The American Road & Transportation Builders Association (ARTBA) supports the proposed Revolutionary Federal Acquisition Regulation Overhaul, noting its potential to reduce administrative burdens and improve procedural flexibility. They provide specific recommendations to streamline certifications, cloud services, and dispute clauses to better serve the transportation construction industry.

Palantir Technologies Inc. supports the Administration's effort to modernize federal acquisition and promote commercial-product preferences. However, they argue that the proposed rules lack sufficient enforcement mechanisms and recommend five specific reforms to ensure accountability, clarify commercial definitions, and increase transparency for IDIQ task orders.

CNI Government, LLC, a subsidiary of Chickasaw Nation Industries, Inc., opposes the proposed FAR rewrite due to concerns that it reduces clarity, increases contracting officer discretion, and creates ambiguity. They argue that removing detailed performance standards, relocating definitions to external resources, and expanding discretionary authority will lead to increased costs, higher protest risks, and inconsistent procurement practices.

The American Small Business Chamber of Commerce (ASBCC) opposes several proposed changes to the Federal Acquisition Regulation (FAR) that would eliminate or narrow existing protections for small businesses. They argue that the proposed rules lack sufficient analysis of the economic impact on small entities, specifically regarding presolicitation notice periods, market research triggers, and subcontract visibility.

Brian B. Tung, an attorney commenting in his personal capacity, supports the FAR overhaul's simplification goals. He provides context on the proposed "duty to proceed" revision, identifies potential financing burdens for small firms, and offers several suggestions to ensure the continuity and joinability of public procurement records.

The law firm Sheppard, Mullin, Richter & Hampton LLP is submitting comments on behalf of a global telecommunications client regarding proposed amendments to the Federal Acquisition Regulation (FAR). While the firm supports the overall goal of streamlining the FAR, they argue that several specific provisions create significant administrative burdens, legal uncertainties, and compliance risks for contractors.

Daron L. Davis, an independent governance researcher, supports the consolidation of federal acquisition requirements but argues that the final rule must explicitly preserve government authority, audit access, and accountability. He recommends specific requirements for authority mapping, institutional layer separation, and the preservation of government correction rights during the transition to reorganized security controls.

The commenter recommends adding a specific subparagraph to FAR 4.402 to include FAR 52.212-4 (Terms and Conditions—Commercial Products and Commercial Services). They argue that without this addition, the record retention requirements in FAR 52.212-4 (t)(2) would become meaningless because the current scope of FAR subpart 4.4 would not apply to them.

The commenter provides five specific technical recommendations for updating the Federal Acquisition Regulation (FAR). These include clarifying applicability, correcting terminology regarding Contracting Officer responsibilities, adding definitions for commercialization and computer programs, updating records retention citations, and incorporating due diligence requirements for foreign risk and cybersecurity.

The Alaska Native Village Corporation Association (ANVCA) supports the proposed FAR overhaul, particularly the streamlining of SAM registrations and security provisions. However, they oppose the proposed regulatory sunset framework due to the uncertainty it creates for small businesses and request specific exemptions or protections for socioeconomic programs like the Rule of Two.