Comment on FR Doc # 2011-29445

Education and Training Resources (ETR) has been a small business contractor with USDOL/ETA, Office of Job Corps for nearly 15 years. ETR is currently the prime contractor for the management and operation of 4 Job Corps Centers, all of which were set-aside procurements for 100% Total Small Businesses. Each of these center operations, at the time of contract award, were poor performing centers. ETR, during its tenure as prime small business contractor, has significantly improved the overall performance of these centers. In short, ETR has spent nearly 15 years becoming and experienced, capable and qualified Job Corps center contractor/operator. In the past 10 years, there have been 8 other small business Job Corps center contractors who are no longer operating Job Corps centers as small businesses. Recognizing that Job Corps Centers already have Special Considerations under the SBA's Small Business Size Standards for Educational Services, and based on our experience as a current small business Job Corps operator, ETR firmly believes that this Special Consideration Size Standard should be increased from $35.5 Million to $50 Million. Within the next 2-3 year period under the current $35.5 Million Size Standard, ETR will no longer be eligible to compete for any of the 4 current Job Corps Centers we operate. In short, after improving the performance and quality of these Job Corps Centers as a prime small business contractor, ETR will be not be eligible to compete for them, simply and solely because we now exceed the current $35.5 Million Size Standard. The SBA, USDOL/ETA, and Office of Job Corps do not have any type of small business "graduation plan or process" in place to permit successful small businesses to continue to compete as an incumbent contractor for Centers they operate at the time they exceed the current SBA Size Standard. The management and operation of Job Corps Centers is unique for small businesses, as evidenced by its current SBA Special Consi