SBIR Gateway
Comments on Pending SBA Policy Directive
In Opposition to the SBA Policy Directive

The following is a letter to the Zyn SBIR Gateway from a source within the federal laboratory network. The author is speaking on his own behalf and is not representing any government agency or organization.

July 8, 2002

Please note that your article [on the SBIR Gateway], makes it sound as if only the DOE Labs will be unable to partner with small businesses on SBIR Projects. It is my understanding that the policy directive will eliminate small businesses receiving SBIR funds from partnering with any FFRDC. Furthermore, the facts appear to be that the original complaints that precipitated this policy directive did not involve the DOE or its Labs. As someone who coordinates the interaction of a DOE Lab with small businesses pursuing and performing SBIR projects, let me state that I have received no complaints concerning our assistance to small businesses. To the contrary, I have only received notes of appreciation which have acknowledged that the small businesses would not have been able to perform the research had it not been for the assistance they received from our laboratory.

The damaging part of this policy directive for the small business, if in fact it is implemented, is the negative effect it has on the very small business. Partnerships with FFRDCs provide very small businesses (e.g., those with less than 50 employees) access to:

  • World-class research facilities they could not afford, the utilization of which produces a higher quality of research.
  • Assistance from/Collaboration with world class researchers employed by the FFRDCs who are intimately familiar with the needs of the Federal government as well as the current trend in the technology field.
Thus, I predict that if the policy directive is implemented, it will have the following negative effects on the SBIR Programs and the small businesses they are intended to assist:
  • Due to the inability to use world class research facilities, the quality of research proposed for/utilized by SBIR projects will decline.
  • Due to the fact that a small business will not be able to complement its capabilities with special expertise not currently available within the company, the number of proposals that comprehensively respond to SBIR solicitation topics will decline.
  • Due to the fact that innovation occurs most often in smaller groups/companies, the number of innovative proposed approaches to SBIR solicitation topics will decline.
  • Accompanying the decline in the quality of the research will be a reduction in the economic development potential of SBIR Programs.
None of these are desirable for either the small business or the country. Therefore, I would strongly encourage consideration that the prohibition on using FFRDCs be eliminated from the policy directive before it is enacted, or, if it is too late for that, that the policy directive be rescinded.


[name withheld by request]