A three-document compliance practice — CMMC readiness, DPAS procedure documentation, and Berry-Amendment chain-of-custody — for the regional Berry-Amendment supplier bench downstream of the Olive Hill DLA Troop Support cut-and-sew cluster.

Three compliance regimes converge on this customer set inside the fiscal year 2026 to 2028 window. The final CMMC rule was published in October 2024 with a December 2024 effective date and sets a phased contract-clause incorporation schedule across 32 CFR Part 170. Every DLA Troop Support prime and every sub-contractor flowed CMMC clauses by a prime faces a Level 1 self-attestation gate at minimum; suppliers handling Controlled Unclassified Information face Level 2 third-party assessment. DPAS under 15 CFR 700 requires every DOD supplier to accept and schedule rated orders ahead of commercial work and to document order-acceptance, scheduling, supplier flowdown, and declination procedures. Berry Amendment under 10 USC § 2533a requires DOD purchases of covered apparel and textile items to be 100 percent domestic origin from fiber to yarn to fabric to finished article, with chain-of-custody documentation running back to the fiber producer.

Apparel-tier Controlled Unclassified Information is meaningfully thinner than aerospace-tier CUI, which is why apparel-tier Level 2 readiness engagement scope and pricing both run lower than aerospace equivalents. The Berry-Amendment chain-of-custody leg is the apparel-specific differentiator. Generalist DOD compliance consultants typically thin-out on Berry documentation because it requires apparel-industry supply-chain familiarity — fiber producers, spinning operations, weaving and dyeing and finishing, narrow-fabric trim, woven labels, zipper and hook-and-pile fastener tape — that aerospace-tier and IT-tier practitioners do not naturally hold.

The Cyber-AB Marketplace credentialing stack is the practitioner gate. Certified CMMC Professional at $3,500 to $6,000 in training plus examination plus Registered Practitioner Organization registration is the entry credential; Certified CMMC Assessor is the upper credential where the practice scales toward Level 2 assessment-support work below the C3PAO line. Cyber-AB Registered Practitioner count in Eastern Kentucky is thin; the regional bench is not saturated. The NIST MEP program at the University of Kentucky's Advantage Kentucky Alliance operates CMMC, ISO, and lean-manufacturing programming with federal subsidy that can price below private-practice rates on CMMC-only line items. The candidate competes on Berry-Amendment plus DPAS scope outside the MEP's typical CMMC-only lane and on apparel-industry depth that a generalist MEP cannot match.

The regional supplier bench against which this bundle competes is rough-sized at 200 to 500 establishments across Eastern Kentucky, upper East Tennessee, Middle Tennessee, western West Virginia, and the southern Ohio cut-and-sew belt. A solo-founder practice retaining 6 to 12 active customer engagements sits well below the saturation point of the bench. The Eastern Kentucky APEX Accelerator at Morehead State and the Kentucky APEX Accelerator network operate federal-procurement counseling and bid-match for the same small-manufacturer customer base; they are referral channels rather than competitors.

Per-engagement scope at industry-typical apparel-tier ranges. CMMC Level 1 self-attestation readiness at $8,000 to $22,000 initial engagement covers System Security Plan documentation, scoping memorandum, NIST SP 800-171 baseline implementation, and basic policies. CMMC Level 2 third-party-assessment readiness at $15,000 to $60,000 initial engagement plus $1,500 to $4,000 monthly retainer covers gap analysis against the 110 NIST SP 800-171 controls, SSP buildout, Plan of Action and Milestones, GCC-High Microsoft 365 migration support, evidence-of-control collection, and mock assessment. DPAS procedure documentation at $3,500 to $10,000 covers written order-acceptance, rated-order scheduling integration, supplier flowdown templates, declination procedures, and training. Berry-Amendment chain-of-custody documentation at $6,000 to $18,000 plus $2,000 to $5,000 annual refresh covers supplier qualification framework, bill-of-materials traceability templates, certificate-of-conformance templates, audit-binder construction, and prime-flowdown alignment. Blended bundle retainer on a typical regional sub-contractor carrying CMMC Level 2 plus DPAS plus Berry runs roughly $20,000 to $45,000 per year.

Year 1: solo founder with 3 to 5 active engagements, mostly CMMC Level 1 plus DPAS plus Berry initial scope. Revenue base $120,000 to $240,000. Founder take-home $80,000 to $130,000 against a heavy working-capital reinvestment posture and the CCP credentialing arc.

Year 2: 5 to 8 active engagements with Level 2 readiness retainers building. Revenue base $180,000 to $340,000. Founder take-home $120,000 to $180,000.

Year 3 onward: 6 to 12 active engagements at blended $20,000 to $45,000 per customer. Revenue base $200,000 to $400,000. Sustained founder take-home $120,000 to $220,000. Above $300,000 take-home requires a multi-consultant expansion outside this candidate's solo-founder envelope.

Founder-side capital $75,000 to $200,000. Home office plus a GCC-High Microsoft 365 workspace authorized to handle customer CUI at $8,000 to $18,000 initial standup plus $400 to $800 monthly recurring. Cyber-AB CCP credential, training, examination, and RPO registration at $3,500 to $6,000 plus ongoing. Errors-and-omissions professional-liability insurance at $3,000 to $7,000 per year. Regional travel across Eastern Kentucky, Tennessee, West Virginia, and southern Ohio plus occasional travel to DLA Philadelphia at $10,000 to $25,000 per year. Initial 18-month working-capital reserve at $30,000 to $120,000.

• Carter Industries Inc.

  Carter-resident DOD-prime apparel manufacturer — regulatory-pressure source, not direct customer

  Active in market

  198 Caleb Powers Lane, Olive Hill. NAICS 315210 and 315990. Per published company materials makes the CWU-27P Nomex flight suit under MIL-DTL-25947 and the ICVC combat-vehicle-crewman coverall for DLA Troop Support. $40.8 million across 59 DOD awards over three years.
• Pennsylvania Apparel, L.L.C.

  Carter-resident DOD-prime apparel manufacturer — regulatory-pressure source, not direct customer

  Active in market

  Olive Hill. NAICS 315220. $8.6 million across 89 DOD awards on a high-cadence recurring profile of roughly 30 awards per year.
• DLA Troop Support Clothing and Textiles

  Federal procurement source — administers the CWU-27P, ICVC, and broader DOD apparel item-master

  Out-of-county

  700 Robbins Avenue, Philadelphia. The procurement source of the CMMC, DPAS, and Berry-Amendment clauses that flow downward through the regional supplier bench. DIBBS at dibbs.bsm.dla.mil is the published solicitation and award-detail portal.
• DCMA Lexington

  Federal contract administration — performance and quality oversight

  Out-of-county

  Administering Contracting Officer and Quality Assurance Representative assignments to the Olive Hill cluster are the procedural-introduction channel for compliance posture.
• Cyber-AB

  CMMC practitioner-credentialing administrator

  Out-of-county

  cyberab.org. Administers Certified CMMC Professional, Certified CMMC Assessor, and Registered Practitioner Organization credentials. The Cyber-AB Marketplace publishes the practitioner registry.
• Advantage Kentucky Alliance (AKA-MEP)

  NIST MEP affiliate at the University of Kentucky — regional CMMC, ISO, and lean-manufacturing programming

  Out-of-county

  Competitive set on CMMC-only scope; not competitive on Berry-Amendment and DPAS apparel-industry depth. Potential subcontractor channel where MEP scope exceeds delivery capacity.
• Kentucky APEX Accelerator network and Eastern Kentucky APEX Accelerator at Morehead State

  Federal-procurement counseling and bid-match — referral channel

  Out-of-county

  About 45 miles west of Carter. Operates federal-procurement counseling and bid-match for the regional small-manufacturer customer base. Referral channel into the supplier bench rather than competitor.
• FIVCO Area Development District

  Regional planning, workforce, economic development — introduction channel

  Institution

  32 FIVCO Court, Grayson. Carter-resident ADD headquarters; introduction channel to regional small-manufacturer customers and to AKA-MEP regional programming.

The founder profile is mid-career credentialed-services with either DOD-supplier IT-security or quality-systems exposure (former DCMA quality, ex-defense-prime supplier-quality, ex-military cyber, or experienced apparel-industry quality manager) or export-compliance and federal-acquisition background with willingness to add Cyber-AB CCP credentialing on top. Eastern Kentucky residence or willingness to relocate to the Carter, Greenup, or Boyd labor shed lowers customer-trust friction inside the Olive Hill cluster and across the regional supplier bench. A first-time founder without prior DOD-supplier or compliance-consulting tenure cannot enter this lane cold.

Relationship-portfolio target at launch: the DCMA Lexington Administering Contracting Officer and Quality Assurance Representative office contacts for the Olive Hill cluster; the DLA Troop Support Clothing and Textiles procedural-introduction channel; a Cyber-AB RPO sponsoring-organization for the founder's RP registration; the Advantage Kentucky Alliance regional director and CMMC program manager; the Eastern Kentucky APEX Accelerator counselor at Morehead State; the Kentucky Association of Manufacturers regional liaison; the FIVCO workforce and procurement-introduction lead; 6 to 12 named regional supplier-bench operators across Eastern Kentucky, East and Middle Tennessee, western West Virginia, and southern Ohio. Ten to fifteen named contacts minimum by end of Year 1.

Entity and credentialing posture. SAM.gov registration plus Cyber-AB RPO registration plus Cyber-AB CCP credentialing inside a 9 to 15-month arc. GCC-High Microsoft 365 environment standup authorized for customer CUI handling. Errors-and-omissions plus general-liability insurance against compliance-consulting professional-liability exposure. The bundle survives schedule slippage on CMMC because DPAS and Berry-Amendment legs do not depend on CMMC timing; the founder structures Year 1 around DPAS plus Berry initial scope and adds CMMC Level 1 and Level 2 retainer as 32 CFR 170 clauses incorporate.

National DOD-compliance consultancies — Optiv, Coalfire, Schellman, Booz Allen — bid the prime layer where engagement scopes absorb their cost structure. The regional sub-supplier bench sits below the national-vendor pricing floor. A Carter-resident or Eastern Kentucky-resident contractor of record carrying CMMC plus DPAS plus Berry-Amendment depth at apparel-industry-specific scope is the structural advantage the nationals cannot replicate.

• — Pennsylvania Apparel's corporate relationship to Carter Industries (sister entity, co-located independent operator, or wholly separate Olive Hill manufacturer).
• — Pennsylvania Apparel's exact Olive Hill address, current employment level, and current DLA-contract scope.
• — Carter Industries' current employment level (working estimate 100 to 300 FTE) and current DLA-contract active status.
• — The Olive Hill cluster's current CMMC posture — whether either prime has contracted CMMC readiness with a national vendor and on what terms.
• — The Olive Hill cluster's ITAR registration status, USML classification of the CWU-27P and the Pennsylvania Apparel 315220 product line, and technology-control-plan presence.
• — DCMA Lexington Administering Contracting Officer and Quality Assurance Representative assignment to the Olive Hill cluster.
• — DIBBS current solicitation cadence for CWU-27P, ICVC, and the Pennsylvania Apparel 315220 item-master.
• — Advantage Kentucky Alliance regional CMMC pricing posture and apparel-industry programming reach.
• — Cyber-AB Marketplace Registered Practitioner and Registered Practitioner Organization count resident in Eastern Kentucky.
• — Carter County HUBZone boundary status per the current SBA map.
• — Operator P&Ls. The math above is industry-benchmarked, not measured.

Tonight, this week, this month — in that order. Each step produces a yes/no or a number, not a deeper understanding.