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DBE Goal Methodology

The Ohio Department of Transportation has developed its Federal Fiscal Year 2020 through 2022 Triennial DBE Goals, which are required by the Code of Federal Regulation 49, Part 26. Through this process, ODOT established two separate DBE goal methodologies – one for contracts funded by Federal Highway and one for Federal Transit. This page has been established to share details of these methodologies.

ODOT hosted a series of public meetings around the state to invite comments on the methodologies from small and disadvantaged businesses and other business enterprises, public agencies, elected officials, and interested individuals. In June 2019, comments were accepted at these meetings and through this web page. ODOT incorporated comments in the final goal methodologies, and submitted the respective plans to the Federal Highway Administration and Federal Transit Administration on August 1, 2019. The goals went into effect beginning October 1, 2019.​​​​​​

For the Federal Highway goal document, see below. For the Federal Transit goal document, visit Civil Rights & Transit Compliance.

Introduction

The Ohio Department of Transportation (ODOT) hereby submits its overall goal for Federal Fiscal Years 2020-2022 to the Federal Highway Administration (FHWA). Included with this submission are a description of the methodology used to establish the goal, including the base figure and the evidence with which it was calculated; a summary listing of the relevant available evidence in ODOT’s jurisdiction and an explanation of why ODOT did not use that evidence to adjust the base figure; the projection of the portions of the overall goal ODOT expects to meet through race-neutral and race-conscious measures; and ODOT’s consultation process.

Overall Goal for FFY 2020-2022:
15.6% of all Federal-aid highway funds that ODOT will expend in FHWA-assisted contracts in FFY 2020-2022

Methodology

ODOT’s proposed goal is based on the Department’s review of the availability of DBE firms that are ready, willing, and able to participate on DOT-assisted contracts pursuant to 26 CFR 26.45(b). This proposed goal reflects the true level of expected DBE participation absent the effects of current and past discrimination.

The methodology utilized for setting ODOT’s Overall DBE Goal for Federal Fiscal Years 2020- 2022 is thoroughly outlined in the disparity study conducted on behalf of ODOT and released to the public on April 15, 2016. The goal setting methodology outlined in the disparity study follows the methodology that was proposed by FHWA in the Annual DBE Goal Setting Methodology training and in the U.S. Department of Transportation’s (USDOT) Tips for Goal- Setting in the Disadvantaged Business Enterprise (DBE) Program document. As specified in Section 26.45(c) of the DBE Regulations, the method used to calculate the relative availability of DBEs (base figure) of the goal setting process is a percentage figure calculated by dividing a number representing available DBEs by a number representing all available firms.

To continue narrowly tailoring the goal methodology, ODOT has implemented the suggestion of USDOT to weight the participation of DBE firms between construction and professional services. The weighting used is in proportion to the dollars spent within each industry. The data provided herein is narrowly tailored to the law and is defensible under this rule. The following is a summary of the statistical analysis:

Step 1

The disparity study team used ODOT’s contracting and vendor data to help determine the relevant geographic market area, which is the geographical area in which the agency spends the substantial majority of its contracting dollars and where the substantial majority of interested contractors and subcontractors that seek to do business with ODOT are located. The study team’s analysis showed that 93 percent of ODOT’s construction and construction- related professional services contracting dollars during the study period went to businesses located in Ohio, indicating that Ohio should be considered the relevant geographic market area for the study. ODOT therefore utilized Ohio as the relevant geographic market area for determining the DBE goal.

Establishing a base figure is the first step in calculating an overall goal for DBE participation in ODOT’s FHWA-funded transportation contracts. As a result of the availability study conducted as part of ODOT’s disparity study, potential DBEs—that is, minority- and women- owned businesses that are DBE-certified or appear that they could be DBE-certified based on their ownership and annual revenue limits described in 13 CFR Part 121 and 49 CFR Part 26— might be expected to receive 15.6 percent of ODOT’s FHWA-funded prime contract and subcontract dollars based on their availability for that work. Thus, ODOT is using 15.6 percent as the base figure for its overall DBE goal because it anticipates that the types, sizes, and locations of FHWA-funded contracts that the agency awards in the future will be similar to the FHWA-funded contracts that it awarded during the disparity study period (January 1, 2010 through December 31, 2014).

The below figure presents the construction and professional services components of the base figure for ODOT’s overall DBE goal. The availability estimates presented are based on the availability of potential DBEs for FHWA-funded prime contracts and subcontracts. The overall base figure reflects a weight of 0.95 for construction contracts and 0.05 for professional services contracts based on the volume of dollars of FHWA-funded contracts that ODOT awarded during the disparity study period.

Availability components of the base figure (based on availability of potential DBEs for FHWA-funded transportation contracts)

 

 

Potential DBEs


Availability Percentage


Construction


Professional
Services


Weighted
Average

Black American-owned

6.4%

6.1%

6.4%

Asian Pacific American-owned

0.7%

0.9%

0.7%

Subcontinent Asian American-

owned

0.1%

0.4%

0.1%

Hispanic American-owned

0.4%

8.9%

0.9%

Native American-owned

0.5%

0.8%

0.5%

White woman-owned

7.2%

5.0%

7.1%


Total potential DBEs


15.2%


22.1%


15.6%

Industry weight

95%

5%

 


Note:

  • Numbers rounded to nearest tenth of 1 percent and thus may not sum exactly to totals.
  • See Figures F-20, F-21, and F-22 in Appendix F of the 2015-16 Ohio Public Authorities Disparity Study for corresponding disparity study results tables.
  • “Potential DBEs” include minority‐ and women‐owned businesses that are DBE‐certified or appear that they could be DBE‐certified based on their ownership and annual revenue limits described in 13 CFR Part 121 and 49 CFR Part 26.

Step 2

For the second step of the goal setting process, federal DBE regulations require ODOT to examine all evidence available in its jurisdiction to determine what adjustment, if any, is needed to the base figure to arrive at an overall goal. If the evidence does not suggest an adjustment is necessary, then no adjustment shall be made. The regulations outline several types of evidence that an agency must consider when assessing whether to make a Step 2 adjustment to its base figure:

  • The current capacity of DBEs to perform work in the agency’s DOT-assisted contracting program, as measured by the volume of work DBEs have performed in recent years;
  • Evidence from disparity studies conducted anywhere within the agency’s jurisdiction, to the extent it is not already accounted for in the agency’s base figure;
  • If the agency’s base figure is the goal of another recipient, the agency must adjust it for differences in its local market and its contracting program (This does not apply here);
  • Statistical disparities in the ability of DBEs to get the financing, bonding and insurance required to participate in the agency’s program;
  • Data on employment, self-employment, education, training and union apprenticeship programs, to the extent it can be related to the opportunities for DBEs to perform in the agency’s program.

As part of conducting the disparity study, the study team completed an analysis of these types of evidence.

The current capacity of DBEs to perform work in ODOT’s DOT-assisted contracting program, as measured by the volume of work DBEs have performed in recent years.

USDOT’s “Tips for Goal-Setting in the Disadvantaged Business Enterprise (DBE) Program” document suggests that agencies should examine data on past DBE participation on their USDOT-funded contracts in recent years. USDOT further suggests that agencies should choose the median level of annual DBE participation for those years as the measure of past participation:

Your goal setting process will be more accurate if you use the median (instead of the average or mean) of your past participation to make your adjustment because the process of determining the median excludes all outlier (abnormally high or abnormally low) past participation percentages.1

The following figure illustrates past DBE participation. Median DBE participation on FHWA- funded contracts from FFYs 2014 through 2018 was 11.8 percent.

Past certified DBE participation on FHWA-funded contracts, FFY 2014-2018

FFY

DBE Attainment

Annual DBE Goal

Difference

2014

10.4%

8.9%

1.5%

2015

11.8%

8.9%

2.9%

2016

9.8%

8.9%

0.9%

2017

13.7%2

15.6%

-1.9%

2018

12.7%3

15.6%

-2.9%


The information about past DBE participation supports a downward adjustment to ODOT’s base figure. If ODOT elects to use the approach that USDOT outlined in “Tips for Goal- Setting” based on its Uniform Reports of DBE Awards/Commitments and Payments, the overall goal would be the average of the 15.6 percent base figure and the 11.8 percent median past DBE participation/goal attainment, yielding a potential overall DBE goal of 13.7 percent.

Evidence from disparity studies conducted anywhere within ODOT’s jurisdiction, to the extent it is not already accounted for in the base figure.

USDOT suggests that federal-aid recipients also examine evidence from disparity studies conducted within their jurisdictions when determining whether to make Step 2 adjustments to their base figures.

Ohio Turnpike and Infrastructure Commission Study: The study team also conducted a disparity study for the Ohio Turnpike and Infrastructure Commission (the Commission) that used the same study period as ODOT’s study and a relevant geographic market area of Northern Ohio. The Commission awards transportation-related construction and professional services contracts similar in scope to those that ODOT awards and does not apply race- and gender-conscious goals to those contracts.

The study team analyzed 882 construction contracts and 158 professional services contracts awarded by the Commission during the study period (January 1, 2010 through December 31, 2014). Minority- and woman-owned businesses exhibited substantial disparities for both construction and professional services contracts. ODOT has reviewed the results from the Commission’s disparity study as part of determining its overall DBE goal. ODOT realizes that the results of that study are tailored specifically to the Commission’s contracts and policies. Those contracts and policies are different in many important respects from those of ODOT.

City of Cincinnati Study: The City of Cincinnati commissioned a disparity study, completed in September 2015, to review the existing City procurement processes for construction, professional services, and supplies and service contracts. The study found statistically significant underutilization of African-American, Asian-American and Caucasian women-owned businesses for construction prime contracts and statistically significant underutilization of African-American, Hispanic-American, and Caucasian women-owned businesses for professional services prime contracts. As a result of this study, the City of Cincinnati recommended race- and gender-conscious remedies to address the identified disparities in the City of Cincinnati’s contracting.

ODOT reviewed the findings of the City of Cincinnati’s disparity study as a part of determining its overall goal. Overall, results of Cincinnati’s study were not adverse to ODOT’s disparity study in that there was a significant underutilization of African-American, Asian, and Hispanic firms. Contrary to ODOT’s disparity study results, however, was the finding of a significant underutilization of Caucasian women-owned businesses in Cincinnati’s contracting opportunities.

Statistical disparities in the ability of DBEs to get the financing, bonding and insurance required to participate in ODOT’s program.

The results of the disparity study revealed quantitative and qualitative evidence that minorities, women, and minority- and woman-owned businesses in Ohio do not have the same access to those business inputs as non-Hispanic white men and businesses owned by non- Hispanic white men. Any barriers to obtaining financing, bonding, and insurance might limit opportunities for minorities and women to successfully form and operate businesses in the Ohio transportation contracting marketplace. Any barriers that minority- and woman-owned businesses face in obtaining financing, bonding, and insurance would also place those businesses at a disadvantage in competing for ODOT’s FHWA-funded prime contracts and subcontracts. Thus, information from the disparity study about financing, bonding, and insurance supports an upward Step 2 adjustment to ODOT’s base figure.

Data on employment, self-employment, education, training and union apprenticeship programs, to the extent it can be related to the opportunities for DBEs to perform in ODOT’s program.

Results of the disparity study revealed that there are barriers that certain minority groups and women face related to human capital, financial capital, business ownership, and business success in the Ohio transportation contracting industry. Such barriers may decrease the availability of minority- and woman-owned businesses to obtain and perform the FHWA- funded contracts that ODOT awards, which supports an upward Step 2 adjustment to ODOT’s base figure.

Although it may not be possible to quantify the cumulative effects that barriers in human capital, financial capital, and business success may have on the availability of minority- and woman-owned businesses in the local contracting industry, the effects of barriers in business ownership can be quantified. As part of the disparity study conducted on behalf of ODOT, the study team used regression analyses to investigate whether race/ethnicity and gender are related to rates of business ownership among workers in the local contracting industry. The regression analyses allowed the study team to examine those relationships while statistically controlling for various race- and gender-neutral personal characteristics including education and age. Appendix D to the disparity study provides detailed results of the study team’s business ownership regression analyses.

The regression analyses revealed that, even after accounting for various race- and gender- neutral personal characteristics, being a woman was associated with a lower likelihood of owning construction and professional services businesses compared to being a man. Being a minority was not associated with a lower likelihood of owning construction and professional services businesses after statistically controlling for race- and gender-neutral factors. However, that result does not necessarily indicate that minorities have the same opportunities to own businesses in the local support services industry as non-Hispanic white men.

Potential step-2 adjustment considering disparities in the rates of business ownership

 

 

Industry and group

a.

Current availability

b.

Disparity index for business ownership

c.

Availability after initial adjustment*

d.

Availability after scaling to 100%

e.

Components of base figure**


Construction

 

 

 

 

 

(1) Black American

6.4%

n/a

6.4%

6.0%

 

(2) Asian Pacific American

0.7%

n/a

0.7%

0.7%

 

(3) Subcontinent Asian American

0.1%

n/a

0.1%

0.1%

 

(4) Hispanic

American

0.4%

n/a

0.4%

0.4%

 

(5) Native American

0.5%

n/a

0.5%

0.5%

 

(6) White woman

7.2%

55

13.1%

12.4%

 

(7) Potential DBEs

15.2%

n/a

21.2%

20.0%

18.9%

(8) All other businesses***

84.8%

n/a

84.8%

80.0%

 

(9) Total firms

100.0%

n/a

106.0%

100.0%

 


Professional Services

 

 

 

 

 

(10) Black American

6.1%

n/a

6.1%

5.7%

 

(11) Asian Pacific American

0.9%

n/a

0.9%

0.8%

 

(12) Subcontinent Asian American

0.4%

n/a

0.4%

0.4%

 

(13) Hispanic American

8.9%

n/a

8.9%

8.4%

 

(14) Native American

0.8%

n/a

0.8%

0.8%

 

(15) White woman

5.0%

44

11.4%

10.7%

 

(16) Potential DBEs

22.1%

n/a

28.5%

26.8%

1.4%

(17) All other businesses

77.9%

n/a

77.9%

73.2%

 

(18) Total firms

100.0%

n/a

106.4%

100.0%

 

(19) Total

15.6%

n/a

n/a

 

20.4%


Note:

  • Numbers rounded to nearest tenth of 1 percent and thus may not sum exactly to totals due to rounding.
  • * Initial adjustment is calculated as current availability divided by the disparity index.
  • ** Components of the base figure were calculated as the value after adjustment and scaling to 100 percent, multiplied by the percentage of total FHWA-funded contract dollars in each industry (construction = 0.95; professional services= 0.05).
  • *** All other businesses included majority-owned businesses and minority- and woman-owned businesses that were not potential DBEs.

Source: BBC Research & Consulting.

The study team analyzed the impact that barriers in business ownership would have on the base figure if women owned businesses at the same rate as comparable non-Hispanic white men. The results of that analysis—sometimes referred to as a but for analysis, because it estimates the availability of minority- and women-owned businesses but for the effects of race- and gender-based discrimination—are presented in the above figure. The analysis included the same contracts that the study team analyzed to determine the base figure (i.e., FHWA-funded construction and professional services prime contracts and subcontracts that ODOT awarded during the study period). The study team made but for adjustments to the availability of woman-owned businesses for construction and professional services and then combined those results in a dollar-weighted manner. The weights for each industry were based on the proportion of FHWA-funded contract dollars that ODOT awarded in each industry during the study period (i.e., a 0.95 weight for construction and a 0.05 weight for professional services). In that way, the study team determined a potential adjustment to ODOT’s base figure that attempted to account for race- and gender-based barriers in business ownership in the local contracting industry.

Information related to business ownership alone might lead ODOT to consider adjusting the base figure up to 20.4%.

There is quantitative evidence that certain groups of minority- and woman-owned businesses are less successful than businesses owned by non-Hispanic white men and face greater barriers in the marketplace, even after accounting for race- and gender-neutral factors.

There is also qualitative evidence of barriers to the success of minority- and woman-owned businesses. Some of that information suggests that discrimination based on race/ethnicity and gender adversely affects minority- and woman-owned businesses in the local contracting industry. Thus, information about the success of businesses also supports an upward step-2 adjustment to ODOT’s base figure.


1 Section III(A)(5)(a) in USDOT’s “Tips for Goal-Setting in the Disadvantaged Business Enterprise (DBE) Program.”
2 As revised in FFY 2017 Shortfall Analysis
3 As revised in FFY 2018 Shortfall Analysis

Adjustment Determination

Based on the findings in the disparity study, ODOT has elected to utilize the base figure of 15.6 percent and not make an adjustment to the base figure for the following reasons:

  • Past participation suggests that ODOT could make a Step 2 downward adjustment by averaging the base figure with past median DBE participation. However, available data reveals that a very small percentage of DBEs are awarded contracts. Thus, DBE capacity is greater than that reflected in the volume of work performed by a select few DBEs. The disparity study clearly indicated that there was a disparity in utilization of DBE firms caused by passive discrimination.
  • The results of the disparity study revealed that there are barriers that certain minority groups and women face related to human capital, financial capital, business ownership, and business success in the Ohio transportation contracting industry that would justify an upward adjustment to the DBE goal.
  • Taking both factors into consideration, they appear to offset or cancel each other out and compel ODOT to not make any Step 2 adjustments to the base figure of 15.6 percent for the FFY 2020-2022 overall DBE goal.

Projections of Race/Gender-neutral and Race/Gender-conscious Portions of the Overall Goal

ODOT will meet the maximum feasible portion of its overall goal by using race/gender-neutral measures. The breakout of race/gender-neutral (RN) and race/gender-conscious (RC) DBE participation for the last three Federal fiscal years is shown below:

 

FFY 2016

FFY 2017

FFY 2018

Race/Gender-conscious

6.54%

7.84%

8.43%

Race/Gender-neutral

3.23%

5.85%

4.26%

Total

9.77%

13.69%

12.69%


 

Race/gender-neutral efforts are derived by tracking DBE prime contracts awarded, DBE subcontracts awarded on contracts without goals, and DBE participation in excess of contract goals. The median race/gender-neutral participation for FFY 2016-2018 was 4.26%. (The median race/gender-neutral participation for FFY 2013-2015 was 2.8%.)

ODOT has determined that race/gender-conscious measures will again be necessary to ensure non-discrimination and a level playing field for DBEs in Ohio and to meet the overall goal of
15.6 percent.

The race/gender-conscious projection is calculated by the following formulas:


Relative RN Attainment =                  Median RN Attainment             
                                           Median Overall DBE Achievement

Absolute RN Attainment = Relative RN Attainment x Proposed Overall Goal

RC Projection = Proposed Overall Goal - Absolute RN Attainment


ODOT’s median race/gender-neutral attainment for FFY 2016-2018 was 4.26%, and its median total DBE attainment for this period was 12.69%.


Relative RN Attainment =    4.26%   =  33.57%
                          12.69%


ODOT’s proposed overall DBE goal for FFY 2020-2022 is 15.6%.


Absolute RN Attainment = 33.57% x 15.6% = 5.2%

RC Projection = 15.6% - 5.2% = 10.4%


Projections

ODOT projects that it will meet one-third of its overall goal by using race/gender-neutral measures, and it will meet the remainder by using race/gender-conscious measures.

 

FFY 2020-2022

Race/Gender-conscious

10.4%

Race/Gender-neutral

5.2%

Overall

15.6%

 

Consultation Process and Publication

Federal regulations require that in establishing an overall goal, agencies must consult with minority, women’s and general contractor groups, community organizations, and other officials or organizations which could be expected to have information concerning the availability of disadvantaged and non-disadvantaged businesses, the effects of discrimination on opportunities for DBEs, and the agency’s efforts to establish a level playing field for the participation of DBEs. The consultation must include a scheduled, direct, interactive exchange (e.g., a face-to-face meeting, video conference, teleconference) with as many interested stakeholders as possible focused on obtaining information relevant to the goal setting process, and it must occur before the date upon which the agency is required to submit its methodology to FHWA for review. The agency must document its consultation process in its goal submission.

Federal regulations also require that an agency publish a notice announcing its proposed overall goal before it submits its goal to FHWA. The notice must be posted on the agency’s official website and may be posted in any other sources (e.g., minority-focused media, trade association publications).

ODOT posted a notice on its website and accepted public comments via an online form. ODOT received two online comments. One commenter, a certified DBE consultant, stated, “I reviewed the methodology and have no major concerns at this time.” The other commenter, who posted anonymously, stated, “The handout from the 6/24 meeting in Columbus indicated 8.9% Hispanic American and 0.4% Subcontinent Asian American for Professional Services.
Those seem to be reversed. Are they correct?” (They are correct per the disparity study.)

Five public outreach meetings were held (see table below for details). Transcripts and copies of comments received are attached.

Date

Location

Registered

Attendance

Written comments received

June 24

Columbus

110

80

3

June 25

Cleveland

125

72

0

June 26

Toledo

43

34

0

June 27

Cincinnati

62

53

0

June 27

Dayton

29

30

0

 

Total

369

269

 

 

These meetings were promoted heavily (see table below).

Statewide DBE Goal Meeting Outreach

 

 

 

Publication Date

Media Outlet

Statewide NET Reach

 

 

 

Ohio Department of Transportation

June 14, 18, 21

Facebook

175,000 (each post)

June 22

LinkedIn

8,202

May 23, June 21

Email blast

9,264 each

 

 

 

Ohio MBE Newspaper (a statewide publication)

May 15, June 1

Print

2,000 each

May 20, June 23

Electronic distribution

10,000 subscribers

 

 

 

Radio One – 30 second radio ad

June 21-24

Central Ohio – Columbus

53,800

 

Facebook

90,521

June 20-25

Northeast Ohio –

134,000

 

Cleveland/Lorain

 

 

Facebook

220,000

June 21-26

Southwest Ohio –

43,400

 

Dayton/Cincinnati

 

 

Facebook

2,349

 

 

 

LaMega Spanish Media Outlet – 20 second radio ad

June 20-26

Northeast Ohio

22,000

June 20-26

Central Ohio

35,000

June 20-26

Southwest Ohio –

Dayton/Cincinnati

28,000

 

 

 

ACEC of Ohio

May 27

e-Newsletter

1,416

 

 

 

Ohio Contractors Association

June 3, 10, 17, 24

e-Newsletter

1,796 each

Total

1,213,400

 

Summary of public comments

Columbus

  • One commenter asked for a definition of ready, willing, and able.
  • One commenter asked how we how we establish project goals on professional service projects versus construction, as well as DBE developmental goals. In a later comment, a different commenter stated appreciation for developmental goals.
  • One commenter asked about ODOT’s plans related to SBE set-asides for construction management.
  • One commenter asked how the split between 95% for construction and 5% for professional services was derived.
  • One commenter asked about the process of accounting for firms that “graduate” and whether those firms could be eligible for DBE certification in the future. As a follow-up to that question, another commenter asked why it was rare that DBE firms graduate and if any assistance could be provided to graduated firms.
  • One commenter asked why there were no set-asides for DBEs.
  • One commenter asked if ODOT was preparing a new disparity study.
  • One commenter asked why ODOT consistently meets its Transit DBE goal (and why the same couldn’t be said for Highway). The commenter suggested there could be lessons learned from Transit that could be brought over to Highway.
  • One commenter asked about ODOT’s Supportive Services program—specifically, the availability of reimbursements to DBEs.
  • One commenter, a certified DBE consultant, asked if ODOT had a plan in place to meet its goal, and specified that Maryland has a 26% DBE goal.
  • One commenter mentioned that for construction project in southern Ohio, it is difficult to meet project DBE goals.
  • One commenter thought that ODOT was setting its race-conscious project goals too low. One commenter mentioned that the Illinois Tollway provides bid incentives for contractors who have exceeded the project goal and thought this could make a difference with ODOT’s previous goal shortfalls.

Cleveland

  • One commenter had a question about whether a white male could be certified as a DBE.
  • One commenter wanted to know what ODOT is doing to protect DBEs and brought up the idea of an ombudsman.
  • Two commenters discussed the idea of reciprocal certification with DBE and state/local certification programs.
  • One commenter, who owns a firm that provides transportation, was concerned that primes were not giving an opportunity to all DBE firms. This commenter also wanted to know if there was a system that would help firms understand who was receiving contracts.
  • One commenter stated that doing business with the government isn’t easy but it’s
  • worthwhile.
  • One commenter offered his services in developing a database of firms. Another commenter asked where to find out about where and for how much various certifications count.
  • One commenter asked for more mentor/protégé programs and stated that waiting 65 days to get paid is unjust. A commenter from a non-DBE consulting firm provided some advice regarding prompt payment.
  • One commenter asked for a definition of ready, willing, and able, and wanted to know if only prequalified firms were included. When ODOT mentioned that potential DBEs were included in the goal calculation, another commenter asked why ODOT couldn’t limit the goal calculation to only currently certified firms.
  • One commenter encouraged all businesses to prepare themselves financially.

Toledo

  • One commenter, a representative of a Minority Business Assistance Center, asked about the meaning of the word “race”. He later discussed opportunities for his center to work with ODOT.
  • One commenter, a DBE-certified firm in Michigan (but not Ohio), questioned why the goal was based only on ready, willing, and able businesses in Ohio. He later asked about how he could become DBE-certified in Ohio.
  • Another commenter asked about the difference between race-conscious and race-neutral.

Cincinnati

  • One commenter asked if the project goals set were aspirational or measured and held against performance.
  • One commenter asked if we consider for the overall goal and each project goal the location of the DBE and the willingness of the DBE to travel.
  • One commenter asked if ODOT was planning to award more SBE set-aside projects.
  • One commenter asked about what ODOT is doing to avoid an overconcentration of DBEs in any particular industry.
  • One commenter asked about what ODOT does if the DBE goal is not met on a particular project.
  • One commenter asked about declining work available for DBEs, especially in work types that are saturated, and that it would be useful to know where the opportunities were for DBEs.
  • One commenter asked for an update on the DBE developmental goal program.
  • One commenter stated that she received too many solicitations for DBE work in areas of the state where she did not work.
  • One commenter asked for an update on ODOT’s mentor-protégé program.

Dayton

  • One commenter asked why she hadn’t been placed with a mentor as a protégé. She wanted to know what ODOT was doing to make sure that people are going to get services and opportunities.
  • Another commenter asked when supportive services funds would be available this year. One commenter asked about SBE set-aside projects for professional services.
  • One commenter asked about whether ODOT captures DBE dollars spent beyond a project’s
  • DBE goal.
  • One commenter asked about why a firm would want to mentor a protégé.
  • One commenter asked about how goals are set on A plus B projects where time is incentivized.
  • One commenter asked about the availability of supportive services for back office work.
  • One commenter complimented ODOT’s training classes.
  • One commenter asked about certification reciprocity.

Consultation Process: In Summary

The vast majority of comments dealt with ODOT’s efforts to establish a level playing field for the participation of DBEs. No evidence was received that would lead ODOT to adjust its overall goal for 2020-2022.