Henry Chang

With regard to amending (a)(2)(ii) and (iii) to have PNW include ownership interests in the applicant firm, i.e. business assets, we oppose to the inclusion of such assets. The threshold was raised to account for inflaction, therefore it should not include the value of the applicant firm. To do so will make it difficult for individuals to qualify and defeat the purpose of raising the PNW threshold to $1.32 million. We do agree that only real estate assets of the applicant firm should be counted toward PNW. This is one area prone to abuse. However, the value of the firm itself has traditionally be excluded in counting toward PNW. We do not agree that the spouse of a non-participating spouse of an applicant owner should have to file a PNW statement. We would also like to reiterate our earlier position that DBE firm thresholds have been set much too high. Statutory gross receipt cap of $23.98 million is much higher than many non-DBE firms. Firms with such high gross receipt should not be able to be certified as DBEs. Assuming a profit margin of 10%, one year profit alone will exceed the PNW. A lower limit, such as $10 million for construction, and $4 million for architectural or engineering services are much more appropriate.