DBE Narrative Information & Congress’ Point of View

A couple updates for the DBE program. Reevaluation process is underway at all entities with a target date of December 5, 2025 to fill out the form and get your narrative completed. As a reminder, you must do your reevaluation process with the entity you are certified with.

The MnUCP agencies have been doing updates in various forums and this Friday (November 21, 2025) they are doing a joint session to help explain what is happening. The event will be held in person at MAC and can also be attended virtually. Event details are listed in this week’s issue of The Scoop.

Now for my two cents – the information that is being provided is muddy at best. Due to the DOT’s mandate that the entities can not assist in the narrative process to guide applicants or they could risk losing funding or not getting approved for their recertification process, there has been zero guidance on what would qualify as disadvantaged without using race or gender. We don’t know how the narratives will be reviewed and assessed by the certifiers.  As I have been saying all along, when there are no metrics or standardized ways to measure a subjective narrative, it is impossible to apply “qualifications equally” to everyone.

Additionally in a presentation given Wednesday there was contradicting statements made on how the PNW will be evaluated. While I blame the USDOT for creating this fiasco, with absolutely no authority I might add, the roll out in this hurried manner without guidance to DBEs has made it even more chaotic. Additionally, this timeline is during project closeout and season end for most of the small businesses that do DBE work. Finding the time to complete this in 3 weeks is one more way to disenfranchise small businesses.

A big update is that members of the congress sent a letter to Secretary Duffy at USDOT indicating that the DOT has no authority to have modified the program. You can view the full letter here. What this means is anyone’s guess. I am continuing to work with all our contacts in DC to understand what direction this will go. Please continue to reach out to your US Representatives telling them that the DBE program modifications will hurt the very businesses the program was intended to help.  The barrier that this will now create will cost small businesses millions of dollars. Not sure how to reach out to your elected officials? You can find them by putting your address into this website and reach out via phone or email.

 —B