Managing Developers to Meet City Requirements

Managing Compliance

Recently an audit conducted by Auditor Kathleen Patterson concluded that:

“The District government is failing to ensure that developers fulfill pledges they make in exchange for tax benefits and loans, and hasn’t collected potential monetary penalties since the mid-1980s as a result, the city’s auditor said.” [Washington Post Article]

Requirements Management Needed Starting with the Contract

The city is not monitoring, tracking and reviewing performance of the projects under it’s jurisdiction:

“In August, Patterson’s office reported that the city’s oversight of at least two development projects showed that even as developers delivered on a variety of promises, city agencies “did not sufficiently monitor” compliance.” [Washington Post Article]

It takes a Program Office

To do this the City Government has to setup a system for documenting, tracking and monitoring compliance with contract requirements. As the article notes:

“There needs to be oversight of commitments that developers make,” [Washington Post Article]

Documenting Contractual Requirements

That starts with assigning an agency or contractor to function as a program office for managing the project requirements during the contract development period. As the contract is written, it’s requirements need to be be placed in a requirements database.

Developing and Documenting Deliverables

As the contract is finalized, the developer works with the program office to develop the technical details of how and when they will deliver on those requirements. These then become the deliverables needed to meet contract’s requirements along with priorities, milestones and due dates.

Tracking, Monitoring and Compelling Performance

That program office should then be responsible for tracking the deliverables and monitoring performance via status reports and milestone reviews. Each contract requirement deliverable should have it’s value to the developer and any penalties spelled out so that the program office can then enforce compliance.

Making sure they “do what they are supposed to do”

The purpose of the District providing oversight of projects is to ensure they are delivered in a way that meets (or exceeds) the districts needs in an affordable manner. This is a fiduciary duty of government. As Patterson notes:

“I work for the taxpayers and I need to make damn sure they do what they’re supposed to do.” [Washington Post Article]

Making a program office and specific officers responsible for monitoring and ensuring compliance is best practices for doing this. It also helps avoid costly legal battles by ensuring that contract responsibilities are clear and agreed on.

Program Manager

Someone must be responsible for overall project compliance. That person within the government is a Program Officer. The Program Officer is given the authority to make sure that the persons responsible for project performance perform and that their progress is monitored week to week, month to month and at milestone reviews set in the contract. They ensure the deliverable are met and if not that action is taken to punish the transgression or remedy the shortfall.

Contracting Officer Technical Representative (COTR)

A Program Manager usually is assisted by a COTR. The COTR has the job of making sure that the developer or contractor with the project is paid if and when he she delivers on the contract requirements and deliverables. And of ensuring that action is taken when they don’t. The COTR also has overall responsibility for tracking those deliverables usually with assistance from Office Personnel who do data entry/IT/Database work or work with the project teams.


Some of the requirements that the Audit found developers were not meeting, were workforce training and local hiring requirements. One of GABIDDC’s core missions is to ensure that City Wide Development, especially on public lands, is done in a manner that is sustainable and equitable to all citizens.

Our purpose is to do our part to ensure that all the citizens of this area have the opportunity to receive both the training and the job opportunities to be fully functional, free and independent citizens. Towards that end the City mandates that developers provide Jobs to DC residents.

GABIDDC is devoted to develop and facilitate the kinds of workforce training so that developers can meet the requirements for providing those jobs, and that citizens can fill job positions as they become available. That is why we are developing Workforce Training opportunities. It is also why we are proposing that the District use a requirements management system and program office to manage them.

GABIDDC can help projects like Hines Urban Atlantic to meet their workforce hiring requirements by providing recruiting and training services.

GABIDDC is doing what it can with limited funding, but stands ready to assist developers and the city in reaching it’s workforce requirements.

About the Author

Chris Holte is currently voluntarily assisting GABIDDC by helping with the website and working as CIO. He has 20 years+ experience working on projects and project management. He is the author of this article. The opinions expressed in this article are his own based on years of experience with IT projects, contract deliverables and requirements.

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