Comment on FR Doc # 2011-11717

Ladies and Gentlemen: • Based on Ameican Instute of Architects data, currently the overwhelming majority of architectural firms (91.7%) have net receipts less than $4.5 million. I do not support the SBA’s proposed change in size standard for architectural services to $19 million. The current $4.5 million in net receipts standard already puts smaller practices at a disadvantage. Increasing the standard further tilts this already biased participation towards larger mega-firms, which by virtue of their size already control most of the Federal market. • It has long been shown that smaller firms are a better source for innovation and quality in design. Smaller firms have lower overhead costs and produce more design value per dollar spent on design fees. • Rather than increasing the SBA standard, as regards architectural services, there is a greater need for the SBA to encourage micro-status for architectural firms to begin to enable the overwhelming majortiy of architectural firms the ability to participate more fully in the federal market. R. Burton Ward ARCHITECH