Comment on FR Doc # E8-23139

Document ID: SBA-2008-0006-0003
Document Type: Public Submission
Agency: Small Business Administration
Received Date: October 15 2008, at 04:49 PM Eastern Daylight Time
Date Posted: October 24 2008, at 12:00 AM Eastern Standard Time
Comment Start Date: October 1 2008, at 12:00 AM Eastern Standard Time
Comment Due Date: October 31 2008, at 11:59 PM Eastern Standard Time
Tracking Number: 8075ed39
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Dear Ms Korbol: I’d like to comment on the proposed rule “the women-owned small business federal contract assistance” in comparing the CCR (Central Contractor Registration), and SBO (Survey of Business database). In past few years, WOBS improved the federal funding from $4.6 billion to $11.6 billion and created the more opportunities for the women entrepreneurs in different fields. CCR is a great idea to provide a sound base to identify underrepresented industries in WOSB showed both for the public and Federal. This database use represents the official and objective of the WOSB. Now, we have two databases, CCR, primary registrant database for Federal government; and SBO, a non-public data. CCR collects, validates, stores and disseminates data in support of agency acquisition missions for many years. It is public, well-organized and has been used in other fields also. Thus, it has lots of practical experience and solid technique support. Moreover, it is easy to approach the internet and present to the whole public. It increased the transparency of the WOSB and enhances more people to apply for WOSB according to its easy approach. However, it has its own disadvantage. It does not provide the information concerning the revenue of each industry, which has a separate code in NAICS. SBO has a separate code system. Each company will report its revenue in separate category fitting in the different codes, which indeed helps economists estimate the funding for each field. However, in nowadays situation, many industries are overlapping. It is not very applicable to report the revenue just in one category. Also, it enhanced the possibility of over-estimate the overall revenue, which will deter the people who want to join the WOSB. Furthermore, the SBO is gathered every five years. We doubt that whether the former 5 years data will represent today’s economy situation. The most important, it does not open to the public. The public may concern about the funding use and revenue in WOSB. It might cause the crisis of public trusty. After the comparing and contrasting of CCR and SBO, I confirm there is more advantage in CCR system than SBO. I suggest you consider continuing use CCR in WOSB for long-term progress. Sincerely, Hanqi Luo

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