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POLICY STATEMENT
Section 26.1, 26.23 Objectives/Policy Statement
The Atlanta Regional Commission (ARC) has established a Disadvantaged Business Enterprise (DBE) program in accordance with regulations of the U.S. Department of Transportation (DOT), 49 CFR Part 26. ARC has received Federal financial assistance from the Department of Transportation, and as a condition of receiving this assistance, ARC has signed an assurance that it will comply with 49 CFR Part 26.
It is the policy of ARC to ensure that DBEs, as defined in part 26, have an equal opportunity to receive and participate in DOT–assisted contracts. It is also our policy:
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.
The Contract & Grants Analyst has been designated as the DBE Liaison Officer. In that capacity, the Contracts & Grants Analyst 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 ARC in its financial assistance agreements with the Department of Transportation.
ARC has disseminated this policy statement to the ARC Board of Directors 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. ARC has provided notice of our DBE Program in the Fulton County Daily Report. The DBE Program is also available for copying or viewing at ARC Offices located at 40 Courtland Street, Atlanta, GA 30303 and on ARC’s website at www.atlantaregional.com.
Douglas R. Hooker Date
Executive Director
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SUBPART A – GENERAL REQUIREMENTS
Section 26.1 Objectives
The objectives are found in the policy statement on the first page of this program.
Section 26.3 Applicability
ARC 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.
ARC is also the recipient of federal-aid highway funds authorized under Titles I and V of the
Intermodal Surface Transportation Efficiency Act of 1991 (ISTEA), Pub. L. 102-240, 105 Stat. 1914,
Titles I, III, and V of the Transportation Equity Act for the 21st Century (TEA-21, Pub. L.105-178,
112 Stat. 107.
Section 26.5 Definitions
ARC will adopt the definitions contained in Section 26.5 for this program.
Section 26.7 Non-discrimination Requirements
ARC 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, ARC 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 26.11 Record Keeping Requirements
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Reporting to DOT: 26.11(b)
ARC will report DBE participation to DOT as follows:
ARC will report DBE participation to FTA on a semi-annual basis, using DOT Form 4630.
These reports will reflect payments actually made to DBEs on DOT-assisted contracts.
ARC will report DBE participation to FHWA on a semi-annual basis, using DOT form 4630.
Bidders List: 26.11(c)
ARC will create a bidders list, consisting of information about all DBE and non-DBE firms that bid
or quote on DOT-assisted contracts. The purpose of this requirement is to allow use of the
bidders list approach to calculating overall goals. The bidders list will include the name, address,
DBE/non-DBE status, age, and annual gross receipts of firms.
ARC will collect this information in the following ways:
The Center for Business Services and/or the Center for Livable Communities will provide a
notice in all solicitations requiring the prime bidder to provide appropriate bidder data on
prime and sub-bidders, including:
o Name
o Address of office to perform contract
o Bid Amount
o MBE/WBE/DBE status
o NIGP Code, Description of Work
o Number of years in business
The Department and/or Purchasing Agent will obtain appropriate bidder information on all
quotes submitted in response to opportunities below $25,000, including:
o Name
o Address of office performing contract
o Bid Amount
o MBE/WBE/DBE status
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o NIGP Code, Description of Work
o Number of years in business
Section 26.13 Federal Financial Assistance Agreement
ARC has signed the following assurances, applicable to all DOT-assisted contracts and their
administration:
Assurance: 26.13(a)
ARC 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 ARC 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.).
This language will appear in financial assistance agreements with sub-recipients.
Contract Assurance: 26.13b
ARC will ensure that the following clause is placed in every DOT-assisted contract and
subcontract:
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
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appropriate.
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SUBPART B - ADMINISTRATIVE REQUIREMENTS
Section 26.21 DBE Program Updates
Since ARC has received a grant of $250,000 or more in FTA planning, capital, and or operating
assistance in a federal fiscal year and received grant funds from FHWA as a sub-recipient, ARC
will continue to carry out this program until all funds from DOT financial assistance have been
expended. We will provide to DOT updates representing significant changes in the program.
Section 26.23 Policy Statement
The Policy Statement is elaborated on the first page of this program.
Section 26.25 DBE Liaison Officer (DBELO)
ARC has designated the following individual as our DBE Liaison Officer:
Brittany Zwald
Contract & Grants Analyst
Financial Services Division
Atlanta Regional Commission
40 Courtland Street
Atlanta, GA 30303
404-463-3162
In that capacity, the DBELO is responsible for implementing all aspects of the DBE program and
ensuring that ARC complies with all provision of 49 CFR Part 26. The DBELO has direct,
independent access to Douglas R. Hooker, Executive Director, concerning DBE program matters.
An organization chart displaying the DBELO’s position in the organization is found in Attachment
2.1 to this program.
The DBELO is responsible for developing, implementing and monitoring the DBE program, in
coordination with other appropriate officials. The DBELO does not have any direct reports,
however, she may utilize resources in the Division of Financial Services, as well as the Center for
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Business Services, 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 ARC’s progress toward attainment and identifies ways to improve progress;
7. Participates in pre-bid meetings;
8. Advises the Executive Director\Board on DBE matters and achievement;
9. Chairs the DBE Advisory Committee;
11. Provides DBEs with information and assistance in preparing bids, obtaining bonding and
insurance;
12. Plans and participates in DBE training seminars;
13. Acts as liaison to the Uniform Certification Process in the State of Georgia;
14. Provides outreach to DBEs and community organizations to advise them of opportunities;
and,
15. Maintains ARC’s Bidder’s list.
Section 26.27 DBE Financial Institutions
It is the policy of ARC 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.
Periodically, ARC solicits competitively for banking services. In these instances, ARC will ensure
that DBE financial institutions are included on the solicitation lists, provided sufficient notice of
the solicitation and encouraged and provided the opportunity to respond to the solicitation.
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To date we have identified the following such institutions:
Carver State Bank
Contact: Robert E. James, President & CEO
701 Martin Luther King, Jr. Boulevard,
P.O. Box 2769
Savannah, GA 31402
Routing and Transit (ABA) Number: 061200658
Phone: 912-447-4203
Fax: 912-232-8666
E-mail: [email protected]
MC: 50
Citizens Trust Bank
Contact: Samuel J. Cox, Senior EVP & CFO
75 Piedmont Avenue, Suite 1200
Atlanta, GA 30303
Routing and Transit (ABA) Number: 061010220
Phone: 404-575-8306
Fax: 404-575-8311
E-mail: [email protected]
MC: 50
Metro City Bank
Contact: Abdul Mohdnor, Vice President
Contact: Farid Tan, Vice President
5441 Buford Highway, Suite 109
Doraville, GA 30340
Routing and Transit (ABA) Number: 061120686
Phone: 770-455-4989
Fax: 770-455-4988
E-mail: [email protected]
MC: 30
Quantum National Bank
Contact: Dana Litman, SVP & CFO
505 Peachtree Industrial Boulevard
Suwanee, GA 30024
Routing and Transit (ABA) Number: 061104893
Phone: 770-945-8300
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Fax: 770-945-4888
E-mail: [email protected]
MC: 30
State Bank of Georgia
Contact: Kathy Hulsey, SVP and CFO
131 Gingercake Road
Fayatteville, GA 30214
Routing and Transit (ABA) Number: 061121009
Phone: 770-719-1200
Fax: 678-833-1641
E-mail: [email protected]
MC: 30
Touchmark National Bank
Contact: Jorge L. Forment, EVP & CFO
3651 Old Milton Parkway
Alpharetta, GA 30005
Routing and Transit (ABA) Number: 061121106
Phone: 770-407-6700
Fax: 770-407-6752
E-mail: [email protected]
Information on the availability of such institutions can be obtained from the DBE Liaison Officer.
Section 26.29 Prompt Payment Mechanisms
ARC will pay its prime contractors within 30 days from the receipt of a prime contractor’s invoice.
ARC 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 ARC. 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 ARC. This clause applies to both DBE
and non-DBE subcontracts.
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Any contractor found not to be in compliance with this clause will be considered in
breach of contract and any further payments will be withheld until corrective
action is taken. If contractor does not take corrective action, contractor may be
subject to contract termination.
Any dispute and appeal regarding this prompt pay provision will be handled
according to ARC’s Purchasing, Contracting and Procurement Policy, pg. 36. For
more information concerning ARC’s dispute and appeals process, please contact
the Director of Business Services at 404-463-3120.
Section 26.31 Directory
ARC participates in the State of Georgia Uniform Certification Program administered by the
Georgia Department of Transportation (GDOT). GDOT maintains a directory identifying all firms
eligible to participate as DBEs. The directory lists the firm’s name, address, phone number, date
of the most recent certification, and the type of work the firm has been certified to perform as a
DBE. ARC makes a link to the Directory available on our website at www.atlantaregional.com
and makes a copy available in the office of the DBELO at 40 Courtland Street, Atlanta, GA 30303,
404-463-3162. The Directory may be found in Attachment 2.2 to this program document.
Section 26.33 Overconcentration
ARC has not identified that overconcentration exists in the types of work that DBEs perform.
Section 26.35 Business Development Programs
ARC has not established a business development program. ARC refers DBEs and non-DBEs
needing business development services to:
Georgia Department of Transportation Supportive Services Consultant
Atlanta Small Business Development Center at Georgia State University
Atlanta Minority Business Development Center and/or
SCORE Atlanta
Georgia Tech’s Procurement Assistance Center
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Section 26.37 Monitoring and Enforcement Mechanisms
ARC will provide the following monitoring and enforcement mechanisms to ensure compliance
with 49 CFR Part 26.
1. ARC 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. ARC will consider similar action under our own legal authorities, including responsibility
determinations in future contracts. ARC’s procurement and contracting manuals list the
regulation, provisions, and contract remedies available to ARC in the events of non-
compliance with the DBE regulations by a participant in our procurement activities.
3. ARC 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:
Tracking DBE contracts in Concur or other financial tracking system on prime contractor
activity and producing a report of DBE prime participation on a semi-annual basis; and,
Requiring prime contractors with subcontractors to submit evidence of all subcontractor
performance, including DBEs, with monthly invoice.
4. ARC will keep a running tally of actual payments to DBE firms, both prime contractors and
subcontractors, for work committed to them at the time of contract award.
Section 26.39 Small Business Participation
ARC has incorporated the following non-discriminatory element to its DBE program, in order to
facilitate competition on DOT-assisted public works projects by small business concerns (both
DBE and non-DBE small businesses):
Publish list of informal procurements normally procured by ARC each year and forecast
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of upcoming formal procurements for the year. These procurement opportunities will
cover both sub-recipients and prime contractors;
Ensure that small businesses are included on ARC Prospective consultant list; and,
Encourage solicitation of at least one small business on prime and subcontracting
opportunities.
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SUBPART C – GOALS, GOOD FAITH EFFORTS, AND COUNTING
Section 26.43 Set-asides or Quotas
ARC does not use quotas in any way in the administration of this DBE program.
Section 26.45 Overall Goals
A description of the methodology to calculate the overall goal and the goal calculations can be
found in Attachment 2.3 to this program. This section of the program will be updated every three
years.
In accordance with Section 26.45(f) ARC will submit its overall goal to DOT on August 1 every
three years. Before establishing the overall goal for the required period, ARC will consult with
minority, women, and general contractor groups, community organizations, and other officials
or organizations to obtain information concerning the availability of disadvantaged and non-
disadvantaged businesses, the effects of discrimination on opportunities for DBEs, and ARC’s
efforts to establish a level playing field for the participation of DBEs.
Following this consultation, ARC will publish a notice of the proposed overall goals informing the
public that the proposed goal and its rationale are available for inspection during normal business
hours at ARC’s Financial Services Division and on ARC’s website following the date of the notice
and informing the public that ARC and DOT will accept comments on the goals for 45 days from
the date of the notice. Notice will be issued in general circulation media and minority focused
media.
ARC’s proposed goal may be reviewed at and comments regarding ARC’s proposed DBE goal can
be sent to:
Brittany Zwald
Contract & Grants Analyst
Financial Services Division
Atlanta Regional Commission
40 Courtland Street
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Atlanta, GA 30303
404-463-3162
www.atlantaregional.com
ARC’s overall goal submission to DOT will include a summary of information and comments
received during this public participation process and our responses.
ARC will begin using our overall goal on October 1 of the designated year, unless we have
received other instructions from DOT. If ARC establishes a goal on a project basis, we will begin
using our goal by the time of the first solicitation for a DOT-assisted contract for the project.
Section 26.49 Transit Vehicle Manufacturers Goals
ARC, as a planning organization, does not anticipate the acquisition of transit vehicles. As such,
ARC does not establish goals for Transit Vehicle Manufacturers.
Section 26.51(a-c) Breakout of Estimated Race-Neutral & Race-Conscious Participation
The breakout of estimated race-neutral and race-conscious participation can be found in
Attachment 2.4 to this program. This section of the program will be updated when the goal
calculation is updated.
Section 26.51(d-g) Contract Goals
ARC may use contract goals to meet any portion of the overall goal ARC does not project being
able to meet using race-neutral means. Contract goals may be 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.
ARC may establish contract goals only on those DOT-assisted contracts that have subcontracting
possibilities. We 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.)
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We will express our contract goals as a percentage of total amount of a DOT-assisted contract.
Section 26.53 Good Faith Efforts Procedures
Demonstration of good faith efforts (26.53(a) & (c))
The obligation of the bidder/offeror is to make good faith efforts. The bidder/offeror can
demonstrate that it has done so either by meeting the contract goal or documenting good faith
efforts. Examples of good faith efforts are found in Appendix A to Part 26. They are repeated
here for convenience:
A. Soliciting through all reasonable and available means (e.g. attendance at pre-
bid meetings, advertising and/or written notices) the interest of all certified
DBEs who have the capability to perform the work of the contract. The bidder
must solicit this interest within sufficient time to allow the DBEs to respond to
the solicitation. The bidder must determine with certainty if the DBEs are
interested by taking appropriate steps to follow up initial solicitations.
B. Selecting portions of the work to be performed by DBEs in order to increase
the likelihood that the DBE goals will be achieved. This includes, where
appropriate, breaking out contract work items into economically feasible units
to facilitate DBE participation, even when the prime contractor might
otherwise prefer to perform these work items with its own forces.
C. Providing interested DBEs with adequate information about the plans,
specifications, and requirements of the contract in a timely manner to assist
them in responding to a solicitation.
D. (1) Negotiating in good faith with interested DBEs. It is the bidder's
responsibility to make a portion of the work available to DBE subcontractors
and suppliers and to select those portions of the work or material needed
consistent with the available DBE subcontractors and suppliers, so as to
facilitate DBE participation. Evidence of such negotiation includes the names,
addresses, and telephone numbers of DBEs that were considered; a
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description of the information provided regarding the plans and specifications
for the work selected for subcontracting; and evidence as to why additional
agreements could not be reached for DBEs to perform the work.
(2) A bidder using good business judgment would consider a number of factors
in negotiating with subcontractors, including DBE subcontractors, and would
take a firm's price and capabilities as well as contract goals into consideration.
However, the fact that there may be some additional costs involved in finding
and using DBEs is not in itself sufficient reason for a bidder's failure to meet
the contract DBE goal, as long as such costs are reasonable. Also, the ability
or desire of a prime contractor to perform the work of a contract with its own
organization does not relieve the bidder of the responsibility to make good
faith efforts. Prime contractors are not, however, required to accept higher
quotes from DBEs if the price difference is excessive or unreasonable.
E. Not rejecting DBEs as being unqualified without sound reasons based on a
thorough investigation of their capabilities. The contractor's standing within
its industry, membership in specific groups, organizations, or associations and
political or social affiliations (for example union vs. non-union employee
status) are not legitimate causes for the rejection or non-solicitation of bids in
the contractor's efforts to meet the project goal.
F. Making efforts to assist interested DBEs in obtaining bonding, lines of credit,
or insurance as required by the recipient or contractor.
G. Making efforts to assist interested DBEs in obtaining necessary equipment,
supplies, materials, or related assistance or services.
H. Effectively using the services of available minority/women community
organizations; minority/women contractors' groups; local, state, and Federal
minority/women business assistance offices; and other organizations as
allowed on a case-by-case basis to provide assistance in the recruitment and
placement of DBEs.
The following personnel are responsible for determining whether a bidder/offeror who has not
met the contract goal has documented sufficient good faith efforts to be regarded as responsive.
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Senior Principal Management Analyst, Center for Livable Communities
Provider Network and Financial Services Manager, Aging and Health Resources
Brittany Zwald, DBELO and Contract & Grants Analyst, Financial Services
ARC will ensure that all information is complete and accurate and adequately documents the
bidder/offer’s good faith efforts before we commit to the performance of the contract by the
bidder/offeror.
Information to be submitted (26.53(b))
ARC treats bidder/offerors’ 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:
1. The names and addresses of DBE firms that will participate in the contract;
2. A description of the work that each DBE will perform;
3. The dollar amount of the participation of each DBE firm participating;
4. Written and signed documentation of commitment to use a DBE subcontractor whose
participation it submits to meet a contract goal;
5. Written and signed confirmation from the DBE that it is participating in the contract as
provided in the prime contractors commitment and
6. If the contract goal is not met, evidence of good faith efforts.
Administrative reconsideration (26.53(d))
Within 7 days of being informed by ARC 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:
Emerson Bryan, Director of Business Services, 40 Courtland Street, Atlanta, GA 30303, 404-463-
3120, [email protected]. The reconsideration official will not have played any role in
the original determination that the bidder/offeror did not document sufficient good faith efforts.
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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 Transpiration.
Good Faith Efforts when a DBE is replace on a contract (26.53(f))
ARC will require a contractor to make good faith efforts to replace a DBE that is terminated or
has otherwise failed to complete its work on a contract with another certified DBE, to the extent
needed to meet the contract goal. ARC 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, ARC 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.
Sample Bid Specification:
ARC will include the following language in its bid specifications in bids where a contract goal is
established. The language provided below will serve as notice to bidders/offerors of the
requirements to make good faith efforts. The forms found in Attachment 2.5 will be utilized by
ARC to collect information necessary to determine whether the bidder/offeror has satisfied these
requirements.
The requirements of 49 CFR Part 26, Regulations of the U.S. Department of
Transportation, apply to this contract. It is the policy of ARC 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
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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 2.8), 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 26.55 Counting DBE Participation
ARC will count DBE participation toward overall and contract goals as provided in 49 CFR 26.55.
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SUBPART D – CERTIFICATION STANDARDS
Section 26.61 – 26.73 Certification Process
ARC relies upon the standards established under the Uniform Certification Program, which is
administered by the Georgia Department of Transportation. The UCP will use the certification
standards of Subpart D of Part 26 to determine the eligibility of firms to participate as DBEs in
DOT-assisted contracts. To be certified as a DBE, a firm must meet all certification eligibility
standards.
For information about the certification process or to learn how to apply for certification, firms
should contact:
Brittany Zwald
Contract & Grants Analyst
Financial Services Division
Atlanta Regional Commission
40 Courtland Street
Atlanta, GA 30303
404-463-3162
The UCP certification application forms and documentation requirements are found in
Attachment 2.6 to this program.
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SUBPART E – CERTIFICATION PROCEDURES
Section 26.81 Unified Certification Programs
ARC is a member of a Unified Certification Program (UCP) administered by the Georgia
Department of Transportation. The Georgia Department of Transportation and The
Metropolitan Atlanta Rapid Transit Authority (MARTA) entered into a State of Georgia Unified
Certification Program (known as the GUCP agreement). All applications, affidavit of no change
forms and personal net worth for certification will be sent to Georgia DOT. Each item will be
logged in and date stamped for data management by the GDOT DBE Administrator.
Section 26.83 Procedures for Certification Decisions
Re-certifications 26.83(a) & (c)
Re-certifications are reviewed and determined by the UCP, administered by the Georgia
Department of Transportation. ARC will direct all inquiries regarding recertification to the UCP.
“No Change” Affidavits and Notices of Change (26.83(j))
ARC will direct all inquiries regarding No Change Affidavits and Notices of Change to the UCP.
Section 26.85 Denials of Initial Requests for Certification
Denials of Initial Requests for Certification are reviewed and determined by the UCP,
administered by the Georgia Department of Transportation. ARC will direct all inquiries to the
UCP.
Section 26.87 Removal of a DBE’s Eligibility
Removal of a DBE’s Eligibility are reviewed and determined by the UCP, administered by the
Georgia Department of Transportation. ARC will direct all inquiries to the UCP.
Section 26.89 Certification Appeals
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Any firm or complainant may appeal a 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
The UCP will promptly implement any DOT certification appeal decisions affecting the eligibility
of DBEs for our DOT-assisted contracting (e.g., certify a firm if DOT has determined that the UCP
denial of its application was erroneous).
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SUBPART F – COMPLIANCE AND ENFORCEMENT
Section 26.109 Information, Confidentiality, Cooperation
ARC will safeguard from disclosure to third parties information that may reasonably be regarded
as confidential business information, consistent with Federal, state, and local law. In responding
to requests for information concerning any aspect of the DBE program, ARC complies with the
provisions of the Federal Freedom of Information and Privacy Act (5 U.S.C. 552 and 552a).
Notwithstanding any contrary provisions of state or local law, ARC will not release personal
financial information submitted in response to the personal net worth requirement to a third
party (other than DOT) without the written consent of the submitter.
Monitoring and Enforcement Mechanisms
ARC utilizes both Georgia Department of Transportation and the federal government
enforcement mechanisms.
The federal government has available several enforcement mechanisms that it may apply to firms
participating in the DBE program, including, but not limited to, the following:
1. Suspension or debarment proceedings pursuant to 49 CFR part 26;
2. Enforcement action pursuant to 49 CFR part 31; and,
3. Prosecution pursuant to 18 USC 1001.
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ATTACHMENTS
Attachment 2.1 Organizational Chart
Attachment 2.2 DBE Directory
Attachment 2.3 Overall Goal Calculation
Attachment 2.4 Breakout of Estimated Race-Neutral & Race-Conscious Participation
Attachment 2.5 Form 1 & 2 for Demonstration of Good Faith Efforts
Attachment 2.6 Certification Application Forms
Attachment 2.7 Procedures for Removal of DBE’s Eligibility
Attachment 2.8 Regulations: 49 CFR Part 26
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Attachment 2.1
ARC Organizational Chart
ARC Board of Commissioners
Douglas R. Hooker
Executive DirectorOffice of Executive Director
Brittany Zwald
DBELOFinancial Services
I. Emerson Bryan
DirectorCenter for Business Services
Christopher Burke
ManagerGeneral Services
Diane Pelletier
ManagerFinancial Services
Greg Mason
ManagerHomeland Security and Recovery
Kathryn Lawler
ManagerAging and Health Resources
Ray Randolph
ManagerInformation Technology Services
Robert LeBeau
ManagerWorkforce Solutions
Steven McClure
ManagerTalent Management
Julie Ralston
DirectorCenter for Strategic Relations
Liz Sanford
ManagerCommunity Engagement
Paul Donsky
ManagerCommunications and Marketing
Scott Haggard
ManagerGovernment Affairs
Mike Alexander
DirectorCenter for Livable Communities
Cain Williamson
ManagerMobility Services
Dan Reuter
ManagerCommunity Development
John Orr
ManagerTransportation Access
Katherine Zitsch
ManagerNatural Resources
Mike Carnathan
ManagerResearch and Analytics
I. Emerson Bryan
Deputy Executive DirectorOffice of Executive Director
I. Emerson Bryan
DirectorCenter for Community Services
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Attachment 2.2
DBE Directory
http://www.dot.ga.gov/doingbusiness/dbePrograms/Pages/default.aspx
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Attachment 2.3
Section 26.45: Overall Goal Calculation
Amount of Goal
ARC’s overall goal for FY 2016 is the following: 15.64% of the Federal Financial assistance we will
expend in DOT-assisted contracts.
Methodology used to Calculate Overall Goal
Local Market Area
The local market area or relevant market is typically established by the geographical area
representing 70-80 percent of an entity’s commercial activity based on bidders, vendors or
awardees, with bidders being the preferred measure of determining relevant market. Zip codes
provided in a firm’s address information is utilized to determine its location.
An analysis of all three sources of data is provided below. Based on the analysis, the local market
area has been determined to be Fulton County, Georgia.
Bidder data reflects Fulton County as the local market at 58.38 percent. Bidder data was
derived from ARC Comprehensive Planning contracts data. A small set of large
engineering firms consistently bid on ARC opportunities. These national firms primarily
bid and contract on ARC opportunities through their Atlanta offices. Award and vendor
data also were reviewed, as sub-bidder data was not complete.
Awardee data reflects Fulton County as the local market at 75.26 percent. The remaining
24.74 percent was awarded to firms outside of the State of Georgia.
Vendor data reflects ARC’s 10-county transportation planning MPO as the local market,
representing 73.72 percent of vendors. The Vendor data is based on ARC’s Prospective
Consultants List. While this list is sometimes utilized, the bidders list more accurately
reflects those firms who are ready, willing and able to do business with ARC.
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Table 1a: Local Market Area
Based on Bidders
County Within Georgia Count Percentage
Fulton 115 58.38
DeKalb 9 4.57
Gwinnett 5 2.54
Cobb 4 2.03
State 6 3.05
Nation 58 29.44
Totals 21 100.00
Source: ARC Comprehensive Planning Contracts Data, Hathor Strategic Consulting, Inc.
Table 1b: Local Market Area
Based on Award Dollars
FY 2013 through FY 2016
Dollars Percentage
Fulton County $4,796,324 75.26%
Outside GA $1,576,970 24.74%
Total Contracts $6,373,294 100.00%
Source: ARC Comprehensive Planning Contracts Data; ARC Compilation Data; Hathor Strategic Consulting, Inc.
All dollars are allocated in either Fulton County or Outside GA
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Table 1c: Local Market Area
Based on Vendors By County
County Within Georgia Count Percentage
Cherokee 6 1.19%
Clayton 7 1.38%
Cobb 39 7.71%
DeKalb 55 10.87%
Douglas 9 1.78%
Fayette 7 1.38%
Fulton 193 38.14%
Gwinnett 42 8.30%
Henry 13 2.57%
Rockdale 2 0.40%
Totals within 10-County Atlanta RC Area
373 73.72%
Bartow 1 0.20%
Coweta 1 0.20%
Forsyth 1 0.20%
Walton 2 0.40%
Totals within ARC’s 18-County MPO for Transportation
378 74.70%
Bibb 2 0.40%
Bulloch 1 0.20%
Carroll 1 0.20%
Chatham 5 0.99%
Clarke 1 0.20%
Columbia 1 0.20%
Habersham 1 0.20%
Houston 1 0.20%
Meriwether 1 0.20%
Union 1 0.20%
Totals within the State of Georgia 393 77.67%
Outside State of Georgia 113 22.33%
Total 506 100.00%
Source: ARC Professional Consultant’s List for Comprehensive Planning; Hathor Strategic Consulting, Inc.
10 County Atlanta RC Area: Cherokee, Clayton, Cobb, Dekalb, Douglas, Fayette, Fulton, Gwinnett, Henry, Rockdale; 18 County Atlanta MPO Area: 10 County Atlanta RC Area + Barrow, Bartow, Coweta, Forsyth, Newton, Paulding, Spalding, Walton
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Anticipated Federally-Funded Contracts for FY 2016
ARC anticipates contracting or grant activity in the amount of $2,110,000 in FY 2016. These
dollars represent only contracting or grant activity where there are meaningful opportunities
for DBE participation and are funded by FTA or FHWA. The activity listed below falls into the
following NAICs codes:
541330—Engineering Services
511210—Software Publishers
541320—Landscape Architectural Services
Table 2: Anticipated Contracts and Subgrants for FY 2016
Contracting Activity Project Description Contract Amount
Procurement One-Click Software $40,000
Procurement Regional Transportation Technology Plan $75,000
Procurement Regional Transit Plan $625,000
Procurement Land use study $120,000
Subgrant North Fulton County Transportation Plan $1,250,000
Total Dollars $2,110,000
Source: ARC, Hathor Strategic Consulting, Inc.
Baseline Availability
DOT measures availability, by including firms who are ready, willing and able to provide services
to an agency. Ready, willing and able are those firms that exist and actively seek to do business
with ARC, and have the capacity to perform on ARC’s federal-assisted transportation-related
contracts. DOT allows agencies to calculate availability based on five different methodologies.
The methodology utilized here is the Census-based availability analysis of comparing, by NAIC
code, the relative availability of DBEs, based on the Georgia Department of Transportation DBE
Directory, to the total pool of available contractors, as represented in the U.S. Census County
Business Patterns for the identified local market area. In order to properly reflect the impact of
each project on the overall availability calculation, the percentage of total work is established.
Multiplying the project percentage of work by the DBE/CBP availability calculation results in a
weighted availability measure. The resulting baseline availability is 11.89 percent.
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Table 3: Baseline Availability Calculation (Fulton County)
NAICs
Code
Project Description Contract Amount % of
Work
DBEs CBPs Weighted
Availability
511210 One-Click Software $40,000 1.89 3 114 .026*1.89
0.04914
541320 Study of Area
Around Transit
Signage
$120,000 5.69 14 37 .378*5.69
2.15082
541330 Regional
Transportation
Technology Plan
$75,000 3.55% 31 348 .109*3.55
.38695
541330 Regional Transit
Plan
$625,000 29.62% 31 348 .109*29.62
3.2286
541330 North Fulton
County
Transportation Plan
$1,250,000 59.25% 31 348 .109*59.25
6.4582
Total Dollars $2,110,000 100.00% 11.88681
Source: ARC, Hathor Strategic Consulting, Inc., CBP, 2014
Adjusted Availability
In considering whether to adjust the baseline availability calculation of 11.89 percent, ARC Past
Participation for the last three years was considered.
Over the past three years, ARC had an average goal of 15.1 percent. However, its average DBE
participation for the same period was 19.38 percent. Thus, ARC exceeded its DBE goal by about
4.28 percent over the 3-year period.
For the purposes of adjusting the baseline availability measure, ARC will utilize ARC’s Historical
DBE Participation.
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Consultation
TO BE COMPLETED
At the time of this submittal, we have received/have not received any formal written responses.
Calculation of the 2016 DBE Goal
ARC calculates the 2016 DBE Goal as outlined below:
Baseline availability: 11.89 percent
Adjustment factor to be used with baseline availability: 19.38
Adjusted DBE Goal calculation: 11.89 + 19.38/2 = 15.64
Public Participation
TO BE COMPLETED
Table 4: ARC Past DBE Participation
FY 2012 – FY 2015
Year DBE Goal Historical DBE
Participation
2013 15.1% 21.95%
2014 15.1% NA
2015 15.1% 16.81%
15.1% (Average) 19.38% (Average)
Source: ARC, Hathor Strategic Consulting, Inc.
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Attachment 2.4
Section 26.51: Breakout of Estimated
Race-Neutral & Race Conscious Participation
ARC will meet the maximum feasible portion of its overall goal by using race-neutral means of
facilitating DBE participation. Contract goals may be used to meet any portion of the overall goal
that the ARC does not project being able to meet using race neutral means. Contract goals may
be established on contracts with subcontracting opportunities and need not be established on
every contract. 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).
ARC uses the following race-neutral means to increase DBE participation:
Encourage prime contractors to subcontract portions of their work that they would
normally perform in-house.
Encourage local governments and non-profits receiving ARC sub-grants on which they will
utilize consultants to include DBEs in the pool of potential vendors from which they solicit
services.
Ensure that the DBE website is updated with available opportunities for DBE-owned and
other small business firms in the community.
Conduct pre-bid seminars for DBE and small business firms on contracts that have a high
degree of specialized technology.
Outreach to DBEs to register on ARC’s Prospective Consultants List and to meet with the
DBE Liaison Officer to discuss their services and experiences.
The following is a summary of the basis of our estimated breakout of race-neutral and race-
conscious DBE participation:
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ARC exceeded its established DBE goal utilizing race-neutral means in 2 of the 3
years reported, with the third year having no federal dollars expended. As such,
ARC anticipates achieving its goal of 15.64 percent through race neutral means.
ARC will review its performance semi-annually through its reporting on Form 4630
to determine if race-conscious means are necessary to achieve its overall goals.
In order to ensure that our DBE program will be narrowly tailored to overcome the effects of
discrimination, if we use contract goals, ARC will adjust the estimated breakout of race-neutral
and race-conscious participation as needed to reflect actual DBE participation (see 26.51(f)). ARC
will also track and report race-neutral and race-conscious participation separately. For reporting
purposes, race-neutral DBE participation includes, but is not necessarily limited to, the following:
DBE participation through a prime contract a DBE obtains through customary competitive
procurement procedures; DBE participation through a subcontract on a prime contract that does
not carry a DBE goal; DBE participation on a prime contract exceeding a contract goal; and DBE
participation through a subcontract from a prime contractor that did not consider a firm’s DBE
status in making the award.
ARC will maintain data separately on DBE achievements in those contracts with and without
contract goals, respectively.
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Attachment 2.5
Forms 1 & 2 for Demonstration of Good Faith Efforts
These forms will be included in a Title VI and DBE Attachment to all ARC bids and proposals.
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 and submits documentation
demonstrating good faith efforts.
Name of bidder/offeror’s firm:
By (Signature) Title
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FORM 2: LETTER OF INTENT
Name of bidder/offeror’s firm:
Address:
City: State: Zip:
Name of DBE firm:
NAICS Code:__________________________________________
Address:
City: State: Zip:
Telephone:
Description of work to be performed by DBE firm:
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
The bidder/offeror is committed to utilizing the above-named DBE firm for the work described
above. The estimated dollar value of this work is $ _.
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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)
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.
(Submit this page for each DBE subcontractor.)
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Attachment 2.6
Certification Application Forms
Certification forms are available at
http://www.dot.ga.gov/doingbusiness/dbePrograms/Pages/default.aspx
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Attachment 2.7
Procedures for Removal of DBE’s Eligibility
See http://www.dot.ga.gov/doingbusiness/dbePrograms/Pages/default.aspx
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Attachment 2.8
Regulations: 49 CFR Part 26
http://ecfr.gpoaccess.gov/cgi/t/text/text-
idx?c=ecfr&tpl=/ecfrbrowse/Title49/49cfr26_main_02.tpl