It is important to note that DBE involvement only satisfies DBE goals if the DBE serves a commercially useful function. Generally, this means that the DBE must perform the whole of a task itself and the task must be necessary for the completion of the project. The specific rules vary by the task being performed, however.
As a DBE, you will not be considered to be performing a commercially useful function if you acts only as an extra participant in a transaction or project to provide the appearance of DBE participation. If you do not perform or exercise responsibility for at least 30 percent of the total cost of its contract with your own work force, or if you subcontract a greater portion of the work of a contract than would be expected on the basis of normal industry practice for the type of work involved, ADOT will presume that you are not performing a commercially useful function.
For you, as a DBE trucking company, to be deemed to be performing a commercially useful function, you must be responsible for the management and supervision of the entire trucking operation for which you are responsible on a particular contract. Further, you firm must own itself (i.e., you cannot be a subsidiary of another firm) and operate at least one truck, and you must use that truck each day on which it is earning credit toward the DBE goal.
If you are presumed not to be performing a commercially useful function as provided above, you may present evidence to rebut this presumption. Decisions on commercially useful function matters are subject to review by FHWA, but are not administratively appealable to U.S. DOT.
ADOT BECO staff and/or Construction Inspectors will visit construction work sites to conduct Commercially Useful Function reviews to ensure that this requirement is being met. Contractors and DBE firms must cooperate and participate in interviews by ADOT staff that will make every effort not to disrupt workflow on the project.
The LPA-CUF-Worksheet is available from BECO.
See this video from the FHWA for more information on what qualifies as a Commercially Useful Function.
For more information on good faith efforts, as well as information on what sort of work satisfies the commercially useful function requirement of DBE goals, read the Commercially Useful Function Checklist on the ADOT website.