B08_Attachment_6_Q-A_Amendment_1__Summary_0001.pdf

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Dunn Main House Rehabilitation, NPS-PORE
Solicitation number
140P8425R0002
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About this file

This document is a Questions and Answers (Q&A) Amendment for a federal solicitation (No. 140P8425R0002) for the Dunn Main House Rehabilitation and Accessory Dwelling Units Construction project at Point Reyes National Seashore. The document covers details from a site visit on June 30, 2025, and includes responses to 52 questions from potential bidders regarding project specifics such as material substitutions, work scope, utilities, licensing requirements, and contract terms.

Key details include the project will involve rehabilitation of the main house and construction of accessory dwelling units, with work potentially starting in September 2025. Contractors can propose alternative materials like vinyl windows and composite decking, subject to Contracting Officer Representative (COR) approval. The procurement is a negotiated best-value process, with proposals evaluated using the Best Value Continuum Tradeoff Process. The National Park Service anticipates awarding the contract in mid-to-late August 2025, and a California Contractor State License is required for the work.

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REQUEST FOR PROPOSAL NO. 140P8425R0002

DUNN MAIN HOUSE REHABILITATION & ACCESSORY DWELLING UNITS CONSTRUCTION

POINT REYES NATIONAL SEASHORE

SITE VISIT – JUNE 30, 2025

QUESTIONS AND ANSWERS

SITE VISIT SUMMARY:

A site visit occurred on Monday, June 30, 2025 from 11:00a.m. to 2:00p.m. Pacific Daylight Time.

Par cipants met at 20401 Shoreline Hwy, Marshall, CA 94940. Upon arrival, all par cipants were asked to sign in. Par cipants were shown the site, and ques ons asked during the site visit are answered below.

See: B08_A achment_5_Site Visit Sign-In Sheet.pdf

B08_A achment_6_Q-A_Amendment_1_ Summary.pdf (this document)

PROJECT QUESTIONS FROM SITE VISIT, 6/30/2025:

1. When is the deadline for pre-proposal ques ons and requests for informa on (RFI)?

Ques ons must be submi ed via email to alanna_gardner@nps.gov a minimum of seven (7) calendar days prior to the due date and me for proposals.

2. How will bids be evaluated?

Refer to Sec on M of the Solicita on star ng on page 55 of 57 for a detailed descrip on. The proposals will be evaluated using the Best Value Con nuum Tradeoff Process as defined in FAR

Part 15.1.

3. Are material and product subs tu ons allowed?

Materials or products specified may be subs tuted with approved equal products, with the approval of the contrac ng officer representa ve (COR).

a. How will material subs tu ons be approved and documented in proposals?

Approval of proposed subs tu ons should be documented by submi ng a pre-proposal ques on via email to the contrac ng officer. The subs tu on should also be documented in the proposal submission by including a supplemental technical descrip on of alternate materials and approaches.

b. Are alternate window materials acceptable for any new windows, such as vinyl?

Solicita on 140P8425R0002, A achment 6, Q-A & Amendment 1

Yes. Alternate windows should be rot and corrosion resistant. Style and color should reflect exis ng windows to remain. Vinyl windows would be an acceptable subs tute.

Specific brands and window series should be submi ed for COR approval.

c. Are material/product subs tu ons allowed for showers?

Yes. Alternate shower materials are allowed. Alternate shower materials should avoid the use of grout. Alternate shower materials should be resilient, easy to clean, not easily damaged by common household cleaners, and should minimize the number of joints.

Alternate materials and/or systems should be submi ed for COR approval.

d. Are material/product subs tu ons allowed for decks and railings?

Yes. Decks and railings may use alternate materials/products that provide the same func on, strength, durability, and weather-resistance. For example, pressure treated lumber that has been sealed or painted would be an acceptable alterna ve to steel deck frames or composite deck materials. Alternate materials should be submi ed for COR approval.

4. When is the project work expected to start?

Project work may start as soon as prac cable a er award subject to the comple on of required submi als following award. Based upon the current award schedule, work would not be an cipated to begin any earlier than September of 2025.

5. Have any hazardous materials reports been done?

No hazardous materials reports have been completed for the project.

6. Is water and electricity available for contractor use?

Water for the site is supplied from a nearby well to four 3,200-gallon (12,800 gallons total) storage tanks located approximately 200- east and uphill of the main house. Water from these tanks or the distribu on piping to the main house may be used for project purposes. Electric service to the main meter at the corner of the garage is ac ve and can be used for the project.

7. Are any architectural or civil design services required on any por on of the project?

Architectural, structural, and civil engineering design services are not an cipated to be required for the project.

8. Will value approaches be considered and how will they be evaluated?

Value approaches will be considered. Value approaches differing from the proposed scope of work may be documented by submi ng a pre-proposal ques on via email to the contrac ng officer a minimum of seven (7) calendar days prior to the due date and me for proposals, to allow a public response to your query via Amendment to the Solicita on. The approach should be documented in the proposal submission by including a supplemental technical descrip on of the approach and the value added. An example could be ground based solar panel racks with corrugated metal roofing in lieu of roof mounted solar on a standing seam metal roof; assuming an efficiency or value is added to the project by the changed approach.

9. Can the exis ng exterior siding be le in place and used as sheathing for new siding?

Yes; provided any ro en siding is repaired before covering it with new siding.

10. What is included in the fire suppression sprinkler system scope?

The scope includes a piped sprinkler loop fire suppression system. The work includes a new water supply line from the exis ng tanks or distribu on system as needed. The work does not include any new or replacement water storage tanks.

11. For op onal contract line item appliances, such as washer/dryer units, are the connec ons and ven ng part of the base bid or part of the op on?

The op onal contract line item for appliances, CLIN 9, includes the purchase and final installa on of the appliance. The installa on of properly sized outlets, water supply lines, vents, and drains are considered part of the base rehabilita on work of CLINs 2-6.

12. Can parking areas and open spaces be used for staging? Does the access driveway need to stay open?

Yes, parking areas and open spaces adjacent to the buildings can be used for staging. The access driveway does need to remain open for access to the residence immediately south of the project site. Throughout construc on, the residents of the home to the south will need to be provided safe access through the site.

13. Will payments only be made for completed contract line items, or are progress payments allowable?

Progress payments will be made on the work as it progresses. Payment requests may be submi ed monthly based on the CLINs and schedule of values developed by the contractor.

14. Are any other buildings on the site included in the project?

No other buildings on the site are included in the project. The work includes only those buildings shown in the drawings and described in the specifica ons.

PROJECT QUESTIONS RECEIVED VIA EMAIL TO DATE (7/6/2025):

15. What basic u li es are available for the contractor’s use (electric, water, etc.)?

Electric service to the residence is on and can be used by the contractor for contract work, subject to the limita ons of the exis ng electrical system service and contract related rehabilita on work on such.

Untreated (non-potable) water is available for project use from four (4) 3,200 gallon storage tanks located approximately 200 feet east of the main house. An underground water service line connects the tanks to the main Dunn house at the rear of the house where the exis ng water treatment system is located. The tanks are filled by a nearby well and require me to refill when used.

Func onal restrooms are not available at the site.

No other u li es are available at the site.

16. Would our Tanzite Stonedecks product (www.tanzite.com) be an acceptable alterna ve to Trex for the decking por on of the project?

From a brief review of the product informa on available publicly, it appears to be a reasonable alterna ve that meets the func on and provides the important features of the basis of design product. If a contractor were to propose it as an alterna ve, the NPS technical reviewers do not see a reason to object.

17. The documents provided on SAM.gov do not seem to include any drawings, with he only technical informa on found in A achment 1 for Scope/Statement of Work. Are any contract drawings included for this solicita on?

Construc on drawings generated for the project are included in the specifica ons

(B08_A achment_1_Specifica ons.pdf) as A achment B, star ng on page 180 of 370. These drawings represent general plan views and profiles of the completed rehabilita on. Site specific plans for proposed interior and exterior building systems are to be developed by the contractor as part of the work.

18. Is the intent for this to be a design/build?

The intent for this project is for the contractor to develop site specific plans for interior and exterior systems covered by the scope of work. This includes but is not limited to: the residen al water treatment system, electrical systems & appurtenances, fire detec on/alarm/suppression systems, HVAC systems, plumbing systems, and the op onal photovoltaic power system. The intent would be for the contractor to provide shop drawings or similar during the submi al process to adequately describe the work. The scope does not include any architectural, structural, or civil changes to the buildings. The intent is to provide the contractor and trade professionals flexibility in the execu on of the scope to maximize value and cost savings.

19. If not Design Build are there any construc on drawings available?

Construc on drawings generated for the project are included in the specifica ons as A achment

B, star ng on page 180 or 370. These drawings represent general plan views and profiles of the completed rehabilita on. As noted, site specific plans for proposed interior and exterior systems will be developed by the contractor. Architectural drawings and permits from previous renova on work can also be found in the specifica ons as A achment H, star ng on page 215 of

370.

20. Will there be any local permi ng requirements?

The Na onal Park Service, Point Reyes Na onal Seashore is the agency of jurisdic on. No local agency permits are required for work ac vi es on park lands.

21. Who is the JHA for fire life safety?

The Na onal Park Service is the jurisdic on having authority for fire life safety.

22. Who is the JHA for the sep c/environmental scope items?

The Na onal Park Service is the jurisdic on having authority for sep c/environmental items.

23. Is there any Mold and asbestos report and abatement included in this bid?

There are no mold or asbestos reports for the property. The main house was extensively renovated circa 1990, and the dance studio and garage were built subsequent to that renova on. Very li le of the original main house remains. Asbestos is considered unlikely to be present based upon the extent of renova on and me of construc on. As such, asbestos abatement is not included in the scope of work. Specifica ons sec on 02 42 00 CLEANING AND

REMEDIATION includes the cleaning and remedia on of mold. Mold is visible in some areas as you will note during the site visit.

24. Is it acceptable to have one person cer fied QC/Safety/Superintendent on site? Or do you need separate QC manager and safety manager on site?

One person may hold mul ple roles as long as they meet the qualifica ons for the roles and are able to perform the required du es of each.

25. Sec on 01 31 00 Project Management and Coordina on, page 1 Related Requirements, item 4 references “Sec on 01 91 14 Total Building Commissioning……..” that sec on is not included in the specifica on book. Please advise.

Total Building Commissioning is not included in the scope of work or specifica ons. Line item 4 in

Sec on 01 31 00 Project Management and Coordina on on page 1 was inadvertently le in the document but should have been deleted. Please ignore any references to Total Building

Commissioning or Sec on 01 91 14.

26. For the Dunn House project, will the bid results be published on the bid day (7/14) so bidders have an idea if they are low? If not the same day then when?

No, this isn’t sealed bid, it’s nego ated procurement. The proposals will be evaluated for best value and any award decision will be posted to sam.gov in addi onal to individual no fica on to unsuccessful offerors. The evalua on process takes about 2 weeks. Once the award decision is known, we send out required pre-award no ces so offerors will know who the apparent awardee is while the award is pending final clearance reviews, which can take about 1 month.

We an cipated awarding mid-late August.

27. I am seeking clarifica on on a sec on of the Solicita on. For Factor 2 California Contractor

License do both the Prime contractor and the subcontractor have to have the license or can it just be the subcontractor?

We understand there may be wide variety of team configurations that offerors may choose to employ. We require a California Contractor State License as applicable to the type of work being performed on this project. This is why the Solicitation instructs you to describe in detail in your proposal who will be performing what work with what license. While there may be acceptable scenarios where the proposed prime contractor does not have a license but the subcontractor does, the possession of a current and valid State License applicable to the work performed will be more favorably rated.

28. Is this a brand new contract OR was an incumbent performing these services?

This is a new requirement.

29. Specifica on lacks informa on to clearly specify ceiling le. Please clarify item number to quote, or confirm that we are using the cheapest op on that fits characteris cs in Spec.

No le ceilings are proposed. Review 011100 SUMMARY OF WORK and 02 to 48 OUTLINE

SPECIFICATIONS for descrip ons of ceilings:

Unit 1 ceilings shall be gypsum board/drywall. Exis ng gypsum board/drywall may be preserved where possible in Unit 1 or it may be replaced with new material.

With the excep on of the new bathrooms, the exis ng wood tongue and groove ceilings in all other rooms of Units 2 and 3 shall be preserved to the extent prac cable. Repairs and patches of ceiling materials in Units 2 and 3 are to be tongue and groove wood to match exis ng. New bathroom ceilings in Units 2 and 3 shall be gypsum/drywall.

With the excep on of the new bathrooms, new ceilings in Units 4 and 5 are to be tongue and groove wood. New bathroom ceilings in Units 4 and 5 shall be gypsum/drywall.

Tongue and groove wood materials shall meet the specifica on in 062000 WOOD CARPENTRY. Materials shall be solid wood matching the species and dimensions of exis ng materials.

Gypsum board/drywall shall meet the specifica on in 092900 GYPSUM BOARD.

See a ached Figure 1 depic ng the extent of ceiling finishes. (This is provided as A achment 7 to Amendment 1 of the Solicita on.)

30. Are there exis ng as-built drawings available for the Dunn House, Studio, and Garage structures to confirm wall, founda on, and framing condi ons before interior renova ons and conversions begin?

Drawings and diagrams that exist are included in the a achments to the specifica ons beginning on page 215 of 370.

31. If we bid the op onal resilient decking/walkways/stairs, are there any product restric ons or fire ra ng requirements due to the park’s wildland-urban interface loca on?

Decking, walkways and stairs products should meet the California State Fire Marshal’s “Wildland- Urban Interface Fire Areas Building Standards.” See h ps://osfm.fire.ca.gov/divisions/fire-engineering-and-inves ga ons/building-materials-lis ng/ for a list of currently approved materials and products.

32. Will the replacement of the skylights (op onal CLIN 8) trigger addi onal structural or Title 24 energy code upgrades to the roof system?

The replacement of skylights will not trigger any addi onal structural or Title 24 energy code upgrades.

33. Are there record drawings or diagrams of exis ng plumbing/sep c/sewer lines? Can we e into the exis ng systems, or must all new lateral lines be installed?

Drawings and diagrams that exist are included in the a achments to the specifica ons beginning on page 215 of 370. Limited to no informa on is included on the interior systems. Exterior sep c system diagrams are included in these drawings. Exis ng systems and lines may be ed into and u lized when possible.

34. Is a u lity site survey or underground u lity loca on plan available before excava on?

No u lity site surveys or underground u lity plans are available.

35. What equipment (if any) currently exists for hea ng and cooling in each unit? Will it be removed by the government or the contractor?

An exis ng gas furnace is located in the first floor u lity closet adjacent to the living room for hea ng the main house. A wood stove is located in the dance studio for hea ng. Pictures are shown below. Removing and disposing of these exis ng units is considered part of the demoli on work to be completed by the contractor.

36. Has a load study been completed to verify that the exis ng service is adequate for the new EV charging sta ons, HVAC heat pumps, and all ADU units?

A load study has not been completed.

37. Is the en re system to be designed by a licensed fire protec on engineer? Is there a preferred vendor or exis ng e-in for water supply?

The detec on, alarm, and suppression systems can be designed by a licensed fire protec on engineer or alterna vely, a licensed C-16 Fire Protec on Contractor can design and install systems within the parameters of their license, provided the work is performed by them or their supervised employees.

There is not a preferred vendor. NPS has worked previously with Uponor for the design and installa on of similar systems, however any qualified vendor would be acceptable.

Water for the site is supplied from a nearby well to four 3,200-gallon (12,800 gallons total) storage tanks located approximately 200- east and uphill of the main house. A distribu on line connects these tanks to the main house. The scope assumes the contractor will e into the exis ng water supply line or at the exis ng storage tanks. The work does not include any new or replacement water storage tanks. A future project will address increased water storage.

38. Is the installa on of five EV chargers supported by exis ng power infrastructure, or will panel upgrades and trenching be required?

There is no exis ng power infrastructure for the proposed EV chargers.

39. Will internet service be extended by the contractor from the street u lity pole, or will NPS provide an ISP drop to the site?

It is the understanding of NPS that there is an exis ng func onal ISP drop to the site by Tomales Bay LAN. If that drop is no longer func onal, NPS will coordinate with Tomales Bay LAN to provide a new drop for the site.

40. Can equivalent products to Sherwin-Williams (e.g., Benjamin Moore or Dunn-Edwards) be submi ed for approval, or is Sherwin-Williams proprietary?

Equivalent paints and coa ngs may be submi ed for approval. Subs tu ons should be premier products that are self-priming, mildew resistant, acrylic latex, with a life me warranty.

41. For Pergo Defense+ and Sherwin-Williams Resuflor Topcoat Metallic, are color selec ons finalized, or will submi als be required for approval?

Color selec ons indicated in the specifica ons are pre-approved for use. If colors are not available, or subs tute products are proposed, the submi al process would be used for approval of alternate colors. NPS is flexible on colors and products if the same func onality can be provided at a be er value.

42. What standard or reference should be used to match exis ng baseboard, casing, and wood ceiling finishes (e.g., species, stain, profile)?

In areas where wood will be painted, only profile and dimensions of materials are considered relevant. In areas where wood will be stained, matching or mimicking the species and appearance to the extent prac cable is preferred. Stain on new wood should be matched to exis ng features to the extent prac cable.

43. Can the exact boundaries of the 14,200 SF for landscaping, tree trimming, and clearing be staked by the COR prior to work?

The boundaries for landscaping, tree trimming, and clearing can be staked by the COR prior to work.

44. Can the 15’ / 10’ / 5’ limits of disturbance around buildings and u li es be exceeded temporarily for equipment access?

Yes, the 15’ / 10’ / 5’ limits of disturbance around buildings and u li es can be exceeded temporarily for equipment access. Temporary disturbances outside of these limits can be coordinated with the Contrac ng Officer Representa ve (COR) as needed.

45. What service scope is required—pump, inspect, replace components, or full system replacement?

The exis ng sep c tank and drain field will not be replaced or repaired. If components are damaged, they will be noted in the condi on report. The scope of work includes: “Service the exis ng site sep c tank, piping, and leach field. Inspect the system, pump the tank(s), and flush/service the drain field. Clean effluent filter screen(s). Purge and balance the system. Switch the diversion valve(s). A condi on report shall be provided upon comple on of servicing.”

46. What is the required review period for submi als and RFIs—10 working days or another dura on?

The specifica ons provide 30 days for an ini al review and five days for re-submi al reviews of ac on submi als. Ten days are provided for reviews of informa onal submi als. However, these are maximums and rarely would that much me be required for a review. The CO/COR will review each individual submi al and will respond accordingly based on the cri cal nature of each. Most submi als and requests will be responded to within five business days or less.

47. Is Microso Project an acceptable format for the construc on schedule, or is Primavera P6 required?

Microso Project is an acceptable construc on schedule format.

48. Are work hour excep ons available for cri cal path items or u lity shutdowns, and what is the process to request weekend/evening work?

Excep ons to work hours will be considered based upon project needs. Requests shall be submi ed to the COR/CO in advance for approval. Alterna ve and flexible work schedules may be accommodated to allow for longer work hours during normal business weekdays. Approval for weekend or Holiday work would be unlikely, however could be approved in a limited nature if sufficient jus fica on is provided.

49. For mixed-scope trades like demo crews or finish carpenters, how should workers be classified under the wage determina on?

Refer to clause 52.222-6 which states that all laborers and mechanics employed or working upon the site of the work shall be paid not less than the appropriate wage rate and fringe benefits in the wage determina on for the classifica on of work actually performed, without regard to skill, except as provided in the clause en tled Appren ces and Trainees (refer to clause 52.222-9).

Laborers or mechanics performing work in more than one classifica on may be compensated at the rate specified for each classifica on for the me actually worked therein; provided that the employer’s payroll records accurately set forth the me spent in each classifica on in which work is performed.

50. Are the op onal items to be bonded as part of the original performance/payment bonds, or will separate bonding be required upon award?

Pre-award, a bid-bond (Standard Form 24) is required with your proposal; the amount of the bid bond shall be 20% percent of the total proposal price. This is your total price inclusive of all op on line items.

Post-award, the successful contractor shall provide both a performance bond (Standard Form 25) and payment bond (Standard Form 25A) within 10 days of award, each at 100 percent of the original contract price. If any or all op ons are awarded at the me of award, that amount would be considered part of the original contract price.

The Government may require addi onal performance and payment bond protec on if the contract price is increased. The increase in protec on generally will equal 100 percent of the increase in contract price.

51. Can you supply me with contact info for who you know are bidding the project as GCs?

If you visit www.sam.gov and search for the opportunity using keyword 140P8425R0002, you can “follow” the solicita on to receive updates in general, and to answer your ques on you can likely see/add yourself to the Interested Vendors List which is where you might see who has registered as an interested GC. You may need to create an account and sign in to see this informa on.

52. Is there any possibility that you could schedule another site visit for the referenced solicita on?

Yes, another site visit has been scheduled for Wednesday, July 9, 2025 from 1:30 to 3:30 p.m.

Meet at 20401 Shoreline Hwy, Marshall, CA 94940 (La tude longitude for the site is approximately 38°10'0.36"N, 122°53'39.67"W). Driving Direc ons: From Point Reyes Sta on, CA, travel north/northwest on CA-1 (Shoreline Highway) for ten miles. Turn le into the driveway for 20401 Shoreline Hwy and park along the loop road adjacent to the house. Map provided in Sec on J A achments of original Solicita on.

To par cipate in the site visit, send an email to Jason Nemeth at jason_nemeth@nps.gov with the following informa on:

Email tle: “140P8425R0002, Request for Site Visit Par cipa on (PORE Dunn House)”.

The email shall contain: The Name of the Par cipant, Company Name, Trade (ex.

General Contractor, Roofer, etc.) and phone number and email address of all par cipants.

You may also RSVP via telephone by calling Jason Nemeth at 415-858-2562 and providing the informa on listed above.

SUMMARY OF AMENDMENT 0001 ITEMS:

The offeror shall make the following changes, amendments and addi ons to the per nent sheets, pages and paragraphs of the specifica ons and all associated Solicita on documents, and shall take the same into considera on in the proposed prices:

1. Revised specifica on sec ons

a. 01 31 00:

Total Building Commissioning is not included in the scope of work or specifica ons. Line item 4 in Sec on 01 31 00 Project Management and Coordina on on page 1 was inadvertently le in the document but should have been deleted. Ignore any references to Total Building Commissioning or Sec on 01 91 14.

b. 01 11 00 SUMMARY OF WORK and 02 to 48 OUTLINE SPECIFICATIONS:

See a ached Figure 1 depic ng the extent of ceiling finishes (This is provided as A achment 7 to Amendment 1 of the Solicita on).

2. Updated provisions and clauses

a. Sec on I is updated as follows:

Update 52.222-6 Construc on Wage Rate Requirements (AUG 2018) with (DEVIATION FEB 2025) version.

Add 52.222-9 Appren ces and Trainees (JULY 2005) (DEVIATION FEB 2025)

Update 52.222-11 Subcontracts (Labor Standards) (MAY 2014) with (DEVIATION FEB 2025) version.

Update 52.222-12 Contract Termina on—Debarment (MAY 2014) with (DEVIATION FEB 2025) version.

b. Sec on J is updated to include the following new a achments:

B08_A achment_2_Wage_Determina on_27Jun2025.pdf

B08_A achment_5_Site Visit Sign-In Sheet.pdf

B08_A achment_6_Site Visit Notes_Q-A_Amendment_1_Summary.pdf

B08_A achment_7_Dunn Ceiling Finishes.pdf

Updates to the Federal Acquisi on Regula on (FAR) are underway with changes to date incorporated into this Amendment as summarized above.

The full text of a solicita on provision or clause may be accessed electronically at this/these address(es):

h p://www.acquisi on.gov/far/ h ps://www.acquisi on.gov/diar h ps://www.acquisi on.gov/caac-le ers Alterna vely, please reach out to the contrac ng officer at alanna_gardner@nps.gov for any ques ons or clarifica ons.

Recent policy updates require the issuance of the following no ces:

NOTICE: System updates may lag policy updates. The System for Award Management (SAM) may con nue to require en es to complete representa ons based on provisions that are not included in agency solicita ons. Examples include 52.222-25, Affirma ve Ac on Compliance, and paragraph (d) of

52.212-3, Offeror Representa ons and Cer fica ons—Commercial Products and Commercial Services.

Contrac ng officers will not consider these representa ons when making award decisions or enforce requirements. En es are not required to, nor are they able to, update their en ty registra on to remove these representa ons in SAM.

NOTICE: System updates may lag policy updates. The System for Award Management (SAM) may con nue to require en es to complete representa ons based on provisions that are not included in agency solicita ons, including 52.223-22, Public Disclosure of Greenhouse Gas Emissions and Reduc on

Goals—Representa on, and paragraph (t) of 52.212-3, Offeror Representa ons and Cer fica ons—

Commercial Products and Commercial Services. Agencies will not consider or use these representa ons.

En es are not required to, nor are they able to, update their en ty registra on to remove these representa ons in SAM.

--END OF NOTES--

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