2 CCR 604-1
DEPARTMENT OF TRANSPORTATION Transportation Commission EMERGING SMALL BUSINESS PROGRAM 2 CCR 604-1 [Editor’s Notes follow the text of the rules at the end of this CCR Document.] _________________________________________________________________________ Chapter 1 General Provisions I. Authority The authority for the State of Colorado Transportation Commission (“The Commission” ) to adopt the Rules is contained in § § 43-1-106(8)(j), (k) and (p), C.R.S. as amended. The Statement of Basis, Specific Statutory Authority, and Purpose for the July 1, 1992, rulemaking to adopt the Rules is incorporated herein by this reference and made a part of the Rules. The Statement of Basis, Specific Statutory Authority, and Purpose for the July 15, 1994 - August 18, 1994, rulemaking to amend the Rules is incorporated herein by this reference and made a part of the Rules. The Statement of Basis, Specific Statutory Authority, and Purpose for the January 8, 2002, rulemaking to amend the Rules is incorporated herein by this reference and made a part of the Rules. A copy of the Statements can be obtained by contacting: ESB Program Manager Colorado Department of Transportation (CDOT) 4201 E. Arkansas Avenue Denver, CO 80222 II. Purpose The general purpose of the Rules is to put into practice Section 43-1-106 (8)(p) C.R.S. as amended to implement an Emerging Small Business (ESB) Program for certain CDOT projects. The ESB Program authorized by the Rules is intended to provide assistance to eligible small Businesses, including minority, women and disadvantaged business enterprises, which could not otherwise participate successfully in the competitive process for award of CDOT contracts for Construction work, Professional Services consulting work and Practice of Research work to enable such Businesses to gain the knowledge, experience and resources needed to participate in the competitive process for such contracts, thereby increasing competition and lowering the cost to the public for such work. The Rules establish criteria and other requirements which a Business must meet to qualify as an ESB and to participate in the ESB Program. The Rules authorize CDOT to provide certain development assistance tools to increase the opportunity for participation in designated CDOT Construction and non- Construction projects by all eligible small businesses, including minority, women, and disadvantaged business enterprises, that meet such criteria and requirements.
III. Applicability The Rules determine the approval, denial, suspension and revocation of eligibility for ESB status and the development assistance tools provided by the CDOT ESB Program. Chapter 2 Definitions The following definitions shall apply to terms used in the Rules.
1) Affiliate: Businesses are affiliates of each other if, directly or indirectly, either one controls or has the power to control the other, or a third person controls or has the power to control both, but they are not affiliates if the combined income of all related Businesses does not exceed the total income limitations for eligibility for an ESB as described in Chapter 3, II, (2) (b). Indicia of control include, but are not limited to: interlocking management or ownership, identity of interests among family members, shared facilities and equipment, common use of employees; or a business entity organized following the graduation, suspension, debarment or voluntary exclusion of a person which has the same or similar management, ownership, or principal employees as the graduated business or the suspended, debarred, or voluntarily excluded person.
2) Bid: The offer of a contractor, on the prescribed bid proposal form, to perform the work and to furnish the labor and materials in conformance with the invitation for bids at the prices quoted.
3) Business: A sole proprietorship, partnership, corporation, or any other legal entity authorized by law to perform Professional Services consulting work and Practice of Research work or Construction and Non-Construction work on CDOT projects in Colorado. For the purposes of the eligibility requirement contained in Chapter 3(II)(2)(f) of the Rules, the term “Business” shall also be construed to mean any principal of the Business.
4) Business Development Plan: A plan developed by an ESB with the assistance and approval of the CDOT ESB Program Manager. This plan will identify specific training which the ESB must complete during the time period identified in the plan in order to develop the necessary skills and resources to obtain and perform work on projects.
5) CDOT: The Colorado Department of Transportation.
6) Consultant: An individual, corporation, partnership, business trust association, Business or any other legal entity providing Professional Services and Practice of Research work.
7) Construction: Building, altering, repairing, improving, or demolishing work as described in a CDOT project. The term includes “capital construction” and “controlled maintenance” as defined in section § 24-30-1301, C.R.S.
8) Contractor: Any individual, partnership, corporation, joint venture, company, firm, association, or any other legal entity contracting with, or intending to contract with, CDOT for performance of prescribed work.
9) Controlling Interest: Ownership of 51 percent or more of the Business by one person, or ownership of the largest single portion of the Business by one person if no one person holds 51 percent or more.
10) CFR: Code of Federal Regulations 11) C.R.S.: Colorado Revised Statutes, as amended.
12) Eligibility determination: The process of review by the CDOT ESB Program Manager of a Business' qualifications to determine whether the Business is eligible for the ESB Program.
13) Emerging Small Business (ESB): A business which CDOT has determined meets the eligibility criteria and requirements of the Rules.
14) Independent Business: A Business which is not an affiliate of any other Business.
15) Non-Construction Work: Professional Services work and Practice of Research work, as defined below.
16) Principal: A sole proprietor, a general or limited partner, a person who owns 25 percent or more or a controlling interest, a director, or an officer of the business.
17) Practice of Research: The performance of professional services involving the design, data collection and data analysis of studies such as evaluation studies, usage studies, feasibility studies, environmental impact studies, polling studies and other such studies performed by a person qualified by education or training or actual performance in the field, but does not include “Professional Services” as defined in Chapter 2(18) below.
18) Professional Services: Those services defined in § 24-30-1402(6) C.R.S.: 1) the practice of architecture, 2) the practice of engineering, 3) the practice of professional land surveying, and 4) the practice of landscape architecture.
19) Rules: Regulations entitled “2 CCR 604-1” that are within the jurisdiction of the Colorado Department of Transportation and the State of Colorado Transportation Commission and are referred to as “the Rules” .
20) Total Income: Total Income of the Business is defined as that number which is reported to the Internal Revenue Service on the business' federal tax return as “Gross receipts or sales less (minus) returns and allowances,” as indicated in the appropriate IRS tax form most recently filed by the business, including U.S. Corporation Income Tax Return, or Profit or Loss from Business (Sole Proprietorship), or U.S. Partnership Return of Income.
Chapter 3 Eligibility Determination I. Application Requirements A Business that desires to take part in the ESB Program must file an application for eligibility determination with CDOT. The Business must submit a complete application to CDOT not less than 60 calendar days prior to the date the Business desires to participate in the ESB Program. The Business must obtain the application forms and a copy of the Rules from CDOT. The Business must complete and, if necessary, supplement the application forms to provide all information necessary for CDOT to determine whether the Business is eligible for the ESB Program. The applicant shall provide the following information in the application:
1) The name, telephone number, address, and legal status (sole proprietorship, partnership, corporation, etc.) of the Business seeking ESB eligibility;
2) The name, address, and telephone number of the registered agent of the Business. If the Business is a corporation, the Certificate of Incorporation and if incorporated for more than 2 years, Certificate of Good Standing;
3) The names, addresses, and telephone numbers of all principals of the Business, and a listing of other Businesses in which such persons have been or are currently principals;
4) The names, addresses, and telephone numbers of all persons or legal entities who own any interest in the Business and affiliates and subsidiaries of the Business, if any, and the percentage of ownership held by each;
5) A copy of the federal tax return for the Business for the previous three fiscal years, if the Business has been in existence for that period. If the Business has not been in existence for the previous three years, then either a copy of the federal tax return, if available, for the period the Business has existed prior to filing the application, or other documents indicating the total income of the Business for that period. If the Business is a new Business with no income earned to date, it must so certify on the form provided by CDOT for that purpose;
6) A statement as to whether any principal or owner of the Business has either been debarred or convicted of bid related crimes or violations within the past six years in any state or federal jurisdiction, or is under notice of intent to debar in any jurisdiction, and the current status of any such principal or owner and debarment;
7) A statement in which the Business identifies all of its current resources, experience, education, training, capability, managerial skills, and the qualifications of its personnel;
8) A statement in which the Business identifies:
a) specific areas where it needs assistance, including but not limited to work performance, contract skills, resources, and experience; and b) specific development assistance tools authorized by the Rules which can provide help to the Business in successfully obtaining and performing work on CDOT Construction and non- Construction or Professional Service consulting projects; and 9) Ethnic and gender identification of the principal(s) of the Business.
II. Eligibility Determination Procedure The following procedure shall govern CDOT approval or denial of ESB eligibility:
1) The Business shall submit the application and supporting information to the CDOT ESB Program Manager. The Business shall answer any questions the CDOT ESB Program Manager may have concerning the application information. The Business shall provide all additional information requested by CDOT as soon as possible. The ESB application will not be considered complete until all questions of the CDOT ESB Program Manager relative to the application have been answered to the satisfaction of CDOT. The Business shall have one year from the date of the initial application to provide the additional information needed to complete the application. CDOT will not be required to take any action concerning an incomplete application.
2) CDOT will approve or deny an initial or renewal application for ESB eligibility status based upon all the terms and conditions of the Rules, including the following criteria:
a) The Business must be an independent operational business;
b) The Business must not have exceeded the following total income limitations:
c) The Business must satisfy all applicable requirements, including any required Business or professional licensing, to be authorized to perform Construction, Professional Services, or Practice of Research work in Colorado;
d) The Business must submit to CDOT, in its application, proof of either:
e) The Business must not have made false, deceptive, or fraudulent statements in the application for ESB eligibility or in any other information, statements, or documents submitted to CDOT;
f) The Business or any principal or owner of the Business must not have been in the ESB Program for longer than a maximum twelve year period. The twelve year eligibility period shall commence with the date of CDOT approval of the initial application of the Business or principal or owner of the Business to enter the program and shall terminate with twelve years of active eligibility status of the Business or principal or owner of the Business;
g) The Business must complete a two-part Business Development Plan form provided by CDOT; and h) The Business, or any principal or owner of the Business, must not have been debarred or convicted of bid-related crimes or violations within the past six years in any state or federal jurisdiction, or be under notice of intent to debar in any jurisdiction.
3) The CDOT ESB Program Manager shall give written notice of approval or denial of a completed ESB application, including renewals, promptly after receipt of such application.
4) If CDOT approves an application, the term of ESB eligibility shall be for a period of one calendar year from the date of approval. ESB eligibility may be renewed for additional one-year terms, up to the maximum of twelve active eligible years from the date of initial CDOT approval of an application for ESB status, subject to the requirements of the Rules.
III. Eligibility Maintenance After CDOT has approved an initial application for ESB status, the ESB must submit a separate application for renewal of ESB status on an annual basis to maintain eligibility. The renewal application must comply with the requirements of this Chapter 3, including Section I, and must be submitted to the CDOT ESB Program Manager prior to the expiration of the ESB's annual eligibility period. The application for renewal shall also contain: 1) the Business' most recent federal tax return; 2) a Business Development Plan form provided by CDOT for the renewal year, describing completion of the previous year's Business Development Plan.
IV. Termination of ESB Status ESB status shall be terminated by: 1) the ESB exceeding the income limitation, as defined in Section II (2) (b) of Chapter 3; or 2) the passage of twelve active eligible years since initial ESB determination, as defined in Section II (2)(f) of Chapter 3; or 3) the ESB's failure to meet all requirements and criteria of the Rules, as determined by CDOT. CDOT may review the ESB eligibility status of a Business at any time. If the ESB status of a Business is terminated, the Business may reapply for ESB eligibility status for any remainder of the maximum twelve active eligible year period, unless it exceeded the income limitation as defined in Section II (2)(b) of Chapter 3. No reinstatement of ESB eligibility will be permitted after termination for exceeding the income limitation.
V. Reinstatement of ESB Status A Business may be reinstated into the ESB Program if: 1) the Business has previously graduated from the ESB program by exceeding the income limitation set forth in the Rules adopted August 18, 1994 and has not exceeded the current income limitation described in Section II (2)(b) of Chapter 3; 2) the Business has previously graduated from the ESB program by completing the maximum six calendar year period in accordance with the Rules adopted August 30, 1992 and has not exceeded the current income limitation described in Section II (2)(b) of Chapter 3. The Business will be allowed six more active eligible years, for a maximum of twelve years total, in the ESB program unless it exceeds the current income limitation described in Section II (2)(b) of Chapter 3. The years the Business had active eligibility status in program will count toward the maximum twelve year total.
Chapter 4 Development Assistance Tools I. Requirements and Criteria CDOT may, at its discretion, provide the development assistance tools described in Section II of this Chapter to eligible ESBs, and may use state and/or federal funds to pay for assistance tools, subject to the following requirements and criteria:
1) CDOT will use federal funds to provide development assistance tools on federal aid projects only to an ESB that also is certified as a Disadvantaged Business Enterprise (DBE), as defined in 49 C.F.R. Part 26.
2) CDOT will provide the certain development assistance tools described in Section II (3), (4), (5), (6), and (8) regarding reimbursement payments, restricted projects, assistance with the bonding, and Professional Services consultant evaluation and the Practice of Research work only to the extent CDOT expressly so indicates in the formal public advertisement for each particular CDOT project.
3) CDOT will consider the following criteria to determine whether CDOT will provide the development assistance tools at a particular time, or to a particular ESB, or on a particular project:
a) Availability of funds to pay for such tools.
b) Availability of eligible ESBs to perform the type(s) of work available or required on a particular project.
c) Availability of certain development assistance tools, or of eligible ESBs, at the time or location a particular project is to be performed.
d) Ability of CDOT, or of other cooperating entities where necessary or appropriate, to provide such development assistance tools.
e) Applicability or suitability of certain development assistance tools to ESBs available to perform work on a particular project.
f) The need of a particular ESB, as determined by CDOT, to participate in available development assistance tools.
g) Whether such tools are unsuitable, impractical, or impossible for CDOT to provide to a particular ESB, or on a particular project, or for any other reason.
II. Assistance Tools Subject to the above requirements and criteria, CDOT will provide the following development assistance tools:
1) Business Development Plan CDOT will provide a two-part Business Development Plan form. The Business Development Plan will identify and prioritize the skills, experience, and resources which the ESB must acquire or develop to achieve minimum proficiency in CDOT project work-related areas, including contract administration, finance, bid preparation, cost accounting, payroll, bonding, personnel, and construction management, in order to assist the ESB in participating competitively in the award of project contracts.
The Business Development Plan will also set specific training goals which the ESB must meet by the timeline agreed to in the Business Development Plan. The specific training goals will be limited to those that are reasonable and capable of being achieved by the ESB, as determined by CDOT after discussion with the ESB, and will be based upon such factors as:
a) information provided by the ESB in the application;
b) needs of the ESB identified by CDOT based on Construction and Non-Construction work industry standards;
c) training requested by the ESB;
d) current experience and resources of the ESB; and e) an expectation by CDOT that each annual element of the Business Development Plan will build on the previous elements.
2) Technical Assistance CDOT will provide technical assistance to the ESB in certain work-related areas, if CDOT determines that such assistance is appropriate based upon the Business Development Plan(s). General technical assistance from the following work-related areas may be provided:
a) Construction management;
b) Time management and project work scheduling;
c) Project financing requirements, including insurance;
d) Personnel management;
e) Bidding, estimating, job costing, and contract administration procedures;
f) Evaluation and use of project plans;
g) CDOT contracting procedures and specifications; and h) Construction and Non-Construction techniques and industry standards.
3) Reimbursement Payments to Prime Contractors and Consultants CDOT will provide two types of financial reimbursement payments to prime contractors or consultants in exchange for the prime contractor or consultant providing certain on-the-job training services to an ESB in order to encourage ESB participation on projects. The prime contractor or consultant may only qualify for one type of reimbursement payment per ESB subcontractor per project.
a) First-time reimbursement payment CDOT will provide a reimbursement payment to any prime contractor or consultant who retains an ESB subcontractor or subconsultant if the retained ESB has never before had a contract or a subcontract on a CDOT project. This reimbursement payment may be earned only one time per project, regardless of how many ESBs are retained as subcontractors on that project.
In exchange for this reimbursement payment, the prime contractor or consultant must request approval and agree in writing with CDOT, on a form provided by CDOT, to provide work-related services to the ESB subcontractor or subconsultant in the performance of the work and to provide a written evaluation of the ESB's performance of the work to CDOT. The specific work-related services to be provided and other terms and conditions will be described in the reimbursement agreement form. The work-related services may include, but are not limited to, instructions in scheduling, accounting, billing, purchasing, payroll, and project superintendence.
This reimbursement payment may not be used in conjunction with any other reimbursement payment for this ESB on the project.
b) Hourly reimbursement payment CDOT will provide an hourly reimbursement payment to a prime contractor or consultant who retains one or more ESB(s) as subcontractor(s) or subconsultant(s) on a CDOT project.
In exchange for this reimbursement payment, the prime contractor or consultant must request approval and agree in writing with CDOT, on a form provided by CDOT, to provide work-related services to the ESB subcontractor or subconsultant in the performance of the work and to provide to CDOT a written evaluation of the ESB's performance of the work. The specific work-related services and other terms and conditions will be described in the reimbursement agreement form. The work-related services to be provided by the prime contractor or consultant to the ESB may include, but are not limited to, assistance in the following:
CDOT will pay the prime contractor or consultant at the then prevailing industry hourly rates for the services actually provided and documented, as defined in the formal public advertisement in the standard special provision for the project. This reimbursement payment may not be used in conjunction with any other reimbursement payment for this ESB on the project.
4) Reimbursement Payments to ESBs CDOT will provide two types of financial reimbursements to eligible ESBs.
a) Bonding assistance reimbursement payment
b) Tuition reimbursement payment CDOT will reimburse half the cost of training attended by owners and/or employees of the ESB's business up to a total of $300 per year per ESB. The training must be approved in advance by ESB Program Manager. The training must help to improve the ESB's ability to do business in the transportation industry. This payment is not a part of the CDOT standard special provision advertised in projects.
5) Restricted Projects CDOT may restrict certain projects for award only to eligible ESBs as prime contractors where the contract award is expected to be $150,000 or less. Provided, however, that CDOT must first determine that such restricted projects are necessary to provide a reasonable opportunity for ESBs to participate in CDOT projects.
A CDOT determination to use restricted projects for ESBs will be based upon a consideration of the following factors:
a) the number of qualified ESBs available in the area to perform certain CDOT project work;
b) the amount of such work actually performed by ESBs on CDOT projects without use of restricted projects;
c) the success of the ESB Program without restricted projects; and d) the potential for adequate competition among qualified, available ESBs to perform the work if the project is restricted.
If the percentage of qualified ESBs available to perform the work is greater than the proportion of CDOT project work actually performed by ESBs (as measured by dollar amount of work), a sufficient number of qualified ESBs exist to ensure adequate competition for such work, and CDOT determines that restricted projects will aid the success of the ESB Program, then CDOT may restrict certain projects only to eligible ESBs where the contract award is expected to be $150,000 or less, but only to the extent reasonably necessary to balance the percentage of available ESBs with the proportion of project work performed by the ESBs.
6) Pilot Programs CDOT may establish pilot programs, such as a Mentor-Prot#eacute#g#eacute# Program, in order to develop and evaluate their effectiveness prior to establishing formal development tools. A pilot program must be approved by the Transportation Commission before formal implementation and allocation of a budget. After a three year period a program evaluation will be completed by the ESB Program Manager of the prot#eacute#g#eacute#s' continuous improvement and their ability to successfully bid CDOT work.
7) Increase Smaller Projects CDOT may increase the number of Construction and Non-Construction work projects which do not exceed a maximum cost of $150,000 if CDOT determines that such action is necessary to increase the opportunities for ESBs to participate on such projects as prime contractors or consultants. In determining whether to increase the number of such projects, CDOT will consider the following factors:
a) the number of eligible ESBs;
b) the types of work such ESBs are able to perform;
c) the current need in the CDOT annual work plan for the types of work eligible ESBs are able to perform; and d) whether a sufficient number of such ESBs are available to perform the needed work to ensure adequate competition for such work.
8) Professional Services and Practice of Research Work Consultant Evaluation In accordance with the § 24-30-1403(2) and § 24-103-203, C.R.S. requirements for evaluating and selecting consultants for Professional Services work and Practice of Research work, respectively, CDOT will:
a) provide evaluation points, or increase the weight given existing points, to a prospective prime consultant if the consultant is either an ESB or will use an ESB as a subconsultant. The number of points, or the amount of increase in the weight of existing points, to be provided by CDOT will be determined by CDOT on a case by case basis and identified in the formal public advertisement for the project; and b) attempt to effect a more equitable distribution of such Professional Services work and Practice of Research work contracts among all qualified businesses, including qualified ESBs.
9) Prompt Payment CDOT may provide for prompt payment to ESB prime contractors and consultants and ESB subcontractors and subconsultants on CDOT projects, as follows:
a) CDOT may provide payment every two weeks and not less than once each month to ESB prime contractors or consultants provided the work is being satisfactorily performed. Such payments will be based upon progress estimates prepared by CDOT of the value of the work satisfactorily performed by the ESB prime contractor or consultant; and b) Every prime contractor or consultant on a Construction project or consultant contract shall pay the subcontractor or subconsultant within seven calendar days of receipt of the payment from CDOT, or within any shorter time provided in the contract between the prime contractor or consultant and CDOT, subject to compliance by the subcontractor or subconsultant with the requirements of § 24-91-103(2), C.R.S.
10) Resource Center a) CDOT will establish a resource center to make available to ESBs information on CDOT Construction and non-Construction work, including contracting procedures;
b) CDOT will contact public institutions and private entities in fields related to the skills and resources needed for CDOT Construction and Non-Construction work, and will solicit and make available to ESBs any information about such assistance that is supplied by such institutions and entities;
c) CDOT will compile and make available to ESBs schedules of education and training opportunities related to Construction and Non-Construction work;
d) CDOT will also cooperate with other public entities and government contractors in publicizing other available contracting opportunities to assist ESBs in broadening their market base. Chapter 5 Denials, Suspension and Revocation The procedures contained in § § 24-4-104 and 24-4-105, C.R.S., shall apply to any denial, suspension, or revocation by CDOT of ESB eligibility.
I. Denial of ESB Eligibility CDOT may deny an application for ESB eligibility if CDOT determines that the applicant Business does not meet all of the requirements and criteria of the Rules. CDOT shall notify the Business of its determination and the Business may request a hearing concerning such denial, as provided in § § 24-4- 104 and 105, C.R.S.
II. Suspension or Revocation of ESB Eligibility 1) CDOT may suspend or revoke ESB eligibility if a Business is under a notice of intent to debar, or is suspended or debarred from participating in Construction or Non-Construction work, or is convicted of bid-related crimes or violations within the past six years in any state or federal jurisdiction.
2) CDOT may suspend or revoke ESB eligibility if the CDOT ESB Program Manager determines that:
a) The Business is declared in default of or commits a willful violation of any CDOT contract or subcontract;
b) The Business has made false, deceptive or fraudulent statements on its application for ESB eligibility, or in any documents submitted on a CDOT project including prequalification, or in any other information submitted to CDOT, or in the course of any determination or hearing associated with ESB eligibility;
c) The Business commits any action or omission which evidences a lack of Business integrity or honesty in performing public projects; or d) The Business does not meet all requirements and criteria of the Rules at all times.
3) If the CDOT ESB Program Manager has reasonable grounds to believe that the public health, welfare, or safety imperatively requires summary suspension of the ESB eligibility of a Business, the CDOT ESB Program Manager may summarily suspend, upon written notice, a Business' ESB eligibility for a temporary period of time pursuant to the procedures of § 24-4-104(4), C.R.S., as amended.
4) The procedures contained in § § 24-4-104 and 105, C.R.S. shall govern the suspension or revocation of ESB status.
III. Length of Suspension or Revocation of ESB Eligibility and Reinstatement If a Business' ESB eligibility is denied, suspended, or revoked by CDOT, such denial, suspension, or revocation will remain in place until:
1) the Business submits new information which is determined by the CDOT ESB Program Manager to satisfactorily dispose of the grounds for denial, suspension, or revocation, if no hearing is requested by the Business pursuant to § § 24-4-104 and 105, C.R.S., regarding the denial, suspension, or revocation; or 2) the date determined after any hearing requested by the Business, pursuant to § § 24-4-104 and 105, C.R.S.
Chapter 6 Program Administration I. Program Evaluation CDOT will utilize various methods to obtain feedback, evaluation, and advice concerning the operation and content of the ESB Program. These methods may include an Advisory Committee, surveys, and annual meetings to assess the effectiveness of the program and make recommendations for improving the program.
II. Program Reports The CDOT ESB Program Manager will report annually to the Commission regarding the ESB Program with more frequent reports if requested. This report will include, but is not limited to, a complete and detailed description of the following:
1) the number, ethnic, and gender composition of all eligible ESB Businesses participating in the ESB Program;
2) the number and total dollar amounts of contracts and subcontracts awarded to ESB Businesses, fiscal year to date;
3) the number of new Businesses added and old Businesses renewed to ESB status since the previous report;
4) the type and extent of training and technical assistance provided by CDOT and other entities to ESB Businesses;
5) the types and total dollar amount of reimbursement payment provided by CDOT to prime contractors to use ESB Businesses;
6) a breakdown of the CDOT costs of the ESB Program; and 7) recommendations for changes to the ESB Program.
_________________________________________________________________________ Editor’s Notes History