolution adopting DBE program and aspirational goal. BOARD/COMMISSION RECOMMENDATION. Approve Resolution adopting DBE program and aspirational goal. COUNCIL ACTION. OFFICE OF THE CITY MANAGER 129 North Second Street CITY HALL, Yakima, Washington 98901 Phone (509) 575-6040 March 31, 2000 Mr. Phil Pleasant Pleasant's Contracting Service 1202 S. Fair Avenue Yakima, Washington 98901 Re: Proposed City of Yakima DBE Program Dear Phil: Thank you for your March 2, 2000 letter regarding the City's proposed Disadvantaged Business Enterprise ("DBE") Program. The City appreciates your input in the development of a DBE Program. A number of the points made in your letter warrant a response and clarification. The following information is provided for your consideration. Your letter states that the City of Yakima has "a meager history of success when working with minority and disadvantaged businesses," that City "leadership does not fully support the DBE Program," and that City "administration is resistant to implementing a good sound DBE Program." These statements are incorrect and unfair. City Management is committed to continuous improvement in working with minority and disadvantaged business and attaining a successful DBE program. The number one priority of the City is economic development. The City does not knowingly or illegally discriminate against anyone in promoting this overriding goal, nor would we tolerate such behavior. City representatives have worked diligently through the years to involve DBEs to help achieve this priority. This has been accomplished by utilizing certified DBEs in City projects and in hiring minority candidates as City employees. The facts reflect that our efforts have resulted in the City generally meeting or exceeding both its DBE goal of 10% and similar affirmative action employment goals during the last several years. I would invite you to compare our record against other public employees in the area. I believe you will find that given our workforce composition, the City has performed well, maintained accurate statistics and records and been very responsive to this issue in comparison to other public entities. Still, we are willing to acknowledge that even more can and should be done within the legal constraints the City faces. As to maintenance of a DBE directory and outreach efforts, the City Purchasing Division subscribes to OMWBE's Directory of Certified Minority, Women and Disadvantaged Business Enterprises, which is published on a quarterly basis, and also has access to OMWBE's web page (which lists certified firms).' Additionally, the Purchasing Division maintains a computerized vendor listing, which also identifies entities that are DBEs. Your firm is on this vendor listing. Every time the Purchasing Division issues a request for bids on a project, the The City does not recognize WAME as a certified DBE because WAME is not currently a certified DBE. Yakima Iry an 994 Phil Pleasant March 31, 2000 Page - 2 Washington Association of Minority Entrepreneurs ("WAME") is also faxed a copy of the announcement so that WAME may also contact DBEs who may be interested in the project. With regard to the methodology used to arrive at a proposed 10% aspirational goal, the United States Department of Transportation suggests several ways of calculating this aspirational goal in 49 CFR § 26.45(a). One recommended method is a review of the number of DBEs that have participated in previous DOT -assisted prime contracts or subcontracts. This method is described in 49 CFR § 26.45(a)(2). City representatives and the Yakima Valley Conference of Governments ("YVCOG") felt that use of the data regarding prior DBE participation based upon prior Transit Division contracts was in accordance with this DOT -suggested methodology and was an appropriate method of determining the proposed DBE goal. Based upon the available data, City staff and YVCOG recommended an aspirational DBE goal of 12% to the City Transit Committee. The Council Transit Committee reviewed the matter and, based in part upon prior practice and history, suggested a 10% DBE participation goal. However, the City Council will be considering this matter next Tuesday. This DBE Program development involves setting an aspirational goal, and not a quota, for participation of DBEs in DOT and FTA -assisted contracts of the City. The City cannot legally mandate a set aside or impose a quota requiring that a certain percentage of contracts be awarded to minority businesses or any special ethnic group to remedy alleged past discrimination. Such action would expose the City to significant liability in light of the United States Supreme Court decisions of City of Richmond v. J.A. Croson Co., 109 S. Ct. 706 (1989) and Adarand Constructors, Inc. v. Pena, 115 S. Ct. 2097 (1995), and would not be enforceable. The new DOT regulations are largely a response to these Supreme Court decisions. In particular, DOT recognized the liability exposure presented by quotas and set - asides in DBE programs. Accordingly, in 49 CFR § 26.43, DOT expressly prohibited the use of quotas and severely limited the use of set -asides. The City must comply with the federal DOT regulations in this matter. As to the 1998 bus bench contract, Glenn Rice previously responded to your concerns by way of a written letter on July 30, 1999. A copy of that letter is attached hereto for your reference. Again, the City thanks you for your timely completion of the required work. However, please be aware that the City always has the right to reject any and all bids on any particular project. The City could have exercised that right on the 1998 bus bench project when it became apparent that there was not enough funds available to complete the full scope of the project. Instead, the City chose to work with you to reach a mutually acceptable situation. As part of that solution, you were not required to provide a performance or payment bond for that project.2 The 1999 bus bench project represented a new and separate contract with an expected cost in excess of $25,000. In accordance with Article VI, Section 6 of the City Charter and Section 1.80.040 of the Yakima Municipal Code, the City was required to bid out that project and acted appropriately by doing so. In your letter you state that the City did not notify you of this project. However, in Mr. Rice's July 30th letter you were clearly notified of the project and invited to 2 With regard to the performance bond issue, RCW 39 08.010 generally requires performance and payment bonds on public works projects. There does not appear to be anything in the DOT regulations that preempts these bond requirements. Accordingly, the City generally requires performance and payment bonds on projects that are publicly bid. At the same time, the City has exercised some flexibility regarding bond requirements when the cost of a project is below the $25,000 bid limit. Phil Pleasant March 31, 2000 Page - 3 submit a bid. Additionally, your business is on the City's list of vendors that is maintained by the Purchasing Division. As such, it is my understanding that a bid package was mailed to you for the 1999 bus bench project. Finally, as with all public bid projects of the City, the bid announcement was published in the Yakima Herald Republic. And, in fact, you submitted a successful bid on the project. We believe that the City's public bid process follows legal requirements, provides a level playing field and is a fair process for all interested parties. We do not agree that the requirement to bid on any particular project, including the 1999 bus bench contract, is an obstacle to minority businesses or that it discriminates against minorities who seek to do business with the City of Yakima. This is evidenced by the fact that you bid on the 1999 bus bench project and were awarded the contract as the lowest responsible bidder. Like the 1998 bus bench contract, you were not required to provide a performance or payment bond for that project. The City thanks you for input and suggestions. We would welcome any additional recommendations as to other ways that the City may legally promote the development of minority and disadvantaged business enterprises. Very truly yours, Dick Zais City Manager cc: City Council Members Glenn Rice, Asst. City Manager Chris Waarvick, Public Works Director Sue Ownby, Manager, Purchasing Division John Haddix, Acting Manager, Transit Division OFFICE OF THE CITY MANAGER 129 North Second Street CITY HALL, Yakima, Washington 98901 Phone (509) 575-6040 July 30, 1999 Phillip L. Pleasant 701 South 7th Avenue Yakima, Washington 98901 On May 19, 1998, the City executed a contract with you regarding installation of bus benches. Specifically, the contract required that you install 50 bus benches at specified locations for a total sum of $15,000.00. The contract required that you complete installation of the 50 bus benches within 45 working days after_ receiving the notice to proceed. You have now completed the work within the required time and have been paid $15,000 in compensation. The contract has been completed. Thank you for your work and efforts. The City now has an additional 100 bus benches that need to be installed. This installation is a new and separate contract and is expected to cost in excess of $25,000 for placement. According to our legal counsel, Article VI, Section 6 of the City Charter and Section 1.80.040 of the Yakima Municipal Code require that purchase of installation services in excess of $25,000 must be made through a call for bids. I anticipate that the City will publish a call for bids regarding this new bus bench installation project in the near future. Of course, you are welcome and invited to submit a bid on this project after the call for bids is published. Thank you for your attention to this matter. Sin e Assistant City Manager c: Dick Zais, City Manager Chris Waarvick, Public Works Director Bill Schultz, Manager, Transit Division Sue Ownby, Manager, Purchasing Division Ray Paolella, City Attorney Yakima March 2, 2000 Mr. Dick Zais, City Manager Yakima City Council Purchasing Manager, DBELO City of Yakima 129 North 2nd Street Yakima, WA 98901 Dear Mr. Zais, Speaking from years of personal experience working in the construction industry, and experience as a general contractor bidding on City of Yakima jobs, I submit the following on the Department of Transportation (USDOT), Disadvantaged Business Enterprises (DBE) Program proposed by the City of Yakima for the year 2000. The Eastem Washington region and the City of Yakima have a meager history of success when working with minority and disadvantaged businesses. The administration of the programs has been seen, at best, as a minimal attempt to be in compliance. The DBE program was designed by the Federal Govemment to provide stability to minority communities, not only in terms of employment, but also in terms of minority business utilization. As a Black general contractor, I want the DBE program to be administered in a way that makes it an effective economic development tool for me, and the minority community of the City of Yakima. I do not want it to be a program that just gives lip service to compliance with the Federal requirements in order to continue to receive Federal funds. I would like to see the City of Yakima promote the development of minority and disadvantaged businesses. A thorough review of the documentation available for public inspection at the Purchasing Manager's Office confirms that the City of Yakima has little to show in terms of maintenance of a directory, or in outreach efforts to firms eligible to participate as DBE's. The same is true regarding creation of Business Development Programs or any other supportive services to develop DBE's ability to grow successfully or to be involved in Federally funded projects. Further review finds that the process of establishing the published goals is very disturbing. The City of Yakima requested the Yakima Valley Conference of Govemments (YVCOG) to assist in developing the USDOT DBE Goal for the Federal Transit Administration. The YVCOG Memorandum indicates that, "Yakima Transit staff requested YVCOG assistance in developing a goal for DBE's as required by USDOT, Federal Transit Administration." And, although YVCOG's work is remarkable, the City should have taken advantage of the very commendable work already being done and available, by such minority organizations as OMWBE (Office of Minority and Women's Business Enterprises), a State agency, and WAME (Washington Association of Minority Entrepreneurs), a local agency. The City has failed to recognize WAME, a minority financial institute, who they fund. Mr. Dick Zais March 2, 2000 Page Two Sue Ownby, City of Yakima Purchasing Manager, provided documentation to YVCOG from May 1994 through September 1999 on contracts let out by the City of Yakima on behalf of the Yakima Transit Department. YVCOG's Memorandum specifically states that their calculations and their recommendations are for the Federal Transit Administration DBE Program. Yet the City of Yakima uses YVOC's Memorandum to arrive at their DBE goal for the overall USDOT DBE Program, of which FTA expenditures represents a minimal portion. And even so, YVCOG recommends a DBE goal of 12% which the City of Yakima reduces to 10% without any documentation to substantiate the rationale for the 2% reduction. In the analysis of the FTA -assisted contracts for 1998, my firm contracted for $15,000 not the $11,216 indicated. That contract was negotiated, not bid, so rightfully it should not be included in the analysis calculations. To make the type of analysis required by the DOT programs (Chapter 49, Combined Federal Regulations, Part 26.45), all of the DOT -assisted contracts let by the City of Yakima, over the same five year period, should be included in the calculations for the USDOT DBE Program goal that the City of Yakima proposes for the year 2000. This analysis will show that the same companies, year in and year out, are awarded contracts with minimal actual participation given to other DBE's. This analysis will also show that the over -concentration of use of the same DBE's year after year results in a measurably negative impact upon DBE's that could have been participating, or been given assistance in their development toward active participation. I am also addressing several points of contention that I have with the City of Yakima as they've dealt with my firm when I've bid FTA contracts. • My experience is that the City of Yakima administration is resistant to implementing a good sound DBE Program. • Little has been accomplished in terms of economic development, especially in the Black community. • The economic development for the minority community that has been done has only been done with resistance on the part of the City, • The City imposes additional conditions that serve to create greater obstacles to aspiring minority businesses, including my own. In 1998, I was the lowest bidder on an FTA project to set up street benches. The City representative informed me that money was not available for completion of the entire contract. I was asked, "How many will you do for $15,000?" This was approximately % the contact amount , so I contracted to set up / of the benches. The question then presents itself, can the City legally publicize a project for bids when they do not have the money available? It would be easy to conclude from this exercise that the City didn't want to give my firm the contract. Furthermore, I was asked not only to put up a bid bond, but also a performance bond. Neither of these bonds are required by the Federal govemment for bids of this size. These additional, unnecessary demands create very real financial obstacles to a small business. The bench installation contract stated that the successful bidder, at option of the City of Yakima, had the opportunity to perform for two additional years on the same contract. Mr. Dick Zais March 2, 2000 Page Three However, in 1999, the contract was again put out for bids. I was not notified, nor was there any discussion with me, whatsoever. When I asked for clarification, the rationale given was that the scope of work had changed, thus designating it as a new contract that required a new bidding process. The change in the scope of work was the additional anchoring of the street benches. Realistically, the scope of work had not changed to such a degree that it called for a new contract. This is another kind of obstacle laid down in the path of minority businesses. And, it has the appearance of discrimination against Black and other minorities who attempt to do business with the City of Yakima. It becomes apparent that the City of Yakima and its leadership do not fully support the DBE Program, nor do they seem to have the will to undertake the enforcement and monitoring of this program. The program itself is essential to the minority community, as it is to the majority community. The DBE Program has been issued as a Final Rule and is the law of the land and should be enforced - to the strictest letter of the law. The City of Yakima is not demonstrating that it can, and will, do so. Further, based on the City of Yakima's record, I disagree that race -neutral goal of 5% should be used. At present, it would be appropriate for these contracts to be awarded to DBE's in an attempt to remedy past discrimination. In the future, after the City of Yakima develops business assistance programs for Black and other minority businesses, and develops a history of utilization with a minimum participation of, at least, 12%, then and only then, should the City attempt to use race neutral goals. Good faith efforts by the City of Yakima or Non -DBE contractors should not be allowed when there is at least one eligible DBE seeking to participate. The City of Yakima should immediately begin to take concrete, positive steps to develop these relationships. The criteria they use should be based upon the opportunities identified within the contract that could be "subbed" out to minority businesses. Optimally, the City should set a minimum acceptable goal of 12% over all contacts that involve Federal dollars mandated for utilization of protected businesses. I appreciate your attention to my comments and your serious consideration of the concerns I've voiced here. Sincerely, Phillip L. Pleasant General Contractor cc: DOT w/ enclosures