AST Safety SIR Comments and FAA Responses.xlsx
XLSX spreadsheet 22 KB Posted
- Attached to
- AST Safety Engineering Support Q&A Federal contract opportunity
- Solicitation number
- 693KA9-25-R-00011
About this file
The file is an Excel matrix containing comments and responses between industry stakeholders and the FAA regarding a Draft Solicitation Information Request (SIR) for Safety Engineering Support services. The solicitation (693KA9-25-R-00011) is a pre-solicitation opportunity from the Department of Transportation Federal Aviation Administration Headquarters seeking engineering and technical support, particularly for aerospace safety analysis and project management.
Key details include a Time and Materials contract structure with predefined labor categories, with the most notable being a Project/Program Manager position requiring a Bachelor's degree in engineering, mathematics, or science and substantial industry experience. The government does not plan to set the award aside for any specific socioeconomic business category. Industry comments focused on clarifying contract cost principles, data handling requirements, and labor category qualifications, with the FAA providing responses and noting potential future revisions to the solicitation. The pricing worksheet contains fixed hours, and proposers are expected to provide their own labor rates for the highlighted cells.
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Other files for this federal contract opportunity
| File | Type | Posted |
|---|---|---|
| guidanceT3.3.2_Cost Principles.pdf | ||
| 1 D_SIR 693KA9-25-R-00011_24 FINAL_update 0715.pdf |
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Text version
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 | Industry Comment | Rationale | FAA Response |
| Draft SIR | 35 | I.1 / 3.3.2-1 FAA Cost Principles | Clause 3.3.2-1(d) states that "upon request, the Contracting Officer will provide a copy of the FAA "Contract Cost Principles." | We were unable to find an authoritative copy of the FAA Contract Cost Principles and request it be provided. | The "FAA Cost Principles" must be used for pricing of contracts, and will be required to ensure submission of a compliant proposal. | The "FAA Cost Principles” are contained in AMS Guidance Section T3.3.2 - Contract Cost Principles, under the following link: |
https://fast.faa.gov/PPG_Procurement_Guidance.cfm A hard copy has been attached.
| Draft SIR | 35 | I.1 / 3.5-13 | Alternate II Rights in Data - General | ||||
| Alternate III Rights in Data - General | Both Alternate II and Alternate II appear to insert modifications into 3.5-13 in paragraph (g). Can you clarify that both clauses are intended to be included even though they could "overwrite" eachother? | We envision situations where both Alternate II and Alternate III are appropriate to the work under this contract and encourage their conclusion, but would simply like clarification that they both can be applied at the same time. | Both clauses are intended and will be included. Depending upon the requirement within each individual Task Order, Alternate II or III (or both)may be included. | ||||
| Draft SIR | 4 | B.7 | T&M TOs will be issued per AMS T3.2.4 6, Time and Material/ Labor Hour Contacts | AMS 3.2.4-6 is entitled "Fixed Fee (October 2019)" and we cannot find a clause with the 'T' prefix T3.2.4 6 or any clause under 3.2.4 on https://fast.faa.gov/contractclauses.cfm that reference "Time and Material". Can you clarify the intended clause? | It is unclear what clause applies to pricing under this contract. | The reference on page 4 Section B.7 of the Draft SIR is cited incorrectly. The correct reference is “AMS Procurement GuidanceT3.2.4.A.6, Time-and-Materials/Labor-Hour”. This reference is not a clause but procurement guidance under the AMS that describes the type of contract. The intended clause is included in the draft SIR, page 35, Section I, titled: 3.3.1-5 Payments under Time and Materials and Labor Hour Contracts (October 2024) | |
| Draft SIR | 79 | I.25(b) | Contractors who generate, create, process, use, transmit, receive, store, or dispose of FAA Data must use proper handling procedures required for the sensitivity of that data, in accordance with FAA Order 1600.75 | Can you provide FAA Order 1600.75? It is not publicly available. | We maintain protections for handling of DoD Controlled Unclassified Information (CUI), but would like to confirm that the requirements of FAA Order 1600.75 are substantially the same and need the document to review. | A hard copy of FAA Order 1600.75 is attached. | |
| J002 LCATs | 1 | C.3 Labor Category and Skill Descriptions - Project/Program Manager | This position requires a Bachelor’s degree in engineering, mathematics, or science, and ten years industry experience in managing technical personnel engaged in the investigation and development of policy, guidance, processes, tools, and technical analyses for the aerospace industry, which includes responsibility for end-product quality, customer reporting, and the establishment and implementation of associated schedules and budgets. | Proposed change to requirement to the following: |
| This position requires a Bachelor’s degree in engineering, mathematics, or science, and either: 1) ten years industry experience in managing technical personnel engaged in the investigation and development of policy, guidance, processes, tools, and technical analyses for the aerospace industry, which includes responsibility for end-product quality, customer reporting, and the establishment and implementation of associated schedules and budgets; 2) three years of hands-on technical experience with quantitative flight safety or system safety modeling risk analysis and five years experience in the investigation and development of policy, guidance, processes, tools, and technical analyses for the aerospace industry, which includes responsibility for end-product quality, customer reporting, and the establishment and implementation of associated schedules and budgets | The support requested by AST is highly technical in nature and involves integration of complex workstreams by different parties and presentation of alternatives to AST. A project/program manager for this SIR must have general experience in policy, processes, and schedule/budget management, but will be significantly more effective with particular experience in the technical work of AST. That particular technical experience should permit a lower overall years of experience. | The FAA has not made a decision to modify the years of experience OR the Labor Category and Skills Description at this time. If a decision is made to modify Labor Category and Skills Decription(s), the final SIR will reflect the change. | ||
| Draft SIR | 108 | L.18 (1) SubFactor 1 Technical Approach | The Offeror must provide a credible and comprehensive technical approach to demonstrate |
how the Offeror will complete the requirements identified in the Section C Statement of Work (SOW). The Offeror’s technical approach must explain what tools, methods, technologies, steps, deliverables, and/or other actions the Offeror will employ to satisfy the SOW
| requirements. | The FAA should consider providing a sample task that respondents must address specifically within their response, e.g. "An applicant under part 450 is proposing a new type of uncrewed vehicle with a vertical launch and horizontal return to ground, with planned launches from the East Coast of Florida. Please describe in detail the tools, methods, technologies,and steps the Offeror will employ to independently assess the safety considerations of this proposed activity." | The type of expertise required under the SOW will require the application of highly specific techniques and procedures. Evaluation of the depth of Offerors understanding could prove challenging without a specific task to focus the response on. This would be a limited version of example task orders or "challenge problems" commonly offered as part of other IDIQ solicitations. | Noted. If the FAA makes a decision to include a “sample task” that offerors must address, it will be included in the final SIR. | |||
| L003 Pricing | Pricing | Are the hours listed in the Pricing Worksheet fixed or is the proposer expected to provide a labor breakdown? It appears that the hours are already set, but want to confirm. | The hours listed in “Pricing Worksheet L002” are fixed. The offeror (proposer) is expected to provide its proposed labor rate(s) in all cells highlighted in blue. See language in Section L.20 of the draft SIR providing further guidance related to Attachment L002. | |||
| Draft SIR | Does the government anticipate setting this award aside for a socioeconomic business category (WOSB, 8(a), HUBZone)? | No, the Government does not anticipate setting this award aside to any particular socieoconmic category. | ||||
| Draft SIR | 7 | C.2.1.b | b. The contractor must prepare a Project Management Status Report (PMSR) to | |||
| provide a synopsis of the project's activity over the reporting period. | How often is this report submitted? What are the contents? | Deliverables will be specific to each individual Task Order (TO) and will outline the frequency of submission of reports/deliverables to the COR and also include the minimum content requirements for acceptance. | ||||
| Draft SIR | 7 | C.2.1.c | c. The contractor must conduct a quarterly Project Management review. This report |
will include a Performance and Cost Report, as an Attachment, to provide status and projected requirements of funds, man-hours and work completion. Does this "report" refer to the PMSR mentioned in paragraph b? Draft SIR text in this Section has been revised.
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