What’s With SBA’s Comment Numbers on the Size Standards Rule? Clear Error Uncorrected?

SBA’s website says it has received 66,254 comments on its small business size standards rule. You can read 761 of them.

Two words on that website do a lot of work, so here is what each one means.

Received is SBA’s count of submissions it has taken in on a rule. It counts submissions, not people. One person filing twice counts twice. Identical form letters each count. The number runs through 11:59 p.m. the night before. Nobody outside SBA has seen most of what it counts.

Online is the set SBA has reviewed and published. These are the only ones anyone can read. SBA does not have to publish everything it takes in, and it can combine identical submissions into one published comment.

Now the numbers. They all come from regulations.gov.

SBA put out two rules on August 20. Both close September 21. Same office, same subject.

The methodology rule: 602 received, 182 online.

The size standards rule: 66,254 received, 761 online.

The methodology rule has 1 comment online for every 3 submissions it counted. The size standards rule has 1 online for every 87.

I checked the size standards count on five days:

September 4 — 66,108

September 7 — 66,148

September 8 — 66,154

September 9 — 66,200

September 10 — 66,254

That is 146 submissions in six days.

Comments opened August 20. To reach 66,108 by September 3, the count would have had to climb by 4,407.2 a day, every day, for fifteen days.

The same count on other rules:

SBA’s 2025 size standards proposal, covering 263 industries — 66.

SBA’s 2023 inflation adjustment — 9.

The four Revolutionary FAR Overhaul proposed rules together — 323.

SBA has published comments on ten days since August 20. Its biggest day was 191. Its count says 65,493 submissions are still unpublished, with 11 days before comments close.

Checked September 10 on regulations.gov. Received counts run through 11:59 p.m. the night before.

If someone can explain the 66,254, I will post the explanation.

Sources: regulations.gov/docket/SBA-2026-0199 and regulations.gov/docket/SBA-2026-0265. Small Business Size Standards, 91 Fed. Reg. 53,741 (proposed Aug. 20, 2026); Small Business Size Standards: Revised Size Standards Methodology, 91 Fed. Reg. 54,096 (Aug. 20, 2026); Small Business Size Standards: Monetary-Based Industry Size Standards, 90 Fed. Reg. 41,168 (proposed Aug. 22, 2025); Small Business Size Standards: Adjustment of Monetary-Based Size Standards, Disadvantage Thresholds, and 8(a) Eligibility Thresholds for Inflation, 88 Fed. Reg. 46,048 (July 19, 2023).