Comment on FR Doc # 2011-11717

Dear Ms. Sharma: I am an employee of a small consulting firm (< 60 employees) who specializes in surface water quality related issues, and with expertise in water quality criteria and related services which support all facets of the Clean Water Act. It has recently come to my attention that the Small Business Administration’s (SBA) is reviewing SBA’s current size standards for Sector 54 Professional, Scientific and Technical Services. I am writing this letter on behalf of other scientists and engineers like myself to offer encouragement for the SBA to make the necessary changes to current Section 54 size standards to better reflect current industry realities. The President of my firm has written a letter detailing our position as a small business trying to compete with a number of much larger (in excess of 500 employees) firms, e.g., engineering with one or more environmental divisions, who are ever-increasing in size and capabilities as they merge, buy-out, usurp one another to capture a larger share of the available government contract work, and, while I am aware of the fact that some smaller firms may object to an increase in size standard, the fact remains that: 1) the SBA has only nominally changed its current size standard for Sector 54 categories for many years by small, incremental “inflationary” amounts, 2) the government Agency’s themselves find the current size standard inoperable for many of its on-going small-business oriented/run programs, and 3) the work required of contractors such as myself to support such programs places more and more emphasis on diversity in staffing, as well as a greater premium on office, laboratory and field capabilities and supporting equipment. So, with that said, I applaud the SBA in this endeavor and encourage the SBA to follow through with its current proposed size standard of $14 million for at least the following NAICS Sector 54 categories: 541380, 541611, 541620, and 541690.