Dear Ms. Dennis and Ms. Coughlin:

The recent debate over the proposed language in the SBA Policy Directive relative to excluding Federal Laboratories and FFRDCs from participating in Small Business Innovation Research Programs has been a healthy one. However, there is one glaring omission in the arguments made by the proponents. The proponents of the Federal Lab prohibition have failed to put forward ANY examples of when the alleged coercion has occurred. We believe it would be a gross injustice to the thousands of small companies that now have the right and opportunity to subcontract with the Federal Laboratories if those who claim there is a problem do not offer proof of it.

Therefore, we respectfully request that the proponents of the proposed policy directive demonstrate its need by providing specific examples of when SBIR competitors have been coerced into using a Federal Laboratory in their proposals and projects. We would recommend that the following details be provided for as many specific examples as they can identify:

• The name of the alleged victimized company
• The year and agency when they were applying for an SBIR award and feel they were coerced
• The federal laboratory involved
• Whether the company won the SBIR award or not
• How and by whom the company was coerced

We anxiously await this information, since the DOE SBIR Program Manager and ourselves cannot identify even a single example of alleged (much less substantiated) coercion.

--Gail & Jim Greenwood