Comment on FR Doc # 2011-26207

The definition of industry NAICS Code 561210, Facility Support Services is establishments primarily engaged in providing operating staff to perform a combination of support services within a client's facilities. These establishments provide operating staff to carry out these support activities; but are not involved with or responsible for the core business or activities of the client. For government contracting this service involves the supply of personnel to work on a government site under the purview and in accordance with government rules and regulations, which are generally much more detailed and sophisticated than commercial practices. However, Note 12 to the SBA Size Standard Table states: 12. NAICS 561210 – Facilities Support Services: a) If one or more activities of Facilities Support Services as defined in paragraph (b) (below in this footnote) can be identified with a specific industry and that industry accounts for 50% or more of the value of an entire procurement, then the proper classification of the procurement is that of the specific industry, not Facilities Support Services. It is proposed that all support services performed on a government site fall under this larger size standard ($35.5 million) due to the added skill sets needed to perform work on a government site vs the commercial market. For example the operation of a motor pool (garage) on a military base requires a wider range of skills and is much more complex than operating a privately held commercial garage.