DBE Disparity Study

The Arizona Department of Transportation Disparity Study is analyzing whether there is a level playing field for minority- and women-owned firms when competing for transportation work in Arizona. The study team, led by Keen Independent Research, is assessing what ADOT might do to increase contract opportunities for minority- and women-owned firms and other small businesses. ADOT will also use results to set new overall goals for participation of disadvantage business enterprises (DBEs) in its federally-funded contracts.


Developing New Overall Goals for DBE Participation

Every three years, ADOT analyzes the availability of DBEs and other firms to perform its contracts.
The DBE Disparity Study will provide information for ADOT to adopt new overall DBE goals in 2020. ADOT currently has an overall goal of 9.55% for dollars of Federal Highway Administration-funded contracts going to DBEs.


The study team began work in February 2019. By March 2020, Keen Independent will publish a draft
report for public review. ADOT will also distribute its proposed overall DBE goals at that time.

The study team and ADOT will consider comments prior to preparing a final report and final DBE goals in May 2020. After Federal Highway Administration review, the new overall goal for FHWA-
funded contracts will go into effect starting October 1, 2020.

disparity study timeline

Frequently Asked Questions (FAQ's)

What is a disparity study?

A disparity study examines whether there are disparities between:

  • The percentage of dollars that minority- and women-owned businesses received on an agency's prime contracts and subcontracts during a particular time period (referred to as "utilization analysis"); and
  • The percentage of dollars that those firms might be expected to receive based on their availability to perform on the agency’s prime contracts and subcontracts (referred to as an “availability analysis”).

The comparison between the utilization of minority- and women-owned businesses on an agency's contracts and the availability of those businesses to perform that work is referred to as a "disparity analysis."

In addition to utilization, availability and disparity analyses, disparity studies examine quantitative and qualitative information about:

  • Marketplace conditions for minority- and women-owned businesses;
  • Contracting practices and business assistance programs that the agency currently has in place; and
  • Potential program measures

Why does ADOT conduct disparity studies?

This is the third disparity study conducted by ADOT. The first study was completed in 2009 as a result of a 2005 court decision by the Ninth Circuit Court of Appeals and subsequent U.S. Department of Transportation guidance that any use of DBE goals on transportation contracts must be based on the results of a disparity study or similar analysis.

What contracts will be examined in the study?

The study will include state- and federally-funded construction, professional services, construction materials supply and other transportation-related contracts awarded from October 2013 through September 2018. It will include contracts using ADOT or federal funds that were awarded by local public agencies.

Who is the team involved in completing the study?

Keen Independent Research LLC is an economic research firm specializing in disparity studies. It has staff throughout the country and is based in Phoenix. David Keen (Principal) is leading the study.

Keen Independent will be assisted by five subconsultants:

  • Keith Wiener of Holland & Knight, LLP (H&K) is preparing the legal framework for the study and examining other issues related to federal regulations and case law;
  • The survey team at Customer Research International (CRI) is responsible for the availability survey; and
  • Así Marketing Group, Gordley Group and Partners In Brainstorms (PIB) are conducting in-depth interviews with business owners and representatives of trade associations and other groups.

Is a DBE contract goal the same as ADOT’s overall DBE goal?

No. The overall DBE goal is the level of DBE participation on federally-funded contracts ADOT hopes to cumulatively achieve over the course of a year. DBE contract goals are one tool ADOT can use to reach its overall DBE goal. ADOT sets each contract goal based on the unique characteristics of a contract and availability of DBEs for that work.

Does ADOT set an overall DBE goal for its non-federally-funded contracts?

No. The Federal DBE Program only applies to contracts funded in whole or in part by U.S. Department of Transportation funds.

Will the study results be made public?

Yes, the draft report will be distributed for public comment, including being posted on this website. The final report will be posted after the study is completed. In spring 2020, ADOT will publish the draft Disparity Study report and its proposed overall DBE goals for public comment.

What can I do to be involved?

Anyone can provide input by attending a public meeting or providing written comments. For more information send an email to [email protected].