SEBAC Advocacy Efforts and Letters to Agencies


– SEBAC advocates for Small Business set-asides with all of the federal agencies and we have had many successes

– SEBAC has advocated for and received extensions on multiple proposals

– SEBAC advocates for revisions to qualification requirements

– SEBAC has succeeded in having the correct NAICS code assigned

– SEBAC alerts our members to all Sources Sought announcements

– SEBAC has advocated for inclusion of the Economic Price Adjustment


Architect-Engineering Services to Support the U.S. Air Force Mission and AFCEC Environmental Program Worldwide AEES2023 (follow on to AE13ES).

SEBAC letter was sent to express concern regarding the inclusion of Large Business contractors as Primes for the Architect-Engineering Services to Support the U.S. Air Force Mission and AFCEC Environmental Program Worldwide AEES2023 (follow on to AE13ES) and to request that the AEES2023 contract be set aside for eligible Small Businesses. We provided multiple Sources Sought responses to the recent AFCEC Market Research requests showing there is both sufficient capacity and capability within the Small Business community to perform all four Functional Areas in support of the AEES2023 contract. Click here for the letter.

GSA OASIS+ MAC Program, Small Business, Research & Development Domain, under North American Industry Classification System (NAICS) codes 541713; 541714; 541715, including Exceptions 1, 2, and 3; and 541720.

SEBAC requested that GSA re-evaluate the minimum annual value for QPs submitted to the R&D SB domain and adjust this value to align with the other GSA SB domain minimum annual values and typical industry funding: suggested lowering the R&D SB QP minimum annual value to $250,000, which is more consistent with the current OASIS SB Pool 4 contract and with industry practices and this will promote competition from SBs and socioeconomic SBs in this domain and provide the government buyers with access to a qualified pool of contractors to support the comprehensive R&D opportunities for the OASIS+ MAC Program. Click here for the letter.

Solicitation W912WJ23R0002 Environmental Planning and Consulting Services Indefinite Delivery/Indefinite Quantity Small Business Contract for Various Projects Locations Throughout the Northeastern United States.

SEBAC asked that Attachment C “Contractor Evaluations”, which is requesting very specific project details that most large and small businesses likely do not have easily accessible, be removed from the response requirements, and asked that this IDIQ response date be extended to two weeks after the remaining responses to questions are posted. Click here for the letter.

Solicitation W912BV21R0019 – $45M Small Business Set-Aside Multiple Environmental Government Acquisition (MEGA) Indefinite Delivery Contract (IDC) Multiple Award Task Order Contract (MATOC) for Environmental Remediation Services (ERS) Projects Within the Southwestern Division (SWD) Boundaries and As Assigned in Accordance with UAI Sub-part 7.1 and ER 5-1-10.

SEBAC asked that the Tulsa District provide an extension to the proposal response date to allow the Tulsa District to answer the questions and align this RFP with the due date for the Unrestricted MEGA IDC MATOC for ERS which is currently due December 7, 2021, due to the fact that the RFP was issued on March 26, 2021, the current response date is November 16, 2021, and inquiries for this opportunity are collected via Bidder Inquiry in ProjNet, and to-date, there are more than 60 questions from the small business community that have gone unanswered since August 30, 2021 impacting the government’s ability to conduct a timely and equitable evaluation of proposals. Tulsa District responded by extending the due date to January 11, 2022! Click here for the letter.

Sources Sought Notice ID 21_PR_22 DLA Disposition Services – Hazardous Waste Removal and Disposal on Guam, NAICS 562211

SEBAC asked this IDIQ remain a Small Business set-aside as it has been in the past, noting that: “Representing a number of small businesses that meet the requirements under NAICS 562211 and offer the skills necessary to successfully complete this work, we encourage DLA to allow this to remain within the small business community”. Click here for the letter.

Solicitation W9128F21R0037 8(a) Indefinite Delivery/Indefinite Quantity (ID/IQ) Single Award Task Order Contract (SATOC) with capacity of $47M for Environmental Remediation Services with Military Munitions Response Program (MMRP) in support of the U.S. Army Corps of Engineers, Northwest Division (NWD) and existing and future customers

SEBAC noted that this RFP is well suited for Small Businesses under 562910, but for 8(a) companies not in joint ventures, the criteria are misaligned with the SBA’s 8(a) Business Development program, such that the current 8(a) sole source maximum is only $4M, and to have two completed projects equal to or greater than $4M is the amount of two entire IDIQ sole source contracts for an 8(a) company. SEBAC asked the Omaha District that the experience requirements criteria be revisited and aligned with 8(a) firm capabilities, specifically, the $4M value on past experience should be revised to not more than $2M, and this request was granted! Click here for the letter.

DOD POL Worldwide Construction – WERC 09 Requirements (F41624-03-R8046)

SEBAC asked that USAF/AFICA consider a total small business set-aside IDIQ under NAICS 562910 for Environmental Remediation and Fuels (broad scope which falls under the definitions used in the WERC 09 IDIQ SOW). Click here for the letter.

Solicitation W912DR21Q0069 – Fuel Removal, Cleaning, and Removal of Two Aboveground Storage Tank(s), Joint Base Fort Myer Henderson Hall, VA

SEBAC asked that the USACE Baltimore District revise the NAICS code specified for the subject solicitation, adding that SEBAC’s position is that this procurement should be classified under NAICS 562910, “Environmental Remediation Services” with a size standard of 750 employees, and this request was granted! Click here for the letter.

Notice ID PANNGB-21-P-0000-010092 Number 21-A4-061 Environmental Investigation and Remediation Services at ANGB Atlantic City, New Jersey and ANGB Gabreski, New York – Contract Opportunity Type: Sources Sought

SEBAC asked that the Army National Guard set this procurement aside for the small business community as a 100% Small Business set aside under the prescribed NAICS code. Click here for the letter.

Notice ID W9124J-21-R-0038 Environmental Remediation MAIDIQ (ERMA2022) Sources Sought

SEBAC requested 100% Small Business set aside for this notice. Click here for the letter.

Solicitation #W912DS21R0006 (Total Small Business Set-Aside) MATOC (IDC’s C-208,
C-209 & C-216) General Architect-Engineer (A-E) for Primarily Navigation, Coastal Flood Risk Management and Ecosystem Restoration Projects in the NAN/NAD Region

SEBAC voiced disagreement with some of the requirements of this solicitation. Click here for the letter.

SBA Bona Fide Office Rule Changes for Federal Construction Contracts

SEBAC voiced disagreement with recent SBA interpretation of the Small Business Act and associated application to CFR 124.501(k). Click here for the letter.

Sources Sought Announcement: US Army Corps of Engineers, New England District
A‐E HTRW ID/IQ Services MATOC Strategy, NAICS 541330

SEBAC requested that the planned acquisition referenced above be fully set‐aside only for SB/SDB concerns, and that large business
concerns be excluded from this acquisition. Click here for the letter.

FUDSChem (EMSS II) Procurement

From a SEBAC member

“I am following up on our call from a couple of months ago regarding the re-compete for the FUDSChem database management (EMSS II) procurement. After the sources sought which was put out solely under IT, the solicitation ultimately came out as a HUBZone set-aside split between two GSA schedules (IT and ENV). It was exactly what we were hoping for, and we were successful in our bid.  Thank you for your time and support, and for the support of SEBAC!”

Comments on the Proposed Rule for JVs and 8(a)s  
Submitted to website – August 4, 2020

SEBAC expressed support of changes to subparts 9.1 (Responsible Prospective Contractors), 15.3 (Source Selection), 19.3 (Determination of Small Business Status for Small Business Programs), and 19.8 (Contracting with Small Business). Click here for the Comments.

Environmental and Munitions Mandatory Center of Expertise International Remediation & Environmental Services Two (IRES2) Sources Sought Notice – June 23, 2020

SEBAC requested USCE Huntsville Center to consider revising the requirements for the proposed solicitation to a total small business set aside under NAICS 562910 (750 employees) or 50% of the awards be reserved for small business if the acquisition strategy doesn’t support a total small business set aside. Click here for the letter. 

U.S. Army Corps of Engineers, Baltimore District, MAMMS Request for Proposals – Solicitation W912DR19R0051 – April 7, 2020

SEBAC requested USACE Baltimore to consider revising the proposal submittal requirements to take into account the significant restrictions on the environmental industry caused by the COVID-19 virus. Click here for the letter. 

U.S. Army Corps of Engineers, Baltimore District, Multiple Award Environmental Services (MAES) Task Order Summary – April 7, 2020

SEBAC asked USACE Baltimore and SBA to consider setting aside two pending Air Force Optimized Remediation Contract (ORC)task orders for small businesses. Click here for the letter.

SBA Regarding the GSA MAS Consolidation – February 3, 2020

SEBAC requested the SBA to weigh in on the GSA MAS and support the small business community subject to the 562910 NAICS by providing guidance to GSA on the proper use and application of this size standard. Click here for the letter.

U.S. Environmental Protection Agency Emergency and Rapid Response Services Contract (ERRS) – December 17, 2019

SEBAC asked EPA to review and revise the process employed during the solicitation for the Emergency and Rapid Response Services (ERRS) contracts. Click here for the letter.

U.S. Army Corps of Engineers, Sacramento District, MEGA ERS – Unrestricted; Notice ID – W91238-20-S-2078 – December 12, 2019

SEBAC requested USACE Sacramento and SBA to reevaluate the need for designating the planned Sacramento $50M ERS contract as an unrestricted solicitation as per the Rule of Two. Click here for the letter.

GSA MAS Consolidation SIN 562910 – November 6, 2019

SEBAC asked GSA to change the small business size standard basis of $20 million annual revenue for SIN 562910REM to the 750 employee-based size standard for environmental services, consistent with SBA’s definition. Click here for the letter.

GSA OASIS On-Ramp Solicitation – September 30, 2019

SEBAC expressed concerns about an obvious change in support for Small Business participation in a solicitation circulated by the General Services Administration (GSA). The request for proposal (RFP) is for Unrestricted awards for the One Acquisition Solution for Integrated Services (OASIS) Open Season On-Ramp for Pools 1, 3 & 4. This is a Multiple Award (MA), Indefinite Delivery, Indefinite Quantity (IDIQ) Unrestricted opportunity under Solicitation Number GS00Q-13-DR-0001-P1P3P4. Click here for the letter.

Past Performance Experience – Period of Performance Request Change from Five Years to Ten Years – September 5, 2019, and September 18, 2019

SEBAC expressed concerns regarding the Past Performance Experience timeframe criteria when responding to USACE solicitations. Our primary concern is the use of a five-year window for presenting past experience in an industry where major projects of this nature fall off the five-year resume very quickly. Our goal is to expand the past experience timeframe to ten years, not unlike the recent solicitations put out by the Kansas City District for the Welsbach SATOC and the Unrestricted PRAC. Click here for the letter.

On September 18, 2019, a similar letter was sent to the Corps of Engineers, Omaha District. Click here for the letter.

BRAC FY 2020 PBR Follow On Acquisition Strategy Solicitation Number: FA8903-18-BRAC-RFI-01 – August 30, 2019

SEBAC expressed concerns regarding the Air Force’s acquisition strategy for the OCONUS PBR Follow On contract for Galena Air Force Station and Kulis Air Base identified in the BRAC BECOS Update presented by Daniel Medina on 14 August 2019 as “Full and Open”. Click here for the letter.

NAVFAC SW Procurement Strategy – N6247319R3001:  Environmental Multiple Award Contract for Remediation of Various Radiological Contaminants at Various Navy and Marine Corps Installations in the NAVFAC SW and NAVFAC LANT Aor, RADMAC – July 16, 2019

SEBAC asked the SBA weigh in on the Navy’s deliberations relative to this procurement strategy, as this contract is ideally suited for a total Small Business Set-Aside under the SBA Rule of Two. A review of the Federal Procurement Data System (FPDS) NextGen, of recent and ongoing US Army Corps of Engineers, Department of Energy and NAVFAC contract awards and task orders issued under these contracts will demonstrate a capable pool of contractors to support this effort. Click here for the letter.

US Army Corps of Engineers Pre-Placed Remedial Action Contracts – June 21, 2019

SEBAC requested USACE Kansas City and SBA reevaluate the need for two separate acquisitions (given the fact Federal Procurement Data System statistics for these contracts – Pre-Place Remedial Action Contracts (PRACs) – are substantially under-subscribed. We believe the right course of action is a single Small Business PRAC. Click here for the letter.

SEBAC Responds to the 809 Panel Recommendations – March 7, 2019

On March 7, 2019, SEBAC sent individual letters to members of the U.S. House and Senate Small Business Committees urging them to strike from the National Defense Authorization Act (NDAA) the Panel 809 recommendation to do away with small business set-asides in favor of a 5% price preference. Click here for an example of the letters that were sent. SEBAC members were urged to contact their senators and representatives on this important issue. For more information on the issue, click here for the Koprince Law LLC blog.

SEBAC’s Comments to SBA Proposed Rule – February 4, 2019

RIN 3245-AG86, National Defense Authorization Acts of 2016 and 2017, Recovery Improvements for Small Entities After Disaster Act of 2015, and Other Small Business Government Contracting
Click here for the letter.

The Acquisition Strategy Update

The Acquisition Strategy Update is a recap of recent awards and upcoming procurements and sources sought in NAICS code 562910 and 541620 prepared for SEBAC by FEDMINE, an Associate Member. Information about and from agencies we track is often included. Click here for the latest edition. Earlier Updates are available here.