Jobs to Move America
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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.

Associated Resources

Fact Sheet: Empowering Cities and States: Making Federal Funds Work for Our Communities

Currently, a set of decades-old federal rules (known as the Uniform Guidance) impede cities and states from using innovative programs in the procurement process that can amplify the benefit of federal funds for communities. The procurement process can be a powerful tool to address historic inequities and uplift millions of struggling people—particularly people of color—but …