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Tom's avatar
Apr 22Edited

I was afraid this was coming. They really want to spend that "One Big Beautiful Bill" money ASAP, although now that it was approved by Congress, I doubt midterms or a change in the Trump Regime (25th amendment, whatever) could stop this from proceeding. No daycare or healthcare for you, Americans! We have a border to "protect", brown people to deport and illegal, unprovoked wars to fight!

A couple of comments:

"Using 236220 is a sign that the agency anticipates using these contracts for large-scale, institutional building work, not small projects or repairs."

This is not necessarily true, and the solicitation/sources sought notice mentions repairs, demolition and upgrades to existing facilities in addition to engineering and environmental compliance (yeah I chuckled at that too). Virtually all that is signaled by the use of NAICS Code 236220 is that these SACCs will be used for 'vertical' construction projects (as opposed to 'horizontal' projects like levee and land-based border fences and floating waterborne barriers) - so, likely repairs and additions to existing buildings and new design-build (DB) construction of smaller stations and checkpoints. Most of the "joint processing centers" (i.e., immigrant prisons built according to "corrections facility" standards) are too high in $ magnitude for me to think they'd be acquired under the resulting SACC contracting vehicles....if they ever end up getting awarded at all. Furthermore, there is currently another $10Bn IDIQ already in final source selection. Anyone can download the documents here, including the scope of work: https://sam.gov/workspace/contract/opp/98cdd5a9942a41a399b0ea7ecff2a529/view Nearly equivalent to what this SACC program seems to be aiming for. More on that toward the end of my comment.

That said, you are correct when pointing out that the bonding capacity limitations might point to screening out smaller firms, however $10M single/ $300M aggregate would allow for mid-size firms to qualify. Most Small Business firms are able to bond $10M single projects and typical Small Business(es according to the NAICS 236220 size standard* can usually bond $50-$80M aggregate). It's the aggregate of $300M that in itself is interesting because most *larger* firms don't want to be performing numerous concurrent $10-20M projects and would rather be awarded one or two $150M+ projects. And to flesh out your explanation of what this means, a construction firm doing business with the government has to provide a bid bond with their proposal (assuming for an actual construction project), and then performance and payment bonds upon award.

Also, being very familiar with the government construction sector, I would point out that a "sources sought" *is* merely market research - the results of which may cause them to open up the eventual acquisition to small businesses including the socioeconomic categories they listed (WOSB, HUBZone, 8(a)**, SDVOSB, etc.). IOW, depending on the industry feedback they get, the ultimate solicitation and resulting contracts could include a SB set-aside pool for smaller projects.

What I would guess here is that they want to award multiple SACCs to individual firms so that they can 'efficiently' assign out projects without further scrutiny to pre-qualified contractors. This is what DHS CBP is currently doing under what I call their shadow border wall program, which was just awarded in 2025 after the previous MATOC program expired. https://factually.co/fact-checks/politics/largest-us-mexico-border-wall-contracts-through-2025-98d86b.

In essence they did a no-bid award to several of the firms (aka short listed) who were already on the previous MATOC and they're farming out "task orders" (basically border wall segments) to contract holders individually. This prevents protests and fast-tracks time to award and completion. Personally I think it's in violation of the FAR, but as we've seen with the Trump Regime, accountability and legality are things of the past. So yeah, this looks like what they're doing is developing a short list and then issuing sole-source solicitations/awards to individual SACC holders so that they can estimate/bid them and be awarded with no further scrutiny.

Additionally, I found it interesting that they didn't even specify a target 'ceiling' value for the overall program (see the SAM link I provided above for the MATOC). Generally that is information firms responding to this type of market research want to know because they are going to evaluate whether it's worth it to spend any time on this kind of 'business development' activity. And to a previous point, most large, established firms don't want, say, 12 concurrent ~$10M rinky dink projects spread out all over the country. Which also makes me wonder if the eventual solicitation ends up breaking the awards out into regions.

This will be an interesting one to follow, because the stated scope is already attainable via existing and upcoming contract awards, so the way I look at this SACC program is a means to funnel taxpayer money to a group of well-connected firms who don't happen to be among the group that the article above alludes to. Probably Trump and associate cronies with direct ties to the regime.

Also, they said they won't be answering any questions, LOL.

* - The first asterisk is a referral to the NAICS 236220 size standard, which effectively means a business cannot qualify as a "Small Business" if its rolling 5-year annual average revenues exceed $45M (this may have been upped recently). Being a "Prime Contractor" Small Business according to the SBA and NAICS standards carries advantages in terms of set-asides, and being a subcontractor Small Business means that larger firms are required to farm out a certain % of large government contracts to SBA designated Small Businesses.

**- The asterisk by 8(a) was because Pete Kegsbreath's Department of WAR has basically waged war on the SBA's 8(a) program and I was surprised to see it mentioned by DHS.

Jeannine Anderson's avatar

Makes me wonder if these are going to be camps for dissidents/political prisoners.

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