80JSC020OME Draft RFP QA Part 1.pdf
PDF 361 KB Posted
- Attached to
- Orion Main Engine Federal contract opportunity
- Solicitation number
- 80JSC020OME
About this file
This document contains questions and answers regarding a Draft Request for Proposal for the Orion Main Engine. The solicitation seeks proposals for the production of up to 16 Orion Main Engines to be used on NASA's Space Launch System and Orion spacecraft. Key details include that the anticipated period of performance is from November 2020 through May 2031, with engine deliveries scheduled through 2033. Offerors are invited to submit questions to the contact provided by January 21, 2020 for consideration before issuance of the final RFP. The Draft RFP and any amendments will be made available on the specified government website.
View the file
Other files for this federal contract opportunity
Show all 20
On GovTribe
Work with this file on GovTribe
- Download the original file
- Contacts named in this file
- Similar government files
- Ask GovTribe AI about this file
Text version
80JSC020OME
DRAFT RFP
Question and Answers
Question Answers
1 Please clarify that the OME
Contractor does not integrate the
OME into the Orion ESM, rather the Contractor will be responsible for ensuring the OME meets the
ESM interface requirements. Ref:
OME Contractor DD250's OME to
NASA, as stated in Section 2.2, d.
The Orion Main Engine (OME) contractor will not be responsible for integrating the OME into the Orion European Service Module (ESM).
The Final Request for Proposal (RFP)
Attachment J-1, Performance Work Statement, Section 1 will be updated to clarify “The OME
Contractor will be responsible for ensuring the
OME meets the European Service Module
(ESM) interfaces and that required ground support equipment is provided to integrate the
OME into the ESM." Draft RFP Performance
Work Statement (PWS) Section 12.2.1 states
"The Contractor shall support NASA and ESA during ground operations with technical assistance. The Contractor shall be present at the Airbus Defence & Space Bremen, Germany, facility for installation of the first OME on ESM.
Examples of technical assistance include, but are not limited to, on-site engine expertise during engine installation, testing, engine processing, and operations reviews."
2 Confirm the cited Key Personnel past performance needs to be within the last 10 years similar to the three past performance contracts.
The Key Personnel past performance will be evaluated for the last 5 years. The Past
Performance of the Contractor will be evaluated within 10 years from the date of the Original
Solicitation. Section L.17.6 (b) has been updated to read “Provide information from organizations and companies for which the Key
Personnel position listed in Section H 1852.235-
71 KEY PERSONNEL AND FACILITIES has previously performed work, in the past 5 years in order for the Government to obtain appraisals of past performance via the Key Personnel Resume in Attachment L-7.”
3 Do the Key Personnel past performance references cited in
Section L require a past performance questionnaire(s)? If so, how many?
Yes, the Key Personnel past performance reference requests submission of Attachment L-
3, Past Performance Questionnaire.
Section L.17.6 52.214-114 Past Performance
Information (h) states, " In addition to the information above, Offerors, any major/minor subcontractors, as defined in L.17.8
Responsibility Considerations, proposed program manager, and any other organizational entity (parent or affiliated company, division(s), business units, or segments of your company, which is considered to provide meaningful involvement in contract performance), shall each submit the Past Performance Questionnaire, Attachment L-3, to all of the point of contact references required in paragraph (d) above. The
Offeror is responsible for ensuring that all references are directed to return two copies of each questionnaire directly to the Contracting
Officer in a sealed envelope, or e-mail to the contact identified in Provision L.17.3
PROPOSAL MARKING AND DELIVERY
THROUGH LARGE FILE TRANSFER (LFT).”
4 Please confirm that it is up to the
Offeror to determine which positions are Key Personnel.
The Key Personnel Position will be identified in the Final RFP in Section H per 1852.235-71, Key Personnel and Facilities.
5 Would NASA like a new tab and duplicated table for each referenced past performance contract?
No, the instructions for filling out the Past
Performance Matrix are located in in Attachment
L-5, Past Performance Matrix, in the box titled
“Note to Offerors”. The offeror should provide only the Past Performance information for the number of contracts outlined in L.17.6, JSC
52.215-114 Past Performance Information. An updated Attachment L-5, Past Performance
Matrix, will be provided at Final RFP.
6 Please clarify what is expected in the Past Performance Matrix
"Legend of Resources for Past
Performance of Parent/Affiliate" table.
The Legend of Resources Provided for Past
Performance of Parent/Affiliate is to indicate what type of work was performed that is relevant to the Performance Work Statement. The
Attachment L-5, Past Performance Matrix will be updated in the Final RFP.
7 This section addresses both contract past performance and Key
Personnel past performance. To ensure offerors comply with the requirements, please separate the instructions for contract past performance and Key Personnel past performance.
The final RFP will include more detailed instructions concerning past performance of Key
Personnel and of contracts in L.17.6 JSC 52.215-
114 Past Performance Information.
8 Please clarify that [contract past performance and Key Personnel past performance] questionnaires should be sent to the contracting officers for the three contracts cited as past performance, and that additional questionnaires may be sent for each of the OME Key
Personnel identified by the offeror, if the Key Personnel's relevant performance is not on one of the three contracts cited in the past performance section.
The RFP L.17.6(a) states that "Offerors shall demonstrate past experience in all areas of the
Performance Work Statement by submitting information on up to 5 past contracts that best demonstrates their ability to perform the OME work," which includes Key Personnel.
The Key Personnel is identified in 1852.235-71
KEY PERSONNEL AND FACILITIES (MAR
1989).
9 Please confirm total page count is
130 pages. Recommend that volume page count only be at the sub factor level. This will allow offeror to manage the page count for sub sections as long as sub factor level page count is not exceeded.
The page count will be updated in L.17.2, Proposal Arrangement, Page Limitations, Copies, and Due Dates in the final RFP. The page limitation for each section ensures sufficient response is provided for each subsection.
10 Recommend "Approach to
Production" be a total of 20 pages.
Not broken into 5 and 15 pages.
The final RFP, Table L-2: Overview of Proposal
Volumes, Page Limitations, Copies, and Format will be updated to read a total of 10 pages. The page count has been updated because the OME
Work Plan-Production, DRD OME-M-003 has been removed from the “Approach to
Production” and will be evaluated under
“Approach to OME Certification and OME
Production Milestones.”
11 Recommend IMS be MS Project or pdf document.
Table L-2: Overview of Proposal Volumes, Page
Limitations, Copies, and Format will be updated to align with Attachment J-2, Data Procurement
Documents (DRD), OME-M-002 delivery method. The delivery method in DRD OME-M-
002 has been updated in the Final RFP.
12 Please clarify the intent of the line item [in Table L-2 Overview of
Proposal Volumes, Page
Limitations, Copies, and Format] for Alternate Standards DRD OME-
T-094.
The Table L-2 will be updated in the Final RFP to show that the "Approach to Meeting the Intent of Technical Standards" has a combined page count of 15 pages which includes the DRD
OME-T-094 submission.
13 Recommend Graphics be minimum
8-pt. Arial. This is normal industry standard and allows for clearer graphics.
The L.17.4.1, 52.215-113 Proposal Formatting
Instructions (a)(2) requires "compressed Times
New Roman font" and "Text in diagrams, charts, tables, artwork, and photographs shall be no smaller than 12 point text size."
14 Please confirm Reference to FAR clause is 3.104-4, not 3.104-5.
Yes, the reference should be to FAR 3.104-4, Disclosure, Protection, and Marking of
Contractor Bid or Proposal Information and
Source Selection Information. The RFP will be updated to incorporate the change.
15 Please confirm 2-page limit is per resume.
Yes, Attachment L-7 Key Personnel Resume states: "The resume shall not exceed two pages."
16 Recommend files submittal include
.pdf as primary delivery.
In accordance with L.17.4.1, 52.215-113
Proposal Formatting Instructions, the proposal shall be submitted in Word except for the
Integrated Master Schedule and Schedule
Deliverables (OME-M-002).
17 Please provide size limitation on the
.zip file.
There is not a size limitation on the for proposal submission in the proposal submission instructions outlined in L.17.3 PROPOSAL
MARKING AND DELIVERY THROUGH
LARGE FILE TRANSFER (LFT).
18 Will NASA please consider releasing the model contract prior to the final RFP release to enable
Offerors to review and plan accordingly?
The model contract will not be release prior to the final RFP release. NASA will release the model contract with the final RFP and allow additional time for offerors to submit questions.
19 The cover letter states the OME contract is anticipated to have a period of performance of 10 years and 7 months from November 1, 2020, through May 31, 2031.
Attachment J-9 shows engine deliveries through 2033. Please clarify.
The OME Ordering Period will be delineated in
Section H, 52.216-18, Ordering, with an
Ordering period from Date of Award through
May 31, 2031, which is the last day to place the order.
Section H Clause 52.216-22, Indefinite Quantity, will allow deliveries up to 36 months beyond the end of the ordering period.
20 During development testing, will international propellants meeting
MIL specs be acceptable to NASA?
International propellants are acceptable as long as they conform to Multi-Purpose Crew Vehicle
(MPCV) 70156, Cross Program Fluid
Procurement and Use Control Specification listed in Attachment J-3, Applicable, Meet The
Intent, Informational, and Tailored Documents
List. In MPCV 70156, Table 3.5-23 states the
“Procurement shall be to Specification MIL-
PRF-27404, Propellant, Monomethylhydrazine.
In addition, Table 3.5-25 state that “Procurement shall be to Specification MIL-PRF-26539, Propellants, Dinitrogen, Tetroxide, MON-3.”
21 Does NASA plan the resulting
OME contract to a be a phased award where more than one bidder is selected initially to compete during the initial phase with a down select for the production on the
OME?
The OME acquisition will be a single-award
IDIQ contract with the ability to issue Firm
Fixed Price (FFP) orders.
22 Section L.14.3.1 (a) (2), page 12, states, "Text in diagrams, charts, tables, artwork, and photographs shall be no smaller than 12 point text size." To enhance readability and the efficacy of diagrams, charts, tables, artwork, and photographs we recommend NASA consider, "Text in diagrams, charts, tables, artwork, and photographs shall be no smaller than 10 point Arial text size."
See answer to Question 13.
23 Section L.14.6 details a minimum order of 4 production engines with a maximum of 16 production engines.
Would NASA consider an order structure of a minimum of 4 flight engines at a time? This would allow bidders to propose a cost and schedule that maximizes economies of scale and reduces performance risk to the mutual benefit of NASA and potential bidders alike.
The final RFP Section B will request the offeror to price out order quantities of 1-4 engines in the year that it is ordered. The order quantity will be determined by the Government’s need at the time of the order.
24 Will NASA provide a model contract as part of the Draft RFP for review and comment prior to the
Final RFP? Subsection M.6 of
Section M - Evaluation Factors for
Award does not include a model contract nor information regarding ownership of Intellectual Property during the execution of the contract.
We recommend NASA release a model contract as soon as possible in advance of the Final RFP for review and comment as part of the draft procurement package.
Obtaining a model contract prior to
The model contract will not be released prior to the final RFP. NASA will release the model contract with the final RFP and allow additional time for offerors to submit questions. The Final
RFP will include information regarding ownership of Intellectual Property during the execution of the contract in Section H, Section
I, and Section L.
Final RFP is a crucial element in the process of offerors deciding whether to pursue the opportunity.
25 Table 5.3.2-3 of MPCV 72634
Technical Requirements
Specification references the following sections that are marked as "Reserved": 5.3.2.13, 5.3.2.14 and 5.3.2.15. Are these sections to be included in the Final RFP? We recommend NASA either include them if they will be qualification test requirements, or removed if not for this program.
The sections marked as “Reserved” were MPCV
72634 Technical Requirements Specification requirements that were not longer required for the Final RFP. NASA will leave these as
Reserved for the Final RFP.
26 Is the current engine compliant with the requirements stated in the Draft
RFP? It would be beneficial for
NASA to provide a compliance matrix for the current engine program for comparative analysis and a concept of technical specifications between the existing engine and this opportunity.
The heritage engine was designed before the requirements for the MPCV program requirements were approved. The requirements for the OME reflect the updated MPCV requirements. A compliance matrix will not be provided.
27 We understand prospective bidders will have to put use agreements in place with certain government organizations and facilities to execute the proposed program, however it is unclear how the costs for those facilities will be accounted for in the evaluated price and have no basis to estimate costs. We recommend NASA establish a standard price based on the anticipated scope of the proposed program for Government range and test facilities and have those costs included in a Government Provided
Services and Equipment (GPSE) section wherein bidders can acknowledge whether or not they plan to take advantage of
Government range and test facilities as provided. If bidders elect to take advantage of GPSE, the standard price for that GPSE is added to the
Section L in the Final RFP will provide instructions detailing how the Government Task
Agreement (GTA) shall be requested, priced, and how the Government will conduct evaluations.
bidder's proposed price and is evaluated as part of the total evaluated price for their offering.
Subsequent to final selection, the successful bidder will provide a detailed SOW and put in place a subcontract with the Government range and test facilities necessary to provide the deliverables required by the contract. This approach establishes a standard cost as determined by the Government for the use of GPSE and levels this price component across potential bidders that choose to take advantage of it. It also takes the burden of developing individual cost responses for potential bidders off the individual GPSE providers during the proposal phase, narrowing this effort to only successful bidders subsequent to contract award.
28 Will lists of drawings, functional descriptions, locations, and availability of all GSE used in the current related engine program be provided to prospective bidders to avoid duplicating those costs as part of any proposed bid for the OME program?
Ground Support Equipment (GSE) will not be provided under this contract; however, NASA will provide a list of examples in the Technical
Library of GSE used at Bremen, Germany for the final Request for Proposal. At this time, there is not government property available in time for use on the OME contract.
29 Section 2.2 (c) & (d) detail Pre- and
Post-Ship HARs, specifically in regard to Post-Ship HARs being classified as a Pre-Ship HAR if an engine is sent to storage after production. NASA might consider clarifying whether an engine placed in storage will need both a Pre-Ship
HAR (Storage Review) and Post-
Ship HAR, or just a Post-Ship HAR to better inform the program plans and costs from prospective bidders.
The Pre-ship Hardware Acceptance Review
(HAR) and Pre-ship Review are different reviews. If the engine is to be shipped after the
Pre-ship HAR and not go into storage, then the
Pre-ship HAR will include a Pre-ship Review
(PSR). If the engine will go into storage after the Pre-ship HAR, then the Pre-ship HAR will include a Storage Review. Prior to an engine in storage being shipped, a Pre-ship Review (PSR) will be held. The PWS Section 2.2 (d) will be updated to read "If the engine was in storage, then a Pre-ship Review shall be held either as a standalone review or as part of the Post-ship
HAR."
30 What type and scope of effort is anticipated in special studies; are special studies to be determined by the contractor, or are they dictated by NASA? Section 2.3 states, "The
Contractor shall perform special studies and analyses, provide materials, fabricate incidental hardware in support of this contract, and/or store hardware as required."
Does NASA have specific examples of special studies tasks contractors may be required to perform? NASA might consider providing a model special study task that can be reviewed for purposes of evaluation of cost and schedule. Additionally, NASA may simply consider evaluating prospective bidders by having them provide a list of representative labor categories and burdened labor rates that may be used for study tasks.
The Special Studies are driven by the
Government's need by issuing a task order. The
Final RFP Attachment J-1 will have updated language to read “In accordance with
Attachment J-1, Performance Work Statement, the task ordering procedures and other terms and conditions in the contract, the Contractor shall perform special studies, test and analyses, as initiated by the Contracting Officer. IDIQ tasks may include performing technical, cost, schedule and risk assessments for potential new requirements or changes to existing requirements, as identified by the Government, for their impact on the Contractor’s design, schedule, and price as it relates to OME or life cycle activities; performing additional analyses, modeling, and/or tests of hardware to provide further confidence and understanding of robustness of design and advance planning, feasibility or trade studies for development or certification activities.” Section L will include pricing instructions for the work in the final
RFP.
31 Section 2.3.1 requires the contractor to evaluate proposed requirement changes per the MPCV Change
Request process. We recommend
NASA clarify if these changes are flowed down from the Orion program or if they include those changes that may emanate from the anticipated OME development.
Section 2.3.1 was deleted from the PWS.
32 Section 2.3.1 states, "The OME storage requirements will be procured via FFP task order. NASA reserves the right to determine, on an as needed basis, if there is a need to procure storage facilities using
Sub-CLIN 0003C." Would NASA consider allowing offerors the opportunity to integrate this storage with the storage related to production phasing and completion?
Section 2.3.1 was deleted from the PWS. As long as the offeror meets the PWS Section 2.4, OME Storage, the government does not detail what the facility the OME contractor decides to use.
33 NASA may consider sharing Time
& Material specifications for CLIN
0003. Access to these specifications would improve accuracy of the proposal; as it stands there is little understanding of basis of scope and costing/pricing. NASA could choose to define sample support tasks with specific scope to enable bidding. This approach may provide
NASA some insight on costs and schedule for representative tasks for evaluation purposes.
NASA has considered all contract types, but have determined that all work under this contract is best suited to FFP. Contract Line Item
Number (CLIN) 0003 is a Firm Fixed Price
CLIN. The offeror will provide Standard Labor
Category rates at proposal. As tasks are identified, the quantity and skill mix required will be negotiated via a task order and added to the contract.
34 Is Sub-CLIN 0003(b) missing from
Section 2.3.1 of Attachment J-1
Performance Work Statement? We recommend NASA review Section
2.3.1 for accuracy and amend as necessary.
Sub-CLIN 0003(b) and Section 2.3.1 has been deleted from the Final PWS.
35 We recommend NASA provide information on all parties affiliated with the European Space Agency for knowledge to plan travel, coordinate integration specifics, and draft agreements between agencies necessary to inform proposal and perform on any contract resulting from the OME solicitation (e.g., TAAs).
The Final RFP will include points of contacts for
GTA’s and additional information needed to respond to the RFP.
36 Form 254 is listed as an applicable document. Is it anticipated that the
OME program may contain some aspect of classified information?
We recommend NASA clarify whether the OME program may contain classified information as any classified requirements may have an impact on facilities and personnel for which a prospective bidder would need to account in terms of cost and schedule.
The OME project will not be classified. The
DD254 has been removed from the final RFP.
37 It would be beneficial to NASA to coordinate visits, briefings, and tours of current operations to familiarize prospective bidders with
The Pre-Proposal Conference will detail information about the OME Requirement. Any additional information will be provided in the
OME Technical Library.
the current operations for which the
OME is intended, to provide better context to improve cost and schedule estimates, and encourage a more fair and open competition.
38 Will there be an option for one on one conferences during/after the pre-bid conference time frame? If so, will it be a presentation format or question and answers?
The OME Pre-Proposal Conference will include the ability for interested parties to schedule one-on-one conferences immediately following the
Pre-Proposal conference. One-on-ones are an opportunity for the government to answer interested parties questions. Additional information concerning registration and meeting location information will be posted on the
Governmentwide point of entry.
39 In 2019, NASA stated that the
OME procurement will be guided by the Buy American Act, 41
U.S.C. § 83, and Federal
Acquisition Regulation (FAR) §
25.001. Any end product resulting
from work under the OME contract must comply with the Buy
American Act or fall under one of the Act’s exceptions. Has there been any change to this direction?
Yes, after further review, FAR 52.225-5, Trade
Agreements is applicable to this procurement.
40 Is the page count per section intended to cover the entire Initial
Submittal of the DRD requested in that section? If so, we recommend increasing the management approach DRD OME-M-001 pg count from 20 pages to 30 pages.
The page count is intended to cover the entire submittal of the DRD. The OME Page Count has been updated to 30 pages for OME-M-001.
41 Is the intended Initial DRD scope modified by Section L details?
Example: L.14.4.1 Overall
Management Approach – Mission suitability Subfactor 1 is provided
20 pages. Does that include the entire OME-M-001 as defined in the J-2 (addressing all 15 defined sections/requirements) or is the offeror to provide an initial overview OME-M-001 submittal that focuses on the 3 key items explicitly highlighted in L.14.4.1?
The final RFP has been updated to only require the submission of OME-M-001 and the paragraphs have been removed in L.17.5.1
Overall Management Approach – Mission suitability Subfactor 1. The Page count in Table
L-2: Overview of Proposal Volumes, Page
Limitations, Copies, and Format is for the entire
DRD located in L.17.5.1 Overall Management
Approach (Ma) - Mission Suitability Subfactor
1.
42 How will a foreign entity be able to have access to the export control documents?
According to NASA NASA Procedural
Requirement (NPR) 2190.1C, “NASA Export
Control Program”, NASA is restricted from sharing export controlled data unless a formal agreement or approved contract is in place:
2.1.3. In principle, exports or transfers of export-
controlled items (including transfers of commodities, software, technical data, technology, and/or defense services, and/or technical assistance ITAR and EAR) will not be made to any foreign entity under any NASA program unless the exporter is confident that such exports or transfers are in conformity with approved contracts or agreements (usually international agreements) and U.S. export control laws and regulations, as delineated in 22
CFR pts. 120-130 and 15 CFR pts. 730-774.
Further, NASA exports to foreign entities will only be conducted in furtherance of NASA agreements or contracts, when there is a mission requirement and an appropriate export authorization can be used.
In addition, NPR 2190.1C states in Chapter 3, NASA Export Control Process that contractors are responsible for obtaining their own export authorization required to perform their work:
“3.1.2 In general, NASA is not responsible for contractors' export compliance in the execution of contracted work.”
A foreign entity can receive access to the export control documents by obtaining a Technical
Assistance Agreement in accordance with 22
CFR§ 124.1 Manufacturing license agreements and technical assistance agreements to receive the export control data.
“§124.1 Manufacturing license agreements and technical assistance agreements.
(a) Approval. The approval of the Directorate of
Defense Trade Controls must be obtained before the defense services described in §120.9(a) of this subchapter may be furnished. In order to obtain such approval, the U.S. person must submit a proposed agreement to the Directorate of Defense Trade Controls. Such agreements are generally characterized as manufacturing license agreements, technical assistance agreements, distribution agreements, or off-shore procurement agreements, and may not enter into force without the prior written approval of the
Directorate of Defense Trade Controls. Once approved, the defense services described in the agreements may generally be provided without further licensing in accordance with §§124.3 and
125.4(b)(2) of this subchapter. The requirements of this section apply whether or not technical data is to be disclosed or used in the performance of the defense services described in
§120.9(a) of this subchapter (e.g., all the information relied upon by the U.S. person in performing the defense service is in the public domain or is otherwise exempt from licensing requirements of this subchapter pursuant to
§125.4 of this subchapter). This requirement also applies to the training of any foreign military forces, regular and irregular, in the use of defense articles. Technical assistance agreements must be submitted in such cases. In exceptional cases, the Directorate of Defense Trade
Controls, upon written request, will consider approving the provision of defense services described in §120.9(a) of this subchapter by granting a license under part 125 of this subchapter.”
Accessibility Report
Filename:
80JSC020OME Draft RFP Q&A Part 1.pdf
Report created by:
Organization:
[Enter personal and organization information through the Preferences > Identity dialog.]
Summary
The checker found no problems in this document.
Needs manual check: 2
Passed manually: 0
Failed manually: 0
Skipped: 0
Passed: 30
Failed: 0
Detailed Report
Document
Rule Name Status Description
Accessibility permission flag Passed Accessibility permission flag must be set
Image-only PDF Passed Document is not image-only PDF
Tagged PDF Passed Document is tagged PDF
Logical Reading Order Needs manual check Document structure provides a logical reading order
Primary language Passed Text language is specified
Title Passed Document title is showing in title bar
Bookmarks Passed Bookmarks are present in large documents
Color contrast Needs manual check Document has appropriate color contrast
Page Content
Rule Name Status Description
Tagged content Passed All page content is tagged
Tagged annotations Passed All annotations are tagged
Tab order Passed Tab order is consistent with structure order
Character encoding Passed Reliable character encoding is provided
Tagged multimedia Passed All multimedia objects are tagged
Screen flicker Passed Page will not cause screen flicker
Scripts Passed No inaccessible scripts
Timed responses Passed Page does not require timed responses
Navigation links Passed Navigation links are not repetitive
Forms
Rule Name Status Description
Tagged form fields Passed All form fields are tagged
Field descriptions Passed All form fields have description
Alternate Text
Rule Name Status Description
Figures alternate text Passed Figures require alternate text
Nested alternate text Passed Alternate text that will never be read
Associated with content Passed Alternate text must be associated with some content
Hides annotation Passed Alternate text should not hide annotation
Other elements alternate text Passed Other elements that require alternate text
Tables
Rule Name Status Description
Rows Passed TR must be a child of Table, THead, TBody, or TFoot
TH and TD Passed TH and TD must be children of TR
Headers Passed Tables should have headers
Regularity Passed Tables must contain the same number of columns in each row and rows in each column
Summary Passed Tables must have a summary
Lists
Rule Name Status Description
List items Passed LI must be a child of L
Lbl and LBody Passed Lbl and LBody must be children of LI
Headings
Rule Name Status Description
Appropriate nesting Passed Appropriate nesting
Back to Top
File details come from the government source that posted it. Updated .