70FA2020R00000004 A00002 Q and A.xlsx

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COBRATF Training Operations and Support Services Federal contract opportunity
Solicitation number
70FA2020R00000004
Issued by
Federal Emergency Management Agency Preparedness Section

About this file

This document contains a request for proposal for training operations and support services at the Chemical, Ordnance, Biological and Radiological Training Facility in Anniston, Alabama. The federal agency issuing the solicitation is the Federal Emergency Management Agency Preparedness Section. Services required include chemical and biological agent training support, air monitoring operations, laboratory support operations, safety control panel operations, contaminated trash removal, site specific training, quality control, protective clothing and equipment laundry operations, and other miscellaneous requirements. The anticipated period of performance is one month for transition followed by eleven months of base period services, with four optional twelve-month periods. Proposals are due by April 16, 2020. This competitive acquisition is limited to eligible small businesses. The incumbent contractor is TET Consulting and Business Management Services under contract number HSFE20-15-C-0169.

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Other files for this federal contract opportunity

Other files attached to COBRATF Training Operations and Support Services, newest first.
File Type Posted
Attachment 30 Safety Plan.pdf PDF
70FA2020R00000004 A00002.pdf PDF
Site Visit Presentation-1.pdf PDF
70FA2020R00000004 A00001.pdf PDF
Attachment 18 Quality Management Procedures.pdf PDF
Attachment 8 FEMA Personal Identity Verification Guidance.pdf PDF
Attachment 15 GFE.pdf PDF
Attachment 14 Occupant Emergency Plan.pdf PDF
Attachment 16 Vehicle Management Procedure.pdf PDF
Attachment 21 Tech Library List.pdf PDF
Attachment 24B Air Monitoring SOPs.pdf PDF
Attachment 5 Workplace Attire.pdf PDF
Attachment 20 TOS SOPs.pdf PDF
70FA2020R00000004.pdf PDF
Attachment 19 CASARM Quality Assurance Plan.pdf PDF
Attachment 9 FEMA Facility Access Directive.pdf PDF
Attachment 26 AMP QC Plan.pdf PDF
Attachment 6 Fitness-Security Request Form.pdf PDF
Attachment 10 FEMA Credentialing Manual.pdf PDF
Attachment 4 Visitor Access.pdf PDF
Attachment 12 CERP Manual.pdf PDF
Attachment 25 Air Monitoring Plan.pdf PDF
Attachment 27 Accident Incident Reporting.pdf PDF
Attachment 17 Facilities Layout.pdf PDF
Attachment 23 Laboratory SOPs.pdf PDF
Attachment 22 Safety Control SOPs.pdf PDF
Attachment 1 PWS.pdf PDF
Attachment 11 DHS Management Directive 11042.1.pdf PDF
Attachment 2 QASP.pdf PDF
Attachment 7 Declaration for Federal Employment Form.pdf PDF
Attachment 24A Air Monitoring SOPs.pdf PDF
Attachment 13 Schedule of Deliverable Reports.pdf PDF
Attachment 29 Hazardous Materials List.pdf PDF
Attachment 3 SCA Wage Determination.pdf PDF
Attachment 28 PC and E SOPs.pdf PDF
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Sheet1

Question #Category or Page #RFP or PWS ReferenceQuestion/CommentGovernment Response
1PWS Section 1.0 GeneralPWS Section 1.3.1.4The PWS section 1.3.1.4 makes direct reference to contractor section leads and technical experts (specifically in the areas of Quality Control, Air Monitoring, NEAT, Chemical, and Biological Laboratory Support, Training Operations, and Safety. Does Government have any restrictions on Dual-Hatting Sections Leads and/or Technical Experts?No restrictions
2PWS Section 1.0 GeneralPWS Section 1.3.4; RFP Cost Price Schedule, pg. 6Section 1.3.4 states, “Licenses required of the Contractor to conduct business (i.e., local or state business license) shall be obtained prior to beginning work on this contract.” The RFP Cost/Price Schedule implies a Phase-In period of 30 days. Does Government anticipate making an award well in advance of the anticipated Phase-In date to ensure adequate time for local or state business or regulatory licenses to be processed by time contract performance begins at the end of the Phase-In period?Yes
3PWS Section 1.0 GeneralPWS Section 1.5.1 Phase-In/Orientation Period RFP Cost/Price Schedule, pg. 6Section 1.5.1 makes no explicit reference to the duration of the Phase-In period though the RFP Cost/Price Schedule implies a 30-day period. Can Government confirm that the duration is to be a 30-day duration or if the Offeror is to provide a duration in their proposal?The Government plans a 30-day phase-in period
4PWS Section 1.0 GeneralPWS Section 1.5.1 Phase-In/Orientation Period; Subsection 1.5.1.6 Obtain employment suitability clearances (CERP); 1.5.1.7 Complete training requirementsSuitability clearances and training requirements are essential to providing the right employees to execute work on COBRATF. Can Government provide an estimate of the time it takes a new employee to be processed through CERP (1.5.1.6.1) and the time it takes to complete each of the training specified in 1.5.1.7?All requirements should be obtainable within 30 days
5PWS Section 1.0 GeneralPWS Section 1.5.1.9 (CERP); PWS Section 6.0 Management Responsibilities; 6.2.2 Work controlIn section 1.5.1.9 there is reference to “…work scheduling and procedures…” and in section 6.0 “…full range of management duties including, but not limited to, planning, scheduling, and quality control…” and 6.2.2 “Contractor shall plan and schedule work to assure material, labor, and equipment are available to complete work requirements within the specified time limits and in conformance with the quality standards established herein.“ Does Government currently utilize software tools for planning and scheduling that includes tracking of material, labor, and equipment resources to enable effective work control? If so, what is the software platform used?The Government uses standard Microsoft Office software that includes Word, Excel, PowerPoint, Project, etc.
6QASP Section 5 - Performance Requirements Summary (PRS)PRS 5.1 and PRS 5.3 per PWS 4.0-5.0; Section J, Attachment 15Will Government provide the source file and or identify system used to maintain Government Furnished Equipment (GFE) inventory/asset lists for efficiency in establishing, maintaining, and reporting GFE inventory by contractor?CDP uses FEMA's Sunflower Asset Management System (SAMS)
7PWS Section 5.0 – Contractor - Furnished Property, Equipment, and MaterialPWS Sections 5.1 – 5.3 RFP CLINs 002, 0004, 1002, 2002, 3002, and 4002Based on the definition of Other Direct Costs (ODCs) provided in the referenced CLINs, are we to assume that the reference to Equipment and Supplies as listed in PWS 5.0 will be covered by these CLINs?Yes
8PWS Section 5.0 – Contractor - Furnished Property, Equipment, and MaterialPWS Sections 5.1 – 5.3 RFP CLINs 002, 0004, 1002, 2002, 3002, and 4002If contractor proposes to provide other equipment or supplies not included or identified in PWS Section 5.0, such as required uniforms, business licenses, IT hardware/software to support local Program Management Office requirements, etc., will this also be covered by the referenced CLINs or should they be included in the price build up for the respective FFP CLINs?These type costs would not be billable to the Government. Should be included in FFP CLINs.
9PWS Section 6.0 Management ResponsibilitiesPWS Section 6.2.2 Work ControlHow are work requirements conveyed to the contractor, by work orders, call tickets, other?Scheduled meetings, training schedules, communication to the contractor through the Government COR and designated representative.
10PWS Section 6.0 Management ResponsibilitiesPWS Section 6.2.2 to 6.2.4PWS Section 6.2.3 is missing. Is that an unintentional omission or an error in numbering? If the former, will Government provide the missing information.Numbering error. No information is missing.
11PWS Section 6.0PWS Section 6.2.8 Energy conservation ProgramWill Government identify the specific/current federal Government Energy Conservation document for the required Energy Conservation Plan?Executive Order (E.O) 13834 Efficient Federal Operations directs federal agencies to manage buildings, vehicles, and operations to optimize energy and environmental performance, reduce waste, and cut costs.
12PWS Section 6.0PWS Sections 6.3 Daily Operations Support; 6.4 Special Tours; 6.5 Emergency Response (ERP) Exercises; 6.6 All-Hazard Exercises; 6.7 Continuity of Operations (COOP) SupportThe PWS sections listed indicate work requirements relative to daily operations and special events such as: Special Tours, Emergency Response Plan and All-Hazard Exercises, and Continuity of Operations support. The level of effort (labor, material, and equipment) for each activity, frequency of activity, and duration of activity are some of the high-level information needed by an offeror to develop a basis of estimate in creating a credible organization, staffing plan, and cost proposal. Will Government provide respective information and work load data relative to the referenced PWS sections?The Government will coordinate with the contractor for these events to ensure no additonal personnel are necessary to meet the requirements.
13PWS Section 7.0PWS Section 7.1 Training Operations SupportThe execution of chemical and biological operational safety procedures at the COBRATF prior to and during the conduct of student training operations at the COBRATF includes many pertinent activities beyond the actual training of students as is evident in Section 7.1 and the related SOP (Section J, Attachments 20 & 22). Will Government provide an estimated number of FTEs by associated labor categories that are anticipated to perform the work described within Section 7.1 for the base year of operations?Staffing to meet the requirements is dependent on the offeror's work plan and approach.
14PWS Section 7.0PWS Section 7.2 Laboratory SupportThe support for chemical, biological, and air monitoring laboratory operations is to be completed with two full-time laboratory technicians with additional support personnel as required. Will Government provide the number of additional support personnel required to perform this work within Section 7.2 by labor category; frequency, number of personnel, and total FTEs anticipated in the base operating year?Staffing to meet the requirements is dependent on the offeror's work plan and approach.
15PWS Section 7.0PWS Section 7.3 Air Monitoring OperationAir Monitoring Operations include a variety of tasks as outlined in PWS Section 7.3 with supporting SOPs and Plans as well as an Air Monitoring QC plan. Will Government provide an estimated number of FTEs by associated labor categories that are anticipated to perform the work described within Section 7.3 for the base year of operations?Staffing to meet the requirements is dependent on the offeror's work plan and approach.
16PWS Section 7.0PWS Section 7.4 Quality Management System (QMS) SupportQMS Support includes numerous requirements as outlined in Section 7.4 and documented as indicated in section 7.4.1. Will Government provide an estimated number of FTEs by associated labor categories that are anticipated to perform the work described within Section 7.4 for the base year of operations?Staffing to meet the requirements is dependent on the offeror's work plan and approach.
17PWS Section 7.0PWS Section 7.5 Industrial Hygiene and Safety ManagementIndustrial Hygiene and Safety Management in the COBRATF environment is of the utmost importance for everyone at COBRATF. Will Government provide an estimated number of FTEs by associated labor categories that are anticipated to perform the work described within Section 7.5 for the base year of operations?Staffing to meet the requirements is dependent on the offeror's work plan and approach.
18PWS Section 7.0PWS Section 7.6 Personal Clothing and Equipment (PC&E) Laundry Ops.Will Government provide an estimated number of FTEs by associated labor categories that are anticipated to perform the work described within Section 7.6or the base year of operations?Staffing to meet the requirements is dependent on the offeror's work plan and approach.
19PWS Section 7.0PWS Section 7.6.15; PC&E SOPs, Pg. 3PWS Sec 7.6.15: “Contractor shall ensure full lifecycle management, efficient tracking, and accountability of equipment using the Wedge Advanced Software Product (WASP)…” PC&E SOP pg3.: 6. Scan the barcode label on each chemical protective over garment to track use in the ADP… (Automated Data Processing) What system is used for ADP?The same WASP system
20RFP Section LSection L.3.B Technical Proposal Instructions/ Content (Volume 1), Section 5 – Experience (Volume 1); Section 6 – Past Performance (Volume 1)This acquisition is 100% set-aside for Small Business concerns. In Section 5, Offerors are required to submit a minimum of three (3) Prime contracts of recent and relevant experience. In Section 6 the requirement is a minimum of 3 without reference to Prime contract. Considering the skill sets required to complete the PWS of this acquisition, there may only be a very small number of small business concerns that can meet this criterion. Will Government consider lessening the requirements in Section 5 and 6 to two examples of experience of which one must be a Prime contract and the second may be a subcontract which it performed relevant work similar in size, scope, and complexity to the subject requirement to increase the competitiveness of this opportunity?As stated in the RFP, in addition to prime contracts, this information may include the relative experience of a predecessor

company (resulting from mergers and acquisitions), major subcontractor(s) (defined as a subcontract with a total value greater than $750,000 over the life of the contract), or Contractor Team Arrangement/Joint Venture (FAR 9.6), or an offeror's parent or affiliated companies (where the offeror's proposal demonstrates that the resources of the parent or affiliated company will affect the performance of the offeror)

21RFP Section MSection M.4 Technical Evaluation Factors, Factor 5 – Experience; Factor 6 – Past PerfWith reference to our question 20, will Government consider lessening the evaluation criterion to match potential changes with the requirements under consideration IAW Sections 5 and 6 as noted in question 20?No, see Question # 20 response.
22RFP Section MSection M.4 Technical Evaluation Factors, Factor 5 – Experience; Factor 6 – Past PerformanceIn Factor 5 the merits of the prime contract(s) is to be considered with the implication that if not all the required Prime contracts identified in Section 5 are submitted, the offeror could be considered non-compliant. However, in Factor 6 there is the caveat that If, “Offerors with no similar past performance will be rated ‘neutral’ for past performance only.” Will Government consider adjusting Section/Factor 5 and Section/Factor 6 to provide consistency and equitable requirements and evaluation criterion for both?See Question # 20 response. Other than prime contracts may be referenced for experience. No, factors 5 and 6 will not be adjusted. Those two evaluation factors are separate and different and require different evaluation criteria. "Neutral" is not an rating option for Experience. "Neutral" is a FAR required rating option for Past
23PWS Section 1.0Section 1.4.1 - Security ClearanceIs there a security clearance level or access required for the Contractor to perform work on this contract? If so, what is the security level required?See Section PWS 1.4.5: Non-CERP personnel are designated moderate risk, and CERP personnel are designated high risk
24PWS Section 1.0Section 1.4.5 – Back-ground InvestigationsIs there reciprocity by FEMA PSD for personnel who hold current active DoD clearances?FEMA security performs an independent background check
25PWS Section 1.0Section 1.3 – Contractor PersonnelAre any of the positions anticipated to be employed by the Contractor for this contract covered by a Collective Bargaining Agreement (CBA)? If so, which labor categories under which Union(s)?Not at this time
26RFP Section LSection L.3.C – Business Proposal InstructionsIn the referenced section, “the proposed firm fixed price shall be based on the requirements of the PWS (attachment 1) and supporting attachments provided under Section J. NOTE: to assist offerors in the preparation of their proposal, the Government considers 22 full time equivalents (FTEs) may be required to complete the requirements.” Though the PWS does describe Tasks to be completed, and the Section J does include list of equipment and SOPs (some of which include specific reference to worker titles) they lack the specificity to create a basis of estimate to support the suggested number of FTEs required by labor category. Will the Government provide sufficient workload data to define the Scope of Work (frequency of activity, number of students, etc.) to establish a basis for firm fixed price level of effort?There is sufficient information in the PWS and attachments to propose the labor amount and mix.
27RFP Section LSection L.3.C – Business Proposal InstructionsIn the referenced section, “the proposed firm fixed price shall be based on the requirements of the PWS (attachment 1) and supporting attachments provided under Section J. NOTE: to assist offerors in the preparation of their proposal, the Government considers 22 full time equivalents (FTEs) may be required to complete the requirements.” Though the PWS does describe Tasks to be completed, and the Section J does include list of equipment and SOPs (some of which include specific reference to worker titles) they lack the specificity to create a basis of estimate to support the suggested number of FTEs required by labor category. Is it the intent of the Government to have an offeror provide a firm fixed price estimate for a Core Crew of 22 FTEs? If so, will Government identify the respective labor categories associated with the projected number of FTEs?This is a performance based contract. Offerors shall propose their labor mix based on the information provided in the PWS and supporting attachments, which is suifficient. The 22 FTEs reference is for informational purposes only. Offerors shall propose their number of FTEs based on the requirements of the PWS.
28RFP Section LSection L.3.C.1, Paragraph 2The RFP states, “Other Direct Costs - Offerors shall use the following “plug-in” numbers for CLINs 0002, 0004, 1002, 2002, 3002, and 4002 for the purpose of proposal preparation for Other Direct Costs. Other Direct Costs include, but are not limited to, materials, expendable and non-expendable equipment, supplies, fully burdened overtime direct labor costs, travel, emergency or temporary subcontracts or labor costs, and, as well as the proposed applicable G&A rate/Handling Fee/Mark-Up applied to those applicable other direct costs. Up applied to those applicable other direct costs. Can the government clarify whether the ODC plug in numbers for CLINs 0002, 0004, 10002, 2002, 3002, and 4002 include or exclude G&A Rate/Handling Fee/Mark-up? In other words, should we submit the ODC “plug-in” numbers as part of our final price without making any change or should we take the “plug-in” numbers, load them with applicable G&A rate/Handling Fee/Mark-up, and submit a higher, fully-loaded ODC number for those CLINs?Offerors shall propose the ODC plug-in numbers exactly as provided in the soitation. The G&A rate/Handling Fee/Mark-up would be paid out of that ODC amounts.
2957 of 68RFP L.3The font shall be no smaller than Courier 12 point, Times New Roman 12 point, or equivalent as the minimum size standard, with no reduction permitted except organization charts or other graphic illustrations; in those instances where reduction is allowable (no smaller than 10 point font recommended).

Does the Government consider a table an illustration? For example, past performance, experience, resumes, process tables, list of assigned roles and responsibilities, etc.

Yes, a table is considered a chart or graphic illustration.
3057 of 68RFP L3The font shall be no smaller than Courier 12 point, Times New Roman 12 point, or equivalent as the minimum size standard, with no reduction permitted except organization charts or other graphic illustrations; in those instances where reduction is allowable (no smaller than 10 point font recommended).
May we use a font no smaller than 10 in a table?No smaller than 10 point font recommended.
3157 of 68RFP L.3The font shall be no smaller than Courier 12 point, Times New Roman 12 point, or equivalent as the minimum size standard, with no reduction permitted except organization charts or other graphic illustrations; in those instances where reduction is allowable (no smaller than 10 point font recommended). Offerors shall ensure that the print is easily readable.
Will the Government please provide examples of an equivalent font style?As stated, Courier, Times New Roman. Other fonts could be Calibri, Arial, etc, as long as it is easliy readable.
3257 of 68RFP L.3The font shall be no smaller than Courier 12 point, Times New Roman 12 point, or equivalent as the

minimum size standard, with no reduction permitted except organization charts or other graphic illustrations; in those instances where reduction is allowable (no smaller than 10 point font recommended). Offerors shall ensure that the print is easily readable.

Are we restricted to Courier or New Times Roman for illustrations? May we use Arial, Tahoma, or others as long as the print is easily readable?There is no restriction or requirement to use Courier or Times New Roman. As state, equivalents may be used as well, such as Arial, Tahoma, etc, as long as it is easily reasable.
3359 of 68RFP Section 5 and 6Section 5 requires the offer shall submit examples of experience. Section 6 requires the offer to submit examples of past performance.
Both of these sections are asking for examples that are similar in size, scope, and complexity. It is unclear to us exactly what the difference is in these two section. It appears to us you are asking for the same information in each section. Will the Government please clarify the requirements in these two sections?Experience is what the contractor has previously or currently performed. Past performance is how well the contractor has previously or currently performed.
3459 of 69RFP Section 5 and 6Section 5 requires the offer shall submit examples of experience. Section 6 requires the offer to submit examples of past performance.
Do the examples of experience in Section 5 and the examples of past performance have to be the same 3 to 5 contracts? May we provide 3 to 5 examples of experience in Section 5 and 3 to 5 different/additional examples of past performance in Section 6?No, while the experience and past performance references may be the same, they do not have to be the same. The references provided for past performance (some or all) may be different than the experience references.
3538 of 69RFP Clause 3052.215-70This clause identifies only the Project Manager as Key Personnel

Will the Government please verify that the only person considered key for this proposal is the Project Manager and that we are only required to submit a resume for our proposed Project Manager?

Answer: The Project Manager is the only position designated as “Key” by the Government as set forth in the contract clause HSAR 3052.215-70, Key Personnel or Facilities 36 38 of 69 RFP Clause 3052.215-70 This clause states "Any additional Key Personnel to be proposed by the offeror/contractor".

Are we limited to the number of key personnel we identify and the subsequent number of resumes we can submit?

No, there is no limit on the proposed number of key personnel.

37 5 of 60 PWS 1.3.1 This paragraph states "The Project Manager is further designated as Key"

We find no other instances in the PWS where the Government identifies a position as key. Will the Government please verify that the only required key position is the Project Manager?

Answer: The Project Manager is the only position designated as “Key” by the Government as set forth in the contract clause HSAR 3052.215-70, Key Personnel or Facilities 38 5 of 60 PWS 1.3.1.1 The name of the Project Manager, and the name(s) of any alternate(s) who shall act for the Contractor in the absence of the Project Manager, shall be provided to the Government as part of the Contractor's proposal.

Although not identified as "Key Personnel" are we required to submit the resume of our Alternate Project Manager or just her name as part of the proposal?

Answer: Only individual identified as "Key Personnel" require submission of the resume 39 39 of 60 PWS 7.3.3.2.1 This paragraph takes the PWS to the 5th level.

To what level is the Government expecting us to respond in our technical volume?

Answer: Expectation of technical volume is to address all requirements 40 44 of 60 PWS 7.6.2.1 Paragraph 7.6.2.1 is titled Laundry/Equipment Suitability Checks. Subsequent paragraphs 7.6.2.1.1 through 7.6.2.1.7 provides a list of certifications and processes.

Will the Government please clarify what this paragraph and each of the subsequent paragraphs are addressing and what you are expecting from us in our technical volume?

Answer: Elements of a program for the operation and maintenance of PC&E equipment and for cleaning and maintenance of PPE. Expection is for the offeror to provide a technical proposal to meet the Governement's requirements.

41 45 of 60 PWS 7.6.2.2 through 7.6.2.2.8 Paragraph 7.6.2.2 is titled Equipment. Subsequent paragraphs 7.6.2.2.1 through 7.6.2.2.8 provides a list of equipment.

Will the Government please clarify what this paragraph and each of the subsequent paragraphs are addressing and what you are expecting from us in our technical volume?

Answer: Elements of a program for the operation and maintenance of PC&E equipment and for cleaning and maintenance of PPE. Expection is for the offeror to provide a technical proposal to meet the Governement's requirements.

42 45 of 60 PWS 7.6.2.3 through 7.6.2.3.10 Paragraph 7.6.2.3 is titled Laundry/Equipment Suitability Checks. Subsequent paragraphs 7.6.2.3.1 through 7.6.2.3.10 provides a list of equipment.

Will the Government please clarify what this paragraph and each of the subsequent paragraphs are addressing and what you are expecting from us in our technical volume?

Answer: Elements of a program for the operation and maintenance of PC&E equipment and for cleaning and maintenance of PPE. Expection is for the offeror to provide a technical proposal to meet the Governement's requirements.

43 47 of 60 PWS 7.6.8 PC&E personnel will meet mandated training requirements stipulated in the CDP Safety Plan (COBRATF)

Will the Government please provide a copy of the CDP Safety Plan (COBRATF)?

Answer: Refer to Attachment 30, CDP Safety Plan 44 46 of 60 PWS 7.6.6.2 PPE requiring certification will be certified by the PC&E personnel IAW applicable regulations. PC&E Laundry Operations SOP, 29 CFR OSHA 1910-134 and CDP Toxic Agent Exposure Control Plan.

Will the Government please provide a copy of the CDP Toxic Agent Exposure Plan?

Answer: Refer to Attachment 30, CDP Safety Plan 45 48 of 60 PWS 7.6.12.1 The system shall also ensure that equipment and tools requiring calibration do not exceed expiration date and that personnel maintain training and certification levels IAW applicable tables within this section.

Will the Government please provide the tables containing the list of training and certification requirements?

Answer: See Section 7.6.6 and 7.6.7 46 53 of 101 Attachment 23 III CDP Safety Plan (COBRATF) – COBRATF Biosafety Manual Annex

Will the Government please provide a copy of the COBRATF Biosafety Manual Answer: Refer to Attachment 30, CDP Safety Plan 47 66 of 68 RFP Factor 2 Consideration will be given to how well the offeror addresses schedule controls, other direct cost accounting and tracking, and management of multiple concurrent work order assignments. Consideration will be given to how well the offeror describes how work orders will be managed to ensure they are efficiently processed in a timely manner.

We are familiar with other contract related work order requirements to include classification and response timelines. However, the PWS makes no reference to work orders, classifications, approval authority, timelines, etc. Will the Government please provide clarification on the work order requirements, classification, timelines, etc. as it relates to this contract? See solictation amendment A00002 for revised Section L Proposal Instructions and Section M Technial Evaluation Criteria. References to work orders have been removed.

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