22. Industry Questions and Answers to the G-Z IRSC Model.pdf

Questions/Comments and answers to the G-Z IRSC Contracting Tool as part of the Request for

Information (RFI).

Q. Recommendation for NEPA - For each Region or National Forest determine the NEPA team capacity to complete a proposed landscape project. Most forest in region 5 do not have the capacity or staff. Imbed a NEPA team through the G-Z model to work with a forest NEPA team to stay on schedule and dedication to see a NEPA proposal through from scoping to the record of decision. This is imperative. Hold subject matter experts i.e., specialist to completing reports in a strict timely manner. Do not allow revolving door NEPA team staff to accept details on other forests or regions. Set priorities early in process.

A. The G-Z contracting model is intended to perform services to 1) prepare projects to be implementation ready; and 2) implement those projects to complete the on-the-ground end-results. This model is not intended to perform any pre-decisional NEPA activities. The Stewardship Branch is in coordination with forests discussing this contracting tool while NEPA planning activities are being performed.

Q. The litany of work items would be at the least, difficult for one contractor to fulfill. Any single contractor is a one stop shop for all the tasks associated with the items listed. A contractor would have to name a team of subcontractors in their proposal. This inherently can cause confusion and inefficiency, especially in a large landscape project.

A. Sub-contractors and use of sub-contracting is a normal practice of IRSCs. The only “Specialized Sub-

Contractor” required for Go Big G-Z is for the heritage work associated with Item #2 and a licensed engineer for the road reconstruction plan. The FS does intend to allow sub-contractors to perform under the primary contractor. All sub-contractors must be approved by Contracting Officer (CO) prior to starting any work. If award is made to a Large Business, a formal Sub-Contracting plan will be required.

Q. Comparison or transaction evidence in region 5 will not work in any given geographic area, due to market conditions and the glut of sawtimber from mega fire areas and the lack of evidence from bids.

Do not leave your local and regional appraisal experts out of this process. Best value proposals with a timber component imbedded in IRSCs is extremely risky for a contractor. Small diameter trees from 4” to 14” are largely considered biomass. Recommendation-explore residual value appraisals. RSV cost analysis tend to be more accurate in the absence of transaction evidence or simply advertised at minimum rates and let the market determine the stumpage price. Do not allow USFS manual direction limit your options.

A. The Agency recognizes the number of transactions, and the associated volume totals, across appraisal groups and appraisal zones FS-wide has decreased significantly, especially in the west as the regions have crafted portfolios of primarily stewardship contracting instruments. Fortunately, pond value data is available across appraisal zones in California and Oregon and the regions’ appraisal applications has the capability to perform a residual type of appraisal in the absence of sufficient transactions evidence. Regional appraisers work diligently to produce accurate cost estimates that reflect the additional costs associated with Agency mechanical thinning requirements, including the mandatory cut and removal of small diameter trees.

When including small diameter trees and biomass as mandatory product removal or adding as Timber

Subject to Agreement, additional thought is taken to determine best approach to mitigate the risk to best value determinations. Such as splitting up the removal of products (saw vs non-saw) in the

Schedule of Items to isolate the deficit cost of biomass removal. For products that the Transaction

Evidence Appraisal indicated are deficit, additional market research is conducted and examination of which cost centers are leading to the deficit and how these costs can be mitigated. Residual Value

Appraisals (RSV) and IGCE are recalculated together typically in this scenario to reflect the cost estimate of removing the deficit products, while accounting for the recouped delivered pond value of products.

For Go Big G-Z IRSC specifically, the FS reserves the right to determine the best method of appraising the timber value after each cruise is completed. FS intends to use the R6 Transaction Evidence Appraisal system and Residual Value Appraisal together to determine the final Rate for products. All the entries into the Log Cost and Log Haul will be taken directly from the accepted treatment plans developed by the awardee as part of Item 1. Please see the notes section under the Schedule of Items for how Bid

Premiums will be applied. Total value offering for products will be utilized to ensure one rate for all products. Cruise and volume determination by awardee have been set to “Tree Measurement” standards to mitigate risk to both parties when utilizing total value offering. This will also provide contractor the maximum flexibility to market and remove all products. The timber cannot be offered as tree measurement due to the use of DxP prescriptions.

As part of the Price Proposal, contractors will be required to provide delivered market value prices for products planned to be delivered and to which facilities. This information provided by all contractors will be used (kept internally to protect proprietary information), coupled with the variable logging cost entries obtained from logging plans produced by the contractor will be used to determine the final timber rates per Timber Treatment Area.

Q. Implementing projects is not the bottleneck, completing NEPA, pre-sale layout and contract prep is.

Focus on developing a prime contractor pool with more specialized targeted skill sets to fill voids in the agency’s workforce. This will increase the quality of the projects prepared and implemented and more importantly it will increase the pace and scale of projects that have cleared the NEPA gate.

A. Stewardship Branch has developed the Land Management Integrated Resources (LMIR) BPA to help with this bottleneck. All professional services were included in the BPA scope that were identified as needed for increasing pace and scale on forests that are limited in internal workforce capacity. This BPA is an open and continuous opportunity on SAM.gov. Vendors may submit a proposal at any time to competitively join the BPA vendor pool.

Go Big G-Z IRSC has been designed specifically to overcome the bottleneck of pre-sale layout and contract prep needs prior to implementation without the need for multiple contracts.

Q. The scope of work items are too broad and require a diversity of skills/expertise that no single prime contractor currently possesses. Because of this, the bidder will have to rely on estimates from multiple subcontractors to complete their project proposal, all which will have to be disclosed and described in the technical proposal with enough specificity to allow the Forest service to evaluate the proposal to determine award. When a prime contractor must rely on multiple contractors to complete a project it expands their risk profile and an allowance for profit and risk will be built into those work items to cover the cost of paying, supervising and potential failure to perform. The scope of this proposal creates a broker middleman business relationship, consequently the more subcontractors in the middle, the likelihood of higher cost to complete the project exists. This proposal vests to much control with one contractor. Both elements expand the risk profile to the government.

The pre-solicitation period and solicitation period have been increased from the required minimum to allow for contractors the needed time to find acceptable sub-contractors, write the proposal and sub-contracting plans. Additional risk associated with prime contractors relying on sub-contractors has been considered. Contractors may also hire employees with specialized skills, such as foresters, rather than use subs. Stewardship Agreements and Good Neighbor Authority are agency examples of success where a partner coordinates and completes the project while utilizing contractors and sub-contractors. The prime contractor must coordinate all work Items similarly and bid this contract accordingly based on their analyzed risk profile.

Multiple contracts using a phased approach to limit or decrease the risk to the prime contractor creates additional time lag between phases, additional work on the agency to prep/award/administer more contracts, additional work on industry for quotes/proposal development, and ultimately will not increase pace and scale. The use of Optional Items will allow the FS to award additional Treatment Areas and Units based on the successful completion of the work already awarded and the contractor meeting the desired progress schedule as detailed in the Period of Performance section of the solicitation. Risk profile is reduced to both parties using this approach to ensure awardee is not awarded more work than they can successfully complete by December 31, 2030.

Q. Segment the project into three parts: project design and layout; mechanical treatments; prescribed

Fire. This leverages common skill sets and expertise that currently exist in the marketplace. It will also improve the specificity of the proposals submitted which will allow the forest service to make a more accurate determination of best value.

A. The contract and Schedule of Items have been set up similarly to how suggested.

Q. More shovel ready projects create an environment that fosters market certainty, which stimulates the innovation and capital investment in infrastructure necessary to create a durable long-term solution to improving forest resilience.

A. The G-Z model allows forests to concentrate forest staff resources on preparing shovel ready projects outside of the G-Z project area while the primary contractor completes the prep and implementation work. Less FS resources are needed to oversee and administer this contract compared to prepping in-house or utilizing multiple contracts to complete the same results.

Q. Why isn’t NEPA included in G-Z? The biggest time consumer is NEPA preparation.

Partners/Contractors can do NEPA far quicker than the Forest Service. In R5, it’s common for a Forest to take 2 years or more to complete an EA. To increase pace and scale, the Agency has to find a way to dramatically reduce the time to complete the NEPA.

A. The A-Z IRSC contracting model is the tool that includes NEPA through project completion. We have successful examples of A-Z where NEPA through final completion of work has been done. If Forests were to desire this tool, we would work with them to develop it. If the NEPA decision was challenged on an A-

Z, contractor would be held up and contract may need to be Terminated for Convenience. The G-Z concept is an adaptation of the A-Z IRSC where forests already have NEPA decisions ready, but preparation work is the bottleneck.

As stated above, LMIR BPA has been designed to meet the need of increasing capacity where the agency is lacking the internal resources to complete NEPA/prep/etc.

Q. Why does the Forest Service have to do the timber appraisal? The potential bidders are far more informed on market condition than the Forest Service. Transaction Evidence is a joke. The most obvious example is right now. The wholesale lumber indices by species are down over 20% since July

2022. Housing starts nationwide are down 50%. None of any transaction evidence is going to reflect these realities. You would be far better off having a contractor prepare an appraisal with USFS review.

Or better yet, set the appraised rate at minimum rates and let the bidders tell you what the market price

is. I would expect in a volatile market like we now have, 95% of the time the bidder is not going to agree with the advertised rate.

A. See answer above for the G-Z appraisal procedures. The Agency has a legal requirement to determine an appraised value for trees and portions of trees prior to transfer of ownership of said property from the United States to another party. The Forest Service would be remiss in our fiduciary responsibility to the public and to congress to allow purchasers to appraise the value of federal timber. Our appraised value effectively serves as a reserve price in our auctions and relies on the bidding process to determine the true market price for stumpage. One observation the Agency has made over the last three years is that volatility in the finished goods marketplace has had much less of an effect on stumpage market prices than systemic price inflation. Every region in the Forest Service can input Unusual Adjustments in the Transaction Evidence Calculations. Changing market conditions can be included as an Unusual

Adjustment.

Q: Major issue with transaction evidence appraisals is they don’t consider current market delivered value.

A: When the Agency transitioned away from residual value appraising to transactions evidence appraising the Agency also transitioned away from manufacturer data collection. Absent a public or independent data source providing pond value/gate value/delivered value, the sum of our transactions evidence base period values is the government's best estimate of total delivered cost of a given appraisal group. G-Z IRSCs will ask for current market delivery value to best utilize both appraisal methods.

Q. With no idea what the treatments are going to be by harvest unit (the recon won’t even be done), how are you going to come up with appropriate criteria to evaluate proposals?

A. Contractors will be evaluated based on the Evaluation of Proposals as indicated in the solicitation.

Each Work Item has been analyzed using GIS to estimate gross acres. When GIS did not provide an acceptable estimate, a general gross estimate was used. To answer specifically, the total contract cost will be determined by adding all work Items (including sub-items for stepladder pricing) by gross acres/quantities as listed. This will ensure price proposals are evaluated fairly with increased weight on individual unit prices per Item.

Technical Proposals that remove/treat the most fuels, from the most acres, in the least amount of time are going to rate the highest in most cases. This is a generalized statement. Please see the Evaluation section of the solicitation for specific trade-off criteria and evaluation factors.

Q. A 6-year, 30,000-acre project seems reasonable. But to conclude this will provide an increase in pace and scale is not clear. Most timber forests are currently doing 5,000+ acres/year of mechanical thinning.

A. The Go Big G-Z IRSC is now >66,000 gross acres. The plan is to have the entire contract completed by

December 30, 2030. This project allows limited FS personal to prepare the contract while forest staff can prep other contracts and timber sales. During implementation prep and work completion, forest staff can be concentrating on other projects. This will ensure regular program of work, the 5,000+ acres/year to proceed and continue simultaneously. Effectively doubling or more the pace of treatment.

Q. Evaluators of proposals will have to recognize that RISK will be a sizeable component of a 6-year contract. If a wildfire occurs in the project area after contract award, the contract modification can take over 2 years to complete. By then, the burned timber will no longer produce sawlogs so is worthless.

The USFS will appraise that the burned timber has value. All the contractor can do is request termination. This will be a major cause of increased costs.

A. Catastrophic wildfire effects will be analyzed as rapidly as possible for needed contract changes.

Supplemental Impacts Reports will be used to the maximum extent possible to allow this contract to be modified as rapidly as possible to ensure products are removed prior to deterioration. The FS will work with awardee to modify the contract bilaterally in the best interest of both parties. Contract Termination for Convenience may be the only recourse for both parties in this situation.

Q. What liability does the contractor have for prescribed burning? Prescribed burning requires specific conditions to perform. Contracts have deadlines. What if the conditions are not present during the contract timeline?

A. No Rx Burning will be performed on Go Big G-Z IRSC. Any burning activities performed by contractors on G-Z contracts will be done under the oversite of a certified Burn Boss and Ignitions Boss (Contracted or FS). Liability for escapes or damage would fall on FS when no negligence on the part of the contractor.

Contract deadlines specific to burning operations would be kept flexible and time extended via modification to accommodate burn windows with no need for “considerations” by either party.

Q. Is there a possibility of switching to more modern cruising software systems such as Superace?

A. Not at this time.

Q. Will virtual boundaries be an option in layout?

A. Yes

Q. How will the Forest Service obtain accurate data for conducting appraisals?

A. From the contractor produced harvest cards of Item 1, FS inspections of stand treatment data, and the market related pond value information requested/required by all proposing contractors. All data will be provided by industry and the contractor.

Q. For the Blue Mile project, what is the age of the timber? How soon will project locations be known?

A. Age of timber is variable due to large treatment area and many different timber stands. There are maps provided with the pre-solicitation and/or solicitation Request for Quotes.

Q. Will real market rates for contractors be applied?

A. Yes, to the maximum extent policy and law allows. See answers above.

Q. Will invasive weed control be included in contracts?

A. It is a possibility for weed control to be included, but not currently included in Go Big G-Z.

Q. How many subcontractors are allowed?

A. No limit on number of subs on a contract. All subs are subject to CO approval. Large businesses are required to have a sub-contracting plan.

Q. Will contract extensions be allowed due to unforeseen circumstances?

A. Yes, when the unforeseen circumstance is an Excusable Delay per FAR 52.212-4(f) - The Contractor shall be liable for default unless nonperformance is caused by an occurrence beyond the reasonable control of the Contractor and without its fault or negligence such as, acts of God or the public enemy, acts of the Government in either its sovereign or contractual capacity, fires, floods, epidemics, quarantine restrictions, strikes, unusually severe weather, and delays of common carriers. The

Contractor shall notify the Contracting Officer in writing as soon as it is reasonably possible after the commencement of any excusable delay, setting forth the full particulars in connection therewith, shall remedy such occurrence with all reasonable dispatch, and shall promptly give written notice to the

Contracting Officer of the cessation of such occurrence.

Q. What happens if a catastrophic event happens after money has already been invested, but no timber has been harvested yet?

A. Contractor will be paid for work completed on the contract up to the point of the event. Please see answer above for catastrophic events.

Q. Will timber rates be adjusted for market conditions?

A. No adjustments will be made after award of timber products for each Timber Treatment Area has been made. Each treatment area will have a separate cruise, appraisal, and established rates. Each award of timber will capture the current market conditions for that award. So answer is no, but each timber award should be reflective of any adjusted market conditions.

Q. There are concerns regarding taking on the risk of prescribed burning.

A. Rx burning is not included with Go Big G-Z IRSC. This is being heavily analyzed with each G-Z contract on the merits of including vs not. The FS knows the industry concerns over contractor Rx burning and liability concerns. Numerous vendors are available in the market that perform this work successfully and could perform as subs if this is included in any G-Z contracts.

Q. Transparency and accuracy of appraisals, leading to advertised rates. In-house appraisals often do not align with current industry rates and lag behind market fluctuations.

A. The actual appraisal cannot be shared with industry or vendors because it is part of the independent government cost estimate, which per the FAR is off limits externally. The transparency and accuracy leading to market reflective rates is in allowing and requiring proposals to provide current market pond values and contractor will provide the inputs for calculating logging costs.

Q. Would it be possible to have a prospective bidder workshop or a more involved pre-bid meeting?

A. Yes. Already planning on it.

Q. Could the pre-bid meeting be mandatory?

A. No. Can't make it mandatory.

Q. Could a pay item for developing proposals be incorporated?

A. No. Cost of doing business to compete for the award. We can't pay every contractor for preparing their proposal and we can't pay just the awardee for their proposal.

Q. If the contractor did not want to agree to complete the timber removal of one area would they be able to still complete others?

A. Contractors will identify the treatments that each unit needs as part of the Logging Plan or Service

Treatment Plan of Item 1. The major tenet of this contract is to remove as much fuel from the landscape as possible and deliver it to market. There will be sub-optimal logging units. Units that will require lower volume or lower quality per acre of mandatory removal than others. Solid reasoning for not agreeing to removal of timber, when needed to meet silvicultural and fuels objectives, will need to be presented by the contractor before awarding the timber for each Timber Treatment Area. Contractor’s technical proposals must include a plan to complete all treatment including removal of included timber.

Q. Could the pre-bid meeting be multi-day with one day going over the solicitation?

Yes, we plan on having one in office meeting with a call in during the pre-solicitation and then a pre-bid field meeting once the final solicitation is out.

Q - For bidding on merchantable timber when there is no information on volume, dbh, species mix, etc.

followed eventually by a USFS Appraisal when the timber prep work is done. How does a bidder make an upfront bid on the timber when there’s no information? Is the bid then adjusted to match an agreed upon appraisal later in the process?

A. Please see the Schedule of Items, the Timber Products table, and notes section. Only Bid Premium offers will be required and evaluated for the unknown estimated product value. Vendors will have the opportunity to view stands and make their own determination of overall project product information.

Vendors should have a good idea of the value of timber and the approximate volumes per acre. The FS has incorporated past data of timber sales to establish a range of lowest to highest acceptable advertised timber rates where bid premiums would be fully applied. If the final appraised rates are higher than the maximum range, bid premiums will be incrementally reduced.