6/4/2025
TO: HONORABLE MAYOR
AND CITY COUNCIL
FROM: Mukesh (Mookie) Patel
SUBJECT: See Below DATE: May 27, 2025
Approved
Date:
COUNCIL DISTRICT: Citywide
SUBJECT: Airport Disadvantaged Business Enterprise Goal Development for Grant Funded Airport Development Projects for Federal Fiscal Years 2026-2028
RECOMMENDATION
Adopt a resolution:
(a) Approving a proposed overall Disadvantaged Business Enterprise participation race-neutral goal of 3% for the Federal Aviation Administration’s Airport Improvement Program grant-funded Airport development projects at the San José Mineta International Airport for Federal Fiscal Years 2026-2028; (b) Authorizing the City Manager or her designee to submit the three-year Disadvantaged Business Enterprise participation plan to the Federal Aviation Administration, which is due by August 1, 2025; and
(c) Authorizing the City Manager or her designee to make revisions as requested by the Federal Aviation Administration.
SUMMARY AND O
UTCOME
Approval of the Disadvantaged Business Enterprise (DBE) participation plan and acceptance by the Federal Aviation Administration (FAA) will result in the City of San José being compliant with the DBE Program requirements, allowing the City to remain an eligible recipient of FAA financial assistance for the estimated $50,536,738 share of the estimated total $62,726,018 in Airport development projects for this plan period.
COUNCIL AGENDA: 6/17/25
FILE: 25-675
ITEM: 2.8
HONORABLE MAYOR AND CITY COUNCIL
May 27, 2025
Subject: Airport Disadvantaged Business Enterprise Goal Development for Grant Funded Airport Development Projects for Federal Fiscal Years 2026-2028
BACKGROUND
The United States Department of Transportation’s (USDOT) DBE Program provides a vehicle for increasing the participation of disadvantaged business enterprises in federally funded procurement projects. USDOT DBE regulations require state and local transportation agencies that receive USDOT financial assistance to establish goals for the participation of DBEs. Each USDOT-assisted state and local transportation agency is required to establish annual DBE goals and review the scopes of anticipated contracts throughout the year for compliance of their DBE program.
The main objectives of the DBE program are:
• To ensure nondiscrimination in the award and administration of USDOT-assisted contracts;
• To ensure that small, disadvantaged business enterprises can compete fairly for federally funded transportation-related projects;
• To ensure that the DBE program is narrowly tailored in accordance with applicable law;
• To ensure that only eligible firms participate as DBEs; and • To help remove barriers to the participation of DBEs in USDOT-assisted contracts.
ANALYSIS
Under FAA regulations, the City is required to submit an updated DBE participation plan that incorporates anticipated new opportunities, potential DBE participants, and a new percentage goal for DBE participation goal every three years. A copy of the draft DBE participation plan goal to be submitted to the FAA is attached to this memorandum. This plan goal will apply toward federal fiscal years (FFY) 2026-2028 (October 1, 2025 through September 30, 2028).
The San José Mineta International Airport (Airport) is planning for an estimated total of $62,726,018 in USDOT-assisted contracts between FFYs 2026-2028. Table 1 below provides a listing of the anticipated Department of Transportation-assisted contracts with amounts.
HONORABLE MAYOR AND CITY COUNCIL
May 27, 2025
Subject: Airport Disadvantaged Business Enterprise Goal Development for Grant Funded Airport Development Projects for Federal Fiscal Years 2026-2028
Table 1
PROJECT NAME/DESCRIPTION
ESTIMATED
TOTAL
PROJECT
COST
ESTIMATED
FAA
DOLLAR
SHARE
ESTIMATED
FAA % SHARE
New Taxiway Victor Phase 2
The New Taxiway V program replaces
Runway 11/29, determined to officially
close as part of the recommendations
from Airport’s RIM (Runway Incursion
Mitigation) study completed in 2021.
New Taxiway V will be a full-length
parallel TDG (Taxiway Design Group) III
taxiway adjacent to Taxiway W. The
New Taxiway V will implement airfield
safety recommendations from the RIM
study by allowing unrestricted TDG III
aircraft operations, addressing a
previous Modification of Standard for
the west side of the airfield for
insufficient Taxiway Object Free Area.
Additionally, the New Taxiway V will
eliminate Airport’s two published
hotspots for runway incursions
associated with former Runway 11/29
and address airfield geometry concerns
on the west side associated with direct
aircraft access from apron to runway.
Taxiway V Phase 2 project will include
construction of 2,200 linear feet of new
Portland Cement Concrete concrete
pavement and associated grading,
drainage improvements, and lighting
upgrade works. Project will also include
demolition of old asphalt taxiway
pavement.
$28,982,518 $23,357,011 80%
New Taxiway Victor Phase 3
The New Taxiway V program replaces
Runway 11/29, determined to officially
close as part of the recommendations
from Airports RIM study completed in
2021. New Taxiway V will be a full-
length parallel TDG III taxiway adjacent
$29,643,500 $23,889,697 80%
HONORABLE MAYOR AND CITY COUNCIL
May 27, 2025
Subject: Airport Disadvantaged Business Enterprise Goal Development for Grant Funded Airport Development Projects for Federal Fiscal Years 2026-2028
PROJECT NAME/DESCRIPTION
ESTIMATED
TOTAL
PROJECT
COST
ESTIMATED
FAA
DOLLAR
SHARE
ESTIMATED
FAA % SHARE
to Taxiway W. The New Taxiway V will
implement airfield safety
recommendations from the RIM study
by allowing unrestricted TDG III aircraft
operations, addressing a previous
Modification of Standard for the west
side of the airfield for insufficient
Taxiway Object Free Area . Additionally,
the New Taxiway V will eliminate
Airport’s two published hotspots for
runway incursions associated with
former Runway 11/29 and address
airfield geometry concerns on the west
side associated with direct aircraft
access from apron to runway.
Taxiway V Phase 3 project will include
construction of 1825 lineal feet of new
Portland Cement Concrete pavement
and associated grading, drainage
improvements and lighting upgrade
works. Project will also include
demolition of old asphalt taxiway
pavement.
Airside High Mast Lighting
This project includes the replacement of
the ramp high mast lighting at each
terminal to improve the aircraft ramp
lighting levels on the ramp, and along
Terminal A/A+ and B ramps, particularly
at the tail end of the aircraft. Current
lighting levels are inadequate, and the
intent is to implement lighting
improvements that conform as much as
possible to current FAA and Illuminating
Engineering Society recommendations.
$1,700,000 $1,370,030 80%
HONORABLE MAYOR AND CITY COUNCIL
May 27, 2025
Subject: Airport Disadvantaged Business Enterprise Goal Development for Grant Funded Airport Development Projects for Federal Fiscal Years 2026-2028
The Airport used the recommended FAA formula to determine an overall DBE participation goal for the Airport for FFYs 2026-2028. In determining this overall DBE participation goal, the Airport closely followed the USDOT’s DBE program regulations set forth in 49 Code of Federal Regulations Part 26 (49 CFR 26), including a two-step goal-setting methodology identified in 49 CFR Section 26.45.
To determine the overall DBE participation goal, the Airport was required to:
• Examine the types of projects the Airport anticipates for the plan period and the specific job functions needed for these projects (depending on the type of projects anticipated, the goals for one DBE plan period may not be comparable to the goals for different DBE plan period);
• Base requirements on the federal laws, regulations, and guidance set forth by the USDOT;
• Base goals on evidence of DBE firms that are ready, willing, and able; and • Narrowly tailor the goals to the evidence.
Step 1: Determination of a Base Figure (26.45)
To establish the Airport’s Base Figure of the relative availability of DBEs relative to all comparable firms (DBE and non-DBE) available to bid or submit proposals on the Airport FAA-assisted contracting opportunities projected to be solicited during the triennial goal period, the Airport followed the prescribed federal methodology to determine relative availability. This was accomplished by assessing the California Unified Certification Program DBE Database of Certified Firms and the 2024 U.S.
Census Bureau County Business Patterns Database Quarterly Census of Employment and Wages Database within the Airport’s market area (defined as Alameda and Santa Clara counties) for each of the categories of work defined in the below table.
PROJECT NAME/DESCRIPTION
ESTIMATED
TOTAL
PROJECT
COST
ESTIMATED
FAA
DOLLAR
SHARE
ESTIMATED
FAA % SHARE
Aircraft Rescue and Fire Fighting
Apparatus
This project includes the replacement of
an Aircraft Rescue and Fire Fighting
vehicle. The existing apparatus is 16
years old, and the Federal Aviation
Administration recommends
replacement after 15 years.
$2,400,000 $1,920,000 80%
Total $62,726,018 $50,536,738 80%
HONORABLE MAYOR AND CITY COUNCIL
May 27, 2025
Subject: Airport Disadvantaged Business Enterprise Goal Development for Grant Funded Airport Development Projects for Federal Fiscal Years 2026-2028
In accordance with the formula listed below, the Base Figure is derived by:
• Dividing the number of ready, willing, and able DBE firms identified for each North American Industrial Classification System (NAICS) work category by the number of all firms identified within the Airport’s market area for each corresponding work category (relative availability);
• W eighting the relative availability for each work category by the corresponding work category weight (weighted ratio); and
• Adding the weighted ratio together.
Base Figure = ∑
For the numerator: California Unified Certification Program DBE Database of Certified Firms
For the denominator: 2024 U.S. Census Bureau Quarterly Census of Employment and Wages Database
A concerted effort was made to ensure that the scope of businesses included in the numerator were as close as possible to the scope included in the denominator. The result of the Base Figure calculation is shown in Table 2 below:
Table 2
Table
2NAICS
Code Category of Work DBEs
ALL
Firms
Relative
Availability
237990 Other Heavy and Civil Engineering Construction 0 19 0.0% 238110 Poured Concrete Foundation and Structure
Contractors 1 168 0.6%
238210 Electrical Contractors and Other Wiring Installation Contractors 14 906 1.6%
238910 Site Preparation Contractors 7 161 4.4%
238990 All Other Specialty Trade Contractors 9 1,048 0.9% 541330 Engineering Services 15 144 10.4%
541620 Environmental Consulting Services 0 83 0.0%
562111 Solid Waste Collection 0 4 0.0%
Total 46 2,533 1.8%
The relative availability of DBEs from Table 2 is 1.9%. However, to make the base figure more accurate, the Airport used weighting to consider the amount of work that is available for each category of work (NAICS Code).
HONORABLE MAYOR AND CITY COUNCIL
May 27, 2025
Subject: Airport Disadvantaged Business Enterprise Goal Development for Grant Funded Airport Development Projects for Federal Fiscal Years 2026-2028
The weighted relative availability of DBEs, also known as the Base Figure, is calculated in Table 3 below.
Table 3
NAICS
Code Category of Work
Relative
Availabilit
y
Estimated
FAA % by
NAICS
Weighted
Ratio
237990 Other Heavy and Civil Engineering Construction 0.0% 34.9% 0.0% 238110 Poured Concrete Foundation and Structure
Contractors 0.6% 15.7% 0.1%
238210 Electrical Contractors and Other Wiring
Installation Contractors 1.5% 10.6% 0.2%
238910 Site Preparation Contractors 4.3% 6.1% 0.3%
238990 All Other Specialty Trade Contractors 0.9% 15.2% 0.1% 541330 Engineering Services 10.4% 0.4% 0.0%
541620 Environmental Consulting Services 0.0% 12.5% 0.0% 562111 Solid Waste Collection 0.0% 4.7% 0.0%
Total 0.7%
Step 2: Adjusting the Base Figure
Upon establishing the Base Figure, the Airport reviewed and assessed other known evidence potentially impacting the relative availability of DBEs within the market area in accordance with prescribed narrow tailoring provisions as set forth under 49 CFR Part
26.45: Step 2, DBE Goal Adjustment Guidelines.
Evidence considered in adjusting the Base Figure included Past DBE Goal Attainments, as shown in Table 4 below:
Table 4
FEDERAL FISCAL
YEAR (FFY)
FAA DBE
GOAL %
FAA DBE %
ATTAINMENT
FFY 2022 4.1% 5.3%
FFY 2023 5.0% 11.3%
FFY 2024 5.0% 0.6%
Median DBE Attainment Within
the Last 3 FFYs 5.3%
Table 5 below shows the adjusted base figure of 3% by averaging the Base Figure
0.7%, also known as the weighted relative availability of DBE firms, and the Median DBE achievement 5.3% as recommended by the FAA.
HONORABLE MAYOR AND CITY COUNCIL
May 27, 2025
Subject: Airport Disadvantaged Business Enterprise Goal Development for Grant Funded Airport Development Projects for Federal Fiscal Years 2026-2028
Table 5
Base Figure 0.7%
Median DBE Attainment 5.3%
Adjusted Base Figure (Average) 3.0%
The City proposes to meet the overall goal by using race-neutral methods for DBE and small business participation in accordance with 49 CFR 26.51(c).
The City estimates that in meeting its 3% overall DBE participation goal, it will obtain 100% from race-neutral participation and 0% through contract goals (race-conscious measures).
The City held a stakeholder meeting on May 27, 2025, to present this proposed goal to the community and to seek input about the availability of disadvantaged and non- disadvantaged businesses, the effects of discrimination on opportunities for DBEs, and the City’s efforts to establish a level playing field for the participation of DBEs.
Also, a notice of the proposed 3% overall goal was published on the City and Airport websites. The public was informed that the proposed goal and its methodology were available for inspection during normal business hours and that the City would accept written comments for 30 days following the date of the notice. A supplemental memo will provide a summary of information and written comments received by the close of the public comment period. The City’s final overall goal submission to the DOT will include a summary of information and comments received during this public participation process and the City’s responses.
POLICY ALTERNATIVE
Alternative: Do not submit a three-year DBE participation plan to the FAA.
Pros: None
Cons: Not submitting a three-year DBE plan to the FAA by the August 1, 2025 deadline would jeopardize the City’s eligibility to receive millions of dollars in federal Airport Improvement Program grants.
Reason for not recommending: Staff is confident that the proper methodology set forth in the DBE regulations of 49 CFR 26 was taken. The required two-step process considers the types of anticipated projects, the availability of DBE firms given the work codes involved, and the market factors, including participation rates and capacity.
HONORABLE MAYOR AND CITY COUNCIL
May 27, 2025
Subject: Airport Disadvantaged Business Enterprise Goal Development for Grant Funded Airport Development Projects for Federal Fiscal Years 2026-2028
EVALUATION AND FOLLOW-UP
This memorandum will not require any follow-up from staff.
COORDINATION
This memorandum has been coordinated with the City Attorney’s Office and the City Manager’s Budget Office.
PUBLIC OUTREACH
This memorandum will be posted on the City’s Council Agenda website for the June 17, 2025 City Council meeting.
The Airport held a stakeholder meeting on May 27, 2025, to present this DBE goal- setting process and to seek community input into the goal. This meeting allowed any stakeholders to see how the goal was formulated and ask questions or make comments. No comments were given so no adjustment to the goal figure of 3.0% is recommended.. The DBE goal-setting process was presented to the Airport Commission and the public at the May 12, 2025 meeting. The DBE Goal Notice was also posted to the FAA DBE Opportunities website and the Airport Minority Advisory Council website. The DBE goal has also been published on the City’s and Airport’s websites to inform the public that the proposed goal and its rationale were available for inspection during normal business hours and that the City accepted written comments on the proposed goal for 30 days following the date of the notice.
Once approved by the City, the goal will be posted to the San José Airport website.
COMMISSION RECOMMENDATION AND INPUT
No commission recommendation or input is associated with this action.
CEQA
Not a Project, File No. PP17-008, general procedure and policy making resulting in no changes to the physical environment.
HONORABLE MAYOR AND CITY COUNCIL
May 27, 2025
Subject: Airport Disadvantaged Business Enterprise Goal Development for Grant Funded Airport Development Projects for Federal Fiscal Years 2026-2028
PUBLIC SUBSIDY REPORTING
This item does not include a public subsidy as defined in section 53083 or 53083.1 of the California Government Code or the City’s Open Government Resolution.
/s/
Mukesh (Mookie) Patel, C.M.
Director of Aviation
For questions, please contact Magdelina Nodal, Senior Analyst, Civil Rights Liaison, Airport Department, at [email protected] or (408) 392-3673.
ATTACHMENT
Federal Aviation Administration Overall Disadvantage Business Enterprise Goal-Setting Methodology Fiscal Federal Years 2026-2028 Goal Period
Federal A
viation Administration (FAA)
Overall Disadvantaged Business Enterprise
(DBE)
Goal-Setting Methodology
Federal Fiscal Years (FFY) 2026-2028
Goal Period
Subm
itted in fulfillment of:
Title 49 Code of Federal Regulations Part 26
Attachment
San Jose International Airport FAA DBE Goal Methodology FFY 2026-FFY 2028
Table of Contents
I. INTRODUCTION ..................................................................................................... 3 II. BACKGROUND ...................................................................................................... 3 III. FAA-ASSISTED CONTRACTING PROGRAM FOR FFY 2026-2028 ..................... 3 Market Area .......................................................................................................... 3 Anticipated Projects .............................................................................................. 3 Subrecipients ........................................................................................................ 5 Categories of Work ............................................................................................... 5 IV. GOAL METHODOLOGY ......................................................................................... 7 A. Step 1: Determination of a Base Figure (26.45) ......................................... 7 B. Step 2: Adjusting the Base Figure ............................................................. 9 1) Past DBE Goal Attainments ................................................................. 9 2) Disparity Studies ................................................................................ 10 3) Other Available Evidence .................................................................. 11 V. PROPOSED OVERALL DBE GOAL ..................................................................... 11 VI. RACE-NEUTRAL IMPLEMENTATION MEASURES ............................................ 12 VII. PUBLIC PARTICIPATION AND FACILITATION ................................................... 14
San Jose International Airport FAA DBE Goal Methodology FFY 2026-FFY 2028
DBE GOAL METHODOLOGY
I. INTRODUCTION
The City of San Jose/Norman Y. Mineta San Jose International Airport (SJC) herein sets forth its Overall Disadvantaged Business Enterprise (DBE) Goal and corresponding federally prescribed goal-setting methodology for the three-year Federal Fiscal Year (FFY) goal period of 2026-2028 (October 1, 2025 through September 30, 2028), pursuant to Title 49 Code of Federal Regulations (CFR) Part 26 “Participation by Disadvantaged Business Enterprises in U.S. Department of Transportation Programs.” The purpose of the DBE goal -setting process is to level the playing field so that DBEs c an compete fairly for Department of Transportation- assisted contracts, however, the program must be narrowly tailored in accordance with applicable law.
II. BACKGROUND
SJC is a recipient of U.S. Department of Transportation (USDOT), Federal Aviation Administration (FAA), funding. As a condition of receiving this assistance, SJC signed an assurance that it will comply with FAA’s DBE requirements. In accordance with Title 49 CFR Part 26 provisions:
Participation by DBEs in USDOT Programs, SJC is required to develop and submit a Triennial Overall DBE Goal for its FAA-assisted projects.
SJC herein presents its Overall DBE Goal Methodology for FFY 2026-2028.
III. FAA-ASSISTED CONTRACTING PROGRAM FOR FFY 2026-2028 Market Area
The Federal DBE program requires agencies to implement the DBE program based on information from the relevant geographic market area—the area in which the agency spends the substantial majority of its contracting dollars.
The SJC local market for contracts consists of a geographic area that is:
• where a large majority of contracting dollars is expended, and • where a substantial number of contractors and subcontractors are located and available to submit bids or quotes.
The SJC bidder’s list was reviewed and analyzed to determine where SJC spends the substantial majority of its contracting dollars. The previously established market area of Alameda and Santa Clara counties remain the valid market area.
Anticipated Projects
SJC has five (4) FAA-assisted projects that are anticipated to be awarded during the triennial period and which were considered in preparing this goal methodology. The projects, which include construction and professional services contracting opportunities, are anticipated to be awarded during the triennial period and have potential subcontracting opportunities. These projects and their federal share are listed in Table 1.
San Jose International Airport FAA DBE Goal Methodology FFY 2026-FFY 2028
TABLE 1
(amounts subject to rounding differences)
PROJECT NAME/DESCRIPTION1
EST. TOTAL
PROJECT
COST 2
EST. FAA $
SHARE3
EST. FAA
% SHARE4
New Taxiway Victor Phase 2
The New Taxiway V program replaces Runway
11/29, determined to officially close as part of the
recommendation’s from SJC’s RIM study
completed in 2021. New Taxiway V will be a full
length parallel TDG III taxiway adjacent to
Taxiway W. The New Taxiway V will implement
airfield safety recommendations from the RIM
study by allowing unrestricted TDG III aircraft
operations, addressing a previous MOS for the
west side of the airfield for insufficient TOFA.
Additionally, the New Taxiway V will eliminate
SJC’s two published hotspots for runway
incursions associated with former Runway 11/29
and address airfield geometry concerns on the
west side associated with direct aircraft access
from apron to runway.
Taxiway V Phase 2 project will include
construction of 2200 LF of new PCC concrete
pavement and associated grading, drainage
improvements and lighting upgrade works. Project
will also include demolition of old asphalt taxiway
pavement.
$28,982,518 $23,357,011 80.00%
New Taxiway Victor Phase 3
The New Taxiway V program replaces Runway
11/29, determined to officially close as part of the
recommendation’s from SJC’s RIM study
completed in 2021. New Taxiway V will be a full
length parallel TDG III taxiway adjacent to
Taxiway W. The New Taxiway V will implement
airfield safety recommendations from the RIM
study by allowing unrestricted TDG III aircraft
operations, addressing a previous MOS for the
west side of the airfield for insufficient TOFA.
Additionally, the New Taxiway V will eliminate
SJC’s two published hotspots for runway
$29,643,500 $23,889,697 80.00%
1 The name and brief description of each project.
2 The total estimated cost of each project.
3 The estimated FAA dollar share for each project.
4 The estimated FAA percentage share for each project.
San Jose International Airport FAA DBE Goal Methodology FFY 2026-FFY 2028
PROJECT NAME/DESCRIPTION1
EST. TOTAL
PROJECT
COST 2
EST. FAA $
SHARE3
EST. FAA
% SHARE4
incursions associated with former Runway 11/29
and address airfield geometry concerns on the
west side associated with direct aircraft access
from apron to runway.
Taxiway V Phase 3 project will include
construction of 1825 LF of new PCC concrete
pavement and associated grading, drainage
improvements and lighting upgrade works. Project
will also include demolition of old asphalt taxiway
pavement.
Airside High Mast Lighting
This project includes the replacement of the ramp
high mast lighting at each terminal to improve the
aircraft ramp lighting levels on the ramp, and
along Terminal A/A+ and B ramps, particularly at
the tail end of the aircraft. Current lighting levels
are inadequate, and the intent is to implement
lighting improvements that conform as much as
possible to current FAA and IES
recommendations.
$1,700,000 $1,370,030 80.00%
ARFF Apparatus
This project includes the replacement of an
Aircraft Rescue and Fire Fighting (ARFF) vehicle.
The existing apparatus is 16 years old, and the
Federal Aviation Administration recommends
replacement after 15 years.
$2,400,000 $1,920,000 80.00%
Total $62,72,018 $50,536,738 80.00%
Subrecipients
SJC does not reallocate any FAA funds to subrecipients.
Categories of Work
SJC reviewed each project anticipated to be awarded in the triennial period and determined the applicable categories of work applicable for each project using North American Industry Classification System (NAICS) codes. The corresponding dollar values for each NAICS code for each project were summarized for purposes of weighting the categories of work based on the staff estimates. Table 2 provides a summary of the categories of work with estimated dollars for each.
San Jose International Airport FAA DBE Goal Methodology FFY 2026-FFY 2028
TABLE 2: Project NAICS Codes
(amounts subject to rounding differences)
PROJECT
NAME
EST. FAA $
SHARE5
NAICS
CODE6
NAICS TITLE7 EST. FAA $
SHARE
NAICS8
New Taxiway
Victor Phase 2
$23,357,011 237990 Other Heavy and Civil Engineering
Construction
$8,795,635
238110 Poured Concrete Foundation and Structure
Contractors
$3,950,000
238210 Electrical $2,162,873
238910 Site Preparation Contractors $1,550,500
541330 Engineering Services $3,650,679
541620 Environmental Consulting $100,000
562111 Solid Waste Collection $3,147,324
New Taxiway
Victor Phase 3
$23,889,697 237990 Other Heavy and Civil Engineering
Construction
$8,996,230
238110 Poured Concrete Foundation and Structure
Contractors
$4,040,084
238210 Electrical $2,212,200
238910 Site Preparation Contractors $1,585,862
541330 Engineering Services $3,733,938
541620 Environmental Consulting $102,280
562111 Solid Waste Collection $3,219,103
237990 Other Heavy and Civil Engineering
Construction
$8,996,230
238110 Poured Concrete Foundation and Structure
Contractors
$4,040,084
238210 Electrical $2,212,200
Airside High
Master Lighting
$1,370,030 238210 Electrical $1,020,030
541330 Engineering Services $350,000
ARFF
Apparatus
$1,920,000 922160 Fire and Rescue Service $1,920,000
Total $50,536,738
$50,536,738
Table 3 is a summary of each NAICS code and the total dollar values for each NAICS code based on projects listed in Table 2.
5 The estimated FAA dollar share for each project.
6 The category of work (NAICS) code for each project.
7 The category of work (NAICS) title.
8 The estimated FAA dollars for each NAICS code in each project.
San Jose International Airport FAA DBE Goal Methodology FFY 2026-FFY 2028
TABLE 3: NAICS Code Summary
(amounts subject to rounding differences)
NAICS
Code Category of Work NAICS
Dollars9
NAICS
Funding
Weight10
237990 Other Heavy and Civil Engineering
Construction
$17,791,865 35.21%
238110 Poured Concrete Foundation and Structure
Contractors
$7,990,084 15.81%
238210 Electrical $5,395,103 10.68%
238910 Site Preparation Contractors $3,136,362 6.21%
541330 Engineering Services $7,734,617 15.30%
541620 Environmental Consulting Services $202,280 0.40% 562111 Solid Waste Collection $6,366,427 12.60%
922160 Fire and Rescue $1,920,000 3.80%
237990 Other Heavy and Civil Engineering
Construction
$17,791,865 35.21%
238110 Poured Concrete Foundation and Structure
Contractors
$7,990,084 15.81%
238210 Electrical $5,395,103 10.68%
$50,536,738 100.0%
IV. GOAL METHODOLOGY
A. Step 1: Determination of a Base Figure (26.45)11
To establish the SJC Base Figure of the relative availability of DBEs relative to all comparable firms (DBE and Non -DBE) available to bid or submit proposals on SJC FAA-assisted contracting opportunities projected to be solicited during the triennial goal period, SJC followed the prescribed federal methodology to determine relative availability. This was accomplished by assessing the California Unified Certification Program (CUCP) DBE Database of Certified Firms and the 2024 U.S. Census Bureau Quarterly Census of Employment and Wages Database within the SJC market area (defined as Alameda and Santa Clara counties) for each of the categories of work defined in Table 2.
Base Figure = ∑
(Number of Ready, Willing and Able DBEs)
(Number of All Ready, Willing and Able Firms) x weighted ratio ð For the numerator: CUCP DBE Database of Certified Firms ð For the denominator: 2024 U.S. Census Bureau Quarterly Census of Employment and Wages Database
9 The total dollars for each category of work (NAICS) that are summed from the values in Table 2 . 10 The percentage of dollars for each category of work (NAICS) for all projects anticipated to be awarded. 11 26.45 represents Title 49 CFR Part 26 regulatory goal setting methodology reference.
San Jose International Airport FAA DBE Goal Methodology FFY 2026-FFY 2028
In accordance with the formula listed below, the Base Figure is derived by:
a. Relative Availability: dividing the number of ready, willing and able DBE firms identified for each NAICS work category by the number of all firms identified within the market are for each corresponding work category,
b. Weighted Relative Availability: weighting the relative availability of each work category by the corresponding work category weight from Table 2 (NAICS %) to determine the Weighted Ratio for each NAICS work category and adding the weighted ratio figures together.
A concerted effort was made to ensure that the scope of businesses included in the numerator was as close as possible to the scope included in the denominator.
The relative availability of DBEs is calculated in Table 4 below.
TABLE 4: DBE Relative Availability
(amounts subject to rounding differences)
NAIC
S
Code
Category of Work DBEs
12 ALL
Firms
13 Rel. Aval.14
237990 Other Heavy and Civil Engineering Construction 0 19 0.0% 238110 Poured Concrete Foundation and Structure Contractors 1 168 0.6% 238210 Electrical Contractors and Other Wiring Installation Contractors 14 906 1.6%
238910 Site Preparation Contractors 7 161 4.4%
238990 All Other Specialty Trade Contractors 9 1,048 0.9% 541330 Engineering Services 15 144 10.4%
541620 Environmental Consulting Services 0 83 0.0%
562111 Solid Waste Collection 0 4 0.0%
Total 46 2,533 1.8%
The relative availability of DBEs from Table 4 is 2.7%. However, to make the Base Figure more accurate, SJC used weighting to take into account the amount of work that is available for each category of work (NAICS).
The weighted relative availability of DBEs is calculated in Table 5 below.
12 The number of DBEs in the market area for each NAICS code from the CUCP DBE Database of Certified Firms . 13 The number of all firms (DBE and non-DBE) in the market area for each NAICS code from the 2024 U.S. Census Bureau Quarterly Census of Employment and Wages Database. 14 The number of DBEs divided by the number of all firms.
San Jose International Airport FAA DBE Goal Methodology FFY 2026-FFY 2028
TABLE 5: DBE Weighted Relative Availability
(amounts subject to rounding differences)
NAICS
Code Category of Work Rel. Aval.15 Estimated FAA
% by NAICS16
Weighted
Ratio17
237990 Other Heavy and Civil Engineering
Construction
0.0% 34.9% 0.0%
238110 Poured Concrete Foundation and Structure
Contractors
0.6% 15.7% 0.1%
238210 Electrical Contractors and Other Wiring
Installation Contractors
1.5% 10.6% 0.2%
238910 Site Preparation Contractors 4.3% 6.1% 0.3%
238990 All Other Specialty Trade Contractors 0.9% 15.2% 0.1% 541330 Engineering Services 10.4% 0.4% 0.0%
541620 Environmental Consulting Services 0.0% 12.5% 0.0% 562111 Solid Waste Collection 0.0% 4.7% 0.0%
Total
0.7%
B. Step 2: Adjusting the Base Figure
Upon establishing the Base Figure, SJC reviewed and assessed other known evidence potentially impacting the relative availability of DBEs within the market area, in accordance with prescribed narrow tailoring provisions as set forth under 49 CFR Part 26.45: Step 2, DBE Goal Adjustment Guidelines.
Evidence considered in adjusting the Base Figure included Past DBE Goal Attainments and Other Evidence, as follows:
1) Past DBE Goal Attainments
Historical DBE participation attainments provide demonstrable evidence of DBE availability and capacity to perform on SJC projects. The projects anticipated to be awarded during the triennial period are substantially similar to those awarded in the recent past. SJC proceeded to calculate past DBE participation attainments for the three (3 ) federal fiscal years, for which DBE attainment data is available. The table below reflects the demonstrated capacity of DBEs (measured by actual historical DBE participation attainments) on FAA-assisted contracts awarded by SJC within the last three (3) federal fiscal years.
15 From Table 4
16 From Table 3
17 The NAICS weight multiplied by the relative availability.
San Jose International Airport FAA DBE Goal Methodology FFY 2026-FFY 2028
TABLE 6: Past Participation
(amounts subject to rounding differences)
FEDEAL FISCAL
YEAR (FFY)
FAA DBE
GOAL %18
FAA DBE %
ATTAINMENT
FFY 2022 4.1% 5.3%
FFY 2023 5.0% 11.3%
FFY 2024 5.0% 0.6%
Median DBE Attainment Within the Last 3
FFYs 5.3%
The median established for the past three (3) federal fiscal years (5.3%) is lower than the Base Figure derived from Step 1 ( 0.8%); therefore, an adjustment to the Base Figure based on SJC past DBE goal attainments has been made. The adjustment is calculated in accordance with FAA guidance by averaging the Base Figure with the median DBE Past Attainment, as shown below.
TABLE 7: Adjusted Base Figure
(amounts subject to rounding differences)
Step 1 Base Figure19 0.7%
Median DBE Attainment20 5.3%
Adjusted Base Figure21 3.0%
2) Disparity Studies
SJC reviewed a number of recent Federal DBE Program -related disparity studies in California. Those studies reveal quantitative and qualitative evidence that minority- and women-owned businesses do not have the same access to financing, bonding, and insurance as non- Hispanic white male -owned businesses in California. Any barriers to obtaining financing, bonding, and insurance might affect opportunities for minorities and women to successfully form and operate construction and engineering businesses in SJC’s marketplace. Any barriers that minority- and women -owned businesses face in obtaining financing, bonding, and insurance would also place those businesses at a disadvantage in obtaining SJC FAA-funded prime contracts and subcontracts.
The 2017 San Francisco Bay Area Rapid Transit District (BART) Disparity Study 22, which
includes Alameda and Santa Clara counties, found statistically significant disparity across all categories of work, including architecture and engineering, construction, professional services, other services, and procurement.
18 The FAA DBE Goal percentage for each Federal Fiscal Year. 19 From Table 5.
20 From Table 6.
21 The average of the Base figure and the median DBE attainment [(0.7% + 5.3%) ÷ 2]. 22 https://www.bart.gov/sites/default/files/docs/VI.BART%20Final%20Report.Volume%20I.1.12.2017_0.pdf San Jose International Airport FAA DBE Goal Methodology FFY 2026-FFY 2028
The 2015 San Francisco Municipal Transportation Agency (SFMTA) Disadvantaged Business Enterprise Availability, Utilization and Disparity Study23 (2015 SFMTA Disparity Study) conducted quantitative and qualitative analyses of conditions in SFMTA’s local marketplace, (which includes Santa Clara and Alameda Counties) to examine whether barriers exist in the marketplace in the construction and engineering industries for minority- and women-owned businesses and whether such barriers affect the utilization and availability of these businesses for SFMTA contracting. The 2015 SFMTA Disparity Study’s quantitative analyses show barriers in the San Francisco Bay Area marketplace for minority - and woman -owned businesses in the areas of entry and advancement, business ownership, access to capital, and success of businesses.
The 2016 Caltrans FHWA Disparity Study
24 includes Santa Clara and Alameda counties
and demonstrates substantial disparities in the utilization of minority- and women-owned businesses in transportation-related construction and professional services contracting.
While these disparity studies demonstrate that disparity exists in federal contracting, no adjustments to the SJC base figure were made due to the result of any disparity studies. 3) Other Available Evidence
SJC is not in possession of other information that would have an impact on the DBE goal assessment and has not made an adjustment to the SJC base figure due to the result of other airport goals.
V. PROPOSED OVERALL DBE GOAL
Since the Ninth Circuit Court of Appeals decision regarding Western States Paving v. Washington State Department of Transportation, SJC has set race neutral goals. SJC will periodically re- evaluate its DBE Program to determine whether contract goals are necessary to achieve the overall goal. If after re -evaluation SJC believes a race -conscious program is necessary, as required by Western States, SJC will gather evidence to determine if discrimination in the transportation contracting industry is present. SJ C will make a determination at that time what type of evidence gathering is appropriate, based on DOT regulations and case law.
The Proposed Overall DBE Goal for FFY 2026-2028 for SJC FAA-assisted contracts is 3.0%.
SJC will continue to have a race-neutral DBE Program for FFY 2026-2028. SJC has been able to achieve DBE participation by using only race-neutral methods and will continue to use the existing race-neutral measures as listed below and will consider new measures in order to achieve even greater participation over the triennial period. SJC will carefully monitor participation during the course of the goal period. At the conclusion of each year during the goal period, SJC will re- evaluate the effectiveness of the race-neutral methods and determine if it is necessary to institute a race- conscious portion and contract specific goals. If, in the future, as a result of this re - evaluation, SJC decides to implement race- conscious means, SJC will submit a revised DBE Goal Methodology for FTA’s review and approval.
23 https://www.sfmta.com/sites/default/files/agendaitems/2016/4 -19- 16%20Item%2014%20Disparity%20Study%20-%20report.pdf
24 http://www.dot.ca.gov/obeo/docs/2016DisparityStudyReport.pdf San Jose International Airport FAA DBE Goal Methodology FFY 2026-FFY 2028
SJC has a race-neutral DBE Program and is not using race-conscious methods, including contract specific goals. SJC will use solely race-neutral methods, as shown below, to meet the overall DBE goal of 3.0% for FFY 2026-2028 in accordance with Title 49 CFR Part 26.51.
RACE-CONSCIOUS & RACE-NEUTRAL
PROJECTIONS
DBE Adjusted Base
Figure 3.0%
Race-Conscious
Component 0.0%
Race-Neutral Component 3.0%
VI. RACE-NEUTRAL IMPLEMENTATION MEASURES
SJC is currently implementing a number of race- and gender -neutral remedies. In order to outreach and promote the participation of DBEs and small businesses in the SJC FAA-assisted contracting program and to increase the effectiveness of these remedies, SJC plans to continue utilizing existing remedies and will continue to explore other options for consideration based on SJC success in meeting its overall DBE goals based on these efforts.
SJC will:
• Arrange contract solicitations, times for the presentation of bids, quantities, specifications, and delivery schedules in ways that facilitate and maximize DBE and other small business participation.
o SJC will encourage prime contractors to identify subcontracting work that DBEs may bid on.
o SJC will provide greater detail on the importance of the DBE program at pre- bid/proposal meetings.
o SJC will invite all DBEs in the market area that perform the type of work included in a solicitation to the pre-bid/proposal meeting.
o SJC will provide time before or after pre-bid/proposal meetings to allow for prime and subcontractor networking.
o SJC will disseminate bid opportunity information to Small, Minority, Women and other Business Organizations within the market area.
• SJC will offer instructions and clarification on bid specifications, procurement policy, procedures, and general bidding requirements. SJC will provide information on sub - contracting practices and bonding requirements and provide instructions and clarifica tion on job performance requirements.
o SJC will review solicitation language to provide an emphasis on the importance of the DBE program.
o SJC will utilize the California Unified Certification Program website to provide prospective bidders with a list of all DBEs in the market area that perform the type of work included in a solicitation:
http://www.dot.ca.gov/hq/bep/find_certified.htm
San Jose International Airport FAA DBE Goal Methodology FFY 2026-FFY 2028
• Maintain a file of successful bid documents from past procurements and permit potential participants to review and evaluate such documents.
o SJC will offer unsuccessful DBE bidders the opportunity for a debrief to help them understand areas in which they can improve their bid/proposal in the future. • Host and participate in workshops for the DBE and small business contracting community. o SJC will attend and participate in vendor fairs hosted by other public agencies in order to learn about best practices for DBE and small business inclusion on procurement. • As a supportive service to help develop and improve immediate and long- term business management, record keeping, and financial and accounting capability for DBEs and other small businesses, SJC will actively promote the small business conferences, programs, and support services offered by other agencies that have established DBE and other small business programs.
o SJC will refer DBEs and other small businesses to the local Small Business Development Centers, and other local government related entities for technical assistance and other business development services.
• SJC will advise its contracting community of the online directory of certified DBEs, found at the California Unified Certification Program website:
www.dot.ca.gov/hq/bep/find_certified.htm
• SJC will advise the contracting community of the available small businesses certified by the California Department of General Services (DGS):
http://www.dgs.ca.gov/pd/Programs/eprocure.aspx
• On a case-by-case basis and depending on the availability and capacity of small businesses to perform subcontract opportunities, the City will implement race- neutral Small Business Enterprise incentives on federally funded contracts.
Fostering Small Business Participation25
SJC has implemented several strategies to foster small business participation in its contracting process. These include the following:
• Conducting “How to do Business with SJC” and DBE workshops. • On larger prime contracts , encouraging the prime contractor to consider subcontracting opportunities of a size that small businesses, including DBEs, can reasonably perform, rather than self-performing all the work involved.
• Identifying alternative acquisition strategies and structuring procurements to facilitate the ability of consortia or joint ventures consisting of small businesses, including DBEs, to compete for and perform prime contracts.
• Ensuring that a reasonable number of prime contracts are of a size that small businesses, including DBEs, can reasonably perform.
• Provide outreach to current SJC contractors or past SJC contractors who may qualify for DBE- certification by encouraging them to seek and obtain DBE-certification.
25 See Title 49 CFR Part 26 Section 26.39 “Fostering Small Business Participation.” San Jose International Airport FAA DBE Goal Methodology FFY 2026-FFY 2028
VII. PUBLIC PARTICIPATION AND FACILITATION
In accordance with Public Participation Regulatory Requirements of Title 49 CFR Part 26, minority, women, small, and local business associations, and community organizations within the SJC market area were consulted and provided an opportunity to review the triennial goal analysis and provide input.
SJC posted a Public Notice to the airport’s website on April 24, 2025, publishing the SJC Draft Proposed FAA Overall DBE Goal-Setting Methodology for FFY 2026-2028 (See ATTACHMENT 1: Website Notification). The notice informed the public that the proposed goal and rationale were available for inspection at the SJC principal office during normal business hours and SJC would accept comments on the goal analysis for 30 days. This notice was also distributed to the following:
• Posted to FAA DBE Opportunities on April 24, 2025
• Posted to Airport Minority Advisory Council’s Events Page on April 24, 2025 • Presented to Airport Commission on May 12, 2025
• Sent to the Council Members, the San Jose Minority Business Development Agency, Airport Minority Advisory Council, Small Business Development Center - Hispanic Chamber (SBDCHC), and various Business & Ethnic Chambers.
SJC reached out to local minority, women, and community business organizations to provide them information on the SJC DBE program and specifically the Draft Proposed FAA Overall DBE Goal- Setting Methodology for FFY 2026 -2028. Each organization will be contacted and given an opportunity for a one- on-one meeting or to participate in a webinar. This notice also provided information about how to attend the Stakeholder meeting. ATTACHMENT 2: Consultative Process Summary includes SJC’s outreach efforts, and any comments received from the organizations.
SJC hosted a webinar on May 27, 2025 from 11:00 a.m. to 2:00 p.m. SJC provided the option to participate virtually in order to accommodate more participation from the public. Stakeholders were able to join via Microsoft Teams.
During this Stakeholder Meeting, a PowerPoint presentation was shown explaining the DBE program and the FFY 2026 -2028 Triennial DBE Goal Methodology. The following slides were presented at the Stakeholder Meeting.
San Jose International Airport FAA DBE Goal Methodology FFY 2026-FFY 2028
San Jose International Airport FAA DBE Goal Methodology FFY 2026-FFY 2028
San Jose International Airport FAA DBE Goal Methodology FFY 2026-FFY 2028
ATTACHMENT 1: Website Notification
San Jose International Airport FAA DBE Goal Methodology FFY 2026-FFY 2028
San Jose International Airport FAA DBE Goal Methodology FFY 2026-FFY 2028
ATTACHMENT 2: Consultative Process Summary
List of Minority/Trade Organizations
Company & Address Contact Info Notes Comments
Building & Construction
Trades Council
David Bini, Executive Director
[email protected];
408-265-7643
• Email notifications sent 5/7 No comments received.
Filipino American
Chamber of Commerce
of Silicon Valley
[email protected];
(408) 283-0833
• Email notifications sent 5/7 No comments received.
San Francisco Bay Area
Hispanic Chamber of
Commerce
[email protected];
(415) 572-3568
• Email notifications sent 5/7 No comments received.
Hispanic Chamber of
Commerce Silicon
Valley
Dennis King, Executive Director
[email protected];
Connie Madrigal, Office Manager-
Executive Assistant
[email protected];
[email protected];
(408) 248-4800
• Email notifications sent 5/7 No comments received.
Silicon Valley Minority
Business Consortium
Walter Wilson
[email protected];
Reginald Swilley
[email protected];
[email protected];
408-660-9171
• Email notifications sent 5/7 No comments received.
San Jose International Airport FAA DBE Goal Methodology FFY 2026-FFY 2028
Company & Address Contact Info Notes Comments
San Jose MBDA
Business Center
Tony Tang
[email protected];
[email protected];
408-998-8058 x134
• Email notifications sent 5/7 No comments received.
National Association of
Women Business
Owners Silicon Valley
[email protected];
[email protected]
(408) 657-7190
• Email notifications sent 5/7 No comments received.
Oakland African
American Chamber of
Commerce
Airport Plaza Building
[email protected];
510-268-1600
• Email notifications sent 5/7 No comments received.
Silicon Valley
Vietnamese American
Chamber of Commerce
[email protected];
408.673.7181
• Email notifications sent 5/7 No comments received.
The Silicon Valley Black
Chamber of Commerce
[email protected];
408-288-8806
• Email notifications sent 5/7 No comments received.
City of San Jose -
Capital of Silicon Valley
District l
Vice Mayor Chappie Jones, Chair
David Gomez, Chief of Staff
[email protected]
(408) 535-4901
• Email notifications sent 5/7 No comments received.
Korean American
Chamber of Commerce
of Silicon Valley
Ken Kim
[email protected]
(408) 781-8346
• Email notifications sent 5/7 No comments received.
San Jose International Airport FAA DBE Goal Methodology FFY 2026-FFY 2028
Company & Address Contact Info Notes Comments
Santa Clara County
Korean American
Chamber of Commerce
(408) 747-9894
[email protected]
• Email notifications sent 5/7 No comments received.
Rainbow Chamber of
Commerce
Bettie Owen
[email protected]
(916) 266-9630
• Email notifications sent 5/7 No comments received.
Silicon Valley Chinese
Technology & Business
Association
Helen Wang
[email protected]
• Email notifications sent 5/7 No comments received.
Vietnamese American
Chamber of Commerce
of Northern California
Nga Nguyen
[email protected]
408-676-9789
• Email notifications sent 5/7 No comments received.
Winchester Business
Association
Ken Kelly
[email protected]
(408) 823-8201
• Email notifications sent 5/7 No comments received.
Latino Business
Foundation
Jesus Flores
[email protected]
408.618.8599
• Email notifications sent 5/7 No comments received.
San Jose Chamber of
Commerce
Derrick Seaver
[email protected]
Kathryn Satcher, COO
[email protected]
(408) 291-5260
• Email notifications sent 5/7 No comments received.