I commend the SBA for taking a look at size standards as this has been been addressed for some time; however, the rationale for increases of these amounts and for a select group of NAICS codes within Sector 56 is flawed when taking into account the industires involved. These increases range from 180% to over 300%. While I agree that lowering the size standards is not in the best interest of the small business community, it is also not in the best interest to raise levels this much at one time. This is not the answer to fostering small business inclusion in government contracting, nor will it provide financial means in the form of SBA programs and loans to true small businesses.
The SBA should phase in changing the size standards much as they are planning with regard to addressing all NAICS codes.
The size standards should be raised approximately 50 to 75% immediately, across all NAICS codes within Sector 56. This will provide true small businesses with the ability to continue to seek SBA assistance and foster positive competition and contribution by true small businesses in federal contracting.
This step would be a more accurate reflection of true small business size standards over this recent recession. Doing a similar increase in other Sectors would also be appropriate, then perform a full review of the SBA program/loan data, amount of federal contracting participation by small business, andother factors, within two to three years to determine if another increase is appropriate.
Thank you for allowing industry to comment on this matter.
Allowing more contracts to be competed among true small businesses would also foster increased small business participation. Taking some of the 8(a) program set aside contracts that are not competed but sole sourced and making them competitive small business set asides would allow industry to compete and improve as a whole.
Comment on FR Doc # 2011-26207
This is comment on Proposed Rule
Small Business Size Standards: Administrative and Support, Waste Management and Remediation Services
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