The American Small Business Chamber of Commerce is requesting an extension of the public comment period for the proposed FAR Overhaul rules. They argue that the scale of the changes, the lack of cost analysis for small entities, and the interdependence with an unpublished rule (Part 19) require more time for meaningful public input.

The U.S. Women's Chamber of Commerce, representing women-owned small businesses, requests an extension of the comment period for the proposed FAR Overhaul rules. They argue that the current short timeframe prevents small businesses without dedicated regulatory staff from providing meaningful input on rules that significantly impact their operations.

Lynette T. Stevenson, owner of DALS Credit Solutions Co., argues that the proposed FAR overhaul weakens necessary oversight for sole-source awards, which she identifies as a major barrier for small and new businesses. She requests that the Council restore specific "guardrails," including mandatory small-business set-aside analyses, stricter market research requirements, and public reporting of sole-source rates.

The Council of Defense and Space Industry Associations (CODSIA) is requesting a 30-day extension to the public comment period for the "Revolutionary FAR Overhaul" proposed rules. They argue that the scope of the changes—covering seventeen parts of the FAR—is too extensive to review thoroughly within the current timeframe, especially given the need to coordinate input from their many member companies.

GovContractPros, LLC, a government contracting consultancy, requests that the FAR Council extend the public comment period for four proposed rules regarding the Revolutionary Federal Acquisition Regulation (RFO) overhaul. They argue that the current 30-day period is insufficient for the public to review the massive volume of complex changes and that a 60- to 90-day extension is necessary to allow for meaningful feedback and to identify potential unintended consequences.

A former Contracting Officer argues that the current staggered public comment deadlines for various FAR and RFO cases create risks of discrepancies and implementation failures. The commenter requests that the OGP, FAR Council, and OFPP establish a single, common public comment due date for all related cases to ensure a comprehensive review of how the regulations interact.

The commenter argues that replacing the term "shall" with "must" or "will" in the FAR text is misguided because "shall" is the standard for creating binding legal obligations. They suggest that "will" is too conditional and "must" is better suited for tangible items, recommending a more nuanced use of "shall," "must," "will," and "may" depending on the specific context of the requirement.

A Contracting Officer argues that the proposed changes to the FAR are inefficient, vague, and create unnecessary complexity by removing explicit text and replacing it with links to external documents. The commenter specifically criticizes the move toward oral acquisition plans, the consolidation of emergency acquisitions, and the lack of clarity regarding agency-specific requirements.

The commenter, likely a government employee or contractor involved in defense acquisition, argues for an exception to full and open competition for "enterprise" requirements. They contend that standardizing equipment like HVAC systems and IT across the DoD reduces total cost of ownership, simplifies maintenance, and improves cybersecurity.

The commenter argues that eliminating FAR Part 10 and moving only a small portion of its content to Part 7 will result in poor market research and suboptimal federal acquisition outcomes. They suggest that without robust market research, the government will face issues like reduced competition, higher costs, and requirements that are misaligned with commercial standards.