DBE Program Goal for 2010
Battle Creek Transit’s ( BCT ) goal under the Disadvantaged Business Enterprise ( DBE ) Program for FY 2010 is the following:
4.5% of the Federal financial assistance BCT will expend in DOT-assisted contracts during the fiscal year beginning October 1, 2009, and ending September 30, 2010. (Exclusive of FTA funds to be used for the purchase of transit vehicles and other non-contractible costs).
The following is a summary of the method BCT used to calculate this goal:
Step 1:
Step 1 of the goal-setting process is the establishment of a Base Figure for the relative availability of DBE’s in the market area utilized by BCT. The base figure is established by determining the number of ready, willing and able DBE’s in the Calhoun County market from DBE directories provided to Battle Creek Transit by the Michigan Department of Transportation (MDOT) and the Southwestern Michigan Urban League. For FY 2010, this figure is 128.
Battle Creek Transit then used the Census Bureau’s County Business Patter (CBP) data base from 2006 to determine the number of all ready, willing and able businesses available in Calhoun County to perform work. For 2010, this figure is 2,874.
The number of potential DBE bidders determined in this analysis (128) is then divided by the total number of all potential bidders (2,874) in order to arrive at the relative availability of DBE’s in Battle Creek Transit’s market area, as expressed by a percentage. The results of this analysis are as follows:
| DBE's in Market Area | 128 | |||
| Base Figure = | Total Firms in Market Area | 2,874 | = 4.5% |
Step II:
Step II of the goal-setting process involves examining available evidence in Calhoun County in order to determine what adjustment, if any, is needed to the base figure in order to arrive at the overall, final goal.
What is the volume of work that DBE’s have performed for Battle Creek Transit in recent years?
From FY’s 2005 through 2009, Battle Creek Transit has been exempt from the requirements of having a DBE goal due to the "$250,000 threshold" rule. In each of these years, Battle Creek Transit did not award prime contacts in excess of $250,000 in FTA funds. As such, Battle Creek Transit was not required to develop a DBE goal. However, Battle Creek Transit did submit to the FTA documentation that it did not exceed the $250,000 threshold in each of these years.
Is there evidence from any disparity studies conducted anywhere within Battle Creek Transit’s purchasing area (Calhoun County) that would suggest that the base figure arrived at in Step 1 should be adjusted.
At the current time Battle Creek Transit does not have any data that would require an adjustment to the DBE goal expressed in Step 1. Therefore, the base figure of 4.5% in Step 1 will be used as Battle Creek Transit’s DBE goal for FY 2010.
Public Participation
BCT has published a notice of its proposed overall DBE goal in local newspapers and national trade journals. This notice informs the public that the proposed goal and its rationale are available for inspection during normal business hours at our office at 339 W. Michigan, 49017, for 30 days following the date of the notice. The notice further informs the public that Battle Creek Transit and the US Department of Transportation will accept comments on the goal for 45 days from the date of the notice.
BCT has also contacted minority and community organizations, churches and others who are expected to have information on the availability of disadvantaged businesses. This contact included an explanation of the US DOT Disadvantaged Business Enterprise program. All potential DBE’s are encouraged to contact the agencies throughout Michigan that have been designated to certify businesses under the Michigan Unified Certification Program for DBE’s.
As part of this annual goal submission, BCT will forward a summary of information and comments received during the public participation period, along with our responses, to the DOT within 30 days following the closing date for the submission of comments.
BCT will attempt to meet its DBE goal by using race-neutral means of facilitating DBE participation (i.e. Outreach and technical assistance to DBE’s when requested or required). The attainment of BCT’s goals for DBE purchases is dependent upon increasing the number of certified DBE vendors within BCT’s market area that can provide the products and services that BCT requires. There are a number of factors that affect BCT’s ability to meet its DBE goal. These are:
First, both new and previously certified DBE’s continue to certify under the language of the DBE revised program. Various reasons exist for the reluctance of previously certified DBE’s to now become certified under the new DBE Revised Program. One reason is that some DBE’s no longer qualify under the program’s new guidelines for gross sales or personal net worth. Other DBE’s have remarked that the certification requirements of the new program are too onerous or intrusive. The complexity of certification under the DBE Revised Program along with the fact that DBE certification is not a requirement to do business with BCT, has tended to suppress the certification of DBE’s who had been previously certified under the old DBE program. BCT will purchase goods and services from vendors who were previously DBE certified but have chosen not to certify under the current DBE guidelines. BCT will take advantage of the Michigan Unified Certification Program for Disadvantaged Business Enterprises in order to draw upon a greater number of certified DBE’s for goods and services that it procures on an annual basis. BCT further agrees to abide by the Michigan Unified Certification Program as administered by the US DOT.
Second, BCT used the vast majority of its DOT funds to help cover its annual operating budget. Prior years budget analysis’s have indicated that approximately only 15% of Battle Creek Transit’s operating budget offers contracting opportunities to DBE’s. The majority of BCT’s operating budget goes toward non-contractible expenses such as wages, fringe benefits, utilities, health care, etc. These are areas where the opportunity for DBE purchasing is nonexistent or (in the case of vehicles) is passed through to bus manufacturers.
Third, within Battle Creek Transit’s market area of Calhoun County, there are not very many DBE firms. In most cases, the DBE firms that do exist do not provide the types of goods or services that Battle Creek Transit is seeking. Within Calhoun County, the total number of businesses have decreased approximately 5% over the past few years. It is reasonable to assume that some of these businesses were DBE firms.
Operating Budget Analysis for FY 2010 DBE Goal
| BCT FY 2010 Operating Budget | $3,631,452 |
| Federal Operating Funding - (estimated for FY 2010) | $ 969,212 |
| Federal Funding as % of Operating Budget | 27% |
| Budgeted operating expenses | $3,631,452 |
| Less Non-Contractible expenses | |
| Wages | $1,711,844 |
| Fringe benefits | $1,012,887 |
| Utilities | $49,800 |
| Contracted Insurance | $178,922 |
| Travel/Meetings | $8,500 |
| Training | $3,000 |
| Dues/Subscriptions | $9,500 |
| Non-Contractible Total | $2,974,453 |
| Contractible Operating Expenses | $656,999 |
| Federal Funding as % of Operating Budget | 27% |
| Operating Budget Available for DBE Contracting Opportunities | $177,390 |
| DBE Goal | 4.5% |
| Dollar Expenditure Value of DBE Goal with DBE Firms | $7,983 |
Capital Budget Analysis for FY 2010 DBE Goal
Battle Creek Transit will be receiving $944,000 in Federal ARRA capital funds in FY 2010 for the purpose of making facility improvements, replacing support vehicles, and upgrading revenue vehicles and equipment. Of this total, approximately $542,000 or 57% will not offer contractible opportunities to DBE firms. Reasons for this include certain projects that will be procured under existing State contracts, other projects that there are no known minority vendors, and projects that will be of a proprietary nature. The remaining $402,000 will be used in calculating DBE contracting opportunities. Based upon a DBE goal of 4.5%, this would result in approximately $18,090 being spent with DBE firms. When added to the $7,983 from the operating budget analysis shown above, Battle Creek Transit’s anticipated total expenditure with DBE firms in FY 2010 should be approximately $26,073.
