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ABCs of the
DBE Program for
General Aviation Airports
Association of California AirportsSouth Lake Tahoe, California
September 12 - 14, 2012
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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
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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.
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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
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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, email request to [email protected]
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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
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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
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Questions?
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Patricia Wright
DBE and ACDBE Programs Compliance Specialist
Western-Pacific & Central Regions
FAA Office of Civil Rights
310-725-3955
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