Comment on FR Doc # E9-25196

As the SBA itself knows, when it makes a change to the size standard of an industry, it almost necessarily hurts some small businesses in its attempt to help others. (Here we refer only to contract opportunities for businesses, not loan opportunities.) More specifically: (a) When size standards are decreased, companies below the new standards benefit at the expense of companies between the old and new standards that suddenly are forced to compete as large businesses for contracts. (b) When size standards are increased, companies between the old and new standards benefit at the expense of companies below the original size standard that then have to compete with more and larger companies for small-business contracts. So, while it's true that increasing size standards allows the SBA to help more businesses, it is also true that increasing size standards makes the playing field among small businesses less level, with larger small businesses having obvious competitive advantages over smaller business that may be only 20% or less of their size. An increased size standard tends to promote the further growth of companies that have already grown and well established themselves at the expense of companies that haven't yet. It is our judgment that the SBA Size Standards Methodology White Paper (published April 2009) may not adequately take this tradeoff into account when assessing size standards. We believe that the number of "winners" and "losers" of a size standard change, which to our understanding can be evaluated through assessments of "Distribution of firms by size," should perhaps be given more consideration in the methodology, as should the potential impact on both winners and losers. (Additional related comments follow as separate submissions.)