Questions and Answers RFQ 693JK326RA001.pdf

U.S. Department of Transportation Research Announcement # 693JK326RA001 Pipeline & Hazardous Materials Safety Administration Questions & Response

# RFP Section # / Page #

Government Response

1 Are there award amounts attached to each RA 12 Toping and/or budget cap?

There is no posted award amount or formal budget cap per topic. Proposals will be evaluated individually based on the proposed scope of work and technical approach submitted to meet the solicited project objectives.

2 Accounting System: Provide a copy of the most recent approval (audit report) of the organization/corporation accounting system. Ensure that the approving organization is identified.

While our accounting system is "audit ready" there has yet to be the need for an audit. What needs to be audited? What are the requirements? Who does the approval need to be from? Does this need to be provided upon submission or only if awarded?

If no audit report is available, one of the following would suffice at the time of proposal submission:

1. Formal Non-Audit Attestations such as CPA Review or Compilation Engagement, Agreed-Upon Procedures Report, or CPA Letter of Adequacy.

2. Self-Assessment/Questionnaires such as Standard Form 1408 (SF 1408/Pre-Award Survey of Prospective Contractor Accounting Systems) or Agency-Specific Financial Capability Questionnaires.

3. Internal Financial & Structural Documentation such as Written Accounting Policies and Procedures Manual, Chart of Accounts, Job Costing/Project Ledger Demonstration, or Internally Prepared Financial Statements.

4. Supporting Proof of Operational Compliance such as Payroll Records & Sample Timecards, Bank Reconciliation Statements, or Tax Returns, such as Form 1120, Form 1065, or Form 990.

Pipeline & Hazardous Materials Safety Administration Questions & Response

3 If an organization has never had an accounting system audit, what is acceptable in its place: a CPA's financial statement audit or review letter, a prior federal pre-award survey (for example, from an SBIR award), or a self-certification of GAAP compliance?

See response to Question 2.

4 The RA says no award will be made if a listed attachment is missing. Will a proposal without an audit report be found incomplete?

No, provided the proposal is submitted with one of the acceptable substitutions in the Question 2 response.

5 Background: The RA's budget instructions state that the total cost of consultants and/or subcontractors must not exceed 50 percent of the "proposed amount of Federal contribution to project." The RA also requires the cost application to show the breakout between Federal and non-Federal sources, with resource share detailed to the same degree as Federal costs. Because the limit is expressed against the Federal contribution, we read it as applying to the Federal-funded portion of consultant and subcontract costs.

Question: Please confirm the following:

(a) The 50 percent limit applies to consultant and subcontract costs paid with Federal funds.

(b) Consultant and subcontract costs paid from the non-Federal resource share do not count toward the limit.

If PHMSA intends the limit to apply to total consultant and subcontract costs regardless of funding source, please confirm that instead.

(a) Confirmed

(b) Confirmed

(c) PHMSA confirms the 50% limit only applies to the Federal funding.

Pipeline & Hazardous Materials Safety Administration Questions & Response

6 Background: Topic 1 requires supplemental laboratory testing to ensure consistent seam toughness characterization. For most applicants, this means purchasing standard tests (Charpy V-notch at temperature, metallography, chemical analysis) from commercial laboratories at published per-specimen prices. These laboratories provide the same service to many customers in the normal course of business, operate in a competitive market, provide services that are ancillary to the project, and have no responsibility for project objectives, design, analysis, or performance decisions. These are the characteristics of a contractor relationship described in 2 CFR 200.331(b), as distinct from a subaward. Attachment 4 lists both "Contractual" and "Other" lines, and the RA does not state where such purchases belong.

Question: Please confirm the following:

(a) Fee-for-service purchases from commercial testing laboratories with the characteristics above are not subcontracts for purposes of the 50 percent consultant and subcontractor limit.

(b) These purchases may be budgeted as Other Direct Costs on the "Other" line of Attachment 4.

(c) The same treatment applies to purchased sample procurement and specimen machining services.

If PHMSA considers these purchases subcontracts, please specify which categories of outside purchases do fall outside the limit.

(a) Confirmed. Fee for services would fall into the “Consultant” category.

(b) Confirmed, provided the costs are supported by a detailed budget justification for the costs.

(c) Confirmed if it is a fee for service purchase.

Pipeline & Hazardous Materials Safety Administration Questions & Response

7 Background: The RA states that PHMSA will not fund the purchase of equipment for projects under this announcement.

Topic 1 calls for advancing a technology from TRL 5 to TRL 6/7 through in-ditch field testing, which requires building or modifying research prototype hardware.

That work typically involves purchasing many individual components, each below the equipment threshold, that are incorporated into an experimental apparatus used for the research and not placed into commercial service. The RA does not define equipment and does not address components incorporated into a research prototype or used to modify an existing applicant-owned instrument.

Question: Please confirm the following:

(a) Components with a per-unit acquisition cost below the equipment threshold in 2 CFR 200.1 are supplies/materials, including when they are incorporated into a research prototype NDE apparatus or used to modify an existing applicant-owned instrument for the purposes of the project.

(b) Building or modifying such a research prototype from these components is not a purchase of equipment for purposes of the RA's equipment restriction.

Equipment is defined in accordance with 2 CFR § 200.1 as tangible personal property having a useful life of more than one year and a per-unit acquisition cost that equals or exceeds $10,000 (or the applicant’s lower established capitalization threshold).

Individual components, prototype materials, or research apparatus acquired below this threshold are classified as supplies/materials rather than equipment.

Applicants should categorize line items accordingly in their proposed budget breakdown.

8 Background: The RA requires firm letters of commitment for resource sharing with the proposal, and states that resource sharing arrangements need not be finalized until the project is approved for award. The form of the letter is clear when a third party contributes. It is less clear when the applicant provides the entire resource share in cash, including funds available to the applicant under committed financing.

Question: Please confirm the following:

(a) When the resource share is the applicant's own cash, a commitment

(a) & (b) - Confirmed, provided the recipient must have a financial or accounting system capable of tracking and verifying that the cash contribution was actually spent on the project, it does not come from another Federal source, and the terms, valuations, and verification process of the cash cost share are established in the negotiated Article/Clause on Cost Share within the binding agreement.

Pipeline & Hazardous Materials Safety Administration Questions & Response letter signed by an authorized officer of the applicant satisfies the commitment requirement at submission.

(b) Cash available to the applicant under committed financing is an acceptable form of cash resource share.

If not, please specify what additional documentation would satisfy the requirement at submission

9 Background: The Attachment 3 template example shows resource share varying by item, including several items with no resource share, while the project total meets its requirement.

The RA asks that Federal and non- Federal amounts be shown per task, and Attachment 8, Section 4.01 refers to each task meeting its cost share requirement. The RA also sets two minimums: 50 percent for research topics developing technology and 20 percent for research topics developing knowledge. Projects under a technology development topic often include tasks that are not themselves technology development, such as sample acquisition and laboratory characterization, which are closer in nature to knowledge-development work.

Question: Please confirm the following:

(a) Consistent with the Attachment 3 example, resource share may vary by task and by quarter, provided the total project resource share meets the minimum for the topic.

(b) For tasks within a technology development topic that are not themselves technology development, such as sample acquisition and

(a) Confirmed. Resource share contributions may vary by task and across billing quarters, provided that the overall cumulative project budget meets or exceeds the required cost-share minimum for the assigned topic.

b) Disagreed. The minimum resource share threshold (50% for Technology Development, 20% for Knowledge Development) is governed by the overarching topic category. Individual tasks cannot be assigned a lower topic threshold to create a blended project rate.

Pipeline & Hazardous Materials Safety Administration Questions & Response laboratory characterization, the resource share rate the RA sets for non-development topics may be applied to those tasks, with the project total shown against that blended minimum.

10 Background: The RA states that PHMSA intends to make multiple awards and that reviewers will assess whether proposed costs are appropriate to the scope. The RA does not state total funding available, an anticipated award range, or estimated funding by topic. Knowing the expected scale helps applicants size scope and resource sharing so that proposals are realistic for a 12-month project.

Question:

(a) Does PHMSA anticipate a maximum Federal contribution per award or per topic, or a limit on Federal spend per 12-month period?

(b) In particular, is a Federal contribution on the order of $500,000 for a single 12-month Topic 1 award outside what PHMSA anticipates?

(a) PHMSA has not established fixed maximum award ceilings or topic caps, for this solicitation. Each proposal will be evaluated individually on its technical merit, feasibility, and whether the proposed costs are reasonable and necessary to achieve the solicited project objectives.

(b) PHMSA does not disclose benchmark funding amounts or set limits for individual proposals. Applicants should propose a budget that realistically reflects the necessary scope, resources, and technical effort required to meet the 12-month objectives.

11 Topic 16 requires the desired application move from TRL 2 to TRL 7/8. Will PHMSA consider proposals that are longer than the stated 12-month timeline?

PHMSA requested projects in all topics to be completed within a 12-month period of performance.

12 What is the envisioned scale of the "geographically bounded pilot program"?

Is it more important for the pilot program to prioritize a large geographic area or the volume of actionable reports received?

PHMSA does not prescribe a specific geographic size or minimum volume of reports for the pilot program. Applicants should propose a pilot scale and methodology that effectively demonstrates operational feasibility, validates the technology or process, and generates sufficient actionable data to satisfy the project’s technical objectives. Proposals will be evaluated on the quality, relevance, and actionability of the pilot data rather than geographic size alone.

13 Can PHMSA clarify the meaning of "precise GPS coordinates"? What level of spatial precision is envisioned?

PHMSA does not mandate a specific level of spatial precision or sub-meter accuracy tolerance. It is up to the applicant to

Pipeline & Hazardous Materials Safety Administration Questions & Response define, propose, and justify the required level of GPS spatial precision based on what is necessary to successfully solve the requested project objectives and validate their proposed technology.

14 We are preparing a proposal in response to Research Announcement 693JK326RA001 and would appreciate clarification regarding letters from participating pipeline or facility operators.

May applicants submit letters confirming an operator’s willingness to participate on the Technical Advisory Panel or assist with project testing and validation when the operator is not providing resource sharing or cost share?

If these letters are permitted, should they be submitted as separate proposal attachments, and would they be excluded from the 20-page proposal limit?

We understand that letters documenting resource-sharing commitments are required separately. Our question concerns operator participation letters that do not include a resource-sharing commitment.

Yes, they should be submitted as separate proposal attachments.

15 The research objective is identified as an evaluation of “composite reinforced transmission pipelines”. This may include high-pressure structured composite pipes used in the replacement of transmission pipes under special permits.

However, the project scope identifies the repaired samples as “composite-lined cured-in-place lining". We are requesting clarification about which type of the above two rehabilitations is to be covered in the project.

This research project will establish a defensible and repeatable methodology to quantify the structural contribution of composite liners and translate measured performance into metrics usable for engineering assessment, operational decision-making, and regulatory acceptance.

If the scope or project type appears ambiguous, offerors must explicitly state in their proposal which technology or rehabilitation method they intend to pursue.

Pipeline & Hazardous Materials Safety Administration Questions & Response

16 Could you please clarify whether each organization must submit an audit report with the application, or whether the prime organization's audit report will suffice?

Just the prime as PHMSA does not enter into agreements subrecipients/subcontractors.

17 Is an offeror that has never held a federal contract eligible for award under this RA?

Such an offeror has never had a Federal agency review of its accounting system

Yes, provided they have an active registration in the System for Award Management (SAM.gov) at the time of proposal submission.

18 If so, what should such an offeror submit in place of an official government audit report or approval letter?

See response to Question 2.

19 Would it be acceptable to supply an independent CPA attestation of GAAP compliance, or a self-certification?

Either is acceptable.

20 Is the audit report or approval letter required at proposal submission, or only before award or before the first invoice?

Proposal submission.

Pipeline & Hazardous Materials Safety Administration Questions & Response