HomeMy WebLinkAbout5961 RESOLUTION NO 5,961
A RESOLUTION AUTHORIZING THE CITY MANAGER TO
ENTER INTO A CONTRACT AND LETTER OF AGREEMENT
WITH METROPLAN FOR URBAN TRANSPORTATION PLANNING
FOR THE CITY OF LITTLE ROCK; AND FOR OTHER
PURPOSES
BE IT RESOLVED BY THE BOARD OF DIRECTORS OF THE CITY OF
LITTLE ROCK, ARKANSAS .
SECTION 1. The City Manager is hereby authorized to enter
into a contract and Letter of Agreement with Metroplan wherein
it is provided that Metroplan will administer the funding of
certain Urban Transportation Planning Process activities , as
identified in the PATS UNIFIED WORK PROGRAM as detailed in
the attached summary of services for the Little Rock corporate
area. A copy of the Contract and Letter of Agreement is
attached to this Resolution and made a part hereof as though
set out herein word for word.
SECTION 2 . This Resolution shall be in full force and
effect from and after its adoption.
ADOPTED: June 20, 1978
adufATTEST: G� !Ze,
City Cler APPROVED
Vice e Ma or
draft
CONTRACT BY AND BETWEN
METROPLAN
AND
THE CITY OF LITTLE ROCK
THIS AGREEMENT, entered into as of the day of
, by and between Metroplan and the City of Little Rock
(hereinafter called the "Contractor") , WITNESSETH THAT:
WHEREAS , Section 112 of the Federal Aid Highway Act of 1973
provides for the Federal Highway Funds to be made available to
Metropolitan Planning Organizations (MPO' s) as designated by
the Governor to support the Urban Transportation Planning process
established pursuant to Section 134 of Chapter I of Title 23
United States Code, and
WHEREAS , Metroplan has been designated by the Governor of
Arkansas as the Planning Organization responsible for conduct
of the Pulaski Area Transportation Study as described in the
PATS Prospectus and Unified Work Program documents approved by
the U. S. Department of Transportation, and
WHEREAS , Metroplan and the Contractor are participating
agencies in the PATS for the urbanized area of the Little Rock-
North Little Rock Metropolitan Area, and
WHEREAS, Metroplan desires to engage the Contractor to
render certain technical and professional services required for
completion of the Transportation Systems Management (TSM work
element of the PATS FY ' 79 Unified Work Program which is to be
financed with funds provided by Section 112 of the Federal-Aid
Act of 1973, and
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A work authorization letter will be issued upon execution
of the Contract and after the overhead rate has been established
by the Contractor, reviewed by Metroplan and AHTD and approved
by the FHWA.
IN WITNESS WHEREOF, the parties hereunto have executed this
Letter of Agreement by their duly authorized officers or agents
on this day of June, 1978.
Metroplan
City of Little Rock
LETTER OF AGREEMENT
Fiscal Year 1979
PULASKI AREA TRANSPORTATION STUDY
Between
Metroplan
and
The City of Little Rock
The undersigned hereto mutually agree to implement the
Contract entered into as of June , 1978 , between Metroplan
and the City of Little Rock which is hereinafter called Metroplan
and the Contractor as follows :
Section 112 Federal-Aid Highway Act Planning Funds in the
amount of $ for FY 1979 , are hereby made available to
the Contractor to be expended subject to and in accordaxce with
the approved Unified Work Program Tasks for the period July 1, 1978 ,
through June 30, 1979 . Following the year-end close out audit ,
any of the FY 1979 programmed amount of Section 112 Planning
Funds not spent by June 30, 1979 , will be deprogrammed, and may
be eligible for reprogramming under subsequent agreements if
mutually agreeable. Reprogramming must follow the development
of satisfactory UWP Work Tasks and development of a satisfactory
PL Contract or Letter of Agreement for the following year.
Metroplan will continue to administer PL funds in conformance
with State and FHWA regulations until the Contract is mutually
terminated.
Reimbursement for programmed tasks will be eligible for
participation with Section 112 Planning Funds after a letter is
issued by Metroplan authorizing the Contractor to proceed with
work as outlined in Section 4.
WHEREAS , all contracts with other parties for services within
the scope of the Transportation Planning Process shall be subject
to prior approval by the Arkansas State Highway and Transportation
Department (hereinafter called the "AHTD") and the Federal High-
way Administration (hereinafter called "FHWA") .
NOW THEREFORE, the parties hereto do mutually agree as follows :
1. Purpose . The purpose of this contract is to provide
for Metroplan to administer the funding of certain Urban Trans-
portation Planning process activities, as identified in the PATS
Unified Work Program (UWP) and as detailed in the attached summary
of services for the Little Rock corporate area, which are attached
hereto and made a part hereof, and establish an understanding
between Metroplan and the contractor as to the responsibility of
each agency.
2 . Employment of Contractor. Metroplan hereby agrees to
engage the Contractor and the Contractor hereby agrees to perform
the services hereinafter set forth.
3. Area Covered. The Contractor shall perform all the
necessary services provided under this Contract in connection with
and respecting the portion of the PATS Area which is within the
City's corporate boundaries .
4. Scope of Services . The Contractor shall do , perform,
and carry out, in a satisfactory and proper manner, as determined
by Metroplan, the services necessary to accomplish the Tasks of
the FY ' 79 Unified Work Program as described in the attached
TSM Work Statement , Attachment No . 1 , herewith made a part of
this contract .
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5. Data To Be Furnished to Contractor. Metroplan will
make available to the Contractor such information as is in the
possession of Metroplan and is pertinent to the study. All
mapping, secretarial and report production expense required to
accomplish the scope of services will be borne by the Contractor.
6 . Time of Performance. The services of the Contractor
are to commence on July 1, 1978 , and shall be undertaken and
completed in such sequences as to assure their expeditious
completion in conformance with the UWP schedule. If this Agree-
ment is not terminated by written mutual agreement, this basic
contract shall be amended each year by a letter agreement which
makes reference to the UWP and specifies the extent of funding.
7. Compensation. Metroplan will reimburse the Contractor
for the authorized cost incurred, which is to be matched with
20 per cent by the Contractor, for the work outlined in. Section 4
above in accordance with Federal Procurement Regulations ,
Parts 1-15 , and current AHTD practice .
8. Method of Payment . Metroplan will reimburse the
Contractor on the basis of monthly progress reports and reim-
bursement request for the authorized cost incurred which is to
be matched with 20 per cent by the Contractor for Services as
described in Section 4. All payments to the Contractor will
be made when Federal funds are available for Metroplan to use
for such reimbursement after all State and Federal Highway
Administration Regulations are satisfied. It is expressly
understood and agreed that the total compensation to be paid
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hereunder shall not exceed the authorized amount which is
setforth in the Letter of Agreement which becomes a part of
this Contract.
The Contractor shall be subject to the provisions contained
in the Agreement between the AHTD and Metroplan (the Designated
Agency) regarding direct costs , indirect costs and proposed fee
where appropriate, which cannot be exceeded without a modification
of this Contract.
Reimbursement for programmed tasks will be eligible for
participation with Section 112 Planning Funds after a letter is
issued by Metroplan authorizing the Contractor to proceed with
work as outlined in Section 4.
A work authorization letter will be issued upon execution of
the Contract and after the overhead rate has been established
by the Contractor, reviewed by Metroplan and AHTD, and approved
by the FHWA.
9 . Termination of Contract for Cause . If, through any
cause the Contractor shall fail to fulfill in a timely and
proper manner the obligations under this Contract, or if the
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Contractor shall violate any of the covenants , agreements , or
stipulations of this Contract, Metroplan shall thereupon have
the rights to terminate this Contract by giving written notice
of thirty (30) days to the Contractor of such termination and
specifying the effective date of such termination. In the event
the designation of Metroplan shall be revoked or modified, this
Contract shall automatically terminate as of the date of such
revocation or modification. Further, either party may terminate
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its interest and obligation under this Contract by giving
thirty (30) days notice in writing to the other party. In that
event, all finished or unfinished documents , data, studies ,
surveys , drawings , maps , models , photographs , and reports or
other material prepared by the Contractor under this Contract
shall, at the option of Metroplan, become its property, and the
Contractor shall be entitled to receive just and equitable
compensation for any satisfactory work completed on such docu-
ments and other materials , as determined by Metroplan.
10 . Changes . Metroplan may, from time to time, require
changes in the scope of the services described in Section 4 in
order to satisfy FHWA approved UWP Amendments . Such changes ,
including any increase or decrease in the amount of the Contractor' s
compensation , which are mutually agreed upon by and between
Metroplan and the Contractor, in cooperation with the AHTD,
shall be incorporated in written amendments to this Contract .
11. Compliance with Title VI of the Civil Rights Act of
1964. Metroplan and the Contractor agree that all operations
under the terms of this Agreement will be in compliance with
the applicable requirements of Title 49 , Code of Federal Regu-
lations , Part 21 , which was promulgated to effectuate Title VI
of the Civil Rights Act of 1964 . In furtherance of requirements
of Title 49 , the attached clauses (Attachment No . 2) are made
a part of this Contract.
12 . Interest of Metroplan and Others . No officer, member,
or employee of Metroplan and no members of its governing boay,
and no other public official of the governing body of the
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locality or localities in which the Project is situated or
being carried out who exercises any functions or responsibilities
in the review or approval of the undertaking or carrying out
of this Project , shall participate in any decision relating to
this Contract which affects his personal interest of the interest
of any corporation, partnership , or association in which he is
directly or indirectly interested, or have any personal or
pecuniary interest, direct or indirect, in this Contract or the
proceeds thereof.
13 . Assignability. The Contractor shall not assign any
interest in this Contract, and shall not transfer any interest
in the same (whether by assignment of novation) , without the
prior written consent of Metroplan thereto : Provided, however ,
that claims for money due or to become due to the Contractor
from Metroplan under this Contract may be assigned to a bank,
trust company or other financial institution without such
approval . Notice of any such assignment or transfer shall be
furnished promptly to Metroplan .
14. Interest of Contractor. The Contractor covenants that
he presently has no interest and shall not acquire any interest ,
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direct or indirect, which would conflict in any manner or
degree with the performances of services required to be per-
formed under this Contract . The Contractor further covenants
that in the performance of this Contract no person having any
such interest shall be employed.
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15. Officials Not To Benefit. No member of or Delegate
to the Congress of the United States of America, and no City
Board member, shall be admitted to any share or part hereof or
to any benefit to arise herefrom.
16. Identification of Documents . All reports , maps , and
other documents completed as a part of this Contract, other than
documents exclusively for internal use within Metroplan, shall
contain an acknowledgement on the front cover and title page
such as "prepared in cooperation with the U. S . Department of
Transportation, Federal Highway Administration" .
The title page should also include : The preparation of this
report, map, document, etc. , was financed in part through
Planning Grants from the U. S . Department of Transportation,
FHWA-PL Contract No. PL-0092(2) 701, together with the date
(month and year) the document was prepared.
17 . Office Space. The Contractor hereby agrees to provide
all office space required to perform the responsibilities under
this Contract.
18. Publication, Reproduction and Use of Materials . No
material produced in whole or in part under this Contract shall
be subject to copyright in the United States or in any other
country. Metroplan, AHTD, and the U. S . Department of Trans-
portation shall have unrestricted authority to publish, disclose,
distribute and otherwise use, in whole or in part, any reports ,
data, or other materials prepared under this Contract.
19 . Travel . Any travel outside the PATS area related to
activities of the approved Unified Work Program and funded all
or in part with Section 112 funds must have prior approval of
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Metroplan and AHTD and shall not exceed lodging, meal, and
travel expenses approved for Metroplan by the AHTD.
20 . Responsibility for Claim and Liability. The Con-
tractor shall be required to save harmless Metroplan and other
agencies of government from any and all claims , demands , suits
and judgments of sums of money to any party for loss of life or
injury or damage to persons or property growing out of, resulting
from or by reason of any negligent act or omission, operation
or work of the Contractor, its agents , servants or employees
while engaged upon or in connection with services required or
performed by the Contractor hereunder.
21. Audits and Inspections . At any time during normal
business hours and as often as Metroplan, AHTD and/or the U. S.
Department of Transportation may deem necessary, there shall be
made available to the Commission, AHTD and/or the U. S . Depart-
ment of Transportation for examination all of its records with
respect to all matters covered by this Contract and will permit
Metroplan, AHTD and/or the U. S . Department of Transportation to
audit, examine and make excerpts or transcripts from such
records , and to make audits of all contracts, invoices ,
materials , payrolls , records of personnel, conditions of employ-
ment and other data relating to all matters covered by this
Contract.
22. Records . The Contractor is to maintain all books,
documents , papers , accounting records , and other evidence per-
taining to costs incurred, and to make such materials available
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at its offices at all reasonable times during the Contract
period and for three years from the date of final payment to
the Contractor. Such materials are to be available for in-
spection by authorized representatives of the AHTD or the
Federal Government and copies thereof shall be furnished if
requested.
IN WITNESS WHEREOF, by resolution adopted by a majority
vote of the Metroplan Board of Directors to approve the services
herein on , the undersigned do hereby execute this
Agreement between Metroplan and the City of Little Rock.
METROPLAN
By:
President of the Board
IN WITNESS WHEREOF, the City of Little Rock hereby accepts
the terms and conditions of this Agreement .
CITY OF LITTLE ROCK
By: - --
City Manager
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Attachment 1
TSM WORK STATEMENT
INTRODUCTION
Transportation Systems Management (TSM) has been set forth
as a systematic approach to achieving greater performance from
existing transportation facilities and services . This proposed
work statement describes an approach for developing a TSM study
for the Little Rock portion of the Pulaski Area Transportation
Study. The proposal is set forth in response to the city' s need
to actively pursue and improve TSM planning efforts .
A number of TSM actions have already been initiated in the
City of Little Rock. These range in scale from an ongoing pro-
gram of traffic engineering improvements to large scale projects .
Large scale actions include auto free zones in Metrocentre Mall ,
transit turnouts on 1-630, transit park and ride sites , and
signalization studies . These actions serve to highlight the
TSM interest and accomplishments of the City. In addition to
these actions is an apparent need to improve the overall efficiency
of transportation by reducing the amount of energy consumed for
transportation, and reducing the level of noise and air pollution
within the area. This joint planning effort will significantly
enhance the cooperative aspects of the PATS process and should
lead directly to the programming of TSM projects utilizing both
Federal-Aid Urban and Urban Mass Transportation Administration
construction funds .
The following work statement is presented in three sections
describing the study approach , organization, and scope of work.
The approach describes the study objectives and general work flow.
The organization indicates the composition of the study team, the
agencies involved, and their responsibilities . The scope of work
describes each task in terms of purpose and activities .
Approach
Metroplan' s approach to the study is directed at accomplishing
study objectives . These objectives are listed below and are
addressed by tasks in the scope of work.
Objectives
1 . To formulate , apply and evaluate procedures for systematic
TSM planning in the PATS area that will provide the
basis for a beneficial , on-going process .
2 . To establish a TSM planning process that includes :
a. A clear statement of goals and objectives .
b . An evaluation of existing conditions .
c . An adequate set of proposed actions .
d. Justification of actions recommended for inclusion
in the TIP .
e. Adequate and timely funding.
f. A balance of the level of planning effort with the
scope of problem solution.
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3. To broaden familiarity and experience of the City of
Little Rock with TSM planning addressing a cross-section
of transportation problems .
Organization
The PATS Study Director will have primary responsibility for
all aspects of the TSM study.
A TSM working group will be formed to include the city staff
who may be assigned to accomplish the designated tasks , a staff
member of Metroplan assigned by the Study Director, a staff repre-
sentative of the AHTD and a staff representative of Central Arkansas
Transit. This group will represent transportation operating
agencies, providing overall technical and coordinative support,
advise on project selection, and ultimately, assist with project
implementation.
Organization Chart
------------- 1
PATS I
1 Study
Director 0
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F+ City of L. R. F+
›, Staff Services ›.,
Transportation 4.3
Technical 1
1 Advisory
Committee
1 1 '
I 1
Project Decision PATS Policy
Making ----- Committee
L.R. Board of Directors TIP Funding Approval
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As indicated by the chart , the study team is responsible
to the PATS Study Director . The Transportation Technical Advisory
Committee will provide technical review and advise on project
selection. The City of Little Rock is ultimately responsible for
initiating the TSM projects as approved by the City Board of
Directors in the City and the PATS Policy Committee for providing
programming of TSM projects in the TIP .
Scope of Work
TASK 1. STUDY OVERVIEW
Purpose :
To set the stage for the study by establishing a common frame-
work of issues , objectives and procedures for use by technicians
and decision makers .
Activities :
1. Metroplan will furnish to the city, based on the PATS
plan, transportation issues in terms of population
growth, land use growth and change , inteLmodal trans-
portation deficiencies , environmental quality attainment
guidelines , energy constraints , and areawide roadway
system plan. These are factors that necessitate a
TSM response.
2. Metroplan will furnish a map which identifies candidate
projects for TSM study by the city.
3 . Metroplan will establish a study team consisting of the
city' s designated staff for the study, a Metroplan
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transportation planner, a representative of the
Arkansas Highway and Transportation Department , and
a representative of transit agencies in the area, to
identify potential TSM projects and provide technical
support to the city' s designated staff.
4. Metroplan will provide incentives for TSM project
development by establishing procedures to assure timely
project programming in the TIP.
5 . The Transportation Improvement Program (TIP) shall con-
sist of improvements recommended from the TSM and long-
range elements of the approved PATS plan.
TASK 2. PERFORMANCE AND PROBLEM MEASUREMENT
Purpose:
To establish quantitative and qualitative measures of system
performance to use in dimensioning candidate problems and
evaluating alternative TSM solutions .
To establish analytical and graphic procedures for determining
effectiveness .
To identify data requirements and collection procedures .
To define the extent of existing problems and of existing
project effectiveness through data collection and analysis .
Activities :
1. Establish criteria relative to transportation objectives
that will measure system performance in the Little Rock
portion of the PATS area. Potential criteria and
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measures for consideration based on the objectives ,
the nature of the particular problem, and the available
data include the following:
a . System performance criteria encompass efficiency
of person movement and travel time . Potential
performance measures include peak hour person trips ,
daily person trips , vehicle hours traveled, trip
length, person hours traveled, and modal level of
service .
b . Social criteria include safety, measured in terms
of accident cost and number, and dislocation measured
in terms of persons and business relocated.
c . Economic criteria cover direct , indirect , and user
costs . Direct costs include right of way, construction,
maintenance , and operations subsidy. Potential
measures include total cost, annualized cost, and
cost per trip . Measures of indirect costs relate to
changes in property values . User costs including
travel time, vehicle operations , and user charges
with potential measures covering cost per vehicle
hour or mile traveled and in user cost per trip .
d. Environmental criteria encompass air quality measured
by vehicle miles traveled per mode, energy conser-
vation measured by BTU' s per person mile traveled,
and the measurement of noise necessary to support
TSM project selection.
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2 . Determine analytical techniques and data requirements
and sources applicable to the different types of
candidate problems .
3 . Dimension baseline problem and project conditions .
a . Collect and analyze data for each candidate problem
to dimension the extent of deficiencies .
b . Collect both pre-project and existing data on existing
TSM projects and determine changes in relevant
performance measures .
5 . Prepare Task 2 Report .
TASK 3 . EVALUATION PROCEDURES
Purpose :
To establish and test procedures for evaluating alternative
TSM project solutions as an aid to decision making.
1. Establish a two level approach for evaluating alternatives
that enables a reconnaisance level evaluation to narrow
the range of potential actions prior to detailed
evaluation.
2. Establish minimum thresholds of performance, where
determined practical , as a means of assisting decision
making.
3. Test the evaluation procedures by applying them to
existing TSM projects .
4. Adjust the evaluation procedures as needed after re-
viewing the test run results . Adjustments will include
consideration of accuracy, acceptability to decision-
makers , sensitivity, and practicality in terms of study
resources .
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5 . Prepare Task 3 Report .
TASK 4. TSM PROJECT ALTERNATIVES
Purpose :
To formulate alternative TSM solutions for candidate problems .
Activities :
1 . Establish limits on the alternatives considered for
each problem to assure a practical balance with available
study resources .
2 . Work with the PATS study team as a whole in foLmulating
TSM alternatives for each candidate problem. Use as
comparisons in each case the following range of
alternatives .
a. Null
b . Long-range , high-capital (where previously available )
c. Low-capital facilities
d. Operational and institutional improvements
e . Combination of C and D (immediately above)
3 . Describe the advantages and disadvantages of the alterna-
tives of each problem. Apply the two level evaluation
procedure developed in Task 3 to the alternatives for
each candidate problem.
4. Prepare Task 4 Report .
TASK 5 . IMPLEMENTATION PROCESS
Purpose :
To provide agencies involved in project implementation an
opportunity to select alternatives for implementation.
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To prepare an implementation strategy for implementing the
alternatives selected.
To devise procedures to monitor the implementation and operation.
Activities :
1. Present the project alternatives and evaluations to the
city for project selection and endorsement .
2. To the extent possible , resolve any differences in
project selection among jurisdictions through consultation.
3 . Outline an implementation strategy in terms of activities ,
timing, sources and magnitude of funds and responsible
agencies for agreed upon projects .
4. Outline a program for monitoring project implementation
and operation.
5 . Prepare final technical report.
TASK 6. STUDY EVALUATION
Purpose :
To determine the effectiveness of the TSM study in fulfilling
objectives .
To recommend organizational and operational changes that will
improve effectiveness .
Activities :
1. Conduct an evaluation of the study by the study team that
addresses the practicality of the study and recommends
improvements with respect to:
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a. Form and extent of agency participation
b . Scope of problems considered
c. Method of problem selection
d. Data collection and analytical techniques
e . Formulation of alternatives
f. Evaluation techniques
g. Implementation procedures
h. Continuation of the process
2. Prepare evaluation report.
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Attachment 2
NOTICE TO CONTRACTORS -
COMPLIANCE WITH TITLE VI OF THE CIVIL RIGHTS ACT OF 1964
FOR
FEDERAL-AID CONTRACTS
During the perfonnance •of this contract, .the contractor, for itself, its
assignees and successors in interest (hereinafter referred to as the
"contractor") agrees as follows:
(1 ) Compliance w•with Regulations: The contractor will comply with
• the Regulations of the Department of Transportation relative
to nondiscrimination in Federally-assisted programs of the
Department of Transportation (Title 49, Code of Federal
Regulations , Part 21 , hereinafter referred to as the Regulations) ,
which are herein incorporated by reference and made a part of
this contract.
(2) Nondiscrimination: The contractor with regard to the work
performed by it after award and prior to completion of the
contract i•;ork , will not discriminate on the ground of race,
color, or national origin in the selction and retention of
subcontractors , including procurements of materials and leases
of equipment. The contractor will not participate either
directly or indirectly in the discrimination prohibited by
Section 21 . 5 of the Regulations , including employment practices
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when the contract covers a program set forth in Appendix B of
the Regulations.
(3) Solicitations for Subcontracts , Including Procurements of
Materials and Equipment: In all soliciations , either by
competitive bidding or negotiation made by the contractor for
work to he performed under a subcontract, including procurements
of materials or equipment, each potential subcontractor or
supplier shall be notified by the contractor of contractor's
obligations under this contract and the Regulations relative
to nondiscrimination on the ground of race, color or national
• origin.
.(4) Information and_ Reports: The contractor will provide all
information and reports required by the Regulations , or orders
• • and instructions issued pursuant thereto, and will permit access
to its books , records , accounts , other sources of information,
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and its facilities as may be determined by the State Highway
Department or the Federal Highway Administration to be pertinent
to ascertain compliance with such Regulations , orders and
instructions. Where any information required of a contractor is
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in the exclusive possession of another who fails or refuses to
furnish this information, the contractor shall so certify to the
State Highway Department, or the Federal Highway Administration
as appropriate, and shall set forth what efforts it has made to
obtain the information.
(5) Sanctions for Noncompliance: In the event of the contractor's
noTicanpliancc with the nondiscrimination provisions of this
contract, the State Highway Department shall impose such contract
sanctions as it or the Federal Highway Administration may determine
to be appropriate, including, hut not limited to ,
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(a) withholding of payments to the contractor under the -
contract until the contractor complies, and/or
(b) cancellation , termination or suspension of the contract,
in whole or in part. -
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(6) Incorpo`ation of Provisions: The contractor will include the
provisions of paragraph (ii through (6) in every subcontract,
including procurements of materials and leases of equipment,
unless exempt by the Regulations , order, or instructions
issued pursuant thereto. The contractor will take such action
with respect to any subcontract or procurement as the State
Highway De 3rtment or the Federal Highway Administration may
direct as a means of enforcing such provisions including
sanctions for noncompliance: Provided , however, that , in the
event a contractor becomes involved in , or is threatened with,
litigation with a subcontractor or supplier as a result of
such direction, the contractor may request the State to enter
into such litigation to protect the interests of the State , and,
in addition , the contractor may request the United States to
enter into such litigation to protect the interests of the
United States.
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