1. General Aviation Airports
ABCs of the
DBE Program for
General Aviation Airports
Association of California Airports
South Lake Tahoe, California
September , 2012

2. Agenda
FAA’s expectations of General Aviation airports related to the DBE Program
How often your DBE Program should be updated
How your DBE Program should look
Construction and professional services reporting of DBE participation
Q&A

3. FAA’s Expectations § 26.21 Who must have a DBE program?
(a) If you are in one of these categories and let DOT-assisted contracts, you must have a DBE program meeting the requirements of this part:
(1) All FHWA recipients receiving funds…;
(2) FTA recipients receiving planning, capital and/or operating assistance… ; and,
(3) FAA recipients receiving grants for airport planning or development who will award prime contracts exceeding $250,000 in FAA funds in a Federal fiscal year.

4. DBE Program Updates
§ 26.21(b)(2) You do not have to submit regular updates of your DBE programs, as long as you remain in compliance. However, you must submit significant changes in the program for approval.
Significant changes could be:
New DBE Liaison Officer
Change from City-owned airport to an airport authority
Evidence showing race-conscious measures are overly-effective, or
Evidence showing race-neutral measures are not effective

5. Sample DBE Program/Plan
Includes all required components of an approvable DBE Plan:
Policy Statement
General Requirements
Administrative Requirements
Goals, Good Faith Efforts, and Counting
Certification Standards
Certification Procedures
Compliance and Enforcement
On FAA website by 9/21/2012
Or, request to

6. Reporting DBE Participation
§ 26.29   What prompt payment mechanisms must recipients have?
(e)(2) A contract clause providing that the prime contractor will not be reimbursed for work performed by subcontractors unless and until the prime contractor ensures that the subcontractors are promptly paid for the work they have performed.
Require primes to submit monthly reports of subcontractor or subconsultant participation
Track payments to all subcontractors and subconsultants, including DBEs
Annual report of DBE participation/achievement due August 1; form and instructions online

7. Other Items Small Business Element of the DBE Program
NPRM – Comments Wanted by November 5, 2012
Revisions to Personal Net Worth Form, Application, and Reporting Forms
Modifications to certification-related provisions
Modifications regarding good faith efforts, transit vehicle manufacturers, and counting of trucking companies
Mandatory Certification Training for those that Certify DBEs
Concessions Program Highlights
Conformance to Part 26

8. Questions?

9. Patricia Wright DBE and ACDBE Programs Compliance Specialist Western-Pacific & Central Regions FAA Office of Civil Rights