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The American Council of Engineering Companies (ACEC) – the business voice of the engineering industry – appreciates the Trump Administration’s initiative to overhaul the Federal Acquisition Regulations (FAR) and streamline the federal procurement process. ACEC represents nearly 5,500 engineering firms and more than 600,000 engineers, surveyors, architects, and other specialists nationwide, many of which hold federal agency-specific or multiple award contracts and will be directly impacted by these changes.
We are pleased to provide input and seek clarification on the proposed FAR Companion Version 1.0 released on September 9, 2025. While we appreciate that the Companion Guide has more pages devoted to Part 36 than many other FAR Parts, we want to avoid potential unintended consequences if the Companion Guide is missing the same provisions as were removed from the
text of the FAR itself. As we said in the attached FAR Part 36 comments submitted on September 8, 2025, three changes made to Part 36 risk future innovation, project acceleration, and cost-efficient project delivery by weakening the foundation of how the government hires engineers:
• Removal of Specific Architect-Engineer Minimum Selection Criteria
• Lack of Clarity When Engineering Services Are Dominant
• Reduced Transparency in Awards and Debriefs
We maintain that our proposed additions to FAR Part 36 found in our September 8, 2025 comments be included in FAR Part 36 and the Companion Guide. Without those additions, our concerns are amplified. As with our FAR comments, the scattering of Architecture and Engineering (A/E) Services related subparts (e.g., 36.102 and 36-202) between Construction subparts creates confusion and increases the potential for errors and/or misuse. Continue Reading