Do Subcontractor Listing Requirements Apply to Design-Build?

Background:  In Washington State, RCW 39.30.060 requires bidders to list subcontractors for HVAC, plumbing, and electrical work on all public works projects estimated to cost $1 million or more.  The list of such subcontractors (or the listing by the prime contractor that they will perform such work themselves) must be submitted either with the bid, or within one hour of the bid submittal deadline.

Question:  Do these requirements apply to Design-Build projects (chapter 39.10 RCW) when firms are responding to either an RFQ or RFP (the two parts of the selection process)?

Not Applicable:  It is my opinion that the subcontractor listing requirements do not apply to either an RFQ or RFP as part of a Design-Build project.  I base my opinion on the following:

1. No Invitation to Bid:  RCW 39.30.060 (1) states that the requirements for subcontractor listing applies to "every invitation to bid" estimated to cost $1 million or more.  Selection of a Design-Builder is not conducted through an "invitation to bid" but through the two step process of an RFQ followed by an RFP for short-listed finalists.
   
2. No Subcontract Bidding:  The very nature of a response to an RFQ or RFP for Design-Build is different from the process in place for responding to a bid under a Design-Bid-Build project, in which the prime contractor solicits bids as part of developing their bid for a project.  Under a Design-Build RFQ or RFP, while the proposer may engage in some discussions with subcontractors, there is no design for subcontractors to bid on, since the project hasn't been designed.  

Thus, the purpose of RCW 39.30.060, which is to prevent bid shopping from occurring on public works projects, doesn't appear to be applicable for firms responding to an RFQ or RFP for a Design-Build project.

If you have different thoughts on this subject, I would be interested in hearing your opinion.