Comment on FR Doc # 2012-17440

Small Business- I am the owner of R A Burch Construction, based in Ramona California, founded in 1984. R A Burch specializes in government DOD construction work. Until a few years ago, we were classified as a small business by the SBA standards(33.5 million), at that time there were no “set aside” for standard small business, and we competed against large and other small business firms for government contracts. When the small business demonstration program ended, and the government began to set aside projects up to 30 million in size for small business (should not set aside any projects over 10 million), we are now excluded from those projects. Larger projects require past performance qualifications with similar size projects in order for us to bid on them, so we can’t qualify to bid. The combination of the government setting aside projects of 10 to 30 million for “small business”, combined with prequalification for the larger projects, has frozen us out of a market that we have exceled in since 1984. We, and quite a few other companies that had just crossed the threshold to “large business” are having a hard time finding projects to bid on. Most “small business” companies are not able to bond and perform projects of 15 to 30 million, so these set aside projects are being competed for by a very small slice of small business, with very little competition. Our revenue for the last few years is just over that, about 48 million, and we are forced to compete with companies who have revenues of over one billion a year. Because they are that large it is much easier for them to pre-qualify to bid the government contracts and their resources obviously dwarf ours. The steps that the government / SBA has taken in the last few years, have resulted in damaging the ability of recently graduated small to mid-size businesses like ours, who need those 10 to 30 million dollar projects to be open competition. It makes no sense to set aside projects over 10 million in siz