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ASLA Urges SBA Not to Increase Size Standards for Landscape Architecture Firms

In a letter from Executive Vice President Nancy Somerville, Hon. ASLA, ASLA urged the Small Business Administration (SBA) not to increase the cap on annual receipts for small landscape architecture firms and instead recommended maintaining the current $7 million threshold.

As part of a comprehensive review, SBA is proposing a change to its size standards for all professions in the North American Industry Classification System (NAICS) Sector 54, the professional, scientific, and technical services industries, including architecture, landscape architecture, engineering, planning, and a host of other professions.

Under the proposed rule, SBA recommends that small landscape architecture firms be capped at $19 million instead of the current $7 million. For purposes of the new size standards calculations, SBA grouped landscape architecture, architecture, and engineering together because they believe there is a tremendous overlap in the type of work that the professions perform for federal procurement projects. With this analysis in mind, SBA recommends that all three professions be grouped together with a common size standard of $19 million.

“ASLA has heard from a number of members and firms about this proposal and learned that the vast majority of them believe that SBA’s proposed new standard of $19 million is too high and would have a devastating impact on their ability to compete for any small business opportunities and could decimate their businesses. Our members believe that under this proposal, a large portion of the profession would be forced to compete unsuccessfully against the few ‘giants in the industry’ that have more resources to devote to marketing and securing small business contracts,” wrote Somerville.

ASLA also urged SBA not to group the landscape architecture profession with other design professions who may perform similar work, including the professions of architecture and engineering, and instead to perform size standards analysis based on the specific data from each profession. Finally, ASLA urged SBA to take any necessary steps to exclude “pass-through” payments to third-party subcontractors in a landscape architecture firm’s annual receipts. “Together, these three recommendations would establish a more accurate size standard for the profession of landscape architecture in today’s market conditions,” Somerville concluded.

ASLA thanks the many individual landscape architects and firms for weighing in on this important issue and forwarding your comments to ASLA. ASLA will continue to update you on this issue, as the SBA reviews all the comments and moves forward in its rule-making process. If you have any questions or comments, please contact Federal Government Affairs Manager Roxanne Blackwell.

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