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2014 SANDAG Disparity Study for FTA-Funded Procurements
Pursuant to guidance from the United States Department of Transportation, approximately every five years SANDAG conducts an extensive review of its FTA contracting program to determine if there is a disparity between the number of women and minority-owned businesses within the geographic market area that are ready, willing, and able to provide goods and services, and the number of these businesses that are actually participating in FTA-funded SANDAG contracts. Further, this review includes analysis of procurements that did not have a Disadvantaged Business Enterprise (DBE) goal in order to determine if there are any indicators of discrimination against women- and minority-owned businesses. The results of the Disparity Study guide recommendations from staff regarding DBE goals at the agency level as well as the contract level on procurements using Federal Transit Administration (FTA) funding. A separate disparity study is prepared by the California Department of Transportation for procurements using Federal Highway Administration (FHWA) funding.
There is significant financial advantage for public agencies within a similar geographic area to work together as a consortium to conduct a disparity study. Broad data that is compiled about the market area that can then be utilized uniquely by each agency as it implements its own FTA DBE Program. SANDAG, North County Transit District, and Imperial County Transportation Commission formed a consortium to conduct this study with SANDAG as the lead agency. Each consortium agency received a customized Disparity Study report focused on its organization.
The Disparity Study began in May 2013 and reviewed data on all contracts that SANDAG awarded from January 31, 2008, through December 31, 2012. The study also extensively analyzed minority- and women-owned businesses across the relevant regions through public workshops, in-person interviews, telephone surveys, meetings with trade associations, written testimony, and business databases. The results of the Disparity Study can be accessed here: Disparity Study - Executive Summary and Disparity Study - Final Report.
Based upon the results of the Disparity Study, the following three changes to the SANDAG DBE Program applicable to FTA procurements became effective August 1, 2014:
- The SANDAG current Overall FTA DBE Triennial Goal of 6.5 percent was confirmed as an appropriate goal for the current Federal Fiscal Year (FFY) 2013 through FFY 2015 triennial goal period.
- The agency’s relevant geographic market area was modified to include Orange County and remove Imperial and Riverside Counties. The Federal DBE Program requires agencies to implement the program based on information from the relevant geographic market area - the area in which contractors are located that receive the substantial majority of the agency’s contract dollars. The SANDAG market area was previously defined as Imperial, Riverside, and San Diego Counties. Information collected regarding the number of contracts awarded during the Disparity Study, however, indicated that it would be appropriate for SANDAG to include Orange County in its local market area and remove Imperial and Riverside Counties when setting DBE contract goals.
- Asian-Pacific American-owned DBEs are now included along with all other DBE groups, as eligible for participating in DBE contract goals on FTA-funded projects. Although Asian-Pacific American DBEs did not show substantial disparities on contracts that did not include DBE contract goals, a single Asian-Pacific American-owned engineering firm (that was DBE certified during the study period, but was no longer DBE certified or minority-owned at the end of the study period due to its revenue growth) received 60 percent of the total dollars that were awarded to Asian-Pacific American DBEs during the study period. If this firm was treated according to its current majority-owned status, this DBE group would be considered underutilized. Due to this unique circumstance, Asian-Pacific American-owned DBEs will be included in contract goals.
The SANDAG Board of Directors accepted the Disadvantaged Business Enterprise (DBE) Disparity Study for Federal Transit Administration (FTA) funded projects to use in developing the FTA DBE Program Goal and Methodology for Federal Fiscal Year 2015 on July 25, 2014.
SANDAG did outreach to DBE firms, community organizations, minority and women business groups, and other stakeholders to notify them of the revisions to the implementation of the agency’s FTA DBE Program.
If you have any questions or comments regarding the Disparity Study, please contact:
Manager, Small Business Development
401 B Street, Suite 800
San Diego, CA 92101
Small Business Project Manager
401 B Street, Suite 800
San Diego, CA 92101