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When the FAA went from the FAR to their new AMS regulations, the 1996 DOT Appropriations Act exempted the FAA from some Federal Laws and Regulations, amoung them the Brooks Automatic Data Processing Act. However, now the FAA is saying that they are also exempt from the Brooks Act for Architecture and Engineering contracts. However, I am unable to find any Act, regulation or other documentation exempting them from following the Brooks Act and Qualifications-Based Selection (QBS) when solicitating Architecture & Engineering services. I did find a requirement that the FAA is required to follow the Brooks Act for A&E contracts funded by grants and Airport Improivement Funds, but nothing for direct FAA contracts funded with appropriated dollars. Does anyone in the group know of where the FAA waiver from having to use the Brooks Act for A&E contracting lies? I appreciate the help. Thank you
