1. The sum of the amounts computed in Step 9 will then be divided by the expected total cost of projects identified in Step 1 to determine an overall goal based strictly on availability of firms.
  2. The % determined in Step 10 will then be adjusted to reflect as accurately as possible the DBE participation that we would expect in the absence of discrimination. These adjustments will be based on past participation, a disparity study and/or any other available information concerning the relative opportunities for DBEs to form, grow and compete in our market area. This adjusted % will be established as the proposed overall DBE Goal for SMAA.

In establishing our overall goal, SMAA will solicit public participation in the process. We will consult with minority, women's and general contractor groups, community organizations, and other officials or organizations to obtain information concerning the availability of disadvantaged and non-disadvantaged businesses and the effects of discrimination on opportunities for DBEs.

We will publish notice of the proposed overall goal, informing the public that the proposed goal, the rationale used in its determination, and the entire DBE program are available for inspection during normal business hours at the SMAA offices located at SRQ. The inspection period will continue for 30 days following initial publication and comments on the program and goals will be accepted for 45 days following publication. Our notice will be published on the SRQ website and in minority focused media.

The submission of our DBE program and overall goal to FAA for review will include a summary of information and comments received, if any, during the public participation process as well as SMAA's responses thereto. We will begin using our overall goal on October 1 of the triennial reporting period, unless we have received other instructions from FAA.

Failure to meet overall goals

SMAA will maintain an approved DBE Program/Overall DBE Goal and administer our DBE Program in good faith. If awards and commitments shown on our Uniform Report of Awards or Commitments and Payments at the end of any fiscal year are less than the overall goal applicable to that fiscal year, we will:

  1. Analyze in detail the reasons for the difference between our overall goal and our awards and commitments in that fiscal year;
  2. Establish specific steps and milestones to correct any problems revealed by our analysis to improve participation for the ensuing fiscal year;

Breakout of Estimated Race-Neutral & Race-Conscious Participation

The overall goal will be divided into two components that comprise the total:

1. Race Neutral Component – The portion of the overall goal that SMAA expects to meet exclusive of contractually required DBE subcontracting goals established by the written terms of prime construction contracts. Among other means, this component may be met by: