HomeMy WebLinkAboutMINUTES - 10171989 - IO.3 I.O. -3
TO: BOARD OF SUPERVISORS
Contra
FROM: Fes/ Costa
INTERNAL OPERATIONS COMMITTEE
\
DATE: October 9, 1989 -~
srq� County
SUBJECT: STATUS REPORT ON AFFIRMATIVE ACTION AND MINORITY AND
WOMEN-OWNED BUSINESSES
SPECIFIC REQUEST(S)OR RECOMMENDATION(S)&BACKGROUND AND JUSTIFICATION
RECONIlOKNDATIONS
1. Request the Affirmative Action Officer to prepare for her
next quarterly report to the Internal Operations Committee a
breakdown in the data on the County' s workforce by
department, income level and sex so we can determine which
departments. are promoting women to higher technical,
professional and management levels and which departments are
not. In breaking down this information, the income levels
which are used should be the same ones used by the Personnel
Department in the Pay Equity Study.
2. In regard to the above recommendation, request the County
Administrator to intervene with Data Processing on behalf of
the Affirmative Action Officer so as to insure that the data
requested by our Committee is completed and available in a
timely manner.
3 . Request the Affirmative Action Officer to develop a booklet
which explains the County' s Affirmative Action and MBE/WBE
Programs which can be forwarded to members of the general
public who ask for information on the County' s Affirmative
Action and MBE/WBE Programs and return a draft of such a
booklet to the Internal Operations Committee when she makes
her next quarterly report to the Committee.
4. Request the Affirmative Action Officer to consider the
implications of the two changes which County Counsel has
identified as possible additions to the County' s Affirmative
CONTINUED ON ATTACHMENT.Yee YES SIGNATURE:
RECOMMENDATION OF TY ADMI ISOR OMMENDATI BOARD COMMIT EE
APPROVE OTHER
OM POWERS SUNNE WRIGHTi`MovcPPEAK
SIGNATUREvt
(S):
ACTION OF BOARD ON nC�G1b2Z 1 Jy A R APPROVED AS RECOMMENDED OTHER
VOTE OF SUPERVISORS
I HEREBY CERTIFY THAT THIS IS A TRUE
UNANIMOUS(ABSENT ) AND CORRECT COPY OF AN ACTION TAKEN
AYES: NOES: AND ENTERED ON THE MINUTES OF THE BOARD
ABSENT: ABSTAIN: OF SUPERVISORS ON T�H-E-DATE SHOWN.
CC: ATTESTED—
County
TTESTED County Administrator PHIL BATCHELOR,CLERK OF THE BOARD OF
Sheriff-Coroner SUPERVISORS AND COUNTY ADMINISTRATOR
Director of Personnel
Affirmative Action Officer
M382 (10/88) Chair, ACEESW BY DEPUTY
a
Action Program (assigning job classifications to job
categories and increasing the standard for determining
imbalance) and return a report on this subject to the
Internal Operations Committee when she makes her next
quarterly report to the Committee.
This report should include an estimate ofthe additional
work which would be involved in combining job
classifications into job categories. In addition, this
report should identify how many additional job
classifications would be considered to be imbalanced if the
County were to move from 80% of the percentage available in
the external work force to 85% and to 90% of the percentage
available in the external work force.
5. Request the Affirmative Action Officer to ask the
Sheriff-Coroner how his hiring program for the West County
Detention Center will fit into the County' s overall
affirmative action goals and suggest that the
Sheriff-Coroner report on this issue when he appears before
our Committee November 13 , 1989 on the matter of hiring
Career Development Employment Programs participants in the
West County Detention Center.
6. Request the Affirmative Action Officer to review the summary
of affirmative action accomplishments which is attached to
her quarterly report as attachment 6, insure the accuracy of
the data and make revisions as ate necessary and then
finalize the report and forward it to the Members of the
Board of Supervisors.
BACKGROUND:
On July 18 , 1989 our Committee made our last status report to the
Board of Supervisors on the County's Affirmative Action and
MBE/WBE Programs. On October 9, 1989 our Committee reviewed the
attached reports; first, the regular quarterly report from the
County' s Affirmative Action Officer; second, an analysis by our
Affirmative Action Officer on the Affirmative Action plans of the
County of Santa Clara and ' P.G. & E. ; third, comments from the
County Counsel' s Office on changes which might be made by the
Board of Supervisors if it wanted to do more in the Affirmative
Action field than is strictly required by the existing Federal
District Court consent decree.
As can be seen from the attached reports the County continues to
have a good record in hiring and promoting minorities and women.
The County also seems to be doing a reasonably good job in
awarding contracts to minority and women-owned firms, although
more needs to be done in both areas.
We are concerned about the Sheriff ' s plans for hiring minorities
and women from the Richmond area to staff the new West County
Detention Center and how his plans fit into and further the
County' s overall Affirmative Action Program goals. We are,
therefore, asking the Sheriff to meet with us and review his
plans in this regard.
We are also repeating our request that the data be presented in a
manner which will allow easier analysis of which departments are
making progress in hiring and promoting minorities and women and
which are having difficulty doing so. In addition, we are
requesting that the final draft of a brochure describing some of
the County' s accomplishments in the Affirmative Action and
MBE/WBE areas be forwarded to our Committee for review before it
is finalized.
It is also suggested by our Committee that once the next
quarterly report is reviewed and approved by our Committee that
future reports by the Affirmative Action Officer be limited to
semi-annual reports in order to allow the Affirmative Action
Officer more time to work with individual departments rather than
gathering statistics on what the departments have or have not
done.
Coni,a Co-fa County
COUNTY COUNSEL'S OFFICE RECE;VED
CONTRA COSTA COUNTY
MARTINEZ, CALIFORNIA O.0 T 0 4 1989
Offce of
Date: October 4, 1989 C0U(_+y Aolministr?
To: Internal Operations Committee
From: Victor J. Westman, County Counsel �i r
By: Mary Ann McNett, Deputy County Counsel
Re: Consent Decree and Other Affirmative Action Programs
SUMMARY: The County's existing consent decree is consistent
with standards for affirmative action plans specified in recent
United States Supreme Court decisions. Possible additional actions
that the Board of Supervisors might take in regard to affirmative
action include adoption of a Board Order expanding the basis for
application of affirmative action criteria from individual job
classifications to broader categories of jobs for which
identifiable labor market data is available; and changing the
numerical standard used to determine if an imbalance in the number
of females and minorities exists. Such actions would not be
inconsistent with recent Supreme Court decisions.
I. Comparison of County Consent Decree, Santa Clara County
and PG&E Affirmative Action Plans
A. Santa Clara County Affirmative Action Plan.
Santa Clara County's long range goal for affirmative
action is that the percentage of females and minorities employed ,by
the County equal their percentage in the Santa Clara County area
work force as reported by the 1980 U.S. Census. The County's short
range goal is that the percentage of protected individuals in the
County's work force approximate the percentage of protected
individuals employed in similar job classifications in the County's
recruitment area.
Each county job classification is allocated to one of the
eight job categories established by the U.S. Equal Employment
Opportunity Commission (EEOC) . For each job category, County
departments are informed which protected groups are under-
represented in comparison to their representation in the area work
force. Each County department must adopt a biannual affirmative
action plan stating short range goals for placement of protected
groups in the categories where such groups are under-represented.
In setting goals, departments must project the number of positions
Internal Operations Committee -2- October 4, 1989
to be filled for a category during the plan period and consider the
availability of protected individuals in the Santa Clara County
Area working in positions similar to the job category at- issue.
Work force availability information is based on a consulting
group's 1980 Special Occupation Tabulation for each EEOC category.
B. P.G.&E. 's Affirmative Action Plan.
The P.G.&E. plan does not specify company-wide goals for
affirmative action. All employee positions and identified job
families with common functions and skills are assigned to job
groups . Within each job group, four job categories are identified:
Management, technical, physical, and clerical. Company divisions
and departments compare the actual representation of females and
minorities employed in each job group and job category to the
estimated availability in the external work force of females and
minorities . When a minority group is underutilized, the department
must set goals for affirmative action. The plan does not specify
when a minority group is deemed underutilized. Estimated
availability is calculated through a complex statistical formula.
For any given minority, eight factors stated in Department of Labor
guidelines for Federal contract compliance programs are considered.
The factors address: minority population, unemployment and work
force percentage in the labor area surrounding a given P.G.&E.
facility; skills; recruitability; and the existence of external
training institutions . Estimated availability based on the eight
factors is tested against two benchmarks. The External Benchmark,
aweighted average of the skilled work force in the immediate labor
area, shows what the job group's ethnic and sex mix would be if
hired today; the Work Force Reference Benchmark, a weighted average
of work force data from the two most recent censuses, shows what
the ethnic and sex mix of a job group would be if hiring had been
at estimated availability in the past two census periods .
C. Comparison of Plans and Consent Decree.
The affirmative action goal expressed in the consent decree is
similar to the short range goal expressed in the Santa Clara County
plan: employment of the percentage of females and minorities in
each County job classification that reflects the percentage of
qualified members of minority groups and females in the County work
force. The Santa Clara Plan and the consent decree differ in the
manner in which County jobs are grouped for purposes of comparison.
The Santa Clara Plan allocates all County job classifications to
one of eight EEOC job categories . The consent decree does not
require that every job classification be assigned to a
comprehensive job category for which identifiable labor market data
is obtainable.
The P.G.&E. plan uses a broader external labor market for
purposes of comparison than does the consent decree. The P.G.&E.
labor market definition includes residents of all counties in the
Internal Operations Committee -3- October 4, 1989
region served by the P.G.&E facility at issue. Under the consent
decree, the external labor market includes only Contra Costa County
residents available for employment. Unlike the consent decree, the
P.G.&E. plan sets no specific, identifiable goals for affirmative
action. In cases of imbalance, the P.G.&E. plan does not establish
a goal that the percentage of females and minorities employed by
the company be equal to the percentage of qualified females and
minorities in the external work force. In contrast, the consent
decree does mandate this 100% employment goal when an imbalance
exists .
II. Possible Additions to the County's Existing Affirmative
Action Program.
A. Assignment of Job Classifications to Job Categories .
The Board could adopt an order directing the Affirmative
Action Officer to assign County job classifications to broader job
categories for which adequate external work force data exists, and
to evaluate each category in each department for imbalance under
the procedures specified in the consent decree. This would assure
that County job classifications are not excluded from review for
imbalance due to a lack of adequate external work force data for
those classifications. Perameters for job categories are discussed
infra at page 5.
B. Change the Standard for Determining Imbalance.
The consent decree provides that an imbalance in the number of
females and minorities employed is deemed to exist when the number
is less than 80% of the number representative of the percentage
available in the external county work force qualified for a given
job classification. The Board could adopt an order specifying that
an imbalance will be deemed to exist when the number employed is
less than 85% or 90% of the number representative of the percentage
of available qualified minorities and females in the external
County work force. By tightening the standard imbalance would be
deemed to exist more frequently, thereby requiring that more goals
and timetables for affirmative action be set.
We do not recommend that the Board modify the definition of
the external work force to include individuals residing outside
Contra Costa County. The current definition, limited to County
residents, operates to the advantage of those minorities who are
County residents . Goals for affirmative action provide employment
opportunities for a given minority group that are more likely to be
in proportion to that group's actual representation in the County
population, and potential employment opportunities for resident
minorities are not diluted.
Internal Operations Committee -4- October 2, 1989
III. Legality of Suggested Actions
A. Review of Recent Supreme Court Decisions
In 1987, the United States Supreme Court upheld an
affirmative action plan voluntarily adopted by the Santa Clara
County Transportation Agency. (Johnson v. Transportation Agency
(1987 ) 480 U.S. 616; 94 L.Ed.2d 615 . ) The Court held that an
employer may adopt a voluntary affirmative action plan to rectify a
"manifest imbalance" in the representation of females and
minorities in traditionally (or actually) segregated job
categories . The Court set standards for determination of a
"manifest imbalance. " To assess whether an imbalance exists in
jobs which do not require special expertise or training programs
designed to provide expertise, a plan should require a comparison
of the percentage of women and minorities in the employer's work
force to the percentage in the area labor market or general
population. In determining whether an imbalance exists in skilled
jobs, the proper comparison is between the percentage of women and
minorities in the employer' s work force and the percentage of
qualified women and minorities in the area labor force. (Johnson
v. Transportation Agency, supra, 480 U.S. at p. 631, 632; 94
L.Ed. 2d at 630, 631. ) The Johnson case further held that an
affirmative action plan: must take distinctions in qualifications
into account in providing guidance for actual employment decisions;
may take sex or race into account as one factor in employment
decisions; should be flexible and take a moderate, gradual approach
to eliminating an imbalance, with minimal intrusion on the
legitimate expectations of other employees; and should be intended
to attain a balanced work force, not to maintain a permanent racial
and sexual balance. (Johnson v. Transportation Agency, supra, 480
U.S. at p. 638-640; 94 L.Ed. 2d at 635-637 . )
In Wards Cove Packing Co. v. Antonio (June 5, 1989 ) 490 U.S.
104 L.Ed.2d 733, the Court considered the necessary elements of a
prima facie case, under the disparate impact theory, of racial
discrimination prohibited by Title VII of the 1964 Civil Rights
Act. Though not addressing affirmative action plans, this case
helps clarify the proper way to calculate an "imbalance. " The
Court described the statistical proof necessary to show the
disparate impact of a facially neutral employment practice. Such
proof must be developed by comparing the racial composition of the
at-issue jobs with the racial composition of the qualified
population in the relevant labor market. (Wards Cove v. Antonio,
supra, 490 U.S. ; 104 L.Ed. 2d at 747 . ) The Court further held
that the relevant labor market cannot be limited to the employer's
internal work force. Such a definition of the labor market would
be too narrow because it would exclude the qualified minorities who
are not current employees . (Wards Cove v. Antonio, supra, 490 U.S.
; 104 L.Ed. 2d at 749 . ) However, the Court did not address the
relevant labor market for promotional examinations .
" a
Internal Operations Committee -5- October 4, 1989
are not current employees. (Wards Cove v. Antonio, supra, 490 U.S.
104 L.Ed.2d at 749 . ) However, the Court did not address the
relevant labor market for promotional examinations.
B. Assessment of Consent Decree.
The Consent Decree complies with the requirements of the
Johnson and Wards Cove cases . In determining whether an imbalance
exists which would require establishing a goal for affirmative
action, the decree requires a comparison between the number of
females and minorities who are employed in a given job
classification and the number of Qualified minorities and females
in the external County work force. As required under the Johnson
case, the decree takes distinctions in qualifications into account
in providing guidelines for employment decisions . Moreover, the
consent decree is flexible and designed to address imbalance where
it actually exists . The decree is not intended to maintairr a
permanent racial and sexual balance but to attain a balanced work
force reflective of the number of qualified females and minorities
in the external labor market.
C. Assessment of Proposed Actions .
If the Board adopted an order effectuating the two proposals
suggested above, such action would not be inconsistent with the
recent Supreme Court decisions. Neither decision addressed how an
employer may group jobs for purposes of comparison to the external
work force. The use of job categories is permissible as long as
the jobs included in a single category have similar qualifications.
Positions which are arguably, similar but have qualifications that
vary significantly should not be placed in the same category. For
example, engineers, doctors, and attorneys should not be in the
same job category even though they are all licensed professional
positions . In addition, external labor market data must exist for
each category. These requirements are necessary to ensure
consideration of job qualifications and a meaningful basis for
comparison.
The recent cases also do not address the point at which an
imbalance in the percentage of minority and female employees
exists. Neither of the recent Supreme Court cases would prohibit
the Board from adopting an order tightening the numerical standard
used to calculate imbalance. The Wards Cove case does say that,
absent a practice discouraging minority applications, a particular
selection mechanism probably does not have a disparate impact on
minorities unless the percentage of minorities employed is .
significantly less than the percentage of qualified minorities who
applied. (Wards Cove v. Antonio, supra, 490 U.S. at p. ; 104
L.Ed. 2d at 749 . ) The standard for determining when employment is
"significantly less, " or out of balance, is uncertain. In
considering the issue, a court might refer to the EEOC Guidelines
on Employee Selection Procedures . These guidelines adopt the
1
Internal Operations Committee -6- October 4, 1989
"4/5ths" or "80 percent" rule as a standard for determining the
adverse impact of employment practices. Under the rule, a
selection rate for any race, se_x or ethnic group which is less than
80 percent of the rate for the group with the highest selection
rate is generally regarded as evidence of adverse impact. (Title
29 Code of Fed. Regs . ch. XIV § 1607 .4 (D) . ) Thus, a twenty percent
disparity would be "significant. " However, the guidelines also
provide that smaller differences in selection rate (i.e. , less than
twenty percent) show adverse impact where they are significant in
statistical and practical terms . (Title 29 Code of Fed. Regs . ch.
XIV § 1607 .4(D) . )
MAM/tb/jh
cc: Emma Kuevor, Affirmative Action Officer
J-1a:\compare.£
1
Contra Costa County
MBE/WBE CONTRACT COMPLIANCE PROGRAM
Affirmative Action Office
651 Pine Street, Martinez, CA 94553
(415) 646-4106
DATE: October 9, 1989
TO: Internal Operating Committee
FROM: Emma Kuevor
Affirmative Action Officer
SUBJECT: Comparing Affirmative Action Plans
The Internal, Operations Committee requested a comparison between
two agencies Affirmative Action Programs and the County ' s
Affirmative Action Program. Santa Clara County and PG&E were the
agencies selected for the comparison.
Santa Clara County. has 13 , 478 employees with an Affirmative
Action & MBE/WBE staff of three ( two professionals and one
administrative support position) . Their MBE/WBE Program does not
include a detailed certification procedure or the responsibility
for monitoring construction projects.
PG&E ' s corporate office has approximately 18,000 employees in
their Northern/Central California region (from Bakersfield to the
Oregon border) . They have four staff (three professionals and
one administrative support) for the Affirmative Action
responsibilities and seven ( five professionals and two
administrative support ) staff for their MBE/WBE Contract
Compliance Program.
Contra Costa County has as of June 30, 1989, 6,518 employees in
the workforce. There are three positions (two professional and
one administrative support ) in the Affirmative Action Office
responsible for implementing a comprehensive Affirmative Action
Program and MBE/WBE Contract Compliance Program.
There are several areas among the agencies that are similar and
others that are significantly different. The areas that are
different involve who is included in the program and how goals
are established.
Santa Clara County' s program includes handicapped individuals
and a goal is established for that group . PG&E includes
handicapped individuals , disabled veterans and Vietnam Era
. Veterans , but does not establish a goal for these groups. Our
County does not include handicapped individuals , disabled
veterans or Vietnam Era Veterans.
The second significant difference involves the way timetables and
goals are established. The general labor force in Santa Clara
County (by race/ethnic and sex) is used to establish their goals
Their goals are Countywide by occupational category such as
Officials & Administrators , Professionals , Technicians , etc.
PG&E ' s goals are based on job groups similar to occupational
categories and they use a formula that includes the labor force.
The County's timetables and goals are based on labor force data
in Contra Costa County by job classes.
Some of the areas that are similar in all of the agencies are
training supervisors and employees about Affirmative Actin laws
and why we have an Affirmative Action Program; monitoring
applicant flow data; recruitment; and disseminating information
to community groups and professional organizations.
The County ' s program is unable to be aggressive in its
implementation because of the volume of work. For example ,
Contra Costa County should be able to:
1. indicate corrective action if adverse effect
exists on exams (very little time is given to
this task and it' s difficult to keep track of
the next time the exam is given; Personnel
Analyst document corrective actions but my
review of the recommendations is only for the
highly visible classes like firefighters ,
clerical classes, etc. ) ;
2. review representation on eligible lists
prior to their expiration dates (a tickler
file or procedure has not been developed to
monitor this task) ;
3. review disciplinary actions in departments
( little time is given to follow up with
departments on disciplinary actions except
for those employees who file a discrimination
complaint) ; and
4. participate in new employees orientation (no
time is given to this task by the Affirmative
Action Office although it is reviewed in the
New Employees ' Orientation Workshop.
Page 2
In addition to these points our County is reviewing in a general
manner:
5. monitoring the selection of applicants from
the eligible lists for exams that are
targeted;
6. assisting departments implement their
Department Affirmative Action Plans when
requested;
7. establishing a procedure to survey the
workforce for employees who may have become
disabled and want to be identified as a
handicapped employee;
8. presenting our consent decree requirements in a
different format.
Our County meets the requirements of an effective program;
however, more can be done. Our program is more detailed than the
two programs reviewed; therefore, any changes in our program, to
become similar to Santa Clara County or PG&E' s program, will not
affect our legal requirements under the consent decree.
Page 3
WP:A:Compare.AAPlan
OFFICE OF THE COUNTY ADMINISTRATOR
C O N T R A C O S T A C O U N T Y
Affirmative Action Office
Administration Building
651 Pine Street
Martinez, California
DATE: September 21, 1989
TO: Internal Operations Committee
FROM: Emma Kuevor, Affirmative Action Office
SUBJECT: Affirmative Action Quarterly Report
The following is a report on the County' s Affirmative Action
Program. The Internal Operations Committee has requested a
report on a quarterly basis to review the County' s Affirma-
tive Action and Contract Compliance Programs. The County's
hires, promotions and separations will be presented, fol-
lowed by an analysis of the County's MBE/WBE Contract
Compliance Program.
Affirmative Action Program
The County compares itself against Contra Costa County 1980
labor force data which is: 42% females; 7. 6% Black; 7.7%
Hispanics; 5.4% Asians, Pacific Islanders/Filipinos, and .6%
American Indians/Alaskan Natives.
1. Hires
a. Countywide
This is the second quarter (April, May, June) report.
Black and female employees were significantly above
their labor force representation ( 32 ( 12%) and 190
(720) respectively] ; Hispanics (20/7.60) ,
Asian/Pacific Islanders (11/4. 10 & Filipinos (6/2. 2%)
and American Indians/Alaskan Natives (2/.7$) near or at
their labor force representation. . There were
(186/700) White employees hired. The total number of
people hired this quarter was 262 employees.
I . O. Committee
9-21-89
b. Occupational Categories
The largest number of hires (attachment 1) occurred in
the Professional (79) and Administrative Support (66)
categories. There were ( 55/69%) females and' (24/ 30%)
males hired in the Professional category. Minority
groups hired the following: Hispanics (4/ 5%) ; Black
(8/10%) ; Asian & Pacific Islander ( 4/5%) ; Filipino
(3/3%) ; American Indians ( 1/1. 0%) ; and White employees
were ( 56/70%) .
The Administrative Support category is (61/92%) females
compared to (5/7%) males. This category also had (8/
12%) Hispanic; ( 9/13%) Black; (2/3%) Asian/Pacific
Islanders; (0%) Filipinos and (45/68%) White employees.
c. Departments
The departments (attachment 1) with the largest number
of employees hired this quarter were Health Services
with twenty ( 20) and Sheriff-Coroner with fifty-three
( 53) .
2. Promotions
a. Countywide
There were 58 promotions (attachment 2) this quarter.
An. equal number of females (29/50%) were promoted when
compared to males 29/50%. Among minorities ( 6/10%)
Blacks; (3/5%) Asian/Pacific Islanders; (3/5%)
Filipino; Hispanics ( 4/6%) ; and (2/3%) American Indians
promoted. There were ( 40/68%) White employees
promoted.
b. Occupational Categories
Professional (25) and Administrative Support (15) were
occupational categories (attachment 2) with the largest
number of employees promoted.
Employees in the Professional category had ( 13/52%)
that were females compared to (12/48%) males, with
(1/4%) Black; ( 1/4%) Hispanic; ( 1/4%) Asian Pacific
Islander; (3/12%) Filipino; (2/8%) American Indian/
Alaskan Native; and ( 17/68%) White employees.
Page 2 of 5
I . O. Committee
' 9-21-89
The Administrative support category had ( 12/800)
females compared to (3/200) males with ( 1/60) Hispanic;
(2 /13%) Black; (1 or 6%) Asian and Pacific Islander;
and (11 or 730) White employees.
C. Departments
The department (attachment 2) with the largest number
of promotions is the Sheriff/Coroner' s Department with
7 employees promoted, of which (2/280) were females,
compared to ( 5/710) males, Black (2/50) ; and White
employees were (5/ 71%) promoted.
3 . Separations
a. Countywide
During this quarter there were 117 separations
(attachment 3 ) . Females separated at a higher
percentage (79 or 670) than males ( 38 or 32%) . There
were 14 or 11% Black employees that separated and
( 3/2%) Hispanic; Asian & Pacific Islanders ( 5/4%) ;
Filipino ( 8/60) American Indian and Alaskan Native
(11/8%) and White employees ( 85 or 72%) .
b. Type of Separation
The largest number of separations (attachment 3 ) were
due to resignations ( 94 ) ; followed by retirements ( 13 ) ;
and dismissals ( 6) .
SUMMARY
Females, Asian/Pacific Islanders and Black employees were
hired significantly above their labor force repre-
sentation. American Indians were hired at their labor force
representation and Hispanics were . 1% short of their labor
force representation.
Promotions showed a similar pattern with females,
Asian/Pacific Islanders and Black employees significantly
above their labor force representation. American Indians
and Hispanics were below their labor force representation.
The freeze (May 1989) resulted in fewer hires and promotions
Countywide; however, the County was still able to maintain
its aggressive hiring and promotions of minorities and
females.
Page 3 of 5
I. O. Committee
9-21-89
MBE/WBE Contract Compliance Program
The County continues to review its Contract Compliance
Program and evaluate the progress being made in this program
area.
1. West County Justice Center
The West County Justice Center (attachment 4) is
approximately 50% completed. Walsh Construction
continues to make concerted efforts to increase the
minority and female participation on this project in
order to meet or exceed the County' s goals of 130
minority and 2% female. Walsh currently has 11.1%
minority ($3,288,460. 00) and 2. 2% female ($663,203 )
projected expenditure through the utilization of
MBE/WBE subcontractors, second tier subcontractors,
suppliers and truckers.
Through July 31, 1989, there were twenty-five ( 25)
sub-contractors actively performing work with overall
percentages of 38% minority and 1.39% female
participation which meets the County' s work force goals
of 20.7% minority participation goals but falls short
of the female goal of 6%.
2. Other Construction
(a) Construction projects (attachment 5) awarded for
the reporting period July 1, 1989 through .
September 30, 1989, totaled $1,550,979 of which
MBE's received 10% or $160,892; WBE' s received
2.8% or $43,407 and local firms received 38% or
$594,658. (Local non-minority firms received 37%
or $573,827, 0% to local women business
enterprises and 1. 3% or $20,831 to local minority
businesses. )
Contracts awarded in this period with Disadvantage
Business Enterprise (DBE) requirements totaled
$2,005,068 with DBE' s receiving $410,106 or 20%.
A total of $41 , 000 or 2% was awarded to local DBE
firms.
The combined. (Public Works and General Services)
construction projects awarded in this period
• totaled $3,556, 047. A total of $635, 658 or 18%
was awarded to local firms ($573,827 or 16% to
local non-minority firms; 0% to local women
business enterprises; $41, 000 or 6% to local
DBE's; and $20, 831 or 1. 1% to local minority
businesses) .
Page 4 of 5 '
I . O. Committee
' 9-21-89
3 . Purchasing Contracts
We continue to finalize the quarterly reporting
procedures for our purchasing contracts. Department
MBE/WBE liaisons have been sent copies of the January
to March and the April supply reports for their review,
corrections and comments. Comments have been received
and changes have been made.
4 . Service Contracts
Department MBE/WBE liaisons are reviewing their service
reports for January to March and April. They were
asked to submit their comments and corrections so we
can move toward finalizing the service reports. Their
comments have also been received and changes are being
made to finalize the professional/personal services
report.
ADDITIONAL REQUESTS
1. The I . O. Committee requested an update on the
accomplishments of the County' s Affirmative Action and
MBE/WBE Contract Compliance Program for the last three
years. An analysis of our progress is presented in
attachment 6 .
2. The departments were advised of their need to meet
employment parity for 1990. In attachment 7 the
departments have submitted their plans and objectives
to show how they will meet parity by 1990 .
3. The Affirmative Action Subcommittee of the Advisory
Comittee on the Employment and Economic Status of Women
requested an analysis of salary ranges for departments
on a quarterly basis grouped into three or more salary
ranges. Data Processing and the Affirmative Action
Office staff are finalizing the procedure to generate a
quarterly departmental salary analysis.
CONCLUSION
The Affirmative Action Quarterly Report continues to
show progress in both the Affirmative Action and Contract
Compliance Programs.
B:QREPORT.doc
Page 5 of 5
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a
Contra Costa County
MBE/WBE CONTRACT COMPLIANCE PROGRAM
Affirmative Action Office
651 Pine Street, Martinez, CA 94553
(415) 646-4106
Date: 9/31/89
TO: Emma Kuevor,
Contract Compliance Officer
FROM: Sheila Walker,
Contract Compli Specialist
SUBJECT: Status Report on West County Justice Center
WEST COUNTY JUSTICE CENTER
STATUS REPORT AS OF JULY 31, 1989
This $29, 678 , 350 . 00 project is approximatey 50% complete.
To-date, the Prime Contractor has a projected expenditure of
$3 , 288 , 460. 00 or 11. 1% through the utilization of MBE
sub-contractors, 2nd tier sub-contractors, suppliers and
truckers as follows:
Carlos Interiors MBE/Hispanic Non-Local $ 317,775
Valverde & Son MBE/Hispanic Non-Local 329;285
Aire Sheet Metal MBE/Black Non-Local 1,616,000
Fred Grimes Trucking MBE/Black Local 9,000
Jensen Electric MBE/Hispanic Non-Local 800, 000
Gaffney Glass MBE/Black Non-Local 16, 400
Watson Electric MBE/Amer. Ind Local 200,000
and $663 ,203 or 2 . 2% through the utilization of WBE
sub-contractors, 2nd tier sub-contractors, suppliers and
truckers as follows :
Kinel of California WBE Non-Local $ 1 , 480
Frank Alegre Trucking WBE Non-Local 2, 806
R & S Trucking WBE Non-Local 46, 917
Bauman Landscape WBE Non-Local 490, 000
City Electric Supply WBE Non-Local *300 , 000
Glastech WBE Non-Local 92,000
* Actual contract = $500 , 000; however because they are
suppliers, 60% of $ are counted.
Page 1 of 4
Attachment 4
Walsh Construction, through their Project Manager, Bob
Abbott, has made, and is continuing to make, a concerted
effort to increase the minority and female participation on
this project in order to meet or exceed the County' s goals
of 13% minority and 2% female. This effort is evidenced by
the increase in participation from 2% at time of bid opening
to 11. 5% through January 1989 for minorities and from . 0005%
to 1. 9% through January 1989 for females. The slight
decrease in minority participation and proportionate
increase in female participation is due to the substitution
of Gaffney Glass (MBE) with Glastech (WBE) . Gaffney was not
properly licensed and was not performing. Walsh
Construction is continuing to encourage sub-contractors to
utilize minority and/or female suppliers and second tier
sub-contractors wherever feasible.
$5, 591. 400 or 18. 84% of the contract dollars were committed
to local business. ( $5, 580, 401 or 18. 83% to non-minority
local firms and $11, 000 or . 01% to local minority firms. ) A
breakdown of firms, their locality and percentage of the
contract follows:
WEST COUNTY JUSTICE CENTER $29, 678, 350. 00
Phase B
Walsh Construction, Scaramento, CA 10. 2%
Areoplex, Sacramento, CA . 08%
Automated Filing System, Emeryville, CA . 2%
AA Aimes Co. , San Leandro, CA less than 6k
Anning-Johnson Co. , Burlingame, CA 1 . 2%
Frank Alegra Trucking, Lodi, CA . 00009%
Allen Building Products, Oakland, CA . 46%
Arrowoods, San Dimas, CA 1%
Bauman Landscape, San Rafael, CA (WBE) 1. 9%
Beck Steel, Inc. , Lubbock, TX 5. 4%
Boldig Enterprises, Rancho Cucamonga, CA . 4%
The Brookman Co. , Burlingame, CA 1. 1%
California Builders Hardware, Concord, CA 1. 2%
Carlos Interiors, San Francisco, CA (MBE-H) 1%
CM Security Group, Montreal, Canada . 88%
Coast Insulation, Martinez, CA . 080
Contra Costa Electric, Martinez, CA .12%.
Display Concepts, Sacramento, CA . 09%
Emerald Food Service Equipment Co. , Secaucus, NJ .15%
Norwalk Food Service Equipment Co. , Secaucus, NJ 3%
Erickson, Fairfield, CA 1. 4%
Falconer Glass Industries, Sacramento, CA . 37%
Gaffney Glass, Sacramento, CA (MBE-B) . 490
Gallette & Sons, Inc. , Martinez, CA 5 . 4%
Gradeway, Fremont, CA 1 . 30
Fred Grimes ' s Trucking, Richmond, CA (MBE-B) . 00030
The Healthco International, Hayward, CA .110
Hope' s Architectural, Jamestown, NY . 4%
J.R. Enterprises, Saratoga, CA . 4%
Page 2 of 4
Kidde Automated Systems, Long Beach, CA 8. 40
Lafayette Manufacturing, Hayward, CA . 3%
Lodestar Elevator Co. , Benicia, CA .150
Masonry Services, Pleasanton, CA 8.90
J.W. McClannahan, San Mateo, CA . 120
B.T. Mancini Co. , Santa Clara, CA . 4%
Marathon Engineering, Mountain Ranch, CA . 25%
Nor-Cal Caulking, Sacramento, CA . 26%
Oakland Fence, Hayward, CA 1. 6%
Overhead Door Co. , Stockton, CA . 09%
Owen Pacific, Hayward, CA 1. 1%
Pacific Allied Fire Protection, Oakland, CA 1. 80
Penninsula Floors, Fremont, CA . 1%
R & S Trucking, Sebastapol, CA (WBE) . 0015%
Security Metal Products, Hawthorne, CA .5%
Herb Shearer Plastering, Inc. , Bakersfield, CA 7. 8%
Tec-Flor Services, San Francisco, CA . 2%
Universal Security Products, Hayward, CA 1. 4%
Valverde & Sons Painting, Santa Clara, (MBE-H) 1 . 18%
Western State Design, Hayward, CA 45%
Second-Tier Sub-contractors:
Aire Sheet Metal, Redwood City, CA (MBE-B) . 05%
Jensen Electric, Watsonville, CA (MBE-B) . 26%
Watson Electric, San Pablo, CA (MBE-AI) . 0067%
City Electric Supply, Novato, CA (WBE) . 001%
Through July 31, 1989 the following contractors were
actively performing work on this project with workforces
composed of the ethnic/gender composition reflected below.
Minority Female
Walsh Construction 50% 0%
Erickson & Associates 69% 18%
Oakland Fence 0% 0%
Galleti & Sons, Inc. 50% 0%
J.W. McClenahan 170 0%
.. ,Contra Costa Electric 29% 7%
Masonry Services 48% 5. 160
Kidde 20% 0%
Kister, Savio & Rei 0% 0%
Bauman Landscape (WBE) ** 89% 8%
Gradeway 41%. 0%
Jensen Electric (MBE/Hispanic) * 0% 0%
Watson Electric (MBE/Amer. Ind) * 0% 0%
Alegre Trucking (WBE) **
R & S Trucking (WBE) **
H.C. Hansen Company 85% 0%
Camblin Steel Services 200 0%
Page 3 of 4
Beck Erectors 43% 0%
Aire Sheet Metal (MBE/Black) * 100% 0%
Gaffney Glass Service (MBE/Black) * 1000 0%
Pacific Allied Fire Protection 25% 0%
Lodestar Elevator Co. 0% 0%
Cost Insulation 13 0%
Carlos Interiors 100% 0%
Owen Pacific 51% 0%
* = MBE Contractor
** = WBE Contractor
Overall percentages for the project are 38% minority and
1. 39% female which meets the County' s workforce goals of
20. 7% minority but falls short of the female goal of 6%.
Bob Abbott, Walsh Construction Project Manager, has been
notified of this via a copy of this memo.
SW:cg
WCJC.RPT
cc: Bob Abbott, Project Manager
Walsh Construction
Page 4 of 4
u.
OFFICE OF THE COUNTY ADMINISTRATOR
C O N T R A C O S T A C O U N T Y
Affirmative Action Office
Administration Building
651 Pine Street, Martinez, California
QUARTERLY REPORT
Construction projects awarded for the reporting period
July 1, 1989 through September 30, 1989, totaled $1,550,979
of which MBE' s received 10% or $160,892; WBE' s received 2.8%
or $43 , 407; and local firms received 38% or $594,658.
(Local non-minority firms received 37% or $573,827; 0% to
local women business enterprises and 1 . 3% or $20,831 to
local minority businesses. )
Contracts awarded in this period with Disadvantage Business
Enterprise (DBE) requirements totaled $2 ,005,068 with DBE' s
receiving $410, 106 or 20%. A total of $41,000 or 2% was
awarded to local DBE firms.
The combined (Public Works and General Services)
construction prjects awarded in this period totaled
$3,556,047. A total of $635,658 or 18% was awarded to local
firms ( $573 ,827 or 16% to local non-minority firms; 0% to
local women business enterprises; $41, 000 or 6% to local
DBE' s and $20,831 or. 1/1% to local minority businesses) .
Following is a breakdown of contracts awarded in the first
quarter of fiscal year 189-190 by department.
I. General Services
Fire Station #7 $6.73,000
*Pacific Construction Corps. , Oakland 260,188
B&B Excavating & Grading Co. , Oakland 56,952
Horizon Construction, Clayton 13,331
(MBE-H-Mexican/American)
Giles Landscape, Walnut Creek 21,900
R & O, San Ramon 4,980
Coliseum Steel Products, Oakland 7,280
Sierra Fencing, Morgan Hill 8,781
Graphics in Wood, Carmichael 28,025
Alcal, San Ramon 3,640
C.W. Delta Roofing, Modesto 13,700
Overhead Door, San Leandro 8,676
Hayward Glass, Hayward (WBE) 4,345
O'Donnel Plastering, Santa Clara 15,175
* Prime Contractor
Attachment 5
R & I Specialties, Suisun 10,393
Calif. Tile, San Jose 12,500
Pleasanton Flooring, Pleasanton 11,498
Tollner Painting, Menlo Park 14,516
Petroleum Engineering 28,063
Marque, Sacramento 18,445
Ehlert Sheet Metal, San Jose 37,500
Scott Electrical, San Francisco 57, 050
Miars Plumbing, Danville 30,000
Continental Bldg. Specialties, S.F. (WBE) 6,062
Total General Services Contract = $673 ,000
MBE _ $13, 331 or 20
WBE _ $10,405 or 1. 5%
II. Public Works $65,669.00
1. Manor Road Bike Lanes
*Gallagher & Burke, Inc. , Oakland 34,461.00
Bunny Chang, Mt. Eden, (MBE-A-Chinese/ 19,616.00
American)
Sugar Loaf, Fremont (WBE) 1,642.00
M.F. Maher, Vallejo 4,800.00
Chrisp, Fremont 3,150.00
2. Marsh Creek Road Slide Repair ** $262,376.00
*Evans Cros, San Ramon 140,697.00
Carefree Greens, Sacto (WBE) 1,150.00
A.C. Dike Company, Loomis (WBE) . 1,953.00
George Hall Trkg, Sacto (MBE-Black) 4,444.00
Rich Heminez Concrete, Mtz (MBE-H-Mexican/ 36,000.00
American)
Retaining Wall Company, Dublin 78,000.00
3 . Parr Boulevard Overlay $199,358.90
*Gallagher & Burk, Oakland 150,015.90
Fred Grimes Trucking, Oakland (MBE-Black) 16,524.00
Esprit Enterprises, San Jose (MBE-H-Mexican/ 10,287.00
American)
Sugarloaf Trkg. Fremont (WBE) 4,000.00
Anrak Corp. , Belmont 11,098.00
Chrisp Co. , Fremont 7,434.00
4. Neroly Rd. Realignment ** $130,351.50
*Wm. G. McCullough, Antioch 110,351.50
Ayalla Trkg. Manteca (MBE-H-Mexican/ 115,000.00
_American)
Sabotka Specialties, W.C. (MBE-H-Mexican/ 5,000.00
American)
* Prime Contractor
** DBE Goal Requirements
Page 2
Y t1 y
5. San Pablo Dam Rd. Slide Repair ** $244,567.00
*O.C. Jones & Sons, Berkeley 177,342.00
Central Fence, Sact, (MBE-H-Mexican/ 4,410.00
American)
R & S Trucking, Sebastopol (WBE) 10,000.00
Robertson Trkg. Fremont (WBE) 10,000. 00
A.C. Dike, Lincoln (WBE) 1,050.00
Allen Drilling, San Jose 24,000.00
Cagwin & Darward, Novato 3,935.00
Strange & Chalmers, Vallejo 4,790.00
Farwest, Inc. , Tracy 9,040.00
6. AA2pian Way Widening Phase ** $1,367,772. 00
*Gallagher & Burk, Oakland 796,274.00
Bunny Change Pipeline, Hayward
(MBE-A-Chinese/American) 170,262.00
Fred Grimes Trkg, Oakland (MBE-Black) 145,655.00
Vega Fence, Pleasant Hill (MBE-H-Mexican/
American) 7,500.00
Anrak Corp, Belmont 41,800.00
Strange & Chalmers, Vallejo 146,809. 00
Chrisp Co. Fremont 33,377.00
Continental Electric, Pinole 26,095.00
7. Alves Lane Signal Project $ 188,000. 00
*Steiny & Co. , Vallejo 115,388. 00
National Electric Supply, S.F.
(MBE-A-Pacific Islander) 21,470.00
James Diaz Painting, San Jose ,
(MBE-H-Mexican/American) 580.00
Severine Co. , Napa (MBE-H-Mexican/
American) 19,084. 00
Construction Area Signs. , Sacto (WBE) 4,000.00
Sage Construction, Larkspur 17,523 . 00
Riley's Striping, Mtz 9,955.00
8 . Highway 4 Near Discovery Bay
Kellogg Creek & Kendall Creek
Overflow Bridge Replacements $424,952.90
*Wm. G. McCullough, Antioch 218,878. 00
Mission City Rebar, Santa Clara
(MBE-H-Mexican/American) 60,000. 00
Parker Signs, Tracy (WBE) 1,500.00
Jones Trkg, Stockton (WBE) 19,860. 00
Foundation Construction, Antioch 124,714 .00
* Prime Contractors
** DBE Goal Requirements
Page 3
Total Public Works contracts with M/WBE requirements
$ 877,979
MBE = $147,561 or 16. 8%
WBE = $ 33,302 or 3 .7%
Total Public Works contracts DBE requirements
$2,005, 068
DBE = $410,106 or 20%
Total Public Works Contracts: $2,883 ,047
MBE = 147, 561 or 5%
WBE = 33 ,302 or 1%
DBE = 410,106 or 14%
III. Grand total constructions contracts with M/WBE
requirements: $1,550, 979
MBE = $160,892 or 10. 4%
WBE = $ 43 ,407 or 2. 8%
IV. Grand total contracts with DBE requirements:
$2,005,068
Total DBE awarded contract: $410,106 or 20%
* Prime contractors
** DBE Goal requirements
EK:ss
DW4:A:QUART.RPT
Page 4
f
AFFIRMATIVE ACTION ACCOMPLISHIMENTS
1986 - 1989
The County' s Affirmative Action Program is not static. It
changes continuously. The changes in our County have been
positive in several different areas.
In 1986, the County employed 6, 029 of which 580 ( 3504) were
females and 41% (2525 were males. The County' s goal is to
have the County' s employees reflect the County' s labor
force. Females exceed the labor force goal of 42%. Each
race/ethnic group exceeded their goals (Black 7. 60,
Asian/Pacific Islanders 4. 7% ; and American Indians/Alaskan
Natives .7%) except Hispanics (7.7%) . Hispanics were
under-represented in the County with 6. 8% ( 409) Hispanic
employees. The other groups were 662/11% for Black
employees; 297/4. 9% for Asian/Pacific Islanders; and
49/ . 8% for American Indians/Alaskan Natives.
Departments targeted Hispanics as the group most under
represented but they also continued to focus on females and
minorities at mid-management and management level positions.
In order to assist supervisors meet their departments
affirmative action objectives, training was given more
emphasis and new training workshops were developed to assist
employees. The training division in the Personnel
Department was expanded and departments began - to conduct
their own . training and request specialized and customized
training just for their department.
The County's Handicap Program continued to evaluate
facilities and programs to be sure they were accessible to
handicap persons. There were 124 employees that indicated
they were handicapped. There were 29 with visual handicaps;
18 with hearing; 5 with speech; 61 with physical
disabilities; and 18 with developmental disabilities. Our
Handicap (Section 504) Committee continues to evaluate the
effectiveness of the employment and service sections of the
program.
Community and professional groups & organizations expressed
concern in the County not having a MBE/WBE Contract
Compliance Program and offered to assist in its development.
Staff from the Public Works, General Services, and County
Administrators office developed the construction policy for
the MBW/WBE Contract Compliance Program. The policy was
submitted and adopted by the Board.
Attachment 6
1
Increases and Changes in 1987 affected the County' s
Affirmative Action Program. The workforce increased to 6156
employees of which 58% ( 3601) were females and 410 (2555)
were males. Hispanics were under-represented (418/6. 80) ��..
couri/rywide but the remaining race/ethnic groups 'were above 1
their labor force representation with 110 (698) Blacks
employees; 590( 312 ) Asian/Pacific Islanders; and . 8i% ( 50),
American Indian/Alaskan Natives.
Among handicap employees there was a slight increase with
127 handicap employees. The number of handicap employees in
the different areas was 31 visual; 18 hearing; 5 speech;
63 physical; and 17 developmental disabilities. Placement
of employees through the County' s Rehabilitation Program
continued. The County also purchased adaptive equipment for
20 disabled County employees.
The County enhanced its training program and provided a
Frontline Leadership Program for Supervisors. Developing
excellence has become one of the cornerstones in our
training program. The Training Division also developed a
Certificate Program for Public Service Supervision with
instructions that are private consultants, Community College
Faculty, and professional trainers. Other workshops offered
to employees are for example, Equal Employment Opportunity;
Affirmative Action; Sexual Harrassment; Final Selection
Interviewing; & Stress Management.
The County' s MBE/WBE program was expanded to include
purchasing and professional/personal services. A consultant
was hired to assist in developing policy and procedures for
these areas and MBE/WBE goals were placed in the West County
Justice Center bid documents, the County's largest ( $28
million) construction contract.
The Pace didn' t slow in 1988. The County' s workforce
increased to 6,447 employees. There were 59% ( 3842) females
and 40% ( 2605) males. All minority groups were at or above
their labor force representation except Hispanics.
Hispanics increased their representation from 6. 8% to 7. 0%
( 449) in one year; however, they were. still below . their,
labor force representation.
Representation among the other racial groups was 11% (746 )
Black employees; 5 . 9% ( 381) Asian/Pacific Islanders, and 7%
( 48) American Indians/Alaskan Natives.
2
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Y•t-
The County's Handicap Program showed a decrease among
employees with 119. The employees in the handicap areas
were 25 visual; 17 hearing; 5 speech; 60 physical; 18
developmental disabilities. The Rehabilitation Program
continued to assist employees. Eleven County employees who
became disabled were provided with alternate work
assignments as a means of accommodating their limitations.
The County was also able to procure approximately $29,000 in
State funds to augment the salaries of five positions
provided to disabled employees. Adaptive equipment was also
purchased for thirty seven disabled County employees. The
equipment enables the employee to function at maximum
capacity & the equipment was purchased with State funds.
Training was broadened with the addition of another staff
person, the development of the County' s Statement of Values,
and the formation of a Training Council were significant
changes in 1988. The Training Council acts as an advisory
group to establish policy and give directions on thefuture
of countrywide training.
The MBE/WBE Contract Compliance Program began to implement
its policies and procedures for the construction and
purchasing sections of the program. A Contract Compliance
Specialist was also hired into the program to assist in its
implementation. A workshop was held for Minority and Women
Owned Businesses to let them know we have an MBE/WBE program
and want their participation. Staff from the Public Works
and General Services Department participated by presenting
the construction and purchasing programs. The remaining
departments discussed their professional/personal services
contract procedures with Minority and Women vendors,
consultants, etc. The Hispanic, Black and Filipino Chambers
of Commerce have assisted in letting the MBE/WBE community
know we want their business. Presentations were made at
community professional groups & organizations and various
business fairs.
SUMARY: The County' s Affirmative Action Program continues
to change. Hispanic employees increased their overall
representation from 6. 8% to 7. 0%. All other groups are at
or above their labor force representation in the County
workforce. Training is a priority in the County and actions
were taken to provide quality training for employees.
Leadership and Management courses are offered as well as a
wide variety of other classes from Public Contact Skills to
Stress Management.
The County' s Section 504 Committee continues to monitor the
County' s Handicap Program to ensure that we are recruiting,
selecting, and not discriminating against handicap
applicants and employees. The Committee monitors our
buildings to be sure they are accessible, especially when we
provide services or conducting programs.
3
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4'
The Committee also monitors the County' s ability to provide
reasonable accommodations to an employee who is, or becomes
disabled.
Although the County' s MBE/WBE program is new and is still
being reviewed, departments, Hispanic, Black. & Filipino
Chambers of Commerce, Professional, Community, and business
groups and organizations have all been very helpful. The
County has been very active in letting the MBE/WBE
businesses know we have a program; establishing departmental
procedures; and establishing procedures to implement and
evaluate the program.
The progress the County' s Affirmative Action Program has had
in the last three years should continue in the ' 901s.
EK:cg
ACCOMP.AA
4