Disadvantaged Business Enterprise Goal Methodology

Transcription

DISADVANTAGED BUSINESS ENTERPRISEGOAL METHODOLOGYFederal Highway AdministrationFY 2022-2024JULY 2021This report is submitted in accordance with the U.S. Department ofTransportation’s amendments to 49 CFR Section 26.45, dated November 3, 2014.

Disadvantaged Business Enterprise Goal MethodologyFHWA FY2022-2024Table of Contents1.0 Introduction . 32.0 Proposed DBE Goal for FY2022-2024 . 33.0 Race/Gender-Neutral and Race/Gender-Conscious Measures. 133.1 Race Gender-Neutral and Race-Conscious Activities3.1.1 Small Business Enterprise Program . . . . 153.1.2 Expansion of Business Development Program . 183.1.3 Public Participation FY2022-2024 . . . 194.0 Conclusion . 20List of TablesTable 1: Contracting Activity for Federal Aid Contracts FY 2018-2020. 4Table 2: Highway Design, Engineering and Professional Services NAICS Codes . 5Table 3: Highway Construction (Contractors) NAICS Codes . 6Table 4: Relative Availability of DBE Firms. 7Table 5 Percentage of Work Anticipated on DDOT Contracts . 9Table 6: Weighted DBE Availability . 10Table 7: Median for Three Year Contract Period (FY 2018-2020). 11Table 8: DBE Participation in Excess of Goal for FY 2018-2020 (Race-Neutral) . 13Table 9: DBE Prime Contractor Awards for FY 2018-2020 (Race-Neutral) . 14Table 10: SBE Spending . 16Table 11: Representatives at DBE Goal Methodology Public Outreach . . TBDDisadvantaged Business Enterprise Goal Methodology2FHWA FY2022-2024JULY 2021

1.0IntroductionThe District Department of Transportation (DDOT) respectfully submits the Disadvantaged BusinessEnterprise Goal Methodology report for FY 2022-2024 to the United States Department of Transportation,Federal Highway Administration. This report demonstrates the efforts and challenges experienced byDDOT in implementing race conscious and race neutral programs for federally funded contracts.2.0Proposed DBE GoalIn accordance with the November 3, 2014, U.S. Department of Transportation rule amendments to 49 CFRSection 26.45, DDOT proposes a DBE goal of 21.84% with a race conscious goal of 20.27% and a raceneutral goal of 1.57% for Federal Highway Administration (FHWA)-funded projects, effective for a periodof three (3) years: FY 2022-2024.The following describes the goal methodology used to determine this three-year goal:Step 1 - Determination of Relative Availability of DBE ContractorsIn determining the relative availability of DBE contractors, DDOT first defined its local market area usingguidance established by the U.S. Department of Transportation’s Office of Small and DisadvantagedBusiness Utilization’s (OSDBU) website “Tips for Goal Setting in the Disadvantaged Business EnterpriseProgram” (http://osdbu.dot.gov/dbeprogram/tips.cfm). Per the USDOT “Tips for Goal Setting” guidance,the local market area is the area in which most of the contractors and subcontractors with which DDOTdoes business with is located, and the area in which DDOT spends the substantial majority of itscontracting dollars.The local area market for DDOT includes the Washington, DC Metropolitan Area, hereafter referred to asthe “Metro Area”. The Metro Area is defined by the U.S. Census Bureau Metropolitan Statistical Area asWashington-Arlington-Alexandria, DC,MD, VA, and WV. This area includes the District of Columbia; theVirginia cities of Alexandria, Fairfax, Falls Church, Fredericksburg, and Manassas Park City; the Virginiacounties of Arlington, Clarke, Fairfax, Fauquier, Loudon, Prince William, Spotsylvania, Stafford andWarren; the Maryland counties of Calvert, Charles, Montgomery, Prince George’s and Frederick; and theWest Virginia county of Jefferson).Calculation of Relative DBE Availability by NAICS CodeAfter identifying the local market area, DDOT completed a thorough examination of the highwayconstruction related NAICS codes utilized on its federal-aid highway construction projects over itsprior 3-year contracting period from FY 2018-2020. Additionally, DDOT examined forecastedcontracting work anticipated to be performed over the next three-year period from FY 2022-2024.DDOT established standard NAICS codes which encompass highway construction work performedfor highway, bridge and street design and construction, civil engineering services, environmentalconsulting services, construction management, and other administrative and managementconsulting services.Data for this process was gathered by examining contract activity for the period of FY 2018-2020(October 1, 2017-September 30, 2020). Based upon examination of the available data, DDOT’sDisadvantaged Business Enterprise Goal Methodology3FHWA FY2022-2024JULY 2021

contractual dollars totaled 180,949,106 of which 158,515,949 (88%) were awarded to primecontractors whose firms conduct business within the local market area. Table 1 provides asummary of the contracting activity during FY 2018-2020:Table 1Contracting Activity for Federal-Aid Contracts FY 2018-2020DescriptionGeographic Distribution ContractDollarsDistribution of Participating PrimeContractorsDistribution of All ParticipatingContractors (includingsubcontractors)Total Awards andCommitments for thePeriod ofFY 2018-2020Amount Represented byWashington MetropolitanStatistical AreaPortion of WashingtonMetropolitan StatisticalArea 180,947,106 158,515,94988%14914295%31126786%As described in 49 CFR, Part 26.45(c)(1) of the DBE Regulations, DDOT used its DBE directory andavailable data resources to determine the relative availability of ready, willing and able DBE firmswithin DDOT’s local market area. . DDOT collected and compiled DBE availability data obtainedfrom MBE/DBE directories of Federal, State, local governmental agencies, and surroundingcounties in the Metropolitan area to determine the base figure for Step 1 of the goal settingprocess. These data sets are described below: DDOT’s electronic DBE Directory is comprised of all engineering and highway-relatedconstruction firms, suppliers, consultants, etc. certified by the U.S. Department ofTransportation-approved District of Columbia Unified Certification Program (DCUCP).Data used to provide an accurate account of all firms within the geographic market wascollected and compiled from several electronic MBE/DBE directories representative ofFederal, State, local governmental agencies, and surrounding counties in theMetropolitan area for DDOT’s local market area. A list of MBE/DBE directories researchedis included on page 7 under the section titled, “Calculation of Relative DBE Availability byNAICS Code.”DDOT attempted to gather business Census data from several previously identifiedsources, US Census American Community Survey, American Fact Finder and CountyBusiness Pattern resources. Current US Census Bureau County Business Pattern data forDDOT’s local market area was unavailable for public distribution and use at the time ofreport development.To ensure the most accurate goal possible, DDOT estimated the type of work that would beperformed over the next three years and classified each type of work using North AmericanIndustry Classification System (NAICS) codes. According to the U.S. Census Bureau, NAICS Codesare the standard used by federal statistical agencies for the purpose of collecting, analyzing andpublishing statistical data related to the U.S. business economy. Businesses are classifiedaccording to the primary line of business activity at various levels of specificity. Using the mostdetailed codes available, DDOT Equity and Inclusion Division in consultation with DDOTDisadvantaged Business Enterprise Goal Methodology4FHWA FY2022-2024JULY 2021

Infrastructure Project Management Division (IPMD) staff and Consultants reviewed the forecastof projects and identified additional highway and engineering based NAICS Codes the agencyanticipates utilizing on forthcoming projects in FY 2022-2024. The additional NAICS Codes areidentified with an (*) asterisk. DDOT has determined the overall categories of active contractorsavailable for projects planned in FY 2022-2024 from the following NAICS Codes, listed in Tables 2and 3, respectively.Table 2Highway Design, Engineering and Professional Services NAICS Codes(*) Indicates new added DDOT Highway and Engineering NAICS ommercial Printing (Except Screen and Books)Charter Bus IndustryInsurance Agencies and BrokeragesArchitectural ServicesArchitectural Services (Landscaping)Engineering ServicesDrafting ServicesBuilding Inspection ServicesGeophysical Surveying and Mapping ServicesSurveying and Mapping (Except Geophysical Services)Testing LaboratoriesGraphic Design ServicesCustom Computer Programming ServicesComputer Systems Design ServicesAdministrative Management/General Management Consulting ServicesMarketing Consulting ServicesProcess, Physical Distribution and Logistics Consulting ServicesOther Management Consulting ServicesEnvironmental Consulting ServicesOther Scientific and Technical Consulting ServicesPublic Relations AgenciesAdvertising Material Distribution ServicesMarketing Research and PollingInspection ServicesFacilities Support ServicesTemporary Help ServicesLandscaping ServicesTraffic ControlDisadvantaged Business Enterprise Goal Methodology5FHWA FY2022-2024JULY 2021

Table 3Highway Construction (Contractors) NAICS Codes(*) Indicates new added DDOT Highway and Engineering NAICS CodesNAICS 950423320423610484110DescriptionWater and Sewer Line and Related Structures ConstructionPower and Communication Line and Related Structures ConstructionHighway, Street and Bridge ConstructionOther Heavy and Civil Engineering ConstructionPoured Concrete Foundation and Structure ContractorsStructural Steel Erection ContractorsMasonry ContractorsElectrical Contractors and Other Wiring Installation ContractorsPainting ContractorsSite Preparation/ExcavationAll Other Specialty Trade ContractorsReady-Mix Concrete ManufacturingOther Concrete Product ManufacturingFabricated Structural Metal ManufacturingSheet Metal Work ManufacturingSignage ManufacturingBrick, Stone and Related Construction Material Merchant WholesalersElectrical Apparatus and Equipment, Wiring Supplies/Related EquipmentWholesalersGeneral Freight Trucking, LocalCalculation of Relative DBE Availability by NAICS CodeAfter identifying the market area and the types of work to be performed over the next three years,DDOT utilized business census data from a combination of Federal, State, local governmentalagencies, and surrounding counties in the Metropolitan area for DDOT’s local market area.DDOT gathered and cross-referenced contractor data from the MBE/DBE electronic directories ofthe Maryland Department of Transportation (MDOT), Virginia Small Business SupplierDevelopment (SBSD), West Virginia Department of Transportation DBE Support Services (WVA),Washington DC Department of Small and Local Business Development (DSLBD), U.S. Departmentof Veteran Affairs- Office of Small and Disadvantaged Business Utilization (VA-OSDBU) and theDDOT and Washington Metropolitan Area Transit Authority (WMATA) shared electronic DBEdirectories as approved in the Metropolitan Washington Unified Certification Program (MWUCP)certified by the U.S. Department of Transportation (USDOT). At the time of report preparation,current US Census County Business Pattern Data for the Washington DC-MD-VA-WVA Metro Areawas not available to the public for further analysis of DDOT’s local market area.Disadvantaged Business Enterprise Goal Methodology6FHWA FY2022-2024JULY 2021

Provided below is a list of electronic directories researched:·(MDOT) (https://mbe.mdot.maryland.gov/directory/search terms.asp)·(SBSD) �(WVA) (DBE Database (wvdbesupport.com)·(DSLBD) (https://dslbd.secure.force.com/public/DC CBE Certified Contractors Search)·(VA-OBDBU) (https://www.vetbiz.va.gov/basic-search/)·(WMATA) (https://supplier.wmata.com/psp/supplier/)These directories comprise all engineering and highway-related construction firms, suppliers, andconsultants within DDOT’s market area. DDOT analyzed available data to calculate the relative DBEavailability for each NAICS code in which DDOT expects to perform work in FY 2022 - 2024. The result ofthis research and analysis is set forth in Table 4 below.Table 4Relative Availability of DBE Firms(*) Indicates new added DDOT Highway and Engineering NAICS CodesNAICS 20541330541340DescriptionWater and Sewer Line and Related StructuresConstructionPower and Communication Line & Related StructuresConstructionHighway, Street and Bridge ConstructionOther Heavy and Civil Engineering ConstructionPoured Concrete Foundation and Structure ContractorsStructural Steel Erection ContractorsMasonry ContractorsElectrical Contractors and Other Wiring InstallationContractorsPainting ContractorsSite Preparation/ExcavationAll Other Specialty Trade ContractorsCommercial Printing (Except Screen and Books)Ready-Mix Concrete ManufacturingOther Concrete Product ManufacturingFabricated Structural Metal ManufacturingSheet Metal Work ManufacturingSignage ManufacturingBrick, Stone and Related Construction MaterialWholesalersElectrical Apparatus and Equipment, Wiring WholesalersGeneral Freight Trucking, LocalCharter Bus IndustryInsurance Agencies and BrokeragesArchitectural ServicesArchitectural Services (Landscaping)Engineering ServicesDrafting ServicesDisadvantaged Business Enterprise Goal Methodology7FHWA FY2022-2024Number ofDBEsAvailable toPerform thisWorkNumber ofAll 2.00%20.52%19.91%21.81%31.34%JULY 2021

0541990561210561320561730561990Building Inspection ServicesGeophysical Surveying and Mapping ServicesSurveying and Mapping (Except Geophysical Services)Testing LaboratoriesGraphic Design ServicesCustom Computer Programming ServicesComputer Systems Design ServicesAdministrative Management & General ManagementMarketing Consulting ServicesProcess, Physical Distribution and Logistics ConsultingOther Management Consulting ServicesEnvironmental Consulting ServicesOther Scientific and Technical ConsultingPublic Relations AgenciesAdvertising Material Distribution ServicesMarketing Research and PollingInspection ServicesFacilities Support ServicesTemporary Help ServicesLandscaping ServicesAll Other Support Services (formerly Traffic Control)Combined %4.10%Estimating the Dollar Value of Federal Work to be Performed in FY2022-2024In order to determine the specific contracting opportunities for FY 2022-2024, DDOT hasexamined projects which are to be funded from the Federal Highway Administration (FHWA).Based on the examination of DDOT’s proposed budgets, the Agency estimates that it willexecute contracts totaling (in millions):FY 2022:FY 2023:FY 2024: 184,534.00 188,915.00 193,402.00 566,851.00These dollars are to be utilized for highway, bridge and street construction, including excavation,demolition, backfill, PCC pavement base, resurfacing, sidewalks, and alleys. These dollars will alsobe used for highway, bridge and street design, civil engineering services, environmental consultingservices, construction management, and other administrative and management consultingservices.Estimating the Percentage of Federal Work to be Performed by NAICS Code in FY 2022-2024Table 5 below shows the percentage of anticipated work that DBE firms are expected to performon DDOT contracts according to the relevant NAICS Codes from Tables 2 and 3 above. Thispercentage was estimated by using historical contracting data on past DBE performance.Disadvantaged Business Enterprise Goal Methodology8FHWA FY2022-2024JULY 2021

Table 5Percentage of Work Anticipated on DDOT ContractsNAICSCodeDescriptionAmount of DOTFunds on Project:% Of TotalDOT Funds(Weight)237310Water and Sewer Line and Related StructuresConstructionHighway, Street and Bridge Construction237990Other Heavy and Civil Engineering Construction 10,562,494.891.86%238110Poured Concrete Foundation and Structure Contractors 33,672,222.125.94%238120Structural Steel Erection Contractors 79,736,059.0114.07%238140 371,927.320.07% 34,923,151.916.16%238320Masonry ContractorsElectrical Contractors and Other Wiring InstallationContractorsPainting Contractors 1,211,072.580.21%238910Site Preparation/Excavation 24,683,930.724.35%238990All Other Specialty Trade Contractors 91,256.940.02%327320Ready-Mix Concrete Manufacturing 15,114,660.402.67%339950SignageBrick, Stone and Related Construction Material MerchantWholesalers 233,343.710.04% 11,662,671.662.06%237110238210423320 25,857,374.434.56% 147,911,043.8026.09%443320Material Wholesalers 4,095,694.680.72%485510Charter Bus Industry 41,626,637.687.34%484110General Freight Trucking, Long-Distance 14,251,052.662.51%541310Architectural Services 14,372,323.782.54%541330Engineering Services 22,809,452.224.02%541340Drafting Services 110,317.520.02%541370Surveying and Mapping (Except Geophysical Services) 12,221,218.332.16%541380Testing Laboratories 171,948.260.03%541512 45,984.390.01% 19,967,158.013.52%541618Computer Systems Design ServicesAdministrative Management and General ManagementConsulting ServicesOther Management Consulting Services 35,570,968.346.28%541620Environmental Consulting Services 623,919.850.11% 1,885,256.300.33% 60,197.670.01% 1,327,268.150.23% 11,680,392.672.06% apingPublic Relations Agencies541990All Other Professional, Scientific and Technical Services561990All Other Support ServicesTOTALCalculation of Weighted DBE Availability for Each NAICS Code and Step One Base FigureOnce DDOT obtained the relative availability for DBEs in each NAICS code (Reference Table 4) andDisadvantaged Business Enterprise Goal Methodology9FHWA FY2022-2024JULY 2021

the percentage of funds anticipated to be spent in each code (Reference Table 5), DDOT thenweighted the availability for each NAICS code and calculated the Step One Base Figure. This is themethod of Step One Base Figure calculation favored by the Tips for Goal Setting. The sum of theweighted availabilities for all relevant codes to obtain the weighted Step One Base Figure. Table6 sets forth the relative availability, the weights and the resulting weighted DBE availability foreach relevant NAICS code and sums the weighted availability to arrive at the Step One Base Figure.Table 6Weighted DBE AvailabilityNAICS 7990Amount of DOT Funds onProject:% Of Total DOTFunds (Weight)WeightedAvailability 25,857,374.434.56%0.89% 147,911,043.8026.09%6.97%24.44% 10,562,494.891.86%0.46%23811016.48% 33,672,222.125.94%0.98%23812023.33% 79,736,059.0114.07%3.28%23814012.98% 371,927.320.07%0.01%23821013.68% 34,923,151.916.16%0.84%23832012.44% 1,211,072.580.21%0.03%23891015.17% 24,683,930.724.35%0.66%23899013.42% 91,256.940.02%0.00%3273207.69% 15,114,660.402.67%0.21%33995022.41% 233,343.710.04%0.01%42332026.50% 11,662,671.662.06%0.55%4433200 4,095,694.680.72%0.00%48551022.22% 41,626,637.687.34%1.63%48411011.07% 14,251,052.662.51%0.28%54131020.52% 14,372,323.782.54%0.52%54133021.81% 22,809,452.224.02%0.88%54134031.34% 110,317.520.02%0.01%54137027.22% 12,221,218.332.16%0.59%54138030.12% 171,948.260.03%0.01%54151213.11% 45,984.390.01%0.00%54161111.81% 19,967,158.013.52%0.42%5416189.16% 35,570,968.346.28%0.57%54162020.09% 623,919.850.11%0.02%541730 (561730)6.67% 1,885,256.300.33%0.02%54182018.64% 60,197.670.01%0.00%54199019.82% 1,327,268.150.23%0.05%5619904.10% 11,680,392.672.06%0.08%Total 566,851,000.00100%19.93%Weighted Base Figure 19.93%FY 2022-2024 Step One Base Figure: 19.93%Disadvantaged Business Enterprise Goal Methodology10FHWA FY2022-2024JULY 2021

Step 2 – Adjustment to Step One Base Figure1. Consideration of Previous Years’ Performance49 CFR Section 26.45(d) and the Tips for Goal Setting set forth examples of data that must beanalyzed and taken into consideration in determining whether adjustments to the Step 1 Basefigure are necessary. The purpose of 49 CFR Section 26.45(d)is to ensure that the final overallgoal is both narrowly tailored and effective in helping to remedy discrimination. This adjustmentprocess begins by reviewing DDOT’s historical contracting data.In order to determine whether past performance should be used to make an adjustment to Step1 base figure in Step 2, DDOT has collected historical contracting data over a three-year period. .We then calculated DDOT’s “median” past participation. DBE participation for the past three (3)years is shown in Table 7 below. The median percentage is determined by the middle percentagefor the past three (3) years.Table 7Median for Three YearContract Period (FY 2018–2020)ContractPeriodContracting Volume% DBEFY 2018 90,909,92913.64%FY 2019 54,736,64123.76%FY 2020 35,300,53637.03%To determine the median percentage of the past three (3) years, we must arrange the goalattainment from lowest to highest (13.64%, 23.76%, and 37.08%). In this case, the middle valueis 23.76%.The median participation for the past three (3) years used in the calculation is 23.76%.2. Adjusting the Step 1 Base Figure with the Median Past PerformanceThe USDOT OSDBU “Tips for Goal Setting in the Disadvantaged Business Enterprise Program”states: “If your records suggest levels of past participation very similar to the number youcalculated in Step 1, then it is not necessary to make any adjustment for past participation.” DDOTdetermined that the goal with the Step 2 adjustment better reflects the capacity in DDOT’sgeographic market. The calculation for the adjustment is as follows: identify the median pastperformance, which according to Table 7 above is 23.76%. The median figure is then added to theweighted base figure and divided by two to determine the adjusted Step Two goal, as outlinedbelow:Median Past Participation23.76%Weighted Step One Base Figure 19.93%43.69/2 21.84%Disadvantaged Business Enterprise Goal Methodology11FHWA FY2022-2024JULY 2021

Based upon the calculations above, the overall adjusted three-year goal for FY 2022-2024 is21.84%.49 CFR Section 26.45.5(d)(1) states that “there are many types of evidence that must beconsidered when adjusting the base figure.” In addition, 49 CFR Section 26.45.5(d)(2) states that“If available, you must consider evidence from related fields that affect the opportunities for DBEsto form, grow and compete. In this instance, DDOT determined that our goals would be moreaccurate if DDOT did not make adjustments for the factors below. In most cases, the datareferenced in the rule was not available. DDOT found that the factors below did not have animpact on adjusting the base figure. DDOT reviewed the following factors:i.“Evidence from disparity studies conducted anywhere within your jurisdiction, to the extentit is not already accounted for in your base figure.”The OSDBU’s Tips for Goal Setting in the Disadvantaged Business Enterprise Program’swebsite suggests that data should be collected and analyzed to consider the currentmarket dynamics to determine whether an adjustment to the goal is necessary. Onesuggested method is to analyze the results of a disparity study. DDOT has not yetconducted a disparity study, but the District may consider conducting a disparity studywithin the near future.ii.“Statistical disparities in the ability of DBEs to get the financing, bonding, and insurancerequired to participate in your program”DDOT has not performed a disparity study to determine the extent of the difficulty of DBEfirms to obtain bonding and insurance to participate in the DBE program.iii.Data on employment, self-employment, education, training and union apprenticeshipprograms” as it relates to the opportunities for DBEs to perform in DDOT’s DOT-assistedcontracts.DDOT reviewed, the employment data and found the data does not provide the agencywith a reliable way to adjust the goals.iv.Adjustments to the Goal for the Continuing Effects of Past DiscriminationAt this time, DDOT does not have data that would permit a reliable adjustment to the goalbased on the continuing effects of past discrimination.3.0Race/Gender-Neutral and Race/Gender-Conscious MeasuresDDOT will continue its efforts to meet the maximum feasible portion of its overall goal usingRace/Gender-Neutral (R/G-N) means. Historical contracting data for the period FY 2018-2020supports DDOT’s ability to achieve 21.84% with a race/gender/conscious goal of 20.27% and arace neutral goal of 1.57% DBE participation.Disadvantaged Business Enterprise Goal Methodology12FHWA FY2022-2024JULY 2021

Table 8DBE Participation in Excess of Goal for FY 2018-2020(Race-Neutral)Fiscal Year% of Total DBE Participation% Exceeded Overall Goal*FY 201813.64%(8.55)FY 201923.76%1.57%FY 202037.03%14.84%Historical Median1.57*FY19 Overall DBE Goal was 13.64%, FY20 Overall DBE Goal was 23.76%, FY21 Overall DBE Goal was 37.03%According to the Tips for DBE Goal Methodology, it is recommended that estimates of race neutralparticipation in the future be based on past experience with race neutral participation. The calculation isas follows: identify the median past performance, (8.55%), 1.57%, 14.84%). The median number isdetermined by the middle number, which according to Table 8 above is 1.57%.The data collected is then used to perform the following calculations:Median Past Participation (MPP) in excess of the goal: 1.57%Overall DBE Goal: 21.84%Race Neutral Goal: 1.57%Race Conscious Goal: 20.27%DDOT’s recent increase in race neutral achievements were the result of DDOT developing strategies andopportunities to increase participation of DBE Prime firms in federally funded projects with the Office ofContracting and Procurement and leadership in the Project Delivery Administration. In addition, DDOTcollaborated with DLSBD to conduct DBE Certification training for locally certified firms. Table 9 illustratesthat recent increase in race neutral participation.Table 9DBE Prime Contractor Awards for FY 2018-2020(Race-Neutral)Fiscal YearFY 2018FY 2019FY 2020Total Awards 90,909,929 54,738,641 35,300,536DBE Prime Contract Awards(Race Neutral) 0 0 4,440,534% Of TotalAwards0%012.57%DDOT has increased opportunities for DBE firms to serve as Primes on its projects. In October 2019, DDOTheld an Industry Day for the upcoming H Street Bridge Project with leadership teams from the Office ofContracting and Procurement, IPMD, and Civil Rights. The event facilitated new relationships betweenDDOT and members of the Contracting and Design Community, which included new DBE firms.While DDOT is working to increase DBE participation, there are still key concerns with the District ofColumbia’s changes to its risk management requirements for all vendors. These changes include carryingDisadvantaged Business Enterprise Goal Methodology13FHWA FY2022-2024JULY 2021

costly insurance to cover data breaches and enhancing the firm’s accounting systems to mitigate the riskto the Agency. We believe these requirements may be barriers for DBE firms seeking Prime opportunitieswith DDOT. Unfortunately, the requirements are unable to be revised at this time, however, our DBEteam will engage in further discussions with the Office of Risk Management to share the impedimentspresented to the firms that fall under the DBE and SBE programs and explore ways to eliminate thesebarriers.To this end, DDOT will maintain its ability to use Race/Gender-Conscious (R/G-C) measures, because it isour belief that when properly applied through a “narrowly tailored” program, R/G-C measures arenecessary to ensure equitable DBE participation and provide meaningful opportunities to DBE firmsseeking to evolve into prime contractors. With the submission of this report, the Agency understands thatit is at a pivotal stage in its DBE Program and is unwavering in its commitment to exceed the goals. Theagency is striving to achieve the highest levels of DBE p

*541511 Custom Computer Programming Services 541512 Computer Systems Design Services 541611 Administrative Management/General Management Consulting Services *541613 Marketing Consulting Services 541614 Process, Physical Distribution and Logistics Consulting Services 541618 Other Management Consulting Services