
John Hawley
Sep 10, 2026
The Public Money Pipeline: Part V
For a small Jacksonville business trying to win government work, getting the first City contract may be the hardest one.
Established contractors already have references, equipment, insurance, bonding capacity, relationships with suppliers and experience navigating public procurement. A smaller company may be perfectly capable of performing the work but still struggle to get the opportunity to prove it.
Jacksonville’s Small and Emerging Business program—better known as JSEB—exists in large part to address that disadvantage.
The City of Jacksonville says the program is designed to maximize procurement opportunities for certified JSEBs as suppliers, prime contractors and subcontractors. Jacksonville also establishes an overall goal of at least 20% of applicable City contracts going to JSEBs, where legally permissible and qualified businesses are available.
That is a worthy goal. Government contracting can help a small company acquire experience, employees, equipment, financial capacity and a performance history that eventually allows it to compete for much larger work.
But our examination of Jacksonville’s JSEB program found something prospective participants should understand before assuming certification alone opens that door:
Getting into JSEB and successfully navigating JSEB are two different things.
And Jacksonville’s own officials and Monitoring Committee members have spent years wrestling with some of the same questions.

Who Qualifies for Jacksonville’s JSEB Program?
For-profit applicants must satisfy requirements involving business size, ownership, control, residency, independence, experience and the type of work the company actually performs.
Among the most important is size.
Under the current ordinance, a for-profit business generally cannot exceed $12 million in average annual gross revenue. For a company operating four years or longer, Jacksonville generally uses the average of the immediately preceding three years.
The qualifying owner must control at least 51% of the business. The company must operate independently, perform a commercially useful function and possess the expertise, licensing and other qualifications necessary for the work for which it seeks certification.
Jacksonville’s application process goes considerably further than asking a business owner to simply declare the company small. Applicants must provide financial and business documentation and information about ownership, operations and affiliations.
That makes an important point about the program:
JSEB is designed to identify actual operating small and emerging businesses—not fronts or pass-through entities created simply to gain access to protected contracting opportunities.
JSEB Certification Requires Documentation—and Recertification
Certification isn't permanent.
Jacksonville’s current recertification application requires businesses to provide information including their most recent three years of business tax returns, ownership information, employees, licensing, continuing education and the number of City contracts performed as a prime contractor or subcontractor.
Applicants also certify that material changes affecting their eligibility haven't gone undisclosed.
The current ordinance gives the JSEB Administrator responsibility for implementing and enforcing the program, certifying businesses and maintaining certification records.
That means JSEB isn't designed as a pure honor system.
The business supplies the information, but the City has both documentation and administrative authority to determine whether the company continues meeting program requirements.
Jacksonville’s JSEB Website Hasn't Completely Caught Up With Its Own Rules
A prospective small-business owner researching JSEB online can currently encounter contradictory information.
The City's JSEB requirements page still describes a general nine-year participation limit.
But Jacksonville changed that rule in 2024.
Ordinance 2024-437-E extended the general participation period from nine years to 15 years and changed the certification review period from 24 months to 36 months.
Yet the City's FAQ also continues to tell businesses that certification is valid for two years.
These might look like website housekeeping issues, but they're consequential to someone considering participation.
How long can my company remain in JSEB? When do I have to recertify?
A small business investing time and money into government contracting should be able to find current answers to basic questions like those on the program's own website.
For businesses applying today, the current ordinance should control over outdated explanatory webpages.

Getting JSEB Certified Doesn't Mean Getting a City Contract
This may be the most important lesson for a prospective participant.
Certification does not equal a contract.
There are several fundamentally different ways a JSEB can obtain City work.
Jacksonville can reserve an entire prime contract for JSEBs through a set-aside. It can directly contract with a JSEB under applicable program provisions. It can award a much larger contract to another prime contractor and require a percentage of the work to go to JSEB subcontractors. Other solicitations may merely encourage JSEB participation.
And a certified JSEB can compete in an unrestricted public procurement against everybody else—and win.
Those distinctions matter because they don't create the same opportunity.
A $500,000 prime contract reserved for JSEBs gives an emerging business direct responsibility for managing a City contract.
A $500,000 subcontract underneath a $10 million prime contract can provide valuable revenue and experience, but the small business remains a subcontractor.
Both have value.
But they build businesses differently.
Jacksonville Can Create Small-Business Opportunities by Breaking Up Larger Contracts
Jacksonville’s Procurement Code specifically recognizes this issue.
The JSEB Administrator is directed to prioritize direct-contracting opportunities and create them, where feasible, by breaking larger procurement packages into smaller components and separating licensed from unlicensed work where appropriate.
This is generally known as unbundling.
Why does it matter?
Consider $10 million worth of work.
Jacksonville could put virtually all of it into one $10 million umbrella contract.
It could divide the work geographically into five $2 million prime contracts.
Or it could award the $10 million prime contract to a large contractor while requiring a percentage of the work to be performed by JSEB subcontractors.
The City may ultimately spend the same $10 million.
But the opportunities created for emerging businesses can be dramatically different.
Our review of Jacksonville procurement records found examples of the City using these different approaches.
That makes understanding how a contract is packaged almost as important to a small business as knowing that the contract exists.
Small Businesses Should Follow City Contracts Before They Go Out to Bid
A business owner shouldn't simply obtain JSEB certification and wait for the perfect solicitation to arrive.
Jacksonville publishes bidding opportunities, procurement information and, in some departments, forecasts of work expected to be advertised months in advance.
The City's Public Works construction forecast is particularly instructive because individual projects can carry different JSEB treatments.
Some are identified as set-asides.
Others carry 20%, 10% or 5% participation requirements.
Still others may contain encouragement language.
That means a small contractor can potentially identify opportunities before the final solicitation reaches the street.
The practical lesson is straightforward:
Follow the pipeline, not just the bid board.
A business should know which City department buys what it sells, which contractors currently hold the work, when those contracts expire, which projects are approaching procurement and whether the City intends to package the work into one large contract or several smaller opportunities.
Jacksonville provides a central page connecting businesses with City and partner-agency bidding opportunities.
Jacksonville JSEB Citywide Bidding Opportunities
Liberty Landscape Supply Shows What Successful Emergence Can Look Like
Readers of The Public Money Pipeline have already encountered one company that learned how to compete successfully for City work.
Fernandina Mulch & Stone LLC, doing business as Liberty Landscape Supply, grew from a small Northeast Florida operation into a substantial landscaping and supply business and government contractor.
Owner Mike Zaffaroni now chairs Jacksonville’s JSEB Monitoring Committee. Importantly, he serves in the Trade Association Representative seat—not one of the committee's designated JSEB-contractor seats.
Liberty illustrates something important about the intended purpose of programs like JSEB:
A small business isn't supposed to remain small forever.
The objective should be to help businesses develop sufficient experience and capacity to eventually compete successfully in the broader marketplace.
Liberty has demonstrated that capacity.
The company won Jacksonville's current countywide tree procurement, planting and miscellaneous landscaping contract through an open competitive procurement. The contract carries an annual not-to-exceed amount of approximately $14.5 million, with approximately $29 million of capacity during its initial two-year term.
That doesn't mean Jacksonville will pay Liberty $14.5 million each year. A contract ceiling isn't the same thing as revenue or actual City expenditures.
But winning an unrestricted procurement of that scale demonstrates something important.
Liberty isn't simply trying to get its foot in the door anymore. It has become an established City contractor capable of competing for major open-market work.
That's evidence of successful emergence.
It also raises a question Jacksonville eventually has to answer for every successful participant:
Once one company has emerged, how does the program make room for the next company trying to do the same thing?
K and J Lawn Care Shows Why Distribution Matters Too
Liberty isn't the only useful example.
Our review of Jacksonville procurement records found that K and J Lawn Care held three significant landscaping contracts expressly designated as JSEB set-asides.
The cumulative not-to-exceed capacity of those three contract vehicles eventually reached approximately $17.7 million.
That does not mean K and J received $17.7 million in City payments. These were multi-year contract ceilings, and distinguishing contract capacity from actual expenditures is important.
But it demonstrates another reality of small-business contracting:
Significant protected opportunities can become concentrated with successful participants.
That doesn't by itself indicate favoritism or anything improper.
There is a much simpler explanation.
Businesses that successfully perform government work become better positioned to win more government work.
They learn procurement procedures. They understand specifications. They develop pricing histories. They acquire equipment and employees. They establish performance records. They understand insurance and bonding. They know which contracts are approaching renewal.
In other words, successful JSEBs gradually acquire many of the advantages that JSEB was created to help smaller businesses overcome.
That's where distribution, tiers, graduation and unbundling become important.
Jacksonville Officials Have Asked Who Actually Gets the JSEB Money
This isn't a concern imposed on the program by The 101 Report.
Members of Jacksonville's JSEB Monitoring Committee have repeatedly asked how broadly contracting opportunities are actually distributed.
In 2023, committee member Kimano Edwards asked for information showing who was receiving contracts and whether the same JSEBs were repeatedly receiving work.
The question resurfaced more forcefully in 2025.
At a May 2025 Monitoring Committee meeting, officials reported substantial growth in the number of program participants and more than $100 million in JSEB-related procurement payments at that point in the fiscal year.
Committee member Monique Thompson asked how those dollars were distributed among the program's different business tiers and how many individual companies were actually receiving contracts.
JSEB Administrator Greg Grant explained that more detailed tracking had only recently begun. The minutes say future reporting would help determine whether “a few dominant firms are winning disproportionate shares of the contracts.”
That's an unusually important admission because it distinguishes two very different measures of success.
Participation isn't necessarily distribution.
Jacksonville can certify more businesses.
It can increase total dollars going to JSEBs.
It can reach or exceed its percentage goal.
And a relatively small number of experienced businesses could theoretically still receive a disproportionate share of the work.
Those things can all be true simultaneously.

Only About 17% of Certified JSEBs Received City Contracts in One Recent Period
A later Monitoring Committee discussion provides another important data point.
In September 2025, officials reported that approximately 17% of certified JSEB companies—nearly 100 businesses—had received City contracts during the fiscal year being discussed.
That means most certified businesses had not received City contracts during that period.
That statistic requires context.
Some certified companies may not have submitted bids. Some may not have been ready for available work. Others may operate in industries where the City had little relevant procurement during that period.
So the number shouldn't be interpreted as evidence that Jacksonville denied 83% of JSEBs an opportunity.
But it reinforces an important lesson for prospective participants:
Certification growth is not the same as broad distribution of contracting opportunity.
Getting certified gets a company into the system.
It doesn't guarantee that company will get the work.
What Does Jacksonville's 20% JSEB Goal Actually Measure?
That question deserves considerably more attention than it usually receives.
During the May 2025 Monitoring Committee discussion, Zaffaroni asked how the 20% goal should actually be interpreted.
Applying 20% to Jacksonville's entire City budget would produce a vastly larger number.
Officials explained that isn't how the calculation works.
The denominator involves qualifying procurement expenditures—such as applicable services and capital improvements—rather than payroll and other portions of the City budget. Grant also clarified that the dollars being discussed represented actual payments rather than merely contract allocations.
At the following June meeting, Procurement Manager Greg Pease explained another important distinction.
JSEB prime contractors work directly for the City. JSEB subcontractors work under another prime contractor.
Both arrangements count toward JSEB participation goals.
That's where the headline number becomes more complicated.
A dollar received by a JSEB as prime contractor on a protected set-aside and a dollar received by a JSEB subcontractor on a much larger project can both represent legitimate participation.
But they don't necessarily represent the same kind of opportunity.
And there is another question we're now investigating:
What happens when an already-certified JSEB wins a large unrestricted City contract through ordinary competition?
Does that spending also count toward Jacksonville's headline JSEB participation figure even though the JSEB program didn't reserve the contract?
Liberty gives us an unusually useful case study because it is simultaneously a certified JSEB and an established prime contractor capable of winning substantial unrestricted City work.
We'll follow those dollars in the next installment.

Jacksonville Is Already Trying to Improve JSEB Distribution
It would be misleading to suggest Jacksonville officials are unaware of these challenges.
During the May 2025 Monitoring Committee meeting, Grant identified two significant areas of focus: unbundling large contracts into smaller, more accessible opportunities and auditing participation schedules.
The City has also developed business tiers and more recently emphasized micro-business participation.
Those efforts acknowledge an important reality:
A company doing a few hundred thousand dollars in annual business doesn't necessarily compete on equal footing with a company approaching the upper end of JSEB's eligibility limits simply because both technically qualify as JSEBs.
Other jurisdictions have confronted the same problem in different ways.
Miami-Dade County, for example, uses small-business tiers and connects some set-aside opportunities to contract size, attempting to prevent the largest qualifying small businesses from automatically competing for every protected opportunity available to much smaller firms.
Jacksonville doesn't necessarily need to copy Miami-Dade.
But comparing systems can reveal different ways of answering the same question:
How do you help businesses grow without allowing yesterday's emerging businesses to crowd out tomorrow's?

Small Businesses Can Participate in More Than Bidding
There's another lesson in Zaffaroni's experience that deserves attention.
Successful participation in government contracting isn't limited to submitting bids.
Zaffaroni participates in the governance conversation surrounding JSEB.
He serves on and now chairs the Monitoring Committee, which discusses program performance, tiers, contract distribution, unbundling, graduation, reporting, outreach and changes to the program.
That involvement provides something valuable to any business owner:
information and understanding.
That isn't an argument that successful contractors shouldn't participate in government committees.
Quite the opposite.
It's an argument that more small businesses should participate.
If only companies already proficient at government contracting attend meetings, understand proposed ordinance changes and participate in policy discussions, businesses still struggling to enter the system risk having comparatively little voice in how that system evolves.
The Monitoring Committee's meetings are public, and Jacksonville publishes its membership, agendas and minutes online.
JSEB Monitoring Committee meetings and records
A small-business owner doesn't have to wait until a solicitation appears to participate.
Businesses can participate in the conversation that helps determine what future opportunities look like.
How Jacksonville Small Businesses Can Start Participating in JSEB
For businesses considering the program, the first step is determining whether the company meets the current statutory requirements and assembling the documentation necessary to establish eligibility.
Jacksonville provides its application and recertification materials online:
Jacksonville JSEB Application and Recertification
But don't stop at certification.
Prepare a useful capability statement. Make sure the City's procurement system accurately identifies the services your business can perform. Follow procurement forecasts. Study previously awarded contracts in your industry. Identify incumbent contractors. Watch expiration and renewal dates. Learn which contracts are set aside, which carry participation requirements and which are completely open.
And attend the meetings where the program itself is discussed.
The business that understands where government procurement is going can be in a much stronger position than the business that discovers an opportunity only after the bid is posted.

Jacksonville's JSEB Goal Is Worth Protecting—and Understanding
Nothing we've uncovered changes the fundamental value of what Jacksonville is trying to accomplish.
Small businesses face genuine disadvantages when competing against established companies for government contracts.
Creating pathways for those businesses to acquire experience, revenue, employees and capacity can strengthen Jacksonville's local economy while expanding the City's pool of qualified vendors.
The harder questions concern what happens after that pathway is created.
Who gets through it?
How many businesses actually receive meaningful contracts?
How much of Jacksonville's reported JSEB spending represents opportunities specifically created for emerging businesses?
How much becomes concentrated among experienced participants?
When has a successful small business actually emerged?
And who participates when Jacksonville changes the rules governing all of it?
Those aren't arguments against JSEB.
They're questions about whether Jacksonville is getting the maximum small-business opportunity from a program designed to create exactly that.
And they matter to more than taxpayers.
They matter to the small-business owner wondering whether there's actually a place at the table.
There can be. But understanding how the table works may be every bit as important as qualifying for a seat.


