Fred C. Cooper

Document ID: DOT-OST-2010-0118-0008
Document Type: Public Submission
Agency: Department Of Transportation
Received Date: May 18 2010, at 12:00 AM Eastern Daylight Time
Date Posted: May 19 2010, at 12:00 AM Eastern Standard Time
Comment Start Date: May 10 2010, at 12:00 AM Eastern Standard Time
Comment Due Date: July 9 2010, at 11:59 PM Eastern Standard Time
Tracking Number: 80af0130
View Document:

This is comment on Rule

Disadvantaged Business Enterprise: Program Improvements

View Comment

As a state certified DBE firm for the last 18 years, I endorse the proposed improvements to 49 CFR Part 26. I have experienced great frustration, time and expense to become certified in other states and the process has actually discouraged me from expanding the services of my company due to this process. The PNW "cap" should be adjusted to $1.31 million but there should still be limitations on excluding assets in retirement savings. Elimination of such assests can lead to abuse. I have found that not all states in which I am certified, and until recently even myself, understood that assests in IRAs and 401k plans are allowed to be adjusted for withdrawal expense and tax penalties.