Comment on FR Doc # E9-25196

If I understand the methodology correctly, it appears the new small business size standards are partially based on an economic census from 2007 and partially on information entered by private sector companies in the Central Contractor Registration database. The current recession did not start until late 2007, and it has been a period of devastation for most businesses in NAICS Sector 54. The SBA is wrong to use a census from 2007 as a guideline for setting size standards when Sector 54 businesses have receipts much different today than in 2007. For example, my company has 50% fewer employees and 35% less revenue than in 2007. I also believe that revenue passed through to subcontractors should not be included in the calculation of annual receipts. In Sector 54, there is a considerable amount of subcontracting. It does not seem appropriate for the prime contractor to count revenue from a client as a receipt, then pass on a portion of the revenue to a first tier subcontractor, who also counts the revenue as a receipt. That first tier subcontractor may even pass on a portion of the receipts to a second tier subcontractor who counts the revenue as a receipt. The same dollar is being counted as a receipt three times in this scenario. I also feel government agencies should reduce the size of contracts that are being set aside for small businesses. Fee ceilings for Sector 54 contracts have increased considerably while size standards have remained constant. Often, a small business will include a large business subcontractor on its team just so the anticipated workload can be handled. This seems to defeat the purpose of set aside contracts. Government should set aside contracts with values that match the capacities of small business. Then, 100% of the contract revenue might flow to small businesses, benefiting both the small business and the government agency with small business subcontracting goals to meet.