Comment on FR Doc # 2026-11765
DALS Credit Solutions CoOpposeAdvocacy
Summary: Lynette T. Stevenson, writing as a federal procurement and small business advocate, opposes the proposed rule because it creates an imbalance by imposing higher evidentiary burdens on individually owned firms while preserving the lucrative contracting structure for large, entity-owned corporate families like Katmai. She argues that the SBA should not rely on the support of a direct economic beneficiary (Katmai) as evidence of fairness and calls for a comprehensive enterprise-level analysis of award concentration.
Lynette T. Stevenson, This supplemental submission responds to the comments filed by Katmai Government Services in support of the proposed rule. Of course, Katmai supports the rule. The rule preserves the entity-owned contracting structure under which the Katmai family has reportedly accumulated nearly $1 billion in federal prime-contract and subcontract award activity through only two identified affiliates: approximately $825.6 million attributed to Katmai Government Services and approximately $173.8 million attributed to Katmai Information Technologies, before other subsidiaries and major announced awards are considered.
Katmai is entitled to defend a federal contracting framework that has worked exceptionally well for Katmai. SBA, however, should not mistake that institutional self-interest for independent evidence that the rule is fair to individually owned disadvantaged businesses. Katmai supports imposing individualized narratives, documentary proof, and heightened eligibility burdens on independent business owners while preserving the separate statutory and regulatory treatment from which its own affiliated organization benefits.
The reported figures should be verified, de-duplicated, and separated among contract ceilings, obligations, prime awards, and subawards. Even with that necessary qualification, Katmai’s substantial federal award history makes one fact difficult to ignore: this is not a neutral observer defending abstract principles of fairness. This is a direct beneficiary defending the architecture of its own success.
Katmai’s support proves that the proposed rule benefits Katmai. It does not prove that the rule promotes equitable competition, meaningful business development, or fair access for everyone else.