Comments on Pending SBA Policy Directive
In Support of the SBA Policy Directive
Again, as a small technology business, we would like to take exception to the Greenwoods position on the PD.
First, a waiver would not be a cumbersome nor a burdensome task and hence, it would not in any way inhibit business or proposal preparations.
The logic for the PD is clear. It prevents the obvious abuses that would occur at the Federal laboratory level.
The Greenwoods are also INCORRECT about the arrangements for a CRADA. We have had a CRADA with DOE, have an active one with NASA (they use the term Space Act Agreement instead of CRADA) and are developing two CRADA's with the USDA. You can set a CRADA up anyway you want. Yes, you can pay the Federal lab, or you can do as we do and NOT PAY the Federal laboratory. Our CRADA arrangements simply state that they do work on their contact, we do work on our contract and results are shared toward a common goal. The laboratory uses specialized talents and/or instruments that will contribute to our projects, which in our case are both SBIR and non-SBIR projects. The laboratories are quite happy to conduct such arrangements as partial justification for their existence. They have metrics to have a certain number of CRADA's and get "bonus" points with congress for being contributors to business development.
The statement made by the Greenwoods that "if small companies cannot use SBIR dollars to fund Federal labs to do work through CRADA,s, then this means most small firms will not pursue that SBIR project in the first place" is blatantly INCORRECT. It would not inhibit us. In fact, we would strongly condone a polity statement from congress, and/or the administration that provides direction that the Federal laboratories must develop more CRADA's (or other work arrangements) with small technology businesses at NO COST to the small technology businesses. This policy would encourage better utilization of facilities and capabilities at the Federal laboratories and be a stimulus for economic growth.
It is very clear that the policy directive should stand as published. It is greatly beneficial to the small technology business community and to the SBIR program and to the country. There are absolutely no down sides to the PD as written.
Larry Farrar, P.E.