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DBE/ACDBE Participation in Joint Ventures - Metropolitan ...

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Example 1 - cont<strong>in</strong>ued<br />

• Now, let us assume that the AC<strong>DBE</strong> partner is also assigned<br />

the role of f<strong>in</strong>d<strong>in</strong>g <strong>DBE</strong> vendors to be utilized by the bus<strong>in</strong>ess<br />

and recruit<strong>in</strong>g m<strong>in</strong>ority employees.<br />

• These roles are activities <strong>in</strong>cluded under broader categories -<br />

Human Resources (HR) and Purchas<strong>in</strong>g. HR is only one task<br />

with<strong>in</strong> the “Operations” category and purchas<strong>in</strong>g is only one<br />

task with<strong>in</strong> the “Product” category. In addition, it is difficult,<br />

if not impossible, to quantify the value of these tasks <strong>in</strong> terms<br />

of their impact on gross receipts.<br />

• An airport would not have sufficient data to approve the JV<br />

for count<strong>in</strong>g because the portion of the work to be performed<br />

by the AC<strong>DBE</strong> is very difficult to quantify. The airport should,<br />

<strong>in</strong> this case, request that the JV participants clarify the role of<br />

the AC<strong>DBE</strong>.<br />

91

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