Comment on FR Doc # 2011-25767

Document ID: SBA-2011-0009-0006
Document Type: Public Submission
Agency: Small Business Administration
Received Date: October 19 2011, at 12:00 AM Eastern Daylight Time
Date Posted: December 5 2011, at 12:00 AM Eastern Standard Time
Comment Start Date: October 5 2011, at 12:00 AM Eastern Standard Time
Comment Due Date: December 5 2011, at 11:59 PM Eastern Standard Time
Tracking Number: 80f56228
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This is comment on Proposed Rule

Small Business Subcontracting

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Could you increase size standards for general contractors to 50 million or higher? Even at that level, the contractor is mostly seeking projects in the $15 million range. Still small. Beyond this there are serious diconnects with procurement. Under the MATOCs, a contractor must produce a bond letter to confirm that they have a $10 million bonding capacity as a qualifer for submitting their proposal even though most of the task orders will be under $1 million in size. Very few 8(A) contractors can obtains such a letter and will need to partner with a teaming partner who can get the bonding for them. In turn the 8(A) contractor has to give away 50% of thier profit to the teaming partner. Not good. Secondly, for the SBA bond program, it can only go as high as $2 million singe. Gil Genn, my lobbyist and Sen Cardin were able to get an amendment in just in the nick of time in ARRA. But when ARRA sunsetted so did SBA's ability to back projects up to $10 million. We asked for $10 million so SBA could assist in providing the bond letters needed for MATOCs and $5 million for non stimulus work becasue the SDVOB were being sole source projects up to $5 million and needed SBA assistance. This joy is over now. For some reason SBA lost out when ARRA sunsetted. Set aside proejects for 8(A) firms can be as high as $4 million but SBA bond program only goes up to $2 million. So if you increase the size standards you need to increase SBA bond program limits as well or why bother. YOu will only create more frustration for contractors during this harsh economic times.

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