Request for Information Draft SB Subcontracting Plan _25APR2025.pdf

Request for Information (RFI)/Sources Sought (SS) for

Initial Pilot Training (IPT) Draft Small Business Subcontracting Plan

This Request for Information (RFI) seeks Industry’s feedback in the review of the Government’s draft Small Business Subcontracting Plan.

This announcement does not constitute an Invitation for Bids, Request for Proposals, or a Request for Quotations, and is not to be construed as a commitment by the Government to issue a contract or otherwise pay for the information solicited or any follow-up information requests.

The Government does not intend to award a contract based on this notice. Companies responding to this RFI notice are advised that participation does not ensure involvement in any future solicitation or contract award. Contact with Government personnel, other than those specified in this RFI, by interested firms or their employees regarding this requirement is not permitted.

Purpose:

The Government is conducting Market Research/fact-finding to:

a. Seek industry feedback on the draft Small Business Subcontracting Plan and the impact on the commercial business model.

• Would the subcontracting plan requirements, including a requirement to meet a 30% small business subcontracting target, were incorporated into the IPT CSO, how would this impact your willingness or ability to submit a proposal? What percentage of small business subcontracting target would be feasible to execute without impacting your current business model?

(Please explain whether it would discourage, delay, complicate, or otherwise affect your participation, including impacts to your current commercial 14 CFR Part 141 business model.)

• Would the requirement to actively mentor, train, or develop small business subcontractors materially affect:

o Your cost structure for delivering FAA certifications (Private Pilot Certificate (PPC), Instrument Rating (IR), and Multi-Engine Land (MEL))?

o The price charged per student or per FAA certification?

o Your ability to complete FAA certifications within the 139-calendar-day training timeline?

(Please describe any expected cost increases, training delays, or operational impacts.)

• Given that FAA-certified Part 141 schools operate under a commercially regulated and accredited model, would adapting your operations to comply with additional FAR-like subcontracting requirements be feasible without major disruption?

(Please explain if you would need to modify your academic model, contracts, flight training schedules, instructor staffing, or internal processes to accommodate small business participation.)

• Would the addition of a 30% small business subcontracting requirement impact your current commercial training market share, specifically regarding:

o Availability of airfield or airspace resources o Environmental assessments (e.g., requirement to conduct a new NEPA evaluation) o Access to sufficient facilities, aircraft, or instructors

(Please describe how your ability to deliver scalable FAA-certified training (PPC, IR, MEL) could be affected.)

• Do you currently have any existing small business partners supporting your FAA Part 141 training operations? (Yes/No. If yes, please describe.)

• Are there small businesses in the commercial training market capable of assuming 30% of your total IPT operations?

• If so, what portion of the training (academics, flight hours, simulator training, lodging support, etc.) could they reasonably perform without impacting student throughput or quality?

• Would you continue participation into later phases of the IPT Commercial Solutions Opening (FA300225SC001) if these small business subcontracting development requirements were included in the final solicitation, even if they materially impact your commercial business model?

(Yes/No, and briefly explain your rationale.)

DRAFT Small Business Subcontracting Plan:

Other Than Small Business Only: The offeror shall provide a Small Business Subcontracting Plan IAW FAR 52.219-9 Alternate II, FAR 52.219-8, Utilization of Small Business Concerns, DFARS252.219-7003, Small Business Subcontracting Plan (DoD Contracts), and DFARS 252.219- 7004, Small Business Subcontracting Plan (Test Program).

The Small Business Subcontracting Plan shall include all items identified in FAR 19.704(a)(1) through (15) (Subcontracting Plan Requirements), and FAR 52.219-9(d)(1) through (15) (Small Business Subcontracting Plan). The offeror's small business subcontracting plan shall include, but is not limited to, detailing the commitment/targets for each category of Small Business (SB), Veteran- Owned Small Business (VOSB), Service-Disabled Veteran-Owned Small Business (SDVOSB), Small Disadvantaged Business (SDB), Historically Underutilizes Business Zone (HUBZone), and Women-Owned Small Business (WOSB) concerns. The plan shall describe for each category the total contract value subcontracted expressed in dollars and percentage of total subcontracted value if an individual subcontracting plan. The plan shall also state the extent and nature of work to be performed by small business concerns, the method used to develop goals, the method used to locate potential suppliers, if the goals include indirect costs (if so, describe the cost allocation method) and describe the efforts the offeror will make to assure small businesses have an equitable opportunity to compete for subcontracts. The Small Business Subcontracting Plan will be assessed as part of responsibility and must meet the FAR and DFARS requirements prior to the award of a contract. If the planned goals do not meet or exceed DoD Fiscal Year (FY) 25 subcontracting goals below, substantial explanation/rationale shall be provided.

Offerors shall use a hypothetical total contract award amount of $XXXM over the 10-Year Program Life Cycle for the Subcontracting Plan. Additionally, the Subcontracting Plan shall provide the information for the following: 1) Subcontracting for the entire contract period (Base and all options); 2) Subcontracting for the base period of two (2) years, using $XXM as a notional contract value; and 3) Subcontracting for each two (2) year option period separately using $XXM as a notional option period value for each option.

Small Business Subcontracting: 30% (Total Contract Value)

Small Disadvantaged Business: 5% of total small business subcontracting dollars

Service-Disabled Veteran Owned Small Business: 5% of total small business subcontracting dollars

Women Owned Small Business: 5% of total small business subcontracting dollars

HUBZone Small Business: 3% of total small business subcontracting dollars

Subcontracting developmental incentives (Reference: 15 USC 637(d)(4)(E)): Every Offeror is encouraged to propose and implement a small business development program that has the objective of preparing small business subcontractors for future performance in the Initial Pilot Training

Program as prime contractors following on-ramping or as subcontractors with increased roles and responsibilities. If the Offeror is other than small, such a program shall be included as part of an Offeror’s submission of a proposed subcontracting plan. If the Offeror is a small business with a small business teaming arrangement, such program shall be included in the Offeror’s submission describing its small business teaming arrangement. Such program may include:

• Structured training, mentoring, or other capacity-building activities designed to enhance the technical, managerial, and compliance capabilities of small business subcontractors.

- Activities may include, but are not limited to proposal development workshops, compliance training, technical skills transfer, and business systems education.

• The Offeror shall document and report on the progress and outcomes of these activities, including the number of small businesses trained or mentored, their small business categories, the nature of support provided, and the record of increased subcontracting participation.

• Participation in a formal SBA Mentor-Protégé Program or DAF Mentor-Protégé Program administered by the DAF Office of Small Business Programs (SAF/SB) is strongly encouraged, where feasible, to provide developmental assistance to small business protégés (References: 10 USC 4901, Sec. 856(d), Public Law 117-263, DFARS Appendix I, 13 CFR 125.9). Contact SAF/SB at https://www.airforcesmallbiz.af.mil/.

• The Government intends to assess the effectiveness of the Offeror’s small business subcontractor development efforts as part of ongoing contract performance assessments and will incentivize effectiveness with favorable consideration when deciding whether to award contract options.