Nakupuna Companies, a Native Hawaiian Organization-owned firm, supports the FAR Council's efforts to modernize and streamline the Federal Acquisition Regulation. However, they request specific revisions to Parts 6 and 7 to ensure statutory alignment, clarify thresholds for 8(a) awards, and protect small business participation from being diminished by a proposed governmentwide-vehicle-use hierarchy.

The ABA Section of Public Contract Law supports the "Revolutionary FAR Overhaul" but suggests specific improvements to ensure transparency, statutory consistency, and the preservation of established numbering for existing contract clauses. They argue for incorporating certain guidance into the FAR Companion Guide and recommend against a wholesale renumbering of Part 52 clauses to maintain legal predictability.

The commenter suggests a specific revision to the language of proposed rule section 6.104(a) regarding Justification and Approval (J&A) requirements. They argue that requiring an "approved" J&A ensures adequate authority is in place before negotiations with a contractor begin.

CNI Government, LLC (a subsidiary of Chickasaw Nation Industries, Inc.) opposes several proposed changes to the FAR, specifically the removal of statutory references, the oversimplification of agency head and acquisition planning responsibilities, and the merging of distinct requirements for consolidation and bundling. They argue these changes create ambiguity, risk inconsistent application across agencies, and potentially undermine statutory protections for small businesses.

Bering Straits Native Corporation (BSNC) supports the improvements made to the NPRM but requests further clarifications and modifications to ensure the FAR Parts 6, 7, and 10 fully preserve and clarify statutory small-business procurement preferences. Specifically, they advocate for clearer "shall" language regarding set-asides, the inclusion of specific statutory citations for 8(a) and sole-source authorities, and the clarification of J&A thresholds for defense versus civilian agencies.

The commenter provides specific technical corrections and recommendations regarding the Federal Acquisition Regulation (FAR) revisions. They identify inconsistencies in approval authorities and citations between Table 6-1 and FAR 16.507-6(e), and suggest specific language updates to ensure regulatory accuracy.

The Native American Contractors Association (NACA) supports the proposed FAR revisions but requests specific modifications to ensure the preservation of statutory small business authorities. They advocate for clearer "shall" language regarding set-asides, the inclusion of specific statutory citations for 8(a) programs, and clarification on sole source authorities for Native-owned entities.

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 they support the goal of streamlining the FAR, they argue that several specific provisions create compliance burdens, lack clarity, and risk increasing administrative friction for contractors.

Diné Development Corporation, a Navajo Nation-owned company, supports the FAR Council's goal to streamline regulations but requests specific revisions to ensure clarity. They argue that the proposed language should explicitly preserve the mandatory nature of the Rule of Two for small-business set-asides and clarify that the $30 million 8(a) J&A threshold applies only to civilian agencies.

HunaTek Holding, LLC, a small business and 8(a) participant, supports the proposed FAR revisions but requests further clarifications to ensure they fully implement Congressional mandates. The company argues for the inclusion of specific statutory references, the use of "shall" instead of "may" for mandatory set-asides, and the clarification of sole-source authorities for Native entity-owned firms.