"There just aren't any HUBZone companies out there"

Boarhog LLC will be celebrating 9 years in the national security business this month, and we've been fortunate enough to deliver valued services on more contracts than we have associates, while also executing our Labs-as-a-Service Plus (LaaS+) innovation model to rapidly deliver proven innovations solving current problems.  We just completed a LaaS+ for the Naval Information Warfare Systems Command (NAVWAR) on Uninterruptable Power Supplies (UPS) proliferating C4I systems in the Fleet, and the six innovations we specified will certainly solve persistent UPS problems if and when adopted.  We've been asked by the government to author an article on LaaS+ for publication, and that's in the works.  

For more than a few years now our principal offices have been located across the railroad tracks from NAVWAR headquarters, taking me 20 minutes to walk door to door.  We've served on the National Defense Industrial Association (NDIA) San Diego chapter Board of Directors and chaired the chapter's Industry-Government Outreach Committee, and Boarhog has sponsored a booth at AFCEA West and a widely attended luncheon talk by a senior NAVWAR official in the Office of the Chief Engineer.  Point is, Boarhog is not flying below the defense industry and government radars in Southern California, and everyone who knows us knows we're a Service Disabled Veteran Owned (SDVO) and Small Business Administration (SBA) certified Historically Underutilized Business Zone (HUBZone) small business.  That's why it irked me to hear one government Director of the Office of Small Business Programs state in open forum that "there just aren't any HUBZone companies out there" when excusing their failure to achieve their HUBZone prime contractor obligations.  Well, we are indeed out here, but we don't bid prime for very good reasons.  Their response?  If you're out there, why don't you respond to Sources Sought?  Well, I've attempted to answer that question quite a few times, but apparently without success, else we would have detected changes in behavior.  So let's try this again.         

The Director proudly reports to his leadership and defense industry representatives alike that his command has surpassed every one of their socioeconomic category threshold objectives established by the Navy, except for HUBZone.  He laments trying unsuccessfully to get HUBZone small businesses to respond to Sources Sought or to submit prime bids on work that he believes is just right for HUBZone companies to win.  Alas, "there just aren't any HUBZone companies out there."  That, is apparently that.  No evidence offered, or demanded.  Bought hook, line, and sinker... I'm sitting in that audience, and many in attendance turn to look at me, knowing Boarhog is a HUBZone.  What's my take, their looks demand?   

Here's the question I've posed to the Director:  What's the reasoning behind each of the following four standard “requirements” in just about every Sources Sought, and what impact do you think each of the four has on a HUBZone company deciding to work up a Sources Sought response let alone submit a prime proposal?: 

1. Have a DCAA approved accounting system at time of bid in order to be awarded a CPFF services contract;

2. Have prime contractor past performance of similar size and type within the past few years;

3. Have a Secret Facility Security Clearance at time of bid (vice post award DD-254 execution)

4. Have a Seaport-NxG prime contract

Does anybody out there doubt that an extremely small fraction of all HUBZone companies are able to satisfy all four of these Sources Sought “requirements”?  Which of these "requirements" is directly relevant and affects actual performance of the services under consideration?  Might some or all four of them be dismissed by the Navy organization for the right work and thereby increase HUBZone participation if that's indeed an important objective?  These "requirements" can indeed be set aside, as Boarhog knows first hand when a Navy acquisition command kicked all four "requirements" to the curb for a Total Ship Readiness Assessment (TSRA) HUBZone set aside competition.  As a result, quite a few HUBZone small businesses came out of the woodwork to submit prime proposals, and Boarhog won that work before we had an approved accounting system, before we had any prime past performance, before we had a facility security clearance, and before we had a Seaport contract.  That’s the kind of thinking that’ll break the glass ceiling prohibiting many HUBZones from bidding prime, as it did for Boarhog, and that win directly contributed to Boarhog quickly satisfying one, two, then eventually all four of the “requirements.”  More importantly, we performed superbly as a prime contactor according to the technical organization client, who had zero interest in any of those "requirements."  Win-win, putting Boarhog on the map.  

So, are there HUBZone companies out there?  Yes, we're here, in spite of what some would suggest.  I'd offer that more than a few HUBZones continue sitting on their hands when considering Sources Sought containing all four of those "requirements," instead waiting for the government to issue the RFP unrestricted aka "full and open" so the large defense contractors forming teams write their company name under "HUBZone" in their small business subcontracting plan.  Does Boarhog respond to Sources Sought today?  Not very often at all, even though we have an approved accounting system, have a TS facility security clearance, and have a Seaport-NxG prime contract.  The relevant prime past performance "requirement" is an issue, even though the government stated the committee would grade our "no" answer as neither positive nor negative, and the Director quickly followed by stating he's not on the committee and doesn't really know exactly how they decide to set the work aside.  Ok.  We're busy, so good luck achieving that HUBZone threshold.  Maybe the Navy will continue believing without evidence there just aren't any HUBZone companies out there and lower the bar again.  We'll see.