COUNCIL OF THE CITY OF PHILADELPHIA COMMITTEE ON COMMERCE AND ECONOMIC DEVELOPMENT - - - Room 400, City Hall Philadelphia, Pennsylvania Wednesday, January 20, 2010 10:30 a.m. - - - PRESENT: COUNCILMAN W. WILSON GOODE, JR., CHAIR COUNCILMAN BILL GREEN COUNCILMAN CURTIS JONES, JR. COUNCILWOMAN MARIA QUINONES-SANCHEZ COUNCILWOMAN BLONDELL REYNOLDS BROWN RESOLUTION 090860 - Resolution authorizing the Committee on Commerce and Economic Development to hold hearings to review the strategic plan of the Office of Economic Opportunity. - - - 2
Good morning. This hearing is called to order. This is a public hearing of the Commerce and Economic Development Committee on Resolution 090860. My name is W. Wilson Goode, Jr., Chair of this Committee. A quorum is not necessary. I note for the record the Vice-Chair of the Committee, Councilwoman Blondell Reynolds Brown, is present, as well as Councilman Bill Green. Other members may join us as we go along. The title of the Resolution No. 16 090860, resolution authorizing the Committee on Commerce and Economic Development to hold hearings to review the strategic plan of the Office of Economic Opportunity. Our first witness is Kevin Dow. (Witnesses approached witness table.)
Good morning. Good morning, Chairman Goode and members of 3 1/20/10 - COMMERCE - RESOLUTION 090860 the Committee on Commerce and Economic Development. I am Kevin Dow, Deputy Commerce Director and Acting Chief Operating Officer of the Commerce Department. Joining me today is Curtis Gregory, who is the interim Director of the Office of Economic Opportunity, otherwise known as OEO. We are here today to provide testimony regarding Resolution No. 12 090860, which calls for Council hearings to review the strategic plan of the OEO, Office of Economic Opportunity, which will be released shortly. However, it is my understanding that a focus of today's hearing will be the review of the Annual Disparity Study and those completed over the last few years. Pursuant to Section 6-109 of the Home Rule Charter and Chapter 17-1500 of The Philadelphia Code, the Annual Disparity Study is designed to analyze the City of Philadelphia's utilization of minority, women and disabled-owned 4 1/20/10 - COMMERCE - RESOLUTION 090860 businesses, collectively known as disadvantaged business enterprises, relative to the availability of such firms to compete for City business, for Public Works, Personal and Professional Services, and Supplies, Services and Equipment contracts. Per the Home Rule Charter, the Annual Disparity Study is due 30 days before the start of the new fiscal year to the Mayor and the President and Chief Clerk of City Council, and as such, the Fiscal Year 2008 study has been delivered to City Council. The Fiscal Year 2009 report is in process and will be delivered to Council by June 1st, 2010. The goal is to identify areas in which disparity exists between availability and utilization of minority, women and disabled firms and compare the results to those of the Fiscal Year 1998-2003 Disparity Study conducted by DJ Miller and Associates and provide recommendations and goals for future 5 1/20/10 - COMMERCE - RESOLUTION 090860 M/W/DSBE participation based on these results. We have gained invaluable information from the Disparity Studies conducted by Econsult since Fiscal Year 2006. The data demonstrates that the City of Philadelphia has indeed made tremendous gains in MBE, minority business, and WBE, women business, utilization between the 1998-2003 time period and 2008. In the years between 1998-2003, participation for MBEs, minority businesses, was 2.3 percent and 2.2 percent for WBEs, or women businesses. This participation has increased to 12.7 percent for minority businesses and 5.1 percent for women businesses in 2008, representing approximately a 280 percent overall increase as measured on a percentage basis. Although these numbers are not quite where we would like to be or where we strive to be, we have come a long, long way, and we will continue to work 6 1/20/10 - COMMERCE - RESOLUTION 090860 with Councilman Goode and this committee so that this trend continues. The Commerce Department has already begun to implement changes at OEO, incorporating many of Econsult's recommendations. This is clearly reflected in the Economic Opportunity Strategic Plan. These changes include reforming the certification process to streamline it, taking a more proactive approach in enforcement, promoting capacity, establishing a process for reporting DBE participation on non-profit contracts, and verifying actual payments to DBE subcontractors. Thank you for the opportunity to testify today. This concludes my written remarks. I will be happy to answer any further questions. In addition, representatives from Econsult are also present today to assist in responding to any questions you may have regarding the Annual Disparity Study. Thank you. 7 1/20/10 - COMMERCE - RESOLUTION 090860
Thank you for your testimony, Mr. Dow. I have a series of questions. I've already informed the Committee that I'm going to go through my line of questioning, then I will open it up to other members of the Committee. Please feel free to take your time in answering them. Don't feel free to rush and answer. The first question is, should the Office of Economic Opportunity be an independent agency, a Charter-mandated authority like the Board of Ethics, with the power to institute penalties and fines?
Should we have an independent Charter agency, we be an independent Charter agency?
Like the Board of Ethics, like has been recommended for the Office of Inspector General. Should the Office of Economic Opportunity be a Charter-mandated agency with its own authority and 8 1/20/10 - COMMERCE - RESOLUTION 090860 responsibilities separate from any administration, any branch of government?
I think the answer to that question depends on what you would have the mission of the Office of Economic Opportunity to be. If it's solely an enforcement and monitoring, that could possibly be a case where it might be a separate Charter agency, but I would also argue that that could also be considered part of the IG's office or the Board of Ethics' office as separate -- as a function of that, so not a separate function. If the current charter or mission of the Office of Economic Opportunity, which is to help engage departments achieve participation ranges and goals around minority participation, remains the same, I think it remains a part of the Administration, so that we can have the influence we need to drive the outcomes.
The Board of 9 1/20/10 - COMMERCE - RESOLUTION 090860 Ethics was originally done by Executive Order. The Inspector General's Office is still done by Executive Order. OEO is under Executive Order. Should it be an independent agency like the other two? I mean, essentially the Mayor, when he was a Councilperson, drafted legislation that made the Board of Ethics independent. The Mayor has submitted legislation to Council to make the Inspector General's Office independent. Should the Office of Economic Opportunity be independent or do you have sufficient authority to reach your goals?
Well, I don't know if I have authority to say whether or not this should be independent or not, to be quite candid with you. Do we have the authority to reach our goals? I think what we have to do is to have -- we have the authority to influence departments in reaching their goals. The overall responsibility of the Office of Economic Opportunity is to help guide departments 10 1/20/10 - COMMERCE - RESOLUTION 090860 in achieving participation goals.
Specifically, does OEO have sufficient authority to reach its FY11 goals?
According to the strategic plan, the total DBE goal for FY11 is percent; is that correct? 10
According to 12 the strategic plan, the total DBE goal 13 for Fiscal Year '11 is 25 percent; is 14 that correct? 15
That's in a draft 16 document that we've provided, yes. That 17 is stated there. Until that document is 18 finalized and executed and delivered by 19 the Mayor, I can't commit solely to that 20 goal right now. But that is what's 21 stated in the goal plan right now. 22
I don't have that 25 information -- hold on. Let me see. Do 11 1/20/10 - COMMERCE - RESOLUTION 090860 we break it out? Okay. What we have is minority and women. It would be -- again, this is not defined, set in stone. This is something that's still being debated, and once we have finalized the document, we will --
Mr. Dow, I understand that the strategic plan is still in draft form, and the purpose of the hearing is to allow the Committee some input before it's in its final draft, but I don't think there should be any problem referring to what's already in draft form.
Sure. Thank you very much. We would put it at a range of anywhere between -- it would be anywhere between 12 and 20 percent. And then the women would be anywhere between a range of 7 and 12 percent. The total goal is around the range of between 20 and 30 percent, is really what's stated. In the 12 1/20/10 - COMMERCE - RESOLUTION 090860 plan that you have as a draft, it's stated as a specific goal of percent. 4
We have not broken 7 out the African American segment. To 8 break out an individual segment of the 9 goal would be, in our estimate, improper 10 and that we should not set specific goals 11 to an African American segment or 12 Hispanic segment or -- 13
No. The 13 1/20/10 - COMMERCE - RESOLUTION 090860 Home Rule Charter gave Council the power to define what goes in the Disparity Study and in participation goals, and the law -- in fact, I have the bill here. It's Bill 060855-A, and the law specifically says that it should be broken down by African Americans, by Hispanic Americans, by Asian Americans, by Native Americans, by women, by disabled persons and by DBEs operating within the City of Philadelphia. So what is the African American goal?
Well, right now the process that we just embarked on was to meet with individual departments to find out what their specific commitment was going to be from a participation --
If you don't have it, you don't have it. It's a 14 1/20/10 - COMMERCE - RESOLUTION 090860 number. It's a range.
We don't have it right now. We don't have that level of detail.
Is that the local versus the MSA in terms of Philadelphia specific, Philadelphia County?
-- sets a goal for these areas. The last one is DBEs operating within the City of Philadelphia.
Will the departmental goals be submitted to City Council in June?
You do 15 1/20/10 - COMMERCE - RESOLUTION 090860 realize that usually when a Disparity Study and participation goals are done, participation goals are generally broader goals and we do not give them by department in June. My question is more specifically, will we get the goals by department in June?
Can you please describe the new goal achievement process outlined in the strategic plan and the assignment of OEO staff to project managers and procurement officials?
We've commenced -- as we've being putting together the strategic plan, we figured that we would begin to implement the structural changes that we are anticipating moving forward and announced in the strategic plan. That includes a goal achievement process or a goal process whereby which we engage individual departments by department as individuals to determine what their 16 1/20/10 - COMMERCE - RESOLUTION 090860 contracting opportunities are, what opportunities are available for minority firms, and we do analysis of what availability we have in our participation -- our certified database rather, and we do a match, working hand in hand with the individual departments to get the individual goal and objective for that department. The idea is that we build accountability at the department level so that we can achieve and hold them accountable to achieving their success at the individual goal. So this is a process that will take place -- has already begun to take place. That's how we're getting the individual department goals that we will report to you. It will be an ongoing process by which we will begin to look at monitoring and compliance around those individual departmental goals. We'll look at each individual department individually. We've had additional staff -- 17 1/20/10 - COMMERCE - RESOLUTION 090860 or staff rather, excuse me, assigned. So the OEO staff has been assigned and will continue to be assigned to individual departments so that there will be an ongoing relationship with those individual departments. So it's not changing characters on the OEO side. Again, we believe that allows that relationship to be built, allows us to be viewed as a partner, as a contributing and valued partner into their contracting process where we can add information, value to the minority participation aspects of that, which over time there will be some success in achieving goals and objectives. So that's it in a nutshell.
It began back in earnest in August, September timeframe of 2009.
And what happened prior to that? 18 1/20/10 - COMMERCE - RESOLUTION 090860
My understanding is that it was not -- it was a process that did not occur consistently over the years prior to our involvement. It was one in which -- as an example, when we came in front of you guys, in front of the Council last budget season, it was a process by which the departments didn't feel as though that there was a working relationship with the Office of Economic Opportunity, that we just gave them their goals and really didn't have the dialogue about how to achieve them. And so that dialogue, while it may have taken place in some areas, it was not across the board and consistent, and our internal departments didn't feel that we provided value there.
How many staff were assigned to that responsibility before and how many are assigned to that now?
I don't know how many were assigned to it before. I know 19 1/20/10 - COMMERCE - RESOLUTION 090860 in terms of the goal-setting process, that was led by myself, Candace Hitchcock and Alice Dungee-James.
So they 20 1/20/10 - COMMERCE - RESOLUTION 090860 weren't doing their job before? I don't understand. If it's a new process, it's in your strategic plan as a new process, goal achievement process, the acronym is GAP --
-- you said the new process began in August, September of 2009?
I asked how many people were assigned to it, this new process, and how many people were assigned to those responsibilities before. So there were seven people assigned to it before?
Yeah. I just think that what we did was that it was configured in a way in which -- well, let me stop. Let me retract that. It was -- the results of a process that existed before did not achieve what we would like to achieve in terms of outcomes. So what we've done is 21 1/20/10 - COMMERCE - RESOLUTION 090860 that we've refined the process --
Let me try to simplify it more. The goals have not been achieved in the past.
No. We've reallocated the current staff that was already in the Office of Economic Opportunity to this particular staff.
So if they didn't achieve the goals before, what's going to make them achieve the goals now?
I think what you might be referring to is, there is a shift of resources. There's no addition to staff, there's no reduction to staff, but what has taken place is, in the past 22 1/20/10 - COMMERCE - RESOLUTION 090860 a significant amount of time and energy and resources was spent on the actual certification process as it's designed. Going forward, we are going to shift those resources away from the certification aspect of what we do and more towards the reporting and monitoring aspect of what OEO is responsible for.
That's the answer I was looking for. In terms of DBE availability, what are your certification goals over the next six months into Fiscal Year '11?
We'd like to see a 16 percent increase in the number of 17 certified firms in our database within 18 the first year. So if we are at 19 approximately 1,200 firms right now, 25 20 percent increase in that, and then 21 increasing it all the way through in each 22 year. 23
I'm asking 24 actually before Fiscal Year '11, through 25 January 2010 to July 1st, 2010 as Fiscal 23 1/20/10 - COMMERCE - RESOLUTION 090860 Year '11 starts, how many certified firms will we have based upon your new certification process?
I can't tell you how many we will have. Our goal is to increase it by percent. So that 8 would be -- 9
Next year. So 12 between this calendar year, essentially 13 we would have it increased by 25 percent. 14
So roughly 17 150 over six months perhaps. 18 Does the Fiscal Year '11 goal 19 take that into account? 20
So as you 22 stated, the plan is to shift human 23 resources from local certification into 24 the goal achievement process. Is that 25 how you reach 25 percent? 24 1/20/10 - COMMERCE - RESOLUTION 090860
That's part of it. The other part of it is, when you're reaching out to other partners that do certification, to add them to our list of organizations that do certifications. So we're hoping to get immediate lift.
But you're only going to have 150 to 300 more firms over the next year. So there's a new certification process that will bring some new firms up to percent, is your 13 goal. So you're not going to get it 14 necessarily by increasing availability 15 dramatically, because that's not within 16 the strategic plan per se. The Disparity 17 Studies already show based upon 18 availability that you can achieve a 25 to 19 28 percent goal, although you have not 20 achieved a 25 to 28 percent goal. My 21 question is, is it the goal achievement 22 process and the shifting of human 23 resources from certification to the goal 24 achievement process that you've outlined 25 that's going to make you reach 25 25 1/20/10 - COMMERCE - RESOLUTION 090860 percent?
I think it's a combination. I think, like I said, it's not just the availability side, it's the utilization side. And so the shifting of the resources or shifting of staff focus from the certification process to the compliance and monitoring side, consulting with internal departments, will allow us to engage them in a way where we will see an increase in the utilization of firms.
I think the availability -- it depends on how you define "availability." I think that there's a greater need for availability to capture more firms within the database outside of what we have right now.
You actually can bring your consultant to the table now. 1/20/10 - COMMERCE - RESOLUTION 090860 (Witness approached witness table.)
Lee Huang. I'm a Director at Econsult Corporation. Last name is H-U-A-N-G.
According to your last Disparity Study, is it fair to say that availability exists to effect utilization of to 28 percent? 14
Broadly speaking, 15 yes. Obviously every department, every 16 procurement varies, but broadly speaking, 17 I think that answer is yes. 18
Thank you. 19 Mr. Dow, from 1998 to 2003, 20 only a single percentage of City contract 21 dollars were committed to all 22 minority-owned businesses, black, Latino 23 and Asian combined. How and why has it 24 risen to a double-digit percentage? 25
I think if you look 27 1/20/10 - COMMERCE - RESOLUTION 090860 at the work of certainly your committee and your efforts to make sure that there was a focus by past and current Administrations to make sure that the City paid attention to minority participation where it was not before, that certainly has had a tremendous impact in our ability to change the numbers to where -- increase and improve the numbers to where they are today. I think also that they're looking at how we do the work of minority participation has been a greater focus in helping departments understand that, with more work around that. That's how we believe we'll increase the utilization of minorities and women and disabled going forward. So I think if you look at the combination of all of the efforts, the increased awareness around it has driven that number of increasing over the years.
Mr. Huang, where specifically did the increase 28 1/20/10 - COMMERCE - RESOLUTION 090860 occur?
From the single-digit percentage of participation from 1998 to 2003 to the double-digit percentage of utilization from 2005 on.
From 1998 to 2003, it was in the single digits for the total --
The question is, in what area of contracting did it occur?
According to the FY08 Disparity Study, we now have double-digit utilization of minority, women and disabled-owned businesses in Public Works at 15.1 percent and in Personal and Professional Services at 22.7 percent. It is still under double digits for Services, Supplies and 29 1/20/10 - COMMERCE - RESOLUTION 090860 Equipment at 9.2 percent.
Is it safe to say that most of the increase in participation came from Professional Services?
How is it taken into account related to the strategic plan?
The increase in Professional Services? So we look at that and from the context of if we know that there's opportunities for utilization that we have right now and don't have the ability to fill, we go out and do technical assistance outreach. We're looking at how do we -- from an outreach perspective, how do we identify firms that are not ready in our database that we could go out and put in the database that are in Professional Services. So we're doing that across the board. That's part of the monitoring, 30 1/20/10 - COMMERCE - RESOLUTION 090860 the compliance in departments working with OEO. As we begin to be more involved in those contracting conversations and processes, we'll be able to identify the gaps that are available there and then go out and work within the Commerce Department and all of our resources there, in addition to OEO, which is part of Commerce, to find out how we can go and attract those types of businesses, even if it's coming into the City or it's us going outside the City where we don't have the availability in the City and reaching out to minority firms that are outside the City or looking at firms that just traditionally have never been certified for various reason and going back to them and saying, Hey, we've changed this process, it's less invasive, it's easier, it's faster, why don't you come on in, get certified so that we can count your numbers. The other part about that, we 31 1/20/10 - COMMERCE - RESOLUTION 090860 believe -- and we're getting more and more information about this, so I don't have quantifiable information, but we believe that there are firms out there that are being utilized that are not certified, that are being utilized by the City of Philadelphia already that we can't count because they're not certified. So we think that there's also a base right there that we could reach out to and say, Okay, we've changed this, we made it better, we want to be able to count you as far as our participation number.
Mr. Huang, I guess my question really is, how has availability changed by contract type since the 1998 to 2003 period? If from 1998 to 2003 we were in single digits in terms of participation and we moved to double digits, can you tell me by contract type how the availability has changed?
The most relevant 32 1/20/10 - COMMERCE - RESOLUTION 090860 availability figures that we take into account are for the metro area. So I want to preface by noting that there has been an out-flux of minority and women-owned businesses from the cities to the suburbs. This is a general demographic trend, and it is true of entrepreneurs as well. The availability has increased at the same time and approximately the same rate as the utilization. We now see double-digit availability rates in Personal and Professional Services, as well as Public Works and as well as Services, Supplies and Equipment when we compare for the period --
I'm asking specifically what's the change in availability by contract type.
I'm not aware that DJ Miller showed availability by contract type. I have the report with me and I can look at that. So I don't know what the change is from '98 to '03 versus '06 33 1/20/10 - COMMERCE - RESOLUTION 090860 to '08.
Would it make sense that if availability has risen for certain contract types, that those are the types of businesses that OEO should go after aggressively in terms of certification?
That would be one factor, is if there is more availability of a particular type of business, that they may want to consider focusing their outreach in that type of industry, but it also depends on the types of contracts that are available.
Well, I was already assuming that we're dealing within the contract types that exist in the City.
Right. So if I may, what I think we're -- if there's an opportunity for a greater level of utilization in any one particular type and we see that there is a low level of availability of the firms that can do 34 1/20/10 - COMMERCE - RESOLUTION 090860 those type of contracts --
Oh, if there's a higher availability. So if there's a greater availability --
I'm asking because this is based on what the Disparity Study -- this is what I meant. If availability is rising in a certain area, are we capturing those opportunities, and how closely are we monitoring availability to capture those opportunities to make sure we aggressively certify those people?
I guess what I was suggesting is that it does depend on what City contracts are available.
That's already understood, that we're basing it upon what City contracts are available, if this is the agency that is monitoring City contracting for opportunities for disadvantaged businesses. If we also, 35 1/20/10 - COMMERCE - RESOLUTION 090860 through a Disparity Study, are monitoring the availability of those businesses that could be certified for those opportunities and we see availability rising, right now are we actually -- have we actually, based upon that, tracked availability and made decisions to actually go out and take advantage of those opportunities?
I think the general answer is, probably not as well as we would like to. The general answer is no. 14
Well, that's actually how we went from single digits to double digits.
And the only way you're going to go to percent or 20 over is actually to look at availability 21 and make sure that all those available 22 firms are certified and that we're 23 actually doing the outreach to them, not 24 only to get them certified but for their 25 participation, and that's actually, in my 36 1/20/10 - COMMERCE - RESOLUTION 090860 mind, a goal achievement process.
I think what Mr. Dow is referring to -- and you can correct me if I'm wrong. I don't want to put words in your mouth -- is, I don't think it needs to be an either/or. Councilman Goode, you're correct that where there is high availability, you would want to focus some effort to match that with high utilization, and the long-term strategy is that where there are situations where the City has contracts that are available and the availability of minorities, women and disabled-owned businesses is low, that there are some ways that OEO can be involved with other entities in the City that provide technical assistance and business outreach and entrepreneurial support to increase those availability numbers, in the hopes that, in concert, utilization levels would increase as well. 37 1/20/10 - COMMERCE - RESOLUTION 090860
Mr. Huang, you did not present your testimony, but just one question in your testimony and then I'm going to finish up very quickly so my colleagues can jump in. In your testimony, your numbers actually differ from the numbers in the Disparity Study. Why is that?
Do you have the most recent version which I made available this morning?
So if you look at, for example, Page VII in the Disparity Study, the 2008 numbers are consistent with what's in the executive summary of the Disparity Study.
Right. Yes. Thank you for bringing this up. This is a -- Figure 1.2, of the FY08 Annual Disparity Study is incompletely labeled. Those numbers represent -- the DJ Miller study that covered '98 to '03 looked at utilization in three ways - purchase orders, awarded contracts and, where possible, where the data was available, payments. The FY08 Disparity Study Figure 1.2 shows the utilization based on purchase orders, and I believe those were the numbers that were quoted by Mr. Dow in his remarks. In my testimony, I felt it more appropriate since we, Econsult, for the '06, '07 and '08 reports used awarded contracts, that a fairer side-by-side comparison would be to use the awarded contracts number for the DJ Miller years so as to be resonant with the Econsult numbers for '06, '07 and 39 1/20/10 - COMMERCE - RESOLUTION 090860 '08. And so that's what I put in my prepared remarks.
I guess my only question is, what will go in the next Disparity Study?
We're going to decide either to more properly label this or to change it to reflect awarded contracts.
And you understand why I'm asking that question. We want to make sure that we're comparing apples to apples and oranges to oranges.
We haven't decided that yet. But we'll certainly be sure to label everything so that it's not as misleading as this one is.
Mr. Dow or 40 1/20/10 - COMMERCE - RESOLUTION 090860 Mr. Huang, what's the most current DBE participation info that you have?
Most current DBE participation for the City? We have draft numbers for Fiscal Year '09.
We have participation roughly 7.5 -- excuse me. I apologize. 17.5 for the total participation. Minority participation would be 11.05 and women would be 6.44.
I don't have that information right here. Hold on. Maybe. Excuse me. I apologize for that. I think I do. I apologize for that. We have -- hold on, give me a moment. In 2009, the total was 17.5. African American would be 8.61.
On a percentage basis, it comes out to zero percent. On an absolute dollars basis, it is $14,000.
Okay. The strategic plan calls for quarterly tracking. Why not --
It boils down to when we are able to -- essentially, it's a systems problem, technology problem.
That cannot be overcome? 42 1/20/10 - COMMERCE - RESOLUTION 090860
If you have a strategic plan that is not final, in your draft strategic plan why would you aim for quarterly tracking rather than realtime tracking?
Well, what we would try to do is get what is most reasonably -- what we can deliver. So if we know we can't deliver the realtime, we're not going to tell you we're going to deliver that. Right now we know that it's a systems problem.
Does quarterly tracking allow you enough response time?
I believe it does, because what you should be less focused on necessarily on terms of how do we change behaviors, it's not necessarily the tracking of it.
So we are in the third quarter of Fiscal Year '10. 43 1/20/10 - COMMERCE - RESOLUTION 090860 Where are we?
-- of Fiscal Year '10. So you have no idea whether you're going to meet your Fiscal Year '10 goals or not?
If we are in the third quarter of Fiscal Year '10 and you can't give me a number, there's no 22 way you can have an idea whether you're going to meet your goals or not. So quarterly tracking is not sufficient.
I mean, that's public information. I would believe that it should be.
My understanding is that that information is public information and so it can be asked for.
Would someone have to request it or are you going to post it on your website? 45 1/20/10 - COMMERCE - RESOLUTION 090860
To be determined. I believe that in order to be transparent, we should post it, but that's to be determined.
This is my last question. You set a Fiscal Year '11 goal of percent. Moving forward, you 9 roll out the strategic plan. The 10 strategic plan is final. The strategic 11 plan is working, even if you only have 12 quarterly tracking. What's the earliest 13 point that we will actually know that we 14 are achieving that 25 percent for Fiscal 15 Year '11? 16