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Scenario: We have a large remediation contract that contains both an SCA wage determination and a Davis-Bacon wage determination. Most of the work we do under this contract is service work, but there is some construction work occasionally that's subject to the DBA. Part of the remediation work under our contract requires drilling for, and installation of, monitoring wells as part of an environmental remediation system. We've previously determined that the drilling and subsequent installation of the monitoring wells is NOT subject to the DBA primarily because the wells are temporary and will be either abandoned and/or filled in after the  monitoring is complete and the remediation system is decommissioned, and as such, are not "works" because they are not improvements. 
Note that our SCA WD includes a labor category of "well drilller" and our DBA WD includes a labor category of "drill operator". The DBA "drill operator" wage is quite a bit higher than the "well driller" wage. To add to the confusion, and what is causing me to reevaluate this, is that I just noticed that the DBA WD includes "Environmental Remediation" and "Monitoring Well" in its labor classification description of "Laborer". 

I've spent a lot of hours  researching this issue and can't seem to find anything definitive, and I've read some conflicting information in various guidance documents and the like. Does anyone have any guidance or information that might be helpful in determining whether SCA or DBA applies to this type of work?

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The entire contract should be SCA or the entire contract should be DBA — this is the general rule.  However, if it is possible for the contract to segregate the work, so that one clearly-defined portion is SCA (and covered by the contract’s SCA WD) and the other clearly-defined portion is DBA (and covered by the contract’s DBA WD), then a contract may have both SCA and DBA WDs.

There should be no confusion in a well-written contract that conforms to FAR instructions.  Perhaps your contract is not a well-written one?

How has your contracting officer responded to your question?

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20 hours ago, elgueromeromero said:

Scenario: We have a large remediation contract that contains both an SCA wage determination and a Davis-Bacon wage determination. Most of the work we do under this contract is service work, but there is some construction work occasionally that's subject to the DBA. Part of the remediation work under our contract requires drilling for, and installation of, monitoring wells as part of an environmental remediation system. We've previously determined that the drilling and subsequent installation of the monitoring wells is NOT subject to the DBA primarily because the wells are temporary and will be either abandoned and/or filled in after the  monitoring is complete and the remediation system is decommissioned, and as such, are not "works" because they are not improvements. 
Note that our SCA WD includes a labor category of "well drilller" and our DBA WD includes a labor category of "drill operator". The DBA "drill operator" wage is quite a bit higher than the "well driller" wage. To add to the confusion, and what is causing me to reevaluate this, is that I just noticed that the DBA WD includes "Environmental Remediation" and "Monitoring Well" in its labor classification description of "Laborer". 

I've spent a lot of hours  researching this issue and can't seem to find anything definitive, and I've read some conflicting information in various guidance documents and the like. Does anyone have any guidance or information that might be helpful in determining whether SCA or DBA applies to this type of work?

The Wage and Hour Division or other office in the Department of Labor would be the one to ask rather than here. 

Generally, exploratory drilling for soil or water table condition borings is considered a service, while drilling working wells is considered constriction. I don’t think that it matters whether or not the wells are permanent or temporary. But ask the DOL about monitoring wells. I’m guessing that the project also includes wells for pumping contaminated water for treatment purposes and/ or injection wells. Those would be  considered construction. 

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