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ARTBA/AGC Contractor Survey on DOT Local Hiring Pilot Program

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ARTBA Contractor Survey Highlights Concerns with DOT Local Hiring Proposal

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ARTBA/AGC Contractor Survey on DOT Local Hiring Pilot Program

  1. 1. L» V , ‘ Transportation Builders THE ASSOCIATED GENERAL courrucrors or AMERICA .1: Association QII= |i1¥Pe°ir| =- Quililv Proi= ds- "--we (V American Roaddt of Amerjca €92‘? May 6, 2015 United States Department of Transportation Docket Management Facility 1200 New Jersey Avenue S. E. W12—140 Washington, D. C. 20590-0001 Re: Docket ID Number DOT-OST-2015-0013, Geographic-Based Hiring Preferences in Administering Federal Awards Our two national associations, the American Road & Transportation Builders Association (ARTBA) and the Associated General Contractors of America (AGC), previously submitted individual comments for this docket. Today we present this joint supplementary submission based on a recent survey of transportation construction firms who are members of either or both of our associations. In this survey, we sought to quantify some of the concerns about local hiring mandates referenced in our previous comments, as well as those offered by our chapters and member-firms. A total of 327 companies responded to the 10-question survey, which is a strong showing and demonstrates the significant concern within the industry about this issue. We are attaching the full survey results, including open-ended comments from the last question. Additionally, we would be happy to provide more detail from the survey as needed. The following are some highlights: In terms of demographics, about two-thirds of the respondents were prime contractors, with the remainder subcontractors or firms who fill either role from project to project. About 48 percent were union contractors, 45 percent open shop and the remaining seven percent work either way based on the local circumstances. 0 Smaller contractors comprised a significant portion ofthe respondents. More than 36 percent reported that within the past two years, their firm's average size federal-aid transportation construction contract was less than $5 million. About three-quarters were $25 million or less in average project size. ° About 35 percent of the respondents reported they had participated in or bid on at least one state— or | ocal| y—funded project in their area with a local hiring preference over the past two years. Another 15 percent were aware of such projects but had chosen not to
  2. 2. bid on them, and the remaining 50 percent were unaware of any such projects in their area. Of the respondents who had experience with local hiring preferences, three-quarters (more than 76 percent) reported the mandate had added "significant costs” to the pro'ject. Among all respondents, about three-quarters (more than 74 percent) reported they would add costs to their respective bids if a local hiring requirement were included. Only about 5 percent said they would not add notable costs. The remainder (21 percent) said they would need more information about the exact requirement. We then provided the respondents with a short list of potential concerns about a local hiring requirement, including the option that they would have "no major concerns" about complying with one. The firms were asked to mark all items that applied to them. 0 Nearly 85 percent believed that local hiring would "likely add significant costs to the project. " 0 More than 86 percent of the union contractors responded that a local hiring requirement "may conflict with union hiring provisions in my company's collective bargaining agreements. ” o More than 83 percent of all respondents believed it would "likely lead to adding employees who are not necessary for the project. " 0 Almost 80 percent reported safety concerns because ofthe need to hire new employees with inadequate training or experience. 0 Only about five percent had no major concerns about a local hiring requirement. More than 58 percent of respondents reported their respective firms had participated in voluntapy efforts to hire local residents, low-income workers, veterans or similar targeted candidates for transportation construction employment. This shows the industry's existing, widespread and ongoing commitment to these objectives. These voluntary programs are typically integrated into a contractor’s business plan, which comprises community outreach, recruitment and training consistent with its overall standards. In some cases they involve a partnership with local unions. These are distinct from local hiring mandates which often include penalties for non—compliance, as well as the likelihood of added and unnecessary costs as described elsewhere. As shown elsewhere in this survey, these mandates can also negatively influence competition by driving down the pool of interested bidders on these projects. We asked whether a local hiring preference on a federal-aid project would change the likelihood of the respondents’ bidding on it. More than 43 percent responded they would be less likely to bid. (The number was 47 percent among the smallest contractors. ) More than 47 percent said it would depend on the project's location and other specifics. Less than three percent said they would be more likely to bid. This
  3. 3. demonstrates the significant effect these mandates would exert on com petition, especially among the smaller firms who are critical to the industry. 0 Finally, we provided the respondents an "open—ended” opportunity to add their comments. More than one hundred did so, and we are including them in the report verbatim. The responses represent a variety of viewpoints, but the overwhelming majority express strong opposition to local hiring preferences. Given that the current administration has spent much of the past six-plus years promoting — quite justifiably — the economic potential of transportation construction projects, it makes no sense to ignore the voices of those charged with actually delivering and maximizing those benefits. Thank you for considering this feedback provided by the transportation construction industry professionals we represent. Please let us know if we can provide further details from the survey. Additionally, both associations stand ready to facilitate opportunities for federal transportation officials to confer with the industry as they consider the future of local hiring policy. Sincerely, ‘ /5/“*4” C0-22>; Richard A. Julian Brian Deery Senior Vice President for Strategic Initiatives Senior Director Managing Director, Contractors Division Highway and Transportation Division American Road & Transportation Associated General Contractors of America Builders Association
  4. 4. ‘E. Which classification most often describes your firm when working on federal-aid transportation (highway, bridge, transit, airport) projects? PRIHE CONTRACTOR SUBCOHTHACTDFI other (please Spar. -ii‘? ! 0% W55 28% 2;‘ :3 4;“ is 5.096 80% 70% 89% 90% It-D’. ’.~ Anlwer Choice: Responses PIMIE CONTRACTOR 68.4393 5: SUBCOIJTRAC TOR 29.545‘. other (waste specify) Iugpunsun 4.00% I . s. .. L _-_. .;;
  5. 5. 2. which of the foilowing best describes your firm? {MICK CONTRACTOR OPEN-SHOP COHTRACTBR VARIES, OEPEHDIHG on. .. 0% 10% EB-‘.1. was 40% 59% eats 7:2’. 30% 9015 100% Answer choices Responses UNION CONT RAICIDR 47.88% t E 5 OPE! » SW05? CONTRACTOR 44.92% I 45 VARIES. DEPEtfllIt: £5 on LOCNNON Aim OTHEIO FACTORS 7.38% ; .. ‘tutu! 325
  6. 6. 3. what is the approximate average size federal-aid transportation construction project on which your firm has worked in the past two years? Lesa mm :5 million $5 mliion to 31¢) mmran SW milluon so 525 mutton 325 million to $190 million Hora than Moo tnitlion 0'5 10% 20% 3: 5; 4095 50% E D'. ;~ 10% 80% 99% I 0056 one» or one :95 Responses Less than $5 Imlmm 36.315‘. " . ; 5:5 maiixou In SW million l? .23¥‘o $15) million to 525 rmlhan 20.00% 325 mutton to $100 mutton ruse more than stun miilron 15.82% . :,
  7. 7. 4. which of the toiiowing best describes your fimfs experience with focal hiring preference provisions on state- or iocaliy- funded projects over the past two years? 10 I13‘ KNOWKOGE. H. .. SOME Pl‘O.3ECTS Ii! 00 R. .. WE HAVE BEDODI AT LEAST OIIE. .. WE W03 OR PARTFCHMFED. .. ME 10" 20% 313% -: ‘.§'. .‘x 51;“; 55% 70% 30%| : 90% 100% 5-1ri'. $s'. ‘dr £r-. 'c. =.-: .~. - Respanses 3'0 ll‘! . no 1'*il0.ii€1‘ 5 ill Dill‘! MAlI| t£l'(S) l-IA! /T IMZUJDEO LOCM, IIIIWIG 49.595‘. PREFERENCES :60 some masters in 0IJi‘tflARKET1SH-iAVElHcLliDEn LOCAL memo PREFERENCES, BUT 15.22% 49 WE criosz not to an on HEM WE HAVE can on A1’ LEAST out PMJECT WHICH auccuoeo A LOCAL ammo PR£f£REIlc'c’. 14.91% BUT DIE HOT WI’? ! OR FARTICYMTE Ill T345 .305 WE ‘WON Of! PARTIZIPATEO N0 AT LEAST ORE PROJECT WITH A LOCAL llfflilm PREIEHEHCE 20.19% ifi. r'&! _rar
  8. 8. 5. If you participated in a project with local hiring or similar preferences during the past two years, which of the following best describes your firm’s experience, related to the overali costs of the project? "IE1! 1.{? «ihr1 i‘. i4!2.‘1‘l'. '»-. IKE LGCRL IQNHG. » Til! 1.96311. HINEJS. ,. ffif 1.0L‘fit Ii! R1.‘. '(«'-_. . WE HAVE Vii” i"AflflC1PATEG~ . 5% 35% 19.335 , ’;{§°»'p £333 SE31: éfiia ? fi"'ei>, 3&3“-is S. ;i’. - ‘. iT*3‘i5 Amwar chums flzesficatu THE men KIIIIIG lfl-. LL'mfl: ‘.. *Ji'T ‘tflfiili SCEOIIFIQADIT CD51 5 T0 IKE $’fi0JECl' 21,71‘. : . ‘_ THE LDCAI. 33511311‘: |'lImi3R£Mfll‘l’ AIJIEB f.1I! fll.1Ai, EZOSTS 10 THE FROJECT 6,99‘. - HIE LOCAL mums ntauzamenr mmow nun costs To TM M19126? MM- Tfli’ 4..0CAi. HIRING EEBIIIREMEKT SAVEO COSTS ON THE PROJECT I: I.W'”o WE HAVE HOT PMITICIPATEB fll §’ROJEC1' S FINN LOCAL IHIIIHG REQUIREMENTS 61.34%: ' 1 '4'
  9. 9. 6. in developing a bid for a prefect that had a iocal hiring or similar requirement, which of the following describes your film's likely approach? WE ‘WOULO HOT ADD iiO'i'ABLE. .. VIE DIGULD A90 COSTS 1'0 ‘HIE. .. DON'T SHEWIDEPEHDS. .. €‘. ‘;- I63: 20% 2:3‘? 2-: 40% 59% 60% 7056 3995 80% 1903 Answer cliches -Rescrmsea we 'b’: :D’x‘>LD MOT ADD NOTABLE COSTS To THE BID SECAUSE or was R£0ulREO.1ENT 4.57%; 15 w; W031 LD AB! ) costs To THE BID To Account FOR IIICREASED Risa AN! ) TEMNING 14.1-Ii. Assoclfiin WITH THE LOCAL mass. Mm, -on Possiati LIOUIBATED DAMAGES FOR 23-8 ! £O! i~COl. ‘.PLlMiC£ IJGWT Il. lwW1£IElPENl}S OH THE EXACT HIRING REQUIHEHEWIS 21.48% 58 ’. ; 1:. 3;!
  10. 10. 7. which of ‘(me following concerns - if any — would your firm have about pariicipating in a project with a local hiring or similar requirement? (check all that apply) YME HIKING EEQUMEMEHT. .. ‘HIE HIRINS REQUIREMENT . .. SHE mum; REGUIREMEIIT flit fllllllm nt= ,oum: n£u1:. . HIE tllmuc REQHEREMEIIT WE WOULD save no IIAJOR. .. {liner (please av: prelim Wlé 13‘ J; 20% 30% nlflfig ‘. -2'-‘. .. 50% NE; 53!; E 3‘: TGIF; fifififlfif Gilbfiii Réiwi-#335? THE ammo BEGUISEIRHT WILL LIKELY ADD (343515 To THE PROJECT 84.57% THE HIRING REQUIREMENT MAY CONFLICT VIIITII IJHIOIE HIRING PROVISIONS ill MN 46.60!- comwlws COLLECYWE BARGAIHDIG AGREEMERT s THE «mac Rfllllliifilnilfl MAY CAUSE as To IJISPLISCE CURRENT EMPLOYEES WHO” WE 33.02% WDIILD OTDIERVVISE USE ON THE 9ROJEC1’ me lllfllflfi Riilllliklililfllf WILL IJKEDJI LIEAD 10 Annette EMFLOYEES WEE ARE NOT 125413 HECESSARY FOR we PROJECT . .. THE mama Rfiflmllfiflfillf MAY £. ‘Al. I$£ $4F€’i"r coucenus AS HEW EMI't. OY£€$WI‘I’H 70.3%. : ilIADEOuAT£ TRACKING on EXPERIHICE WILL BE WORKING on THE PROJECT . 3 WE WORLD HAVE NC? MAJOR C0-IZEERN ii ABOUY Sltcll A HIIINIG REG| IIFl£MElfl' 6.56% other BIIQIUG spasm-3 9.5(u . ' =
  11. 11. B. In the past two years. has your firm participafied in any VOLUNTARY efforts to hire Inca! residents. low-income workers. veterans or similar targeted candidates? V! S 610 NOT Sulki J >12’- . ‘.fi-i4 ‘. £~'_ £092 5435’; ‘', ‘‘. ‘’I. : 70% 39% E33. ‘. C!J-‘. ‘.- flmsvi-: r thmsns féesnnustzi YES $3.511». NO 31.15%. 80T SW25 1I3.2l}'. t
  12. 12. 9. if USDOT allows local hiring or similar preferences on a federal-aid project, will your firm be more or less likely to bid on it’? H5 55 LIK£LY TO BID 1 DVIAR. HIMRG PROV£Sl0!: ‘. ‘1L . . DEFEND! ON THE PROJECTS. .. MON‘. IJXELY TO I 3%: 1 0'1. . .". .'. 'l€. « ZHH6 -'-‘«: ..'€. '. $335: 60% e". "‘: ; B016 9056 169% Answer chums Responses MORE LIKELY 70 B10 2.13% LESS LIIELV Y0 EID 403.3-0-'6 4 4 LOCAL illR§€HG ? ROJlSlGlJ WOULO IAQKE HO DIFFERENCE £a'. €fl”. a . , Bifiillbs Oil ‘HIE PROJECTS I. x>I.7lfl ION Aim Ofllill SFECWQCS £J.0I5€. ii: ’¢. ,'_4~ Q10 10. If you have any additional comments about any of these issues, please provide them here: a Answered: 109 o Skipped:218 Being a union contractor, local hiring only works if the unions are willing to participate with the hiring process and trained employees are available. Safety and training are critical.
  13. 13. 5/5/2015 7:33 PM In an uncertain time regarding the long-term viability of the Highway Trust Fund this Local Hiring Preference seems like an absolute waste of money. There is no way that this program will do anything other than raise overall project costs. 5/5/2015 2:16 PM Our company invests in the training of our employees not only for the technical aspect of their work but also for jobsite safety. We have a very low turnover of employees and have worked to add Veterans to our workforce when an opening does arise. A program like this is not good fit for us or for the industry. 5/5/2015 10:13 AM Employees should be hired on qualifications on my job with out regard to any preference. 5/5/2015 8:48 AM I think it is a terrible idea for the Federal Gov. to add this regulation. 5/4/2015 11:30 AM With the industry facing a worker shortage now, this seems to be a issue that will only curtail and not promote industry worker growth. Qualified personnel will be difficult to hire and retain if a local hiring preference is implemented. 5/4/2015 9:54 AM By having local hiring requirement on these projects we would decrease the local unemployment rate and add a much needed increase to the Baltimore areas economy. 5/4/2015 9:41 AM Government should be focusing on spending the tax payers‘ dollars as efficiently as possible, not loading up projects with requirements to meet social agendas which drive up the costs. 5/4/2015 9:17 AM Local hiring preferences will add significant costs and safety issues. It does not create jobs because it would necessitate laying off existing employees. 5/1/2015 5:36 PM A primary concern for contractors is hiring people with unknown skills/ safety awareness.
  14. 14. 5/1/2015 4:48 PM I would not want this program to become like many of the others where the rules are twisted around and consultants make money trying to "help" with compliance. I would be interested in local, not local and disadvantaged. 5/1/2015 4:24 PM The local hiring requirement typically is only a political benefit. The basis to provide is purely so politicians can say they brought work to their districts. The projects should be built with most efficient cost method, not in the best interest of the politician. 5/1/2015 3:57 PM They should also require that the contractors be local not just the workers. That way more of the funds stay within the area of the project. 5/1/2015 2:07 PM Unemployed "local hiring" personnel should list themselves with the Union jurisdiction for the project and the Union can provide them with assistance within the apprenticeship program. By no means we believe this should be mandatory on any contracts - no matter who is fimding the job. As it is, Contractors take all the risk but now to also have Contractor's take on further risk with inexperienced labor forces. It is not a business fiiendly initiative and horrible for the user and taxpayer. Will the funding agency and OSHA be OK if the quality and safety of the work is not as per contract? The means and methods are responsibility of the contractor - including who should work for them. 5/1/2015 1:44 PM All our employees are specialized and require years of experience. If we have to hire someone for job specific requirements, they would be simply added cost to the job. 5/1/2015 1:36 PM Many jobs performed by laborers and operators are highly specialized and that pool of workforce is already quite small. I don't see how many of the needed skilled workers would be available within a small hiring area. 5/1/2015 12:51 PM If this requirement would cause us to layoff longtime employees I would be very much against it. We have some long time employees that always travel with our company to wherever the work is at. If the projectt requires additional help other than regular employees we always try to hire locally.
  15. 15. 5/1/2015 11:50 AM we are a specialized contractor. traveling all over the midwest taking our trained and loyal employees all over. we hire local as much as possible for our non-critical equipment. 5/1/2015 10:39 AM Tax money comes from the public. The public should have an equal opportunity to participate. 5/1/2015 9:55 AM See my docket comments. 5/1/2015 9:15 AM It is hard enough to locate qualified employees without putting more mandates on the employer. 5/ 1/2015 8:54 AM I really think it is a bad idea to include local hiring requirements. This is so contrary to have a stable work force, and being able to provide employment continuity to our existing employees. 5/1/2015 8:23 AM We bid productivities knowing our workforce and their abilities. Local hiring may impact these productivities at the bid table. 5/ 1/ 2015 7:56 AM With the oil and gas boom in eastem Ohio, the pool of qualified employees is very limited in that area. It would probably be hard to find trained employees so that would lead to a lot of untrained, perhaps unqualified employees on projects 5/1/2015 5:29 AM Free Trade! 4/30/2015 9:34 PM whenever you add additional requirements to a job you add cost 4/30/2015 4:42 PM Why would we think that these individuals could perform safety sensitive task with minimal training and experience? Do they have an interest in doing this work?
  16. 16. 4/30/2015 4:28 PM As a union contractor, our hands are tied as to whether the local unions can provide workers with the specific profile requested. 4/30/2015 3:43 PM Although I understand the intent of this requirement, just putting bodies on a project, with no skills, no training, no experience working in such high risk environments, is not the answer. Those that want to make construction trade jobs their livelihood need to be trained and educated first in all ways related to the work involved. Also, I don't agree with ANY boundaries as to where people live being "equal opportunity" for all. I feel dollars would be best spent in education. ..not mandates. 4/30/2015 3:07 PM Some projects are large enough to accommodate some unskilled locals, but most are not. Unskilled workers are always a safety risk due to lack of experience and awareness. 4/30/2015 2:43 PM The concept of mandatory hiring reeks of constitutional conflict. This issue is not similar to the attempt to mitigate discriminatory practices which propagated DBE requirements. The proposed local hiring mandate would not aid in the regulation of illegal practices (i. e. race/ gender discrimination). I understand the potential for economic gain by a local community, but not when the funding would likely be from sources outside of the community. Why rob the economic gain from other communities. .. i. e. payroll taxes, et. al. 4/30/2015 2:05 PM All of our employees are local. 4/30/2015 1:24 PM Bid on an City of Akron project with a 50% local hire requirement. The liquidated damages are almost unlimited and a high risk for the contractors. Cities need to start with low percentages of labor (5%) to make sure the workforce is available. If you have a project in multiple cities with labor requirements you could end up firing and hiring new workers for a large portion of you work force, just because you crossed a city line. That is not cost efficient for the project. 4/30/2015 1:14 PM How will this work with other EEO goals. Which one will take precedent? This is very much a quality and safety concern. There are very few jobs that involve "unskilled" labor. A program aimed at training the local workforce so they can market their skills would be a better use of the
  17. 17. governments time and money. Forcing contractors to hire a certain percentage does not make an individual marketable on their abilities but on their place of residence. 4/30/2015 1:03 PM We have bid & done work in Baltimore City which had local hiring requirements. 4/30/2015 12:56 PM AS A HIGHWAY LIGHTING SUBCONTRACTOR WE MAY WORK ON MULTIPLE PROJECTS IN VARIOUS CITIES EACH WEEK. WE MAY WORK ON MULTIPLE PROJECTS DAILY. IT WOULD NOT BE POSSIBLE FOR US TO MEET MULTIPLE REQUIREMENTS WITH A SINGLE CREW AND WE WOULD NOT WANT TO LAY OFF ONE LOCATIONS EMPLOYEES WHEN TRAVELING TO ANOTHER CITY OR COUNTY ON A DAILY BASIS. 4/30/2015 12:52 PM Local hiring mandates would be detrimental to rural based contractors. Rural contractors have to be able to work in a variety of locales, as their own local community cannot support them with available work opportunities. One very troubling aspect. ..many contractors purchase goods and services as part ot the contract that come from many a diverse source. For example, a local municipality may want a local hire preference but the materials to supply the project come from out of the locale perimeter. A rural based contractor may buy many goods fiom office supplies, CPA and legal services, insurance and bonding services, raw materials such as concrete, stone from a community that would in tum deny the contractor to be competitive due to hiring rules. I am a small rural contractor who sees these things popping up all over in small communities. it is enough to lose a low bid; it is enough to not bother bidding. 4/30/2015 12:47 PM In our construction market the local hiring preference is on tribal land contracts. The contractor can have a core crew that can work on the project all other positions need to be local unless the position cannot be filled. 4/30/2015 11:58 AM Although we are not a contractor we do take into consideration hiring local talent when it is available. The majority of our project have Federal Funds associated with them and we will adhere to any requirements. 4/30/2015 11:40 AM Added local hiring preferences needs to be taken into consideration with already stringent requirements for DBE and MBE subcontracting and the cost, quality and administrative burdens created by these requirements. The projects where we have dealt with local hiring there is often a
  18. 18. lack of qualified workers. It becomes necessary to simply add bodies that are non-productive and unsafe to meet these requirements. Additionally, it takes jobs away from otherwise qualified individuals who may live just outside the jurisdictional boundaries. Creating a local hire requirement will not lead to increased employment, it simply adds cost to the project and displaces another employee in the area, its a net zero equation on affecting employment. 4/30/2015 11:27 AM We self perform 80% of our Work we can't displace or layoff current employees to accomplish local hiring goals - if we need to hire, we would work with the community to hire local if qualified. 4/30/2015 10:59 AM Most of our regular employees cannot afford to live in the jurisdiction where most of our projects occur. I also irks me that people think we can just hire anybody to fill construction jobs that require real training and experience or the consequences can literally be deadly. 4/30/2015 10:35 AM This is ridiculous. We can not even fill the positions we have open now. 4/ 30/2015 9:49 AM As a business owner, please do not add anymore government regulations as to who we have to hire. It is OUR risk not the governments. 4/30/2015 9:38 AM American Companies compete by hiring and retaining Qualified employees. We do not need USDOT help to do this. 4/30/2015 9:30 AM We take great pride in our long-term employees, specifically hourly tradesmen. Mandating local hires would be detrimental to loyalty, which we believe is paramount to success in a family owned business. 4/30/2015 9:16 AM Continually adding restrictions will do nothing but add costs; local hiring may address issues in an immediate area, but will hurt the overall process of what a competitive market is. 4/30/2015 8:39 AM we do not need more regulations the contracting process is already too burdensome.
  19. 19. 4/30/2015 8:33 AM most construction related businesses especially highway construction service a large geographical area and would have to hire a local unexperianced and dangerous crew for every job they get a contract for thus eliminateing full time jobs for all the workers they employ this idea has been tried for the last 30 plus years and has been a complete failure wasting money that could be saved for the taxpayers. 4/30/2015 8:32 AM My name is Robert Colella, I am the General Superintendent for Defoe Corp and am in charge of all field operations. I have been with Defoe for 35 years and have done every job on my way up. Defoe Corp is a major Heavy Highway GC in the NY Metro area. Worlcing on bridges and roads with and around heavy machinery is extremely difficult and needs trained workers who have many years of experience to do the work safely. We utilize the same core personnel from job to job to maintain a safe workplace and have competitive pricir1g. Many of our employees are from the surrounding area. Forcing untrained workers to be hired will lead to hire costs and many potential safety issues. 4/30/2015 8:20 AM Severe 1:ruck driver shortage already! 4/30/2015 7:29 AM A construction contractor working in the low bid competitive market offered on federal-aid projects must develop and maintain a team type skilled work force to compete on a continuing basis. As in all competitions it is the "team efforts" that will win. Mandatory introduction of new players will reduce efficiency and decrease productivity. The personal relationships developed in and arrrong construction crews are something not understood by those who have not personally experienced the difficult field conditions. 4/30/2015 7:00 AM Mandated hiring preferences especially with attached liquidated damages will actually work in reverse; meaning that due to the increased risk and our necessity to remain competitive, we would be forced to reduce our normal investments in hiring and training new employees which include veterans and low income individuals. 4/30/2015 6:13 AM This could help but not also WBe MBE one or the other might help get the black American back in our labor force . We have some great ones . Not make MBE rich that don't hire minorities 4/29/2015 11:40 PM
  20. 20. Individuals paying State and Local taxes should not be prohibited to work on certain projects due to their residence! 4/29/2015 9:36 PM Costs of complying with local or group hiring preferences increased costs by more than 15% 4/29/2015 6:22 PM This would be very bad for our company and our employees. It would be hard to pick up local employees for one job. Any kind of good employee is-not available at this time, so this would eliminate every bidder that is not already established in that area. 4/29/2015 6:01 PM The limited funds available for DOT projects are already spreading the work out. Our company is an ESOP and we retain our employees paying them to travel. This provision would require us to hire people specific to that area and then tenninate them when we work in a different area. Our long term employees would not be able to go to where the work is and we would be forced to let them go. 4/29/2015 5:54 PM Maybe make this preference an incentive and not a preference. If a contractor wants to go threw the added time, expensive and risk concerns, make an incentive for this added risk as opposed to mandating it for all contractors. 4/29/2015 5:28 PM We already have enough mandates from the State and Federal Government, we DO NOT need anymore. 4/29/2015 5:22 PM We want to bid on projects with local hiring requirements because the state money should local and spent in local communities. 4/29/2015 5:19 PM Met with our DOT last week, they are already fielding questions from local jurisdictions on including these on projects they are looking at in the future. 4/29/2015 5:10 PM
  21. 21. Govt needs to stay out of this altogether. Silly waste of time for Contractors and I think government needs to work more on funding so there are more projects to improve transportation and to put people to work to do these projects. 4/29/2015 5:07 PM USDOL already has requirements in place that provide for proper management of applicants/ personnel related to an employer's non-discriminatory practices, and companies working on Federal Contracts are also subject to OFCCP Regulations as well. These two entities are sometimes in conflict with regards to specifications and jurisdiction. Throwing in a THIRD layer of requirements, as well as a THIRD responsible party for monitoring will only complicate things. Who will be the "guardian of the process"? Which regulations will prevail? If Local Preference is imposed, and contractor is forced to hire local, will this cause potential discrimination against protected work classes? Will a Prime be able to justify potential US DOL violations as the result of contract specifications? We strongly disagree for federal contracts to carry any Local Hiring Preferences. 4/29/2015 4:38 PM I would tend to be more concerned that a local contractor could have an un-fair advantage if given preference, particularly if they are a large contractor. My opinion is cost for the project is likely to increase in that situation. 4/29/2015 4:32 PM The "Blanket Approval" for use of Local Hiring Preferences on Federal-Aid Transportation projects should not be contemplated. The Transportation industry requires trained, experienced, and Skillfill workers that are always aware of the inherent dangers associated with working in and around traffic. The mandatory implementation of Local Hiring Preferences will likely result in an increase of job related deaths, accidents, lawsuits, project costs, and serve as an eternal blemish on the history of the Transportation Industry. It would be appropriate however, to encourage and implement a pilot program on the Voluntary hiring of local residents, low-income workers, and Veterans. The quickest way to encourage involvement of a new program, is to provide an incentive for participation. Incentives can range from monetary to "bonus" points on Performance Grades. 4/29/2015 4:19 PM Most of our projects, whether federal, state, or local are shorty duration projects, almost always less than 60 days, most less than 20 days. Causes a real problem for us for all the reasons stated in #7 above. 4/29/2015 4:17 PM
  22. 22. 1 our area they tried one project that envolved the demo of a building. The project was terrrible and actually was on the news more than once with all the problems that occured. Main problem was inability to keep a workforce. 4/29/2015 4:16 PM Dangerous precedent 4/29/2015 4:13 PM Finding qualified personnel is already difficult this would make it even more difficult. 4/29/2015 4:11 PM This requirement would seriously hurt our Safety Program and also not allow us to use the best people who are safe and productive performing work. 4/29/2015 3:48 PM this would be a pain in the ass as every community could do this. How do you maintain safely trained crews for each and every community? 4/29/2015 2:43 PM I feel local hiring adds additional cost and risk to the project and perfer to bid with no local hiring provisions. 4/29/2015 2:05 PM strongly not in favor of seeing mandated local or low income employee hiring. Believe it will be detrimental to the quality cost of the project. 4/29/2015 1:34 PM We already hire locals and vets to our various branches not the job sites. That would be impossible for us. 4/29/2015 1:10 PM Local hiring mandates result in inferior class of employees who are often unreliable and lacking in experience. 4/29/2015 12:51 PM
  23. 23. FDOT ENCOURAGED US TO HIRE LOCAL IN THE PAST, THE LOCALS WE DID HIRE WERE NOT SUCCESSFUL DUE TO LACK OF EXPERIENCE AND NO DESIRE TO WORK THE WAY THAT IS NECESSARY IN HIGHWAY CONSTRUCTION. 4/29/2015 12:46 PM I don't like to told who I have to hire to work for my company. That should be my decision only. I could lose some valuable workers because of hiring requirements. 4/29/2015 12:40 PM This is not for "Free Enterprise", the risk of hiring locally would hamper our ability to compete as our increased costs for safety training and turnover that I have experienced in these type of programs are significant! l l! 4/29/2015 11:56 AM Local hiring preferences, while potentially well intended by those who don't understand the industry, are simply a bad idea. 4/29/2015 11:53 AM Required local hiring mandates place an undue risk on contractor's due to us being forced to hire persons with unlcnown safety practices and skill levels. Also, local manadtes will displace current employees who would typically be used on the project forcing us to potentially have terminate their employment. 4/29/2015 11:52 AM One of the major achievements of the Federal Aid program has been to reduce contract corruption. It is shocking what local agencies will, to this day, try to get away with, when the federal government is not looking over their shoulders. These types of local preference policies are a step in the wrong direction. They will only encourage behaviors that are otherwise non- existent within the Federal Aid system. 4/29/2D15 11:49 AM I do not believe local hiring is needed on Federally Funded Projects. Where we have local preference, we typically add profit with non—locals are bidding the same work, limiting competition. 4/29/2015 11:18 AM We would only bid on local preference projects that we had current employees to meet the "goals". We would not bid on projects where our current workforce does not meet the requirements
  24. 24. 4/29/2015 10:57 AM In regards to #8. While we try and hire local it needs to be understood that this should a choice and NOT a socialistic mandate. In regards to #9 this is a loaded question. I am a contractor, Ibid jobs and I complete the jobs I successfully bid. It is pretty simple. If the Government mandates who I have to hire I have two choices. Participate in the mandate or find another career. The bottom line is that if you mandate it, people are still going to bid jobs. It will just jack up the cost in most cases. 4/29/2015 10:50 AM Our experience is that local preference initiatives have the real effect of limiting competition and causing an increase in costs. 4/29/2015 10:34 AM training locals adds time, money and safety issues to each bid 4/29/2015 10:27 AM In our experience with local hiring we had to put great effort in finding people and then many were unreliable. It was a constant search and hiring process in order to meet our goal. 4/29/2015 9:34 AM Many of our employees have been with us for years. When provisions such as this become contract requirements and the locals being hired are aware of these provisions and our "need" for them, the quality of employee is diminished while the likelihood of an "injury" resulting in a Worker's Comp case greatly increases. 4/ 29/ 2015 8:44 AM Stop regulating our business. Free market capitalism is not healthy when govemment, who have not one clue as to the process of running a business, adds stipulations to our contracts: DBE, WBE, MBE, now local employees! We must have the latitude to hire the people that will perform not mandates that restrict that freedom. 4/29/2015 8:25 AM we need less goverment 4/29/2015 7:11 AM We bid Work with skilled union workers. We have trained our crews on safety and quality. Any changes to the hiring requirements will completely change our approach to bidding federally funded work
  25. 25. 4/28/2015 6:32 PM Our industry is currently suffering through a significant workforce shortage (a point easily proved through various statistics and media coverage). The free and open market has myriad opportunities for all people, without costly additional regulations. 4/28/2015 6:16 PM We do heavy and highway construction. We're also a union contractor. The vast majority of union members do not qualify as "local hires" due to the income restrictions. Most of the "local hire" applicants that meet the "low income" requirements have little construction experience, and those that do have some experience have primarily residential and light commercial construction experience. Without training, they are a danger to both themselves and others on the jobsite. There is an additional cost of training and additional risk regarding safety and j obsite accidents using inexperienced, low income, local residents that qualify for the program we have participated in. 4/28/2015 5:53 PM Local hiring requirements will likely run afoul of our union contracts and hiring procedures, force us to hire unnecessary unqualified and undertrained people but themselves and those around them at a substantial safety risk. These issues can be somewhat negated with enough time and money being expended which will be reflected in the increased cost of the project. The safety issue is paramount and the duration of these projects do not allow enough time for developing the necessary safety skills fro the previously untrained person. 4/28/2015 5:49 PM The added complexity will reduce the number of potential bidders. Additionally, reducing the mobility of employees will result in higher employee tumover, less continuity, increased safety risk, and much higher financial risk. 4/28/2015 5:34 PM We are a specialty subcontractor with a highly trained workforce that travels. These requirements will impact our ability to bid and execute projects in a cost effective and safe manner. 4/28/2015 5:29 PM Thanks to our local unions, we have competent, qualified, trained, safety oriented employees. I would not want to risk that. 4/28/2015 5:24 PM I could not bid. The risk would be too great.
  26. 26. 4/28/2015 5:10 PM It should be voluntary and not become a bureaucratic night mare to manage and only on specific projects not across the board. 4/28/2015 5:07 PM Union contractors can't control where the union people come from. In dense regions such as NY Metro, employees come fi'om all over so they can live where their lifestyle desires and have a livelihood. Regional contractors are already fighting with international contractors who can cut profit margins to the bones. Then, the M/ W/DN goals add firrther challenges which are significant. They want us to build top quality projects meeting the highest safety requirements but do it all cheaply AND meet all of the "goals" on top of it. What about the local/ regional contractors who essentially are "local" but risk getting filrther harnstrung by yet another requirement. 4/28/2015 5:04 PM local hiring and union hiring are separate issues and we would address them differently 4/28/2015 5:00 PM Generally we try to hire as many local qualified candidates as possible 4/28/2015 3:55 PM The govt. should cut off the "entitlement benefits" for those that are able to go to work. There are too many able bodied people that are unwilling to work because the govt. is keeping them up. There would be an abundance of available labor if the "freebies" stopped & those that could work would work. Currently in our area, there are too many available jobs not being filled. 4/28/2015 3:22 PM This would adversely affect our company because we perform such a specialized trade. 4/28/2015 3:13 PM Qualified cratt workers and supervisory people are difficult to hire and retain. Local preferences (in our case Tribal Employment Rights Oiiices) do not typically provide us with the correct pool of talent required to build a project, but when we do find a "gem, " we try to entice that person to work on other projects - which most likely will not be in the same location that we "found" that employee. 4/28/2015 3:06 PM
  27. 27. It would only complicate things and add expenses for small to medium sized contractors such as us. This is something that is not needed. 4/28/2015 3:02 PM enough social engineering already 4/28/2015 2:56 PM There are already enough mandated requirements on Federal projects without imposing this one. 4/28/2015 2:41 PM

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