Request for a 90-day comment period — Revolutionary FAR Overhaul

FILED 2026-07-03 · FOUR RFO DOCKETS · REQUEST

On 23 June 2026 the FAR Council published four proposed rules under the Revolutionary FAR Overhaul, with comments due 23 July — a thirty-day window spanning a federal holiday. On 3 July, before commenting on any substance, The American Small Business Chamber of Commerce™ asked the Council for more time. One letter, filed into all four dockets.

Asking for adequate time is itself a policy position. A comment period short enough that only organizations with regulatory staff can respond produces a record that reflects those organizations and no one else.

What we asked for

• A 90-day comment period on all four proposed rules.
• At minimum, the 60 days that Executive Order 12866 treats as the norm for significant regulatory actions.
• Better still, a deadline set no earlier than 60 days after the proposed FAR Part 19 rule publishes, whichever date is later.

Why

Scale. The June 23 publications restructure more than a thousand pages of regulatory text across twenty FAR parts, relocate entire subject areas between parts, and revise the clause library throughout. Thirty days is not a period in which a small organization without regulatory staff can analyze that responsibly.

The Regulatory Flexibility Act. The initial regulatory flexibility analyses accompanying these rules quantify none of the costs the rules impose on small entities — re-familiarization with a rewritten FAR, new procedures on consolidated vehicles, and changed compliance obligations among them. With the analyses supplying no numbers, the only cost evidence in the record is what small entities develop and submit themselves. The adequacy of the analyses that 5 U.S.C. §§ 603–604 require depends on a comment period long enough for that evidence to be gathered.

Sequencing. Parts 5, 6, 7, and 10 are connective tissue — they operate through and around FAR Part 19, whose proposed rule remains unpublished. The public is being asked to evaluate the connections before it can see the thing connected to.

The record

Filed 3 July 2026 into all four Revolutionary FAR Overhaul dockets; posted 7 July 2026.

• FAR Case 2026-001 — FAR-2026-0001-0017
• FAR Case 2026-002 — FAR-2026-0002-0011
• FAR Case 2026-005 — FAR-2026-0005-0007
• FAR Case 2026-007 — FAR-2026-0007-0006

Regulations.gov tracking number, Docket FAR-2026-0002: mr5-5f63-uvxr

Signed by Charmagne Giardina, President.

Download the filed letter (PDF)

ASBCC filed substantive comments on 9 July 2026 — a principal comment and a companion comment under 5 U.S.C. § 610.