Business Engagement and Compliance

DBE Disparity Study

The Arizona Department of Transportation operates the Federal Disadvantaged Business Enterprise (DBE) Program to assist disadvantaged business enterprises on contracts that use U.S. Department of Transportation (USDOT) funds. Every three years, ADOT must set an overall annual goal for participation of DBEs in those contracts and submit it to the appropriate funding agency. The goal is expressed as the percentage of contract dollars that will go to firms certified as DBEs.

Through federal Fiscal Year 2014, ADOT had an overall DBE goal of 7.76 percent for contracts using Federal Highway Administration (FHWA) funds. During the most recent reporting periods, ADOT has met this goal or has been close to meeting it.

Federal regulations in 49 CFR Part 26 and other USDOT guidance direct how an agency sets its overall DBE goal. ADOT selected Keen Independent Research (Keen Independent) to conduct Availability and Disparity studies. The information in the recently completed Availability Study indicated a preliminary overall annual goal of 9.38 percent for the next three federal fiscal years beginning Oct. 1, 2014. ADOT submitted this 9.38 percent preliminary overall DBE goal to FHWA on Sept. 30, 2014. This preliminary DBE goal was approved by FHWA in March 2015 pending resubmission of a final goal at the conclusion of the full Disparity Study.

2015 Disparity Study

The 2015 Disparity Study is now complete and available for review. It analyzes the utilization and availability of minority- and women-owned firms by race, ethnic and gender group to determine whether there are disparities in the past utilization of those firms in ADOT contracts. Keen Independent conducted disparity analyses for FHWA-, state-, FAA- and FTA-funded contracts. The Disparity Study also includes analysis of in-depth interviews with business owners, trade associations and others. Keen Independent included information in the Disparity Study for ADOT to use to develop overall DBE goals for FAA- and FTA-funded contracts and a refined goal for its FHWA-funded contracts.

In June, ADOT released a Draft Disparity Study and conducted a 45-day public comment period from June 8 to July 20. ADOT held public hearings in mid-July in four locations around the state on the Draft Disparity Study and Final Proposed Goal.

ADOT reviewed the conclusions of the Disparity Study along with all public comments received during the public comment period and proposed the following goals to the USDOT funding agencies in early August 2015:

Funding Agency

Federal Fiscal Timeframe

 DBE Goal

Overall Proposed
DBE Goal

Race Conscious %

Race Neutral %



















Note: Proposed goals are not final until approved by the individual agencies. ADOT's preliminary goals remain in affect until the newly proposed goals are approved. 

Civil RightsTitle VI of the Civil Rights Act of 1964, and the Americans with Disabilities Act (ADA)