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.

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.