SOUTHERN AUTOMOTIVE WHOLESALERS INC.

597 NORTH SAGINAW STREET

PONTIAC MI 48342-1468

TEL 248-335-5555 FAX 248-335-1564

April 29, 1999

Federal Prison Industries Inc.

Manager, Planning, Research and Activation

Attn: Robert C. Greiser

320 First Street N. W.

Washington DC 20534

RE: Final submission of the Competitive Impact Study of

FPI's Proposed Production of Engine Electrical

Components

Dear Mr. Grieser:

Please consider this my final submission in response to FPI's above proposal.

I was happy to read that in this case, FPI decided to follow the rules set in place for them by Congress. I don't know who to thank....or why I should have to thank anyone. I resent being put through this process, the stress of possibly losing my business and of my employees losing their jobs, the large amounts of time and money spent protecting my company from FPI. I realize I am one of the lucky few, but I wonder how long it will be before another expansion threatens me, or why I have to live under this threat perpetrated by my own Department of Justice.

I am relieved by the changes to the Impact Study which states "to avoid the potential for adversely impacting any domestic vendor, FPI is limiting its request to the annual contract

value of NSN's 2920009092483 and 2920012646542, which is currently performed outside the U.S." (p 12). However I am unclear how by year 2004 FPI could potentially have 18% of

the market share (p 13) or $7 million (p i) based on these two NSN's, or other "repatriation of engine electrical component work". If the U.S. Government decided to no longer purchase these two NSN's, would FPI have no market share? Who will police FPI to make sure that they stay within the parameters the Board of Directors sets in place?

It is my opinion that the FPI's Board of Directors should not approve this proposal for an expansion. I feel my company should have the right to bid on the two NSN's in question.

We have declined bidding on these NSN's in the past because we were operating at capacity, however this does not mean that we would never have bid on them in the future. As a

matter of fact, one of two NSN's was built in the USA by C E Niehoff & Co. Inc. several years ago. When the parts come up for bid again, U S companies would certainly bid the job. I am not opposed to prisoners performing useful work or being educated while incarcerated. But I feel that the "mandatory source of supply" status enjoyed by FPI is not necessary. The obvious financial advantages that FPI receives such as; paying lower wages, having no payroll liabilities, paying no taxes, paying no insurance, paying no rent, paying no utilities, etc. should offset any unique costs they may have. Enabling them to be competitive and leveling the playing field so that we compete together in a fair market.

Under the same quality standards and delivery requirements. I hope the Board will consider having an outside agency compile the information and prepare the impact studies for

FPI's expansions and increases in market share. This would make them more creditable and the question of conflict of interest would be eliminated. Also, an appeal process should

be put in place for businesses that make claims of undue burden. I would like to suggest that documents such are requests for data and impact studies be sent by traceable means to assure delivery.

Respectfully,

Thomas Tyson

President

Southern Automotive Wholesalers Inc.