2020 DBE Disparity Study

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.

ADOT 2020 Disparity Study Fact Sheet

ADOT Seeks Input on its Draft Disparity Study and Proposed Overall Triennial DBE Goals for FHWA, FTA and FAA-Funded Contracts

Webinars to be held in May

ADOT is required to set a new overall annual goal for participation of DBEs in its federally-funded contracts. ADOT will submit a new three-year overall DBE goal to FHWA this summer to go into effect on October 1, 2020.

The Arizona Department of Transportation is seeking public input on proposed goals for the percentage value of federal-aid contract dollars won by firms certified for its Disadvantaged Business Enterprise (DBE) Program.

Based on the study results, ADOT is proposing the following DBE goals:

Funding Agency

Federal Fiscal Years

Overall Proposed Goal

Race/Gender Conscious %
(Contract Goals)

Race/Gender Neutral %
(Small Business Programs and other Efforts)


2021- 2023





2022 - 2024





2022 - 2024




Companies that do business with ADOT and the public are encouraged to comment on the size of the proposed overall DBE goals, the methodology used to develop the proposed goals, the results of the Disparity Study, as well as their experiences competing for or working on ADOT projects. ADOT also seeks suggestions on how to improve contracting opportunities for DBEs and other small businesses, and recommendations on what ADOT and the transportation industry can do to enhance support of the Federal DBE Program. 

The public comment period runs from April 13, 2020 through June 12, 2020.  As part of the comment period, ADOT will be holding two Webinars as follows:

May 12, 2020
1:00 pm – 2:30 pm MST
Attendance via Webinar

(Ended: Presentation | Recording)

May 21, 2020
4:00 pm – 5:30 pm MST
Attendance via Webinar

(Ended: Presentation | Recording)

At any time during the public comment period, comments can be provided in the following ways:

  • During the webinars;
  • By calling the study telephone hotline at 602-730-0466;
  • Via email at [email protected]; and
  • Through regular mail to:

Keen Independent Research LLC
701 N. 1st St., 2nd Floor
Phoenix, AZ 85004

All public comments will be reviewed before preparing a final Disparity Study report.

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

Pursuant to Title VI of the Civil Rights Act of 1964 and the Americans with Disabilities Act (ADA), ADOT does not discriminate on the basis of race, color, national origin, age, sex or disability. Persons who require a reasonable accommodation based on language or disability should contact the BECO office at: (602) 712-7761 or at [email protected] Requests should be made as early as possible to ensure the State has an opportunity to address the accommodation.

De acuerdo con el título VI de la Ley de Derechos Civiles de 1964 y la Ley de Estadounidenses con Discapacidades (ADA por sus siglas en inglés), el Departamento de Transporte de Arizona (ADOT por sus siglas en inglés) no discrimina por raza, color, nacionalidad, edad, género o discapacidad.  Personas que requieren asistencia (dentro de lo razonable) ya sea por el idioma o por discapacidad deben ponerse en contacto BECO en (602) 712-7761 o en [email protected] Las solicitudes deben hacerse lo más pronto posible para asegurar que el equipo encargado del proyecto tenga la oportunidad de hacer los arreglos necesarios.

Informational video by Dave Keen, Principal, with Keen Independent Research who presents ADOT's 2020 Disparity Study Draft results and the proposed ADOT DBE Goal for FHWA based on the disparity study Keen Independent Research conducted.

Video Presentation: ADOT DBE Disparity Study Presentation - March 27, 2020

Frequently Asked Questions (FAQ's)

What is the Disparity Study Timeline?


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

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].