Current Practices to Set and Monitor DBE Goals on Design-Build Projects and Other Alternative Project Delivery Methods (2015)

Below is the uncorrected machine-read text of this chapter, intended to provide our own search engines and external engines with highly rich, chapter-representative searchable text of each book. Because it is UNCORRECTED material, please consider the following text as a useful but insufficient proxy for the authoritative book pages.

63 Attachments Not Included WILLIAMS BROTHERS CONSTRUCTION CO., INC. DBE Performance Plan & Subcontracting Plan Project: Loop 1604 Western Extension Project Prepared by: Bob Lanham, President & DBE Compliance Manager Initial Draft: 10/22/2013 Revision 1: Revision 2: Revision 3: APPENDIX C Sample DBE Plan Submitted by Proposer in Response to a Design-Build RFP (Texas Department of Transportation Design-Build Project from 2013)

64 TABLE OF CONTENTS 1. Definitions ........................................................................................................................................................4 2. Policy Statement ..............................................................................................................................................4 3. Disadvantaged Business Enterprises (DBE) Commitment ............................................................................5 4. Anticipated Areas of Consulting & Contracting Opportunities .....................................................................5 5. Outreach ..........................................................................................................................................................5 6. Professional Services Procurement .................................................................................................................6 a. General .........................................................................................................................................................................6 b. Proposal Phase Solicitations ........................................................................................................................................6 c. Execution Phase Solicitations ......................................................................................................................................6 d. Proposal Evaluation & Negotiation ..............................................................................................................................6 7. Construction Subcontractor Procurement ......................................................................................................7 a. General .........................................................................................................................................................................7 b. Bid Package Development ...........................................................................................................................................7 c. DBE Identification & Solicitations ............................... ....................... .....................................................................................7 d. Proposal Evaluation .....................................................................................................................................................8 8. Subcontract Agreement ...................................................................................................................................8 9. Execution of the Work .....................................................................................................................................9 a. DBE Responsibilities ....................................................................................................................................................9 b. Administration .............................................................................................................................................................9 c. Direction and Management ...........................................................................................................................................9 d. Quality ........................................................................................................................................................................ 10 e. Environment ............................................................................................................................................................... 10 f. Safety .......................................................................................................................................................................... 10 g. Commercially Useful Function (CUF) ...................................................................................................................... 10 h. Assistance to DBEs .................................................................................................................................................... 11 10. Payment ......................................................................................................................................................... 11 a. Monthly Progress Payments & Reporting ................................................................................................................. 11 b. Withholding Progress Payments ................................................................................................................................. 12 11. Reporting ......................................................................................................................................................12 a. DBE Commitment Schedule ...................................................................................................................................... 12 b. Monthly Reporting Schedule ..................................................................................................................................... 12 c. Quarterly DBE Progress Tracking ............................................................................................................................. 12 d. Final DBE Report Schedule ........................................................................................................................................ 12 e. DBE Truckers ............................................................................................................................................................. 12

65 12. Good Faith Efforts Documentation ................................................................................................................12 13. Mentoring ......................................................................................................................................................13 14. Termination ...................................................................................................................................................13 15. Replacement ..................................................................................................................................................14 16. DBE Program Oversight ...............................................................................................................................14 Appendix # Description 1 Forms 2 Report Schedule 3 DBE Special Specification Exhibit 6 of DBA 4 Standard Professional Services Agreement 5 Standard Subcontract Document 6 Federally Required Provisions DBE Performance Plan & Subcontracting Plan 1. Definitions Design Build Agreement (DBA) Part of the Contract between WBCC and TxDOT that contains all of the general business terms and conditions that drive the execution of project Design Builder Williams Brothers Construction Co., Inc. (WBCC) Disadvantaged Business Enterprise (DBE) Certified firm in accordance with 49CFR26 and Exhibit 6 of the Design Build Agreement Instructions to Proposers (ITP) Part of the Contract between WBCC and TxDOT that contains all of the instructions necessary to sub- mit a responsive proposal to TxDOT and the required conditions of award and execution of the contract Joint Check Two-party check issued by WBCC to a subcontractor AND another party designated by the subcontractor Prime Contract (Contract) The collective contract between WBCC and TxDOT Professional Services Any design or technical services provided other than construction in the execution of the project that typically requires the possession of a license or certain credentials Project Loop 1604 Western Extension Design Build Project Proposal The document submitted by WBCC in conformance with the ITP, which was competitively scored against other shortlisted Proposers Qualification-Based Selection (QBS) Selection process for professional services that weights qualifications and credentials as well as price Subcontract The legal agreement between WBCC and a subcontractor Subcontractor A construction firm or professional service firm that is working under a specific agreement or con- tract with WBCC for the execution of a specific scope of work necessary for the successful com- pletion of the project Technical Provisions (TPs) Part of the contract between WBCC and TxDOT that contains all of the technical requirements of the project as stipulated by TxDOT For specific definitions regarding terms applicable to the DBE Program, please refer to Appendix 3 and 49 CFR 26 2. Policy Statement Williams Brothers Construction Company, Inc. (WBCC) does not discriminate against any subcontractor firm based on race, color, sex, ethnic origin, or religious background. WBCC does not tolerate any conduct in its workforce that discriminates against any subcontractor based on the same. WBCC actively supports and encourages the participation of disadvantaged business enterprises in the highway construc- tion industry. WBCC seeks to preserve its reputation of DBE program excellence by maximizing DBE participation throughout the project. All quotations will be treated fairly and confidentially.

66 Corporate past performance in the DBE Program is excellent, averaging 150% attainment of project goals. WBCC participates in outreach to underutilized businesses through the Texas Department of Transportations’ Office of Civil Rights (DBE Program). 3. Disadvantaged Business Enterprises (DBE) Commitment WBCC is committed to fully integrating meaningful DBE participation into our team for this TxDOT Loop 1604 Western Extension Project through outreach, technical assistance/supportive services, compliance monitoring, and reporting. WBCC proposes to accomplish maximum DBE participation through an organized outreach, solicitation, and subcontracting plan. This commitment is made in support of the project goal as stated in Section 7.1.1 of the DBA: The overall Project DBE participation goal is 8%, which includes design and construction. WB commits to: (1) Submitting commitments on DBE design firms within 60 days of NTP1 (contract execution) and (1) Submitting commitments on DBE construction firms within 60 days of reaching 100% design completion. WBCC is committed to implementing the project’s DBE program in accordance with the federal and local guidelines found in 49 CFR Part 26 and the TxDOT DBE program. The WBCC team is aware of its obligations as stated in 26 CFR 26.53(e) and TxDOT’s DBE Specification. WBCC is committed to compliance with all program regulations. This commitment will be supported by a quarterly tracking system to guide the acquisition of subcontractor services in the achievement of the project goal. See Section 11e for details. 4. Anticipated Areas of Consulting & Contracting Opportunities Signing Erosion Protection Design Survey support Illumination Erosion Protection Subsurface utility services Signals Erosion Protection Design support Striping Sanitary Sewer Environ support services Painting Sidewalk Utility relocation design Barricades Driveways Quality Services Guardrail Riprap Environmental Compliance Crash Attenuators Misc. Concrete Constr Quality Control Sod/Seeding Re-Steel (furnish & place) Constr Quality Acceptance Landscaping Geotechnical Services This list is not comprehensive but represents initial management view of possible project opportunities. 5. Outreach Our outreach programs in partnership with TxDOT will include: • Two DBE project information meetings. • Incorporation of opportunities in TxDOT’s project website. • Project and contracting advertisements in local and minority publications. • Collaboration with other organizations to present/advertise project opportunities • Collaboration with TxDOT’s Programs for DBEs, such as TAP, TBOD, and the local TUCP • Participation at DBE-related events and conferences. • Provision of project plans at plan rooms maintained by minority and women business organizations.

67 6. Professional Services Procurement a. General Professional services firms are chosen using a Qualification Based Selection process. The general steps followed are outlined below. The process is more subjective than construction subcontracting, which relies on prequalified firms. The criteria outlined in Section 6.d(1) must be evaluated and matched to the needs of the project and how all commitments are fulfilled. DBE professional service firms will have their certification verified. All firms must meet TxDOT criteria for performing design services. b. Proposal Phase Solicitations DBE firms that were identified as meeting the requirements of Section 6d below as well, as being available as exclusive partners during the proposal phase, were engaged by teaming agreements and participated in the proposal process. Subsequent to award, negotiations will be conducted with these firms. The following firms were included in our proposal and should exceed the goal associated with professional services: • SEA • Gunda • IDC • Alliance Geotechnical Group c. Execution Phase Solicitations (1) The solicitation of additional professional services may become necessary during the execution of the project for a variety of reasons, such as: a. Added scope to the project b. Scope that was not fully defined during the proposal preparation c. Additional assistance or resources were determined to be necessary to support the project schedule d. The inability to successfully negotiate a scope of service or fee with a previously selected firm. (2) A new solicitation will be issued for the services needed. The proposals submitted must be responsive to the solici- tation. The following section outlines procedures for the selection process. (3) Solicitations for proposals will be made based on need determinations discussed in the previous sections. Various resources will be used to target the subcontracting community, such as but not limited to: a. Use of our corporate vendor list b. Contacts developed from outreach events c. Use of TxDOT DBE directory d. Use of the TUCP, the local DBE certifying agency e. Coordination with other subcontractor advocacy groups (4) Any DBE firm selected must have its certification verified through the TUCP directory. d. Proposal Evaluation & Negotiation (1) The following criteria will be used for professional services: a. Ability to provide the number of qualified personnel to complete the required tasks on time. b. Possess the requisite licenses for both the firm and personnel to authorize participation.

68 c. Documentation of design project completion on time and within budget. d. Quality of previous project work completed, including references from past project owners (clients). e. Ability to start when required. f. Consideration of the DBE goal for the project. (2) Attempt to negotiate scope, terms, conditions, and price with the selected Proposer. (3) If the negotiations stall or fail, repeat the process. 7. Construction Subcontractor Procurement a. General It is prevalent practice in the design-build procurement process for the Design-Builder to solicit pricing from the subcontracting community based on 30% (or less) plans. This procedure puts subcontractors in financial jeopardy due to temporal variations, quantity uncertainty, material and commodity price escalations, and variability in the character and nature of the scope. WBCC’s approach will be implemented once subcontract packages have been designed to approximately 75% completion to allow for greater certainty in the bidding process. For subcontractors, this process eliminates financial risk and uncertainty on quantity/scope. Using this deferred procurement approach for the construction phase provides greater opportunity for the success of the subcontractors, especially DBE subcontractors. This process will be closely monitored and tracked. Refer to Section 11e for details. b. Bid Package Development (1) As described in Section 7a, excessive risk can be transferred to a subcontractor by asking for proposals on 30% plans. Our approach is to provide more fully developed plans to the subcontracting community prior to requesting price proposals. Ideally, the plans would be 75% complete prior to releasing. This may vary based on the type of work. (2) Bid packages will be developed and presented for price proposals in support of the overall project construction schedule. Bid packages can be made for a single phase or segment or for multiple phases. (3) Bid packages will be posted in our online plan room, which is a component of our document management system. These materials will be available free of charge to any interested subcontractors where they can view or print. File format will be PDF. (4) Our online system will have a consolidated e-mail address where all quotations will be sent for review. (5) For subcontractors without access to computers, Internet access, and e-mail, hard copies of the bid packages will be made available upon request. c. DBE Identification & Solicitations (1) As bid packages are completed, solicitations for price proposals will be made. Various resources will be used to target the subcontracting community, such as but not limited to: a. Use of our corporate vendor list b. Use of information from outreach events c. Use of TxDOT DBE directory d. Coordination with the TUCP, the local DBE certifying agency e. Coordination with other subcontractor advocacy groups

69 (2) Solicitations will contain the following information regarding the requested price proposal: • Project information • Scope or items of work • Date proposal is due • Where to view plans and specs • Where and how to submit price proposal • To whom the proposal should be directed • To whom all questions should be directed (3) First-time responders to a WBCC solicitation will be required to complete a subcontractor questionnaire and par- ticipate in an interview to determine qualifications, capabilities and capacity in order to avoid potential issues such as the DBE’s failing to perform a commercially useful function. (4) Time is of the essence on this project. Every effort will be made to allow two weeks to respond to any price proposal solicitation; however, this cannot be guaranteed. Exceptions may be granted on a case-by-case basis for noncritical items at the discretion of WBCC. (5) Responsiveness – We will attempt to contact any subcontractor that did not respond to the solicitation. The reason for not quoting, if provided, will be documented. d. Proposal Evaluation (1) Completeness – Each proposal will be reviewed for completeness. All pertinent contact information must be pro- vided by the subcontractor. (2) Scope – Any qualifications or exceptions included in the price proposal will be noted. A dollar value (positive or negative) associated with any proposal qualifications will be assigned to the proposal. (3) Pricing – Proposals will be ranked according to ultimate price/cost. (4) Negotiations – Should the price proposal contain undesirable qualifications or exceptions, an attempt will be made to negotiate a compromise. If opportunities exist for scope modification or expansion, this will be negotiated accordingly. (5) Selection – A successful subcontractor will be selected with consideration of the DBE goal for the project. 8. Subcontract Agreement a. Subcontract agreements shall identify, define, and include those specific services, items, terms, and conditions that are consistent with the contract and the scope of work, including anticipated duration. b. The subcontract will be prepared and submitted with all required conditions and attachments for execution. c. The following items are clearly defined and included in all professional services subcontracts: (1) Identification of parties (2) Definition of work (scope, methods, end results) (3) Definition of Client’s responsibility (4) Provisions for contract changes

70 (5) Compensation (6) Method of payment (7) Federally required provisions d. The following terms and items are included in all construction subcontracts: (1) Parties to the contract (2) Contract start and end dates (3) Scope of work, including deliverables (4) Payment due dates (5) Terms and conditions relating to premature contract termination (6) Terms and conditions relative to undue delays (7) Means to resolve claims and deputes (8) Indemnification terms and conditions (9) Federally required provisions e. Any exceptions taken by the subcontractor with regard to any of the business terms and conditions of the subcontract document will be negotiated (that is in the purview to negotiate). f. Upon complete execution of the document, a copy will be provided to TxDOT. g. See Appendix 4 for a blank “DRAFT” consultant agreement h. See Appendix 5 for a blank “DRAFT” construction subcontract i. See Appendix 6 for federally required provisions. 9. Execution of the Work a. DBE Responsibilities (1) Subcontracted work will be executed in a professional manner. (2) The subcontractor will be an independent business and employer under the laws of Texas and will assume all the rights and responsibilities accordingly. (3) The subcontractor will be required to diligently and faithfully execute the work covered by its agreement. (4) The subcontractor will comply with all of the requirements of its subcontract and the contract. b. Administration (1) The subcontractor will report monthly at an agreed upon recurring monthly date, its progress quantities for the previous pay period for verification by and concurrence of the Project Manager, Deputy Project Manager, or the Construction Manager.

71 (2) The subcontractor will be required to carry the requisite insurance outlined in the contract. Good faith efforts (GFEs) in accordance with 49CFR25, Appendix A, Item F must be followed prior to rejecting a DBE proposal for failure to provide insurance as outlined in the contract. (3) The subcontractor will comply with administrative obligations imposed by federal requirements. (4) The subcontractor will be required to submit any applicable reports, such as but not limited to: a. Monthly progress quantities b. Daily quality control reports c. Certified payrolls d. DBE participation reports c. Direction and Management (1) The subcontractor will receive overall schedule and work priorities from the Project Manager, Deputy Project Manager, or Construction Manager. (2) The subcontractor is an independent business and will be required to plan, manage, oversee, and execute their contracted work in accordance with project schedule and the direction of the Project Manager, Deputy Project Manager, or Construction Manager. (3) The subcontractor will be a licensed participant in the contractor’s document management software at a security level deemed appropriate by the Project Manager, Deputy Project Manager, or Construction Manager. d. Quality (1) The subcontractor will be obligated to abide by the Project Quality Management Plan (QMP). (2) The subcontractor will be accountable for its deficient work and responsible for the implementation of the approved correction or remedy. (3) The subcontractor will be responsible for initiating its own technical submittals associated with the items of work. e. Environment (1) Protection of the environment is a priority for every project. The subcontractor shall abide by the Project Compre- hensive Environmental Protection Plan (CEPP). (2) The subcontractor will be required to attend the project environmental briefing/training. (3) The subcontractor will be required to comply with all environmental commitments on the project that have direct bearing on its work. (4) The subcontractor will comply with all applicable permits, laws, and regulations governing this project and the work subcontracted. f. Safety (1) The contractor has a corporate goal of ZERO accidents. The subcontractor is required to have its own safety pro- gram or model one after the contractor’s. (2) The subcontractor will ensure that its safety program is no less stringent than the Project Safety & Health Plan. (3) The subcontractor will comply with the Project Safety & Health Plan.

72 (4) The subcontractor will participate in project safety briefings. (5) The subcontractor shall be responsible for the safety of its employees. (6) The subcontractor shall comply with all local, state, and federal safety requirements and regulations. g. Commercially Useful Function (CUF) (1) Field supervisors monitor DBE work performance to verify compliance with the subcontract document, paying particular attention to whether the DBE is using its own forces and equipment. Any activity of concern will be reported to the DBE Program Coordinator or DBE Program Manager. (2) Work with TxDOT on DBE work schedules so that a CUF review can be scheduled and conducted early in the project. (3) Follow up with TxDOT on CUF findings. (4) Assist TxDOT as necessary on CUF monitoring throughout the course of the project. (5) In the event of a non-CUF finding, consult with TxDOT on: a. Impacts to the project goal and the need for additional DBE credit. b. Whether other administrative actions are appropriate. h. Assistance to DBEs (1) WBCC shall not provide any assistance to the DBE in the general performance of its work. The term “assistance” is defined in the broadest possible sense: a. Labor, equipment, or materials b. Supervision c. Ordering materials for the DBE from WBCC suppliers d. Fuel e. Any other item one would reasonably expect a viable subcontractor to provide for themselves. (2) The only exceptions permitted by specification and allowed by WBCC are under emergency conditions in which: a. The safety of workers or the public is at risk. b. The work in progress is subject to a total loss (i.e., lose a concrete pour). c. The traveling public will be seriously impacted and excessive travel delays incurred. (3) In the event of any emergencies as defined by Section 9h(2), the Project Manager or designated representative is required to call in a report to the Compliance Manager outlining the circumstances and the assistance rendered. TxDOT will be notified immediately. The DBE Emergency Assistance Call-in Log (see Appendix 1—Forms) will be completed. The Compliance Manager will assess the value of the assistance. The value of the assistance will be deducted from the DBE’s monthly progress report. (4) WBCC serves as an advocate for all of its subcontractors (DBE and non-DBE) with TxDOT in the event of changes, change orders, or payment issues. (5) Joint Checks for DBEs a. The request for a joint check must emanate from the DBE and/or its supplier. The request must be on the DBE’s letterhead or equivalent. If no joint check agreement is provided to WBCC, utilize our version (see

73 Appendix 1—Forms). If a joint check agreement is provided by the DBE and/or its vendor, the Chief Financial Officer (CFO) must review and edit it as necessary to maintain compliance with the DBE special provision and to provide sound legal protection for WBCC. b. Prior to any joint check being issued, its use must be approved by TxDOT. CFO will prepare a request using Form 2178 (see Appendix 1—Forms) signed by the Compliance Manager. The form will be submitted to the TxDOT by fax or e-mail. Copies of the DBE’s request, the joint check agreement, and the associated Form 2178 will remain on file for audit purposes. c. CFO prepares the joint check in the amounts acceptable to the DBE and its supplier. The check will be sent to the DBE in a manner requested by the DBE (e.g., US Mail, Fed-Ex). All requirements shown on TxDOT Form 2178 will be followed as well as those outlined in governing laws, rules, and regulations. Under no circumstances will the check be mailed directly to the supplier or will the DBE be required to endorse the check on our premises for WBCC direct mailing to the supplier. 10. Payment a. Monthly Progress Payments & Reporting (1) Monthly progress payments will be made by the 10th business day following payment received by WBCC for the items of work performed by the subcontractor. (2) A number of instances can impact payment time that are outside the control of the Contractor or higher tier consultant: a. The failure of the subcontractor to provide an invoice in a timely manner. b. Quality issues with the subcontractor’s work. c. Apparent prompt pay or violations of other federally required provisions. d. Failure to pay vendors for materials purchased and used in the project. e. TxDOT’s failure to provide copies of pay estimates in a timely manner. f. Delays by TxDOT in payments to the Design-Builder. b. Withholding Progress Payments (1) Progress payments may be withheld for any violation or breach of a subcontract requirement, such as but not limited to: a. Failure to comply with prompt pay requirements b. Failure to be responsive to TxDOT or WBCC c. Failure to comply with any subcontract provision that creates noncompliance with the contract (2) Efforts by WBCC will be made to expeditiously remedy any impediments so that payments can be made as soon as possible. (3) Any payment dispute will be reflected and reported monthly on TxDOT form 2177.

74 11. Reporting a. DBE Commitment Schedule We will submit a DBE commitment Form SMS 4901, 4901-MS, or 4901-T as applicable to TxDOT (see Appendix 1— Forms) upon selection of DBE subcontractor. Progress toward goal attainment will be monitored. b. Monthly Reporting Schedule DBE monthly progress will be reported on Form SMS 4903 on or about the 15th of each month. Prompt Pay Certifica- tions, Form 2177 will be submitted by the 20th of each month (see Appendix 1—Forms and Appendix 2—Schedule). c. Quarterly DBE Progress Tracking A quarterly report will be generated (See Appendix 1—Forms), which will track commitments, progress, and projected outcomes for DBE participation. The report will track areas available for participation to guide solicitations when con- struction packages are ready for distribution. d. Final DBE Report Schedule We will submit Form SMS 4904 (see Appendix 1—Forms) providing the final DBE participation within 60 days after construction has been completed. e. DBE Truckers If truckers are to be used toward the project goal, Form SMS 2371 worksheet (see Appendix 1—Forms) will be used to track monthly utilization. A modified Form SMS 2371 may be used. In either case, the DBE trucker must sign the form. 12. Good Faith Efforts Documentation Documentation from solicitation process as described in Sections 6 and 7 will be maintained. Should it become nec- essary to submit a good faith effort demonstration, documentation in accordance with Exhibit 6 of the DBA shall be followed. (See Appendix 3—DBE Specification) 13. Mentoring a. As discussed in Section 9h, the level and type of assistance/mentoring that WBCC can provide is restricted by state and federal program regulations. To avoid contravening any programmatic rules, WBCC will work in collaboration with TxDOT. Jointly through TxDOT’s programs such TAP and TBOD, we will assess the needs of the participating DBE and small business firms by identifying areas of improvement. Training classes or workshops in collaboration with the same TxDOT programs will be offered to help them become better businesses. b. The needs assessment will determine: • The type of technical classes or workshops that need to be conducted • Whether there is a specific and recurring audience • Whether there is a genuine interest in attending by the DBE/small business firm, thus establishing frequency c. In addition to training provided through this contract, we will work as a conduit for information for TxDOT and other educational institutions that may offer training conducive to their needs.

75 d. We will collaborate with our insurance and bonding industry partners to integrate training on these financial issues with the DBE/small business firms. e. All training will be recorded digitally and uploaded to our electronic document management system. The training video files will be stored in “public” folders so that the training will be available to any and all interested firms. The videos will be available for downloading and sharing by the DBE/small business firms. f. Project briefings will be conducted with each DBE firm as it begins work on the project. Briefings will cover their responsibilities with regard to compliance with the Project Management Plan. Any performance issues will be addressed quickly to preclude any adverse impacts to quality and the financial well-being of the DBE. 14. Termination g. Termination for convenience of a DBE subcontractor is NOT allowed unless the prime contract is terminated for con- venience by the owner. h. Termination may occur due to the direction of TxDOT. i. Termination for breach of contract may be for any action(s), including but not limited to: (1) Safety/OSHA violations (2) Environmental violations (3) Illegal or illicit conduct (misappropriation, etc.) (4) Failure to perform work according to TxDOT specifications (5) Violation of DBE rules and regulations (e.g., commercially useful function) (6) Nonpayment of employees or bills (materials) (7) Nonresponsive to the project schedule (8) Failure to provide adequate resources (9) Unprofessional conduct (10) A subcontractor removal request by TxDOT j. Any actions that could lead to termination for a DBE subcontractor must be documented and forwarded to TxDOT. k. Adequate opportunities must be afforded to the DBE to remedy deficiencies in accordance with the terms of the subcontract. l. Consultation with and approval by TxDOT must occur prior to taking any termination action for a DBE subcontractor.

76 15. Replacement a. If the DBE is part of the project goal and the DBE quits or is terminated, WBCC should solicit new quotations for the remaining work from other DBEs or solicit quotations for other work available for DBEs. b. Submit to TxDOT for approval following the Contract Award procedures. c. If no DBEs can be found to fulfill the goal, document and submit Good Faith Efforts. (See Sections 6, 7, and 12 for procedures.) 16. DBE Program Oversight a. Corporate: (1) Compliance Manager – Robert C. (Bob) Lanham, PE, President (2) Program Administration – Corina Taylor, Admin. Asst. b. Project: (1) Project Manager – Leon Wright (2) Deputy Project Manager – Mac Qualls (3) Construction Manager – Keith Mittel (4) Document Manager – Lynette Birdsong