These plans (38 remain operational) currently cover geographical areas ranging from one county to entire states. They have goals for participating crafts which are as much as 800 percent of the local minority work force. In addition, they have no consistent administrative structure or requirements for participating contractors. Review of Hometown Plans is the responsibility of the OFCCP regions. Although procedures and minimal standards for evaluating participants in plans have been in existence for many years, OFCCP regions vary widely in the severity with which "good faith effort" by participants is evaluated in the event that goals are not met. Because of the widely disparate goals and compliance standards applied, no real measurement of the numbers of minorities permanently placed in the industry is possible. OFCCP does know, however, that few, if any, of the voluntary plans approved have ever met their goals. Nationwide Heavy Highway Plan National and Heavy Highway Plans are variations of the Hometown Plan concept, involving usually one or a limited number of craft unions either nationally or state establish goals on a large geographic basis for participating crafts and relieve contractors using these crafts of responsibility for any compliance standards established under other bid conditions in the area for nonparticipants. Evaluation of the larger plans is also an OFCCP regional responsibility. As with Hometown Plans, there has been little measurable progress and standards of evaluation have been even less well defined than for the hometown versions. Part II Standards Bid conditions setting forth goals and timetables and a minimum affirmative action plan for all nonparticipating (Part II) contractors were issued for most areas covered by hometown agreements. Hometown area bid conditions required bidders to complete a complicated set of certifications as to their status under (Revised model bid conditions issued in 1976 the plan. eliminated these certifications.) The Part II provisions apply to all nonparticipating contractors and to participating contractors for craft unions which are not participating. When approval is withdrawn from a plan all contractors are subject to the Part II provisions. The Part II goals were generally based on the goals for craft unions signing the voluntary Monitoring and enforcement of the Part II require ments is the responsibility of the designated compliance agency, usually the contracting agency. The Construction Compliance Manual provides the first formal system for OFCCP to resolve cases where more than one agency can claim jurisdiction. Agencies are required to submit monthly summaries of contracting, monitoring, and enforcement activities to the appropriate OFCCP region. The OFCCP regional office evaluates the agencies' activities and notifies them, at least quarterly, of serious deficiencies. Imposed Standards In a few of the 115 urban areas targeted for Hometown Plan development, standards have been imposed when no plan was developed or an existing plan failed. The general language of these requirements is almost identical to that of Part II in Hometown Plan areas. These bid conditions were published in the Federal Register and still contain a certification requirement for bidders. Goal computations for the imposed standards were complicated, involving estimates of current union membership and future vacancies. Monitoring and enforcement of the imposed standards Nonplan Standards In mid-1976, Special Bid Conditions were first issued for use in areas not covered by hometown or imposed standards. Prior to that time there were no standards for these areas. at the agency's discretion. with high-impact projects. Use of these standards is They are designed for use Specific guidance is pro vided for developing these standards and their use must be approved by OFCCP. Goals currently are developed using 1970 census data and apply only to the aggregate work force of contractors working on the specific project. Monitoring and enforcement of these standards is the responsibility of the compliance agency and is similar to that for part II and imposed standards. In addition to the specific major program systems detailed above, the construction program also includes less important but noteworthy aspects. 3. Craft Unions--not covered by the Executive 4. complain that most hometown/imposed standards have been placed in highly unionized areas. Contracting Agencies--acting also as compliance agencies, historically have felt that the agency's project, rather than the contractors' work force should be their primary focus. From 1971 until mid-1976, the program was continually expanded, redirected, and redefined in a piecemeal fashion. No substantive revisions in the basic 1971 documents were made during those years. In August 1976, the Operations Manual for the Construction Compliance Program was issued. This Manual, issued with a revised reporting format, standard form 257, standardized required procedures, systems, and reporting. Although implementation of the Manual by all OFCCP regions and compliance agencies was ordered on October 1, 1976, implementation has been slow and varies widely within the program. As described earlier, inconsistencies in the standards used to measure compliance with the order exist. Because of the emphasis on numerical standards rather |