Comment on FR Doc # 2012-22259

NATIONAL ENVIRONMENTAL FUELS ASSOCATION Date: 11/10/2012 Khem R. Sharma, Ph.D. Chief, Office of Size Standards U.S. Small Business Administration 409 Third Street, S.W. Washington, DC 20416 Dear Mr. Sharma: On behalf of our member companies we are providing comment on the proposed rules regarding small business size standards for Agriculture, Forestry, Fishing and Hunting, RIN 3245-AG43. NEFA is a Non Profit Business Association that represents several companies that primarily deal with fuels management as well as a large amount of fire suppression work under interagency agreements and national contracts. The information we provide may not be indicative of the 10 year trend due to the facts that 2008 – 2010 fire seasons were the slowest on record. And as indicated in the SBA analysis for that period using data obtained from the Central Contractors Registry, it does indicate a reduction in revenue for that period. However, 2012 was a much more normal “fire season”, and we expect that CCR will show that revenues for 2012 will be about 40% over the 3 year average we are providing based on a very active fire season as well as some disaster assistance, and fuels management contractors. The fuels management industry encompasses companies that provide a wide array of services doing fuels management projects such as thinning, prescribed burning, and others. In addition, they provide services for wildfire suppression activities such as 20 Person Hand crews, water handling equipment, port a potties, mobile shower units, potable and grey water trucks, large fire camp support and transportation. Many fuels management and fire suppression companies also are involved with Disaster relief under their fire suppression contracts, and many of our member companies spend a large amount of time assisting with natural disasters every year. Some examples are assistance provide for disaster relief