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These plans (38 remain operational) currently cover
geographical areas ranging from one county to entire
They have goals for participating crafts which
are as much as 800 percent of the local minority work
in existence for many years, OFCCP regions vary widely
in the severity with which "good faith effort" by par
ticipants is evaluated in the event that goals are not
Because of the widely disparate goals and compli
ance standards applied, no real measurement of the num
bers of minorities permanently placed in the industry is
OFCCP does know, however, that few, if any,
of the voluntary plans approved have ever met their
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 partici
pating 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
As with Hometown Plans, there
has been little measurable progress and standards of
evaluation have been even less well defined than for the
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withdrawn from a plan all contractors are subject to the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 requirements is the responsibility of the designated compliance
agency, usually the contracting agency.
tion Compliance Manual provides the first formal system
for OFCCP to resolve cases where more than one agency
them, at least quarterly, of serious deficiencies.
In a few of the 115 urban areas targeted for Home
town Plan development, standards have been imposed when
no plan was developed or an existing plan failed.
general language of these requirements is almost identi
cal to that of Part II in Hometown Plan areas.
bid conditions were published in the Federal Register
and still contain a certification requirement for bid
Goal computations for the imposed standards were
complicated, involving estimates of current union mem
bership and future vacancies.
Monitoring and enforcement of the imposed standards
In mid-1976, Special Bid Conditions were first
issued for use in areas not covered by hometown or
using 1970 census data and apply only to the aggregate
work force of contractors working on the specific
Monitoring and enforcement of these standards is
the responsibility of the compliance agency and is simi
lar to that for part II and imposed standards.
Exemptions--hometown or imposed standards
have been exempted for union locals whose
ance 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 fash
No substantive revisions in the basic 1971 documents
were made during those years.
In August 1976, the Op
erations Manual for the Construction Compliance Program
This Manual, issued with a revised reporting
format, standard form 257, standardized required proce
dures, systems, and reporting. Although implementation of the Manual by all OFCCP regions and compliance agen
cies was ordered on October 1, 1976, implementation has
been slow and varies widely within the program.
As described earlier, inconsistencies in the stand
ards used to measure compliance with the order exist.
Because of the emphasis on numerical standards rather