biddoc.pdf

TOWN OF MORRISON

REQUEST FOR PROPOSALS

Water System Leak Detection Services

RFP PUBLISHED 7/22/26

PRE-PROPOSAL MEETING 8/4/26

QUESTIONS DUE 8/7/26

QUESTIONS & ANSWERS

UPLOADED

8/10/26

PROPOSAL SUBMISSION

DEADLINE

8/17/26

INTENT TO AWARD Late August 2026 CONTRACT EXECUTION Mid-September 2026

TABLE OF CONTENTS

REQUEST FOR PROPOSALS

SECTION 1 - SCOPE OF WORK & TECHNICAL SPECIFICATIONS

SECTION 2 - PROPOSAL SUBMISSION REQUIREMENTS

SECTION 3 - GENERAL REQUIREMENTS

SECTION 4 - SELECTION PROCESS

ALL ATTACHMENTS ARE UPLOADED SEPARATELY IN RMEPS

ATTACHMENT A - SAMPLE AGREEMENT

ATTACHMENT B – TOWN WATER SYSTEM EXHIBITS (6 PAGES)

REQUEST FOR PROPOSALS (“RFP”)

The Town of Morrison (“Town”) is requesting proposals for a water system leak detection services project. Proposals must be submitted electronically through Rocky Mountain E-Purchasing

System (“RMEPS”) by 5:00 PM MST on August 17, 2026.

Pre-Proposal Meeting:

Proposers are encouraged to attend the pre-proposal meeting which shall take place online at

1:00 PM MST on Augus t 4 , 2026.

Microsoft Teams meeting

Join: https://teams.microsoft.com/meet/252943849188738?p=fIMwN9t3RlyfA996z8

Meeting ID: 252 943 849 188 738

Passcode: rg2SU69L

Need help? | System reference

Dial in by phone

+1 309-644-4427,,867350456# United States, Rock Island

Find a local number

Phone conference ID: 867 350 456#

The pre-proposal meeting is not mandatory, but proposers will be held responsible for all information presented at the meeting. The Town will publish meeting notes and questions/answers in RMEPS as indicated on page 1.

No site walks will be offered by the Town.

Questions:

All inquiries and questions regarding this RFP must be submitted electronically via email to

Glendon Berrett (Glendon.w.berrett@imegcorp.com) by 5 : 0 0 PM MST on August 7, 2026.

Selection:

A Town selection committee shall review the proposals received and consider any causes for rejection or disqualification. Proposers may be requested to participate in interviews to further assess their qualifications.

RFP Designated Contact:

Glendon Berrett, Project Manager, is the RFP Designated Contact. From the date of issuance of the RFP through completion of the selection process, any proposer who contacts Town employees other than the RFP Designated Contact may be disqualified from further participation in the selection process, at the Town’s sole discretion.

https://www.bidnetdirect.com/colorado https://www.bidnetdirect.com/colorado https://www.bidnetdirect.com/colorado https://teams.microsoft.com/meet/252943849188738?p=fIMwN9t3RlyfA996z8 https://aka.ms/JoinTeamsMeeting?omkt=en-US https://teams.microsoft.com/l/meetup-join/19%3ameeting_YTVlMzQwMmUtZGZkZS00ZmFiLWJiYzUtZTcwMDEwNzMzZTc1%40thread.v2/0?context=%7b%22Tid%22%3a%227b8f7acc-e1c0-467a-86e9-678144da7881%22%2c%22Oid%22%3a%226d08356b-0d51-40f1-9de1-8dcbeb8ada65%22%7d tel:+13096444427,,867350456 https://dialin.teams.cloud.microsoft/af4f2250-3cf7-44d6-9236-cbf87254969d?id=867350456

Section 1 - SCOPE OF WORK & TECHNICAL SPECIFICATIONS

The Contractor shall conduct comprehensive acoustic leak detection surveys of the Town's water distribution system. The primary objective is to identify, quantify, and precisely locate active leaks within the water mains, service connections, valves, and fire hydrants so that Town staff can prioritize and complete repairs or capital replacement projects. Work shall include, but is not limited to:

• Furnish all labor, transportation, tools, and equipment. A minimum of two (2) persons shall be on-site at all times during field operations.

The Contractor shall provide, at minimum, the following equipment for each survey:

- Electronically enhanced acoustic listening device

- Electronic leak correlators capable of analyzing non-metallic PVC pipe frequencies

- Line locating equipment

- Magnetic locators

- All necessary valve keys and hand tools

- Sub-meter GPS unit for leak location data collection

• The Contractor shall employ a rigorous, systematic methodology to maximize leak location accuracy and minimize error. At a minimum, the Contractor shall:

- Use two-person field teams at all times for both safety and quality assurance.

- Verify all suspected leak locations a second time before confirmation; at least four (4) hours shall elapse between the initial and confirmation listening sessions.

- Perform leak correlations from multiple listening points where possible; obtaining the same leak location via independent correlations substantially increases confidence.

- Investigate all connections located within 10% of the total correlation length to the suspected leak area to confirm the leak is on the pipe under investigation.

- For service line leaks, verify findings by temporarily shutting off the service (with Town permission and coordination with the property owner).

- Use a ground microphone as an additional verification tool where conditions allow.

- Maintain and submit daily progress logs and a progression map indicating all suspected leak noise indications and confirmed leak locations.

• Coordinate with the Town's designated representative prior to commencing field work to review system maps, identify areas of interest, discuss pump station locations, and confirm any known system anomalies or recent repairs.

• Obtain and comply with all required Right-of-Way (ROW) permits and prepare Traffic Control Plans (TCPs) as required for work within public roadways. The majority of system valves and hydrants are located within roadways; adequate traffic control is required at all times. See specific notes in Working Provisions Section.

• Conduct initial acoustic listening on all accessible fire hydrants, all accessible mainline valves, and, where necessary, selected service connections throughout the designated survey area. Listening shall be made by direct physical contact with the valve, hydrant, pipe, or B-box.

• Apply the following minimum listening distances based on pipe material:

- Metallic pipe (CIP/DIP/Galv): no greater than 500 feet between listening points.

- Non-metallic AC/Concrete pipe: no greater than 300 feet between listening points. (Not anticipated to be applicable).

- Non-metallic PVC (C900): no greater than 150 feet between listening points.

• Exhibits and Data are in process of being refined and provided to the selected Firm, but the following table provides anticipated diameters/materials for general consideration.

Diameter: 2”

Material: Galvanized Segments: 6 Length: 890 LF

Material: Unknown Segments: 2 Length: 270 LF

Unknown thought to be likely Galvanized.

Diameter: 4”

Material: Cast Iron Segments: 5 Length: 465 LF

Material: Ductile Iron Segments: 1 Length: 10 LF

Material: Galvanized Segments: 4 Length: 695 LF

Material: PVC Segments: 7 Length: 1075 LF

Material: Unknown Segments: 7 Length: 830 LF

Unknown thought to be likely Cast Iron.

Diameter: 6”

Material: Cast Iron Segments: 4 Length: 600 LF

Material: Ductile Iron Segments: 53 Length: 2155 LF

Material: PVC Segments: 13 Length: 785 LF

Material: Unknown Segments: 23 Length: 3880 LF

Unknown thought to be likely Cast/Ductile Iron.

Diameter: 8”

Material: Ductile Iron Segments: 30 Length: 4330 LF

Material: PVC Segments: 21 Length: 3890 LF

Material: Unknown Segments: 6 Length: 1155 LF

Unknown thought to be likely Ductile Iron.

Diameter: 10”

Material: Ductile Iron Segments: 11 Length: 7480 LF

Diameter: 12”

Material: Ductile Iron Segments: 1 Length: 420 LF

Material: PVC Segments: 5 Length: 1220 LF

Material: Unknown Segments: 24 Length: 4800 LF

Unknown thought to be likely Cast/Ductile Iron.

Diameter: 16”

Material: PVC Segments: 5 Length: 1070 LF

• Maintain a "suspected leak" log documenting all areas where suspected leak noise is detected. This log shall be submitted to the Town as part of all periodic and final reports, regardless of whether a confirmed leak is found in a given area, with an explanation of the identified noise source.

• Re-survey all suspected leak areas a second time, with a minimum of four (4) hours elapsed between the initial and confirmation listening sessions.

• Line-locate water mains and service lines in the vicinity of each suspected leak to confirm pipe geometry and input accurate distances into leak correlators, and coordinate with the

Town so that Town staff may observe the locates, provide institutional knowledge where available, and assist in confirming that the observed conditions are consistent with known system information.

• Utilize state-of-the-art electronic leak correlators to confirm and pinpoint leak locations. For PVC/C900/HDPE mains, only correlators capable of analyzing sound frequencies inherent to non-metallic pipe shall be used. When normal contact points are not available and/or accessible within allowable distances, an on-the-ground (microphone) listening device may be used. The ground microphone device should have quality earphones and a graphic or numerical display of the potential leak noise.

• Mark confirmed leak locations on the surface using environmentally formulated blue marking paint.

• Collect sub-meter coordinates (NAD 83 Colorado State Plane Central) for all confirmed leak locations. GPS data shall be exported in a format compatible with the Town's GIS system (shapefile, geodatabase).

• Report leaks requiring immediate attention (immediate threat to life, injury, or traffic safety) to the Town as quickly as possible.

• Note and report all mapping discrepancies, inaccessible appurtenances, and distribution system assets found in disrepair.

• Valves and hydrants shall not be operated without prior Town permission. Valves or hydrants that break due to pre-existing conditions are the sole responsibility of the Town.

The Contractor shall familiarize itself with the following known system characteristics prior to commencing work:

System Component Details

Water Mains Update

Mainline Valves Update

Operating Pressures ~30–110 psi (70 psi)

Water Service Lines Update services; typically 3/4-inch copper or SDR9 pipe

Fire Hydrants Update

As part of each leak detection survey, the Contractor shall acoustically assess all accessible fire hydrants for evidence of leakage. For each hydrant where leakage is suspected:

• Verify the finding by closing the hydrant's auxiliary (isolation) valve to observe whether leak noise dissipates. This shall be performed only with the Town's prior permission.

• Attempt to seat the hydrant valve by tightening the operating nut only with Town authorization.

• Document all hydrant leakage findings in the suspected leak log and final report.

Deliverables:

Deliverable Description Due Date

Work Plan & Schedule

Detailed schedule identifying survey areas, sequence of operations, crew assignments, and projected completion dates.

Prior to kickoff meeting

Daily Reports

Field staff shall meet daily with the assigned Town representative to review prior day's progress and planned work for the current day.

Each field day

Priority 1 & 2 Deficiency Reports

Written reports including leak location diagram, GPS coordinates, estimated loss rate (GPM), pipe material, and recommended corrective action.

Per Section 5

Weekly Summary Reports

All leak detection activity for the week including suspected leak log, confirmed leaks, appurtenance deficiencies, and mapping discrepancies. Submitted in Town-preferred format.

Within 5 business days of week end

Final Report

Comprehensive report including: all leak location reports with diagrams;

GPS point locations; estimated total water loss (GPD/GPY); total pipe distance surveyed; description of area surveyed; mechanical deficiencies noted; mapping errors; cost-benefit analysis based on cost to produce water; and system maintenance recommendations.

Within 30 working days of fieldwork completion

GIS / ArcGIS Shapefile

ArcGIS shapefile or geodatabase with one point per confirmed leak. Attribute fields shall include: GPS location (sub-meter), date of test, estimated severity (GPM), leak type (main, service, valve, hydrant), and notes.

With final report

Each confirmed leak shall be accompanied by a field diagram illustrating the leak location relative to nearby system components (valves, hydrants, service connections), correlation distances, and sensor placement.

Report Requirements

A final report shall be provided within two-weeks of completion of the project, unless separate timeline coordinated with the Town is approved based on the findings. Report shall include at minimum:

• Summary of the areas surveyed

• Other observations made for the area surveyed

• Dates and times that surveys were conducted

• Description of equipment and techniques used to conduct the survey

• Specific location of all detected leaks. Note main size, material, and leak rate estimate.

• If identified leaks were repaired by the Town (If applicable)

• Results of the resurvey of leak repaired locations

Working Provisions The Town will designate a single point of contact that is familiar with the water distribution system and the areas to be surveyed. This person will be available during normal work hours by cell phone. The Contractor will appoint one person for its point of contact and with a cell phone. The

Town will provide the necessary field personnel for assistance in locating and operating valves, services, and hydrants. Assist, as needed, to locate non-metallic pipe within the service area and to clear service valves, meter pits, and valve boxes required for listening. Assist, as needed, to gain entry into secured facilities, pump stations, or other access-restricted sites.

The Contractor shall prepare and submit for approval to the Owner a project schedule. Items on the schedule shall be arranged by day in the order and sequence in which they will be performed.

The schedule shall be updated at the end of the first two-week period and every one-week period thereafter, if necessary.

Prior to commencing field work, the Contractor shall participate in a kickoff meeting with designated Town staff and Engineer to review system maps, confirm areas of interest, identify any pump stations or special coordination needs, verify communication protocols, and establish reporting schedules.

Most work will be on public property/rights-of-way, while a portion may require access through private property. Potential points of private property access are reflected on the supporting maps.

The Town will facilitate this access as possible in coordination with the Contractor. The

Contractor shall obtain a right-of-way permit and approval of traffic control plans from Town of

Morrison, and CDOT (Morrison Road, Bear Creek Avenue, Highway 8, Highway 72), as required.

CDOT Permit fees as applicable shall be paid by the Contractor. Morrison Right-of-Way Permit fees shall be waived, but Contractor is required to procure right-of-way permits and submit applicable traffic control plans, and other required documentation in advance of the performance of the work. As part of the right-of-way permit, the Contractor shall retain insurance to the limits as required by the Contract.

Traffic Control Expectations:

CDOT Controlled Streets: Contractor should anticipate the requirement of a lane closure, with the possibility of two-way flagging around the closure area, and/or possible temporary routing of traffic into center lane if possible. Contractor will not be able place no-park signage in these work areas until the morning of the work and should remove the no-park designations as the work progresses.

Town Controlled Streets: Town controlled streets have far less traffic, and access is generally limited to local access only. Contractor will at minimum be required to provide a single flagger for traffic observation and direction. Contractor shall avoid blocking driveways for extended durations as possible.

After-Hours Work: If survey conditions (e.g., high traffic noise) require work outside normal hours, the Contractor shall provide the Town a minimum of 24 hours advance notice to allow coordination with other affected parties.

Quality Assurance and Quality Control

The Contractor shall collaborate with the Town Engineer to ensure data quality, accuracy, and consistency. If any questions or concerns arise from the provided data (such as inconsistencies from map to field, asset identification numbers, etc.), the Contractor shall meet with the Town

Engineer to review and ensure data accuracy and understanding.

The Town Engineer will provide:

• Water system maps and files (hard copy, PDF, GIS Export etc.)

• Recommendations for access as coordinated with Town Staff.

• Any answers necessary for ensuring data integrity and proper data transfer from the Contractor to the Town.

Applicable Standards & References

• AWWA Manual M36 — Water Audits and Loss Control Programs

• AWWA Manual M33 — Flowmeters in Water Supply

• AWWA Water Loss Control Committee Guidelines and Free Water Audit Software

• OSHA 29 CFR 1910 / 1926 — General Industry and Construction Safety Standards

• Manual on Uniform Traffic Control Devices (MUTCD) — Traffic Control Requirements

• Colorado Department of Public Health and Environment — applicable drinking water regulations

Section 2 - PROPOSAL SUBMISSION REQUIREMENTS Proposals must specifically address each of the questions or items listed below. The information provided will be a guide, subject to verification, for determining the capacity and qualifications of the proposer who can provide the highest level of services to the Town.

Proposals should not exceed ten (10) pages in length. The page limit is not affected by the transmittal letter, Attachment B, pricing, cover pages, table of contents, or divider sheets.

Provide your proposal response which must include the following information, in the order listed below.

Cover Letter

1. Address the letter to the Town.

2. Provide your company name and physical office location.

3. Provide the name and email address of the individual authorized to represent your company.

Experience

1. Describe how many years your company has worked on leak detection projects.

2. Provide no more than three (3) examples of past projects similar in scope to the

Town’s project. Projects should highlight experience in self-performed work.

3. Identify key staff and personal involved in the project.

Approach

1. Provide a milestone schedule for completing the work.

2. Describe how many staff will be assigned work for this project, and each staff member’s capacity.

3. Describe your approach to data quality assurance and quality control.

4. Describe your approach to overcoming schedule changes and delays, and how you plan to communicate changes to the Town.

Pricing

1. Response should include a Price Proposal for Total System Analysis. Shall be a not to exceed number for the full scope established by contract.

Price Proposal should include general details on anticipated days to complete the survey, standard cost per/day reflecting all field labor, equipment, transportation, daily reporting, gps data collection, and all other costs described. Proposal should include separate line items for final report, final GIS deliverables, and an identified mobilization fee that is anticipated for initial request for payment.

Forms and References

1. Certificate of Good Standing issued by the Colorado Secretary of State

2. Provide the names, phone numbers, and email addresses for at least three (3) references who the Town may contact, who are free to discuss all aspects of their experience working with your company.

Section 3 - GENERAL REQUIREMENTS

A. INTERPRETATIONS AND ADDENDA:

Should a proposer find a discrepancy or omission in this RFP, or should a proposer be in doubt as to the meaning of any provision of this RFP, the proposer should submit their question in RMEPS, and any necessary clarifications or addenda will be provided by the Town in writing. Proposers are solely responsible for obtaining and reviewing all addenda.

THE TOWN WILL NOT BE RESPONSIBLE FOR ANY ORAL INSTRUCTIONS OR

INTERPRETATIONS GIVEN BY OR TO ANYONE. It shall be conclusively presumed that the proposer did, before submitting a proposal, closely review the RFP, all exhibits/attachments, and other items relevant to the RFP.

The instructions contained within are not intended to completely define the proposed contractual relationship between the Town and the successful proposer. The awarded contract will be similar in form to the attached Sample Agreement (Attachment A), but the Town reserves the right to make changes and additions prior to contract execution at the sole discretion of the Town.

B. PRICING:

All prices quoted shall be firm and fixed for the specified contract period. The proposer is solely responsible for determining any and all direct and incidental costs associated with performing the work, including but not limited to, insurance, tools, vehicles and equipment, labor, minimum wage requirements (if applicable), overhead, and any other related costs.

C. ELECTRONIC PROPOSAL SUBMISSION:

The Town will only accept and consider proposals electronically submitted via RMEPS.

Registration with RMEPS is available at no charge. Hardcopy proposals or proposals submitted by any other means will not be accepted. The Town is not responsible for the actions or lack thereof on the part of the proposer in regards to their interaction with RMEPS, and the

Town does not have access to or control the vendor side of RMEPS; for technical assistance, contact RMEPS at 1-800-835-4603.

Costs for developing proposals in response to this RFP are entirely the obligation of the proposer and shall not be chargeable in any manner to the Town. This includes travel to and from the Town for the purpose of participating in any interviews as part of the selection process.

Proposers cannot modify submitted proposals after the proposal submission deadline. Any proposer, upon their authorized representative’s written request, will be given permission to withdraw their proposal at any time before the proposal submission deadline.

D. CONFLICT OF INTEREST:

The proposer and its subsidiaries, affiliates, subcontractors, principals, or employees shall not engage in any transaction, activity or conduct which would result in a conflict of interest. If applicable, prior to submitting a proposal, the proposer must disclose to the Town RFP Designated Contact any and all current or potential conflicts of interest, including transactions, activities, or conduct that would affect the judgment, actions, or work of the proposer by placing the proposer’s own interests, or the interest of any party with whom the proposer has a contractual arrangement, in conflict with those of the Town. The proposer should contact the Town RFP Designated Contact with any questions regarding what may constitute a conflict.

The Town, in its sole discretion, shall determine the existence of a conflict of interest and may disqualify proposals in the event such a conflict exists.

E. CONTRACT EXECUTION:

Proposers shall indicate whether all terms and conditions of the Sample Agreement are acceptable, or whether the proposer has any proposed modifications. The Town reserves the right to conduct negotiations with the successful proposer(s) and to accept scope of work revisions prior to contract execution.

Prior to finalization of award, the successful proposer will be required to furnish a Certificate of Good Standing from the Colorado Secretary of State’s Office as proof that they are properly registered to do business in the State of Colorado or provide certified documentation indicating that the proposer meets an exemption under C.R.S. § 7-90-801(2).

Proposers cannot be presently debarred, suspended, proposed for debarment, or declared ineligible for the award of contracts by any Federal agency. By submitting a proposal, proposers certify they have not, within a three year period preceding this RFP, been convicted of or had a civil judgment rendered against them for a commission of fraud or a criminal offense in connection with obtaining, attempting to obtain, or performing a public (federal, state, local) contract or subcontract; violation of Federal or state antitrust statutes relation to the submission of offers; commission of embezzlement, theft, forgery, bribery, falsification or destruction of records, making a false statement(s), tax evasion, or receiving stolen property;

or presently been indicated for, or otherwise criminally or civilly charged by a governmental entity with, the commission of any of the offenses enumerated above.

Proposers shall provide immediate written notice to the Town if, at any time prior to contract award, the proposer learns that its certification was erroneous when submitted or has become erroneous by reasons of changed circumstances. If it is later determined that the proposer knowingly rendered an erroneous certification, in addition to other remedies available to the

Town, the Town may terminate the contract resulting from this RFP for default; termination for default may result in additional charges being levied for the costs incurred by the Town to initiate activities to replace the awarded contractor.

No rights to provide goods or services shall arise unless and until the awarded contract is signed by the Town and approved by Contract. Failure to comply with any of the requirements to execute the contract within 10 days of the Town’s request shall be just cause for the annulment of the award. Award may then be issued to the next qualified proposer, or work may be readvertised, or may otherwise be handled at the Town’s sole discretion. The Town shall not incur any liability whatsoever if the awarded contract is not approved by Town

Contract. The awarded contract shall be non-exclusive. In the Town’s best interests, the Town reserves the right to purchase the same materials and services through other procurements.

F. COLORADO OPEN RECORDS ACT:

Any information submitted with the proposal shall become public information, subject to release, under the Colorado Open Records Act (C.R.S. §§ 24-72-201 through 205) (“CORA”).

It is the responsibility of the proposer to ensure that no confidential or proprietary information is included in the proposal that the proposer would not wish to be released, or to identify in its proposal any information the proposer deems confidential, or which contains proprietary information, patents, copyrights, or trade secrets. The proposer must provide justification of what information, upon request, should not be disclosed by the Town under CORA. The Town may otherwise use or disclose the information submitted by the proposer for any purpose, unless its use is so identified and restricted by the proposer; however, the proposer’s opinion of what constitutes confidential information under CORA is not binding upon the Town. The

Town shall be held harmless from any claims arising from the release of information within the proposal.

Section 4 - SELECTION PROCESS

A. EVALUATION CRITERIA:

Proposals shall be evaluated based on the criteria below and other relevant considerations as determined by the selection committee. Proposals shall also be evaluated to confirm the proposer has conformed with the requirements of the RFP (signed forms, etc.), and to confirm the proposer is not in arrears to the Town, in default with the Town, or otherwise subject to award disqualification. The Town may, if it deems necessary, request clarifications, conduct discussions or interviews, or request best and final offers.

1. Experience

2. Approach

3. Pricing

B. PROPOSAL ACCEPTANCE AND DISQUALIFICATION:

In the Town’s best interests, and at the Town’s sole discretion, the Town reserves the right to cancel, suspend, or modify the solicitation; to reject any or all proposals; and/or to waive informalities, irregularities, or omissions in any proposals. As the Town deems necessary and appropriate, and in its sole discretion, the Town reserves the right to make any inquiries or other follow-up required to verify or clarify information provided by the proposer. Any one or more of the following causes may result in the disqualification of a proposer and the rejection of a proposal:

i. Failure to provide complete information, pricing, and/or documentation as required.

ii. Submission of more than one proposal for the same work from an individual, firm, partnership, or corporation under the same or different names.

iii. Evidence of collusion among contractors; participants in such collusion may receive no consideration for award for any future work.

iv. Default, breach, or termination of other contracts pertinent to proposer’s ability and willingness to perform contractual obligations.

v. Breach or violation of terms and conditions of existing Town contracts, licenses, or permits.

vi. Delinquent federal, state, or local tax obligations; or outstanding debts to the Town.

i. Federal debarment or suspension.

ii. Omissions or fraudulent statements.

iii. Lack of competency as revealed by the proposer’s submission, or lack of ability to operate as required.

iv. Uncompleted work which, in the judgment of the Town, might hinder or prevent the prompt completion of additional work if awarded.

v. Conviction or indictment of a proposer or proposer’s staff for a felony involving violence, including sexual offenses, and/or listing of same on the Colorado sex offender registry or a similar sexual offender registry of another state or the federal government.

vi. Not being in good standing with the Colorado Secretary of State.

vii. Failure to disclose potential conflicts of interest.