HomeMy WebLinkAboutItem 4.05 DisadBusEnterpriseCTTY CLERK FILE # 1060-90
AGENDA STATEMENT
CTTY COUNCIL MEETTNG DATE: February 20, 2001
SUBJECT:
Approval of draft Disadvantaged Business Enterprise (DBE)
Program for Federally Funded Projects
Report Prepared by: Lee S. Thompson, Public Works Director
ATTACHMENTS:
Resolution approving draft DBE Program and authorizing the Mayor
to execute the Program for federally funded projects, together with
Exhibit "A", the draft DBE Program and annual DBE Goal
RECOMMENDATION: Adopt Resolution approving draft DBE Program and authorize the
Mayor to execute the Program for federally funded projects
FINANCIAL STATEMENT:
The City is receiving approximately $2.07 Million in federal funds
in current Fiscal Year 2000-2001. The DBE Program will establish a
10.25% goal for DBE business participation in City projects
utilizing federal funds.
DESCRIPTION: The Disadvantaged Business Enterprise (DBE) Program is created to
encourage small businesses owned by socially or economically disadvantaged individuals to participate in
City projects utilizing federal funds. Such individuals include minorities, women, or any other group
found to be socially and economically disadvantaged by the Small Business Administration.
The draft DBE Program (Attachment 2) has established a 10.25% DBE participation goal for federally
funded projects in the current Fiscal Year 2000-2001. The DBE goal was determined by compiling a list
of qualified DBE businesses capable of performing work under current federally fimded City projects and
comparing the list to the total licensed businesses. DBE participation in past City projects was also
considered in developing the current DBE goal. Staff has submitted the draft DBE Program to Caltrans
and has been given preliminary approval.
The City has published notices of the proposed 10.25% DBE goal and informed the public that the
proposed goal and its rationale are available for public review and comment for a 45-day period that
ended February 9, 2001. The City did not receive any comments regarding the draft DBE Program and
goal.
Staff is recommending that the City Council adopt the resolution approving the draft DBE Program for
federally funded City projects and authorizing the Mayor to execute the Program.
COPIES TO:
ITEM NO.
g:\miscproj\DBE\agst DBE Approval
RESOLUTION NO. - 01
A RESOLUTION OF THE CITY COUNCIL
OF THE CITY OF DUBLIN
APPROVING THE DRAFT DISADVANTAGED BUSINESS ENTERPRISE
(DBE) PROGRAM
WHEREAS, the City of Dublin has developed a draft Disadvantaged Business Enterprise (DBE)
Program for. City projects utilizing federal funds; and
WHEREAS, a goal of 10.25% DBE participation is established for City projects utilizing federal
funds in the Federal fiscal year ending September 30, 2001; and
WHEREAS, the City of Dublin has established the draft DBE Program in accordance with
regulations of the U.S. Department of Transportation (DOT), 49 CFR Part 26;
NOW, THEREFORE, BE IT RESOLVED that the City Council of the City of Dublin does hereby
approve the draft DBE Program as to content and form, which is attached hereto as "Exhibit A".
BE IT FURTHER RESOLVED that the Mayor is authorized to execute the draft DBE Program.
PASSED, APPROVED AND ADOPTED this 20th day of February, 2001.
AYES:
NOES:
ABSENT:
ABSTAIN,:
Mayor
ATTEST:
City Clerk
g:miscproj\DBEXresolution
ATTACHMENT
L~, 5
EXHIBIT "A"
DISADVANTAGED BUSINESS
ENTERPRISE (DBE) PROGRAM
FOR
THE CITY OF DUBLIN
This Program is in accordance with Title 49 of the Code of Federal Regulations Part 26
DISADVANTAGED BUSINESS ENTERPRISE (DBE) PROGRAM
City of Dublin
I Definitions of Terms
The terms used in this program have the meanings defined in 49 CFR §26.5.
II Objectives/Policy Statement (§§26.1, 26.23)
The City of Dublin 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 of Dublin has received Federal financial assistance from the DOT, and as a condition
of receiving this assistance, the City of Dublin will sign an assurance that it will comply with 49
CFR Part 26.
It is the policy of the City of Dublin to ensure that DBEs, as defined in part 26, have an equal
opportunity to receive and participate in DOT-assisted contracts. It is also our 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.
Steven Yee has been delegated as the DBE Liaison Officer. In that capacity, Steven Yee 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 of Dublin in its financial assistance agreements with the California Department of
Transportation (Caltrans).
The City of Dublin has disseminated this policy statement to the City Council of the City of
Dublin and all the components of our organization. We have distributed this statement to DBE
and non-DBE business communities that perform work for us on DOT-assisted contracts by
publishing this statement in general circulation, minority-focused and trade association
publications.
IIl Nondiscrimination (§26.7)
The City of Dublin 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.
Page 2
In administering its DBE program, the City of Dublin 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.
IV DBE Program Updates (§26.21)
The City of Dublin will continue to carry out this program until the City of Dublin has
established a new goal setting methodology or until significant changes to this DBE Program are
adopted. The City of Dublin will provide to Caltrans a proposed overall goal and goal setting
methodology and other program updates by June 1 of every year.
V Quotas (§26.43)
The City of Dublin will not use quotas or set-asides in any way in the administration of this
DBE program.
VI DBE Liaison Officer (DBELO) (§26.45)
The City of Dublin has designated the following individual as the DBE Liaison Officer: Steven
Yee, City of Dublin, 100 Civic Plaza, Dublin, California 94568, (925) 833-6630. In that
capacity, Steven Yee is responsible for implementing all aspects of the DBE program and
ensuring that the City of Dublin complies with all provisions of 49 CFR Part 26. This is
available on the Internet at osdbuweb.dot.gov/main.cfm. Steven Yee has direct, independent
access to the City Manager concerning DBE program matters. The DBELO has a staff of one
(1) employee assigned to the DBE program on a part-time basis who devote a portion of
their time to the program. An organization chart displaying the DBELO's position in the
organization is found in Attachment 1 to this program.
The DBELO is responsible for developing, implementing and monitoring the DBE program, in
coordination with other appropriate officials. Duties and responsibilities include the following:
1. Gathers and reports statistical data and other information as required.
2. Reviews third party contracts and purchase requisitions for compliance with this program.
3. Works with all departments to set overall annual goals.
4. Ensures that bid notices and requests for proposals are available to DBEs in a timely manner.
5. Identifies contracts and procurements so that DBE goals are included in solicitations (both
race-neutral methods and contract specific goals) and monitors results.
6. Analyzes the City of Dublin's progress toward goal attainment and identifies ways to
improve progress.
7. Participates in pre-bid meetings.
8. Advises the Public Works Director on DBE matters and achievement.
9. Participates with the legal counsel and project director to determine contractor compliance
with good faith efforts.
10. Provides DBEs with information and assistance in preparing bids, obtaining bonding and
insurance.
11. Plans and participates in DBE training seminars.
12. Provides outreach to DBEs and community organizations to advise them of opportunities.
Page 3
VII Federal Financial Assistance Agreement Assurance (§26.13)
The City of Dublin will sign the following assurance, applicable to all FItWA-assisted contracts
and their administration as part of the program supplement agreement for each project:
The recipient 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 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.).
VIII DBE Financial Institutions
It is the policy of the City of Dublin 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.
Information on the availability of such institutions can be obtained from the DBE Liaison
Officer. The Caltrans Disadvantaged Business Enterprise Program may offer assistance to the
DBE Liaison Officer.
IX Directory (§26.31)
The City of Dublin will refer interested persons to the DBE directory available from the Caltrans
Disadvantaged Business Enterprise Program website at www.dot.ca. gov/hq/bep.
X Overconcentration (§26.33)
The City of Dublin has not identified any types of work in DOT-assisted contracts that have a
overconcentration of DBE participation. If in the future the City of Dublin identifies the need to
address overconcentration, measures for addressing overconcentration will be submitted to the
DLAE for approval.
Page 4
XI Business Development Programs (§26.35)
The City of Dublin does not have a business development or mentor-prot~g6 program. If the
City of Dublin identifies the need for such a. program in the future, the rationale for adopting
such a program and a comprehensive description of it will be submitted to the DLAE for
approval.
XII Required Contract Clauses (§§26.13, 26.29)
Contract Assurance
The City of Dublin ensures 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 recipient deems appropriate.
· Prompt Payment
The City of Dublin ensures that the following clauses or equivalent will be included in each
DOT-assisted prime contract:
Satisfactory Performance
The prime contractor agrees to pay each subcontractor under this prime contract for satisfactory
performance of its contract no later than 10days from the receipt of each payment the prime
contractor receives from the City of Dublin. Any delay or postponement of payment from the
above referenced time frame may occur only for good cause following written approval of the
City of Dublin. This clause applies to both DBE and non-DBE subcontractors
Release of Retaina~e
The prime contractor agrees further to release retainage payments to each subcontractor within 30
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 of Dublin. This clause applies to both DBE and non-DBE subcontractors.
XIII Monitoring and Enforcement Mechanisms (§26.37)
The City of Dublin will assign a Resident Engineer (RE) or Contract Manager to monitor and
track actual DBE participation through contractor and subcontractor reports of payments in
accordance with the following:
Page 5
After Contract Award
After the contract award the City of Dublin will review the award documents for the portion of
items each DBE and first tier subcontractor will be performing and the dollar value of that work.
With these documents the RE/Contract Manager will be able to determine the work to be
performed by the DBEs or subcontractors listed.
Preconstruction Conference
A preconstruction conference will be scheduled between the RE and the contractor or their
representative to discuss the work each DBE subcontractor will perform.
Before work can begin on a subcontract, the local agency will require the contractor to submit a
completed "Subcontracting Request," Exhibit 16-B of the LAPM or equivalent. When the RE
receives the completed form it will be checked for agreement of the first tier subcontractors and
DBEs. The RE will not approve the request when it identifies someone other than the DBE or
first tier subcontractor listed in the previously completed "Local Agency Bidder DBE
Information," Exhibit 15-G. The "Subcontracting Request" will not be approved until any
discrepancies are resolved. If an issue cannot be resolved at that time, or there is some other
concem, the RE will require the contractor to eliminate the subcontractor in question before
signing the subcontracting request. A change in the DBE or first tier subcontractor may be
addressed during a substitution process at a later date.
Suppliers, vendors, or manufacturers listed on the "Local Agency Bidder DBE Information" will
be compared to those listed in the completed Exhibit 16-1 of the LAPM or equivalent.
Differences must be resolved by either making corrections or requesting a substitution.
Substitutions will be subject to the Subletting and Subcontracting Fair Practices Act (FPA).
Local agencies will require contractors to adhere to the provisions within Subletting and
Subcontracting Fair Practices Act (State Law) Sections 4100-4144. FPA requires the contractor
to list all subcontractors in excess of one half of one percent (0.5%) of the contractor's total bid
or $10,000, whichever is greater. The statute is designed to prevent bid shopping by contractors.
The FPA explains that a contractor may not substitute a subcontractor listed in the original bid
except with the approval of the awarding authority.
The RE will give the contractor a blank Exhibit 17-F, "Final Report Utilization of Disadvantaged
Business Enterprises, First Tier Subcontractors" and will explain to them that the document will
be required at the end of the project, for which payment can be withheld, in conformance with
the contract.
Construction Contract Monitoring
The RE will ensure that the RE's staff (inspectors) know what items of work each DBE is
responsible for performing. Inspectors will notify the RE immediately of apparent violations.
Page 6
When a firm other than the listed DBE subcontractor is found performing the work, the RE will
notify the contractor of the apparent discrepancy and potential loss of payment. Based on the
contractor's response, the RE will take appropriate action: The DBE Liaison Officer will
perform a preliminary investigation to identify any potential issues related to the DBE
subcontractor performing a commercially useful function. Any substantive issues will be
forwarded to the Caltrans Disadvantaged Business Enterprise Program. If the contractor fails to
adequately explain why there is a discrepancy, payment for the work will be withheld and a letter.
will be sent to the contractor referencing the applicable specification violation and the required
withholding of payment.
If the contract requires the submittal of a monthly truck document, the contractor will be required
to submit documentation to the RE showing the owner's name; California Highway Patrol CA
number; and the DBE certification number of the owner of the truck for each truck used during
that month for which DBE participation will be claimed. The trucks will be listed by California
Highway Patrol CA number in the daily diary or on a separate piece of paper for documentation.
The numbers are checked by inspectors regularly to confirm compliance.
Providing evidence of DBE payment is the responsibility of the contractor.
Substitution
When a DBE substitution is requested, the RE/Contract Manager will request a letter from the
contractor explaining why substitution is needed. The RE/Contract Manager must review the
letter to be sure names and addresses are shown, dollar values are included, and reason for the
request is explained. If the RE/Contract Manager agrees to the substitution, the RE/Contract
Manager will notify, in writing, the DBE subcontractor regarding the proposed substitution and
procedure for written objection from the DBE subcontractor in accordance with the Subletting
and SubcontraCting Fair Practices Act. If the contractor is not meeting the contract goal. with this
substitution, the contractor must provide the required good faith effort to the RE/Contract
Manager for local agency consideration.
If there is any doubt in the RE/Contract Manager's mind regarding the requested substitution, the
RE/Contract Manager may contact the DLAE for assistance and direction.
Record Keeping and Final Report Utilization of Disadvantaged Business Enterprises
The contractor shall maintain records showing the name and address of each first-tier
subcontractor. The records shall also show:
1. The name and business address, regardless of tier, of every DBE subcontractor, DBE vendor
of materials and DBE trucking company.
2. The date of payment and the total dollar figure paid to each of the firms.
3. The DBE prime contractor shall also show the date of work performed by their own forces
along with the corresponding dollar value of the work claimed toward DBE goals.
Page 7
When a contract has been completed the contractor will provide a summary of the records stated
above. The DBE utilization information will be documented on Exhibit 17-F and will be
submitted to the DLAE attached to the Report of Expenditures. The RE will compare the
completed Exhibit 17-F to the contractor's completed Exhibit 15-G and, if applicable, to the
completed Exhibit 16-B. The DBEs shown on the completed Exhibit 17-F should be the same as
those originally listed unless an authorized substitution was allowed, or the contractor used more
DBEs and they were added. The dollar amount should reflect any changes made in planned work
done by the DBE. The contractor will be required to explain in writing why the names of the
subcontractors, the work items or dollar figures are different from what was originally shown on
the completed Exhibit 15-G when:
There have been no changes made by the RE.
The contractor has not provided a sufficient explanation in the comments section of the
completed Exhibit 17-F.
The explanation will be attached to the completed Exhibit 17-F for submittal. The RE will file
this in the project records.
The local agency's Liaison Officer will keep track of the DBE certification status on the Internet
at www.dot.ca.gov/hq/bep and keep the RE informed of changes that affect the contract. The RE
will require the contractor to act in accordance with existing contractual commitments regardless
of decertif~cation.
The DLAE will use the PS&E checklist to monitor the City of Dublin's commitment to require
bidders list information to be submitted to the City of Dublin from the awarded prime and
subcontractors as a means to develop a bidders list. This monitoring will only take place if the
bidders list information is required to be submitted as stipulated in the special provisions.
The City of Dublin will bring to the attention of the DOT through the DLAE 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 of Dublin also will consider similar action under our own legal
authorities, including responsibility determinations in future contracts.
XIV Overall Goals (§26.45)
Amount of Goal
City of Dublin's overall goal for the Federal fiscal year Ivy 2000/2001 is the following:10.25%
of the Federal financial assistance in FHWA-assisted contracts.
Methodology
Step 1, the Base Figure, was calculated by obtaining the total number of Caltrans certified DBE
contractors and the total number of businesses per the US Census Bureau ,data in the greater Bay
Area (our selected market area), per the Work Category Codes (WCC) as related to the City of
Dublin anticipated Federal projects to be awarded for the FY 2000/01.
Page 8
Step 2, the Resultant Goal, was calculated utilizing Historical DBE Participation on Federal
projects awarded within the past five years. Additionally, due to the changes in Part 26, an
adjustment for trucking was made. An average attainment was calculated using the Historical
DBE Participation, less trucking data, and then averaged with the Base Figure obtained in Step 1
to reach our Step 2 Resultant Goal.
Breakout of Estimated Race-Neutral and Race-Conscious Participation
The Race-Conscious Participation goal is estimated at 10.25%. At this time, the City does not have historical
evidence to provide a Race-Neutral goal. The City of Dublin typically awards Federal projects on the basis of
the lowest bidder.
Process
Starting with the Federal fiscal year 2002, the amount of overall goal, the method to calculate the
goal, and the breakout of estimated race-neutral and race-conscious participation will be required
annually by June 1 in advance of the Federal fiscal year beginning October 1 for FHWA-assisted
contracts. Submittals will be to the Caltrans' DLAE. An exception to this will be if FTA or
FAA recipients are required by FTA or FAA to submit the annual information to them or a
designee by another date. FHWA recipients will follow this process:
Once the DLAE has responded with preliminary comments and the comments have been
incorporated into the draft overall goal information, the City of Dublin will publish a notice of
the proposed overall goal, informing the public that the proposed goal and its rationale are
available for inspection during normal business hours at the City of Dublin's principal office for
30 days following the date of the notice, and informing the public that City of Dublin comments
will be accepted on the goals for 45 days following the date of the notice. Advertisements in
newspapers, minority focus media, trade publications, and websites will be the normal media to
accomplish this effort. The notice will include addresses to which comments may be sent and
addresses (including offices and websites) where the proposal may be reviewed.
The overall goal resubmission to the Caltrans DLAE, will include a summary of information and
comments received during this public participation process and the City of Dublin's responses.
This will be due by September 1 to the Caltrans DLAE. The DLAE will have a month to make a
final review so the City of Dublin may begin using the overall goal on October 1 of each year.
XV Contract Goals (§26.51)
The City of Dublin will use contract goals to meet any portion of the overall goal. The City of
Dublin does not project being able to meet by the use of 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 the overall 'goal that is not projected to be met through the use of
race-neutral means.
Page 9
Contract goals will be established only on those DOT-assisted contracts that have subcontracting
possibilities. Contract goals need not be established 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 contract work items
will be compared with eligible DBE contractors willing to work on the project. A determination
will also be made to decide which items are likely to be performed by the prime contractor and
which ones are likely to be performed by the subcontractor(s). The goal will then be
incorporated into the contract documents. Contract goals will be expressed as a percentage of the
total amount of a DOT-assisted contract.
XVI Transit Vehicle Manufacturers (§26.49)
If DOT-assisted contracts will include transit vehicle procurements, the City of Dublin will
require each transit vehicle manufacturer, as a condition of being authorized to bid or propose on
transit vehicle procurements, to certify that it has complied with the requirements of 49 CFR Part
26, Section 49. The City of Dublin will direct the transit vehicle manufacturer to the subject
requirements located on the Internet at http://osdbuweb.dot.gov/programs/dbe/dbe.htm.
XVII Good Faith Efforts (§26.53)
Information to be Submitted
The City of Dublin treats bidders'/offerors' compliance with good faith effort requirements as a
matter of responsiveness. A responsive proposal is meeting all the requirements of the
advertisement and solicitation.
Each solicitation for which a contract goal has been established will require the bidders/offerors
to submit the following information to 100 Civic Plaza, Dublin, California 94568 no later than
4:00 p.m. on or before the fourth day, not including Saturdays, Sundays and legal holidays,
following bid opening:
1. The names and addresses of known DBE firms that will participate in the contract;
2. A description of the work that each DBE will perform:
3. The dollar amount of the participation of each DBE firm participation
4. Written and signed documentation of commitment to use a DBE subcontractor whose
participation it submits to meet a contract goal;
5. Written and signed confirmation from the DBE that it is participating in the contract as
provided in the prime contractor's commitment; and
6. 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 part 26 which is attached.
Page 10
The following personnel are responsible for determining whether a bidder/offeror who has not
met the contract goal has documented sufficient good faith efforts to be regarded as responsive:
DBE Liaison Officer.
City of Dublin will ensure that all information is complete and accurate and adequately
documents the bidder/offeror's good faith efforts before a commitment to the performance of the
contract by the bidder/offeror is made.
Administrative Reconsideration
Within 10 days of being informed by the City of Dublin that it is not responsive because it has
not documented sufficient good faith efforts, a bidder/offeror may request administrative
reconsideration. Bidder/offerors should make this request in writing to the following
reconsideration official: Public Works Director, City of Dublin, 100 Civic Plaza, Dublin,
California 94568, (925) 833-6630. The reconsideration official will not have played any role in
the original determination that the bidder/offeror did not make 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 do so. The bidder/offeror will have the opportunity to meet in person with
the reconsideration official to discuss the issue of whether it met the goal or made adequate good
faith efforts to do. The City of Dublin 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 Caltrans, FHWA or the DOT.
Good Faith Efforts when a DBE is Replaced on a Contract
The City of Dublin will require a contractor to make good faith efforts to replace a 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 prime contractor is required to notify the RE
immediately of the DBE's inability or unwillingness to perform and provide reasonable
documentation.
In this situation, the prime contractor will be required to obtain the City of Dublin 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 to comply in the time specified, the City of
Dublin contracting office will issue an order stopping all or part of payment/work until
satisfactory action has been taken. If the contractor still fails to comply, the contracting officer
may issue a termination for default proceeding.
XVIII Counting DBE Participation (§26.55)
The City of Dublin will count DBE participation toward overall and contract goals as provided
in the contract specifications for the prime contractor, subcontractor, joint venture partner with
prime or subcontractor, or vendor of material or supplies. See the Calltans' Sample Boiler Plate
Contract Documents previously mentioned. Also, refer to XI, A. "After Contract Award."
Page 11
The City of Dublin will count DBE participation toward overall and contract goals as provided
in the contract specifications for the prime contractor, subcontractor, joint venture partner with
prime or subcontractor, or vendor of material or supplies. See the Caltrans' Sample Boiler Plate
Contract Documents previously mentioned. Also, refer to XI, A. "After Contract Award."
XIX Certification (§26.83(a))
The City of Dublin ensures that only DBE firms currently certified on the Caltrans' directory
will participate as DBEs in our program.
XX Information Collection and Reporting
Bidders List
The City of Dublin will create and maintain a bidders list, consisting of information about all
DBE and non-DBE firms that bid or quote on its DOT-assisted contracts. The bidders list will
include the name, address, DBE/non-DBE status, age, and annual gross receipts of firms.
Monitoring Payments to DBES
Prime contractors are required to maintain records and documents of payments to DBEs for three
years following the performance of the contract. These records will be made available for
inspection upon request by any authorized representative of the City of Dublin, Caltrans or
FHWA. This reporting requirement also extends to any certified DBE subcontractor.
Payments to DBE subcontractors will be reviewed by the City of Dublin 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 Caltrans
City of Dublin - Final utilization of DBE participation will be reported to the DLAE using
Exhibit 17-F of the Caltrans' LAPM.
Con~dentialitv
The City of Dublin will safeguard from disclosure to third parties information that may
reasonably be regarded as confidential business information, consistent with Federal, state, and
local laws.
Mayor
Attest:
City Clerk
This Disadvantaged Business Enterprises Program is accepted by:
Date:
Date:
[Signature of DLAE]
Date:
· Page 12
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 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 efforts.
IV. The following is a list of types of actions which you should Consider as part of the bidder's
good faith efforts to obtain DBE participation. It is not intended to be a mandatory checklist, nor
is it intended to be exclusive or exhaustive. Other factors or types of efforts may 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.
Page 13
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 perform 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 perform 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 the rejection or non-solicitation Of bids in the contractor's efforts to meet the project
goal.
F. Making efforts to assist interested DBEs in 6btaining 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
organizhtions; minority/women contractors' groups; local, state, and Federal
minority/women business assistance offices; and other organizations as allowed on a
case-by-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
successful bidder having made good faith efforts.
Page 14
City of Dublin
Overall Annual DBE Goal and Methodology for Federally Funded Projects
October 2000
Summary:
The City of Dublin proposes a 10.25% DBE for the upcoming federal fiscal year (2000/01). The
Step 1 Base Figure using work category codes and Census data is 6.47%. The Step 2 adjustment
utilized historical DBE participation on previous federally funded projects. Historical data
indicated DBE participation of 14.03%. Adjustments for the changes in DBE trucking were
made. Race conscious component of the goal is 10.25% and the race neutral portion is 0%.
DOT- Assisted Contracts for FFY 2000/01
The City of Dublin anticipates that it will utilize federal funds on three projects in the
federal fiscal y6ar 2000/01. These include the following projects:
· Alamo Canal Trail
· Annual Street Overlay Project
· Dublin Boulevard Widen~ing
The list of projects, amount of federal funds and additional information outlined below in
Goal Methodology is presented in Table 1: Step 1 - Base Figure.
Goal Methodology - Step 1: Determination of Base Figure for the relative availability of
DBEs that are ready, willing and able to participate in the Federal-aid contracting
program.
The City of Dublin elected to use DBE Directories and Census Bureau Data. Each
project was analyzed to determine the approximate percentage of work relating to the
various work category codes (WCC) used by Caltrans and the corresponding NAICS
code. This data is also presented in Table 1..
The Caltrans database (Calcert) (http://www.dot.ca.gov/hq/bep/) for DBE firms was used
to obtain the list of ready, willing and able DBEs in our market area. The City's market
area was defined as the 11 greater Bay Area counties (Alameda, Contra Costa,. Marin,
Napa, Sacramento, San Francisco, San Mateo, Santa Clara, Santa Cruz, Solano, Sonoma).
The relative availability of DBEs for each WCC and NAICS are attached as Step 1 tables.
Attached to each table is a list of the DBE's ready, willing and able to work in Dublin.
The Step 1 resulting Base Figure is 6.47%.
HI. Goal Methodology- Step 2: Review and adjustment of the Base Figure.
Table 2 presents the City's historical DBE participation for federally funded contracts.
The DBE market will be impacted by the changes in Part 26, Title 49 of the CFR. In
order to account for this, the tracking portion of the historical analysis should be
deducted. Table 3 presents the tracking portion of the historical analysis. Table 4 is the
adjusted historical DBE (trucking deducted from the project total).
The adjusted historical DBE percentage is 14.03%.
Table 5 presents City of Dublin's resultant goal of 10.25%. This was acquired by
averaging the Step 1 and Step 2 goals.
All back up documents such as Census, NAICS, historical DBE information, Step 1
relative availability tables, and DBE lists for each work code are included for reference.