Comment on FR Doc # 2012-10708

If this rule is enacted then the following must also be a part of the rule: 1) Must have one of the following: a) the winning contractor is not obligated to pay the same salaries or benefits, or if they are b) the solicitation must provide direct labor information (salaries) for every labor category and benefit costs. Otherwise the incumbent will have an unfair advantage. Without this information prospective bidders will have to estimate direct labor and benefit committments. If they underbid and the contract is fixed price they will have to hire people at a higher expense. If they over-bid they could lose the competition; 2) The solicitation evaluation critieria must focus on transition plans versus staffing plans; 3) If key staff resumes are required then Government must provide information regarding the key incumbent personnel they expect to be hired. Or not include key staff as an evaluation factor. For example, a bidder might have several very qualified and experienced staff who can bring new ideas and capabilities to the contract. If they propose these non-incumbent staff they are likely not compliant. If they have to hire key incumbent staff then the Government cannot assign evaluation factors to Key Staff since every bidder has to promise to retain incumbent staff.