Whether intentional or not, GSA created a potentially sticky small business problem when it failed to set-aside specific parts of its planned 2GIT Blanket Purchase Agreement to replace the Air Force’s NetCents contract.  It now has a protest to deal with and a lot of media attention surrounding it. Perhaps one reason for the frustration is that the current NetCents vehicle has several parts specifically set-aside for small businesses.  Federal Procurement Data Center information shows that these parts of the contract have averaged about $1.5 billion a year in sales over the last three completed fiscal years.  Yet GSA’s draft RFP contains no obvious small business set-aside or small business companion provisions.  It is unclear whether the Air Force wanted it that way or whether GSA believed that a lack of set-aside protections would not cause a significant obstacle to small business participation.  What is clear is that the lack of small business protections seems to be tone deaf, at best.  Indeed, Allen Federal is aware that multiple small firms are scrambling to form teams in order to compete for the BPA, lest they be closed out of business they may do now via NetCents.  After an enviable run of being resistant to successful protests, GSA may be on a streak of bad luck.  Recent small business issues with OASIS forced the agency to withdraw awards and conduct a new competition with a revised RFP.  Whatever the outcome of the 2GIT protest, the agency would be well-advised to show a clear path on how small businesses will be able to compete on this BPA as well as other planned large procurements.