The U.S. Small Business Administration (SBA) has extended the deadline for public comments on its proposal to change its size standards, a move that ACRA called on the agency to make last week.
As previously reported in ACRASphere, the SBA has proposed massive changes to its size standards, which if implemented would redefine many more CRM firms as small businesses. For example, the size standard for NAICS code 541620, Environmental Consulting Services, would increase under the SBA’s proposal by 1453 percent, from $19 million to $295 million.
Initially, the SBA allowed the public to comment within 30 days, ending September 21. However, in a notice that is scheduled to be printed in the Federal Register on Thursday, the SBA indicates that, “[i]n response to requests for additional time to comment,” the new deadline for comments will be November 20, 2026.
In its comments submitted last week, ACRA urged the SBA to allow for more time to comment. ACRA pointed out that the proposed changes would have massive impacts on CRM firms and that smaller companies may need more time to fully digest the changes. “Small businesses have, by their very definition, limited capacity,” ACRA wrote. “Small CRM firm owners spend a considerable amount of time in the field conducting cultural resource reviews, meeting with clients, writing cultural resource reports, competing for new contracts, and handling countless other administrative tasks necessary to keep their business running. This means they have limited bandwidth to consider the ramifications of the SBA’s proposals – particularly as many firms perform field work in the summer and early autumn months. The weeks before the end of the federal fiscal year are also especially frenetic for small businesses that contract with the federal government. In addition, small firms have less access to consultants and other experts than larger companies, who can help them conduct assessments of proposed rule changes.”
ACRA also pointed out that the initial 30-day comment period ran counter to the intent of executive orders which direct agencies to allow at least 60 days for the public to comment on regulations.
ACRA’s Government Relations Committee continues to analyze the SBA proposal and welcomes feedback from ACRA member firms.