47PL0121R0008 Q_and_A Sheet.pdf
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- Design-Build Services for Anchorage Federal Building (AFB) GSA Office Tenant Improvement Project
- Solicitation number
- 47PL0121R0008
About this file
This document provides a pre-solicitation notice for a design-build contract to renovate office space in the Anchorage Federal Building for the General Services Administration. The project involves renovating approximately 25 workstations on the first floor and includes HVAC, electrical, and IT infrastructure upgrades along with finishes such as acoustic ceiling baffles and polished concrete floors. The contract value is estimated between $1-2 million and the period of performance is 260 calendar days from award. The solicitation will be available on February 9, 2021 at beta.SAM.gov and site visits will be held on February 19. Proposals are due by March 11, 2021 and award is expected in mid-May. This opportunity is reserved exclusively for women-owned small businesses. The selected contractor will be responsible for 65%, 95%, and construction drawings as well as construction services.
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RFP for Design-Build Services for AFB GSA Office Tenant Improvement Project; GSA Solicitation No.
47PL0121R0008; Amendment No. 0002
REQUESTS FOR CLARIFICATION SUBMITTED AND
ANSWERS TO THOSE QUESTIONS
1. Is there a mechanical schedule for this project yet? I just see structural changes but I know HVAC was mentioned. Have the engineers put that together yet?
a. No, the A/E did not develop mechanical drawings for the project. The selected contractor will need to include mechanical engineer(s) as a part of the design team as a portion of the Design-Build contract scope will include designing the mechanical/HVAC plan.
2. Please identify facility operation and maintenance contractor and provide point of contact information.
a. The current maintenance contract is with Northern Management Services (NMS) and any contact information will be provided to the selected Contractor at the project kick-off meeting.
3. Please provide building as-builds, as it does not appear any MEP DID’s were provided.
a. Part of the scope of this design/build contract is to develop HVAC plans. Any available as-built drawings will be provided upon contract award. Please note these as built drawings are very limited in scope and information. The selected contractor will be responsible for verifying the accuracy of any as-built drawings provided.
4. Can you please identify what system, who the maintenance contractor is & a point of contact for the 3 following disciplines: (1) HVAC Controls, (2) Fire Alarm, and (3) Lighting Controls.
a. This is a design build contract, the contractor is responsible for working with the engineers and subcontractors of their choice. With the exception of work on the fire alarm panel, GSA does not dictate which subcontractors to use, provided they are certified in the building systems. The building’s HVAC and lighting controls are JCI systems. The Fire Alarm panel is a Siemens panel but the only certified contractor in Anchorage is GMW Fire Protection, Incorporated (who can be found online at gmwfireprotection.com).
5. Please confirm electronic submission is acceptable and no hard copies are required.
a. Yes, the Government confirms that electronic submission of proposal documents is acceptable and that no hard copies are required.
https://www.gmwfireprotection.com/contact-1
6. [Regarding Technical Evaluation Factor No. 2, Experience and Key Personnel] As a prime, do we need to have the above stated experience? or our SUB's experience can be taken into consideration in order to qualify for the bid. Please advise.
a. Subcontractor experience can be submitted for consideration, but the summary needs to clearly reflect that this is the experience of the subcontractor and not the prime offering firm. That said, additional consideration will be given to those primes who can demonstrate direct experience on projects similar to the one that is the subject of this procurement.
7. Please confirm offer due time. General information states: Mar 11, 2021 03:00 pm EST Closing answer date states: Mar 11, 2012 03:00 pm PST
a. The Offer due time was updated in Amendment No. 0001 to the RFP and is now March 18, 2021, at 3:00pm (PACIFIC Standard Time).
8. Do past performance projects have to be substantially complete in order to show on our technical submission?
a. Yes, past performance projects must be, at a minimum, substantially complete.
9. During the site visit, it was mentioned that asbestos abatement would be performed ahead of this project. Please provide any sampling results or survey relevant to the renovation areas.
a. Please see document titled “7.17 Hazardous Materials Assessment”, provided in the amendment
10. Should the Contractor assume all asbestos materials will be removed prior to this project?
a. Yes, all known asbestos containing materials (ACM) will be removed prior to the beginning of this construction contract.
11. Universal Wastes are present in the form of mercury-containing fluorescent lamps and likely lead acid back-up batteries for emergency lighting. Should the Contractor assume any hazardous wastes, such as PCB-containing lighting ballasts, are present?
a. GSA is not aware of any PCB containing ballasts
b. Contractor is responsible for recycling all fluorescent lamps.
12. Will there be an area available where the Contractor can stage a roll-off container or small dump trailer for demolition debris?
a. No. There is no room for a dumpster to be placed on site. Contractor shall remove their demolition debris daily.
13. Can you clarify if we can use a previously completed PPQ and/or CPARS in lieu of utilizing the PPQ form provided?
a. Yes, using either a previously completed Public Buildings Service (PBS) PPQ form (i.e, the same form that is included in the RFP package that might have been used in a prior PBS solicitation, updated to reflect that it applies to this solicitation) and/or a printout of a final (i.e, not interim) CPARS evaluation can be used in lieu of the PPQ form provided in the RFP package.
14. Can we receive the Sign-in Sheet from the site visit?
a. Yes, a copy of this list is published as a part of Amendment No. 0002to the Request for Proposals (RFP) package. Please see the file within the “47PL0121R0008_A0002.zip” file package entitled “021921 Site Visit Sign-in Sheet.pdf”.
15. Can as-built drawings be made available for reference during the proposal phase so the design team can verify existing conditions especially with regards to the MEP infrastructure?
a. Please see the answer to Question No. 3 above. These will not be made available during the proposal phase.
16. Are DID Specifications and Design Narrative (Analysis) available?
a. No, specifications and narrative were not created as part of the DID.
17. Section 2.1.8 of SOW requires A/E to engage a licensed manufacturer of Sound Masking system. Is the only manufacturer called out in the Sound Marking Performance Specs (K. R. Moeller) a licensed manufacturer? Please clarify the intent of this requirement.
a. Contractor can propose any sound masking system that will meet the design intent and performance specifications provided in the Solicitation. See section
2.1.8.3. “Sound masking design and components to be provided by Archoustics West or Contracting Officer Approved Equal”.
18. Section 2.1.8.3 of SOW indicates sound masking design and components are to be provided by ‘Archoustics West’ (or approved equal). Will this vendor also perform installation of the sound masking system?
a. No, the contractor is responsible for installing the sound masking components.
19. Section 2.1.12 of SOW calls out the following items as ‘Add Alternates’. Please provide information on what should be included as the Base Bid in the event any of the add alternate(s) is (are) not selected:
o Polished concrete floors in reception area, to include blackened steel trim at wall bases.
o Live edge front desk with blackened steel supports.
o Live edge counter in break room.
o ‘Arktura’ Vapor Soft Trail Wall behind reception desk, to include blackened steel vertical trim.
o ‘Arktura’ Vapor Soft Trail Wall on east side of reception area.
o ‘Arktura’ Vapor Soft Trail at ceiling above reception desk, to include inline lighting.
o ‘Arktura’ Softgrid Flux Ceiling Baffles (large conference room) o ‘Arktura’ Softfrid Square Ceiling Baffles (Huddle Rooms).
o Translucent resin panels.
a. In the event of a situation where GSA does not procure the “add alternates” contractor shall consider the following:
i. Polished concrete floors should now be part of the base bid
ii. Live edge front desk - no substitute required (GSA would likely procure as part of the furniture contract)
iii. Live edge counter - no substitute required (GSA would likely procure as part of the furniture contract)
iv. ‘Arktura’ Vapor Soft Trail Wall behind reception desk should now be part of the base bid
v. Arktura’ Vapor Soft Trail Wall on east side of reception area - no substitute required (and GSA would likely procure as part of the furniture contract)
vi. ‘Arktura’ Vapor Soft Trail at ceiling above reception desk - no substitute required
vii. ‘Arktura’ Softgrid Flux Ceiling Baffles (large conference room)- no substitute required
viii. Arktura’ Softgrid Square Ceiling Baffles (Huddle Rooms) - no substitute required
ix. Translucent resin panels - no substitute required
b. The relevant section of The Agreement (i.e, Section II.B, Contract Price Form) has been updated in Amendment No. 0002 to the RFP package so that the language reflected in Part A of this answer is included.
20. Is an acoustical consultant required to be part of the A/E team?
a. This is not a requirement however the acoustic performance of the Conference, Focus and Huddle Rooms is a critical component of this contract. An acoustic consultant will be considered a benefit to the success of the project.
21. [Ref. Sheet G002: Abbreviations & Legends General Note #18] Per this note, is the ‘Supplemental Hazardous Material Report’ available?
a. Please see the answer to Question No. 9.
22. [Ref. Sheet G002: Abbreviations & Legends General Note #20] Per this note, are FP-series drawings and specs available?
a. Fire protection drawings (as builts) are not available.
23. [Ref. Sheet G002: Abbreviations & Legends General Note #21] Per this note, are FA-series drawings and specs available?
a. Fire alarm drawings (as builts) are not available.
24. [Ref. Sheet G002: Abbreviations & Legends General Note #22] Per this note FEC locations are shown on Sheet A103 – no FEC locations found on this sheet. Also not shown on Floor Plan sheet A104. This note also says to confirm FEC locations with AHJ.
Please provide AHJ information – will the local Fire Department be involved with approving FEC locations.
a. FEC locations will be decided during the design phase of this project. The AHJ is a GSA Region 10 Subject Matter Expert (SME) and will be reviewing all design drawings. Coordination with the local fire department is not required.
25. [Ref. Sheet A101: Exit Doors & Egress Plan] In the legend ‘Assembly Concentrated Chair Only’ hatch is shown but not used on the Egress Plan. Please confirm this space function is not applicable.
a. Correct--Assembly Concentrated Chair Only is not applicable
26. [Ref. Sheet A102: Demolition Floor Plan] Demo keynote #4 refers to Mech, Electrical, Plumbing and Fire Protection drawings for demo work – will these be provided?
a. Please see the answer to Question No. 3.
27. [Ref. Sheet A102: Demolition Floor Plan] Demo keynote #11 indicates all existing items not re-used are to be recycled to the maximum extent possible. Are there any GSA guidelines for recycling?
a. Please see Section 3.5.1.5 of the Statement of Work.
28. [Ref. Sheet A103: Demolition RCP Plan, keynote 02] Please provide sheet reference (shown as x/A50x).
a. That reference was a placeholder that should have been deleted prior to the publication of the original DID set. An updated set of DIDs, entitled “GSA_TI 100% DIDs Rev 1”, has been provided in Amendment No. 0002 which corrects this error.
29. [Ref. Sheet A103 Demolition RCP Plan] Please provide information on ceilings of existing hallways north and west of the tenant space.
a. The selected contractor will be responsible for determining this information through the design phase of this project.
30. [Ref. Sheet A104:Floor Plan] Please provide existing wall assembly and fire rating (if any) of the demising wall common with hallways north and east side of the space.
a. The selected contractor will be responsible for determining this information through the design phase of this project.
31. [Ref. Sheet A104:Floor Plan] Please confirm that ABAAS compliant restrooms and drinking fountains are available for the tenants to use in the building.
a. ABAAS compliant restrooms and drinking fountains are available for the tenants to use in the building.
32. [Ref. Sheet A104:Floor Plan] New doors are numbered but no door schedule is included in the DID’s. Should we assume new doors to be solid core with aluminum frame? Are there any STC requirements for the doors?
a. Door schedule and type will be determined through the design phase of this project. All new doors shall match the building standard of solid core with welded steel frames, unless design dictates otherwise.
b. See SOW section 2.1.7 for STC requirements.
33. [Ref. Sheet A104:Floor Plan] At intersection of grid line K & 7 a gap is shown between the new wall and column furring. Is this a drafting error?
a. That was a drafting error and should have been deleted prior to the publication of the original DID set. An updated set of DIDs, entitled “GSA_TI 100% DIDs Rev 1”, has been provided in Amendment No. 0002 which corrects this error.
34. [Ref. Sheet A104:Floor Plan] Please provide more information on the sliding Conference Room door (#03). Is it a solid door or glass door?
a. It should be a glass door. An updated set of DIDs, entitled “GSA_TI 100% DIDs Rev 1”, has been provided in Amendment No. 0002 which shows this as a swing out glass door.
35. [Ref. Sheet A104:Floor Plan] Any supplemental 24-hour cooling required for the Server Room?
a. No supplemental cooling is required for the new IDF.
36. [Ref. Sheet A104:Floor Plan] Is there any fire rating requirement for the Server Room walls?
a. No, there is no fire rating requirement for the Server Room walls.
37. [Ref. Sheet A104:Floor Plan] Please provide electrical requirements of the existing IT rack in the Server Room that is to be reused.
a. This will be determined during the design phase of the project.
38. [Ref. Sheet A104:Floor Plan] Please provide finish information for countertops shown in the Focus Rooms (assuming it is not part of the furniture).
a. No worksurfaces required in Focus Rooms, it will be part of the FF&E contract.
39. [Ref. Sheet A104:Floor Plan] Please provide interior elevations including finish information for Copy Room lower and upper cabinets.
a. There are no cabinets in the Copy Room.
40. [Ref. Sheet A104:Floor Plan] Please provide specs on GSA provided copier and other equipment that will be installed in the Copy Room.
a. GSA assumes that the contractor is attempting to determine electrical requirements….the copier and plotter use a standard 20 amp plug
41. [Ref. Sheet A104:Floor Plan] Will the Conference Room and Huddle Room table require any floor power and data outlets?
42. [Ref. Sheet A104:Floor Plan] Please provide weight information for the VTC equipment (so adequate wall backing can be designed/provided).
43. [Ref. Sheet A104:Floor Plan] Please provide specs and size of the Project screen to be installed in the Conference Room – manual or motorized?
a. This will be determined during the design phase of the project. For pricing purposes assume manual.
44. [Ref. Sheet A104:Floor Plan] A countertop (island) is shown across from the File Storage and Book Shelves. Please provide interior elevations including finish information for this island (assuming it is not part of the furniture).
a. See elevation 9 on sheet A201 for details in the updated set of DIDs, entitled “GSA_TI 100% DIDs Rev 1”, that has been provided in Amendment No. 0002.
45. [Ref. Sheet A104:Floor Plan] SOW indicates instant hot water heater is not required in the Break Room (section 2.24.1.2). Please confirm code required hot water is available for the sink from the building hot water supply.
a. The selected contractor will need to verify during the design phase of the project.
46. [Ref. Sheet A104:Floor Plan] SOW indicates no garbage disposal is required in the break room sink. Please confirm.
a. It is confirmed that no garbage disposal is required.
47. [Ref. Sheet A104:Floor Plan] Section 2.1.15 of SOW requires manual ‘Mecho’ shades at all internal windows. Will they also be required at existing glazed wall that runs along the south boundary of the space?
a. The existing glazed wall that runs along the south boundary (i.e, the wall bordering the building’s atrium) of the space are the only windows that require shades.
48. [Ref. Sheet A105: Reflected Ceiling Plan] Please confirm if existing sloped glazed ceiling require window tinting for glare?
a. Sloped glazed ceiling area is to receive shades similar to vertical glazing,.
49. [Ref. Sheet A105: Reflected Ceiling Plan] Ceiling legend indicates to place wall washers 1/4th the height away from wall whereas ceiling plan note indicates 1/3rd the height away from wall. Please clarify.
a. Wall washers should be ⅓ the distance away.
50. [Ref. Sheet A106: Floor Finishes Plan] Floor transitions are called out on the finish plan as T1, T2 & T3 but the legend does not reference a sheet number for transition details/information. Please provide.
a. Exact type of transition strip shall be determined during the design process. T1 is concrete to carpet; T2 is carpet to carpet; T3 is carpet to vinyl tile.
51. [Ref. Sheet A106: Floor Finishes Plan] Please provide finish information of doors – painted or wood veneer?
a. All doors shall be veneer, factory finished, and match the building standard. For further information, please see the answer to Question No. 32.
52. [Ref. Sheet A107: Furniture Plan] Is the System Furniture wired for power and data?
Unclear if power/data outlets can be provided along the existing glazed wall that runs along the south boundary of the space.
a. The system furniture will be wired for power and data. The exact requirements for power and data to support the needs of the space will be determined through the design phase of this project. Note furniture shown on Sheet A107 was for concept only and will NOT be the final furniture plan.
53. [Ref. Sheet A107: Furniture Plan] Any wall monitors/displays required in the two Huddle Rooms?
a. Assume one wall will require a monitor. Exact size and location of monitor will be determined through the design phase of this project.
54. [Ref. Sheet A107: Furniture Plan] Please provide power and data requirements of the Reception Desk.
55. Can you provide information on the cubicle style, type, size, etc that will be moved into the space?
a. The furniture design is still pending and should be available by NTP. For further information, see the answer to Question No. 52 above. Note furniture shown on Sheet A107 was for concept only and will NOT be the final furniture plan.
56. Does GSA have a preference for providing power/data to the cubicles? Can it come from the south wall or from the ceiling on a power pole?
a. Power poles shall be avoided if at all possible. Instead, the selected contractor shall use power from the floor or wall.
57. There are speakers in the existing space, are those used for a building wide PA system and need to be retained, or do they get demolished?
a. These speakers are part of the building’s fire alarm notification system and shall be reused. They are considered part of the fire alarm system/design and will need to be reconfigured as such.
58. A card reader is listed in the scope for the server room. Are additional card readers needed for access at the exterior doors into the new space?
a. No additional card readers are required - just (1) entering into the server room.
59. Does GSA contract with a company for security/card readers?
a. GSA does have an existing contract in place with a Gallagher certified integrator who can provide pricing and installation of the new card reader. The company’s name is SIS and can be found at https://securityinstallsolutions.com/.
https://securityinstallsolutions.com/
b. Please note that the card reader shall be compatible with the existing Gallagher ePACS, HSPD-12 and FIPS 201-2 compliant, and listed on the GSA APL as an approved product. The GSA APL Number shall be included in the proposal
60. Will fire alarm panel upgrades be required by the Contractor or does GSA have a maintenance contract for this work?
a. The Contractor is required to design and install any fire alarm upgrades. For further information, please see the answer to Question No. 4, above.
61. Are any permits required for this project (Municipality of Anchorage, State of Alaska, etc.)? If so, is the contractor required to pay for them?
a. FAR 52.236-7, Permits and Responsibilities (Nov 91) will be incorporated by reference into the proposed contract, so the Contractor will be responsible for obtaining any necessary permits.
62. Where can we find the insurance requirements for this project?
a. Insurance requirements for the proposed contract can be found in Section III.F of the Agreement. Please see Page 8 of the file within the “RFP Pckg_47PL0121R0008.zip” file package entitled “2 The Agreement.pdf”.
63. Is the contractor required to provide Builder’s Risk insurance for this project? If so, are quake and flood coverage required?
a. Please see the answer to Question No. 63.
64. What is the anticipated amount of time and expense for security clearances or background checks for each employee who needs access to the project site?
a. The Contractor does not pay for security clearances. The average time for security clearances, provided the forms are correctly completed by the employee, is 3-4 weeks.
65. Is the project to be designed to NFPA 101 or the IBC family of codes?
a. It will depend on what specific requirement the contractor is referring to (lighting, egress, etc.). Please refer to the Section 4 Applicable standards, specifically PBS P100 for further information. The link below should take you to where you can access the P100 online.
https://www.gsa.gov/real-estate/design-construction/engineering-and-architecture /facilities-standards-p100-overview https://www.gsa.gov/real-estate/design-construction/engineering-and-architecture/facilities-standards-p100-overview https://www.gsa.gov/real-estate/design-construction/engineering-and-architecture/facilities-standards-p100-overview
66. Are there any fire ratings or fire protection requirements for the building columns? How are they to be wrapped and with what material?
a. The building is classified as Type IB per IBC. Based on the type of columns, the requirements of IBC Type IB shall be followed.
67. What is the building construction type?
a. The building is classified as Type IB per IBC.
68. What is the fire ratings of the building corridors?
a. Per the PBS P100, if the building is provided with fire sprinklers, no fire rated corridors are required (this does not mean that wall penetrations are acceptable to remain if left opened). Also, please be advised that if the wall is a corridor wall/mechanical room wall, the fire rating associated with the mechanical room will be required to be met.
69. The sliding door at the conference room is likely not permissible by code. What type of door is desired for door #03, at the conference room?’
a. Please see the answer to Question No. 34.
70. Is the breakroom sink required to be ADA accessible?
a. Contractor shall follow all applicable standards as per the Architectural Barriers
Act Accessibility Standard (ABBAS). See Section 4 Applicable Standards in the Statement of Work.
71. Does the contractor need to include any hazardous materials abatement in our pricing?
If so , please provide the scope.
a. See answer to Question No. 10.
72. Where can we locate a roll-off dumpster? Can we leave it for the project duration?
a. See answer to Question No. 12.
73. Will GSA provide us and our subcontractors with parking?
a. See section 6.1.1.5 of the Statement of Work.
74. Is the contractor required to provide break room appliances?
a. The coffee pot, microwave, and refrigerator are all existing and will be reused.
Contractor is responsible for ensuring that all appliances fit in the new break area with proper clearances, access to electrical, etc.
75. The work narrative describes structural improvements, but we don’t see any in the work scope. Is there any structural work in this project?
a. All newly installed ceilings, walls, lights, etc. shall be seismically braced as per applicable codes and standards.
76. Please confirm that an emailed bid submission is acceptable.
a. Please see the answer to Question No. 5.
77. Do we need to register with CPARS, prior to submitting a bid?
a. No, there is no need to register with the Contractor Performance Assessment System (CPARS) prior to submitting a bid.
78. Regarding the Standard Form 1442, are we to enter prices on all seven line items listed?
If so, please provide direction on how to break the costs down into the categories listed.
a. The only lines on the SF1442 that will need to be completed by the Offeror are
Nos. 0001 and 0002; the other lines represent Informational SubCLINs that will be used to track Government funding allocated on the contract. These will be determined by GSA at the time of award. Please see pages 6-7 of the file within the “RFP Pckg_47PL0121R0008.zip” file package entitled “2 The Agreement.pdf” (i.e, Section II.B, Contract Price Form) for further details.
79. Is the main telecom room located in the parking garage? Please provide the location of the main building telecom room.
a. See provided attachment “7.16 Drawing - Garage Telecom Room”
80. Can you please provide the site visit sign-in list?
a. Please see the answer to Question No. 14.
81. Is the building slab in the work scope area constructed using post-tension?
a. No, it is mild reinforced cast in place
82. Do the atrium windows receive new window coverings? If so, do both the vertical and diagonal windows receive new coverings?
a. See answer to Question No. 47 above. Sloped area is to receive the same window treatment, but using the sloped glazing accessories.
83. Do you have any as-builts you can provide, specifically for mechanical, plumbing, or electrical?
a. Please see the answer to Question No. 3.
84. Are ACT-1 and ACP-1 the same product?
a. An updated set of DIDs (titled “GSA_TI 100% DIDs Rev 1”) has been provided.
See sheet A601 for ceiling finish schedule.
85. What is ACP-2?
a. See Finish Schedule A-601.
86. Drawing page A104 references detail 9/A201, but this detail doesn’t exist. Please provide this detail.
a. An updated set of DIDs, entitled “GSA_TI 100% DIDs Rev 1”, has been provided as a part of Amendment No. 0002 and can be found in the Google Drive folder entitled “SOW Attachments for Solicitation No. 47PL0121R0008 (Design-Build Svcs for AFB GSA Office Tenant Improvement Project)”. If you have not yet requested access to this folder, please follow the instructions in the original RFP .zip file entitled “0.1 Exhibit 1_GSAAffiliatedCustomerAccounts_May2014.pdf” and submit the email address to the Contracting Officer at colleen.butler@gsa.gov.
b. This elevation is shown on Sheet A201 of the updated DID set.
87. Does the jagged line on the south wall of the Break Area represent a new, 2’ deep, live-edge, bar-style counter?
a. This jagged line represents a live-edge, bar-style counter.
88. Where is the GSA IDF in Module A located?
a. Please see the newly provided SOW attachment 7.17 “Drawing - Location of current IDF”. This attachment was added as a part of Amendment No. 0002 to mailto:colleen.butler@gsa.gov the RFP and can be found in the Google Drive folder entitled “SOW Attachments for Solicitation No. 47PL0121R0008 (Design-Build Svcs for AFB GSA Office Tenant Improvement Project)”
89. [Ref. The Solicitation, page 9; Technical Evaluation Factor on Experience] Do the 3-4 similar projects need to have all of the following or most of the following characteristics?
i. The project involved a modernization and/or renovations to an office suite within an existing building.
ii. The total project construction cost at award of the construction contract(s) was not less than $750,000.00
iii. The project involved phase construction in an occupied building.
iv. The project required close coordination with occupants.
a. Yes, as stated in the write up for the Technical Evaluation Factor on the bottom of page 9: “One similar project is defined as a project that is comparable in nature, type, and complexity as defined by all the following characteristics…”
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