AST Environmental SIR Comments and FAA Responses.xlsx
XLSX spreadsheet 23 KB Posted
- Attached to
- AST Environmental Support Services Q&A
- Solicitation number
- 693KA9-25-R-00013
About this file
This file is a comprehensive matrix of comments and FAA responses regarding a Draft Solicitation Information Request (SIR) for Environmental Support Services. The solicitation (Solicitation Number: 693KA9-25-R-00013) is issued by the Federal Aviation Administration (FAA) for environmental documentation, review, and support services related to commercial space launch licensing. Key service requirements include developing and reviewing environmental documentation (EIS, EA, CATEX), maintaining electronic records, supporting public outreach, and providing stakeholder engagement for environmental, licensing, and permitting actions.
The document reveals critical evaluation criteria emphasizing direct experience with rocket launch environmental compliance, with the FAA prioritizing vendors with specific commercial space launch experience. The solicitation is not a small business set-aside and includes detailed labor category requirements with specific educational and experience qualifications. Travel and other direct costs will be governed by federal travel policies, and the FAA has noted that estimated hours and travel costs in the document are for evaluation purposes only. Vendors are expected to demonstrate past performance specifically in the commercial space launch environmental compliance context, with the FAA indicating that lack of direct launch experience may result in an "Unknown Confidence" past performance rating.
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| File | Type | Posted |
|---|---|---|
| 1 D_SIR No. 693KA9-25-R-00013 FINAL_20251229.pdf |
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Instructions Please use this matrix to provide comments, questions, and suggestions on any of the provided draft SIR documents. Please use the Comments tab to provide all responses to all documentation.
Column A - Document - Provide which document you are making a comment against.
Column B - Page/Tab - Provide the page number for the associated document or tab label for Excel documents Column C - Section/para/Cell - Provide the section/paragraph for pdf documents or cell for Excel documents Column D - Text - Provide the applicable text taken from the respective document Column E - Comments - Provide all comments, questions, and suggestions Column F - Rationale - Provide any rationale/reasoning for the comment or suggested change
Comments
| Document | Page/Tab | Section/Para/Cell | Text | Comment | Rationale | FAA Response | |
| Draft SIR | 6 | C.4 | Environmental documentation | Can the FAA clarify the expected types and formats (e.g., EIS, EA, CATEX, technical memos, etc.) of environmental documentation to be prepared or reviewed under this contract? | Will provide clarity regarding the type of documentation to be prepared/reviewed | FAA is involved in the preparation of EISs and EAs in compliance with FAA Order 1050.1G, along with technical memos, re-evaluations, and white papers. | |
| Draft SIR | 6 | C.4.3 | Review and comment on mitigation compliance documentation developed by licensees and/or permitees. | What standards or templates should be used for mitigation compliance documentation, and what is the expected reporting format? | Will provide clarity regarding the standards or reporting format. | FAA reports are usually drafted in Microsoft Word format, before being finalized in Adobe PDF format. | |
| Draft SIR | 7 | C.4.10 | Maintain an electronic record of (in MS Word or Adobe Acrobat form) all final environmental documentation and reference materials, to include supporting the development of administrative records associated with litigation and Freedom of Information Act (FOIA) requests. | Are there specific systems, formats, or retention policies the FAA requires for electronic records and FOIA/litigation support? | Will provide clarity regarding the required system, format, or retention policy. | Record retention policy will be described in final SIR contract clauses. | |
| Draft SIR | 6, 7 | C.4.8 | Develop or review public and stakeholder involvement and outreach materials, along with providing public and agency meeting planning, coordination, and implementation support for environmental, licensing, and permitting actions. The COR may request the Contractor to revise the documentation per comments received and/or develop supplemental information as appropriate. | Can the FAA provide more detail on the expected number and type of public/stakeholder meetings, and preferred outreach methods? | Will provide clarity regarding the expected level of effort, number of meetings, or outreach methods | The expected number and type of public/stakeholder meetings, and preferred outreach methods is dependent upon project complexity and the number of evaluations FAA is requested to perform. The pricing worksheet reflects the hours the FAA estimates will be needed to fulfill the documents, meetings, and trips needed to meet the currently estimated demand for FAA launch licenses. Though, as set forth in Section L.20 of the SIR: "Regarding the estimated hours filled into Attachment L002, the FAA is under no obligation to order in accordance with the estimated hours as these are used for evaluation purposes only." | |
| Draft SIR | 2,3,4 | B.5 - B.6 | Travel and other direct costs (ODCs) | Can the FAA provide estimates or guidance on expected travel frequency, destinations, and allowable ODCs? | Will provide clarity regarding the estimated quantities and/or locations. | The FAA follows the Federal Government's General Accounting Office (GAO) travel policy, as well as FAA travel policy. The pricing worksheet reflects the cost of trips the FAA estimates will be needed to fulfill the expected travel frequency, destinations, and allowable ODCs (though, as set forth in Section L.20 of the SIR: "the amounts included for travel and ODCs are estimates for evaluation purposes only."). Post contract award, travel and ODCs will be directed and approved in accordance with the terms of the contract. | |
| Draft SIR | 108 | L.19 | Emphasizes the importance of past performance with environmental regulations and impact analysis specifically for rocket launches, stating that a lack of such experience may result in information gaps and licensing delays as launch cadence increases. | Can the FAA clarify the rationale for requiring direct rocket launch experience, as opposed to accepting relevant experience with other federal agencies or complex environmental compliance projects? | Will provide the FAA with more highly qualified responses - feel this emphasis favors the incumbent | The FAA emphasizes the importance of rocket launch experience in Section L.19 of the SIR for technical performance reasons. In accordance with Section M of the SIR, a vendor with no recent & relevant performance record will receive a rating of “Unknown Confidence.” An “Unknown Confidence” past performance rating does not itself disqualify a vendor from receiving award. | |
| Draft SIR | 108 | ||||||
| 118 | L.19 | ||||||
| M.4.b | Relevancy of previous experience | Will the FAA consider experience with other federal agencies (e.g., DoD, NASA, EPA) on complex NEPA and environmental compliance projects as “relevant” if the offeror can demonstrate technical equivalency and successful outcomes in similarly complex and high-stakes environments? | Will provide the FAA with more highly qualified responses - feel this emphasis favors the incumbent | The definition of "relevant" in Section M.4.b of the final SIR will refer to work that is similar in scope to what is required under the SIR (i.e., similar to the work set forth in Section C of the SIR, which involves work in the commercial space launch/reentry context). | |||
| Draft SIR | 103 | ||||||
| 116 | L.17 | ||||||
| M.4.a | Proposal general instructions / evaluation factors | Is the FAA open to considering innovative and cost-efficient approaches—such as leveraging advanced AI tools, digital modeling, or process automation—proposed by vendors with strong federal environmental compliance backgrounds but no direct FAA/launch experience? If so, how should offerors best demonstrate the value and risk mitigation of these approaches in their proposals? | Will provide the FAA with more highly qualified responses - feel this emphasis favors the incumbent | The FAA is open to innovative and cost-efficient approaches, and process improvement, regardless of the tools used. | |||
| Draft SIR | 108 | ||||||
| 118 | L.19 | ||||||
| M.4.b | Relevancy of previous experience | Would the FAA consider proposals that include a detailed risk mitigation plan and/or teaming arrangements (e.g., with subcontractors or SMEs with direct FAA/launch experience) as sufficient to address the experience gap, provided the prime has a proven record of delivering complex federal environmental projects? | Will provide the FAA with more highly qualified responses - feel this emphasis favors the incumbent | No. | |||
| Draft SIR | 116 | ||||||
| 118 | M.4.a | ||||||
| M.4.b | Evaluation factors | How will the FAA evaluate transferable skills, methodologies, and technologies (such as advanced environmental modeling, stakeholder engagement, or regulatory compliance systems) that have been proven in other federal contexts but not yet applied to FAA commercial space licensing? | Will provide clarity, while also offering the FAA with more highly qualified response | The FAA's evaluation will depend on the specifics in the actual, submitted proposal. When proposals are submitted, the FAA will eavluate using the stated evaluation criteria. | |||
| Draft SIR | 108 | ||||||
| 118 | L.19 | ||||||
| M.4.b | Relevancy of previous experience | Would the FAA consider past performance with other federal agencies on projects involving NEPA, complex environmental impact statements, or high-consequence permitting actions as “relevant” if the offeror can demonstrate the applicability of their experience to the FAA’s mission? | Will provide the FAA with more highly qualified responses - feel this emphasis favors the incumbent | The definition of "relevant" in Section M.4.b of the final SIR will refer to work that is similar in scope to what is required under the SIR (i.e., similar to the work set forth in Section C of the SIR, which involves work in the commercial space launch/reentry context). | |||
| Draft SIR | 8 | C.6 | Principal Consultant/Program Manager | Consider reducing the minimum education requirements to a Bachelor's degree or higher or specifying a number of years of relevant experience to substitute for the Master's degree. For example, 10 years of NEPA experience may be a substitute for a Master's degree. | The current minimum education requirement combined with the years of NEPA experience and years of program management experience unnecessarily limits the individuals who can be proposed in this LCAT, which limits competition. Making this change would increase competition and would more closely align with other large program LCAT requirements, including the FAA's Systems Engineering and Technical Innovative Solutions (SETIS) contract and FAA's Policy, Engineering, Analysis, and Research Support (PEARS) contract. | The FAA will not change the requirements for the LCATs that are set forth in the SIR. | |
| Draft SIR | 8 | C.6 | Senior Consultant/Project Manager | Consider reducing the minimum education requirements to a Bachelor's degree or higher or specifying a number of years of relevant experience to substitute for the Master's degree. For example, 5 years of NEPA experience may be a substitute for a Master's degree. | The current minimum education requirement combined with the years of NEPA experience and years of program management experience unnecessarily limits the individuals who can be proposed in this LCAT, which limits competition. Making this change would increase competition and would more closely align with other large program LCAT requirements, including the FAA's SETIS contract and FAA's PEARS contract. | The FAA will not change the requirements for the LCATs that are set forth in the SIR. | |
| 9 | C.6 | Mid-Level Consultant/Project Manager | Consider reducing the minimum education requirements to a Bachelor's degree | This change would more closely align with industry standards for mid-level project managers. | The FAA will not change the requirements for the LCATs that are set forth in the SIR. | ||
| Draft SIR | 6, 7, 8, 9 | C.6 | All LCATs | Consider adding "or relevant field" after "from an accredited university" | NEPA specialists and practioners come from a wide variety of backgrounds and often possess degrees that are not included in those listed in the minimum education requirements. If a candidate possesses the appropriate years of NEPA experience, then a degree in a relevant field that is not listed should be allowable. | The FAA will not change the requirements for the LCATs that are set forth in the SIR. | |
| Draft SIR | 109 | L.21 | Volume IV Small Business Subcontracting Plan | Consider issuing this contract as a small business set-aside. | The scope of work aligns with the skillsets of small businesses who provide NEPA services to the FAA and other federal agencies. Issuing this contract as a small business set-aside would provide an opportunity for those small businesses to compete for this contract. | FAA will not issue this contract as a set-aside. |
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