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The Certified Brief WBE · MBE · DBE · VOB · LGBTQ+ · SBE
April 2026 · 6 min read

They came for our certifications.
Here’s what we do now.

A field guide for AEC firms facing the new federal posture on diverse-firm participation.

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Editorial
Editorial · The Certified Brief

Analysis for the AEC front lines.

Policy, procurement reform, and the structure of the NY/NJ market. Written for principals, not policy wonks.

Issue 01 · The Certified Brief
▸ Editorial · April 2026

They Came for Our
Certifications.
Here's What
We Do Now.

A field guide for AEC firms facing the new federal posture on diverse-firm participation.

April 2026 Tomar Media Editorial Board 4 min read

On January 20, 2025, the Trump administration began systematically dismantling every federal program built to give certified AEC firms a fighting chance. Two executive orders in two days. The Minority Business Development Agency — 56 years old, $68 million annual budget — zeroed out. DBE certifications suspended. Federal agencies directed to set zero-percent participation goals.

This is the record. Not hyperbole.

In October 2025, the Department of Transportation issued an Interim Final Rule stripping the foundational presumption that had defined the DBE program for four decades. No longer could women or minority-owned businesses be presumed disadvantaged. Every owner must now submit a personal narrative — a written account of specific discrimination — and undergo individual reevaluation. As if the disparity studies in every major American city weren't proof enough.

We could spend this entire editorial in rage. And honestly, the rage is warranted. These programs existed because the construction industry, left entirely to its own devices, produced demonstrably inequitable outcomes for generations. The programs weren't charity. They were a correction.

"The rage is warranted. Hold it. And then get back to work."

— Tomar Media Editorial Board
But Here Is What They Could Not Touch

$22 billion. NYC's FY2024–2028 Capital Plan — moving through agencies governed by New York State law, not federal executive order. The Port Authority just raised its DBE goal to 27%. The Gateway Tunnel program — $16 billion in projected spend — still carries participation requirements being defended in active federal litigation. NJ's Infrastructure Resilience Bond is structured entirely outside federal contracting rules.

They changed the language in Washington. They did not stop the projects in Queens.

The Three Moves to Make Now
1 Do not abandon your federal DBE certification. Executive orders cannot unilaterally eliminate congressionally authorized programs. Adapt to the personal narrative requirement and maintain your standing in the NYS Unified Certification Program. Your cert travels across every state agency in New York.
2 Stack your certifications. WBE + MBE + DBE + SDVOB creates redundancy across funding streams. If one program is constrained, another is not.
3 Build prime relationships before you need them. The firms positioned well when federal policy normalizes are the ones who built those relationships during the disruption — not after it.

"We built businesses in a system that was never designed for us. A hostile federal posture is not new territory. We know how to move in this environment. We've always known."

— Tomar Media Editorial Board

The federal pullback is real. But New York and New Jersey remain among the most active infrastructure markets in the world. The capital plan is funded. The projects are moving. The certifications that matter most to the contracts you can actually win are still intact.

Know your programs. Know your channels. Build before you need it.

Tomar Media Editorial Board · tomarmedia.com · Serving WBE · MBE · DBE · VOB · LGBTQ+ firms in AEC · New York & New Jersey
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The Certified Brief · Editorial

They came for our certifications.
Here’s what we do now.

On January 20, 2025, the federal government began systematically dismantling every program built to give certified AEC firms a fighting chance. Two executive orders in two days. The Minority Business Development Agency — 56 years old, $68 million annual budget — zeroed out. DBE certifications suspended. Federal agencies directed to set zero-percent participation goals.

This is the record. Not hyperbole.

In October 2025, the Department of Transportation issued an Interim Final Rule stripping the foundational presumption that had defined the DBE program for four decades. No longer could women or minority-owned businesses be presumed disadvantaged. Every owner must now submit a personal narrative — a written account of specific discrimination — and undergo individual reevaluation. As if the disparity studies in every major American city weren’t proof enough.

We could spend this entire editorial in rage. And honestly, the rage is warranted. These programs existed because the construction industry, left entirely to its own devices, produced demonstrably inequitable outcomes for generations. The programs weren’t charity. They were a correction.

“The rage is warranted. Hold it. And then get back to work.”

— Tomar Media Editorial Board
But Here Is What They Could Not Touch

$22 billion. NYC’s FY2024–2028 Capital Plan — moving through agencies governed by New York State law, not federal executive order. The Port Authority just raised its DBE goal to 27%. The Gateway Tunnel program — $16 billion in projected spend — still carries participation requirements being defended in active federal litigation. NJ’s Infrastructure Resilience Bond is structured entirely outside federal contracting rules.

They changed the language in Washington. They did not stop the projects in Queens.

The Three Moves to Make Now
1Do not abandon your federal DBE certification. Executive orders cannot unilaterally eliminate congressionally authorized programs. Adapt to the personal narrative requirement and maintain your standing in the NYS Unified Certification Program. Your cert travels across every state agency in New York.
2Stack your certifications. WBE + MBE + DBE + SDVOB creates redundancy across funding streams. If one program is constrained, another is not.
3Build prime relationships before you need them. The firms positioned well when federal policy normalizes are the ones who built those relationships during the disruption — not after it.

“We built businesses in a system that was never designed for us. A hostile federal posture is not new territory. We know how to move in this environment. We’ve always known.”

— Tomar Media Editorial Board

The federal pullback is real. But New York and New Jersey remain among the most active infrastructure markets in the world. The capital plan is funded. The projects are moving. The certifications that matter most to the contracts you can actually win are still intact.

Know your programs. Know your channels. Build before you need it.

Tomar Media Editorial Board · tomarmedia.com · Serving WBE · MBE · DBE · VOB · LGBTQ+ firms in AEC · New York & New Jersey