November 10, 2017

Jobs to Move America (JMA) respectfully submits the following comments to the US Department of Transportation (DOT) regarding the DOT’s strategic plan for FY 2018-2022 and Request for Public Comment, Docket Number DOT-OST-2009-0092. Jobs to Move America is a non-profit committed to harnessing government procurement to realize equity; to promote environmental sustainability; to further open, democratic government; and to achieve an inclusive, diverse workforce that lifts people into middle-class jobs.

JMA applauds the DOT’s recognition of the importance of infrastructure investment and repair as part of its FY 2018-2022 Strategic Plan. In working to meet its strategic plan goals, JMA urges the DOT to ensure that local transportation agencies have maximum flexibility in using procurement as a strategic policy tool in local communities. The principle of federalism was a motivating factor in the creation and formulation of the Common Grant Rule (53 FR 8034-01), which is incorporated into the DOT’s own regulations, and promotes good policy through local experimentation and innovation. The DOT should promote innovative tools that help local transportation agencies fulfill their missions.

Click here to read JMA’s full comment.


















[1] US Department of Justice Memorandum Opinion for the acting General Counsel, Department of Transportation, “Competitive Bidding Requirements Under the Federal–Aid Highway Program” (Aug 23, 2013) [hereinafter 2013 OLC Memo], available at

[2] For data and study, see Appendix Item 2: December 7, 2016 Letter from Professor Scott Cummings to the DOT Acting General Counsel.

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