SFOM Pre-solicitation Conference slides.pdf
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- Solicitation number
- FA251720R0007
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This document provides details for a pre-solicitation conference related to Solicitation Number FA251720R0007 for non-personal services to support 24/7 operations and maintenance of the Space Fence S-Band Radar. The conference slides outline the Space Fence mission, performance work statement requirements including tasks for the Space Fence Operations Center and Sensor Site 1, risk assessment, proposed contract and acquisition information, source selection criteria, and special considerations. Key information includes the requirement for radar operations and maintenance services, a period of performance from December 2021 through November 2027, estimated contract award by September 2021, technical evaluation criteria in areas such as operations support and maintenance, price and subcontracting factors for source selection, and potential risks involving organizational conflicts of interest and additional sensor sites.
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Peterson-Schriever Garrison
Integrated Support… Empowered Ops… Resilient Professionals… Responsive Relationships
Space Fence S-Band Radar Operations and Maintenance
(SFOM)
FA2517-20-R-0007
Pre-solicitation Conference
John “JB” Benjamin, Program Manager Kim Limón, Contracting Officer Date: 24 September 2020
Government Introductions
21st Contracting Squadron (21 CONS):
Contracting Officer (CO): Kim Limón Contract Specialist (CS): Diana Cramer
P-S Gar/Small Business Office (P-S Gar/SB):
Director: Reggie Selby
Program Management Division (P-S Gar/PMD):
Program Manager (PM): John “JB” Benjamin Quality Assurance Manager (QAM): Charles Warren Quality Assurance Manager (QAM): Alexander Young
Overview
Administrative Comments
Purpose of Pre-Solicitation Conference
Ground Rules for Conference and One-on-Ones
SFOM Mission Briefing
Performance Work Statement (PWS) Requirements
Risk Assessment
Proposed Contract Information
Proposed Acquisition Information Proposed Source Selection Method and Criteria
Overview
Special Considerations
Potential Site Move Potential Site Addition Government Property Consideration Organizational Conflict of Interest (OCI)
Anticipated Acquisition Schedule
Questions
Welcome! We’re looking forward to a successful exchange of information and encourage everyone to participate.
This is our first attempt at a Virtual event and we ask for your patience.
Please make note of the following:
The Government has not finalized the Acquisition Strategy
Questions at the end of the presentation will be accepted from the designated representative(s) identified in the RSVP
If you have joined us via WebEx, please do not also join via the telecom line
If you have joined via the telecom line, please mute your phone during the presentation
One-on-one sessions (WebEx/telecom)
All sessions require a reservation – if you requested a session, you should have received confirmation from our office
Questions should have been submitted in advance
Participation is limited to two (2) people per prospective prime and each subcontractor
Sessions are limited to a strict 30 minutes
If you join via WebEx/dial in late, there will be no change in the scheduled end time
Purpose of Pre-solicitation Conference
IAW the Federal Acquisition Regulation (FAR) 15.201, Exchanges with Industry Before Receipt of Proposals:
Exchanges of information among all interested parties, from the earliest identification of a requirement through receipt of proposals, are encouraged
Any exchange of information must be consistent with procurement integrity requirements (see FAR 3.104)
Interested parties include potential offerors, end users, Government acquisition and supporting personnel, and others involved in the conduct or outcome of the acquisition
Pre-solicitation conferences can be invaluable in communicating requirements, risks and methodology, and encouraging industry to provide feedback in an open exchange
Ground Rules
Nothing stated in the Pre-solicitation Conference or during one-on-one discussions is contractually binding
We encourage and appreciate open information exchange The Government may, or may not, incorporate changes to the solicitation or requirements based on feedback received Proprietary information or approaches must be identified and will not be shared Questions asked will be documented and answers posted to all interested offerors Any costs incurred by companies prior to receipt of a contract signed by the CO is at your own risk All Government changes or direction will be communicated in writing by the CO
Ground Rules (cont.)
The Government will post the following on beta.Sam.gov:
Attendance roster to facilitate subcontracting opportunities
Government briefing charts
All questions and answers, including those from the one-on-one discussions, will be compiled on a non-attribution basis and posted to beta.Sam.gov
Identified proprietary information or confidential business strategies will not be shared
Organization Chart
Space Fence Mission Briefing
Microsoft werPoint Presentat
Major Bryan Sanchez will present the Mission Brief for the Space Fence System
Space Fence PWS Requirements General
Section 1.0. Space Fence (SF) General Requirements Overview
1.1. Mission (Increment One – Sensor Site 1 (Radar)):
Strengthen U.S. space superiority Improve Space Domain Awareness (SDA)
Operational Chain of Command:
Space Delta 2 (DEL-2), Peterson-Schriever Garrison
(P-S Gar), CO 20th Space Control Squadron (SPCS), Eglin AFB, FL Detachment (Det) 4, Redstone Arsenal, AL Sensor Site 1 Director & Contracting Officer’s
Representative (COR)
General (cont.)
1.2. Space Fence Scope:
Provide non-personal services to manage, operate, maintain, and provide logistical and general support for the Space Fence system
Provide all personnel, tools, materials, transportation, supervision, and other items necessary to perform SF PWS requirements on 24-hours-a-day, 7-days-a-week (24/7) basis
1.3. Site Changes – Addressed in Slide 50
1.5. PWS Organization
1.6. Contractor Performance Assessment Report (CPAR)
1.7. Site Operations
1.8. Withdrawal of Privileges
1.9. Individual Job Orders (IJOs)
1.10. Contractor Documentation of Contract Performance
1.11. Workload Data
1.12. Incident Reporting
1.13. Continuance of Performance/Mission Essential Services
1.14. Contract Contingency Planning
1.15. Third-Party Support
1.16. Uncleared Personnel Escort
1.17. SF Operating Instructions (SF OIs)
1.18. Technical Order (TO) Distribution and Control
1.19. Quality Program
1.20. Technical Meetings
1.21. Familiarization Briefings and Tours
1.22. Inspections and Exercise Support
1.23. Budget Information
1.24. Training
1.25. Contractor Common Access Cards (CACs)
1.26. SIPRNet Tokens
1.27. Hand Tools and Equipment
1.28. Program Management
Site Specific
Requirements Associated with 2 locations:
SF Operations Center (SOC), Reagan Test Site Operations
Center, Huntsville, AL (ROC-H); remotely operates SF radar
SF Radar, U.S. Army Garrison -- Kwajalein Atoll (USAG- KA), Republic of the Marshall Islands (Western Pacific)
Site Specific (cont.)
Section 2.0. Mission Operations and Support Requirements Overview Applicable to Det 4 SOC and Sensor Site 1 (including all subparagraphs):
2.1. Sensor Operations and Support
2.2. Mission System Maintenance Management
2.3. Logistics Management
2.4. Communications O&M
2.5. Environmental Management
2.6. Civil Engineering (CE)
2.7. Industrial, Physical, and Operational Security
2.8. Knowledge Operations
2.9. Contract Transition
Section 3.0. Det 4 SOC Mission Operations and Support Requirements Overview Applicable to Det 4 SOC Only (including all subparagraphs):
3.1. Mission Planning
3.1.1. Top Secret (TS)/Sensitive Compartmented
Information (SCI) Cleared Personnel
3.1.2. Uncorrelated Target (UCTs)
3.1.3. Hand-offs
3.1.4. Break-up Processing
3.1.5. Maneuver and Proximity Operations Events
3.1.6. Launch Events
3.1.7. Black-box Reporting
3.1.8. Develop, Test, Execute Tactics Improvement
Proposals (TIPs)
Section 4.0 Sensor Site 1
Support Requirements Overview
Applicable to Sensor Site 1 Only (including all subparagraphs):
4.1. Test, Measurement, And Diagnostic Equipment (TMDE)
4.2. Environmental Services
4.3. Civil Engineering (CE)
4.4. Environmental Health
Section 5.0 Government Provided Support of Contract Service Performance Det 4 SOC and Sensor Site 1, as applicable:
5.1. Government-Furnished Property (GFP) and Government-
Furnished Equipment (GFE)
5.2. Government-Furnished Information (GFI)
5.3. Government-Furnished Services (GFS)
(Applicable to Det 4 Sensor Site 1 only)
Section 6.0 Services Summary Applicable to Det 4 SOC and Sensor Site 1:
Mission and Site Requirements
Performance Objective (PO)
PWS
Reference
Acceptable Quality Level (AQL)
PO# 1 - Metric Taskings. Perform metric taskings as directed by 18 SPCS.
Paragraph 2.1.2.1
100% of all category (CAT) I taskings.
Track or attempt to track all CAT I taskings, except when non-contractor liable downtime or physical/geographic limitations.
PO# 2 - SOI Taskings. SOI-tasked objects. Paragraph 2.1.2.2 Complete 100 percent of SOI-tasked objects each month except when non-contractor liable.
PO# 3 - Sensor Contractor-Controlled Availability (Acc). Maintain an overall sensor Acc.
Paragraph 2.1.5 Acc each calendar month of not less than 99.7.%. See PWS reference for additional information.
Section 6.0 Service Summary
Mission System Maintenance Management
PO# 4 - Equipment Status Reporting (ESR). Ensure equipment status updates are entered into the IMDS ESR Subsystem.
Paragraph 2.2.2
Submit an IMDS entry within two hours of the equipment status change. See PWS reference for additional information.
PO# 5 - IMDS Data Entries. Accurately input all MDC data into IMDS in a near real-time basis.
Paragraphs 2.2.4.1, 2.2.5.2
MDC data shall be entered into IMDS with 95% initial accuracy, 98% accuracy within 72 hours and 100% accuracy within 5 days.
Communications Operations & Maintenance (O&M)
PO# 6 – Communications Security (COMSEC). Manage, handle, control, and safeguard COMSEC material, equipment, and local element in accordance with Air Force policy and Key Management Infrastructure (KMI) Operating Account Manager (KOAM) guidance.
Paragraph 2.4.4.3
No Reportable COMSEC incidents due to Contractor error or failure to follow established guidance. Additionally, no “unsatisfactory” rating during an AF or KOAM inspection.
Section 6.0 Services Summary
Industrial, Physical and Operational Security
PO# 7 - Industrial/Information Security. The Contactor shall implement and perform all required industrial/information security functions and actions IAW the certified DD Form 254 and DoD 5220.22-M.
Paragraph 2.7.1.
Zero security incidents resulting in violations.
Appendix A…..Deliverable Requirements
Appendix B…..Publications and Forms
Appendix C…..Host Plans, Policies & Procedures
Appendix D…..PWS Acronyms
Appendix E…..PWS Definitions
Appendix F…..Government-furnished Training
Appendix G…..RMF Artifacts
Space Fence Risk Assessment Overall
Initial Risk Identification:
Low: 1 Moderate: 6 High: 3
C = Cost S = Schedule P = Performance
After Handling:
Low: 8 Moderate: 2 High: 0
Initial ID After Handling 5 Near Certainty 5(S,P)
4 Highly Likely 2(P) 4(C,P), 6(S,P) 2(P)
Likely 1(S) 6(S,P)
2 Low Likelihood 3(P), 7(S), 9(P), 10(P)
1(S), 3(P), 4 (C,P), 9(P), 10(P) 7(S)
Not Likely 8(P) 5(S,P) 8(P)
Minimal
Minor
Moderate
Significant
Critical
Minimal
Minor
Moderate
Significant
Critical
Risk OCI (Moderate)
Risk: Organizational Conflict of Interest (OCI): (Performance) If an OCI exists between the Sustainment Contractor and Space Fence offerors, then there may not be competition.
Handling Strategies:
Provision/Clause in RFP/contract for offerors’ to self identify potential OCI Instructions in RFP to have offerors’ self identify and provide a plan for the Government to evaluate mitigation strategies proposed
Risk BL/WD (Low)
Risk: Bidders Library/Workload Data: (Cost & Performance) If there is not adequate bidder’s library information and workload data, then offeror’s cannot adequately propose level of effort.
Handling Strategy:
Request deliverables from ICS contract for SF O&M Bidder’s
Library Capture ICS Integrated Maintenance Data system (IMDS) data for SF O&M Bidder’s Library.
4 (C,P)Moderate
High
Low
Risk TOs (Low)
Risk: Approved Maintenance Technical Orders (TOs):
(Performance) If Maintenance TOs are not approved by Sep 20, then there is no approved documentation for system maintenance.
Handling Strategy:
DEL-2/TD and DEL-2/MA support TO adjudication and
VAL/VER activities Reference TOs in the PWS with a statement to use Drafts provided in the Bidder’s Library until final TOs are approved for use
3(P)
High
Moderate
Risk IAA (Low)
Risk : Inter-Agency Agreement (IAA): (Schedule & Performance) If the IAA between P-S Gar and the Army Host is not finalized in a timely manner, then mission support services cannot be clearly defined in the PWS.
Handling Strategy:
Coordination of the IAA has been expedited IAA provides clear division of support, allowing PWS to be finalized.
Risk Transportation (Low)
Risk: Contractor Return Transportation to Sensor Site:
(Performance) If commercial transportation isn't available for contractors to return to work at Kwajalein, then contractor performance will be impacted.
Handling Strategy:
Identify for industry mitigation Section L&M Criteria for manning/retention
8 (P)
High
Moderate
Risk Workforce (Low)
Risk: Skilled Workforce & Retention: (Performance) If Skilled contractor personnel are not hired and retained, then the SF mission will fail.
Handling Strategy:
Sharing risk with industry Section L&M retention criteria
9 (P)
Low
High
Moderate
Risk Knowledge/Training (Low)
Risk: Knowledge Transfer/Training: (Performance) If the SF contractor does not hire Interim Contract Support (ICS) contractor personnel and/or capture knowledge (over the shoulder/training, etc.), then there will be a learning curve and a delayed ramp-up for SF Mission Operators.
Handling Strategy:
Operations and Maintenance Training Plan and over the shoulder Training with the ICS contractor L&M retention criteria High
10 (P)
Moderate
Risk Summary
Overall Program Risk after Mitigation: Low to Moderate Zero (0) out of 10 risks are rated high.
Two (2) out 10 risks are rated moderate.
Eight (8) out of 10 risks are rated low.
Cost Risk: Overall cost risk evaluated as low
One cost risk identified as low related to the Bidders’ Library/Workload data
Schedule Risk: Overall schedule risk evaluated as low.
Four schedule risks were identified, all low risk. They include acquisition timeline, IAA completion, PWS development, and review timeline.
Risk Summary
Overall Program Risk after Mitigation: Low to Moderate (cont.)
Performance Risk: Overall performance risk evaluated as low.
Eight risks were associated with performance; two were rated moderate, and six were rated low.
Moderate risks included: OCIs and the development of the PWS Low risks included: Bidder’s Library/Workload Data, Finalized Maintenance TOs, the IAA, Contractor Transport to Kwajalein, Skilled Workforce/Retention, and Knowledge Transfer/Training.
Risk Handling Summary
Implementation Facilitating the Inter-agency Agreement (IAA) between
DEL-2 mission owner and the Kwajalein Army Host Handling via acquisition strategy:
Exchanges with Industry Well defined requirements in the PWS Information in Bidder’s Library Workload data TOs (Operational and Maintenance)
Source Selection Strategy & Evaluation Criteria Required OCI provision/clause
Space Fence Proposed Contract Information
Anticipated Contract Line Items (CLINs) Structure
Firm Fixed Price (FFP) CLINs:
All services and parts necessary in performance of PWS requirements that are foreseeable and can be forecasted
Requirements shall be covered in the fixed price even if the contractor chooses to subcontract to a certified company to perform the work
Consumables (custodial supplies, light bulbs, paper, etc.) and parts, supplies and materials needed for normal maintenance and in performance of day-to-day contract requirements are to be included in the fixed price and will not be reimbursed by the Government
Space Fence Proposed Contract Information (cont.)
Anticipated CLIN Structure (cont.)
FFP CLINs
The contractor shall cover any agreement, employee meal costs, and unofficial travel expenses as agreed to between the contractor and the contractor’s employees
The Government will not reimburse these costs on a cost reimbursable basis
Anticipated CLIN Structure (cont.)
Cost Reimbursable (CR) CLINs (allowable costs):
Government-approved equipment, materials, supplies which are not foreseeable and cannot be forecasted
Government-approved TDY and non-local travel
Parts (if not part of preventive maintenance)
Labor hours resulting from Government-approved minor labor surges
G&A is allowable on CR CLIN purchases if applicable;
however, neither profit nor fee shall be allowed
Space Fence Proposed
Anticipated CLIN Structure (cont.)
Individual Job Order (IJO) CLINs:
Work which is not specifically identified in the PWS, but which is still within the general scope
IJOs, CLIN type to be determined by the CO on a case-by-case basis, dependent on the nature of the work
Contractor shall develop initial technical and cost proposals for Government review and approval at the request of the CO
Contractor shall perform planning, development, and distribution of plans and specifications, installation instructions, bills of materials, drawings and inspection to complete the job at the work location
Space Fence Proposed
Anticipated CLIN Structure - IJOs (cont):
The contractor will provide all necessary management for IJOs to include technical management, logistics support and services, administrative support and services, and similar requirements
Examples of IJOs include, but are not limited to: generation of threat scenarios for system test and evaluation, generation of exercise simulation media for system tests and exercises, special reports or surveys related to the technical operation or maintenance of the mission equipment or support systems
IJOs shall be negotiated by the CO prior to any action
Work shall commence once a bilateral modification is finalized and signed
Space Fence Proposed
Proposed Acquisition Information
NAICS: 517919 –All other telecommunications Small business size standard $35M
PSC: M1BC – Operation of Radar and Navigational Facilities
Competitive: Full & Open
Contract Type: Hybrid w/ FFP CLINS, CR CLINs, and IJO CLINs
Contract Period of Performance: 26 Dec 21 – 27 Nov 27
Estimated Contract Award Date: 15 Sep 21
Phase In Period: 26 Oct 21 – 25 Dec 21
Start Date: 26 Dec 21
Proposed Source Selection Information
It is anticipated the Government will conduct the Source Selection as Technical Price Tradeoff (TPT)
Technical proposals will be evaluated and assigned combined technical/risk ratings to reflect the extent the proposal meets the Government’s specified performance and capability requirements, considering any strengths and weaknesses associated with the proposed approach
The Government may award to a higher-priced offeror if the Source Selection Authority determines the superior technical approach outweighs the price difference
The winning offeror’s technical approach, including the Small Business Participation Commitment Document, will be incorporated into the contract as an attachment in Section J
Selection Criteria
Anticipated evaluation criteria to be based on three factors:
Technical (Factor 1)
Consists of four subfactors; all equally weighted
1. SOC Operations and Support
2. Sensor Site 1 Dual-Role Operator/Maintainers
3. Space Fence Mission System Level 1 Maintenance
4. Overall Space Fence Staffing Plan
Price (Factor 2) Evaluated for reasonableness, balance and affordability Technical is significantly more important than price.
Subcontracting Commitment (Factor 3) Evaluated on an acceptable or unacceptable basis
Selection Criteria (cont.)
Technical factor will be rated at the subfactor level; an overall rating for Factor 1 will not be given
Each Technical subfactor will be given a rating IAW DoD Source Selection Procedures as follows:
Price (Factor 2)
Section L, Sub-section D. Proposal Instructions, para 2. Vol 2
Price information
All Option Periods, to include the base period
All Fixed Price Contract Line Item Numbers
Section M, Sub-section C. Evaluation Factors, para. 2, Factor 2
Total Evaluated Price Calculation
Price Reasonableness
Balanced Pricing
Small Business Commitment (Factor 3) Section L, Sub-section D. Proposal Instructions, para 3. Vol 3 Shall submit a “Small Business Participation Commitment
Document” Minimum Quantitative Requirement (MQR) of 20% of Total
Contract Value (TCV) 20% calculation Base period calculation = 20% of the cost of the Base period Option year 1 = 20% of the cost of the base period + 20% of the cost of option year 1, etc.
Subsequent modification driven by IJOs will not affect the
20% calculation The MQR is a requirement – not a goal.
Small Business Commitment (Factor 3), cont.
Section M, sub-section C. Evaluation Factors, para 3. Factor 3
Factor will be rated acceptable or unacceptable
Minimum Quantitative Requirement (MQR) of 20% of Total Contract Value (TCV)
Signed small business teaming agreement(s)
Table 2 - Ratings for Factors (2-Rating Description)
Acceptable Proposal meets the requirements of the solicitation
Unacceptable Proposal does not meet the requirements of the solicitation
What about Past Performance?
Past performance will not be included as separate evaluation criteria
Past Performance will be included as part of the responsibility determination
A lack of demonstrated history of past performance will be the basis for a determination of non - responsibility
Potential Sensor Site addition
Potential SOC relocation
Government Property
Organizational Conflict of Interest (OCI)
Potential Sensor Site addition – there is the possibility of an additional sensor site to be added during the life of this contract.
The Government has a placeholder in the PWS for this eventuality.
If and when, the second site is built and added to this acquisition, it will be addressed as a separately negotiated modification.
Potential SOC relocation - there is the possibility the SOC will be re-located from Huntsville, AL to Eglin AFB, FL during the life of this contract.
A placeholder is included in the PWS; if the re-location occurs during this contract, it will be addressed with a separately negotiated modification.
Government Furnished Property (GFP) Considerations
We request industry feedback on the following considerations:
Use of Government property in contract performance is subject to the following regulations and guidance
Financial Improvement and Audit Readiness (FIAR)
“Although the Department of Defense may not have physical custody, in order to maintain effective property accountability and for financial reporting purposes, DoD Components shall establish and maintain records and accountability for property (of any value) furnished to contractors as Government furnished property (GFP)”
GFP Considerations (cont.)
Federal Acquisition Regulation (FAR) 45.102 (a) and (b)
(a) Contractors are ordinarily required to furnish all property necessary to perform Government contracts
(b) Contracting officers shall provide property to contractors only when it is clearly demonstrated –
(1) To be in the Government’s best interest;
(2) That the overall benefit to the acquisition significantly outweighs the increased cost of administration, including ultimate property disposal;
(3) That providing the property does not substantially increase the Government’s assumption of risk; and
(4) That Government requirements cannot otherwise be met
GFP Considerations (cont.)
Currently, the Space Fence sites possess one type of Government property:
1) That which properly qualifies as “GFP” as defined at FAR 45.102(b) and DFARS PGI 245.103-70(2)
Property that will be issued as GFP includes that which is on Custodial Authorization/Custody Receipt Listings (CA/CRLs), bench stock issued through the Government Enterprise Solution-Supply (ES-S) system, and Test, Measurement, and Diagnostic Equipment (TMDE)
Potential Organizational Conflicts of Interest (OCI)
A potential conflict of interest exists between the Maintenance of Space Situational Awareness Integrated Capabilities (MOSSAIC) contract and this acquisition
The Space Fence awardee will be responsible for testing or providing technical evaluations of products delivered from the MOSSAIC contract
Design/Build of the Space Fence
Potential OCI (cont.)
Restrictions are needed to ensure that the Contractor is not testing or providing technical evaluations on its own products delivered to the Space Fence program
As a part of the proposal, the offeror shall provide the Contracting Officer with complete information of previous or ongoing work that is in any way associated with the contemplated acquisition
Prime or subcontract work related to the MOSSAIC or Space Fence design/build contract may disqualify an offeror from proposing on Space Fence
Potential Special Considerations
Potential OCI (cont.)
If award is made to the offeror, the resulting contract may include an organizational conflict of interest limitation applicable to subsequent Government work, at either a prime contract level, at any subcontract tier, or both
During evaluation of proposals, the Government may, after discussions with the offeror and consideration of ways to avoid the conflict of interest, insert a special clause in the resulting contract which shall disqualify the offeror from further consideration for award of future contracts, including MOSSAIC and Space Fence design/build or its equivalent
Anticipated Acquisition Schedule
RFP Release 18 November 2020
Anticipated Virtual Site Visit – Huntsville, AL ~2-3 December 2020
Receipt of Proposals from Industry 05 January 2021
Anticipated Contract Award 15 September 2021
Contract Transition 26 October 2021
Contract Performance Start 26 December 2021
Foot Stomp Slides
It is the Government’s intent to incorporate the Offeror’s technical approach (Space Fence System Technical), the Small Business Participation Commitment Document, and approved OCI Mitigation Plan (if applicable) into the contract as an attachment in Section J.
Signed teaming agreements in which each small business concern utilized as a teaming partner or subcontractor is specifically identified and formally committed by name will be required with proposals.
Foot Stomp Slides
Healthcare availability is limited on Kwajalein.
Clearly designate cross-utilized personnel
Continuation of Operations / Mission Essential Service Plan
Furniture for living quarters at Kwajalein – have a plan
Inter-Agency Agreement – provides most key services on Kwajalein
Questions
Any additional questions that result from this Pre-solicitation Conference and the One-on-one sessions are due in writing to the Contracting Officer, Kim Limón, at kim.limon@spaceforce.mil NLT 0800, 28 September 2020.
**No phone calls will be accepted in lieu of a written submission
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