OMB proposes consolidating forty-six industries into eighteen. Tested against the government's own data: eleven of the eighteen exactly duplicate codes that already exist, and the twenty-eight industries being eliminated carry $29 billion in annual federal obligations.

The FAR Council invited small entities to comment on the existing regulations the overhaul would remove. ASBCC accepted — and counted, from the government's own data, what the Council's analysis never did.

Sixteen pages on what the rewrite of Parts 5, 6, 7, and 10 does to the front door of the federal marketplace — grounded in our reproducible analysis of roughly 30 million contract actions, FY2022–FY2026.

Before commenting on substance, ASBCC asked the FAR Council for adequate time — 90 days, or at minimum the 60 that Executive Order 12866 treats as the norm — to analyze a rewrite spanning more than a thousand pages of regulatory text.

ASBCC's comment supporting the proposed climate-disclosure rule's aims while asking for industry-targeted criteria, education, lead time, and financial assistance for small contractors.