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乌鸦传媒, Chapters, Members Comment on DOT DBE Proposal

乌鸦传媒 of America submitted a comprehensive assessment of proposed changes to the Department of Transportation鈥檚 (DOT) Disadvantaged Business Enterprise (DBE) regulations. In addition, 15 乌鸦传媒 chapters submitted their own unique comments on the proposal and 125 members commented through 乌鸦传媒鈥檚 Legislative Action Center website. Additional 乌鸦传媒 member comments were submitted directly to DOT. The comment period closed on December 24, 2012. 乌鸦传媒鈥檚 comments urged DOT to not adopt the bulk of the proposed rule changes and instead to open a dialogue with all segments of the industry to find a more realistic approach to expanding participation of DBE businesses. 乌鸦传媒 suggested that DOT, 鈥渦se this rulemaking as an opportunity to solicit ideas for moving the DBE program in a new direction. Instead of having the program focused exclusively on goals and what can and cannot be done in meeting those goals, 乌鸦传媒 encourages DOT to explore creating opportunities for giving incentives to contractors and DOT funding recipients for DBE utilization such as banking DBE utilization credits and other possibilities. 乌鸦传媒 believes an open dialogue should take place to examine new ways of expanding DBE contracting opportunities.鈥 乌鸦传媒 also commented on the specific proposed rule changes. 乌鸦传媒 questioned the justification supporting many of these significant suggested amendments such as requiring prime contractors to submit at bid time the list of DBEs that will be used on the project along with certification from those DBEs that they intend to carry out that work. 乌鸦传媒鈥檚 comments also pointed out the problems that would be caused if the proposed requirement that contractors who do not meet contract goal requirements submit documentation of the 鈥淕ood Faith Efforts鈥 made to achieve the goal with their bid. 乌鸦传媒 also objected to DOT鈥檚 proposal for states to set annual DBE utilization goals based on a directory of certified DBEs rather than DBEs that are actually ready, willing and able to participate on DOT funded contracts. 乌鸦传媒 also called into question numerous other proposed rule changes. can be read here and . DOT will now assess the volume of comments received on the proposal and determine how it intends to move forward. 乌鸦传媒 will continue to press for more open discussion of the proposal and on ideas for improving the program鈥檚 implementation.