7b attach1

FY 2015 
DISADVANTAGED BUSINESS ENTERPRISE (DBE) 
AND 
AIRPORT CONCESSION DISADVANTAGED BUSINESS ENTERPRISE (ACDBE)
PROGRAM 
COMPLIANCE REVIEW REPORT OF THE 
PORT OF SEATTLE (PORT) 
SEATTLE-TACOMA INTERNATIONAL AIRPORT (SEA-TAC) 
SEATTLE, WA 

REPORT ISSUED: April 24, 2015 
PREPARED BY THE 
FEDERAL AVIATION ADMINISTRATION 
OFFICE OF CIVIL RIGHTS

U.S. Department of Transportation Federal Aviation Administration 
JURISDICTION AND AUTHORITIES 
The Federal Aviation Administration (FAA) Office of Civil Rights is authorized by the Secretary of the U.S. Department of Transportation
(DOT) to conduct civil rights compliance reviews. Reviews are undertaken to ensure compliance of applicants, recipients, and sub-recipients
with 49 CFR, Part 26 Participation by Disadvantaged Business Enterprises in Department of Transportation Financial Assistance Programs and
49 CFR, Part 23 Participation by Disadvantaged Business Enterprises in Airport Concessions, referenced in this report as Part 26 and Part 23,
respectively. Also, specific sections of the programs are referenced using the nomenclature (23.xx) and (26.xx) in this document. 
Part 26 requirements apply to recipients of DOT funds under certain programs including airport funds under 49 U.S.C. 47101 et seq. The
program is narrowly tailored under the law. It is designed to allow firms that meet certain eligibility standards to compete fairly, to remove
barriers to DBE firms seeking to participate in DOT-funded programs, to assist in developing firms that can compete in the marketplace
outside of the DBE program, and to provide flexibility to recipients of federal funds in creating opportunities for DBE firms. 
Part 23 requirements apply to airports that had received a grant for airport development at any time after January 1988 that was authorized
under Title 49 of the United States Code. The requirements under this part apply to those airports classified as primary airports by the
National Plan of Integrated Airport Systems (NPIAS). Part 23 is mandated by 49 U.S.C. 47107(e) and addresses the airport concessions
disadvantaged business enterprises (ACDBEs) at airports receiving funds under the Airport Improvement Program (AIP). The requirements of
this part became effective April 21, 2005 and have been revised several times. 
OBJECTIVES 
The purposes of Part 26 and Part 23 as stated in the regulations are: 
To ensure nondiscrimination in the award and administration of airport concessions and DOT-assisted contracts in the
Department's highway, transit, and airport financial assistance programs. 
To create a level playing field on which DBEs can compete fairly for DOT-assisted  contracts. 
To ensure that the Department's DBE program is narrowly tailored in accordance with applicable law. 
To ensure that only firms that fully meet this part's eligibility standards are permitted to participate as DBEs. 
To help remove barriers to the participation of DBEs in airport concessions and DOT-assisted contracts. 
To assist the development of firms that can compete successfully in the marketplace outside the DBE program. 
To provide appropriate flexibility to recipients of Federal financial assistance in establishing and providing opportunities for DBEs. 

FAA FY-2015 Compliance Review Report                                                   Page 2 of 22

SCOPE OF REVIEW 
This review process is a high level examination of Seattle-Tacoma International Airport (SEA-TAC) and the Port of Seattle (PORT) compliance
with Parts 26 and 23. Unlike a comprehensive audit where testing and extensive examination of records ar e normal procedures, this
compliance review is designed to maximize available resources in assessing an organization's general understanding and implementation of
procedures to meet requirements. Some areas may be more heavily scrutinized than others based on review finding of other recipients,
recently released guidance or final rules, or reports that FAA may have received about a specific sponsor's compliance. 
To maximize the effectiveness of this review, FAA has identified regulatory requirements prior to the review that have higher priorities in the
review process. The review also compared the actual implementation of the Part 26 and Part 23 requirements with the written descriptions
found in the DBE and ACDBE programs and reviewed contract files, internal documents, and information from contractors and
subcontractors.  Interviews were conducted with sponsor officials.  Three focus group sessions were held with prime contractors,
subcontractors, prime concessionaires, ACDBE firms, and other relevant personnel. 
REVIEW PROCESS 
The review process began with a desk review of the airport's DBE and ACDBE Programs. This review focused only on the operations of the
Seattle-Tacoma InternationalAirport.  We sent a letter to SEA-TAC and the PORT on January 21, 2015, notifying it of the planned on-site
review. In the notification letter we requested that the airport send us certain information and respond to questions. 
Documents reviewed to verify compliance of requirements under 49 CFR Part 26: 
A. Airport organization chart, showing DBELO's position. 
B.  Records documenting monitoring of contracts with DBE participation. 
C.  Sample forms used to monitor monthly DBE participation. 
D.  Site visits record. 
E.  Sea-Tac's approved DBE Triennial Goal. 
F.  Copy of DBE accomplishment reports for the most recent three years. 
G.  List of all active FAA funded projects. 
H.  List of active FAA funded projects that have DBE participation, identifying DBE goal and actual contract percentage achieved to date. 
I.   Sample of an FAA funded contract. 
J.   Sample of a contract that includes a DBE goal requirement. 


FAA FY-2015 Compliance Review Report                                                   Page 3 of 22

Documents reviewed to verify compliance of requirements under 49 CFR Part 23: 
A.  Sea-Tac's organization chart, showing ACDBELO's position. 
B.  Records documenting monitoring of contracts with ACDBE participation. 
C.  Sample forms used to monitor monthly ACDBE participation. 
D. Records documenting site visits to concessions locations. 
E. Copy of your approved ACDBE Triennial Goal. 
F.  Copy of accomplishment reports for the most recent three years. 
G.  List of all active concession contracts. 
H.  List of all active concession contracts that have ACDBE participation, identifying ACDBE goal and actual contract percentage achieved to date. 
I.  Copy of the top three revenue generating concession contracts. 
J.  Complete listing of all concession contracts including start date, end date, possible contract extensions, and total potential term including
possible extensions. 
According to FAA AIP grant history, in the most recent three years, the FAA awarded SEA-TAC three (3) Airport Improvement Program (AIP)
grants for the planning and development of public-use airports that are included in the NPIAS. This review focused on active FAA funded
projects funded the by following grants: 
FY-2015
Noise Insulation Project                  $ 11,664,739.00 
FY-2014 
Noise Insulation Project                  $ 6,538,453.00 
FY-2013 
EGSE Infrastructure (VALE)                $ 7,725,000.00 




FAA FY-2015 Compliance Review Report                                                   Page 4 of 22

A site visit has been conducted, as noted below: 

Review Conducted  Ricky Watson, ACR-4; Keturah Pristell, ACR-4;        Site Visit Date(s):    March 24-25, 2015 
By FAA Staff:       and Supriya Raman, ACR-3 
SEA-TAC:       Mark Reis, Managing Director Aviation Division; James R. Schone, Director, Aviation Business
Development; Deanna Zachrisson, Business Leader, Airport Dining & Retail / ACDBELO; Castina Ridge,
Concessions Program Manager Business Development; 
Port of Seattle:     Luis Navarro, Director, Office of Social Responsibility; Mian Rice, Manager/DBELO, Small Business Program
& Policy ; Tina Boyd, Small Business Analyst, Small Business Program & Policy 

DESCRIPTION / HISTORY OF THE SEATTLE-TACOMA INTERNATIONAL AIRPORT (Sea-Tac): 
The Seattle-Tacoma International Airport (Sea-Tac) is owned and operated by the Port of Seattle. Sea-Tac is the largest airport in the Pacific
Northwest region of North America and the nation's 15th busiest airport. The airport is located in the eponymous city of SeaTac,
Washington, approximately twelve miles south of downtown Seattle, and is the primary airport for the Seattle metropolitan area. The
airport has flights to cities throughout North America, Europe, the Middle East, and Asia. It is the main hub for Alaska Airlines and its
regional subsidiary Horizon Air, whose headquarters are near the airport. It is a Large Hub airport and an international gateway to Asia and
Europe. In 2014 the airport served over 37 million passengers, and it continues to rapidly grow. This is evident in part by the recent Sea-Tac
concessions program total gross receipts averaging a year over year increase of 7.5-12% which is 5-10 points higher than the national
average 
Seattle's Seaport and Airport generate nearly 200,000 jobs throughout the region with payroll in excess of $6.8 billion. Five commissioners,
elected at large by the voters of King County, Washington, serve four-year terms and establish Port of Seattle policy. The chief executive
officer, in carrying out these policies, leads 1,700 employees in five divisions. 


FAA FY-2015 Compliance Review Report                                                   Page 5 of 22


FINDINGS: PORT OF SEATTLE - Title 49 CFR Part 26  AIRPORT CONSTRUCTION 
PART 1 DBE Program Questions: 
Administrative Requirements 
Action
Compliance
#            QUESTION/REGULATION REFERENCE            Response               FINDINGS / RECOMMENED CORRECTIVE ACTION (If Any)                          Due 
Issue 
Date 
1 Do you have an FAA approved DBE Program in place? (   YES   The Port of Seattle (PORT) 2012 DBE Program was approved by the FAA on June    NO    N/A 
26.21(b))                                       15, 2012. The DBE program is made available for public review by accessing the
Port of Seattle's website at
http://www.portseattle.org/About/Organization/Pages/Small_Business.aspx 
2                                                    The DBE policy statement was disseminated to the Port of Seattle and to trade
Did you sign and disseminate your DBE Policy          YES                                                       W     NO    6/10/15 
Statement? ( 26.23)                                organizations. Also, it was distributed to DBE and non-DBE business communities
that perform work for the Port of Seattle on DOT assisted contracts.
Recommended Enhancement: 
It is recommended that the PORT's newly appointed Chief Executive Officer, Ted
Fick review, sign, and re-distribute the PORT's current DBE Program.
3 
Does your DBE Liaison Officer have independent        YES    Mian Rice, Manager, Small Business Program & Policy, serves as the Liaison       NO     N/A 
program implementation authority and independent          Officer for the DBE Program. Mr. Rice has direct, independent access to Ted Fick,
(direct) access to the Airport Director/CEO? ( 26.25)            Chief Executive Officer, Sea-Tac.
4                                                    The PORT has reviewed the availability of DBE financial institutions, as part of the
Do you make reasonable efforts to use DBE financial      NO                                                            NO     N/A 
institutions as well as encourage prime contractors on          process in updating their DBE Program. The PORT did not find any financial
DOT assisted contracts to make use of DBE financial            institutions in their market area or within the State of Washington; however, the
institutions? ( 26.27)                                  PORT will continue to assess the market periodically. 
5                                                    The PORT's Office of Small Business Program & Policy conducts monthly outreach
Do you conduct regular outreach sessions to ensure the    YES                                                            NO     N/A 
inclusion of DBE firms in your DBE program? ( 26.51)           events in its market area. 
6  Has your Small Business element been implemented? (    YES    The PORT has developed its Small Business Program Element (SBPE) in accordance   NO      N/A 
26.39)                                           with 49 CFR Section 26.39. To date the PORT has not utilized its SBPE on any
federally funded projects. 
Recommended Enhancement: In order to possibly increase the DBE participation
on federally funded projects in a race neutral environment, the PORT should
consider using its small business program element. 
FAA FY-2015 Compliance Review Report                                                   Page 6 of 22

Action
Compliance
#            QUESTION/REGULATION REFERENCE            Response               FINDINGS / RECOMMENED CORRECTIVE ACTION (If Any)                          Due 
Issue 
Date 
7  Does your DBE program have a method to address over-    YES    The PORT has reviewed past federal assisted projects as well as non-federal        NO      N/A 
concentration? ( 26.33)                              assisted projects and did not identify any overconcentration of DBE firms. 
8  Do you submit your annual overall goal by August 1,       YES    The PORT submitted its FY 13-15 Overall DBE goal methodology on July 12, 2012     NO      N/A 
every three years, pursuant to the schedule established         in accordance with FAA's established schedule.
by FAA? (26.45(f)) 
9  Has the Airport DBE goal methodology been approved     YES    The PORT's FY 13-15 overall DBE goal methodology was approved by the FAA on     NO      N/A 
by the FAA? ( 26.45)                                 July 13, 2012. 
10 In the past three years, has the Airport had any        NO   The PORT has not received any formal or informal DBE complaints of alleged      NO     N/A 
complaints filed alleging that it did not comply with the          violation of 49 CFR Part 26.
DBE regulations? 
11 Does the Airport have an FAA approved business       NO   The PORT has not elected to develop mentor-protg program.             NO     N/A 
development for mentor-protg program? ( 26.35(b)) 
Bid Processing and Contract
Reviews 
1                                                    The PORT Office of Small Business Program & Policy maintains an electronic 
Do you maintain a bidders list of all firms who bid or      YES                                                                NO      N/A 
quote whether or not the bidders were successful? (          Subcontractor Bidding Report (data system) of all projects bidders to included DBE
26.11(c))                                           firms.
2                                                    The PORT's bidders' data system captures all required information for Federally-
Does the bidders list capture information for both        YES                                                              NO      N/A 
successful and unsuccessful subcontractors? ( 26.11(c))         assisted contracts in accordance with 49 CFR Section 26.11(c). 
3                                                    The PORT is currently operating in a race-neutral environment. 
In situations where a DBE contract goal has been        N/A                                                             NO      N/A 
established, are bidders required to submit DBE              However in 2014 the PORT completed a Disparity Study and will be considering a 
information as required by regulation? ( 26.53(b))             race-conscious program during FY 16-18. The PORT has demonstrated a clear
understanding of the requirements of having contract goal. 
Recommended Enhancement: 
It is recommended that the PORT works closely with the FAA's Regional DBE
Compliance Specialist in establishing a race-conscious DBE Program.
4                                                    The PORT is currently operating in a race-neutral environment. 
In situations where a DBE contract goal has been        N/A                                                             NO      N/A 
established, during the review of good faith efforts, do

FAA FY-2015 Compliance Review Report                                                   Page 7 of 22

Action
Compliance
#            QUESTION/REGULATION REFERENCE            Response               FINDINGS / RECOMMENED CORRECTIVE ACTION (If Any)                          Due 
Issue 
Date 
you consider the guidance in Appendix A of the DBE
program requirements? (26.53(a) 
5                                                    The PORT is currently operating in a race-neutral environment. 
In the case of Good Faith Efforts reconsideration, are      N/A                                                               NO      N/A 
reconsideration decisions made by an official who did
not take part in the original good faith effort
determinations? ( 26.53(d)) 
6                                                    The PORT is currently operating in a race-neutral environment. 
Do you have a process in place to verify there is written    N/A                                                               NO      N/A 
confirmation from the DBE firm that it had agreed to
participate in the contract as provided in the prime
contractor's commitment? 
7  In situations where a DBE contract goal has been         N/A    The PORT is currently operating in a race-neutral environment.                  NO      N/A 
established, do you confirm that the DBE firm is certified
in the specified NAICS codes prior to awarding the
contract? ( 26.53) 
8                                                    The PORT has established a system to verify that all relevant contracts are in
Do you have a system to verify and audit that the        YES                                                             NO      N/A 
required assurances are being incorporated in prime           compliance with 49 CFR Section 26.13(a). 
contracts and subcontracts? ( 26.13(a)) 
9  Do you have a prompt payment provision in your         YES    The PORT has established a prompt payment provision. The provision requires all    NO      N/A 
contracts that requires prime contractors to pay all            prime contractors to make payment to all sub-contractors including DBE firms
subcontractors within 30 days of receipt of payment? (         within 10 days of receipt of payment from the PORT. 
26.29(a)) 
10 Do your have a return of retainage provision in your     YES   The PORT holds retainage from prime contractors and provide for prompt and     Yes    6/10/15 
contract that identifies one of three options allowed by         regular incremental acceptances of portions of the prime contract, pay retainage
the regulation? ( 26.29(b))                             to prime contractors based on these acceptances, and require a contract clause
obligating the prime contractor to pay all retainage owed to the subcontractor for
satisfactory completion of the accepted work within 30 days after your payment
to the prime contractor 
Recommended Enhancement: 
The Port should immediately implement the required contract language regarding
prompt payment and retainage found in FAA Advisory Circular 150/5370-10F on
pages 52-54 in the Partial Payments section that was release on 9/30/2011:
http://www.faa.gov/documentlibrary/media/advisory_circular/150_5370_10F.pd
f 

FAA FY-2015 Compliance Review Report                                                   Page 8 of 22

Action
Compliance
#            QUESTION/REGULATION REFERENCE            Response               FINDINGS / RECOMMENED CORRECTIVE ACTION (If Any)                          Due 
Issue 
Date 
11 Does the Airport have written certification that        YES   The PORT has an electronic documented monitoring program in place for       NO     N/A 
contracting records are being reviewed? ( 26.37)             contracts. Prior to the project, the PORT DBELO reviews these contracting
records to ensure that the required language and documents are contained within
the system and contracts for each project. During the project, engineers record 
site reviews on their construction management/project checklist. The review
checklist is maintained in the project folders. 
Monitoring Post Contract
Award 
1                                                    The PORT is currently operating in a race-neutral environment 
Do you have monitoring mechanisms in place to ensure    N/A                                                          NO     N/A 
that work committed to DBEs at contract award or
subsequently is actually awarded to DBEs to whom the
work was committed? ( 26.37(b)) 
2 
Do you have monitoring mechanisms in place to verify    YES    The PORT's Project manager monitors all worksites and verifies that work        NO     N/A 
that work committed to DBEs at contract award or            committed to DBE firms is actually being performed by the named DBE firms.
subsequently is actually performed by the DBEs to
whom the work was committed and that those DBEs are
managing their work and utilizing their own work forces,
equipment, and materials? ( 26.37) 
3                                                 The PORT is currently operating in a race-neutral environment. 
In the case of post-award terminations, pre-award   N/A                                                      NO     N/A 
deletions or substitutions of DBE firms, do you
The PORT did explain its understanding of the termination requirements of 49 CFR
have mechanisms in place to allow you to verify
26.53(f) if it were to establish a race-conscious program. The PORT will ensure
that the DBE has been notified AND given time to
that a prime contractor not terminate a DBE subcontractor without prior written
respond before approving the termination/
consent and for good cause. The prime contractor must give the DBE five days to
substitution as well as verify the documented good
respond to the prime contractor's notice. 
cause that compels the termination before
approving a termination/substitution? ( 26.53(f)) 
4                                                 The PORT is currently operating in a race-neutral environment. 
In situations where a DBE contract goal has been    N/A                                                       NO     N/A 
established and a DBE subcontractor is terminated
or fails to complete its work on the contract, do
you require the prime contractor to make good
faith efforts to find another DBE subcontractor to
substitute for the original DBE to perform at least
the same amount of work or to the extent needed
FAA FY-2015 Compliance Review Report                                                   Page 9 of 22

Action
Compliance
#            QUESTION/REGULATION REFERENCE            Response               FINDINGS / RECOMMENED CORRECTIVE ACTION (If Any)                          Due 
Issue 
Date 
to meet the established contract goal?( 26.37) 
5  Do you conduct regular site visits to verify that       YES 
The PORT's Project manager verifies the ownership of all equipment and vehicles    NO     N/A 
business names on equipment and vehicles are not       on worksites and names of the present employees.
covered with paint or magnetic signs as well as
verify who employs the workers on site. Do you
have written certification of this process? ( 26.37) 
6                                                 The PORT receives monthly accounts payable records and vouchers from the
Do you have monitoring mechanisms in place that    YES                                                     NO     N/A 
provide for a running tally of actual DBE                prime contractors to ensure that all subcontractors to include DBE firms are being
attainments (e.g., payments actually made to DBE        paid. 
firms), including a means of comparing these
attainments to commitments? ( 26.37) 
7  Do you randomly verify who orders and pays for      YES 
The PORT does randomly verify who orders and pays for the necessary supplies     NO     N/A 
the necessary supplies being used by the DBE           being used by DBE firms. 
subcontractor? ( 26.37) 
8   Do you have prompt payment mechanisms in place    NO    The PORT requires all prime contractors to return retainage to all sub-contractors    YES    6/10/15 
to ensure retainage is returned to all                    to include DBE firms after the subcontractor's work is satisfactorily completed. 
subcontractors upon substantial completion of
their work on the project? ( 26.29)                    The Port relies on common business practices, that subcontractors will contact
the Port when a prime contractor has not released their retainage within 30 days 
of satisfactory completion of the accepted work by the subcontractors. Upon
notification, the Port investigates with the prime to identify the delay.
Recommended Enhancement: 
The Port must proactively monitor prime contractor compliance with prompt
payment and retainage requirements through a documented process. Relying on
complaint notifications is not sufficient. See USDOT Q&A on subject. 
9  Do you have a monitoring mechanism in place to     YES   The PORT receives monthly accounts payable records and vouchers from the       NO     N/A 
verify that prime contractors pay all subcontractors        prime contractors to ensure that all subcontractors to include DBE firms are paid
within 30 days of receipt of payment? (49 CFR           within 10 days of receipt of payment. 
26.29 (a)) 
10 Do you conduct compliance reviews, audits and/or   YES 
The PORT conducts both monthly and quarterly audits to ensure DBE participation   NO     N/A 
assessments of all program participants (e.g.,
FAA FY-2015 Compliance Review Report                                                   Page 10 of 22

Action
Compliance
#            QUESTION/REGULATION REFERENCE            Response               FINDINGS / RECOMMENED CORRECTIVE ACTION (If Any)                          Due 
Issue 
Date 
contractors, subcontractors, suppliers)? (              on federally assisted contracts. 
26.37(a)) 
DBE Participation
Reporting 
1 
Do you count the DBE firm's value of work toward       YES 
The PORT only counts the work performed by the DBE firms that perform a       NO     N/A 
contract goals only if the DBE performs a Commercially         Commercially Useful Function on federally assisted projects. 
Useful Function (CUF)? ( 26.55(c)) 
2 
Do you allow a DBE firm's participation to count toward    YES 
The PORT counts DBE participation for DBE firms that are certified prior to the      NO      N/A 
the DBE goal if the firm was not certified at the time it           execution of a contract with the prime contractor. 
executed the contract with the Prime contractor? (
26.55(f)) 
3 
Do you ensure that the contractor has actually paid its     YES 
The PORT requires all prime contractors to make payment to all sub-contractors    NO     N/A 
DBEs and is in compliance with all program                  to include DBE firms within 10 days of receipt of payment from the PORT. 
requirements before determining whether a contractor
met its DBE goal? ( 26.55(h)) 
4 
If a DBE firm's certification eligibility is removed during     NO 
The PORT only counts the amount of work performed by the DBE firm prior to the   NO     N/A 
performance of a subcontract, do you deduct that            removal of the certification.
subcontract amount from the Airport's overall goal? (
26.55(g)) 
5 
In the case where a DBE wins a prime contract through    YES 
The PORT is currently operating in a race-neutral environment. All DBE          NO      N/A 
customary competitive procurement procedures or is          participation is counted as race-neutral. 
awarded a subcontract on a prime contract that does
not carry a DBE goal, do you count the DBE participation
as Race-neutral? ( 26.55(a)) 
6 
Were you required to submit a Uniform Report of DBE    YES    The PORT submitted its annual Uniform Report of DBE Awards/Commitment and    NO     N/A 
Awards/Commitment and Payments for federal FY           Payments for federal FY 2014 via the FAA dbE-Connect system, on December 11,
2014? ( 26.11)                                    2014. The FAA reviewed and approved the annual report on December 12, 2014. 
7 
Have you achieved your annual goal each year in the      NO    The PORT did not achieve its last three years overall DBE goal by utilizing race-     NO     N/A 
past three years? ( 26.47(c))                            neutral means.
8 
In any years that you did not meet the DBE goal, did you   YES    The PORT was required to prepare a DBE goal accountability report for both FY      NO      N/A 
analyze the reasons why the goal was not achieved and         2013 and FY 2014. The overall DBE goal was analyzed to determine why the goal
established specific steps to correct the problem? (            was not achieved. On January 9, 201, the PORT submitted the FY-14 analysis to
FAA FY-2015 Compliance Review Report                                                   Page 11 of 22

Action
Compliance
#            QUESTION/REGULATION REFERENCE            Response               FINDINGS / RECOMMENED CORRECTIVE ACTION (If Any)                          Due 
Issue 
Date 
26.47(c))                                           the FAA for approval. The FAA issued the concurrence letter on January 14, 2014. 
Note: In 2014, the PORT also conducted a Disparity Study in the PORT's market
area. The PORT is now determining if race-conscious measures would better
correct the shortfall problem. 













FAA FY-2015 Compliance Review Report                                                   Page 12 of 22




FINDINGS: SEA-TAC - Title 49 CFR Part 23  AIRPORT CONCESSIONS 
PART 1 ACDBE Program Questions:
Administrative Requirements 
Compli
Action Due 
#   QUESTION/REGULATION REFERENCE                         Response    FINDINGS / RECOMMENED CORRECTIVE ACTION (If Any)    ance
Date 
Issue 
1   Do you have an FAA approved ACDBE Program in place? (               Sea-Tac's ACDBE Program was approved by the FAA on        NO       N/A 
YES 
23.21(a))                                                September 30, 2011. The ACDBE program available for public
review by accessing the Port of Seattle's website at
http://www.portseattle.org/Business/Airport-
Concessions/Documents/2014_%202017acdbe_plan_signed.p
df 
2   Did you sign and disseminate your ACDBE Policy Statement? (     YES                                                     NO     6/10/15 
Sea-Tac's ACDBE policy statement was signed by former Port
23.21) 
CEO Tay Yoshitani shortly before his retirement on September
30, 2014. 
Recommended Enhancement: 
It is recommended that the PORT's newly appointed Chief
Executive Officer, Ted Fick review, sign and re-distribute SEATAC
's ACDBE Program Policy Statement
3   Does your ACDBE Liaison Officer have independent program       YES                                                     NO       N/A 
Deanna Zachrisson, the ACDBELO, is the Business Leader for
implementation authority and independent (direct) access to
the Airport Dining and Retail Program and meets regularly
the Airport Director/CEO? ( 23.23) 
with the Airport Director regarding program issues in general
and ACDBE matters when they arise.
The ACDBELO has ready access to Ted Fick, Chief Executive
Officer, Sea-Tac. 
4   Do you submit your annual overall goal by October 1, every        YES                                                     NO       N/A 
Sea-Tac submitted its FY 15-17 overall ACDBE goal to the FAA
three years pursuant to the established schedule? ( 23.45) 
on September 10, 2014. The airport has consistently 
submitted its three-year overall ACDBE goal in a timely
fashion. 
5   Has the Airport ACDBE goal methodology been by approved by     YES                                                     NO       N/A 
Sea-Tac's ACDBE Program was approved by the FAA on
the FAA? ( 23.45) 
October 2, 2014. 

FAA FY-2015 Compliance Review Report                                                   Page 13 of 22

Compli
Action Due 
#   QUESTION/REGULATION REFERENCE                         Response    FINDINGS / RECOMMENED CORRECTIVE ACTION (If Any)    ance
Date 
Issue 
In advance of the program submittal, Sea-Tac has consulted
with FAA staff regarding the methodology used to calculate
the 3-year participation goal. Sea-Tac uses an alternative
methodology due to the small number of ACDBE-certified
firms in the Airport's market area. 
6   Does your ACDBE program provide for seeking ACDBE             YES    Sea-Tac Airport encourages participation by ACDBEs in all      NO       N/A 
participation in all types of concession activities rather than            areas of concessions. In particular, the Airport has sought to
concentrating participation in one category or a few categories         increase small business opportunities for a variety of types of
to the exclusion of others? (23.25 (c))                           ACDBE firms including those that provide airport goods and
services. The airport also provides supportive services to
potential ACDBE firms regarding certification efforts.
Additionally, as the airport's concessions program is
redeveloped over the next number of years, Sea-Tac intends
to implement a "vendor/supplier" program to facilitate
relationships between tenants and providers of goods and
services for the airport.
7   Does your ACDBE program require businesses subject to ACDBE          Sea-Tac currently administers a race-neutral program.         NO       N/A 
YES 
goals (except car rental companies) to make good faith efforts
to explore all available options to meet goals, to the maximum          Currently, Sea-Tac has a number of prime concessionaire
extent practicable, through direct ownership arrangements with        leases dating back to 2002-2003 that contain ACDBE goals.
ACDBEs? (23.25 (g))                                     Sea-Tac has required these concessionaires to explore a broad
means of achieving those goals. These prime concessionaires
are all close to or exceeding their goals.
In the future, Sea-Tac has articulated a desire to grow the
number of small/minority owned businesses to include ACDBE
firms as direct lessees. This is because Sea-Tac has found that 
direct relationships with these small business tenants are
more effective for their concessions program because both
parties have a vested interest in the success of these
businesses. 
8   Do you conduct regular outreach sessions to ensure the          YES    Sea-Tac has two different types of outreach sessions that are    NO       N/A 
inclusion of ACDBEs firms in your ACDBE program? ( 23.25(e))          intended to ensure the inclusion of ACDBE and other
small/minority-owned businesses in the program. First, Sea-
Tac hosts an annual ACDBE event that is a forum for such
FAA FY-2015 Compliance Review Report                                                   Page 14 of 22

Compli
Action Due 
#   QUESTION/REGULATION REFERENCE                         Response    FINDINGS / RECOMMENED CORRECTIVE ACTION (If Any)    ance
Date 
Issue 
businesses to learn more about growing their business,
promoting services, and relevant matters for ACDBEs.
Secondly, Sea-Tac hosts outreach events as new business
opportunities become available. The publicity for these
events is particularly targeted to small and minority owned
businesses; for example one form of publicity is with
advertisements in minority publications and online media. 
Lastly, Sea-Tac plans to conduct joint outreach with the state
ACDBE certification agency in order to grow interest in the
program participation overall.
9   Does the Airport assess potential for ACDBE participation      YES    The airport has had the opportunity to make several changes   NO      N/A 
when an extension, an option to renew, or a material             to improve the concessions program since the majority of the
amendment of a concession agreement is made? ( 23.71)          existing leases are expiring soon. For example, the airport has
tiered and staggered lease expiration dates on a four year
expiration/renewal schedule in order to allow opportunities
to come up for bid more frequently.  Most recently, Sea-Tac
has negotiated with prime concessionaires HMS Host and
Hudson to return several units for new leasing (Host- 6 units,
Hudson- 7 units). Many of these units will be appropriate for
future small businesses to have direct ownership agreements 
to include ACDBE firms. As an innovative approach to that
end, the airport has also created smaller unit spaces that are
easier for small businesses to bid on and handle since the
required initial investments (based on square footage) for
large spaces can be cost prohibitive to smaller firms. 
10  If a new concession opportunity, the estimated average       YES   When Sea-Tac adds a new concession opportunity, Airport    NO     N/A 
annual gross revenues of which are anticipated to be             staff evaluates the anticipated gross sales if they have the
potential for ACDBE participation and if the increased sales
$200,000 or greater, arises at a time that falls between
projections would warrant an appropriate adjustment to the
normal submission dates for overall goals, does the Airport          FAA goal.
submit an appropriate adjustment to the overall goal to the
FAA for approval? ( 23.45(j))                               Due to the size of current ACDBE participation ($41.5 million
in FY 2013-14), a $200,000 increase would not measurably
affect participation levels, nonetheless the Airport would
consult with the FAA about an adjustment as appropriate. 

FAA FY-2015 Compliance Review Report                                                   Page 15 of 22

Compli
Action Due 
#   QUESTION/REGULATION REFERENCE                         Response    FINDINGS / RECOMMENED CORRECTIVE ACTION (If Any)    ance
Date 
Issue 
11   Does the airport have Long Term (5+ years) and Exclusive        YES    There are two Long Term and Exclusive contracts currently in   YES     6/10/15 
contract(s) currently in place? ( 23.75)                           place. The Airport has a five-year agreement with Smarte-
Carte which transitioned into holdover on January 31, 2015.
The Airport also holds a 10-year agreement with Clear
Channel, which was executed in late 2007. In the process of
preparing for the FAA audit, staff was unable to locate a letter
from the FAA providing approval of an exclusive for this
agreement, which does not have ACDBE participation. 
Recommended Action: 
Sea-Tac must submit a request for waiver approval from the
FAA to include both Long Term and Exclusive contracts.

Bid Processing and Contract Reviews 
1   In situations where an ACDBE contract goal has been             N/A    Sea-Tac currently administers a race-neutral program.         NO       N/A 
established, are bidders required to submit ACDBE information
A few of the airport's older contracts contained ACDBE 
as required by regulation? ( 23.25(e)) 
contract goals and in those RFPs/RFQs, contract goals were
attached regarding ACDBE participation. The most recent
solicitations included an encouragement to seek ACDBE
participation, but no contract goals were present. Proposers
voluntarily proposed participation in many cases, however.
2   In situations where an ACDBE concession goal has been established,    N/A    Sea-Tac currently administers a race-neutral program.          NO       N/A 
during the review of good faith efforts, do you consider the
guidance in Appendix A of the DBE program requirements? (
23.25(e)) 
3   In situation of good faith efforts reconsideration, are             N/A                                                     NO       N/A 
Sea-Tac currently administers a race-neutral program. 
reconsideration decisions made by an official who did not take
part in the original good faith efforts determinations? (
23.25(e)) 
4   Does the Airport verify that there is written confirmation from     YES                                                     NO       N/A 
A written confirmation of an ACDBE's agreement to
the ACDBE that it had agreed to participate in the contract as
participate in a contract was required as part of the RFP
provided in the prime RFP/RFQ? ( 23.29(e)) 
process. 

FAA FY-2015 Compliance Review Report                                                   Page 16 of 22

Compli
Action Due 
#   QUESTION/REGULATION REFERENCE                         Response    FINDINGS / RECOMMENED CORRECTIVE ACTION (If Any)    ance
Date 
Issue 
5   Does the Airport include enforcement provisions to ensure        YES    Sea-Tac maintains an effective contract enforcement program   NO       N/A 
compliance of part 23 in concession agreements? ( 23.29)            to assure compliance with Part23. This includes regular site
visits, interviews with employees, and review of daily sales
generated by ACDBEs. 
6   Does the Airport have a system to verify and audit that the        YES                                                     NO       N/A 
Sea-Tac's concession contracts are audited on a routine basis, 
required assurances are being incorporated in concession
and these audits, initiated by the Port of Seattle Commission
contracts? ( 23.29) 
Audit Committee, assure that the required assurances are
incorporated.
Sea-Tac recently introduced a new SharePoint based
workflow approval system and plans to incorporate a "check"
that contracts are reviewed by the ACDBELO for compliance. 
7   Does the Airport have written certification that all contracts,       YES    Sea-Tac is currently transitioning from a manual 'routing list'    NO       N/A 
leases, joint venture agreements, or other concession-related          system of written tracking and verification. As part of that
agreements are being reviewed? ( 23.29)                       process, the Port's legal department expert for the ACDBE
program verifies that all agreements are reviewed.
8   Does the Airport require the concessionaire awarded the          YES                                                     NO       N/A 
Sea-Tac requires prime concessionaire operators as well as
contract/agreement to make available upon request a copy of
direct lease tenants to provide relevant documentation to the
all ACDBE contracts, leases, joint venture agreements, or other
airport upon request. 
concession-related agreements? ( 23.25(e)) 
Monitoring Post Contract Award 
1   Do you have monitoring mechanisms in place to ensure that       YES                                                     NO       N/A 
Sea-Tac works closely with all tenants in the daily operation of
work committed to ACDBEs at contract award or subsequently is
their businesses. This daily interaction assures that the work
actually awarded to ACDBEs to whom the work was committed?
for contracts committed to ACDBEs have actually been
( 23.25(e)) 
awarded to them.
2   Do you have monitoring mechanisms in place to verify that work   YES                                                NO      N/A 
Sea-Tac works closely with all tenants in the daily operation of
committed to ACDBEs at contract award or subsequently is
their businesses. This daily interaction assures that the work
actually performed by the ACDBEs to whom the work was
for contracts awarded to ACDBEs are actually performed by
committed and those DBEs are managing their work, utilizing
them. 
their own work forces? ( 23.25(e)) 

FAA FY-2015 Compliance Review Report                                                   Page 17 of 22

Compli
Action Due 
#   QUESTION/REGULATION REFERENCE                         Response    FINDINGS / RECOMMENED CORRECTIVE ACTION (If Any)    ance
Date 
Issue 
3   In the case of post-award terminations, pre-award deletions or    YES                                                NO      N/A 
Sea-Tac is currently operating in a race-neutral environment. 
substitutions of ACDBE firms, do you have mechanisms in place
to allow you to verify that the ACDBE has been notified AND           Sea-Tac did explain its understanding of the termination
given time to respond before approving the termination/             requirements of 49 CFR 26.53 in a race-conscious program 
substitution as well as verify the documented good cause that          that also apply to 49 CFR Part 23. Sea-Tac will ensure that a
compels the termination before approving a                     Prime not terminate an ACDBE without prior written approval
termination/substitution? ( 26.25(e))                           and without documented good cause for
termination/substitution of ACDBE firm if the airport were
to choose to have a race conscious program. 
4   In situations where an ACDBE contract goal has been established   YES                                                     NO       N/A 
Currently Sea-Tac primarily administers a race-neutral
and an ACDBE firm is terminated or fails to perform, do you
program. 
require the prime concessionaire to make good faith efforts to
find another ACDBE firm to substitute for the original ACDBE to         A few older concession contracts contained contract goals. In
participate in the contract to the extent needed to meet the           those instances, Sea-Tac requires prime concessionaires with
established contract goal? ( 23.25(e))                           an established ACDBE goal to demonstrate good faith efforts
to find another ACDBE firm to substitute for the original
ACDBE participant.
In late 2014, one ACDBE tenant elected to sell its business to
the prime concessionaire. Sea-Tac is requiring this prime
concessionaire to make efforts to find a new ACDBE; however, 
it recognizes that this endeavor will be very difficult if not
unlikely due to the fact that only two years remain on the
lease. 
5   Do you or designee conduct regular concession site visits to       YES                                                     NO       N/A 
Castina Ridge, Assistant ACDBELO, conducts regular site visits
verify who employs the employees on site, as well as who
at all locations throughout the terminal including ACDBE
manages the location. If so, do you have written certification of
locations. Sea -Tac has developed a questionnaire and
this process? ( 23.29) 
checklist which contain information on interviews with
employees at the locations. During the site visits, the
ACDBELO randomly interviews both employees and managers
to ensure they are aware of the owner of the business.
All site visit information is documented and preserved in
ACDBE files. In addition, each program operator conducts
daily terminal walks to monitor the operations of all tenants. 

FAA FY-2015 Compliance Review Report                                                   Page 18 of 22

Compli
Action Due 
#   QUESTION/REGULATION REFERENCE                         Response    FINDINGS / RECOMMENED CORRECTIVE ACTION (If Any)    ance
Date 
Issue 
6   Do you review monthly ACDBE participation reports? ( 23.29)      YES                                                     NO       N/A 
Sea-Tac maintains a daily sales reporting system which all
tenants are required to use to report sales by which staff can
monitor participation reports.
In addition, monthly reports of participation are provided by
the Port's accounting department to the management of the
concession program in order to monitor participation on a
monthly basis. 
7   Do you conduct compliance reviews, audits and/or assessments    YES                                                       NO       N/A 
Sea-Tac conducts multiple types of audits of all program
of all program participants (e.g., prime concessionaires, sub-
participants. 
concessionaires, joint venture partners)? ( 23.29) 
Sea-Tac's concession contracts (Prime and subconcessionaires
) are audited on a routine basis, and these
audits, initiated by the Port of Seattle Commission Audit
Committee, assure that the required assurances are
incorporated.
Sea-Tac recently introduced a new SharePoint based
workflow approval system and plans to incorporate a "check"
that contracts are reviewed by the ACDBELO for compliance. 
8   Have you undertaken an internal review of your joint venture      YES                                                       NO       N/A 
In conjunction with the FAA's 2010 joint venture audit, the
agreements, if any, in order to verify that they are in compliance
airport worked with its only joint venture, Airport
with the FAA Joint Venture Guidance? ( 23.29) 
Management Services/Hudson Group, to restate their joint
venture agreement in order to comply with the guidance.
Since that time, the Airport has monitored the management
of that joint venture. 
ACDBE Participation Reporting 
1   Do you count toward concession contract goals the value of        NO                                                       NO       N/A 
Sea-Tac only counts ACDBE participation if the work has a
work only if the ACDBE performs a Commercially Useful
commercially useful function as verified by the ACDBELO &
Function (CUF)? ( 23.55(a))
ACDBELO assistant's periodic reviews. 
2   Do you allow an ACDBE to count toward the ACDBE goal if it was    NO                                                       NO       N/A 
Sea-Tac only counts participation by ACDBEs certified prior to
not certified at the time its contract was executed? (
the execution of the contract. There are instances when an
23.55/26.87(j)) 
ACDBE is not certified in Washington at the time of award, but
must be certified by the time that the contract is executed. 
FAA FY-2015 Compliance Review Report                                                   Page 19 of 22

Compli
Action Due 
#   QUESTION/REGULATION REFERENCE                         Response    FINDINGS / RECOMMENED CORRECTIVE ACTION (If Any)    ance
Date 
Issue 
3   Do you count the DBE participation and any costs incurred in       NO                                                       NO       N/A 
Sea-Tac only counts ACDBE participation that provides a
connection with the renovation, repair, or construction of a
service or product to the public. 
concession facility (build-out)? ( 23.55(k))
4   When an ACDBE performs as a participant in a joint venture, do     YES                                                       NO       N/A 
Sea-Tac only counts the specific sales generated by that
you only count a portion of the gross receipts equal to the
portion of the gross receipts that are equal to the distinct,
distinct, clearly defined portion of the work of the concession
clearly defined portion of the work commensurate with the
that the ACDBE performs with its own forces toward ACDBE
ownership share in the joint venture.
goals? ( 23.55(d))
5   When counting participation of fees or commissions (i.e.          YES                                                       NO       N/A 
Sea-Tac does not have any management agreements which
professional, technical, consultant, legal, security systems,
contain ACDBE participation. In such an instance, Sea-Tac
advertising, building cleaning and maintenance, computer
would assure the service fees are reasonable.
programming, or managerial) charged by an ACDBE firm, do you
review to ensure the amount is reasonable and not excessive as         In the one joint venture agreement at the airport, Sea-Tac has
compared with fees customarily allowed for similar services?. (         reviewed fees charged to ACDBEs and has assured by
23.55(e))                                                 consulting with other airports that such fees were reasonable
in comparison to typical fees charged in the marketplace. 
6   In the case where an ACDBE wins a prime concession through      YES                                                       NO       N/A 
Sea-Tac has a completely race-neutral program so all forms of
customary competitive procurement procedures or is awarded a
participation are counted as race-neutral. 
sub-concessionaire on a prime concession contract that did not
carry an ACDBE goal, do you count the ACDBE participation as
Race-neutral participation? ( 23.55(a))
7   Were you required to submit the Uniform Report of ACDBE          YES                                                       NO       N/A 
Sea-Tac has been required to submit the Uniform Report and
participation for federal FY 2014? ( 23.55) 
has completed this in a timely manner. 
8   In the past three years, have you consistently achieved your       YES                                                       NO       N/A 
In the past three years, Sea-Tac has consistently exceeded its
annual goal for concessions other than car rentals? ( 23.57) 
annual goal for concessions participation. 
9   In the past three years, have you consistently achieved your       YES                                                       NO       N/A 
Due to the lack of certified ACDBE firms which offer goods &
annual goal for car rental concessions? ( 23.57) 
services in the State of Washington, Sea-Tac has established
an 0% Overall ACDBE Goal for car rental concessions. 
Recommended Enhancement: 
Sea-Tac should work closely with Office of Minority and
Women's Business Enterprise to increase the number of
qualified and certified ACDBE firms which could offer goods &
FAA FY-2015 Compliance Review Report                                                   Page 20 of 22

Compli
Action Due 
#   QUESTION/REGULATION REFERENCE                         Response    FINDINGS / RECOMMENED CORRECTIVE ACTION (If Any)    ance
Date 
Issue 
services to car rental companies. Sea-Tac should periodically
review availability of certified ACDBE firms that could provide
goods and services to car rental firms and consider
adjusting/revising the goal in the future if appropriate. Sea-
Tac should also periodically encourage the car rental firms to
make good faith efforts to utilize ACDBE firms for goods and
services purchases even without a goal in place. 
10   In the past three years, have you had any complaints filed        NO                                                 NO      N/A 
Sea-Tac has been the subject of two complaints in the last
alleging that the Airport did not comply with ACDBE regulations?
three years.
The first complaint was filed by a group of HMSHost
subtenants after the passage of a Port of Seattle Commission
motion that would provide those ACDBES only with the
opportunity to negotiate new non-competitive leases. The
Port of Seattle Commission solicited the input of the FAA on
the permissibility of the motion, and the ACDBE tenants also
sent a written complaint about Sea-Tac and its support for the
Commission motion. The airport did not move forward with
implementation of the motion based on the concerns of the
FAA.
In late 2014, the FAA received a written complaint from a
community activist in support of an ACDBE participant 
alleging non-compliance. The matter is currently being
litigated in Federal court. 
11   Do you have an FAA approved business development or mentor-   NO                                                 NO      N/A 
Sea-Tac does not currently have an FAA approved business
protg program? ( 23.25) 
development or mentor-protg program.
However, Sea-Tac has sponsored mentorship programs for
new small businesses, minority businesses, and ACDBE
businesses. For example, when a new ACDBE business
entered the Airport in 2013 another ACDBE participant with
experience of the Airport environment, both as a subtenant
ACDBE and a joint venture partner, acted as a mentor to this
new operator. Other current ACDBE tenants also have
expressed their willingness to mentor new small minority
owned businesses. 
FAA FY-2015 Compliance Review Report                                                   Page 21 of 22





REVIEW SUMMARY 
The Federal Aviation Administration (FAA) Office of Civil Rights would like to thank you for your participation in this FY 2015 DBE & ACDBE Compliance Review. We
appreciate the substantial effort taken by Seattle-Tacoma International Airport in providing numerous documents and meeting with the FAA team during this on-site
visit. Your timely response and active participation was an essential element in the successful completion of this important initiative. The collective assessments
made during the review have been incorporated into this report. 
The FAA Office of Civil Rights periodically conducts discretionary reviews of grant recipients and sub-recipients in order to provide technical assistance, note best
practices, identify areas for improvement, and ensure program compliance. This review has examined the Airport's compliance with the DBE Program and ACDBE
Program. Observations and comments have been registered in each area that was examined. 
Areas requiring your attention have been noted as a Compliance Issue under each specific question-corrective action must be taken by each set deadline. To
supplement this year's review, we conducted four focus group meetings with prime contractors, DBEs, master/prime concessionaires, as well as ACDBEs.The primary
objective during these meetings was to evaluate the administration of the DBE and ACDBE program from the participants' perspective. We found that participants are
happy to be doing business at SEA-TAC. They appreciate the support the Airport offers to small businesses as well as the spirit of customer service it promotes.  They
appreciate the open communication and inclusion. In addition, most participants felt that SEA-TAC has designed and implemented its DBE and ACDBE Programs with
the spirit and intent of 49 CFR Parts 23 and 26. However, participants also noted that they would like more transparency and inclusion in the DBE & ACDBE goal
setting processes. They would also like to be notified  more directly of upcoming opportunities and goals during the goal-setting comment periods. As required in 49
CFR 26.45(g), the PORT should begin posting DBE data on their public website regarding DBE Goal Setting public participation, and ensure thorough consultations,
including with local and currently participating firms, are conducted for both the DBE and ACDBE Goal Setting processes. 
The airport has many positive areas of note within its DBE & ACDBE programs. For example, it is very commendable that the airport has innovatively restructured its
concessions program overall and its unit spaces specifically to be more attractive to small business firms including ACDBEs. While SEA-TAC has many positive aspects
of the DBE and ACDBE Programs, based on the findings, we have designed specialized technical assistance to focus on the following areas of concern: (1) New CEO
should review and sign the DBE and ACDBE Program Policy Statements; (2) DBE program must develop a prompt payment mechanisms to return retainage (3) Two
Long Term and Exclusive Leases require FAA review and approval; and (4) Lack of ACDBE participation from Car Rental Concessions. 
The FAA Office of Civil Rights looks forward to continuing to work with you in ensuring compliance with 49 CFR Part 26, "Participation by Disadvantaged Business
Enterprise in Department of Transportation Financial Assistance Programs," and 49 CFR Part 23, "Participation of Disadvantaged Business Enterprise in Airport
Concessions." 

REPORT PREPARED BY:    _________________________________ _________________________________ 
RICKY WATSON                              KETURAH PRISTELL 
Northwest Mountain DBE Compliance Specialist              Southern Region DBE Compliance Specialist 
Recommended Resources: 
FAA website, http://www.faa.gov/about/office_org/headquarters_offices/acr/bus_ent_program/fed_reg/ 
FAA dbE-Connect System, https://faa.dbesystem.com/Default.asp? 
U.S. Department of Transportation Office of Small and Disadvantaged Business Utilization http://www.osdbu.dot.gov/DBEProgram/GuidanceforDBEProgramAdministrators/index.cfm 
DOT Departmental Office of Civil Rights https://www.civilrights.dot.gov/disadvantaged-business-enterprise 

FAA FY-2015 Compliance Review Report                                                   Page 22 of 22

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