Comments on FAR Case 2015-015 Regarding the Federal Strategic Sourcing Initiative - FSSI

August 19, 2016

Includes comments on FAR Case 2015-015

  • The Proposed Rule Should Not Be Applied in Small Business Set Asides
  • The Brief Analysis Should Allow for Flexibility
  • The Notice of Proposed Rulemaking Understates the Impact on Small Businesses

Our Comments in Response to the GAO's Proposed Rule Regarding Electronic Filing System and Filing Fee

May 17, 2016
Read our full comments here Excerpts Filing Fee The new rule envisions imposing a filing fee of $350 on protesters. We respectfully request...

Comments on Proposed Rule Regarding Electronic Filing System and Filing Fee

May 16, 2016

Includes comments on:

  • Filing Fee
  • Redactions

Comments on Advance Notice of Proposed Rulemaking Regarding Women-Owned Small Business and Economically Disadvantaged Women-Owned Small Business Certification

February 16, 2016

Includes comments on:

  • SBA Should Delay Implementation and Work to Change the Law
  • SBA Certification Program
    • If SBA Adopts the Certification Requirement, SBA Should Be the Only Certifier
    • Streamlined Application Process
    • Concurrent Certification Through 8(a) Program
    • Term of SBA Certification
  • Third Party Certification
    • New Regulations & Procedures Are Needed if SBA Permits Third Party Certification in Addition to SBA Certification
    • All Certifiers Should Apply or Re-Apply
    • Term of Third Party Certification
    • No Repository Access for Third Party Certifiers
    • Mentor-Protégé Agreements and Joint Venture Agreements
    • SBA Should Clarify Applicability of the Certification Requirement to WOSB and EDWOSB Industries
  • Certification by States and Other Federal Agencies
    • State WOSB/EDWOSB Certification Authority
    • Acceptance of DBE Certifications in Determining Ownership and Control
    • State Entities’ Expertise
    • Other Federal Agency Certification, Including Contract-Specific Certification
    • WOSB/EDWOSB Protests of Firms Not Certified by SBA

Comments on Proposed Rulemaking Regarding WOSB and EDWOSB Certification

February 16, 2016
PilieroMazza recently submitted comments on the U.S. Small Business Administration's Advance Notice of Proposed Rulemaking Regarding Women-Owned Small Business and...
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