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Agenda 02/25/2025 Item #16B 6 (Approve the Collier Area Transit Disadvantaged Business Enterprise Program Update to ensute its compliance with Federal Transit Administration requirements and authorize its submital to the FTA)2/25/2025 Item # 16.13.6 ID# 2025-544 Executive Summary Recommendation to approve the Collier Area Transit Disadvantaged Business Enterprise (DBE) Program Update to ensure its compliance with Federal Transit Administration (FTA) requirements and authorize its submittal to the FTA. OBJECTIVE: To make certain Disadvantaged Business Enterprises (DBEs) have an equal opportunity to receive and participate in Federal Transit Administration (FTA) assisted contracts and ensure nondiscrimination in the award and administration of these contracts. CONSIDERATIONS: The Collier County Board of County Commissioners (the "Board") has received Federal financial assistance from the FTA, and as a condition of receiving this assistance, the Board must comply with Title 49 of the Code of Federal Regulations (C.F.R.), part 26. The Board is required to have a DBE program in accordance with regulations of the U.S. Department of Transportation, as provided in Title 49 of the C.F.R. A DBE Program ensures that DBE's have an equal opportunity to receive and participate in FTA assisted contracts by ensuring nondiscrimination in their award and administration. On May 9, 2024, the US Department of Transportation updated the DBE Final Rule at 49 CFR § 26.21(a). The update included a modification of the requirements based on the agencies that fall within the Tier 1 or Tier 2 designation. Based on the criteria, Collier Area Transit is designated Tier 1 as it awards prime contracts exceeding a cumulative total value of $670,000 in FTA funds in a federal fiscal year, excluding transit vehicle purchases. The final rule updates the DBE program requirements. Key changes include expanded reporting requirements for recipients of federal transportation funds, refined definitions within the programs, administrative streamlining, and modifications to the certification and decertification processes for DBEs. The necessary changes that were applicable to Collier County have been incorporated into the CAT's DBE Program. The changes, which are minor, are as follows: Section 3.7 Good Faith Efforts Procedures for contracts with DBE Contract Goals [26.531 Section 3.8 Counting DBE Participation [26.551 The BCC will count DBE participation toward overall and contract goals as provided in 49 CFR 26.55. Only the value of the work actually performed by the DBE will count toward DBE goals. Such value will be counted as follows: • The entire amount that is performed by the DBE. • The entire amount of reasonable fees or commissions charged by a DBE firm for providing a bona fide service or for providing bonds or insurance required for the performance of the DOT -assisted contract. • The value of work subcontracted by a DBE to another DBE is counted toward DBE goals. • When a DBE performs as part of a joint venture, the portion of the total dollar value of the contract equal to the defined portion of the work of the contract that the DBE performs will be counted. • Expenditures to a DBE contractor will be counted toward DBE goals only if the DBE is performing a commercially useful function on that contract as set forth in 49 CFR Part 26.55[c] [1-5]. For determining whether a trucking company is performing a commercially useful function, Collier County will refer to 49 CFR Part 26.55[d] (1-6]. • For establishing whether expenditures for materials or supplies count toward DBE goals, Collier County will refer to 49 CFR Part 26.55 [e]. • A DBE's participation will not be counted toward DBE goals of the prime contractor or the BCC's overall goal until the DBE is paid. This item is consistent with the Collier County strategic plan objective to design and maintain an effective transportation system to reduce traffic congestion and improve the mobility of our residents and visitors. Additionally, the item is Page 40 of 94 2/25/2025 Item # 16.13.6 ID# 2025-544 consistent with the objective to support access to health, wellness, and human services. FISCAL IMPACT: Approval of the Disadvantaged Business Enterprises Program update ensures compliance with federal requirements to receive annual appropriations awarded by FTA. FTA Grant Programs are typically funded within CAT Grant Fund (4031). GROWTH MANAGEMENT IMPACT: This item is consistent with Objective 12 of the Transportation Element of the Growth Management Plan. LEGAL CONSIDERATIONS: This item has been reviewed by the County Attorney, is approved as to form and legality and requires majority vote for approval. -JAK RECOMMENDATIONS: To approve the Collier Area Transit Disadvantaged Business Enterprise Program Update to ensure its compliance with FTA requirements and authorize its submittal to the FTA. PREPARED BY: Omar De Leon, Transit Manager, PTNE Divison ATTACHMENTS: DBE Program 2-25-25 update DBE Program 2-25-25 update - TrackChanges Page 41 of 94 COLLIER COUNTY BOARD OF COUNTY COMMISSIONERS Collier Area Transit Disadvantaged Business Enterprise Program 2/25/2025 Page 701 of 2568 Page 2 of 39 Table of Contents Collier County Board of County Commissioners Disadvantaged Business Enterprise Policy Statement..................................................... 4 1. GENERAL REQUIREMENTS .................................. 5 Section 1.1 Objectives [26.1] ....................................... 5 Section 1.2 Applicability [26.3] ..................................... 5 Section 1.3 Definitions [26.5] ...................................... 5 Section 1.4 Non-discrimination Requirements [26.1 & 26.7] .................. 5 Section 1.5 Record Keeping Requirements [26.11] ........................ 5 Section 1.6 Bidders List [26.11] ..................................... 6 Section 1.7 Federal Financial Assistance Agreement [26.13] .................. 6 2. ADMINISTRATIVE REQUIREMENTS ........................... 7 Section 2.1 DBE Program Updates [26.21].............................. 7 Section 2.2 Policy Statement [26.23] .................................. 7 Section 2.3 DBE Liaison Officer (DBELO) [26.25] ........................ 7 Section 2.4 DBE Financial Institutions [26.27] ........................... 8 Section 2.5 Prompt Payment Mechanisms [26.29] ......................... 8 Section 2.6 Directory [26.31] ...................................... 9 Section 2.7 Overconcentration [26.33] ................................ 9 Section 2.8 Business Development Programs [26.35] ...................... 10 Section 2.9 Monitoring and Enforcement Mechanisms [26.37] ................ 10 Section 2.10 Fostering Small Business Participation [26.39] ................. 11 3.0 GOALS, GOOD FAITH EFFORTS, AND COUNTING ................ 13 Section 3.1 Set-asides or Quotas [26.43] .............................. 13 Section 3.2 Overall Goals [26.45] ................................... 13 Section 3.3 Failure to meet Overall Goals [26.47] ........................ 14 Section 3.4 Transit Vehicle Manufacturers Goals [26.49] ................... 14 Section 3.5 Breakout of Estimated Race-Neutral & Race-Conscious Participation [26.51 (a-c)] 14 Section 3.6 Contract Goals [26.51 (d-g)] .............................. 15 Page 702 of 2568 Page 3 of 39 Section 3.7 Good Faith Efforts Procedures [26.53] ....................... 15 3.7.1. Award of Contracts with a DBE Contract Goal: 26.53(a) .............. 15 3.7.2. Evaluation of Good Faith Efforts: 26.53 (a) & (c) ................... 16 3.7.3. Information to be Submitted: 26.53 (b) .......................... 16 3.7.4 Administrative reconsideration [26.53(d)] ........................ 17 3.7.5 Good Faith Efforts when a DBE is terminated or substituted on a contract [26.53(f)] .................................................... 17 Section 3.8 Counting DBE Participation [26.55] ......................... 18 4.0 CERTIFICATION STANDARDS [26.61 – 26.73] .................... 18 5.0 CERTIFICATION PROCEDURES [26.81] ......................... 19 6.0 DENIAL OF DBE STATUS AND APPEALS [26.83 – 26.91] ............ 19 Section 7.1 Availability of records .................................. 19 Section 7.2 Confidentiality ....................................... 19 Section 7.3 Cooperation ......................................... 20 Section 7.4 Intimidation and retaliation ............................... 20 ATTACHMENTS .............................................. 21 Organizational Chart ............................................ 22 Overall DBE Goal Calculation ...................................... 26 Collier Area Transit DBE Vendor Process & Forms Including Good Faith Efforts (Forms 1 & 2) ....................................................... 27 DBE Monitoring and Enforcement Mechanisms .......................... 24 49 CFR Part 26 ................................................ 39 State of Florida UCP Agreement .................................... 35 Page 703 of 2568 Page 4 of 39 Collier County Board of County Commissioners Disadvantaged Business Enterprise Policy Statement The Collier County Board of County Commissioners (BCC) 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 BCC has received Federal financial assistance from the Department of Transportation, and as a condition of receiving this assistance, the BCC has signed an assurance that it will comply with 49 CFR Part 26. It is the policy of the BCC to ensure that DBEs are defined in part 26, have an equal opportunity to receive and participate in DOT–assisted contracts. It is also our policy: 1. To ensure nondiscrimination in the award and administration of DOT – assisted contracts; 2. To create a level playing field on which DBEs can compete fairly for DOT-assisted contracts; 3. To ensure that the DBE Program is narrowly tailored in accordance with applicable law; 4. To ensure that only firms that fully meet 49 CFR Part 26 eligibility standards are permitted to participate as DBEs; 5. To help remove barriers to the participation of DBEs in DOT assisted contracts; 6. To assist the development of firms that can compete successfully in the market place outside the DBE Program. Omar De Leon, Public Transit Manager has been delegated as the DBE Liaison Officer. In that capacity, Mr. De Leon 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 BCC in its financial assistance agreements with the Department of Transportation. By placing this item on a regularly scheduled BCC agenda, Mr. De Leon has disseminated this policy statement to the BCC and all of 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 as an attachment to each contract. The signed program statement will be posted on the Collier County website www.colliergov.net ______________________________ ________________ Trinity Scott Date Chief Executive Officer Page 704 of 2568 Page 5 of 39 1. GENERAL REQUIREMENTS Section 1.1 Objectives [26.1] It is the policy of the Collier County Board of County Commissioners (BCC) to ensure that Disadvantaged Business Enterprises (DBE)s are defined in part 26, have an equal opportunity to receive and participate in Department of Transportation (DOT)–assisted contracts. It is also our policy: 1. To ensure nondiscrimination in the award and administration of DOT – assisted contracts; 2. To create a level playing field on which DBEs can compete fairly for DOT-assisted contracts; 3. To ensure that the DBE Program is narrowly tailored in accordance with applicable law; 4. To ensure that only firms that fully meet 49 CFR Part 26 eligibility standards are permitted to participate as DBEs; 5. To help remove barriers to the participation of DBEs in DOT assisted contracts; 6. To assist the development of firms that can compete successfully in the market place outside the DBE Program. Section 1.2 Applicability [26.3] The BCC is the recipient of federal transit funds authorized by Titles I, III, V, and VI of ISTEA, Pub. L. 102-240 or by Federal transit laws in Title 49, U.S. Code, or Titles I, II, and V of the Teas- 21, Pub. L. 105-178 and as a condition of receiving this financial assistance, the BCC has signed an assurance that it will comply with 49 Code of Federal Regulations (CFR) Part 26. In accordance with these regulations, the BCC has established a DBE Program. Section 1.3 Definitions [26.5] The BCC will adopt the definitions contained in Section 26.5 of 49 CFR Part 26 for this program. Section 1.4 Non-discrimination Requirements [26.1 & 26.7] The BCC 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 BCC 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. Section 1.5 Record Keeping Requirements [26.11] Page 705 of 2568 Page 6 of 39 The BCC will report DBE participation on a quarterly basis, using DOT Form 4630. These reports will reflect payments actually made to DBEs on DOT-assisted contracts. Section 1.6 Bidders List [26.11] The BCC approved an agreement with DOT and the Florida Department of Transportation (FDOT) that establishes the BCC as a non-certifying member of the national Unified DBE Certification Program (UCP) in September 2005. The BCC maintains 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 bidder’s list approach to calculating overall goals. The bidder’s list will include the name, address, and other relevant contact information about the firm. However, it does not collect annual gross receipts information of firms. Such information is collected by certifying members of the National Unified Certification Program (UCP). Attachment 6 includes a copy of the UCP Agreement executed by the Collier County Board of County Commissioners. FDOT’s website provides a list of UCP agencies that provide certification services and non- certification services in the State of Florida. http://www.dot.state.fl.us/equalopportunityoffice/DBECertification/UCP%20CERTIFYING%20 ADDRESSES.pdf The BCC will create a listing of offerors by requiring offerors to report the required information, for their firm, and all firms who quote to them on subcontracts, by issuing a requirement that will be placed in all federally funded solicitations. Section 1.7 Federal Financial Assistance Agreement [26.13] The BCC has signed the following assurances, applicable to all DOT-assisted contracts and their administration: 1.7.1 Assurance The BCC 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 BCC of its failure to carry out its approved program, the Department may impose sanction 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.). Page 706 of 2568 Page 7 of 39 This language will appear in financial assistance agreements with sub-recipients. 1.7.2 Contract Assurance In each DOT-assisted contract, the following language will be utilized: 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. 2. ADMINISTRATIVE REQUIREMENTS Section 2.1 DBE Program Updates [26.21] Since the BCC has received a grant $250,000 or more in FTA planning capital, and or operating assistance in a federal fiscal year, this program will be carried out until all funds from DOT financial assistance have been expended. Updates representing significant changes in the program will be provided to Federal Transit Administration (FTA). Section 2.2 Policy Statement [26.23] The BCC will issue a signed and dated policy statement that expresses its commitment to the DBE program, states its objectives, and outlines responsibilities for its implantation. The statement will be circulated throughout the organization and to the DBE and non-DBE business communities that work on BCC DOT-assisted contracts. The policy statement is found on page 4 of this program document. Section 2.3 DBE Liaison Officer (DBELO) [26.25] We have designated the following individual as our DBE Liaison Officer: Omar De Leon , Public Transit Manager Collier County Public Transit & Neighborhood Enhancement Division 8300 Radio Rd Naples, Florida 34104 (239) 252-4996 Omardeleon@colliercountyfl.gov In that capacity, the DBELO is responsible for implementing all aspects of the DBE program and ensuring that the BCC complies with all provision of 49 CFR Part 26. The DBELO has direct, independent access to the Collie County Board of County Commission Chair concerning DBE Page 707 of 2568 Page 8 of 39 program matters. 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. The DBELO has a staff of two to assist in the administration of the program. The duties and responsibilities include the following: 1. Gathers and reports statistical data and other information as required by DOT. 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 attainment and identifies ways to improve progress. 6. Analyzes BCC’s progress toward attainment and identifies ways to improve progress. 7. Participates in pre-bid meetings. 8. Advises the CEO\governing body on DBE matters and achievement. 9. Provides DBEs with information and assistance in preparing bids, obtaining bonding and insurance. 10. Plans and participates in DBE training seminars. 11. Acts as liaison to the Uniform Certification Process in Florida. 12. Provides outreach to DBEs and community organizations to advise them of opportunities. 13. Maintains the BCC’s updated directory on certified DBEs. Section 2.4 DBE Financial Institutions [26.27] It is the policy of the BCC 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 contract to make use of these institutions. Notification of solicitations for financial services will be sent to the institutions identified in the United States Department of Treasury, Financial Management Services Division, Minority Bank Deposit Program (MBDP) listings of financial institutions in the State of Florida. The availability of such institutions can be obtained at the U.S. Department of Treasure website http://www.fms.treas.gov/mbdp/current_list.html. The BCC has reviewed FDOT’s website DBE Directory and has determined there are no financial institutions owned and controlled by socially and economically disadvantaged individuals. This element will be re-evaluated at least every three years to coincide with the triennial goal setting process or when the Program is updated, whichever is earlier. Section 2.5 Prompt Payment Mechanisms [26.29] Prompt Payment: 26.29 (a) Page 708 of 2568 Page 9 of 39 The BCC will include the following clause in each DOT-assisted prime contract: The prime contractor agrees to pay each subcontractor under this prime contract for satisfactory performance of its contract no later than 30 days from the receipt of each payment the prime contract receives from the BCC. If retainage from DBE subcontractors is allowed per the contract, the prime contractor agrees further to return retainage payments to each subcontractor within 30 days after the subcontractors 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 BCC. This clause applies to both DBE and non- DBE subcontracts. Retainage: 26.29 (b) The prime contractor agrees to return retainage payments to each subcontractor within 30 days after the subcontractors work is satisfactorily completed. Any delay or postponement of payment from the above referenced times frame bay occur only for good cause following written approval of the BCC. This clause applies to both DBE and non-DBE subcontracts. Monitoring and Enforcement: 26.29(d) The BCC shall require in all DOT funded contracts language that allows it to monitor and enforce that prompt payment and return of retainage is in fact occurring on any contract which involves sub-contracting. The BCC will continue to require all prime contractors to report the DBE payments made to DBE subcontractors on all pay requests to monitor and enforce that prompt payment and return of retainage is in fact occurring. Failure of the Contractor to provide the DBE Participation Report may result in the invoice not being paid until the Contractor has provided the report. Further monitoring and enforcement is detailed in Section 2.9 and Attachment 3 of this document. Section 2.6 Directory [26.31] The BCC is required to participate in the Uniform Certification Program (UCP). The combined statewide directory, identifying all firms eligible to participate as a certified DBE, may be located at the Florida Department of Transportation website http://www.dot.state.fl.us/equalopportunityoffice/. The BCC utilizes the FDOT website DBE Directory. The directory lists the firm’s name, contact person, address, phone number, and the type of work the firm has been certified to perform as a DBE. The DBE Directory is updated in “real time“ and is the single source for establishing program eligibility. Section 2.7 Overconcentration [26.33] The BCC has not identified that overconcentration exists in the types of work that DBEs perform. This was determined based upon a review of feedback provided by DBE’s and non-DBE’s during attendance at trade fairs and vendor meetings. This element will be re-evaluated at least every three Page 709 of 2568 Page 10 of 39 years to coincide with the triennial goal setting process or when the Program is updated, whichever is earlier. If the BCC determines that there is an overconcentration in a certain type of work that unduly burdens the opportunity of non-DBE firms to participate in this type of work, appropriate measures will be developed and approved by the Federal Transit Administration to address this overconcentration. Section 2.8 Business Development Programs [26.35] The BCC has not established a formal business development program. We will re-evaluate the need for such a program every three years to coincide with the triennial goal setting process or when the Program is updated, whichever is earlier. While the BCC does not have a formal business development program, it does participate in the following activities designed to ensure that DBEs and Small Business Enterprises (SBEs) have the equal opportunity to participate in contracts: • Participate in training seminars and community outreach activities for the purpose of informing potential contractors of available business opportunities. • Email procurement advertisements to business that have been identified as certified DBEs and SBEs, which are likely to participate on the contract. • Attend trade fairs which include representatives which include representatives from these enterprises. • Encourage DBE and SBE attendance at solicitation conferences. Section 2.9 Monitoring and Enforcement Mechanisms [26.37] The BCC will take the following monitoring and enforcement mechanisms to ensure compliance with 49 CFR Part 26. 1. We 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. 2. We will consider similar action under our own legal authorities, including responsibility determinations in future contracts, removal of firms from the prequalified bidders and consultants’ lists or revocation of DBE certification if applicable, pursuant to Section 337.105; 337.16; and 339.0805, Florida Statutes. The regulation, provisions, and contract remedies available to in the events of non-compliance with the DBE regulation by a prime contractor include: actions for breach of contract; prosecution for any criminal activity or violation of County Code or Ordinance; enforcement of claims against any retainage, bond, surety or insurance provided by contractor or any subcontractor, legal action on any County cause of action created under the applicable provisions of state or federal law; revocation, cancellation or termination of the contract between the BCC and the prime contractor for the project; any other action permitted at law or in equity; or, any self-help measures that the BCC may lawfully undertake to rectify the default. Page 710 of 2568 Page 11 of 39 3. We will also provide a monitoring and enforcement mechanism to verify that work committed to DBEs at contract award is actually performed by the DBEs. This will be accomplished by: a. Requiring the Contractor, prior to undertaking work on the project, provide the BCC with an accurate list of all DBEs who are or who are anticipated to be subcontractors working on the project, which list shall include an accurate detailed description of all work to be done by each DBE. This list shall be updated any time there is a change in the DBEs working on the project or a change in the allocation of work between or among DBEs. b. BCC review of the DBE list provided by the prime contractor and confirm its accuracy. The BCC may request, and prime contractor shall provide, copies of any subcontracts or other contractual documentation between prime contractor and any subcontractors to confirm the scope of work for each. c. Requiring the prime contractor to notify the BCC of the dates/times when the DBEs are anticipated to be performing each contractual task related to the project, so that the BCC can verify DBE participation in the project, and can verify that the DBEs identified in the Contractor provided list are participating in the project. d. Requiring the prime contractor to identify each DBE receiving payment on all payment notifications required to be provided to the BCC. Any DBE receiving payment shall indicate its status as a DBE on its payment notifications. The prime contractor must provide a DBE Participation Report to the BCC with each invoice submitted to the BCC for payment. Failure of the Contractor to provide the DBE Participation Report may result in the invoice not being paid until the Contractor has provided the report. 4. We will keep a running tally of actual payments to DBE firms for work committed to them at the time of contract award. 5. The BCC will require prime contractors to maintain records and documents of payments to DBEs for three years following the performance of the contract. The records will be made available for inspection upon request by any authorized representative of the BCC or DOT. This reporting requirement also extends to any certified DBE subcontractor. 6. We will perform interim reviews of contract payments to DBEs. The review will examine payments to DBE subcontractors to ensure that the actual amount paid to DBE subcontractors equals or exceeds the dollar amounts states in the schedule of DBE participation. Section 2.10 Fostering Small Business Participation [26.39] The BCC has incorporated the following non-discriminatory elements to its DBE program, in order to facilitate completion on DOT-assisted public works projects by small business concerns (both DBEs and non-DBE small businesses): Small Business Program: Page 711 of 2568 Page 12 of 39 Definition – For the purpose of this section, a small business is defined as a firm that meets the definition as contained in 49 CFR Section 26.5 and Section 3 of the Small Business Act, 15 U.S.C. 631 et seq, which do not exceed the cap on average gross receipts specified in 49 CFR 26.65(b). Small Business Concern is one that: • Is organized for profit, with a place of business located in the United States, which operates primarily within the United States or which makes a significant contribution to the United States economy through payment of taxes or use of America products, materials or labor; • Has the legal form of an individual proprietorship, partnership, limited liability company, corporation, joint venture, association, trust or cooperative. • Is at least 51% owned and controlled by one or more individuals who are citizens of, or permanent resident aliens in, the Unit States, except in the case of a joint venture, where each entity to the venture must be 51% owned and controlled by one or more individuals who are citizens of, or permanent resident aliens in, the United States. A Small Business Concern shall not have average annual gross receipts (over the firm’s previous three fiscal years) in excess of $22.41 million. How to calculate average annual receipts and average employment of a firm can be found in 13 CFR 121.104 and 13 CFR 121.106, respectfully. Program participants will be required to establish eligibility via (1) DBE certification in connection with the Florida Unified Certification Program; (2) U.S. Small Business Administration (SBA) 8A certification, or (3) documentation establishing participation as a registered Dynamic Small Business with SBA. This documentation must be provided in the submittal package in order to verify eligibility. Certified DBEs are presumptively eligible to participate in the program. None of the provisions of this Section shall be interpreted to impose any geographic preferences or limitations, and the program is open to all small business concerns regardless of their location. As part of this program element, the BCC will include the following strategies to begin immediately following FTA approval of the DBE program: • Removal of unnecessary and unjustified bundling of contract requirements that may preclude SBE participation in procurements as prime contractors or subcontractors; and • Letting prime contracts of a size that small business can reasonably compete for and perform. • The BCC will include in its construction contract provisions a requirement that prime contractors affirmatively seek out small business as part of its subcontractor workforce. Prime contractors will be required to provide information with their bid that identifies the small businesses that will participate as subcontractors and the copes of work that will be undertaken. Lack of small business participation will require the bidder to provide evidence of the good faith efforts that were made. The good faith effort requirement will be the same as identified in Section 3.0 – Goals, Good Faith Efforts, and Counting. Page 712 of 2568 Page 13 of 39 • Procurement Services Division staff attendance at several annual trade fairs which include representatives from small businesses. • Attending meetings (local chamber of commerce) and social events where in small business are represented. 3.0 GOALS, GOOD FAITH EFFORTS, AND COUNTING Section 3.1 Set-asides or Quotas [26.43] The BCC does not use quotas in any way in the administration of this DBE program. Section 3.2 Overall Goals [26.45] A description of the methodology to calculate the overall goal and the goal calculations can be found in Attachment 4 to this program. The goal will be updated every three years based on the January 28, 2011, Federal Register. In accordance with Section 26.45(f) the BCC will submit its overall goal to FTA on August 1, 2013 and every three years thereafter. The BCC may adjust the three year overall goal during the three year period to which it applies, in order to reflect changed circumstances. The BCC will submit an adjustment to FTA for review and concurrence. The BCC will also request use of project specific DBE goals as appropriate, and/or will establish project specific DBE goals as directed by FTA. The process generally used by the BCC to establish overall DBE goals is to first develop a base figure for the relative availability of DBE’s. The relative availability of DBEs is the total number of ready, willing and able DBE firms in Collier County divided by the total number of all firms based on the US Census data. Once the base figure has been calculated, we must examine all of the evidence available to our area to determine what adjustment, if any, is needed to the base figure to arrive at the overall goal. Types of evidence to consider include current capacity of DBE’s to perform the work, disparity studies, input from interested parties. Before establishing the overall goal, the BCC will, at a minimum, consult with minority and general contractor’s groups, community organizations, and other officials or organizations to obtain information concerning the availability of disadvantaged and non-disadvantaged business, the effects of discrimination on opportunities for DBES, and the BCC’s efforts to establish a level playing field for the participation of DBE’s. Following this consultation, the BCC will publish a notice of the proposed overall goals, informing the public that the proposed goal and its rational are available for inspection during normal business hours at our principal office for 30 days following the date of the notice, and informing the public that the BCC and DOT will accept comments on the goals for 45 days from the date of the notice. The publishing of the notice of the proposed overall goal will be in a newspaper, or other media, of general circulation focused on minority readers. The notice will also be included on the BCC’s Internet website. Normally this notice will be issued by June 1. The notice must Page 713 of 2568 Page 14 of 39 include addresses to which comments may be sent and addresses (including offices and websites) where the proposal may be reviewed. The overall goal submission to DOT will include: the goal (including the breakout of estimated race-neutral and race-conscious participation, as appropriate); a copy of the methodology, worksheets, etc., used to develop the goal; a summary of information and comments received during this public participation process and the BCC’s responses; and proof of publication of the goal in media outlets listed above. The BCC will begin using our overall goal on October 1, unless the BCC has received other instructions from DOT. If the BCC establishes a goal on a project basis, the BCC will begin using our goal by the time of the first solicitation for a DOT-assisted contract for the project. Section 3.3 Failure to meet Overall Goals [26.47] If the BCC does not have an approved DBE Program or overall goal, or if the BCC fails to implement the program in good faith, the BCC is in noncompliance with its program and corrective action(s) must be documented. The analysis does not have to be transmitted to DOT. If the BCC fails to meet its overall goals in a given year, a determination of the reason(s) or unless the BCC is notified by DOT of the required analysis, the analysis and corrective action(s) will be retained for three years and it will be made available to the FTA upon request for their review. Section 3.4 Transit Vehicle Manufacturers Goals [26.49] The BCC will require each transit vehicle manufacturer, as a condition of being authorized to bid or propose on FTA-assisted transit vehicle procurements, to certify that it has complied with the requirements of this section. Alternatively, the BCC may, at its discretion and with FTA approval, establish project-specific goals for DBE participation in the procurement of transit vehicles in lieu of the TVM complying with this element of the program. Section 3.5 Breakout of Estimated Race-Neutral & Race-Conscious Participation [26.51 (a-c)] The breakout of estimated race-neutral and race-conscious participation can be found in Attachment 4 to this program. The BCC will meet the maximum feasible portion of its overall goal using race-neutral means of facilitating DBE participation. In order to do so, the BCC will: 1. Arrange solicitations, quantities, specifications, and delivery schedules in ways that facilitate DBE and other small business participation. 2. Provide technical assistance. 3. Carry out information and communication programs on contracting procedures and specific contract opportunities. This will include the utilization of directories and other reference sources that list DBEs ensuring the dissemination to bidders on prime contracts of lists of potential DBE subcontractors. Page 714 of 2568 Page 15 of 39 Section 3.6 Contract Goals [26.51 (d-g)] The BCC will use contract goals to meet any portion of the overall goal the BCC 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 BCC will establish contract goals only on those DOT-assisted contracts that have subcontracting possibilities. The BCC 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 BCC will express a contract goal as a percentage of total amounts of DOT-assisted contract. The BCC will arrange solicitations, times for the presentation of bids, quantities, specifications and delivery schedules in ways that facilitate participation by DBEs and other small business and by making contracts more accessible to small businesses, by means such as those provided in section 2.10 of this document. Below is a sample bid specification: The requirements of 49 CFR Part 26, Regulations of the U.S. Department of Transportation apply to this contract. It is the policy of the BCC to practice nondiscrimination based on race, color, sex, or national origin in the award or performance of this contract. All firms qualifying under this solicitation are encouraged to submit bids/proposals. Award of this contract will be conditioned upon satisfying the requirements of this bid specification. These requirements apply to all bidders/offerors, including those who qualify as a DBE. A DBE contract goal of ___ percent has been established for this contract. The bidder/offeror shall make good faith efforts, as defined in Appendix A, 49 CFR Part 26 (Attachment 1), to meet the contract goal for DBE participation in the performance of this contract. The bidder/offeror will be required to submit the following information: (1) the names and addresses of DBE firms that will participate in the contract; (2) a description of the work that each DBE firm will perform; (3) the dollar amount of the participation of each DBE firm participating; (4) Written documentation of the bidder/offeror’s commitment to use a DBE subcontractor whose participation it submits to meet the contract goal; (5) Written confirmation from the DBE that it is participating in the contract as provided in the commitment made under (4); and (5) if the contract goal is not met, evidence of good faith efforts. Section 3.7 Good Faith Efforts Procedures for contracts with DBE Contract Goals [26.53] 3.7.1. Award of Contracts with a DBE Contract Goal: 26.53(a) In those instances where a contract-specific DBE goal is included in a procurement/solicitation, the BCC will not award the contract to a bidder who does not either: (1) meet the contract goal Page 715 of 2568 Page 16 of 39 with verified, countable DBE participation; or (2) documents it has made adequate good faith efforts to meet the DBE contract goal, even though it was unable to do so. It is the obligation of the bidder to demonstrate it has made sufficient good faith efforts prior to submission of its bid. 3.7.2. Evaluation of Good Faith Efforts: 26.53 (a) & (c) The DBELO 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 responsive. The BCC evaluation of good faith efforts will be conducted in accordance with Appendix A to Part 26 – Guidance Concerning Good Faith Efforts. The processes used by the BCC to determine whether good faith efforts have been made by a bidder are as follows: 1. If bidder/offeror does not meet the established DBE goal, and is required to submit documentation of good faith effort, then a good faith efforts submission shall be provided within three business days from the bid/proposal submittal date, which shall include documentation that the bidder/proposer made a good faith effort to meet the goal. The BCC may allow a longer period based on submittal of a request demonstrating good cause for such extension. Good faith efforts at a minimum include, the following items (where applicable): a. Attendance at the pre-bid meeting; b. Advertisement in trade association newsletters and minority-focused media within a reasonable time before bids are due for specific sub-bids that would be at least equal to the percent goal for DBE utilization specified for the project. c. Notifications in writing to minority contractor associations within a reasonable time before bids are due of a solicitation for specific sub-bids. d. Direct negotiation with DBEs for specific sub-bids. The BCC will ensure that all information is complete and accurate and adequately documents the bidder/offer’s good faith efforts before the BCC commits to the performance of the contract by the bidder/offeror. 3.7.3. Information to be Submitted: 26.53 (b) The BCC treat bidders/offers’ compliance with good faith efforts’ requirements as a matter of responsiveness. 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; Page 716 of 2568 Page 17 of 39 • A description of the work that each DBE will perform; • The dollar amount of the participation of each DBE firm participating; • 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 contractors commitment and • If the contract goal is not met, evidence of good faith efforts. 3.7.4 Administrative reconsideration [26.53(d)] Within 5 days of being informed by BCC 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: Joanne Markiewicz, Procurement Services Division Director, Procurement Services Division, 3327 East Tamiami Trail, Naples, Florida 34112, (239) 252-8975 or joannemarkiewicz@colliergov.net. 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 do so. The bidder/offeror will have the opportunity to meet in person with our reconsideration official to discuss the issue of whether it met the goal or made adequate good faith efforts to do. We 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. 3.7.5 Good Faith Efforts when a DBE is terminated or substituted on a contract [26.53(f)] The BCC requires that prime contractors not terminate a DBE subcontractor listed on a bid/contract with a DBE contract goal with the BCC‘s prior written consent. Prior written consent will only be provided where there is “good cause” for termination of the DBE firm, as established by Section 26.53(f)(3) of the DBE regulation. Before transmitting to the BCC its request to terminate, the prime contractor must give notice in writing to the DBE of its intent to do so. A copy of this notice must be provided to the BCC prior to consideration of the request to terminate. The DBE will then have five (5) days to respond and advise the BCC of why it objects to the proposed termination. In those instances where “good cause” exists to terminate a DBE’s contract, the BCC will require the prime 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 Page 717 of 2568 Page 18 of 39 the extent needed to meet the contract goal. The BCC will require the prime contractor to notify the DBE Liaison officer immediately of the DBE’s inability or unwillingness to perform and provide reasonable documentation. In this situation, the BCC will require the prime contractor to obtain our 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, our 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. Section 3.8 Counting DBE Participation [26.55] The BCC will count DBE participation toward overall and contract goals as provided in 49 CFR 26.55. Only the value of the work actually performed by the DBE will count toward DBE goals. Such value will be counted as follows: • The entire amount that is performed by the DBE; • The entire amount of reasonable fees or commissions charged by a DBE firm for providing a bona fide service or for providing bonds or insurance required for the performance of the DOT-assisted contract; • The value of work subcontracted by a DBE to another DBE is counted toward DBE goals. • When a DBE performs as part of a joint venture, the portion of the total dollar value of the contract equal to the defined portion of the work of the contract that the DBE performs will be counted. • Expenditures to a DBE contractor will be counted toward DBE goals only if the DBE is performing a commercially useful function on that contract as set forth in 49 CFR Part 26.55[c] [1-5]. For determining whether a trucking company is performing a commercially useful function, Collier County will refer to 49 CFR Part 26.55[d] (1-6]. • For establishing whether expenditures for materials or supplies count toward DBE goals, Collier County will refer to 49 CFR Part 26.55[e]. • A DBE’s participation will not be counted toward DBE goals of the prime contractor or the BCC’s overall goal until the DBE is paid. 4.0 CERTIFICATION STANDARDS [26.61 – 26.73] The BCC is a non-certifying member of the Unified Certification Program (UCP) in the State of Florida. All firms must apply through the UCP to be certified in the State of Florida. The local certifying agency in the southwest Florida area is the Lee County Port Authority located at the Southwest Florida International Airport. The BCC will use the DBE directory administered by the Florida Department of Transportation and listed on the UCP website to verify if a firm is DBE certified by the Florida UCP. Page 718 of 2568 Page 19 of 39 The Florida UCP certifies DBEs in accordance to the Federal Regulations. An Annual Meeting of the Florida UCP is scheduled for all members to attend and discuss any issues or needed changes to the UCP Program 5.0 CERTIFICATION PROCEDURES [26.81] The BCC is a non-certifying member of a Unified Certification Program (UCP) administered by Florida Department of Transportation Equal Opportunity Office, 605 Suwannee Street, MS 65, Tallahassee, Florida 32399-0450. The EEO Office can be contacted by telephone: (850) 414- 4747, fax: (850) 414-4879, and website at www.dot.state.fl.us/equalopportunityoffice/DBEProgram. The Florida UPC will meet all of the requirements of certification procedures. 6.0 DENIAL OF DBE STATUS AND APPEALS [26.83 – 26.91] Any firm or complainant may appeal our 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 Street, SW Room 2104 Washington, D.C. 20590 7.0 INFORMATION, CONFIDENTIALITY, COOPERATION [26.109] Section 7.1 Availability of records The BCC will safeguard from disclose to third parties information that may reasonably regarded as confidential business information, consistent federal, state, and local law. In responding to requests for information concerning any aspect of the DBE program, the BCC complies with provisions of the Federal Freedom of Information and Privacy Acts (5 U.S.C. 552 and 552a). The BCC may make available to the public any information concerning the DBE program release of which is not prohibited by Federal law. Section 7.2 Confidentiality Notwithstanding any contrary provisions, the BCC 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 firm that submitted the information. Notwithstanding the provisions 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 Page 719 of 2568 Page 20 of 39 that, in some circumstances, failure to waive the privilege may result in the closure of the investigation or dismissal of the proceeding or hearing. Section 7.3 Cooperation The BCC will require prime contractors to maintain records and documents of payments to DBE’s 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 BCC or DOT. This reporting requirement also extends to any certified DBE subcontractor. The BCC will 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. 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. Section 7.4 Intimidation and retaliation The BCC will not and will not allow a contractor, or any other participant in the program, to 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. Page 720 of 2568 Page 21 of 39 ATTACHMENTS Page 721 of 2568 Page 22 of 39 Attachment 1 Organizational Chart Burt L. Saunders BCC Chairman Amy Patterson County Manager Trinity Scott TMS Department Head Brian Wells Public Transit & Neighborhood Enhancement Division Director Omar De Leon Public Transit Manager DBELO Corene Sanger Management Analyst I Alexander Showalter Planner II Liz Soriano Project Manager II Elena Ortiz Rosado Program Coordinator Reporting Relationship for DBE Matters Page 722 of 2568 Page 23 of 39 Attachment 2 DBE Directory The BCC does not certify DBEs but rather uses the list of DBEs identified in the Florida Department of Transportation (FDOT) Uniform Certification Program (UCP) Directory. The DBE directory can be found at: https://fdotxwp02.dot.state.fl.us/EqualOpportunityOfficeBusinessDirectory/Home.aspx What is the Florida UCP DBE Directory? The Florida Unified Certification Program Disadvantaged Business Enterprise (UCP DBE) is a searchable listing of all certified Disadvantaged Business Enterprise (DBE) and Airport Concession Disadvantaged Business Enterprise (ACDBE) firms eligible to perform work under the federal DBE Program. The Florida UCP DBE Directory is updated daily and includes information pertaining to the firm’s certification status, including its assigned North American Industry Classification System (NAICS) codes, available work locations and contact information. Advanced search options allow users a means to customize searches, filter items, and sort results based on specific needs. The Florida UCP DBE Directory makes extensive use of the following acronyms/terms. How do I use this directory? The Florida UCP DBE Directory is published to help contractors and consultants identify subcontractors and subconsultants eligible to participate on federally funded contracts towards the attainment of DBE goals. • All certified DBE and ACDBE firms listed in this directory have been approved under the eligibility standards and guidelines set forth in the Title 49 Code of Federal Regulations Parts 23 and 26. • It is the contractor/consultant’s responsibility to evaluate the DBE’s ability to perform on any given project. Most popular browsers will view this site without issue. However the suggested browser is the latest version of Internet Explorer. Page 723 of 2568 Page 24 of 39 Attachment 3 DBE Monitoring and Enforcement Mechanisms In the event that a DBE goal has been established by the Solicitation the prime contractor covenants and agrees as follows: 1. The BCC requires that prime contractors not terminate a DBE subcontractor listed on a bid/contract with a DBE contract goal without the BCC’s prior written consent. Prior written consent shall be provided where there is “good cause” for termination of the DBE firm, as established by Section 26.53(f)(3) of the DBE regulation. Before transmitting to the BCC its request to terminate, the prime contractor shall give notice in writing to the DBE of its intent to do so. A copy of this notice shall be provided to the BCC prior to consideration of the request to terminate. The DBE shall have five (5) days to respond and advise the BCC why it objects to the proposed termination. The five day period may be reduced if the matter is one of public necessity, e.g., safety. 2. In those instances where “good cause” exists to terminate a DBEs contract, the BCC requires the prime 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 contract shall notify the BCC immediately of the DBE’s inability or unwillingness to perform and provide reasonable documentation. 3. The BCC requires the prime contractor to obtain the BCC 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 BCC may issue an order stopping all or part of payment/work until satisfactory action has been taken. If the contractor still fails to comply, the BCC may issue a termination for default proceeding. 4. The prime contractor shall provide the DBE Liaison Officer with at least thirty (30) days written notice prior to instituting any legal action against a DBE subcontractor. 5. The prime contractor shall provide the DBE Liaison Officer with monthly updates as to the prime contractor’s continuing compliance with the DBE requirements set forth in the Solicitation. The prime contract shall submit with each invoice a report of DBE expenditures. Such report must show each DBE, the amount of such DBE’s subcontract, the amount earned to date, the amount earned with respect to that invoice and the amount remaining to be earned. Page 724 of 2568 Page 25 of 39 6. The prime contractor shall make prompt and full payment to any DBE subcontractor (including the payment of any retainage) within the later of: a. Thirty (30) days after the DBE subcontractor’s work is satisfactorily completed, or b. Thirty (30) days after the prime contractor receives payment from the BCC for satisfactory completion of the accepted work. The BCC will bring to the attention of the USDOT any false, fraudulent, or dishonest conduct in connection with the program, so the USDOT can take the steps (e.g., referral to the Department of Justice for criminal prosecution, referral to the USDOT Inspector General, action under suspension and debarment of Program Fraud and Civil Penalties rules) provided in Section 26.109. These may include: 1. Suspension or debarment proceedings pursuant to 49 CFR part 26. 2. Enforcement action pursuant to 49 CFR part 31. 3. Prosecution pursuant to 18 USC 1001. The BCC will also consider similar action under state legal authorities, including responsibility determinations in future contracts, removal of firms from the prequalified bidders and consultants’ lists or revocation of DBE certification if applicable, pursuant to Section 337.105; 337.16; and 339.0808, Florida Statutes. Page 725 of 2568 Page 26 of 39 Attachment 4 Overall DBE Goal Calculation & Section 26.51: Breakout of Estimated Page 726 of 2568 Page 27 of 39 Attachment 5 Collier Area Transit DBE Vendor Process & Forms Including Good Faith Efforts (Forms 1 & 2) Page 727 of 2568 Page 28 of 39 Page 728 of 2568 Page 29 of 39 Page 729 of 2568 Page 30 of 39 Page 730 of 2568 Page 31 of 39 Page 731 of 2568 Page 32 of 39 Page 732 of 2568 Page 33 of 39 Demonstration of Good Faith Efforts (Forms 1 and 2 should be provided as part of the solicitation documents) FORM 1: DISADVANTAGED BUSINESS ENTERPRISE (DBE) UTILIZATION The undersigned bidder/offeror has satisfied the requirements of the bid specification in the following manner (please check the appropriate space): ________The bidder/offeror is committed to a minimum of _____ % DBE utilization on this contract. ________The bidder/offeror (if unable to meet the DBE goal of _____ %) is committed to a minimum of ______ % DBE utilization on this contract a submits documentation demonstrative good faith efforts. Name of bidder’s/offeror’s firm: ____________________________________________ State Registration No. _____________________________ Date: __________________________________________ By: ___________________________________________________________________ Print Name By: ___________________________________________________________________ Signature _______________________________________________________________________ Title Page 733 of 2568 Page 34 of 39 Demonstration of Good Faith Efforts (Forms 1 and 2 should be provided as part of the solicitation documents) FORM 2: LETTER OF INTENT Name of bidder’s/offeror’s firm: __________________________________________ Address: _____________________________________________________________ City: _________________________ State: ________ Zip: ______________ Name of DBE firm: ____________________________________________________ Address: _____________________________________________________________ City: _________________________ State: ________ Zip: ______________ Telephone: ________________________ Description of work to be performed by DBE firm: The bidder/offeror is committed to utilizing the above-name DBE firm for the work described above. The estimated dollar value of this work is $ ____________. Affirmation The above-named DBE firm affirms that it will perform the portion of the contract for the estimated dollar value as stated above. By _________________________________________________________________ Signature Title Page 734 of 2568 Page 35 of 39 If the bidder/offeror does not receive award of the prime contract, any and all representations in this Letter of Intent and Affirmation shall be null and void. (Please submit this page for each subcontractor) Attachment 6 State of Florida UCP Agreement Page 735 of 2568 Page 36 of 39 Page 736 of 2568 Page 37 of 39 Page 737 of 2568 Page 38 of 39 Page 738 of 2568 Page 39 of 39 Attachment 7 49 CFR Part 26 The text of 49 CFR Part 26 can be found at the link: https://www.ecfr.gov/cgi-bin/text- idx?c=ecfr&SID=4195360ce4431b02f1bc643ea0a6e638&rgn=div5&view=text&node=49:1.0.1. 1.20&idno=49 Page 739 of 2568 COLLIER COUNTY BOARD OF COUNTY COMMISSIONERS Collier Area Transit Disadvantaged Business Enterprise Program 2/25/2025 Page 740 of 2568 Page 2 of 39 Table of Contents Collier County Board of County Commissioners Disadvantaged Business Enterprise Policy Statement .....................................................4 1. GENERAL REQUIREMENTS ...................................5 Section 1.1 Objectives [26.1].......................................5 Section 1.2 Applicability [26.3]......................................5 Section 1.3 Definitions [26.5].......................................5 Section 1.4 Non-discrimination Requirements [26.1 & 26.7]...................5 Section 1.5 Record Keeping Requirements [26.11].........................5 Section 1.6 Bidders List [26.11]......................................6 Section 1.7 Federal Financial Assistance Agreement [26.13]...................6 2. ADMINISTRATIVE REQUIREMENTS ............................7 Section 2.1 DBE Program Updates [26.21]..............................7 Section 2.2 Policy Statement [26.23]..................................7 Section 2.3 DBE Liaison Officer (DBELO) [26.25].........................7 Section 2.4 DBE Financial Institutions [26.27]............................8 Section 2.5 Prompt Payment Mechanisms [26.29]..........................8 Section 2.6 Directory [26.31].......................................9 Section 2.7 Overconcentration [26.33].................................9 Section 2.8 Business Development Programs [26.35].......................10 Section 2.9 Monitoring and Enforcement Mechanisms [26.37].................10 Section 2.10 Fostering Small Business Participation [26.39]..................11 3.0 GOALS, GOOD FAITH EFFORTS, AND COUNTING .................13 Section 3.1 Set-asides or Quotas [26.43]...............................13 Section 3.2 Overall Goals [26.45]...................................13 Section 3.3 Failure to meet Overall Goals [26.47].........................14 Section 3.4 Transit Vehicle Manufacturers Goals [26.49]....................14 Section 3.5 Breakout of Estimated Race-Neutral & Race-Conscious Participation [26.51 (a-c)]14 Section 3.6 Contract Goals [26.51 (d-g)]...............................15 Page 741 of 2568 Page 3 of 39 Section 3.7 Good Faith Efforts Procedures [26.53]........................15 3.7.1. Award of Contracts with a DBE Contract Goal: 26.53(a)...............15 3.7.2. Evaluation of Good Faith Efforts: 26.53 (a) & (c)....................16 3.7.3. Information to be Submitted: 26.53 (b)...........................16 3.7.4 Administrative reconsideration [26.53(d)].........................17 3.7.5 Good Faith Efforts when a DBE is terminated or substituted on a contract [26.53(f)].....................................................17 Section 3.8 Counting DBE Participation [26.55]..........................18 4.0 CERTIFICATION STANDARDS [26.61 – 26.73].....................18 5.0 CERTIFICATION PROCEDURES [26.81]..........................19 6.0 DENIAL OF DBE STATUS AND APPEALS [26.83 – 26.91].............19 Section 7.1 Availability of records ...................................19 Section 7.2 Confidentiality ........................................19 Section 7.3 Cooperation ..........................................20 Section 7.4 Intimidation and retaliation ................................20 ATTACHMENTS ...............................................21 Organizational Chart .............................................22 Overall DBE Goal Calculation .......................................26 Collier Area Transit DBE Vendor Process & Forms Including Good Faith Efforts (Forms 1 & 2)........................................................27 DBE Monitoring and Enforcement Mechanisms ...........................24 49 CFR Part 26 .................................................38 State of Florida UCP Agreement .....................................35 Page 742 of 2568 Page 4 of 39 Collier County Board of County Commissioners Disadvantaged Business Enterprise Policy Statement The Collier County Board of County Commissioners (BCC) 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 BCC has received Federal financial assistance from the Department of Transportation, and as a condition of receiving this assistance, the BCC has signed an assurance that it will comply with 49 CFR Part 26. It is the policy of the BCC to ensure that DBEs are defined in part 26, have an equal opportunity to receive and participate in DOT–assisted contracts. It is also our policy: 1. To ensure nondiscrimination in the award and administration of DOT – assisted contracts; 2. To create a level playing field on which DBEs can compete fairly for DOT-assisted contracts; 3. To ensure that the DBE Program is narrowly tailored in accordance with applicable law; 4. To ensure that only firms that fully meet 49 CFR Part 26 eligibility standards are permitted to participate as DBEs; 5. To help remove barriers to the participation of DBEs in DOT assisted contracts; 6. To assist the development of firms that can compete successfully in the market place outside the DBE Program. Omar De Leon, Public Transit Manager has been delegated as the DBE Liaison Officer. In that capacity, Mr. De Leon 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 BCC in its financial assistance agreements with the Department of Transportation. By placing this item on a regularly scheduled BCC agenda, Mr. De Leon has disseminated this policy statement to the BCC and all of 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 as an attachment to each contract. The signed program statement will be posted on the Collier County website www.colliergov.net ______________________________ ________________ Trinity Scott Date Chief Executive Officer Page 743 of 2568 Page 5 of 39 1. GENERAL REQUIREMENTS Section 1.1 Objectives [26.1] It is the policy of the Collier County Board of County Commissioners (BCC) to ensure that Disadvantaged Business Enterprises (DBE)s are defined in part 26, have an equal opportunity to receive and participate in Department of Transportation (DOT)–assisted contracts. It is also our policy: 1. To ensure nondiscrimination in the award and administration of DOT – assisted contracts; 2. To create a level playing field on which DBEs can compete fairly for DOT-assisted contracts; 3. To ensure that the DBE Program is narrowly tailored in accordance with applicable law; 4. To ensure that only firms that fully meet 49 CFR Part 26 eligibility standards are permitted to participate as DBEs; 5. To help remove barriers to the participation of DBEs in DOT assisted contracts; 6. To assist the development of firms that can compete successfully in the market place outside the DBE Program. Section 1.2 Applicability [26.3] The BCC is the recipient of federal transit funds authorized by Titles I, III, V, and VI of ISTEA, Pub. L. 102-240 or by Federal transit laws in Title 49, U.S. Code, or Titles I, II, and V of the Teas- 21, Pub. L. 105-178 and as a condition of receiving this financial assistance, the BCC has signed an assurance that it will comply with 49 Code of Federal Regulations (CFR) Part 26. In accordance with these regulations, the BCC has established a DBE Program. Section 1.3 Definitions [26.5] The BCC will adopt the definitions contained in Section 26.5 of 49 CFR Part 26 for this program. Section 1.4 Non-discrimination Requirements [26.1 & 26.7] The BCC 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 BCC 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. Section 1.5 Record Keeping Requirements [26.11] Page 744 of 2568 Page 6 of 39 The BCC will report DBE participation on a quarterly basis, using DOT Form 4630. These reports will reflect payments actually made to DBEs on DOT-assisted contracts. Section 1.6 Bidders List [26.11] The BCC approved an agreement with DOT and the Florida Department of Transportation (FDOT) that establishes the BCC as a non-certifying member of the national Unified DBE Certification Program (UCP) in September 2005. The BCC maintains 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 bidder’s list approach to calculating overall goals. The bidder’s list will include the name, address, and other relevant contact information about the firm. However, it does not collect annual gross receipts information of firms. Such information is collected by certifying members of the National Unified Certification Program (UCP). Attachment 6 includes a copy of the UCP Agreement executed by the Collier County Board of County Commissioners. FDOT’s website provides a list of UCP agencies that provide certification services and non- certification services in the State of Florida. http://www.dot.state.fl.us/equalopportunityoffice/DBECertification/UCP%20CERTIFYING%20 ADDRESSES.pdf The BCC will create a listing of offerors by requiring offerors to report the required information, for their firm, and all firms who quote to them on subcontracts, by issuing a requirement that will be placed in all federally funded solicitations. Section 1.7 Federal Financial Assistance Agreement [26.13] The BCC has signed the following assurances, applicable to all DOT-assisted contracts and their administration: 1.7.1 Assurance The BCC 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 BCC of its failure to carry out its approved program, the Department may impose sanction 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.). Page 745 of 2568 Page 7 of 39 This language will appear in financial assistance agreements with sub-recipients. 1.7.2 Contract Assurance In each DOT-assisted contract, the following language will be utilized: 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. 2. ADMINISTRATIVE REQUIREMENTS Section 2.1 DBE Program Updates [26.21] Since the BCC has received a grant $250,000 or more in FTA planning capital, and or operating assistance in a federal fiscal year, this program will be carried out until all funds from DOT financial assistance have been expended. Updates representing significant changes in the program will be provided to Federal Transit Administration (FTA). Section 2.2 Policy Statement [26.23] The BCC will issue a signed and dated policy statement that expresses its commitment to the DBE program, states its objectives, and outlines responsibilities for its implantation. The statement will be circulated throughout the organization and to the DBE and non-DBE business communities that work on BCC DOT-assisted contracts. The policy statement is found on page 4 of this program document. Section 2.3 DBE Liaison Officer (DBELO) [26.25] We have designated the following individual as our DBE Liaison Officer: Omar De Leon , Public Transit Manager Collier County Public Transit & Neighborhood Enhancement Division 8300 Radio Rd Naples, Florida 34104 (239) 252-4996 Omardeleon@colliercountyfl.gov In that capacity, the DBELO is responsible for implementing all aspects of the DBE program and ensuring that the BCC complies with all provision of 49 CFR Part 26. The DBELO has direct, independent access to the Collie County Board of County Commission Chair concerning DBE Page 746 of 2568 Page 8 of 39 program matters. 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. The DBELO has a staff of two to assist in the administration of the program. The duties and responsibilities include the following: 1. Gathers and reports statistical data and other information as required by DOT. 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 attainment and identifies ways to improve progress. 6. Analyzes BCC’s progress toward attainment and identifies ways to improve progress. 7. Participates in pre-bid meetings. 8. Advises the CEO\governing body on DBE matters and achievement. 9. Provides DBEs with information and assistance in preparing bids, obtaining bonding and insurance. 10. Plans and participates in DBE training seminars. 11. Acts as liaison to the Uniform Certification Process in Florida. 12. Provides outreach to DBEs and community organizations to advise them of opportunities. 13. Maintains the BCC’s updated directory on certified DBEs. Section 2.4 DBE Financial Institutions [26.27] It is the policy of the BCC 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 contract to make use of these institutions. Notification of solicitations for financial services will be sent to the institutions identified in the United States Department of Treasury, Financial Management Services Division, Minority Bank Deposit Program (MBDP) listings of financial institutions in the State of Florida. The availability of such institutions can be obtained at the U.S. Department of Treasure website http://www.fms.treas.gov/mbdp/current_list.html. The BCC has reviewed FDOT’s website DBE Directory and has determined there are no financial institutions owned and controlled by socially and economically disadvantaged individuals. This element will be re-evaluated at least every three years to coincide with the triennial goal setting process or when the Program is updated, whichever is earlier. Section 2.5 Prompt Payment Mechanisms [26.29] Prompt Payment: 26.29 (a) Page 747 of 2568 Page 9 of 39 The BCC will include the following clause in each DOT-assisted prime contract: The prime contractor agrees to pay each subcontractor under this prime contract for satisfactory performance of its contract no later than 30 days from the receipt of each payment the prime contract receives from the BCC. If retainage from DBE subcontractors is allowed per the contract, the prime contractor agrees further to return retainage payments to each subcontractor within 30 days after the subcontractors 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 BCC. This clause applies to both DBE and non- DBE subcontracts. Retainage: 26.29 (b) The prime contractor agrees to return retainage payments to each subcontractor within 30 days after the subcontractors work is satisfactorily completed. Any delay or postponement of payment from the above referenced times frame bay occur only for good cause following written approval of the BCC. This clause applies to both DBE and non-DBE subcontracts. Monitoring and Enforcement: 26.29(d) The BCC shall require in all DOT funded contracts language that allows it to monitor and enforce that prompt payment and return of retainage is in fact occurring on any contract which involves sub-contracting. The BCC will continue to require all prime contractors to report the DBE payments made to DBE subcontractors on all pay requests to monitor and enforce that prompt payment and return of retainage is in fact occurring. Failure of the Contractor to provide the DBE Participation Report may result in the invoice not being paid until the Contractor has provided the report. Further monitoring and enforcement is detailed in Section 2.9 and Attachment 3 of this document. Section 2.6 Directory [26.31] The BCC is required to participate in the Uniform Certification Program (UCP). The combined statewide directory, identifying all firms eligible to participate as a certified DBE, may be located at the Florida Department of Transportation website http://www.dot.state.fl.us/equalopportunityoffice/. The BCC utilizes the FDOT website DBE Directory. The directory lists the firm’s name, contact person, address, phone number, and the type of work the firm has been certified to perform as a DBE. The DBE Directory is updated in “real time“ and is the single source for establishing program eligibility. Section 2.7 Overconcentration [26.33] The BCC has not identified that overconcentration exists in the types of work that DBEs perform. This was determined based upon a review of feedback provided by DBE’s and non-DBE’s during attendance at trade fairs and vendor meetings. This element will be re-evaluated at least every three Page 748 of 2568 Page 10 of 39 years to coincide with the triennial goal setting process or when the Program is updated, whichever is earlier. If the BCC determines that there is an overconcentration in a certain type of work that unduly burdens the opportunity of non-DBE firms to participate in this type of work, appropriate measures will be developed and approved by the Federal Transit Administration to address this overconcentration. Section 2.8 Business Development Programs [26.35] The BCC has not established a formal business development program. We will re-evaluate the need for such a program every three years to coincide with the triennial goal setting process or when the Program is updated, whichever is earlier. While the BCC does not have a formal business development program, it does participate in the following activities designed to ensure that DBEs and Small Business Enterprises (SBEs) have the equal opportunity to participate in contracts: •Participate in training seminars and community outreach activities for the purpose of informing potential contractors of available business opportunities. •Email procurement advertisements to business that have been identified as certified DBEs and SBEs, which are likely to participate on the contract. •Attend trade fairs which include representatives which include representatives from these enterprises. •Encourage DBE and SBE attendance at solicitation conferences. Section 2.9 Monitoring and Enforcement Mechanisms [26.37] The BCC will take the following monitoring and enforcement mechanisms to ensure compliance with 49 CFR Part 26. 1. We 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. 2. We will consider similar action under our own legal authorities, including responsibility determinations in future contracts, removal of firms from the prequalified bidders and consultants’ lists or revocation of DBE certification if applicable, pursuant to Section 337.105; 337.16; and 339.0805, Florida Statutes. The regulation, provisions, and contract remedies available to in the events of non-compliance with the DBE regulation by a prime contractor include: actions for breach of contract; prosecution for any criminal activity or violation of County Code or Ordinance; enforcement of claims against any retainage, bond, surety or insurance provided by contractor or any subcontractor, legal action on any County cause of action created under the applicable provisions of state or federal law; revocation, cancellation or termination of the contract between the BCC and the prime contractor for the project; any other action permitted at law or in equity; or, any self-help measures that the BCC may lawfully undertake to rectify the default. Page 749 of 2568 Page 11 of 39 3. We will also provide a monitoring and enforcement mechanism to verify that work committed to DBEs at contract award is actually performed by the DBEs. This will be accomplished by: a. Requiring the Contractor, prior to undertaking work on the project, provide the BCC with an accurate list of all DBEs who are or who are anticipated to be subcontractors working on the project, which list shall include an accurate detailed description of all work to be done by each DBE. This list shall be updated any time there is a change in the DBEs working on the project or a change in the allocation of work between or among DBEs. b. BCC review of the DBE list provided by the prime contractor and confirm its accuracy. The BCC may request, and prime contractor shall provide, copies of any subcontracts or other contractual documentation between prime contractor and any subcontractors to confirm the scope of work for each. c. Requiring the prime contractor to notify the BCC of the dates/times when the DBEs are anticipated to be performing each contractual task related to the project, so that the BCC can verify DBE participation in the project, and can verify that the DBEs identified in the Contractor provided list are participating in the project. d. Requiring the prime contractor to identify each DBE receiving payment on all payment notifications required to be provided to the BCC. Any DBE receiving payment shall indicate its status as a DBE on its payment notifications. The prime contractor must provide a DBE Participation Report to the BCC with each invoice submitted to the BCC for payment. Failure of the Contractor to provide the DBE Participation Report may result in the invoice not being paid until the Contractor has provided the report. 4. We will keep a running tally of actual payments to DBE firms for work committed to them at the time of contract award. 5. The BCC will require prime contractors to maintain records and documents of payments to DBEs for three years following the performance of the contract. The records will be made available for inspection upon request by any authorized representative of the BCC or DOT. This reporting requirement also extends to any certified DBE subcontractor. 6. We will perform interim reviews of contract payments to DBEs. The review will examine payments to DBE subcontractors to ensure that the actual amount paid to DBE subcontractors equals or exceeds the dollar amounts states in the schedule of DBE participation. Section 2.10 Fostering Small Business Participation [26.39] The BCC has incorporated the following non-discriminatory elements to its DBE program, in order to facilitate completion on DOT-assisted public works projects by small business concerns (both DBEs and non-DBE small businesses): Small Business Program: Page 750 of 2568 Page 12 of 39 Definition – For the purpose of this section, a small business is defined as a firm that meets the definition as contained in 49 CFR Section 26.5 and Section 3 of the Small Business Act, 15 U.S.C. 631 et seq, which do not exceed the cap on average gross receipts specified in 49 CFR 26.65(b). Small Business Concern is one that: •Is organized for profit, with a place of business located in the United States, which operates primarily within the United States or which makes a significant contribution to the United States economy through payment of taxes or use of America products, materials or labor; •Has the legal form of an individual proprietorship, partnership, limited liability company, corporation, joint venture, association, trust or cooperative. •Is at least 51% owned and controlled by one or more individuals who are citizens of, or permanent resident aliens in, the Unit States, except in the case of a joint venture, where each entity to the venture must be 51% owned and controlled by one or more individuals who are citizens of, or permanent resident aliens in, the United States. A Small Business Concern shall not have average annual gross receipts (over the firm’s previous three fiscal years) in excess of $22.41 million. How to calculate average annual receipts and average employment of a firm can be found in 13 CFR 121.104 and 13 CFR 121.106, respectfully. Program participants will be required to establish eligibility via (1) DBE certification in connection with the Florida Unified Certification Program; (2) U.S. Small Business Administration (SBA) 8A certification, or (3) documentation establishing participation as a registered Dynamic Small Business with SBA. This documentation must be provided in the submittal package in order to verify eligibility. Certified DBEs are presumptively eligible to participate in the program. None of the provisions of this Section shall be interpreted to impose any geographic preferences or limitations, and the program is open to all small business concerns regardless of their location. As part of this program element, the BCC will include the following strategies to begin immediately following FTA approval of the DBE program: •Removal of unnecessary and unjustified bundling of contract requirements that may preclude SBE participation in procurements as prime contractors or subcontractors; and •Letting prime contracts of a size that small business can reasonably compete for and perform. •The BCC will include in its construction contract provisions a requirement that prime contractors affirmatively seek out small business as part of its subcontractor workforce. Prime contractors will be required to provide information with their bid that identifies the small businesses that will participate as subcontractors and the copes of work that will be undertaken. Lack of small business participation will require the bidder to provide evidence of the good faith efforts that were made. The good faith effort requirement will be the same as identified in Section 3.0 – Goals, Good Faith Efforts, and Counting. Page 751 of 2568 Page 13 of 39 •Procurement Services Division staff attendance at several annual trade fairs which include representatives from small businesses. •Attending meetings (local chamber of commerce) and social events where in small business are represented. 3.0 GOALS, GOOD FAITH EFFORTS, AND COUNTING Section 3.1 Set-asides or Quotas [26.43] The BCC does not use quotas in any way in the administration of this DBE program. Section 3.2 Overall Goals [26.45] A description of the methodology to calculate the overall goal and the goal calculations can be found in Attachment 4 to this program. The goal will be updated every three years based on the January 28, 2011, Federal Register. In accordance with Section 26.45(f) the BCC will submit its overall goal to FTA on August 1, 2013 and every three years thereafter. The BCC may adjust the three year overall goal during the three year period to which it applies, in order to reflect changed circumstances. The BCC will submit an adjustment to FTA for review and concurrence. The BCC will also request use of project specific DBE goals as appropriate, and/or will establish project specific DBE goals as directed by FTA. The process generally used by the BCC to establish overall DBE goals is to first develop a base figure for the relative availability of DBE’s. The relative availability of DBEs is the total number of ready, willing and able DBE firms in Collier County divided by the total number of all firms based on the US Census data. Once the base figure has been calculated, we must examine all of the evidence available to our area to determine what adjustment, if any, is needed to the base figure to arrive at the overall goal. Types of evidence to consider include current capacity of DBE’s to perform the work, disparity studies, input from interested parties. Before establishing the overall goal, the BCC will, at a minimum, consult with minority and general contractor’s groups, community organizations, and other officials or organizations to obtain information concerning the availability of disadvantaged and non-disadvantaged business, the effects of discrimination on opportunities for DBES, and the BCC’s efforts to establish a level playing field for the participation of DBE’s. Following this consultation, the BCC will publish a notice of the proposed overall goals, informing the public that the proposed goal and its rational are available for inspection during normal business hours at our principal office for 30 days following the date of the notice, and informing the public that the BCC and DOT will accept comments on the goals for 45 days from the date of the notice. The publishing of the notice of the proposed overall goal will be in a newspaper, or other media, of general circulation focused on minority readers. The notice will also be included on the BCC’s Internet website. Normally this notice will be issued by June 1. The notice must Page 752 of 2568 Page 14 of 39 include addresses to which comments may be sent and addresses (including offices and websites) where the proposal may be reviewed. The overall goal submission to DOT will include: the goal (including the breakout of estimated race-neutral and race-conscious participation, as appropriate); a copy of the methodology, worksheets, etc., used to develop the goal; a summary of information and comments received during this public participation process and the BCC’s responses; and proof of publication of the goal in media outlets listed above. The BCC will begin using our overall goal on October 1, unless the BCC has received other instructions from DOT. If the BCC establishes a goal on a project basis, the BCC will begin using our goal by the time of the first solicitation for a DOT-assisted contract for the project. Section 3.3 Failure to meet Overall Goals [26.47] If the BCC does not have an approved DBE Program or overall goal, or if the BCC fails to implement the program in good faith, the BCC is in noncompliance with its program and corrective action(s) must be documented. The analysis does not have to be transmitted to DOT. If the BCC fails to meet its overall goals in a given year, a determination of the reason(s) or unless the BCC is notified by DOT of the required analysis, the analysis and corrective action(s) will be retained for three years and it will be made available to the FTA upon request for their review. Section 3.4 Transit Vehicle Manufacturers Goals [26.49] The BCC will require each transit vehicle manufacturer, as a condition of being authorized to bid or propose on FTA-assisted transit vehicle procurements, to certify that it has complied with the requirements of this section. Alternatively, the BCC may, at its discretion and with FTA approval, establish project-specific goals for DBE participation in the procurement of transit vehicles in lieu of the TVM complying with this element of the program. Section 3.5 Breakout of Estimated Race-Neutral & Race-Conscious Participation [26.51 (a-c)] The breakout of estimated race-neutral and race-conscious participation can be found in Attachment 4 to this program. The BCC will meet the maximum feasible portion of its overall goal using race-neutral means of facilitating DBE participation. In order to do so, the BCC will: 1. Arrange solicitations, quantities, specifications, and delivery schedules in ways that facilitate DBE and other small business participation. 2. Provide technical assistance. 3. Carry out information and communication programs on contracting procedures and specific contract opportunities. This will include the utilization of directories and other reference sources that list DBEs ensuring the dissemination to bidders on prime contracts of lists of potential DBE subcontractors. Page 753 of 2568 Page 15 of 39 Section 3.6 Contract Goals [26.51 (d-g)] The BCC will use contract goals to meet any portion of the overall goal the BCC 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 BCC will establish contract goals only on those DOT-assisted contracts that have subcontracting possibilities. The BCC 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 BCC will express a contract goal as a percentage of total amounts of DOT-assisted contract. The BCC will arrange solicitations, times for the presentation of bids, quantities, specifications and delivery schedules in ways that facilitate participation by DBEs and other small business and by making contracts more accessible to small businesses, by means such as those provided in section 2.10 of this document. Below is a sample bid specification: The requirements of 49 CFR Part 26, Regulations of the U.S. Department of Transportation apply to this contract. It is the policy of the BCC to practice nondiscrimination based on race, color, sex, or national origin in the award or performance of this contract. All firms qualifying under this solicitation are encouraged to submit bids/proposals. Award of this contract will be conditioned upon satisfying the requirements of this bid specification. These requirements apply to all bidders/offerors, including those who qualify as a DBE. A DBE contract goal of ___ percent has been established for this contract. The bidder/offeror shall make good faith efforts, as defined in Appendix A, 49 CFR Part 26 (Attachment 1), to meet the contract goal for DBE participation in the performance of this contract. The bidder/offeror will be required to submit the following information: (1) the names and addresses of DBE firms that will participate in the contract; (2) a description of the work that each DBE firm will perform; (3) the dollar amount of the participation of each DBE firm participating; (4) Written documentation of the bidder/offeror’s commitment to use a DBE subcontractor whose participation it submits to meet the contract goal; (5) Written confirmation from the DBE that it is participating in the contract as provided in the commitment made under (4); and (5) if the contract goal is not met, evidence of good faith efforts. Section 3.7 Good Faith Efforts Procedures for contracts with DBE Contract Goals [26.53] 3.7.1. Award of Contracts with a DBE Contract Goal: 26.53(a) In those instances where a contract-specific DBE goal is included in a procurement/solicitation, the BCC will not award the contract to a bidder who does not either: (1) meet the contract goal Page 754 of 2568 Page 16 of 39 with verified, countable DBE participation; or (2) documents it has made adequate good faith efforts to meet the DBE contract goal, even though it was unable to do so. It is the obligation of the bidder to demonstrate it has made sufficient good faith efforts prior to submission of its bid. 3.7.2. Evaluation of Good Faith Efforts: 26.53 (a) & (c) The DBELO 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 responsive. The BCC evaluation of good faith efforts will be conducted in accordance with Appendix A to Part 26 – Guidance Concerning Good Faith Efforts. The processes used by the BCC to determine whether good faith efforts have been made by a bidder are as follows: 1. If bidder/offeror does not meet the established DBE goal, and is required to submit documentation of good faith effort, then a good faith efforts submission shall be provided within three business days from the bid/proposal submittal date, which shall include documentation that the bidder/proposer made a good faith effort to meet the goal. The BCC may allow a longer period based on submittal of a request demonstrating good cause for such extension. Good faith efforts at a minimum include, the following items (where applicable): a. Attendance at the pre-bid meeting; b. Advertisement in trade association newsletters and minority-focused media within a reasonable time before bids are due for specific sub-bids that would be at least equal to the percent goal for DBE utilization specified for the project. c. Notifications in writing to minority contractor associations within a reasonable time before bids are due of a solicitation for specific sub-bids. d. Direct negotiation with DBEs for specific sub-bids. The BCC will ensure that all information is complete and accurate and adequately documents the bidder/offer’s good faith efforts before the BCC commits to the performance of the contract by the bidder/offeror. 3.7.3. Information to be Submitted: 26.53 (b) The BCC treat bidders/offers’ compliance with good faith efforts’ requirements as a matter of responsiveness. 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; Page 755 of 2568 Page 17 of 39 •A description of the work that each DBE will perform; •The dollar amount of the participation of each DBE firm participating; •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 contractors commitment and •If the contract goal is not met, evidence of good faith efforts. 3.7.4 Administrative reconsideration [26.53(d)] Within 5 days of being informed by BCC 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: Joanne Markiewicz, Procurement Services Division Director, Procurement Services Division, 3327 East Tamiami Trail, Naples, Florida 34112, (239) 252-8975 or joannemarkiewicz@colliergov.net. 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 do so. The bidder/offeror will have the opportunity to meet in person with our reconsideration official to discuss the issue of whether it met the goal or made adequate good faith efforts to do. We 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. 3.7.5 Good Faith Efforts when a DBE is terminated or substituted on a contract [26.53(f)] The BCC requires that prime contractors not terminate a DBE subcontractor listed on a bid/contract with a DBE contract goal with the BCC‘s prior written consent. Prior written consent will only be provided where there is “good cause” for termination of the DBE firm, as established by Section 26.53(f)(3) of the DBE regulation. Before transmitting to the BCC its request to terminate, the prime contractor must give notice in writing to the DBE of its intent to do so. A copy of this notice must be provided to the BCC prior to consideration of the request to terminate. The DBE will then have five (5) days to respond and advise the BCC of why it objects to the proposed termination. In those instances where “good cause” exists to terminate a DBE’s contract, the BCC will require the prime 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 Page 756 of 2568 Page 18 of 39 the extent needed to meet the contract goal. The BCC will require the prime contractor to notify the DBE Liaison officer immediately of the DBE’s inability or unwillingness to perform and provide reasonable documentation. In this situation, the BCC will require the prime contractor to obtain our 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, our 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. Section 3.8 Counting DBE Participation [26.55] The BCC will count DBE participation toward overall and contract goals as provided in 49 CFR 26.55. Only the value of the work actually performed by the DBE will count toward DBE goals. Such value will be counted as follows: •The entire amount that is performed by the DBE; •The entire amount of reasonable fees or commissions charged by a DBE firm for providing a bona fide service or for providing bonds or insurance required for the performance of the DOT-assisted contract; •The value of work subcontracted by a DBE to another DBE is counted toward DBE goals. •When a DBE performs as part of a joint venture, the portion of the total dollar value of the contract equal to the defined portion of the work of the contract that the DBE performs will be counted. •Expenditures to a DBE contractor will be counted toward DBE goals only if the DBE is performing a commercially useful function on that contract as set forth in 49 CFR Part 26.55[c] [1-5]. For determining whether a trucking company is performing a commercially useful function, Collier County will refer to 49 CFR Part 26.55[d] (1-6]. •For establishing whether expenditures for materials or supplies count toward DBE goals, Collier County will refer to 49 CFR Part 26.55[e]. •A DBE’s participation will not be counted toward DBE goals of the prime contractor or the BCC’s overall goal until the DBE is paid. 4.0 CERTIFICATION STANDARDS [26.61 – 26.73] The BCC is a non-certifying member of the Unified Certification Program (UCP) in the State of Florida. All firms must apply through the UCP to be certified in the State of Florida. The local certifying agency in the southwest Florida area is the Lee County Port Authority located at the Southwest Florida International Airport. The BCC will use the DBE directory administered by the Florida Department of Transportation and listed on the UCP website to verify if a firm is DBE certified by the Florida UCP. Page 757 of 2568 Page 19 of 39 The Florida UCP certifies DBEs in accordance to the Federal Regulations. An Annual Meeting of the Florida UCP is scheduled for all members to attend and discuss any issues or needed changes to the UCP Program 5.0 CERTIFICATION PROCEDURES [26.81] The BCC is a non-certifying member of a Unified Certification Program (UCP) administered by Florida Department of Transportation Equal Opportunity Office, 605 Suwannee Street, MS 65, Tallahassee, Florida 32399-0450. The EEO Office can be contacted by telephone: (850) 414- 4747, fax: (850) 414-4879, and website at www.dot.state.fl.us/equalopportunityoffice/DBEProgram. The Florida UPC will meet all of the requirements of certification procedures. 6.0 DENIAL OF DBE STATUS AND APPEALS [26.83 – 26.91] Any firm or complainant may appeal our 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 Street, SW Room 2104 Washington, D.C. 20590 7.0 INFORMATION, CONFIDENTIALITY, COOPERATION [26.109] Section 7.1 Availability of records The BCC will safeguard from disclose to third parties information that may reasonably regarded as confidential business information, consistent federal, state, and local law. In responding to requests for information concerning any aspect of the DBE program, the BCC complies with provisions of the Federal Freedom of Information and Privacy Acts (5 U.S.C. 552 and 552a). The BCC may make available to the public any information concerning the DBE program release of which is not prohibited by Federal law. Section 7.2 Confidentiality Notwithstanding any contrary provisions, the BCC 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 firm that submitted the information. Notwithstanding the provisions 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 Page 758 of 2568 Page 20 of 39 that, in some circumstances, failure to waive the privilege may result in the closure of the investigation or dismissal of the proceeding or hearing. Section 7.3 Cooperation The BCC will require prime contractors to maintain records and documents of payments to DBE’s 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 BCC or DOT. This reporting requirement also extends to any certified DBE subcontractor. The BCC will 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. 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. Section 7.4 Intimidation and retaliation The BCC will not and will not allow a contractor, or any other participant in the program, to 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. Page 759 of 2568 Page 21 of 39 ATTACHMENTS Page 760 of 2568 Page 22 of 39 Attachment 1 Organizational Chart Burt L. Saunders BCC Chairman Amy Patterson County Manager Trinity Scott TMS Department Head Brian Wells Public Transit & Neighborhood Enhancement Division Director Omar De Leon Public Transit Manager DBELO Corene Sanger Management Analyst I Alexander Showalter Planner II Liz Soriano Project Manager II Elena Ortiz Rosado Program Coordinator Reporting Relationship for DBE Matters Page 761 of 2568 Page 23 of 39 Attachment 2 DBE Directory The BCC does not certify DBEs but rather uses the list of DBEs identified in the Florida Department of Transportation (FDOT) Uniform Certification Program (UCP) Directory. The DBE directory can be found at: https://fdotxwp02.dot.state.fl.us/EqualOpportunityOfficeBusinessDirectory/Home.aspx What is the Florida UCP DBE Directory? The Florida Unified Certification Program Disadvantaged Business Enterprise (UCP DBE) is a searchable listing of all certified Disadvantaged Business Enterprise (DBE) and Airport Concession Disadvantaged Business Enterprise (ACDBE) firms eligible to perform work under the federal DBE Program. The Florida UCP DBE Directory is updated daily and includes information pertaining to the firm’s certification status, including its assigned North American Industry Classification System (NAICS) codes, available work locations and contact information. Advanced search options allow users a means to customize searches, filter items, and sort results based on specific needs. The Florida UCP DBE Directory makes extensive use of the following acronyms/terms. How do I use this directory? The Florida UCP DBE Directory is published to help contractors and consultants identify subcontractors and subconsultants eligible to participate on federally funded contracts towards the attainment of DBE goals. •All certified DBE and ACDBE firms listed in this directory have been approved under the eligibility standards and guidelines set forth in the Title 49 Code of Federal Regulations Parts 23 and 26. •It is the contractor/consultant’s responsibility to evaluate the DBE’s ability to perform on any given project. Most popular browsers will view this site without issue. However the suggested browser is the latest version of Internet Explorer. Page 762 of 2568 Page 24 of 39 Attachment 3 DBE Monitoring and Enforcement Mechanisms In the event that a DBE goal has been established by the Solicitation the prime contractor covenants and agrees as follows: 1. The BCC requires that prime contractors not terminate a DBE subcontractor listed on a bid/contract with a DBE contract goal without the BCC’s prior written consent. Prior written consent shall be provided where there is “good cause” for termination of the DBE firm, as established by Section 26.53(f)(3) of the DBE regulation. Before transmitting to the BCC its request to terminate, the prime contractor shall give notice in writing to the DBE of its intent to do so. A copy of this notice shall be provided to the BCC prior to consideration of the request to terminate. The DBE shall have five (5) days to respond and advise the BCC why it objects to the proposed termination. The five day period may be reduced if the matter is one of public necessity, e.g., safety. 2. In those instances where “good cause” exists to terminate a DBEs contract, the BCC requires the prime 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 contract shall notify the BCC immediately of the DBE’s inability or unwillingness to perform and provide reasonable documentation. 3. The BCC requires the prime contractor to obtain the BCC 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 BCC may issue an order stopping all or part of payment/work until satisfactory action has been taken. If the contractor still fails to comply, the BCC may issue a termination for default proceeding. 4. The prime contractor shall provide the DBE Liaison Officer with at least thirty (30) days written notice prior to instituting any legal action against a DBE subcontractor. 5. The prime contractor shall provide the DBE Liaison Officer with monthly updates as to the prime contractor’s continuing compliance with the DBE requirements set forth in the Solicitation. The prime contract shall submit with each invoice a report of DBE expenditures. Such report must show each DBE, the amount of such DBE’s subcontract, the amount earned to date, the amount earned with respect to that invoice and the amount remaining to be earned. Page 763 of 2568 Page 25 of 39 6. The prime contractor shall make prompt and full payment to any DBE subcontractor (including the payment of any retainage) within the later of: a. Thirty (30) days after the DBE subcontractor’s work is satisfactorily completed, or b. Thirty (30) days after the prime contractor receives payment from the BCC for satisfactory completion of the accepted work. The BCC will bring to the attention of the USDOT any false, fraudulent, or dishonest conduct in connection with the program, so the USDOT can take the steps (e.g., referral to the Department of Justice for criminal prosecution, referral to the USDOT Inspector General, action under suspension and debarment of Program Fraud and Civil Penalties rules) provided in Section 26.109. These may include: 1. Suspension or debarment proceedings pursuant to 49 CFR part 26. 2. Enforcement action pursuant to 49 CFR part 31. 3. Prosecution pursuant to 18 USC 1001. The BCC will also consider similar action under state legal authorities, including responsibility determinations in future contracts, removal of firms from the prequalified bidders and consultants’ lists or revocation of DBE certification if applicable, pursuant to Section 337.105; 337.16; and 339.0808, Florida Statutes. Page 764 of 2568 Page 26 of 39 Attachment 4 Overall DBE Goal Calculation & Section 26.51: Breakout of Estimated Page 765 of 2568 Page 27 of 39 Attachment 5 Collier Area Transit DBE Vendor Process & Forms Including Good Faith Efforts (Forms 1 & 2) Page 766 of 2568 Page 28 of 39 Page 767 of 2568 Page 29 of 39 Page 768 of 2568 Page 30 of 39 Page 769 of 2568 Page 31 of 39 Page 770 of 2568 Page 32 of 39 Page 771 of 2568 Page 33 of 39 Demonstration of Good Faith Efforts (Forms 1 and 2 should be provided as part of the solicitation documents) FORM 1: DISADVANTAGED BUSINESS ENTERPRISE (DBE) UTILIZATION The undersigned bidder/offeror has satisfied the requirements of the bid specification in the following manner (please check the appropriate space): ________The bidder/offeror is committed to a minimum of _____ % DBE utilization on this contract. ________The bidder/offeror (if unable to meet the DBE goal of _____ %) is committed to a minimum of ______ % DBE utilization on this contract a submits documentation demonstrative good faith efforts. Name of bidder’s/offeror’s firm: ____________________________________________ State Registration No. _____________________________ Date: __________________________________________ By: ___________________________________________________________________ Print Name By: ___________________________________________________________________ Signature _______________________________________________________________________ Title Page 772 of 2568 Page 34 of 39 Demonstration of Good Faith Efforts (Forms 1 and 2 should be provided as part of the solicitation documents) FORM 2: LETTER OF INTENT Name of bidder’s/offeror’s firm: __________________________________________ Address: _____________________________________________________________ City: _________________________ State: ________ Zip: ______________ Name of DBE firm: ____________________________________________________ Address: _____________________________________________________________ City: _________________________ State: ________ Zip: ______________ Telephone: ________________________ Description of work to be performed by DBE firm: The bidder/offeror is committed to utilizing the above-name DBE firm for the work described above. The estimated dollar value of this work is $ ____________. Affirmation The above-named DBE firm affirms that it will perform the portion of the contract for the estimated dollar value as stated above. By _________________________________________________________________ Signature Title Page 773 of 2568 Page 35 of 39 If the bidder/offeror does not receive award of the prime contract, any and all representations in this Letter of Intent and Affirmation shall be null and void. (Please submit this page for each subcontractor) Attachment 6 State of Florida UCP Agreement Page 774 of 2568 Page 36 of 39 Page 775 of 2568 Page 37 of 39 Page 776 of 2568 Page 38 of 39 Page 777 of 2568 Page 39 of 39 Attachment 7 49 CFR Part 26 The text of 49 CFR Part 26 can be found at the link: https://www.ecfr.gov/cgi-bin/text- idx?c=ecfr&SID=4195360ce4431b02f1bc643ea0a6e638&rgn=div5&view=text&node=49:1.0.1. 1.20&idno=49 Page 778 of 2568