Hector Manuel Dominguez

Document ID: DOT-OST-2010-0118-0016
Document Type: Public Submission
Agency: Department Of Transportation
Received Date: May 25 2010, at 12:00 AM Eastern Daylight Time
Date Posted: May 27 2010, at 12:00 AM Eastern Standard Time
Comment Start Date: May 10 2010, at 12:00 AM Eastern Standard Time
Comment Due Date: July 9 2010, at 11:59 PM Eastern Standard Time
Tracking Number: 80af3beb
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1- Raising the personal net worth up to an equivalent dollar value of 1989 to 2010 would be helpful. In order to survive as a small business having a net worth of $750,000 today is not nearly sufficient if working in the public works arena. In 2005 when my brother and i started a business I barely qualified as a DBE. We started the business with 200k in savings, and 400,000 in equity lines of credit. Banks would not lend us more than 40,000 in credit cards because we were new business. In 2006 we used all 600,000 cash available and were in debt 40,000 on the credit cards. We barely managed to make it through. Since then the equity line of credits have been the back bone to our cash flow. Working in the public sector arena takes an average of 90 to 120 days to get paid if working under a prime contractor. With a personal net worth of $750,000 one does not have much room to borrow from banks. Increasing the limit to 1.3M would definitely help small business to grow and help employ more. 2. The challenges with the rules of using DBE subcontractors is that most prime contractors perform a due diligence of 'Paper Trail'. They does not exist a genuine interest in allowing a subcontractor to do the work that the prime can do with own employees. Most contractors submit a paper trail of faxes and email asking for a subcontractor to bid on a project and they don't even know what the subcontractor services are. When they do get a bid you never hear back. I've personally called the project manager and sent emails responding to a soliciation for DBE subcontractor but never recieved a call back. In order to enforce DBE 'good faith efforts" the needs to be a mandartory requirement that all contracts out to bid require the prime contractor to provide the email or fax of the contracting agency adminstrator to where a duplicate copy of subcontractor bid submitted to the prime contractor can be sent to the bidding agency in order for the bidding agency for comparison.

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