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Decision Signals Increased SBA Scrutiny of Size Status

Client Alert | 1 min read | 04.16.07

In Size Appeal of Ross Aviation, Inc., SBA No. SIZ-4840, March 07, 2007, the SBA’s Office of Hearings and Appeals (“OHA”) reversed its earlier decision in Size Appeal of Spectrum Landscape Services, Inc., SBA No. SIZ-4313 (1998), and expanded the scope of its review. Basing its reversal of position on the objective of promoting the integrity of the procurement process, OHA held that “[a]part from contract-specific issues (e.g., ostensible subcontractor and non-manufacturer rule), OHA will no longer dismiss automatically an unsuccessful offeror’s appeal as moot after contract award . . . simply because of a contracting officer’s representation that he/she intends not to disturb award of the contract (including their intent to award options).”

Insights

Client Alert | 5 min read | 09.03.26

DOT Final Rule Narrows Airline Delay and Cancellation Reporting Obligation Under FAA Reauthorization Act of 2024

The U.S. Department of Transportation (DOT) published a final rule amending 14 CFR Part 234 that fundamentally changes how airlines report the causes of flight delays and cancellations. Effective October 19, 2026, the rule implements Section 511(b) of the FAA Reauthorization Act of 2024 by creating a new reporting category, the “Section 511(b) category,” for ten specific events that Congress determined are not attributable to airline control. The rule simultaneously narrows the existing "Air Carrier" reporting category by expressly excluding those same ten events....