METHODOLOGY FOR DETERMINING DBE GOAL (49 CFR § 26.45) – Federal Fiscal Years 2017, 2018, and 2019
CENTRAL MIDLANDS REGIONAL TRANSIT AUTHORITY
METHODOLOGY FOR DETERMINING DBE GOAL (49 CFR § 26.45)
Federal Fiscal Years 2017, 2018, and 2019
The Central Midlands Regional Transit Authority (CMRTA) dba The COMET has prepared this document to outline the methodology used to establish its overall three-year Disadvantaged Business Enterprise (DBE) goal for FTA assisted contracts. The overall goal for federal fiscal years 2017-2019 has been set at 5% utilizing the methodologies described in 49 CFR §26.45. CMRTA anticipates that at least 2.5% of the goal will be met through race-conscious measures and the remaining 2.5% will be achieved through race-neutral means.
In setting the overall DBE goal for CMRTA, it is required that a two-step process be utilized in establishing the goal. The goal setting process began with a base figure to determine the relative availability of DBEs. The overall goal must be based on demonstrable evidence of the availability of ready, willing, and able DBEs relative to all businesses ready, willing, and able to participate on FTA assisted contracts. Data was collected from the most recent South Carolina Unified Certification Directory and the County Business Patterns Census database.
STEP 1: Determining the Base Figure – 49 CFR § 26.45(c)
Step One of the goal setting process is an attempt to come up with a measurement of the actual relative availability of DBEs in the market area. CMRTA’s market area consists of counties within South Carolina.
The ratio utilized in Step One is expressed below:
Non-DBE’s and DBEs
The CMRTA reviewed the methods listed in 49 CFR Part 26.45 (c) and selected the South Carolina Unified Certification Directory as the numerator and the Census Bureau database from the 2015 County Business Patterns data as the denominator in determining the best approach for the base figure. See Table 1.
Table 1-Relative Availability of DBEs by Categories of Work
|NAICS Code||Description of Projected Work||Number of DBEs*||Number of ALL Firms **
|RELATIVE AVAILABILITY (# of DBEs divided by # of all firms)|
|561621||Surveillance/Security System (2017)||4||108||0.037|
|45321||Office Supplies (2017)||3||98||0.031|
|323111||Printing Services (2017)||3||216||0.014|
|423990||Bus Stop Signage (2018)||9||121||0.074|
|488490||Automated Passenger Counters (2018)||2||41||0..049|
|236220||Bus Shelters (2018)||63||499||0.126|
|811192||Bus Wash (2018)||5||221||0.023|
|423430||Computer Purchase (2018)||5||84||0.060|
|Hot Spot/Fiber Optics Cabling (2018)||41||906||0.045|
**US Census Economic Data by NAICS for South Carolina (2015 County Business Patterns)
Each upcoming federal project was identified and assigned a North American Industry Classification System (NAICS) code in Table 1. After compiling all data in the chart above, the base figure percentage was determined by dividing the number of ready, willing and able DBE firms that corresponded to the NAICS codes and work category codes by the number of all firms (DBEs and non-DBEs) ready, willing, and able to bid for the types of work CMRTA will have available using FTA assisted funds during the triennial period. The ratio is expressed below:
140 (Certified) DBEs =
2757(Total Market Area Firms)
In this case, using the relative availability of DBEs (140) vs. the relative availability of DBEs and non-DBE firms (2757) for the types of contracts CMRTA anticipate awarding. (140/2757) = 5.1 percent.
Based on the calculation above, CMRTA has determined its Base Figure (relative availability of DBEs) to be 5% (rounded).
Step 2: Adjusting the Base Figure
Upon establishing the Base Figure, CMRTA considered whether a “step two” adjustment was needed to adjust the base figure. CMRTA reviewed and assessed other known evidence potentially impacting the relative availability of DBEs within the market area, in accordance with prescribed narrow tailoring provisions set forth under 49 CFR Part 26 in an effort to derive at a more precise base figure.
Evidence considered in making an adjustment to the Base Figure included Past DBE Goal Attainments to determine capacity, current opportunities relevant to upcoming projects, disparity studies, goal of another recipient, and other evidence which could have an impact on the data analysis
- Past DBE Goal Attainments
As historical DBE participation attainments provide demonstrable evidence of DBE availability and capacity to perform, CMRTA proceeded to consider past DBE participation attainments for the past three (3) federal fiscal years. After a review of the Uniform Report of DBE Commitments/Awards and Payments, it was revealed that several reports had not been prepared and submitted prior to 2016, therefore, using historical data was not available and could not be an option for consideration in adjusting the Base Figure.
- Current Opportunities
The CMRTA reviewed all upcoming grants with contracting opportunities during the triennial period. Consideration was placed on the availability of DBEs who would be available to perform in several areas. Approximately $185,000 was available in federal fiscal year 2017 and approximately $1,234,000 was identified for DBE contracting opportunities in 2018. Since CMRTA does not anticipate an increase in federal funding during 2019, the last year of the triennial year, the agency believes that there will not be a need to make an adjustment in this area.
The breakout of federal dollars available for contracting opportunities is outlined in Table 2. Data is currently not available for FFY2019.
Table 2-Anticipated Contracting Opportunities (2017/2018)
|NAICS||Project Name/Description||Federal Cost||% Total Amount|
|FFY2018||423990||Bus Stop Signage||$80,000||6.5%|
|488490||Automated Passenger Counters||$398,000||32.3%|
|238210||Hot Spot & Fiber Optics Cabling||$60,000||4.9%|
- Disparity Study
CMRTA is not aware of any current disparity studies within their jurisdiction and/or market area that are similar in size and nature to consider in this step of the goal setting analysis.
- Goal of Another Recipient
CMRTA is not aware of another recipient that would be of similar size to consider in this step of the goal setting analysis.
- Other Available Evidence
CMRTA took into consideration other potential evidence such as financing, bonding and insurance requirements. Based on the contracting opportunities available during the triennial period, CMRTA did not believe any of these items would have an impact on the DBE goal assessment.
PROPOSED OVERALL DBE GOAL
The Final Proposed Overall DBE Goal for FFY 2017‐2019 for CMRTA’ FTA‐assisted contracts will be 5%. As a part of the prescribed goal‐setting methodology, CMRTA must project the percentage of its Proposed Overall DBE Goal that can be met utilizing race‐neutral and race‐conscious measures.
Race‐Conscious & Race‐Neutral Projection
CMRTA intends to use a combination of race-conscious and race‐neutral methods to meet the overall DBE goal of 5% for FFY 2017‐2019. Race-neutral approaches will be considered in accordance with the guidelines found at Title 49 CFR § 26.51.
Based on the analysis in Step 1 and Step 2, CMRTA proposes to establish its FFY2017-2019 overall DBE transit goal as follows:
DBE Base Figure 5%
Race‐Conscious Component 2.5%
Race‐Neutral Component 2.5%