CM-2025-068 - 3/14/2025ROUND ROCK TEXAt)
City of Round Rock
Disadvantaged Business Enterprise Program
(DBE)
2025 - 2027
R0 ROUND ROCK
IDES
Updated March 2025
Grantee 1D_ 6631
POLICY STATEMENT
Objectives and Policy Statement
Section 26.1, 26.33
The City of Round Rock (City) has established a Disadvantaged Business Enterprise (DBE) Program
in accordance with regulations of the U.S. Department of Transportation (DOT, 49 C.F.R. Part 26.
The City will receive Federal financial assistance from DOT and as a condition of receiving this
assistance the City has signed an assurance that it will comply with 49 C.F.R. Part 26.
It is the policy of the City to ensure that DBEs have an equal opportunity to receive and participate in
Federally assisted contracts for Transit Services. It is also the City's policy with regard to Transit
Services
A. To ensure non-discrimination in the award and administration of DOT assisted contracts.
B. To create a level playing field on which DBEs can compete fairly for DOT assisted contracts.
C. Implement the DBE Program plan in accordance with applicable law.
D. To ensure only firms that fully meet 49 C.F.R. Part 26 eligibility standards are permitted to
participate as DBEs.
E. To help remove barriers toward the participation of DBEs in contracts, including Federally
assisted contracts.
F. To have a Small Business provision for DOT assisted contracts without regard to DBE
certification.
G. Monitor and enforce the requirements of the DBE Program on Federal Transit Administration (FTA)
assisted contracts.
The Transit Coordinator has been designated as the DBE Liaison Officer and is responsible for
implementing all aspects of the DBE Program. Implementation of the DBE Program is accorded the
same priority as compliance with all other legal obligations incurred by the City in its financial
assistance agreements with DOT.
The City has disseminated this policy statement to the City Council, and all transit -related components of
the City. The city will post this statement on its website to reach DBE and non -DBE business communities.
By signature of the DBE Policy Statement, the City gives it assurance to FTA to comply with 49 CFR Part
26.
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SUBPART A -- GENERAL REQUIREMENTS
Objectives — Section 26.1
The objectives are found in the policy statement on the first page of this program.
Applicability — Section 26.3
This policy will apply to all funding received from any federal agency for Transit Services.
Definitions -- Section 26.5
The City accepts the definitions contained in 49 CFR Section 26.5 for this program plan.
Non -Discrimination Requirements - Section 26.7
The City 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
C.F.R. Part 26 on the basis of race, color, sex or national origin.
In administering its DBE Program, the City will not, directly or through contractual or other arrangements,
use criteria or methods of administration which 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.
Record Keeping Requirements — Section 26.11
Reporting to FTA - Section 26.11(b)
The City will report DBE participation to FTA on a biannual basis using the Uniform Report of DBE Awards
or Commitments and Payments form. These reports will reflect payments made to DBEs on DOT -assisted
contracts and will be uploaded on the Transit Award Management System. These reports will reflect
payments actually made to certified DBEs on FTA assisted contracts. The reports will not include
information on contracts the City may execute using only local funds. Should the City procure any transit
vehicles using FTA funds, the Transit Coordinator will report the federally funded procurement by
submitting the required Transit Vehicle Manufacturer (TVM") form, or such other documentation as may
then be required, to the FTA Office of Civil Rights within thirty days of making the award.
Bidders List — Section 26.11(c)
The City will create and maintain a bidders list. The purpose of the list is to provide as accurate data as
possible about the universe of DBE and non -DBE contractors and subcontractors who seek to work on
state or federally assisted contracts and for helping to achieve overall goals. The bidders list will include
the name, address, DBE and non -DBE status. The bidder's list is not an endorsement of DBE or non- DBE
firms. Reporting may be annually, however, inclusion to participation is ongoing during the program year.
The City will obtain the above information by requiring all prime contractors bidding on DOT assisted
contracts to submit a DBE Certification Form and Intent to Perform at the time of submitting its
bid/proposal. The forms must be completed by the prime contractor and all subcontractors who submitted
a bid to the prime for the contract.
Federal Financial Assistance Agreement — Section 26.13
Assurances — Section 26.13(a)
The City 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 City 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 City's DBE Program, as
required by 49 CFR part 26 and as approved by DOT, is incorporated by reference in this agreement. The
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 City of its failure to carry out its approved program, the
Department may impose sanctions as provided for under 49 CFR 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.).
Contract Assurance: Sections 26.13(b) and 26.53(h)
We will ensure that the following clause is placed in every DOT — assisted contract and subcontract:
The contractor or subcontractor shall not discriminate on the basis of race, color, national origin or sex in
the performance of this contract. The contractor shall carry out applicable requirements of 49 CFR Part
26 in the award and administration of DOT — assisted contracts. Failure by the contractor to carry out
these requirements is a material breach of this contract, which may result in the termination of this contract
or such other remedy as the recipient deems appropriate, which may include, but is not limited to:
• Withholding monthly progress payments.
• Assessing sanctions.
• Liquidated damages and/or
• Disqualifying the contractor from future bidding as non -responsive.
Section 26.15 - Exemptions or Waivers — Section 26.16
The City understands we can apply for an exemption or waiver from any provisions to Sub Parts B and C
of 49 CFR Part 26 including but not limited to, any provisions regarding administrative requirements,
overall goals, contract goals or good faith efforts. In the event the City requests an exemption or waiver,
the City will follow the procedures in section 26.15 and the request will document the special or exceptional
circumstances for exemption or waiver being requested.
SUBPART B - ADMINISTRATIVE REQUIREMENTS
DBE Program Updates — Section 26.21
The City expects to receive a grant for $250,000 or more in FTA planning, capital, and/or operating
assistance in a federal fiscal, the City will continue to carry out this program until all funds from FTA
financial assistance have been expended. The City will provide to the FTA updates representing
significant changes in the program on as needed bases and routinely every three years.
Policy Statement — Section 26.23
The signed Policy Statement is provided on the first page of this program plan and will be available on the
City's web site.
DBE Liaison Officer (DBELO) — Section 26.25
The City has designated the following individual as the DBE Liaison Officer (DBELO):
Edna Johnson
3400 Sunrise
Round Rock, Texas 78665
512.671.2888
ejohnson@roundrocktexas.gov
In that capacity, the DBELO is responsible for implementing all aspects of the DBE Program and
ensuring the City complies with all provisions of 49 C.F.R. Part 26. The DBELO has direct,
independent access to the City Manager concerning DBE Program matters. An organization chart
displaying the DBELO's position is shown below.
The DBELO is responsible for developing, implementing, and monitoring the DBE Program, in
coordination with other appropriate officials, such the Procurement Office and finance department.
The duties and responsibilities of the DBELO include the following:
1. Gathers and reports statistical data and other information as required by FTA.
2. Works with the City management to set overall triennial goals.
3. Works with procurement to contact DBEs on the TUCP list with TxDOT for available
opportunities.
4. Analyzes the City's progress toward DBE goal attainment and prepares shortfall analysis.
5. Monitors contracts with DBE participation for compliance with the DBE program requirements.
6. Provides DBEs and Small Business with information through the City website where they may
obtain assistance.
7. Communicate with DBE's and business organizations to inform them of upcoming
opportunities.
Organization Chart
DBE financial Institutions — Section 26.27
It is the policy of the City of Round Rock to investigate the full extent of services offered by financial
institutions owned and controlled by socially and economically disadvantaged individuals in the community,
to make reasonable efforts to use these institutions, and to encourage prime contractors on DOT -assisted
contracts to make use of these institutions.
Prompt Payment Mechanisms - Section 26.29
Prompt Payment — Section (26.29(s)
The City will include the following clauses in each FTA-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 City. The prime contractor agrees further to return retainage payments to each
subcontractor within 30 days after the subcontractor's work is satisfactorily completed. Any delay or
postponement of payment from the above referenced time frame may occur only for good cause
following written approval by the City.
The City has established the following mechanisms to monitor and enforce prompt payment and return
of retainage:
1. The bidder shall provide the DBELO with a copy of DBE subcontracts or purchase orders upon
request. The subcontracts between the contractor and its subcontractors must contain the
above reference prompt payment clause as set forth herein.
2. During the term of the contract and when there is DBE participation, the prime contractor shall
submit a monthly DBE Contractors Payment Report Form to the DBELO.
3. The prime contractor must maintain records and documents of payments to DBEs for three
(3) years following the performance of the contract. These records will be made available for
inspection upon request by any authorized representative of the City or DOT.
4. Upon completion of the contract where there is DBE utilization and prior to final payment, the prime
contractor shall submit the DBE Contract Close-out Statement of Compliance form to the DBELO.
The City has several remedies available to enforce the DBE utilization and prompt payment and return
of retainage requirements which includes but not limited to, the following:
1. Withholding monthly progress payments.
2. Disqualifying the contractor from future bidding as non -responsible, and/or
3. Delay final contract payment until compliance with this section, if needed.
Directory — Section 26.31
The City uses a directory developed and maintained by the Texas Department of Transportation (TxDOT)
to identify 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. The Directory is available online on the TxDOT Disadvantaged & Small Business Enterprise
Programs.
Overconcentration — Section 26.33
During preparation of the overall triennial DBE goal, The City will assess whether there is an
overconcentration of DBEs in certain types of work as to unduly burden the opportunity of non -DBE firms
to participate in this type of work. If there is a possible overconcentration, the City will consider varying
our use of the type of work to establish the individual DBE contract goals and the triennial DBE goal.
Currently, the City has not identified that an overconcentration exists in the types of work that the City
solicits from DBE subcontractors.
Business Development Program — Section 26.35
The City has not established a business development program. We will re-evaluate the need for such a
program every three years.
Monitoring and Enforcement Mechanisms — Section 26.37 & 26.53
The City will follow the following monitoring and enforcement mechanisms to ensure compliance with 49
CFR Part 26.
The City will bring to the attention of the DOT 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 department or Program
Fraud and Civil Penalties rules) provided in Section 26.109.
The City has a monitoring and enforcement mechanism to verify that work committed to DBEs at contract
award is actually performed by the DBEs. The City will keep a running tally of payments made to DBEs
(Section 26.29) for work performed. The City will also contact each DBE contractor to ensure payment is
received in a timely manner (30 days) after the invoice is sent. The City will also monitor the work of the
DBEs, in association with a contract, to ensure the DBE firm is performing the work.
Fostering Small Business Participation — Section 26.39
The City is committed to fostering small business participation in its procurement. Participation of SBE's
Is incorporated into this DBE program in accordance with 49 CFR Part 26.
The City will include in contract clauses, the request to bidders on large contracts to identify subcontract
opportunities appropriate for small business participation. The City will also refer SBEs to the SBA and
encourage SBEs to pursue procurement opportunities by registering their interest through the City's
website.
SUBPART C — GOALS GOOD FAITH EFFORTS AND COUNTING
Set -Asides or Quotes — Section 26.43
The City does not use quotas in any way in the administration of this DBE Program.
Overall Goals — Section 26.45
A description of the methodology to calculate the overall goal and the goal calculations can be found in
the DBE Goal documentation.
In accordance with Section 26.45(f), the City will submit its overall goal to FTA by October 1 st every
three (3) years, current goal setting period is for FFY2024-2026. The City may adjust the three-
year overall goal during the three-year period to reflect changed circumstances, or as requested
by FTA. Before establishing the overall goal every three years, the City will consult with the Census
Bureau, TXDOT and minority and women businesses to obtain information concerning the
availability of disadvantaged and non -disadvantaged businesses, the effects of discrimination on
opportunities for DBEs, and the City's efforts to establish a level playing field for the participation
of DBEs. Based on the City's vendor's list, which includes DBEs and non -DBEs, the City will send
a notice to these firms requesting input.
2. Following this consultation, the City will publish a notice of the proposed overall DBE goal and
methodology and post a notice of the proposed overall goal on the City's website. The proposed
goal and its rationale are available for inspection during normal business hours at our principal
office informing the public that the City will accept comments on the goals for 30 days from the
date of the notice. The notice must include addresses to which comments may be sent and
addresses (including the office and websites) where the proposal may be reviewed. The DBE
3. Program Plan will also be posted on the City's website.
The City's overall goal submission to FTA/DOT will include a summary of information and comments
received during this public participation process and our responses. The City will begin using the overall
goal on October 1 of that year, unless the City receives other instructions from FTA.
Meeting the Overall Goal —Section 26.47
If the awards and commitments shown on our Uniform Report of Awards or Commitments and Payments
at the end of any fiscal year are less than the overall goal applicable to that fiscal year, the City will provide
assurance to FTA that we are implementing our DBE program in good faith. We will prepare a shortfall
analysis to:
1. Analyze in detail the reasons for the difference between the overall goal and our awards and
commitments in that fiscal year; and
2. Establish specific steps and milestones to correct the problems identified in our analysis and to
enable us to meet our goal for the new fiscal year.
If needed, we will prepare the shortfall analysis and corrective action plan with timetables and have it
available by the last working day in December in which the shortfall occurred. The analysis will be
available to FTA upon request.
Transit Vehicle Manufacturers Goals —Section 26.49
The City will require each transit vehicle manufacturer, as a condition of being authorized to bid or
propose on FTA-assisted transit vehicle procurements and to certify that it has complied with the
requirements of this section. Alternatively, the City 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 in complying with this element of the program.
Race -Neutral Measurers — Section 26.51 (a-c)
The City's DBE Program is designed to be race -neutral, and its overall DBE participation goal will similarly
have a DBE race -neutral goal. If an annual review of the City's DBE participation in its contracts indicates
a need to consider race -conscious goals. The City will follow the guidelines in 26.51(d-g) to establish
race -conscious measures.
Race -Conscious Participation through Contract Goals — Section 26.51 (d-g)
The City will use contract goals to meet any portion of the overall goal, the city 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. We will establish contract goals only on those
DOT -assisted contracts that have subcontracting possibilities.
Good Faith Efforts Procedures — Section 26.53
Demonstration of good faith efforts Section 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 49 CFR Part 26.
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.
We will ensure that all information is complete and accurate and adequately documents how the
bidder/offer meets the DBE goal or demonstrated a good faith effort to meet the goal before we commit to
the performance of the contract by the bidder.
For discussion on Section 26.53, a bidder has the same meaning as a proposer or offeror. Bid has the
same meaning as purchase order or cost proposal. A contractor has the same meaning as a construction
contractor, prime consultant or material supplier, unless specified differently.
Award of Contract when the DBE Contract Goal is Met: Section 26.53(a)(1)
In those instances where a contract -specific DBE goal is included in a procurement/so I i citation, the
City will award the contract to a bidder who documents that it has obtained sufficient DBE participation to
meet the goal. The bidder will submit the DBE Commitment form with a copy of the DBE quote within
5 days of bid opening to the DBELO. See Attachment 4 or DBE Quote Confirmation form.
Award of Contract when the DBE Contract Goal was Not Met and a Demonstration of Good Faith Effort
was made Section 26.53(a)(2)
In those instances where a contract -specific DBE goal is not met, the City will evaluate the bidder's
good faith effort documentation to determine if adequate good faith efforts were made to meet the DBE
goal.
The bidder will submit the DBE Commitment form with a copy of the DBE quote; and good faith effort
documentation with related supporting documents within 5 days of bid opening to the DBELO.
Information to be submitted — Section 26.53(b)(2)
The City treats bidder/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:
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 confirmation from the DBE that it is participating in the contract as
provided in the prime contractor's bid; and,
5. Include a copy of the DBE quote.
Demonstration and Evaluation of Good Faith Efforts: Sections 26.53 a 2 and c
The DBELO is responsible for determining whether a bidder who has not met the contract goal has
documented sufficient good faith efforts to be regarded as responsive to the DBE requirements. The City
treats bidders' compliance with good faith efforts' requirements as a matter of responsiveness.
The bidders will complete and submit the DBE Good Faith Effort form and associated documentation;
DBE Commitment form and DBE quotes within 5 days of bid opening to the DBELO. The process
used to determine whether good faith efforts have been made by a bidder will include consideration of
the following:
A. Documentation that the bidder attended a pre -bid meeting, if any, to network with DBEs on
subcontracting opportunities under a given solicitation.
B. Documentation that for at least 5 business days before bids are due, advertisements were placed
in publications that DBEs use to find sub bid opportunities. The advertisement should include but
not be limited to the description of the project; subcontracting opportunities; date the sub bid
is due, who to contact at the bidder's office on questions regarding the project plans and
specifications, bidder's subcontract conditions and other pertinent project information that will impact
the sub bid price and sub bid conditions.
C. Documentation that written solicitations were sent to sufficient number of DBEs, who could
reasonably perform the subcontracting opportunities. The written solicitation will provide
similar information as included in the notice of publication and where the DBE may obtain
business service assistance in order to prepare the sub bid.
D. Documentation on the follow-up efforts made with DBEs who did not respond to the initial
written solicitation for sub bids. Documentation to support the initial written and follow-up
solicitation will include a list of DBEs contacted, copy of written information to DBEs and general
contract requirements and the result of the solicitation, to include DBE's comments.
E. Documentation of efforts made to assist the DBEs who requested assistance in obtaining bonding
or insurance or other bidding assistance such as equipment, supplies, materials or related
assistance or services.
F. Documentation of efforts to utilize the services of minority/women/small business
organizations, community and contractor groups to locate qualified DBEs.
G. Documentation that the bidder has broken out contract work items into economically feasible
units in fields where there are available DBE firms to perform the work.
H. Documentation for each DBE bid that was rejected, the reason the DBE bid was rejected.
The DBELO will analyze the information for truthfulness, completeness and that it adequately
documents the bidder's good faith efforts.
If the DBE goal was met and/or a demonstration of good faith effort was made, the bid package will
be forwarded to the City's Procurement Officer for further bid processing.
If the DBE goal was not met and the bidder did not demonstrate adequate good faith efforts, the DBELO
will prepare a report of findings and submit it to BTD's Procurement Officer for further processing. The
bidder may request an Administrative Reconsideration meeting.
Administrative reconsideration — Section 26.53(d)
Within 15 days of being informed by the City 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 DBELO or to a reconsideration official who has not played any
role in the original determination that the bidder/offeror did not document sufficient good faith efforts.
As parl of this reconsideration, the bidder/offeror will have the opportunity to provide written documentation
or argument concerning the issue of whether it met the goal or made adequate good faith efforts to do so.
The bidder/offeror will have the opportunity to meet in person with the DBELO officer and the
reconsideration official to discuss the issue of whether it met the goal or made adequate good faith efforts
to do. The City 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.
Good Faith Efforts when a DBE is being replaced/terminated on a contract — Section 26.53 and
The City will require a contractor to make good faith efforts to replace a DBE that has 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 City 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 City 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 Contract Administrator 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 Contract Administrator may issue a termination for default proceeding.
Counting DBE Participation — Section 26.55
The City counts DBE participation toward overall and contract goals as provided in 49 CFR 26.55
SUBPART D - CERTIFICATION STANDARDS S POCEDURERS
Unified Certification Programs — Section 26.61 & 26.73
The City will utilize the State of Texas Unified Certification Program (TUCP) administered by TxDOT. The
TxDOT UCP has an approval UCP and USDOT has certified their certification standards and procedures
to make certification determination as required in section 26.61 through 26.91
The City will also rely on the list of DBE -certified companies maintained by TxDOT to determine those
firms eligible to participate as DBEs. For information regarding the certification process or to apply for
certification for Transit Services, firms should contact one of the following:
• City of Houston at: http://www.houstontx.gov/obo/index.html
• City of Austin at: http:/twww.ci.austin.tx.us/smbr/
• Corpus Christi Regional Transportation Authority at: http://ccrta.org/abouttdbe/
• North Central Texas Certification Agency at: http:/twww.nctrca.org/
• South Central Texas Certification Agency at: http://www.sctrca. org/
• Texas Department of Transportation
In the event the City of Round Rock proposes to remove a DBE's certification, it will follow procedures
consistent with 26.87 through the TUCP.
SUBPART E — COMPLIANCE AND ENFORCEMENT
Information, Confidentiality, Cooperation — Section 26.109
The City will safeguard from disclosure to third parties' information that may reasonably be regarded as
confidential business information, consistent with Federal, state, and local law.
The City will cooperate fully and promptly with DOT and other government agencies in an investigation
related to compliance and enforcement of 49 CFR Part 26,
The City will not intimidate, threaten, coerce, or discriminate against any individual or firm for the purpose
of interfering with any right or privilege secured by 49 CFR Part 26 or because the individual or firm has
made a complaint, testified, assisted, or participated in any manner in an investigation, proceeding, or
hearing under 49 CFR Part 26.
ATTACHMENTS
Attachment A - Monthly Reporting Form
Attachment B- Contractor/Respondent Certification
Attachment C- DBE Subcontractor Certification
Attachment D- Small Business Subcontractor Certification
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