Dear Ms. Fernandez:

We are writing to submit comments on the U.S. Small Business Administration’s (“SBA”) above-referenced proposed rule, issued May 1, 2015, 80 Fed. Reg. 24,846. Our firm represents small businesses, including women-owned and economically-disadvantaged women owned small businesses (“WOSBs/EDWOSBs”), operating across the government contracting spectrum. Many of the WOSBs/EDWOSBs we represent and have talked to have been eagerly anticipating this rulemaking. The proposed rule places the SBA’s WOSB Program on equal footing with other SBA government contracting programs in providing for award of sole source contracts to WOSBs/EDWOSBs. We concur with what SBA is proposing in this rulemaking and commend the agency for its efforts. We urge the SBA to issue the final rule in August 2015, the timetable proposed by the SBA in its Semiannual Regulatory Agenda (80 Fed. Reg. 35,098, 35,102).

Sole Source Authority -

We are in favor of SBA’s proposal to establish the procedures whereby Federal agencies may award sole source contracts to WOSBs and EDWOSBs and to provide a mechanism to protest such awards. This is welcome news for WOSBs and EDWOSBs, as sole source awards are an additional means by which WOSBs and EDWOSBs may do business with the Federal government. We agree with SBA that the Federal Acquisition Regulation (“FAR”) will need to be amended to include this sole source authority so that there is no conflict between the SBA’s rules and the FAR.