Attachment 1 - PWS Rail ITV_vF.pdf
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- Attached to
- Rail Car Intransit Visibility (ITV)
- Solicitation number
- HTC71125QR002
About this file
This Performance Work Statement (PWS) details requirements for a Rail Car In-Transit Visibility (RITV) system for the Military Surface Deployment & Distribution Command (SDDC). The project involves procuring and installing Remote Monitoring Devices (RMDs) on approximately 1,700 Department of Defense owned chain flat rail cars located in the Contiguous United States. The RMDs must provide near real-time tracking, transmit data every 15 minutes while in motion, detect impacts and tampering, and report load status, with capabilities including GPS positioning within 50 feet, battery life of at least 5 years, and ability to withstand extreme environmental conditions from -30°F to 180°F.
The contract requires comprehensive data services, including a contractor website with interactive maps, geofence management, and alert capabilities. Performance standards are stringent, with requirements for 99% device installation accuracy, 99.5% system uptime, less than 1% device failure rate, and strict cybersecurity protocols. The contractor must provide installation services across multiple states, conduct monthly meetings, submit various reports, and ensure seamless data transfer and system interoperability with existing Department of Defense monitoring systems. The contract includes provisions for device replacement, data ownership, and potential expansion beyond the initial 1,700 rail cars.
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PERFORMANCE WORK STATEMENT
MILITARY SURFACE DEPLOYMENT & DISTRIBUTION COMMAND
DODX RAIL CAR IN-TRANSIT VISIBILITY
Rail Car In-transit Visibility (RITV)
Performance Work Statement (PWS)
For
The Defense Freight Rail Interchange Fleet (DFRIF)
July 2025
TABLE OF CONTENTS
1. BACKGROUND AND SCOPE 3
1.1 Background 3
1.2 Scope 3
1.3 Mission Essential Services. 3
2. REMOTE MONITORING DEVICE (RMD) REQUIREMENTS 3
2.1 ITV Transmissions 3
2.2 Device Specifications 4
2.3 Replacement of Malfunctioning Devices 4
3. INSTALLATION OF RMDS 5
3.1 General 5
3.2 Affixing 5
3.3 Installing RMDs and Accessing Military Locations 5
3.4 Activation of the Device 6
3.5 Installation Completion Reports 6
3.6 Travel Costs 6
4. DATA AND NETWORK SERVICE 7
4.1 Required Data Elements 7
4.2 Data Interfaces 7
4.3 Contractor Website Access 8
4.4 Data Storage and Disposition 8
4.5 Data Service 8
4.6 Data Ownership 9
5. CONTRACT MANAGEMENT 9
5.1 Points of Contact and Reporting 9
5.2 Work Hours 9
5.3 Ordering 9
5.4 Invoicing 10
5.5 Contract Transfer Period 11
6. GENERAL INFORMATION 12
6.1 Operations Security (OPSEC). 12
6.2 Vendor Threat Mitigation 12
6.3 Cybersecurity 12
6.4 Damage, Accident, and Loss Reporting. 12
7. PERFORMANCE 13
7.1 Deliverables 13
7.2 Performance Requirements Summary (PRS) 13
1. BACKGROUND AND SCOPE
1.1 Background
1.1.1 The Military Surface Deployment and Distribution Command (SDDC) manages the daily operations and maintenance of the Defense Freight Rail Interchange Fleet (DFRIF). The DFRIF consists of roughly 1,700 Department of Defense (DoD) owned chain flat rail cars, commonly referred to as DODX cars. SDDC is seeking modern technology to allow for advanced real-time information and monitoring of assets beyond the current and outdated transportation service providers (rail carriers) car location messages.
1.1.2 SDDC’s Rail Fleet Movement Branch requires real time tracking and reporting of DODX rail cars to allow for improved in-transit visibility (ITV), a more accurate Common Operating Picture (COP), data for incident investigations, and shop repairs monitoring. Implementation will also lead to enhanced safety, security, and accountability of the DFRIF and provide units with ITV of equipment moving by rail in the Contiguous United States (CONUS).
1.2 Scope
The Rail Fleet Management Branch requires rail car tracking devices for approximately 1,700 DODX cars located in CONUS, installation of the devices on the rail cars, and data service for the devices. The Contractor shall provide data services that can also be incorporated into the current DoD systems for monitoring surface movements.
1.3 Mission Essential Services.
Sections 2.1 and 4 of this PWS have been categorized as contractor mission essential services in accordance with (IAW) Defense Federal Acquisition Regulation Supplement (DFARS) 252.237- 7023. The Contractor shall be required to continue performance in a crisis IAW the Contractor’s Plan for Continuation of Essential Contractor Services incorporated into the contract.
2. REMOTE MONITORING DEVICE (RMD) REQUIREMENTS
2.1 ITV Transmissions
2.1.1 The Contractor shall provide a RMD that can capture and transmit near real time ITV with reporting by way of the Contractor’s commercially available website and API transmission to the data platform required by SDDC as outlined in paragraph 4.2.
2.1.2 RMDs shall provide reporting data every fifteen (15) minutes while the device is in motion. RMDs will be programmed with an energy conservation mode to limit battery drain when not in motion. RMD will reset and report within 5 minutes of impact, when tampering is detected, or movement begins again. The Government may change data reporting intervals as required by mission.
2.1.3 In addition to location and movement data, the device or additional sensors shall be able to detect and report the following:
a) An impact event of greater than or equal to 1.5 G-force and aft or side to side motion.
b) The load status of the rail car (i.e. loaded or empty)
c) A tampering event (e.g., when a sudden impact greater than 4G-forces or a constant oscillating movement occurs that indicates an attempt to remove the device by prying).
Note: Requirements outlined below for RMD specifications, installation, and activation apply to additional sensors utilized to meet the needs of this PWS.
2.2 Device Specifications
2.2.1 RMDs shall not be affixed in an area that will obstruct upload or download operations.
2.2.2 The device shall be capable of over-the-air software updates.
2.2.3 RMDs shall have position accuracy of within 50 feet.
2.2.4 The RMD battery shall maintain a charge for at least 5 years. The battery life shall be monitored by status updates on the Contractor webpage or reports generated by the device showing life remaining and any battery malfunctions to include overheat conditions.
2.2.5 RMD assemblies shall conform to the requirements of the Federal Railroad Administration (FRA) and Association of American Railroads (AAR). RMDs may also be used in the vicinity of ordnance susceptible to radiated energy and subject to stringent Hazards of Electromagnetic Radiation of Ordnance (HERO) requirements. RMD assemblies shall be HERO tested and certified compliant with specifications per MIL-STD 464A.
2.2.6 Contractors shall provide RMDs with the ability to withstand harsh weather and environmental conditions related to rail operations to include temperature operating ranges of - 30°F to 180°F and altitudes up to 15,000 feet above sea level.
2.2.7 A mounting device shall be used to mount the RMD. The RMD shall be affixed to the mounting device with hardware to allow removal for servicing and battery replacement.
2.2.8 A label shall be placed onto the RMD or within proximity to identify the RMD as being property of the “United States (U.S.) GOVERNMENT" and containing sensitive monitoring instruments. The label shall contain a “WARNING” in large red letters with a description of handling requirements to ensure the RMD is not damaged during loading or unloading operations at installations by MHE, such as forklifts. The Contractor’s proposed warning label shall be approved by the Contracting Officer Representative (COR) before production and affixing to DODX rail cars.
2.3 Replacement of Malfunctioning Devices
2.3.1 When a device within the required life expectancy malfunctions or no longer works as described in Section 2, and the malfunctioning is not due to damage caused by the Government, the Contractor shall replace the device at no cost to the Government.
2.3.2 Replacement RMD’s will be installed within 90 days of RMD failure or loss of RMD transmission if the car is in a location where the Contractor is able to install. The Contracting Officer (CO) may allow more than 90 days if required by the Government.
2.3.3 If the car is not at a location where the Contractor can access the car to install the replacement within 90 days, the CO may allow the Contractor to ship a device to an agreed upon location where the Government can install. Replacements will be shipped within 5 days.
3. INSTALLATION OF RMDS
3.1 General
Installation of RMDs on DODX cars shall be the responsibility of the Contractor when the service is ordered by the Government. The Government will identify locations where rail cars are aggregated and coordinate installation with the Contractor IAW PWS Section 6.3 Ordering.
3.2 Affixing
The DODX fleet consists almost entirely of chain flat cars. The mounting bracket may attach to the DODX car by being bolted/screwed into place or by the use of epoxy or other method approved by the COR. The RMD shall be mounted securely on the side of the rail car (including trucks/bogie) offering the least exposure to damage from material handling equipment (MHE).
The Contractor shall get COR approval for mounting location(s) before installation begins.
3.3 Installing RMDs and Accessing Military Locations
3.3.1 Installation of RMD’s on DODX rail cars will require accessing many different locations as DODX cars are in constant demand and routed to several military installations and commercial facilities daily.
3.3.2 Once a location is identified for RMD installation IAW PWS Section 5.3 Ordering, the Contractor is responsible for coordinating installation access requests with the installation where the DODX rail cars are located. These locations could include military installations or ports where SDDC operates.
3.3.3 The Government intends for installation to occur in the following states where the DODX fleet is commonly deployed:
(a) Washington
(b) California
(c) Colorado
(d) Kansas
(e) Texas
(f) North Carolina
(g) New York
(h) South Carolina
3.3.4 The Government may require performance at other CONUS locations.
3.3.5 The Government’s intends for installation to primarily be completed within the Base Year and/or Option Year One of the contract. However, if installation of all tags cannot be completed within the first two years, any remaining tags may be installed in future contract years.
Additionally, installation may be required, at any time, for newly purchased DODX rail cars.
3.3.6 The Contractor will be required to enter and work on U.S. Government military installations. The Contractor is responsible for its employees, to include subcontractors, and will comply with access and control procedures, to include background checks, personal inspections and vehicle inspections as required by the installation.
3.3.7 The Contractor shall coordinate safety requirements for locking out tracks with the Installation Transportation Officer (ITO), or designated Government official, to ensure work can be performed when installing the RMDs on DODX rail cars.
3.3.8 The Contractor is responsible for supplying all safety equipment for its employees engaged in performing work on DODX rail cars. At a minimum the following safety equipment is required when working on military railhead locations: steel toed boots, long sleeve shirt, hard hat, high visibility vest or outerwear, protective eyeglasses, and available hearing protection.
3.4 Activation of the Device
3.4.1 The Contractor will activate the RMD at time of installation and associate the DODX car number with the RMD installed on the rail car. The activation is also the process of registering the device with cellular and/or satellite networks for tracking purposes.
3.4.2 For the contract period in which RMDs have been activated, the Contractor will invoice monthly for the data service after tags have been activated. The Government will pay a prorated usage fee for data service based on the day activation occurs in the monthly billing cycle. At the beginning of each contract period, the Contractor may invoice for all activated devices at a yearly rate.
3.5 Installation Completion Reports
Within five days of installation completion, the Contractor shall provide a report of the devices that were installed and activated during the operation. The report will include the rail car number and device number.
3.6 Travel Costs
3.6.1 The Contractor may invoice for travel expenses when traveling to locations for device installation. Travel within the local commuting area (50 miles) will not be reimbursed.
3.6.2 Travel Costs include transportation, lodging, meals, and incidental expenses. Travel costs incurred by Contractor personnel on official company business are allowable subject to the limitations contained in Federal Acquisition Regulation (FAR) 31.205-46
3.6.3 Costs for transportation may be based on mileage rates, actual costs incurred, or on a combination thereof, provided the method used results in a reasonable charge. Costs for lodging, meals, and incidental expenses may be based on per diem, actual expenses, or a combination thereof, provided the method used results in a reasonable charge.
3.6.4 The Contractor shall invoice for actual travel expenses and allowable taxes or fees applicable to the area in accordance with the FAR 31.205-46. The Contractor shall provide all receipts and documentation required to demonstrate the actual costs as part of the invoice package. Failure to provide receipts will result in no payment.
3.6.5 Travel costs for installation shall be submitted for approval to the Government using the Government provided Travel Expense Report (PWS Appendix A). Within five days of receipt of a Task Order, the Contractor shall submit an estimated Travel Expense Report (TER) to the CO and COR for each individual traveling to include all travel costs. The CO or COR will provide the Contractor with authorization for travel. After installation is completed, the Contractor will submit an invoice with the approved estimate, any revisions, and applicable receipts or supporting documentation. All revisions must be approved by the CO or COR.
4. DATA AND NETWORK SERVICE
4.1 Required Data Elements
All RMD’s shall provide the following minimum data elements:
Globally Unique Tag Identifier: example 21234567890123 *
Position Coordinates: Latitude: 49.46470 ; Longitude: 17.69983 *
Battery Capacity Percent Remaining: example 45%. *
Event Date Time: 2018-04-25T18:30:21 CST. *
4.2 Data Interfaces
4.2.1 After contract award, the Contractor shall enter into a Data Sharing Agreement with the Government to establish the required data interfaces to Government systems.
4.2.2 The Contractor shall establish an interface with government systems within 30 days of the start of contract performance to transmit data elements in paragraph 4.1 with the associated DODX car number.
4.2.3 The Contractor shall comply with the security and interoperability requirements specified for data exchanges between the necessary systems.
4.3 Contractor Website Access
4.3.1 The Contractor shall provide secure account access to their website as requested by the COR. The Contractor will establish user accounts within 3 business days of request from the COR. The COR will provide the Contractor with necessary information for the Contractor to establish new accounts and grant access.
4.3.2 The website will offer the following: interactive maps with trip timeline, geofence management with alerts upon enter/exit, asset historical data that can be queried through running reports, information pertaining to RMD dwell, mileage and utilization.
4.3.3 The Contractor website shall be capable of producing reports, running queries concerning history files/events, providing alerts via email for selectable events such as entering/exiting defined geofences or impacts and start/stop times.
4.3.4 The Contractor shall notify the COR at least one business day in advance of any scheduled website downtime outside of business hours (weekdays from 0800 – 1600 local). If unscheduled downtime is required, the Contractor shall give the COR at least one hour notice.
4.4 Data Storage and Disposition
The Contractor shall retain rail car data, either online or in offline storage, for the length of the contract. At the end of the contract, the Contractor shall provide the Government the data in a mutually agreed to format that will allow use of the data without the Contractor’s system within 30 days.
4.5 Data Service
The device shall have broad access to data networks, enabling coverage at military installations and ports across the country. Cellular devices shall utilize the industry’s globally recognized mobile phone standards, minimally Global System for Mobile Communication (GSM) coverage such as LTE/4G, with fallback to alternative standards (e.g., 3G and 2G), as required to interoperate on the provider’s cellular networks within CONUS. Satellite devices shall provide no less than equivalent coverage as provided by the Iridium satellite constellation. Hybrid devices must meet both cellular and satellite requirements above. Satellite and hybrid devices are not required to utilize the Enhanced Mobile Satellite Services (EMSS) Gateway. All devices shall be capable of storing data when not able to connect to a network and be capable of sending data when reconnection occurs.
4.6 Data Ownership
All collected data shall remain the property of the U.S. Government. Data shall be available for export in standard formats (e.g., CSV, JSON, XML) for integration into alternative systems.
5. CONTRACT MANAGEMENT
5.1 Points of Contact and Reporting
5.1.1 The Contractor shall provide at a minimum one contract manager and one alternate who shall be responsible for the performance of the work and all coordination with the Government. The Contractor shall provide telephone numbers and email addresses for each of the contract managers. The contract manager and alternates shall have full decision-making authority to act for the Contractor on all matters pertaining to the performance of services under this contract.
5.1.2 When installing devices at government directed locations, the Contractor shall provide a POC for each installation team that will be accessible by telephone and email to the COR.
5.1.3 The Contractor shall conduct virtual monthly meetings with the COR to discuss reports of contractual problems, both actual and anticipated. Within five days of the monthly meeting, the Contractor shall provide written meeting minutes of discussions held between the U.S.
Government and the Contractor.
5.2 Work Hours
The Government will not require the Contractor to work outside of normal workday hours under normal circumstances. If the Contractor chooses to work overtime, night or weekend hours in support of the contract, the Government will not reimburse the Contractor for additional labor costs. If the Government does require the Contractor to work outside of normal hours, any premium hours must be approved by the CO in advance.
5.3 Ordering
5.3.1 When the Rail Fleet Management Branch identifies an installation location and timeline, the COR will provide the Contractor a planning notification via email or during the monthly meeting. The intent of the notification is to assist the Contractor with planning only and does not constitute an order from the Government. The notification will include the planned number of required devices (i.e. the number of cars the Government intends to install tags on), the location of the cars, and the timeline for when cars will be positioned at the location. The Contractor may be given a minimum of 30 days’ notice for planning purposes. Additionally, the Government may make minor adjustments after the planning notice is issued (e.g. number of cars, or timelines for installation) and retains the right to cancel any planned mission as required.
5.3.2 Within 14 days from the expected mission start date, the CO will provide the Contractor a task order to include the actual number of required devices (i.e. the number of cars the Government intends to install tags on), the location of the cars, and the timeline for when cars will be positioned at the location. The task order obligates funds and authorizes the Contractor to perform the outlined work.
5.3.3 The Government intends to issue task orders for installation of devices on no fewer than 50 rail cars at a time. However, the Government may request installation for orders on fewer than 50 rail cars as mission requirements require.
5.3.4 When needed, the Government may order devices to be shipped to locations where the Government or its agent will install the device. The Contractor shall ship devices to identified locations within 5 days. The Contractor may invoice the actual cost of shipping. Shipping costs shall be substantiated with the paid invoice or receipt to the COR. The Contractor shall provide any applicable instructions for government installation.
5.3.5 The Government may purchase additional devices, above the projected 1700 devices, if needed.
5.4 Invoicing
5.4.1 The Government will not pay for services unless specifically ordered in the task order or as reconciled by the CO. The Contractor shall conduct a reconciliation and validation of devices purchased and installed with the COR using substantiating documentation within seven business days of completing each installation. Changes in installation (e.g., number of cars, timeline for installation, or final travel costs) which result in a change of task order will be reviewed and approved by the CO. The Contractor shall provide written justification to the CO, including any substantiating documents, when requesting a price increase/decrease due to a change in the task order.
5.4.2 All invoices shall be submitted electronically via upload to the Treasury Invoice Processing Portal (IPP). These invoices will then be routed to the designated COR for review/approval within the IPP tool. Invoices approved by the COR will then be interfaced into the Transportation Financial Management System (TFMS) for entitlement processing and payment.
5.4.3 The Contractor shall submit one invoice per task order for payment to the COR via the Treasury Invoice Processing Portal not later than 30 calendar days following completion of the mission. Invalid or unapproved invoice documents will be returned to the Contractor for corrective action.
5.4.4 Each invoice shall contain the following data elements:
Header:
• Contractor Name and Address *
• Invoice Date and Invoice Number
• Invoice total Amount (MSLP) *
• Contract Number *
• TFMS PO Number *
• Installation Location
Line-Item Detail:
• Line-Item Description *
• Quantity
• Unit of Measure *
• Unit Price *
• Extended price of services performed *
• TFMS PO Line Number *
• TFMS PO Schedule Number *
* Note 1: Items marked with * are provided within Treasury IPP and do not require vendor input.
5.4.5 Each invoice shall be accompanied by the substantiating documents and travel receipts. If reconciliation is necessary, the Contractor shall attach a copy of the substantiating documents used to support the change in the final task order. Further, for travel receipts as required in PWS 3.6, the Contractor shall attach receipts supporting the actual charges paid.
5.4.6 The COR will complete the invoice approval process within seven (7) business days of receipt of a valid invoice from the Contractor IAW Prompt Payment Act guidelines. The prompt payment clock begins when the COR receives a valid invoice. Payments taking longer than 30 calendar days to process after receipt of a valid invoice shall incur interest IAW the Prompt Payment Act. Payment shall be made using the Transportation Financial Management System (TFMS). 52.232-25 (a)(3)(i) through (a)(3)(x).
5.5 Contract Transfer Period
5.5.1 At the end of the contract period, the RMD shall be fully transferable. The Contractor shall provide the Government with all information necessary to reconfigure RMDs to operate with the Government’s follow on platform to ensure uninterrupted service continuity within 30 days. Further, the incumbent Contractor shall provide the incoming Contractor (if not the incumbent) operational familiarization related to processes and procedures for performance of day-to-day duties and deliverables during the first 30 calendar days after the start of the future contract.
5.5.2 Also, if the Contractor does not receive a follow-on contract award, the Contractor shall allow the Government access to its website for a minimum of three months after the contract ends.
6. GENERAL INFORMATION
6.1 Operations Security (OPSEC).
Information provided during work performance shall only be released to personnel/entities who provide specific services in support of the contract. The Contractor shall implement appropriate safeguards to mitigate against the release of said information to third parties not participating in work on this contract. In any case where there is uncertainty or ambiguity, regarding OPSEC protocols, the Contractor shall consult the COR and/or CO for a resolution.
6.2 Vendor Threat Mitigation
The Contractor shall submit a semi-annual report to the CO for each first-tier foreign service provider, operating as a separate legal entity, contracting directly with the Contractor. This includes the foreign service provider’s commonly-owned legal affiliate (if applicable) which has employees who may have access to Government systems or information in the ordinary course of contract performance. The initial report is due 30 calendar days after contract award and every six months thereafter. Refer to Appendix B for further instruction for this requirement.
6.3 Cybersecurity
The services being performed under this contract are “operationally critical support” as defined in Defense Federal Acquisition Regulation Supplement (DFARS) 252-204-7012 Safeguarding Covered Defense Information and Cyber Incident Reporting.
6.4 Damage, Accident, and Loss Reporting.
6.4.1 The Contractor shall immediately notify the COR of any incident and/or accident that results in injury or death to any personnel, damage to cargo or property, or hazardous spills or leaks, during or arising from performance under this contract.
6.4.2 The Contractor shall submit an accident report within 24 hours to the COR with the following information:
• Status of injured personnel
• Pictures of affected equipment
• Training certificates/licenses for personnel involved in incident
6.4.3 Accident Information required from Contractor within 30-Day (or sooner if investigation is complete) Information required from Contractor
• Findings identifying the root cause(s) of the accident
• Corrective actions taken to prevent recurrence
• Follow-on status of any injuries from 24-hour status
• Final incident report from Contractor’s safety representative to COR
6.4.4 The Contractor will be liable for any damage they cause to government property during the course of installation operations.
7. PERFORMANCE
7.1 Deliverables
The Contractor shall deliver data as set forth in the below table. All deliverables shall be submitted electronically via e-mail to the COR, Contracting Officer, and Contract Specialist.
Table 7.1- Deliverables
PWS
Paragraph
Deliverable Delivery Schedule
3.5 Installation Completion
Reports
NLT five days after installation completion
6.2 Vendor Threat Mitigation
Report
Semi-annually, 30 calendar days after contract award and every six months thereafter
6.3 Cybersecurity Incident
Reporting
As required, immediately upon discovery of a cyber incident
6.4 Accident Reporting Immediately and within 24 hours & 30 Days of Incident
5.1.1 Contract Manager POC At contract award
5.1.2 Installation Team POC At time of installation at Government directed locations
5.1.3 Monthly Meeting Minutes Within five days of the monthly meeting
5.5.1 RMD Transfer Information Within 30 days of contract end
7.2 Contractor Performance
Requirements Summary Metric Reports
NLT the 15th calendar day of the month following the reporting month
7.2 Performance Requirements Summary (PRS)
The PRS represents the most important objectives that, when met, will ensure performance under the contract is satisfactory. Although not all PWS requirements are listed in the PRS, the Contractor shall comply with all requirements in the PWS.
Table 7.2 - PRS
Performance Objective
Performance Measure Methodology to Calculate
Metric Performance
Standard
Acceptable Quality
Level (AQL)
Correct Installation
Percentage of installed devices meeting all predefined criteria (functionality, mounting, configuration)
Number of properly functioning and installed devices /Number of devices installed
100% 99%
Active RMDs on Railcars
Percentage of railcars with actively reporting RMDs after installation
Number of devices actively reporting /Number of devices installed
100% 99%
Coverage Gap Duration
Average duration of coverage gaps (loss of signal for >15 minutes) per gap occurrence
Time event is reported minus the time the even happened
1 hour 2 hours
Impact / Tampering Alert Timeliness
Average time elapsed between an event and the corresponding alert
Time event is reported minus the time the even happened
15 minutes 30 minutes
System Uptime
Percentage of time the contactor system visibility platform is operational and providing location data
Total Operational Time / Total Measurement Period Time
99.5% 99%
Device Failure Rate
Percentage of devices requiring replacement/repair within 12 months
Number of malfunctioning devices/ Number of devices installed
<1% <2%
Secure Operations
No more than one (1) security violation per year.
Number of security violations per year
<=1 <=1
Performance Objective
Performance Measure Methodology to Calculate
Metric Performance
Standard
Acceptable Quality
Level (AQL)
Timely Cyber Incident Reporting
No more than one (1) late cyber-incident report or unreported per year.
Number of late or unreported cyber incidents per year
<=1 <=1
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