Comment on FR Doc # 2026-12561

FAR 5 Comments I wanted to share some observations and suggestions regarding the application of FAR Part 5 to Architectural and Engineering (A-E) Services, especially in light of the recent FAR RFO changes. It seems that the current guidance isn't very clear when it comes to A-E procurement processes. Unlike standard practices where opportunities are advertised and any interested quoter can submit a proposal or quote, A-E procurement is governed by the Brooks Act. This means we typically only issue a Notice of Intent to request SF-330s from qualified firms, rather than a broad solicitation. Previously, the FAR provided for a 30-day announcement period for this Notice of Intent, which functioned more like a Special Notice. However, the new RFO doesn't appear to address the distinct A-E process, and instead only references traditional advertisements such as presolicitation and solicitation notices. Since the Brooks Act requires us to select the most highly qualified firm, only that firm receives the solicitation—no broader posting on SAM occurs. The only public announcement, other than award, is for the SF-330s request. To clarify and streamline this process, I suggest considering the addition of the Notice of Intent to pursue A-E services as a specific item within FAR 5.103. It would also be helpful to clarify the expected notice period for SF-330 submissions, as the current language is ambiguous regarding whether a specific timeframe (such as 15 or 30 days) is required or if this is left to the contracting officer’s discretion. Thank you for taking the time to consider these suggestions. I believe clarifying these points will help ensure compliance and provide clearer guidance for future A-E procurements.