We are considering doing a SATOC small business set-aside for construction rather than MATOC. The Defense consolidation memo of October 28, 1996 would indicate this is a consolidation even though it is for construction. Value overf $25M. Though it would be "new" work because it is construction, it is work that could be performed by smalls. Should this be subject to a consolidation analysis and if so, would this a quantitative justification to show the benefits. The Jobs Act refers to this but does not seem clear. Thanks.

Fred, you mention an October 28, 1996 memo. The law has changed a lot since then, so I'm not sure how instructive that memo is at this point. I would start with 10 USC 657q(a)'s definition of consolidation, along with 13 CFR 125.1( c ), both of which, in the context of construction, talk about "a solicitation for a single contract or a Multiple Award Contract to...satisfy requirements of the Federal agency for construction projects to be performed at two or more discrete sites."

In terms of implementation in the FAR, you'll probably want to follow, if you aren't already, FAR Case 2014-015.