Comments Submitted by NUL to U.S. Department of Transportation

Marc H. Morial
President and CEO
120 Wall Street, 8th Floor
New York, NY 10005
212 558 5300
646 568 2185
[email protected]
April 6, 2015
U.S. Department of Transportation
Docket Operations
1200 New Jersey Avenue SE
Washington, DC 20590
Docket DOT-OST-2015-0013
RIN 2105-AE38
Comments Submitted by the National Urban League concerning the U.S Department of
Transportation’s Proposed Rulemaking on Geographic-Based Hiring Preferences in
Administering Federal Awards
The National Urban League is pleased to offer the following comments in strong
support of local hire on federally-funded transportation projects in the U.S Department of
Transportation’s (U.S. DOT) proposed rulemaking on Geographic-Based Hiring
Preferences in Administering Federal Awards.
The National Urban League is a historic civil rights and urban advocacy
organization dedicated to economic empowerment in historically underserved urban
communities. Through direct service programs that are implemented locally by more
than 90 Urban League affiliates in 36 states and the District of Columbia, we have
improved the lives of tens of millions of people nationwide. However, research shows that
we have a long way to go in order to secure economic equality in this country.
According to our just-released 2015 State of Black America report, the National Urban
League 2015 Equality IndexTM i of Black America stands at 72.2 percent, meaning that
Blacks experience less than three-fourths the quality of life experienced by white
Americans. Additional key findings from our report dramatize the need, among other
policies, to create well-paying jobs that can be accessed in African American
Black median household income is about 60% of that of whites - $34,815 vs.
$57,684 respectively.
African Americans are more than twice as likely as whites to be living in poverty.
The poverty level Equality IndexTM for Black-White is 40%, with 27.6% of Blacks living
in poverty vs. 11.1% of whites.
With the Black-White Unemployment Equality IndexTM at 47%, the Black
unemployment rate is more than double the white unemployment rate – with
Blacks at 11.3% and whites at 5.3%.
With an Equality IndexTM of 6%, Blacks have a median wealth of $6,314 vs. whites
who have $110,500 – meaning the median African-American household has just 6
cents in wealth for every dollar of white household wealth.
Docket DOT-OST-2015-0013
RIN 2105-AE38
Transportation construction projects provide access to well-paying jobs and, if
accessed, can bring economic relief to the unemployed and under-employed. Yet,
researchiii has shown that low-income workers, women, people with disabilities and
communities of color are vastly underrepresented in transportation sector jobs when
compared with their overall participation in the workforce. This represents a missed
opportunity for connecting these communities to quality jobs, especially given the good
wages and benefits that often accompany transportation work.
For far too long, the U.S. Department of Transportation has held on to a
prohibition on local hire for federally-funded projects. The Proposed Rulemaking on
Geographic-Based Hiring Preferences in Administering Federal Awards would finally
loosen this prohibition and make it clear that geographic hiring preferences may be used
in Department of Transportation grant programs. Many communities have employed
local and targeted hire provisions on projects large and small with positive results for local
residents and the local economy. For example, Gary, IN Mayor Karen Freeman-Wilson
cites the positive impact that local hire provisions have had in her city in her article, “A
New Day, New Legacy For Gary, Indiana,” in the National Urban League’s State of Black
America report,iv:
“During the past three years, contractors entrusted with public projects have
been pressed to meet local hiring ordinances. Additionally, businesses that move into
Gary or expand their business have worked with the city to hire local residents. These
efforts are reflective of the reality that new businesses in Gary have the greatest longterm impact when they create employment opportunities for Gary residents. During the
course of the past three years, more than 1000 new jobs have been added to the city. At
least 65 percent of these jobs have employed city residents.”
As cited by PolicyLink, Los Angeles, CA represents another example of the
benefits of local hire where the LAX/Crenshaw Light Rail project will create 7,500 jobs.
According to PolicyLink, equity advocates worked to embed a targeted hire provision for
the nearly $2 billion project that will ensure that low-income and underemployed
residents will benefit from this investment, because 40 percent of the project's work will
be reserved for these workers. More recently, upon announcement of the Department of
Transportation’s proposed rulemaking on local hire, Los Angeles Mayor Eric Garcetti
noted that the City has $36 billion committed to public transportation projects in the L.A.
region (including the Crenshaw-to-LAX rail line), and said that “locals” will be defined as
construction workers living in L.A. County.v In addition to Mayor Garcetti, other major city
mayors outlined what this rule change on local hire would mean for low-income residents
in their respective
The National Urban League fully supports the U.S. Department of Transportation’s
(DOT) efforts to allow city and state departments of transportation to set economic and
geographic preferences, as an initial step toward workforce inclusion for all Americans. It
would bring greater benefits to communities where transportation projects are either
planned or underway. The National Urban League also strongly recommends that the
DOT’s proposed local and targeted hire program be made permanent if we are to solidify
future gains in workforce inclusion.
Docket DOT-OST-2015-0013
RIN 2105-AE38
In addition, we would urge the U.S. DOT to extend this allowance for targeted
hiring provisions to apply to women and people with disabilities, who also stand to
benefit significantly from such policies.
Thank you for consideration of our comments on this most important rule change.
Marc H. Morial
President and CEO
2015 State of Black America Save Our Cities Education, Jobs +Justice, National Urban League, 2015. Accessed
ii“National Urban League and President & CEO Marc H. Morial Launch 39th Edition of the State of Black America
– “Save Our Cities: Education, Jobs +Justice.” Accessed at:
iii “All Aboard! Making Equity and Inclusion Central to Federal Transportation Policy,” by PolicyLink, 2009.
Accessed at:
iv 2015 State of Black America Save Our Cities Education, Jobs +Justice, National Urban League, 2015, p.124.
Accessed at:
article by John Guenther, March 3, 2015. Accessed at:
To read what Mayor William Bell of Birmingham, AL, and Atlanta Mayor Kasim Reed said, go to: