Support for an Interim Rule for Amending of the FAR

June 23, 2003

General Services Administration
FAR Secretariat (MVA)
1800 F Street, NW
Room 4035
Attn: Ms. Laurie Duarte
Washington, DC 20405

RE: FAR Case 2003-001
Federal Acquisition Regulation; Increased Federal Prison Industries, Inc. Waiver Threshold

Dear Ms. Duarte:

The U.S. Chamber of Commerce appreciates the opportunity to comment on the interim rule amending the Federal Acquisition Regulation (FAR) to increase the waiver threshold for small dollar-value purchases from Federal Prison Industries (FPI) by Federal agencies, as published in the Federal Register on May 22, 2003 (68 Fed. Reg. 28094). The U.S. Chamber of Commerce is the world's largest business federation, representing more than three million businesses and professional organizations of every size, sector and region of the country.

The Chamber supports the interim rule as it increases the waiver threshold to $2,500, thereby eliminating the requirement that Federal agencies make purchases from FPI of products on FPI's Schedule that are at or below this threshold. The interim rule provides administrative relief from FPI's monopoly for the business community and removes a significant burden from contracting officers thereby expediting Government procurements. Streamlined purchasing procedures increase operational efficiency ultimately saving taxpayers dollars.

On January 8, 2003, the FPI Board adopted a resolution to raise the 'blanket waiver' relating to small dollar-value purchases from $25 to $2,500. Such a change is long overdue and supports the long-time Congressional and Administrative goals to streamline the federal procurement process and to facilitate the purchase of commercial items. The Federal Acquisition Streamlining Act of 1994 provided greater purchasing flexibility to executive agencies to facilitate the purchase of commercial items and to facilitate small dollar-value purchases through the establishment of Micropurchase procedures. In 1996, the Department of Defense and other executive agencies, requested that the FPI Board of Directors increase the blanket waiver relating to small dollar-value purchases from the existing threshold of $25 to the new Micropurchase Threshold of $2,500. This request was subsequently ignored and the blanket waiver was only raised to $250.

The U.S. Chamber has long advocated a fair and efficient federal procurement process, which benefits both the private and public sectors. This action provides a common sense approach for addressing small purchases by federal agencies. On behalf of our membership, we appreciate the opportunity to comment on the interim rule and recommend that it be made final.

Sincerely,

R. Bruce Josten
Executive Vice President, Government Affairs
U.S. Chamber of commerce