MBEWBE/Small Business Enterprise Procurement Program Advisory Committee - March 2, 2021

MBEWBE/Small Business Enterprise Procurement Program Advisory Committee Regular Meeting of the MBEWBE/Small Business Enterprise Procurement Program Advisory Committee - VIA VIDEOCONFERENCING

Agenda original pdf

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Versión en español a continuación. MBE/WBE and Small Business Enterprise Procurement Program Advisory Committee March 2, 2021 MBE/WBE and Small Business Enterprise Procurement Program Advisory Committee to be held March 2, 2021 with Social Distancing Modifications Public comment will be allowed via telephone; no in-person input will be allowed. All speakers must register in advance (March 1, 2021 by noon). All public comment will occur at the beginning of the meeting. To speak remotely at the March 2, 2021 MBE/WBE and Small Business Enterprise Procurement Program Advisory Committee Meeting, members of the public must: • Call or email the board liaison at Nakia James at (512) 974-9108 or nakia.james@austintexas.gov no later than noon, (the day before the meeting). The information required is the speaker name, item number(s) they wish to speak on, whether they are for/against/neutral, and a telephone number or email address. • Once a request to speak has been called in or emailed to the board liaison, residents will receive either an email or phone call providing the telephone number to call on the day of the scheduled meeting. • Speakers must call in at least 15 minutes prior to meeting start in order to speak, late callers will not be accepted and will not be able to speak. • Speakers will be placed in a queue until their time to speak. • Handouts or other information may be emailed to nakia.james@austintexas.gov by Noon the day before the scheduled meeting. This information will be provided to Board and Commission members in advance of the meeting. • If this meeting is broadcast live, residents may watch the meeting here: http://www.austintexas.gov/page/watch-atxn-live Reunión del MBE/WBE and Small Business Enterprise Procurement Program Advisory Committee FECHA de la reunion (March 2, 2021) La junta se llevará con modificaciones de distanciamiento social Se permitirán comentarios públicos por teléfono; no se permitirá ninguna entrada en persona. Todos los oradores deben registrarse con anticipación (March 1, 2021 antes del mediodía). Todos los comentarios públicos se producirán al comienzo de la reunión. Para hablar de forma remota en la reunión, los miembros del público deben: • Llame o envíe un correo electrónico al enlace de la junta en Nakia James at (512) 974-9108 or nakia.james@austintexas.gov a más tardar al mediodía (el día antes de la reunión). La información requerida es el nombre del orador, los números de artículo sobre los que desean hablar, si están a favor …

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Active 3rd Party Project Report original pdf

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Developer Project Name AA H A/NA WBE AA H A/NA WBE Contract Amount Contact Name SMBR Contact Sponsor Dept. Project Status % Expensed Incentive Amount Expenditures to Date (May extend past project completion date) Project Completion Date Consultant/ Contractor Project Type/ Phase Goal Type: C=Contract or P=Project Specific SMALL MINORITY BUSINESS RESOURCES DEPARTMENT ACTIVE THIRD PARTY - March 2021 PROJECT GOALS CURRENT PARTICIPATION (Goals Met to Date) MBE WBE MBE WBE Gensler Sports Design P 1.22% 2.90% 3.48% 3.72% 0.00% 20.41% 2.08% 3.61% $5,306,272.00 $4,614,945.84 Austin Stadco (formally Precourt Sports Venture (PSV)) Design- Miscellaneous P 1.22% 2.90% 3.48% 3.72% 0.00% 6.81% 0.83% 3.62% $1,363,812.60 $1,239,568.81 P 0.65% 1.90% 1.24% 0.91% 0.02% 0.74% 0.00% 3.60% $49,628,535.00 $47,194,459.00 P 2.04% 3.86% 0.16% 6.06% 0.00% 0.00% 0.00% 2.32% $7,956,908.00 $7,332,467.96 P 1.83% 4.70% 1.20% 1.80% 2.41% 0.30% 0.00% 1.54% $59,260,106.00 $57,352,181.49 Austin Commercial P 2.93% 2.89% 0.58% 1.13% 2.53% 6.30% 0.00% 0.45% $37,515,246.00 $35,278,520.46 Construction-RFP 1 Construction-RFP 2 Construction-RFP 3 Construction-RFP 4 Construction-RFP 5 Construction-RFP 6 Professional (Block 185 Misc D) Professional (Block 185 D) Construction (Block 185 C) Professional (Block 185 Misc D) Professional (Block 188 D) Design/Build Building II -4th Floor Reno P P C C CAAICON Q2 Stadium (Austin FC) Mike Rock Land Use Agreement 4/1/2021 P 1.73% 1.49% 1.00% 2.08% 0.07% 0.99% 0.00% 0.00% $12,818,527.67 $10,279,408.68 Jolene Cochran EDD P 1.69% 1.51% 1.00% 2.05% 0.06% 0.00% 11.79% 0.25% $15,506,009.00 $8,387,606.97 Greenwater Block 185 Misc D Trammell Crow C 2.90% 9.00% 4.90% 15.80% 0.00% 0.00% 75.84% 12.87% $273,126.00 $242,281.77 Design in progress 88.71% 4/1/2022 Green Water Treatment Plant Block 185 D STG Design P 2.90% 9.00% 4.90% 15.80% 0.00% 0.45% 0.24% 4.21% $3,682,442.96 $3,089,417.98 Design in progress 83.90% 6/1/2022 Greenwater Block 185-C DPR Construction C 2.70% 9.70% 2.30% 13.80% 0.00% 0.23% 0.01% 0.00% $242,397,885.58 $83,672,153.06 Trammell Crow Bryan Embrey/ Mark Fowler Construction in progress 34.52% 7/31/2022 Developer Agreement; Not applicable Greenwater Block 185 Misc D Trammell Crow 2.90% 9.00% 4.90% 15.80% 0.00% 0.00% 75.84% 12.87% $273,126.00 $242,281.77 Design in progress 88.71% 4/1/2022 Handel Architects/The KOR Group 2.90% 9.00% 4.90% 15.80% 0.00% 5.75% 0.30% 11.16% $2,039,345.00 $2,030,483.00 Design in progress 99.57% 3/1/2021 Green Water Block 188 Austin Commercial Construction (Block 188 C') 2.70% 9.70% 2.30% 13.80% 0.14% 1.24% 0.36% 2.01% $134,625,855.00 $127,934,950.01 Construction in progress 95.03% 3/1/2021 VISA Inc and VISA U.S.A. Global IT Center-Building 2 Gensler/DPR Construction 3.06% 1.42% 2.62% 0.67% $27,667,424.00 $27,667,424.00 Brooke Brindle/ Aimee D. Janousek/Darren Bonnet Construction …

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Austin LGBTBE Inclusion FAQs original pdf

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FREQUENTLY ASKED QUESTIONS What is the rationale for the inclusion of certified LGBT Business Enterprises (LGBTBEs)? The rationale is simple; our economy simply doesn’t work without full participation. Discrimination is not only morally wrong; it’s inefficient. Austin's economy will be strengthened as more citizens fully engage in building equity, creating jobs, and building sustainable economic strength. LGBT business owners pay taxes and create jobs in the same way that all small businesses do. They should have access to every opportunity to grow their enterprises, including contracting and procurement opportunities with their cities and states. Intentional inclusion efforts must be made in order for underutilized diverse communities to recognize and engage in these types of opportunities. The strongest economies are the ones that include and engage everyone. Including LGBTBEs will not detract or diminish the contracting opportunities for our friends already in the diverse business community. Adding more suppliers drives competition, lowers prices for taxpayers, and allows diverse communities to work together in order to grow the overall number of contracting opportunities and increase economic growth. Additionally, the LGBT segment intersects with all other diverse segments. Including LGBT people strengthens all other inclusion efforts; it will attract more people of color, more women, more people with disabilities, and more Veterans. Who else is implementing supplier diversity initiatives? Austin would be following in the footsteps of an ever-growing number of states, state agencies, counties as well as other cities. For LGBT business owners doing business with the State, supplier diversity initiatives provide fair access to business opportunities and cultivates innovation, creates jobs, and drives economic growth. In August 2019, at the 2019 NGLCC International Business & Leadership Conference in Tampa, FL, openly LGBT Mayor Jane Castor announced an executive order to include Certified LGBTBE® suppliers in her state. This order followed Mayor Eric Garcetti’s historic announcement to do the same in Los Angeles just days before. In 2018 and early 2019, NGLCC won the inclusion of Certified LGBTBE® suppliers in Orlando, FL; Nashville, TN; Baltimore, MD; Jersey State, NJ; and Hoboken, NJ, while also advancing statewide bills in New York and New Jersey. Currently, California, Massachusetts, and Pennsylvania also include Certified LGBTBE® suppliers in state procurement, along with major cities like Seattle, Newark, Columbus, and Philadelphia. A bill was introduced in the New York State Council to include Certified LGBTBE® suppliers in the largest economy in America, and is expected to pass …

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Certification Roll Report original pdf

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CERTIFICATION MBE/WBE ADVISORY COMMITTEE UPDATE FY 2021 Report Total number of Certification TYPES (Not number of firms) FY 2020 Oct-20 Nov-20 Dec-20 Jan-21 Feb-21 MBE WBE DBE/ACDBE (ACDBE Only) SBE Total Certification TYPES MBE Certifications by ethnicity Asian African-American Hispanic Native American Total WBE Certifications by ethnicity Asian African-American Hispanic Native American Caucasian Total DBE/ACDBE Certifications Asian African-American Hispanic Native American Non Minority Female Total Total Apps Annual Updates Recertifications DBE/ACDBE New Expansion of Services MBE/WBE New SBE New 730 635 514 88 152 2119 123 215 371 21 730 45 89 133 4 364 635 54 114 180 9 157 514 123 16 12 10 1 77 7 738 630 519 90 150 2127 124 220 373 21 738 45 91 133 4 357 630 54 115 184 9 157 519 121 20 17 10 1 70 3 729 617 511 90 150 2097 739 628 511 91 154 2123 747 632 513 91 155 2138 722 609 520 92 149 2092 121 221 366 21 729 44 94 131 4 344 617 53 115 178 9 156 511 112 14 10 9 0 74 5 123 223 372 21 739 44 95 132 4 353 628 53 115 178 9 156 511 114 9 10 11 0 78 5 124 224 379 20 747 45 97 136 4 350 632 53 115 179 9 157 513 131 10 9 10 0 97 5 119 218 365 20 722 42 94 129 4 340 609 53 117 182 9 159 520 124 14 11 11 0 83 5 PENDING CERTIFICATION APPLICATIONS in CCS Pending Submission 9/30/20 Pending Submission 10/31/20 Pending Submission 11/30/20 Pending Submission 12/30/20 Pending Submission 1/31/21 Pending Submission 2/28/21

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Council Awards Report original pdf

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Goal Information Cost Estimate Award Amount Prime MBE AA H A/NA WBE DBE SMBR Liaison Project Manager Dept Goals Met Type Council Date SG MG $1,800,000 62.52 1.17 1.44 1.47 2.25 17.56 Rachelle Delouis Audra Biediger Public Works 12/3/2020 Yes Construction FY21 Council Awards Report November 2020 MBE/ WBE Non Sub $15,000,000 $15,000,000 68.40 John W Smith Erick Loucks 12/3/2020 Yes Professional Watershed Protection # 1 2 Solicitation No CLMC798 Prime Subs CLMP305 Prime Subs Dalton Lane Site Utilities and Service Center Improvements PGC General Contractors, Inc. (MB) CVI Development, LLC (MH) Environmental Safety Services, Inc. (MH) Rucoba & Maya Construction, LLC (MH) Roadwise Solutions, LLC (MA) Alpha Paving Industries, LLC (FW) Jennifer Weems dba Jennifer Weems Photography (FH) T Morales Company Electric & Controls, Ltd (FH) Melendrez Trucking, LLC Non-M/WBE Subs Total 2021 Stream Restoration and Stormwater Treatment RL HDR Engineering, Inc. (MB) HVJ Associates, Inc. (MH) Arias and Associates, Inc. (MH) Garza EMC, LLC (MA) Encotech Engineering Consultants, Inc. (FW) Baer Engineering & Environmental Consulting, Inc. (FW) MWM Design Group, Inc. Geosyntec Consultants, Inc. (MB) Round Rock Geophysics, LLC (MH) Jose I. Guerra, Inc. (MH) Seagull PME (MA) Asakura Robinson Company, LLC (FW) Glenrose Engineering, Inc. (FW) Holt Engineering, Inc. (FW) MWM Design Group, Inc. Non-M/WBE Subs Total Freese & Nichols, Inc. (MB) Turner Graphics (MH) Arias and Associates, Inc. (MH) EDGE Engineering, PLLC (MA) Asakura Robinson Company, LLC (FW) Cox McLain Environmental Consulting, Inc. (MA) Frank Lam and Associates, Inc. (FW) McGray and McGray Land Surveyors, Inc. (FW) Watearth, Inc. Jacobs Engineering Group, Inc. (MB) HVJ Associates, Inc. (MH) EDGE Engineering, PLLC (MH) Jose I. Guerra, Inc. (MA) Asakura Robinson Company, LLC (MA) HVJ South Central Texas - M&J, Inc. (FW) Hicks & Co Environmental/Archeological Consultants (FW) McGray and McGray Land Surveyors, Inc. (FW) Watearth, Inc. Doucet & Associates, Inc. (MB) HVJ Associates, Inc. (FH) The Rios Group, Inc. (MH) Zamora, LLC (MA) Frank Lam and Associates, Inc. (FW) Cox McLain Environmental Consulting, Inc. (FW) Holt Engineering, Inc. (FW) MWM Design Group, Inc. (FW) Watearth, Inc. Non-M/WBE Subs Total Carollo Engineers, Inc. (MB) HVJ Associates, Inc. (MH) EDGE Engineering, PLLC (MH) Maldonado-Burkett, LLP (MA) Asakura Robinson Company, LLC (MA) Frank Lam and Associates, Inc. (FW) Balcones Geotechnical, LLC (FW) Hicks & Co Environmental/Archeological Consultants (FW) McGray and McGray Land Surveyors, Inc. Non-M/WBE Subs Total Prime Subs Prime Subs Prime Subs Prime Subs Prime Subs Prime Subs Balfour …

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Minority Participation Comparison Presentation by USHCA original pdf

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City of Austin – Minority Participation Comparison of MBE/WBE Programs vs. other Cities And resulting MBE/WBE spend since the 2015 Disparity Study Jan 31st 2021 Position on Minority Participation - Both the US Hispanic Contractor’s Association and the Greater Austin Hispanic Chamber of Commerce have identified “Increasing Minority Participation” for our members as a key initiative for 2019/2020 and will work diligently to advocate on our members behalf ensuring we put forth our best efforts to increase the percentage of contracts awarded to minority/women-owned businesses - Collectively, we support approximately 1,800 local business members in the Greater Austin area, the majority whom are small minority/women-owned businesses. Approximate membershipGreater Austin Hispanic Chamber of Commerce600 U.S. Hispanic Contractors Association1,200 Subtotal1,800 The City of Austin’s Aspirational Goals - The City of Austin has some of the most ambitious goals in the state when it comes to Minority participation….second only to San Antonio. - The Question is whether the structural elements of the program allow MBEs/WBEs to succeed vs. these aspirational goals. - Let’s see what the data says….. Minority Participation GoalsFortSan DallasWorthHoustonAntonioAustinConstruction25.0%25.0%34.0%44.0%41.2%Professional Services36.3%15.0%24.0%40.0%47.4%Architectural/Engineering25.7%15.0%n/a31.0%n/aGoods/Commodities18.0%25.0%11.0%42.0%13.2%Other Services23.8%n/an/a55.0%43.2%Highest2nd HighestSource: City Code 2-9A-19 2015 Disparity Study 2015 COA Disparity Study Key Findings Before we dive into the data…let’s understand what was recommended previously by the previous Disparity studies… Executive Summary – Section F – Paragraph 1. Minorities and Women Chapter III demonstrates that current M/WBE availability levels in the City of Austin’s market area, as measured in Chapter II, are substantially lower in most instances than those that we would expect to observe if commercial markets operated in a race- and gender-neutral manner and that these levels are statistically significant. In other words, minorities and women are substantially and significantly less likely to own their own businesses as the result of discrimination than would be expected based upon their observable characteristics, including age, education, geographic location and industry. We find that these groups also suffer: - - whether they work as employees or entrepreneurs. substantial and significant earnings disadvantages relative to comparable nonminority males, The 2015 City of Austin’s Disparity Study identified that we have an issue that has existed for a significant period of time that required action and changes in policy. 2015 COA Disparity Study – Key Recommendations The 3rd party (i.e. Consultant) recommendations in the 2015 Disparity study were extensive….these are a few of the key recommendations that we thought as having the potential for …

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PNW Presentation by SMBR Certification Team original pdf

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PERSONAL NET WORTH (PNW) FORM TRAINING CITY OF AUSTIN SMALL AND MINORITY BUSINESS RESOURCES (SMBR) HTTP://AUSTINTEXAS.GOV/SMBR 512-974-7645 2  PNW Historical Data  Who is Considered Economically Disadvantaged  Personal Net Worth Exclusions  Supplemental Documents  DBE/ACDBE PNW Differences  Counselors Research  M/WBE PNW Form  M/WBE Alternate PNW  PNW Completion Tips Agenda PNW Historical Data 3  PNW Ordinance was adopted June 8, 2006  Began as certification requirement January 1, 2007  The amount is indexed annually based on the South Region Consumer Price Index published by the US Department of Labor, Bureau of Labor Standards  The PNW limit has increased each year - Initial PNW $900K - Current PNW $1.583M Who is Considered Economically Disadvantaged: 4  An economically disadvantaged individual is a business owner whose Personal Net Worth (PNW) does not exceed:  $1.583 million for the MBE/WBE program* *May change annually  $1.32 million for the DBE/ACDBE program  An individual’s personal net worth includes only his or her share of assets and liabilities held separately AND/OR jointly Exclusions from the PNW 5 An individual’s PNW includes only the applicants share of all assets held separately and/or jointly, or as community property. The following may be excluded:  Individual’s ownership interest in the applicant firm and/or assets titled to the firm  Individual’s equity in his or her primary residence  Tax and interest penalties that would accrue if retirement savings or investments (e.g., pension plans, Individual Retirement Accounts, 401(k) accounts, etc.) were distributed at the present time  The value of an asset or liability not shared/co-owned by applicant  The asset value of a vehicle you are leasing Supplemental Documents Required 6  Full Copy of your most recent Personal Tax Return(s) (include all schedules)  Bank Statement Printouts – within 30 days of your PNW date  Trust Documents: Trust, Bill of Sale, Trust Tax Returns  Attachments for PNW Sections, as needed  Certification staff may request additional documents if required All information provided by the applicant is CONFIDENTIAL and protected by the state’s Open Records Act. DBE/ACDBE PNW Differences: 7          Both Programs require PNW at Initial Application and upon request, usually upon a major financial change IF applying for both programs, applicant should ONLY complete the DBE PNW Form Layout: PNW Calculation Section & Section 6 Section …

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Request for Change Report original pdf

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Request for Change Report - January 2021 Reviewer DateAssigned Contract Amount Prime Contractor Project Description Subcontractor Certified Y/N Scope of Work Managing Department Project Manager Action Date Notes Qty Solicitation Number Add/Delete/ Contract Change/ Substitution- A(Add) or D(Delete) Contract Change Increase/ Decrease/Scope Addition Like-Kind Substitution Like-Kind Availability Subcontract Amount or Percentage GFE Required? Y/N RFC Approved Y/N Violation Letter Issued this Month Y/N Total No. of Firm's Violation(s) 1/29/2021 $1,217,865 CLMC806 MAC, Inc. Williamson Creek – Village at Western Oaks Wetpond Project Add Bradford Holman / Occupational Safety Solutions N/A N/A $2,160.00 Safety Training Tony Lopez 2/5/2021 Adding a certified subcontractor 1/29/2021 $1,217,865 CLMC806 MAC, Inc. Add J Arbor Contracting, LLC N/A N/A $38,414.00 Erosion controls Tony Lopez 2/5/2021 Adding a certified subcontractor 1/29/2021 $62,111,778 CLMB329 JE Dunn Construction Company ABIA Consolidated Maintenance Facility Add V Five, Inc. / Lefever Building Systems N/A N/A $87,206.00 Structural and reinforcement steel David Kim Taylor 1/28/2021 Goals met 70 1/27/2021 $800,000 CLMP272 Freese & Nichols, Inc. Add MWM Designgroup, Inc. N/A $14,368.00 Irrigation design; Landscape architecture Minda Sarmiento 1/28/2021 Adding a certified subcontractor 1/27/2021 $800,000 CLMP272 Freese & Nichols, Inc. Add Holt Engineering, Inc. N/A $22,326.00 Geotechnical engineering Minda Sarmiento 1/28/2021 Adding a certified subcontractor 1/27/2021 $800,000 CLMP272 Freese & Nichols, Inc. Add Doucet & Associates, Inc. N/A $15,777.00 Drainage engineering Minda Sarmiento 1/28/2021 Adding a certified subcontractor 1/27/2021 $800,000 CLMP272 Freese & Nichols, Inc. Add Balcones Geotechnical, LLC N/A N/A $13,209.00 Geotechnical engineering Minda Sarmiento 1/28/2021 Adding a certified subcontractor 1/27/2021 $800,000 CLMP272 Freese & Nichols, Inc. 2020 Large Scale General Civil Engineering Services RL Add Encotech Engineering Consultants, Inc. N/A N/A $30,731.00 Structural engineering Minda Sarmiento 1/28/2021 Adding a certified subcontractor AA 1/26/2021 $3,820,208 CLMP173 HDR Engineering, Inc. Contract Change Doucet & Associates, Inc. Decrease N/A N/A ($23,187.00) Civil engineering Jules Parrish 2/2/2021 Decreasing an existing scope of work LM LM VH CV CV CV CV CV 1 2 3 4 5 6 7 8 9 10 AA 1/26/2021 $3,820,208 CLMP173 HDR Engineering, Inc. Contract Change Aguirre & Fields, LP Decrease N/A N/A ($31,468.00) Structural engineering Jules Parrish 2/2/2021 Decreasing an existing scope of work 11 AA 1/26/2021 $3,820,208 CLMP173 HDR Engineering, Inc. Contract Change Carolyn Kelley Landscape Architect Decrease N/A N/A ($5,670.00) Landscape architecture Jules Parrish 2/2/2021 Decreasing an existing scope of work 12 LM 1/25/2021 $14,141,306 CLMC754 PLW Waterworks, LLC Substitution - Delete Rama Tiru ($14,000.00) Aerial Photography; Photography, …

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Approved Minutes original pdf

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MBE/WBE and Small Business Enterprise Procurement Program Advisory Committee Meeting Minutes Tuesday – April 6, 2021 The MBE/WBE and Small Business Enterprise Procurement Program Advisory Committee convened in a Regular meeting on Tuesday, March 2, 2021 via videoconference. CALL TO ORDER Committee Chair, Eliza May calls meeting to order at 5:30pm. BOARD MEMBERS IN ATTENDANCE: Eliza May (Chair), Reginald World (Vice-Chair), Lena Banks, Daniel Berner, Barbra Boeta, Schiller Liao, Ahmed Moledina, Tina Cannon CITIZEN COMMUNICATION: GENERAL There were no speakers. 1. APPROVAL OF MINUTES The minutes for the regular meeting of February 2, 2021 were considered for approval. The minutes were approved on a motion by Committee Member, Tina Cannon and seconded by Committee Member, Schiller Liao. Minutes approved on an 8-0 vote. 2. NEW BUSINESS For discussion and possible action on recommendations to City Council (City Code § 2-1-163(B)) regarding the following: a. Director’s Updates and Announcements with discussion and possible action • We will partner with our procurement offices for the 3rd annual Small Business Contracting Forum to be held on Wednesday, March 24th. It will be a virtual forum put on by the City of Austin Purchasing office in conjunction and partnership with SMBR and other entities around the city. 3. OLD BUSINESS For discussion and possible action on recommendations to City Council (City Code § 2-1-163(B)) regarding the following: a. Discussion and appropriate action regarding information on the City’s MBE/WBE participation and usage; and the use of a Personal Net Worth (PNW) and the Economic Disadvantage definition in the MBE/WBE Procurement Program. • SMBR Certification Division Manager, Elton Price provided information that was requested by the committee. The committee requested an overview of the personal net worth (PNW) process and what tools used for site audits. Page 1 of 9 • Cloteal Davis-Haynes of Haynes-Eaglin-Waters and a representative of the Austin Black Contractors Association shared their position regarding the PNW proposal brought forth by the US Hispanic Contractors Association and Hispanic Chamber. If PNW is eliminated millionaires or billionaires that fall into these racial categories would be allowed to participate in this program which not acceptable. Consider the valuation of property and the rising median income in the Austin MSA. Let’s review the PNW process and increase it as appropriate but do not eliminate it. We are not in favor of accepting the State of Texas certification because their HUB certification program is the least stringent. …

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