FISCAL YEARS 2013-2015

In keeping with the requirements of 49 C.F.R. Part 26 (Participation by Disadvantaged Business Enterprises in U.S. Department of Transportation (DOT) Programs), an overall Disadvantaged Business Enterprise (DBE) goal has been developed for DBE participation in DOT-assisted contracting by the City of Santa Rosa Transit Division during Fiscal Year 2013 through Fiscal Year 2015.  The City of Santa Rosa Transit Division receives funding from the Federal Transit Administration (FTA) of U.S. Department of Transportation.  The City of Santa Rosa Transit Division’s overall DBE goal for 2013-2015 is 6.6% of the federal financial assistance we will expend in FTA-assisted contracts, exclusive of FTA funds to be used for the purchase of transit vehicles.

This goal identifies the relative availability of DBEs based on evidence of ready, willing, and able DBEs in relationship to all comparable businesses which are known to be available to compete in the Transit Division’s FTA-assisted contracts.  The overall DBE goal reflects staff’s determination of the level of DBE participation which would be expected absent the effects of discrimination. 

Overall DBE Goal Methodology
FTA-assisted contracting for Fiscal Years 2013 - 2015 is expected to consist of four contracts, exclusive of contracts for purchase of transit vehicles, which are not subject to this goal-setting process[1].  Additional projects may be undertaken if additional revenue becomes available; the overall DBE goal will be adjusted if necessary.  The four anticipated contracts are listed in Table 1.

Table 1:  Anticipated FTA-assisted contracts for FY 2013-15 (excluding transit vehicle purchases)

 Project Total Contract

FTA share of

% of total
contract dollars
for FY 13-15

 Bus stop improvements

$ 146,250

$ 117,000


 Automatic Vehicle Location System

$ 1,617,656

$ 1,294,125


 Sonoma Access call center

$ 90,000

$ 72,000


 Sonoma Access web development

$ 40,000

$ 32,000



$ 1,893,906

$ 1,515,125


 A two-step process was used to establish the overall DBE goal, as described below.

Step 1:  Compute Base Figure

Per 49 CFR 26.45(c), a base figure was developed to determine the relative availability of DBEs to perform work on the four anticipated contracts.  The formula for calculating the relative availability of DBEs is as follows:

Base figure equals Ready, willing and able DBEs divided by All firms ready, willing and able (including DBEs and non-DBEs)

However, based on guidance from FTA and the U.S. DOT Office of Small and Disadvantaged Business Utilization, a weighted base figure was computed that takes into account the relative size of the anticipated contracts.  The formula used is as follows:

Weighted Base Figure = [(Project’s % of total contract dollars) * (Relative availability of DBEs)] + [(Project’s % of total contract dollars) * (Relative availability of DBEs)]…

The weighted base figure was developed by:

1)      Using the California Unified Certification Program Directory to identify the number of registered DBEs willing to perform work in the City of Santa Rosa’s market area[2] for each of the anticipated contracts, based on the NAICS (North American Industry Classification System) code(s) most relevant to each contract.  Data were collected in May 2012. 

2)      Using 2009 Countywide Business Patterns (CBP) data from the U.S. Census Bureau to identify the total number of businesses available in the City of Santa Rosa’s market area for work on each contract, based on the same NAICS codes. 

3)      Dividing the number of DBEs by the number of all businesses to determine the relative availability of DBES in the market area, for each contract (noted as “% DBE” in Table 2).

Table 2:  Relative Availability of DBEs for Anticipated Contracts

 Anticipated contract  NAICS

 All businesses
(Census CBP)


 % DBE
 Bus stop improvements 238110,




 Automated Vehicle Location System  54151




 Sonoma Access Call Center  56142




 Sonoma Access Web Design/Development  54151




4)      Computing a weighted base figure using the percent of the total contract dollars for each anticipated contract from Table 1, and the figure for relative availability of DBEs for each contract from Table 2:

Weighted Base Figure = (8%*28.8%) + (85%*4.8%) + (5%*3.3%) + (2%*4.8%)

Weighted Base Figure = 2.2% + 4.1% + .2% + .1%

Weighted Base Figure = 6.6%

Step 2:  Adjust Base Figure

Per 49 CFR 26.45(d), following calculation of a base figure, all available evidence must be examined to determine what adjustment, if any, is needed to the base figure in order to arrive at the overall DBE goal.  The primary form of evidence available is the past participation of DBEs in Transit Division contracting.  It is the judgment of the Transit Division that it is not possible to provide a rational basis for a numerical adjustment of the base figure based on past participation, due to the very different nature of the anticipated contracts, compared with past contracting (i.e., an anticipated emphasis on contracting related to implementation of automated vehicle location technologies and a “one call/one click” transportation information center).  However, past participation by DBEs in recent contracting is generally in line with the proposed base figure.

Thus, the available evidence and information did not provide a rational basis for a numerical adjustment to the base figure computed in Step 1.

Based on this analysis, the City of Santa Rosa Transit Division proposes an overall DBE goal of 6.6% of FTA funds that will be expended in FTA-assisted contracts in Fiscal Years 2013-2015, exclusive of funds to be used for the purchase of transit vehicles.

Use of Race-Neutral Methods and DBE Contract Goals

The U.S. DOT regulations require that race-neutral methods be used to the maximum extent feasible to achieve the DBE overall goal.  Race-neutral methods include making efforts to assure that bidding and contract requirements facilitate participation by DBEs and other small businesses; unbundling large contracts to make them more accessible to small businesses; encouraging prime contractors to subcontract portions of the work that they might otherwise perform themselves; and providing technical assistance, communications programs, and other support services to facilitate consideration of DBEs and other small businesses. 

Because of the emphasis placed on race-neutral methods, the City of Santa Rosa does not propose to set contract-specific DBE goals on FTA-assisted contracts to be awarded in Fiscal Year 2013 through Fiscal Year 2015.  Instead, the City will focus on developing race-neutral methods for facilitating DBE participation.  The City will advise prospective contractors of areas for possible subcontracting, and of the availability of ready, willing, and able subcontractors, including DBE firms, to perform such work.  The City will carefully monitor its progress during the course of the year and may establish contract-specific goals if race-neutral methods do not appear sufficient to achieve the overall DBE participation goals for Fiscal Year 2013 through Fiscal Year 2015.  It is anticipated that the DBE goal for FTA-assisted contracts will be achieved through race-neutral methods.

Public Participation in Setting Overall DBE Goal

This analysis was sent to minority, women’s, and general professional and trade organizations, and other officials and organizations which could be expected to have information concerning the availability of disadvantaged and non-disadvantaged businesses, the effects of discrimination on opportunities for DBEs, and the City’s efforts to establish a level playing field for the participation of DBEs.

Federal regulations require that the City publish a notice in general circulation media, local minority-focused media, and trade association publications announcing the City’s proposed overall DBE goal for Fiscal Year 2013 through Fiscal Year 2015 FTA-assisted contracts.  Such notice must inform the public that the proposed DBE goal and its rationale are available for inspection during normal business hours for a period of thirty (30) days following the date of the notice.  The City and FTA, as the City’s lead agency on behalf of the Department of Transportation, will accept comments on the proposed goal for forty-five (45) days from the date of notice.  These notices were published on June 1, 2012, or in the June 2012 issues of monthly publications.  Notices were published in the Santa Rosa Press Democrat, La Voz, and Passenger Transport.

Interested parties were encouraged to submit comments to: 
Brandalyn Tramel, DBE Liaison Officer
City of Santa Rosa
635 1st St., 2nd Floor
Santa Rosa, CA 95404

Federal Transit Administration, Region IX
Attention: Civil Rights Officer
201 Mission St., Suite 1650
San Francisco, CA 94105

The Santa Rosa City Council formally adopted the overall DBE goal in late July 24, 2012.


The City of Santa Rosa in accordance with regulations of the U.S. Department of Transportation (DOT), 49 CFR Part 26, hereby announces its Fiscal Years 2013, 2014 and 2015 goal of 6.6% for DBE participation on contracts assisted by the Federal Transit Administration (FTA). 

The proposed goal and its rationale are available for public review for the next 30 days during normal business hours from 8:30 a.m. to 4:30 p.m., Monday through Friday, at the Transit Operations Building offices at 45 Stony Point Road, Santa Rosa, CA, at the Transit Department offices in Santa Rosa City Hall at 100 Santa Rosa Avenue, Room 6, and on our web page at www.srcity.org/citybus.  Written comments will be accepted by the City of Santa Rosa and FTA for 45 days following publication of this notice.  The City’s Fiscal Year 2013-2015 goal may be adjusted by any comments received. 

Interested parties are encouraged to submit comments to: Jim Wright, DBE Liaison Officer, City of Santa Rosa, 635 1st St., 2nd Floor, Santa Rosa, CA 95404.  Comments may also be submitted to the Federal Transit Administration, Region IX, Attention: Civil Rights Officer, 201 Mission St., Suite 1650, San Francisco, CA 94105.

[1] DBE goals for Transit Vehicle Manufacturers (TVMs) are established through a separate FTA process.

[2] The City of Santa Rosa’s market area is defined as the nine counties of the Bay Area, including Alameda, Contra Costa, Marin, Napa, San Francisco, San Mateo, Santa Clara, Solano, and Sonom