Dallas Area Rapid Transit - Federal Transit Administration

facilitate small business participation on DOT-assisted projects and contracts. A detailed
program element will be submitted by February 28, 2012 detailing its procedures and
methods for facilitating competition by small business concerns.
8. Determining/ Meeting Goals
A) Calculation
Basic Requirement: (49 CFR Part 26.45) To begin the goal setting process, the recipient
must first develop a base figure for the relative availability of DBEs. After the base
figure is achieved, all other relative evidence must be considered in an adjustment of this
figure to match the needs of the specific DBE community.
Discussion: During this DBE Compliance Review, no deficiencies were found with the
requirements for calculation of goal.
Information was collected on DART’s DBE goals for fiscal years 2009, 2010 and the
2011 – 2013 triennial periods. The overall goal for FY 2009 was 27% with 23%
projected to be met by race-conscious means. The FY 2010 goal was also 27% with a
25% race-conscious projection.
The three-year goal submission for DART was due August 1, 2010. In June 2011,
DART noted that FTA asked that they review their goal methodology and resubmit a
three-year goal. FTA received DART’s DBE goal of 34% for years 2011 through 2013
on September 1, 2011. The goal was conditionally approved pending receipt of an
updated goal methodology by November 21, 2011 that addressed several issues identified
by FTA. DART provided the review team a copy of the November 18, 2011 revised goal
methodology that was sent to FTA addressing weighting the base figure, calculation of
the median, and race-conscious/neutral breakdowns.
Step 1: Determining the Base Figure
DART anticipated that FTA expenditures for fiscal years 2011 to 2013 would total
$451,527,387. This amount was categorized into construction, professional services,
services, and commodities for contractible dollars in each year. However, no FTA
expenditures were projected for the commodities category. DART determined that their
internal vendor database would be more reflective of ready, willing and able DBE and
non-DBE firms rather than the US Census Bureau data. The Texas UCP directory was
used to determine the DBEs for the applicable NAICS codes in the anticipated
contractible opportunities.
The number of DBE firms in relevant NAICS codes was 1,840 firms and 4,372 non-DBE
firms for a total of 6,212 firms. DART divided the number of DBE firms (1,840) over all
firms (6,212) and calculated 29.62% resulting in a rounded 30% base figure. FTA noted
that DART did not address weighting considerations in its goal methodology. DART
noted in their revised methodology sent to FTA that the overall goal was not weighted by
contracting opportunities, as all contracting opportunities with federal funds will be
treated equally in efforts for DBE participation.
The review team used the data in the revised methodology to calculate the weighted base
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