> MAJOR CONTRACTING SERVICES, INC.

MCS Portable Restroom Service 3129 Delta Dr. Colorado Springs, CO 80910

Col Springs:: (719) 391-0176 Online:: <Toiletman@aol.com> FAX:: (719)
391-3764

April 8, 2008

General Services Administration

Regulatory Secretariat (VPR)

1800 F Street, NW; Room 4035

Attn: Ms. Diedra Wingate

Washington, DC 80405

Subject: Comments Re: FAR Case 2006-034, Socioeconomic Program Parity

Dear Ms. Wingate:

As the owners of a Service Disabled Veteran (SDVet) Owned Small
Business, my partner and I would like to submit the following comments
regarding the proposed changes in the Federal Acquisition Regulations
(FAR) relative to our business Socioeconomic Program Parity.

The changes, as proposed, are very good and, in our opinion, reflect the
intent of Congress and Executive Order 13360. The only real "deficiency"
that I find in the proposed changes concerns the dollar limits on Sole
Source Awards. As presently stated in FAR Part 19.1406 the dollar limits
imposed on Sole Source acquisitions may not exceed \$5,000,000 for
manufacturing requirements and \$3,000,000 for all other requirements.

Our company is a [service business]{.underline} and operates under NAICS
Code 562991. When FAR Part 19.1406 was originally drafted, circa 2004,
the cost of operating a business in our industry was significantly lower
on a unit basis than it is today, and the level of military training
activity, our principal government customer, [requiring]{.underline} our
service was considerably lower. This is underscored by the following
example. After labor, our second highest direct expense is fuel, and, as
I am sure you are well aware, the cost of fuel has more than doubled
since the referenced FAR section was drafted and approved. Also, this
cost literally shows no sign of even leveling off -- much less reducing.
This makes it even more difficult to generate "fair and reasonable
pricing" for out years (Option Years).

Also as I noted, at that time, training activity on many military
installations, [our]{.underline} primary customer, was generally at a
much lower intensity, but with the deployment of forces overseas, the
level of training activity has increased to a much much higher level on
most installations, and with that the need for our service has grown
exponentially and along with that the cost of doing business. In
addition, many installations are now "adding" services that were not
generally included in the past, such as hand wash units, and which also
lends to the increase in "cost".

In our NAICS Code, 562991, the availability of competition among SDVet
businesses, as defined and required under FAR Part 19.1405, is
"sporadic" at best because of the nature of our industry. Most SDVet
Small Businesses in our industry are local "mom and pop" type businesses
who, unlike our business model, are not interested in leaving their
immediate area of operations. That leaves many installations, that would
otherwise like to award a requirement to an SDVet Owned Small Business,

***"A Service Disabled Veteran Owned Small Business"***

and especially to one with the depth of experience and quality of past
performance that our company offers, with only one option - FAR Part
19.1406, Sole Source; however, more often than not they will end up
[having]{.underline} to go out for Solicitation as a Total Small
Business Set Aside simply because of the low dollar limits on Sole
Source Awards.

Another "problem" that indirectly effects contracts in our NAICS Code,
562991, is that because of the increasing level of training the
inability to accurately predict actual usage / requirements is rapidly
becoming commonplace. Therefore, a common occurrence in today's
procurement environment is in order to meet ongoing requirements
quantities (and thus "dollars") the Contracting Office will, at some
point in the contract life, begin to "borrow" quantities from future
Option Years. This "borrowing" directly affects the "scope" element of
the contract and thus creates an earlier than anticipated requirement
for re-solicitation.

As I noted above, given today's business environment, I would offer that
these limits could / should justifiably be increased to the vicinity of
\$7,500,000 to \$10,000,000 for Manufacturing, and \$5,000,000 to
\$7,500,000 for all other requirements.

Thank you for the opportunity to provide comment. If you have questions
please do not hesitate to contact me.

With regards,

*Merrill D. Austin*

Merrill D. Austin

Vice President / Co-Owner

***"A Service Disabled Veteran Owned Small Business"***