Comment on FR Doc # 2026-11765

King Aerospace appreciates the opportunity to comment on the Small Business Administration's proposed rule eliminating the rebuttable presumption of social disadvantage for individually owned participants in the 8(a) Business Development Program. We support SBA's effort to strengthen the program and address the constitutional concerns identified by the courts. Requiring applicants to demonstrate social disadvantage is a reasonable step toward improving transparency and public confidence in the program. However, this proposal addresses only one part of a much larger issue. The rule affects individually owned 8(a) firms but leaves unchanged the competitive environment created by Tribal, Alaska Native Corporation (ANC), Native Hawaiian Organization (NHO), and Community Development Corporation (CDC) owned 8(a) firms. In specialized aviation maintenance and sustainment, those organizations represent the primary competitive landscape—not individually owned 8(a) companies. King Aerospace has spent decades supporting complex aviation missions for the Department of Defense, Department of Homeland Security, Department of Energy, Federal Aviation Administration, and other federal agencies. We compete on technical capability, past performance, safety, schedule execution, and cost. Our experience has shown that the greatest obstacle to competition is not the capability of any one company. It is the acquisition strategy itself. When agencies restrict procurements exclusively to entity-owned 8(a) firms, qualified contractors with proven performance are eliminated before the Government has an opportunity to compare technical approaches, pricing, innovation, or execution risk. King Aerospace experienced this under the Department of Energy National Nuclear Security Administration Office of Secure Transportation Aircraft Maintenance and Support Services contract. After successfully performing a five-year mission-critical contract with strong performance, regulatory compliance, favorable CPARS, and national safety recognition, the follow-on requirement was moved into the 8(a) program. King Aerospace was no longer eligible to compete—not because of performance, cost, or mission risk, but because of the procurement strategy. This is why we believe the current proposal, while worthwhile, will not achieve the Administration's broader procurement objectives by itself. The Administration has emphasized making federal procurement faster, simpler, more competitive, and more accountable for cost and schedule performance. Those goals depend on meaningful competition. When qualified contractors are excluded before proposals are submitted, the Government loses the ability to determine which offer truly represents the best value. This comment is not a recommendation to eliminate the statutory authorities Congress established for Tribal, ANC, NHO, or CDC-owned organizations. Those authorities serve important public policy purposes. Rather, we encourage SBA to recognize that the current proposal addresses only one segment of the 8(a) marketplace and does not address procurement practices that increasingly limit competition in specialized industries. We encourage SBA, the Office of Federal Procurement Policy, and Congress to evaluate whether current acquisition strategies are fully aligned with the Administration's goals of increasing competition, improving accountability, controlling costs, and delivering better schedule performance. Without examining those broader incentives, the Government is unlikely to realize the full benefits of procurement reform. King Aerospace appreciates the opportunity to comment and supports continued efforts to strengthen both the integrity of the 8(a) Program and the competitiveness of the federal acquisition system.