Pathfinder_2_DRFP_Response_to_Industry_Comments_29_Mar_2017.pdf

Pathfinder #2 – DRAFT RFP

Comment Matrix

ITEM # DOCUMENT PAGE SECTION COMMENT RATIONALE DISPOSITION

1 Attachment 4 N/A N/A Attachment 4 was not included in the initial package documents.

There is no Attachment 4 included with the other RFP documents, and if it was meant to be included and mislabeled or unintentionally omitted may drastically change the level of our response.

Accepted PCO posting Attachment 4 to FBO

DRFP

Model

Contract 12 3.a.1 The monthly operational availability of the transponder should be 99.97% instead of 99.999%.

99.97% satellite availability is consistent with the standard of satellite availability throughout the industry.

Accepted

- TRD and SOW updated as well

DRFP

Model

Contract 12 3.a.1 The second paragraph should be stricken from the contract.

It is unreasaonable for a provider to comply with all technical specifications required in the SOW under LPTA selection criteria.

Rejected – All listed requirements are necessary under this LPTA source selection. Technical requirements represent the government’s requirements. Follow up questions provided to industry.

4 Attachment 3, DD254 N/A N/A The DD254 should be removed as a requirement for submission.

In the SOW, Section 1.2 states: ‘The acquisition and all documents pertaining to it are unclassified.’ Contractor feels that requiring a DD254 is inappropriate for this response;

however, if included, Contractor will complete as necessary.

Rejected – DD254 is required

Attachment 1, Statement of Work

1.2, Classificat ion

Section 1.2 states that ‘the acquisition and all documents pertaining to it are unclassified.’ There is confusion to the level of classification that the response will require based on other items listed in the SOW.

Section 3.2 Cybersecurity Requirements [SOW- 06], requires clearance for OPSEC activities.

Furthermore [SOW-09] requires Sensitive but

Unclassified (SBU) capabilities to support anomalies. Finally, dRFP Att 3 (DD254) is provided at secret level in support of the draft RFP, specifically Tempest, IA, COMSEC and

OPSEC.

Modified – updated SOW for Clarity

Attachment 1, Statement of Work

1.3, Period of Performan ce

The Period of Performance stated in Section 1.3 needs clarification when viewed in conjunction with Section 2.1.

Section 2.1, USG Transponder(s) states: ‘The USG shall ownt the transponder(s) for the lifetime of the satellite on which they are carried.’ How does the USG plan to fund the use and operations of the USG Transponder, in the event the lifetime of the satellite exceeds the

Period of Performance

Rejected – Contract is for 15 years, we (the Government) will own the transponder for the life of the transponder/satellite. Guarantee of service will provide the government with the required bandwidth should the transponder fail prior to completing 15 years of use.

Attachment 1, Statement of Work

3.4.1.2.

EMI/RFI

Reporting

Requirements stated in [SOW-23] and [SOW-24] need to be restated (in bold and strikethrough): The Contractor shall provide initial acknowledgement of EMI/RFI event to the

Wideband Watch Office (WBWO) Watch Officer by telephone within 10 30 minutes and best effort geo-location of the interfering signal source, spectrum analyzer screenshots, and characterization in accordance with guidance (as described in the Pathfinder EMI/RFI Reporting Checklist) shall be provided within 30 60 minutes of contractor EMI/RFI detection or Government request if events are detected by the

Government. The contractor shall provide updates to the Government upon change in status, upon request, or every 2 hours from initial report until incident resolution. If secure email and/or voice communications are not available, the contractor (and subcontractors) shall use a mutually agreed upon media and voice communications capability capable of protecting sensitive but unclassified data.

The Contractor shall utilize commercial best efforts to comply with [SOW-23, SOW-24, SOW-27] after the Customer identifies an

EMI/RFI and the effect of the EMI/RFI creates an outage to service. In the avoidance of doubt, unused transponders at the time of the identified

EMI/RFI does not qualify as an outage.

Furthermore, failures due to space-asset hardware and where redundant capability on-board the same satellite is available, Contractor shall use commercial best efforts to restore the

USG capability and notify the USG thereafter. In the avoidance of doubt, the USG is not prioritized for restoration utilizing same satellite redundancy capability.

Rejected – These requirements come straight from the expected user. If there is a reason that this will drive cost or competition, request industry provide rationale for those drivers.

Attachment 1, Statement of Work

9-10 3.4.2, Transmiss ion Plans

Suggest [SOW-29] be delivered at PSR and not QPR.

[SOW-29] request is pre-mature, since [SOW- 39] requires the first QPR to be held 45 days following contract award.

Accepted – Updated SOW and CDRL A006 to deliver transmission plan NLT completion of

IOT.

Additionally, CDRL is updated to clarify what is required in the transmission plan.

See comment #39 and #40

Attachment 1, Statement of Work

11-

3.4.5, Reporting

QPRs shall be held at the Contractor or its subcontractor facilities. Furthermore, all QPRs shall be held concurrent with system design review, when practical.

Contractor believes it is reasonable for reviews to be held at the Contractor’s facilities.

Rejected – SOW 39 allows for teleconference or physical meetings. See #17

Attachment 1, Statement of Work

3.7, Deliverabl es

USG needs to re-evaluate its position with regards to the quantity, content and the approval of the requested CDRL’s in order to obtain commercial SATCOM capability cost effectively. Additionally, the USG needs to accept ALL

CDRLs in the Contractor’s format and schedule.

See items below for each CDRL and the reason for the requested change.

Addressed in each item below

11 Exhibit A CDRLs 16 A001, Suggest this language is removed in Block 16, 2c: ‘Update as required or by Procurement Contracting Officer (PCO) direction.’

Out of scope and will increase program cost.

Reject – PCO must retain authority to Direct an update. This is a quarterly report.

12 Exhibit A CDRLs 17 A002

Block 16, 2c: Reference is made to Information Assurance (IA) Certification, where, how and by whom does this event occur.

This is outside the scope of the CDRL.

Accept – Updating CDRL to remove IA certification from Block 16, 2c

13 Exhibit A CDRLs 17 A002

Suggest this language is removed in Block 16, 2d: ‘Update as required or by Procurement Contracting Officer (PCO) direction.’

Out of scope and will increase program cost.

Reject – See Item #11

14 Exhibit A, CDRLs 18 A003 Suggest the language in Block 16, 2b is removed.

Once the NSA-issued signed CNSSP-12 compliance letter should supersede this piece of the CDRL.

Reject – CDA is mechanism to pay contractor

15 Exhibit A, CDRLs 18 A003

Suggest this language is removed in Block 16, 3d: ‘Update as required or by Procurement Contracting Officer (PCO) direction.’

Once the letter is in Block 16, 2a is obtained, updating the CDRL by Procurement Contracting

Officer direction is unnecessary.

Reject – See Item #11

16 Exhibit A, CDRLs

21- 23 A005 Suggest deletion of USG Action Report Form. Request information is provided in Contractor format only Reject – This is required for the Government allocation of bandwidth to users.

17 Exhibit A, CDRLs 24 A006 Suggest that all QPRs shall be held at contractor or subcontractor facility.

Contractor believes it is reasonable for reviews to be held at the Contractor’s facilities.

Modified – Only the 1st meeting needs to be held at SMC. All subsequent QPRs can be held by telecon.

18 Exhibit A, CDRLs 24 A006

Suggest this language is removed in Block 16, 2c: ‘Update as required or by Procurement Contracting Officer (PCO) direction.’

Out of scope and will increase program cost.

Reject – See Item #11

19 Exhibit A, CDRLs 25 A007 Suggest changing the approval request time frame in Block

16, 2a.

By the time the “final submission” the design and performance is already established and implemented. Requesting Approval at this time is too late.

Reject – Acceptance is that contractor has performed this requirement to specification/requirement and this then authorizes a payment IAW the CIP Plan

20 Exhibit A, CDRLs 25 A007

Suggest this language is removed in Block 16, 3d: ‘Update as required or by Procurement Contracting Officer (PCO) direction.’

Out of scope and will increase program cost.

Reject– See Item #11

21 Exhibit A, CDRLs 26 A008 Suggest changing the time frame requested for the letters requested in Block 16, 1, 1-5.

The USG requests the Contractor to provide letters stating the successful completion of various stages of the acquisition, from which the USG has approval. If the Contractor provides the letter(s), what is left for the USG to approve. At these points the design, performance and implementation is already established and completed.

Reject – These letters are tied to specific milestones needed for payment to the contractor

22 Exhibit A, CDRLs 26 A008

Suggest this language is removed in Block 16, 2c: ‘Update as required or by Procurement Contracting Officer (PCO) direction.’

Out of scope and will increase program cost.

Reject– See Item #11

23 Exhibit A, CDRLs 27 A009 Suggest changing the delivery of the PMP in Block 16, 1e.

The PMP is delivered at QPR. Further updates or changes will be by exception. The USG requesting the document be subsequently submitted will increase program cost.

Reject – This follows the government review/acceptance

24 Exhibit A, CDRLs 27 A009

Suggest this language is removed in Block 16, 2c: ‘Update as required or by Procurement Contracting Officer (PCO) direction.’

Out of scope and will increase program cost.

Reject– See Item #11

25 Exhibit A, CDRLs 28 A010 Suggest changing the delivery of the SSPP in Block 16, 1f.

The SSPP is delivered at PDR. Further updates or changes will be by exception. The USG requesting the document be subsequently submitted will increase program cost.

Reject – Govt request for notification of updated documents is not unreasonable

26 Exhibit A, CDRLs 28 A010

Suggest this language is removed in Block 16, 2c: ‘Update as required or by Procurement Contracting Officer (PCO) direction.’

Out of scope and will increase program cost.

Reject– See Item #11

27 Exhibit A, CDRLs 29 A011 Suggest the language in Block 16, 1e be changed. The Mishap Cause Report to be provided by exception and only if necessary.

Reject – Frequency is “as required” so no change to block 1e. Contractor is not required to deliver unless a mishap occurs

28 Exhibit A, CDRLs 29 A011

Suggest this language is removed in Block 16, 2b: ‘Update as required or by Procurement Contracting Officer (PCO) direction.’

Out of scope and will increase program cost.

Reject– See Item #11

Attachment 1, Statement of Work

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Section 4, Aerospace

FFRDC

Enabling Requirem ent

Suggest changing the language in Section 4 to limit the oversight of consultants.

With all respect to Aerospace Corporation, Contractor will provide Customer and their consultants (i.e. Aerospace Corp) all necessary insight to the program with full transparency to the program activities without the oversight entities like Aerospace Corp. impose. As such, The Contractor acknowledges the role of Aerospace Corp. in support of this contract Rjhowever, the Contractor will not entertain

Aerospace Corp.’s participation in program/quarterly reviews, ad hoc meetings, TIMs, design reviews, etc. as other than observer.

Reject – SMC’s FFRDC support (Aerospace) is required for technical guidance

30 TRD 2 TRD-3 [redacted] believes the requirement for CONUS Transponders, Uplink & Downlink Encryption, and Burnout/Overdrive protection to all be on the same satellite and be launched within the desired timeframe, greatly restricts the range of competition and may result in having no compliant responders or only a single source option.

It is highly unlikely that any commercial satellites currently under construction for the CONUS market would coincidentally include the required encryption and burnout protection.

Design changes to satellites currently under production would be cost prohibitive and production start dates beyond 2018 would likely miss the 2021 launch requirement. This leaves a very short window of opportunity between now and 2018 for industry to develop and approve a compliant mission for CONUS.

The likelihood that a new, and previously unplanned mission could be inserted into a commercial operator’s long-term strategic and financial planning process in that timeframe is doubtful.

Given a roughly 3 year lead time from inception to launch, this means that a spacecraft uniquely designed to be compliant would have to be under contract with a manufacturer by end of 2018 to meet the 2021 launch requirement.

A possible alternative is to revert to earlier Pathfinder 2 concepts which allowed the transponders, encryption, and burnout protection to be on different satellites.

Modified -

Government will consider opening launch window 18 months following feedback with industry.

31 TRD 2 TRD-2 Expand downlink frequencies range from

11.7 GHz – 12.2 GHz to 10.7 GHz to 12.2 GHz

Extending the range will provide added flexibility.

Modified – Government considering expanding downlink frequency range

SOW 7 SOW-5 Use of NSA approved Cryptology Please use exact words from CNSSP-12 and DODI. There has been much discussion about what is and isn’t required. Since the DoD is not purchasing crosslinks, they shouldn’t be included.

Updated

The use of “bus and payload/transponder” is confusing as the customer encrypts data on the transponder, not the owner/operator of the commercial satellite.

Wording should be limited to -

(1) NSA Approved AES-256 encryption shall be used to: Encrypt all data transmitted over communications links accessible by unauthorized personnel. Data releasable to the public does not require encryption.

(2) NOT APPLICABLE - Provide pseudo random bit streams to ensure transmission security (TRANSEC) effects are not predictable by unauthorized personnel.

(3) Authenticate and encrypt all system commands transmitted over communications links accessible by unauthorized personnel

SOW 16 TRD-4 Significant modifications and reductions to the statements regarding Aerospace Corporation involvement in the program are necessary.

As described in the SOW, the involvement of Aerospace in the program is unscoped and overreaching. Further, statements in the SOW request release of a wide range of business and technical data which [redacted] does not release and we expect our manufacturing partners to reject. [redacted] spacecraft design and manufacturing processes are mature and highly successful. [redacted]’ processes for engaging with, and interacting with, our manufacturing partners are equally mature and successful. The level of access and engagement by Aerospace described in the SOW threatens to have a negative impact on these mature processes, force delays, and

Reject – See Item #29 drive up costs. The purpose of this type of Pathfinder solicitation is to find ways to for the USG to take advantage of commercial economies. The Aerospace Enabling Requirement language in the SOW will negate those economies.

[redacted] recognizes that the USG will require some level of insight and participation by Aerospace or similar USG representatives. This scope of this participation and its limits will have to be well defined.

SOW 5 SOW-02

SOW-03

SOW-04

SOW-06

SOW-07

[redacted] acknowledges the desire for enhanced cyber security and currently support Risk Managment Framework requirements via our submission of fully executed CIAQ questionnaires.

Flowing the cyber security requirement to the entire commercial satellite build as indicated could be onerous and is possibly not what was intended. It would be desirable to clarify this point in perhaps by stating that the commercial satellite prelaunch build information is not “Government

Data”).

Change to use of commercial best practices during manufacture and launch. Use of NIST RMF for operations in accordance with current DISA CIAQ identified controls.

Anything else could drastically raise the price or not be executable

Clarity and potential cost avoidance

Foreign manufacture can add complication.

Suggested clarity can mitigate.

Modified – Government may consider the identification of particular controls

Instructio ns to

Offerors

6 Table 2 The page limit for Technical Capabilities seems small.

Recommend increase to ~30 pages

Footprint images, EIRP and G/T contours, technical elements related to burnout protection and other necessary information will add up.

Adequate space to include this information is required.

Modified – Increasing page limit to 20 pages

SOW 3 2.1/3.4.3 What is the government plan for use of the transponders if the satellite vehicle remains fully operational beyond the 15-year lease? Will the transponders be returned to the satellite provider for use or continue to be a government asset? The SOW states 15 years in some places and “for the lifetime of the satellite” in others.

The Pathfinder #1 contract has ambiguous guidance on what could be done with the government purchased transponders when the satellite vehicles outlived the government's lease.

This is an opportunity to clarify.

Modified – Typically upon contract closeout, Government property is transferred, abandoned, destroyed, donated or sold to relieve the contractor of stewardship responsibility in accordance with Government Regulations and the FAR.

Government reviewing RFP documents to use consistent language with respect to 15 years and

“lifetime of satellite.” Contract is for 15 years of guaranteed bandwidth

SOW 7 3.4.1 Clarify if the bandwidth allocated to the RSSC-West will be managed as pooled Military Bandwidth or if it will be managed as commercial SATCOM augmentation to the DoD

Clarity. Pooled bandwidth managed by the RSSC-West inserts an additional layer of management and coordination for satellite accesses and problem resolution. The general process for managing pooled Miliary Bandwidth versus commercial SATCOM augmentation would be defined differently.

Accept: Government will clarify management of bandwidth

SOW 7 3.4.1 The SOW does not address bandwidth management. Clarify if the controlling authority will be SMC, DISA or the RSSC-

West. Will the users of the bandwidth coordinate through the RSSC-West to the satellite provider or directly to the satellite provider?

Recommend adding a section on bandwidth/transponder operational management.

[redacted] recognizes that this could change over the life of the satellite but a clear understanding of the bandwidth management environment will aid early integration.

Reject – We have identified the existence of a government entity which will manage the resource which the contractor will interface with for bandwidth allocation. Following contract award and prior to transponder availability, the government will provide the identity of this entity.

Multiple The sequence of requested reports/CDRLs seems out of sync with the typical launch, In- orbit testing, final positioning into the operational slot, and ongoing operation.

For example, CDRL page 24 requests transmission plan 5 days prior to QPR.

Transmission plans are associated with the normal process of assigning users specific frequencies, power levels, and bandwidth. They are not derived until the OSD.

Modified – updated CDRL to clarify what is available in the transmission plan at the QPR.

See Comment #8 and 40

Multiple Transmission plans are requested to be supplied prior to the start of service.

Transmission plans (sometimes referred to as line-ups) are typically associated with bringing up a specific terminal and reflect the results of a link budget calculation and interaction with the payload management center. This happens only after the satellite is placed into operation in its destination orbital slot.

We believe the author may be referring to the “Frequency Plan” for the purchased transponder(s). This plan would typically be available during the design and build stages of the mission.

Modified – government will consider and clarify

See Comment #8 and #39

SOW 10 3.4.4 Host Nation Agreements are not necessary for operation over the Continental United States. Suggest eliminating this section.

HNAs are unnecessary over CONUS. Teleport licensing would be the responsibility of the

Owner/Operator if the DOD was going to use that teleport. Otherwise, licensing of DoD teleports and terminals is the responsibility of the

USG.

Reject – There are scenarios where HNAs may be applicable. If it isn not applicable by what the offeror proposes, then they can disregard this section.

Instructio ns to Offerors

13 Subfactor

This section request offeror to describe methods for analysis and or testing to demonstrate overdrive protection.

Description of analysis is an acceptable approach. Implied or explicitly requested demonstration of overdrive protection will add significant cost to the program.

Clarity and potential cost driver. Must properly define so added costs can be included in FFP offer.

Reject – Response is open to contractor on how to accomplish this

CDRLS 25 of

This page seems to require test and evaluation of overdrive protection. This function will be demonstrated through analysis of design and production elements associated with it.

Potential test to destruction scenarios on QUAL articles will drive substantial cost increases.

Development of subsystem test hardware will drive significant cost into the program. Analysis and limited testing of components can be accomplished within reasonable costs.

Reject – government is not directing on how to accomplish demonstration of this capability, will be based on proposal/QPR.

COST 15 Instruction s to

Offerors

Given the requirements contained in the SOW and TRD which deviate from Commercial Best Practices and the fact the USG is requesting 72 MHz of capacity over a CONUS beam, the $20M limit shown in Table 3 is most likely not achievable.

Modified – Government will consider and may clarify

TRD 2 3 [TRD

02)

We encourage the separation and dedication of the transponder , but the term needs definition.

Transponders typically share equipment with other transponders, payload and bus elements.

The interpretation of this requirement can result in a high degree of variability in proposed cost. For example, can the stand alone transponder share the antenna subsystems?

Modified – Government will consider and may clarify

Exhibit A CDRLs

25 CDRL

A007 , Blk 16, 2.

(BLK8): b

The governments "approval shall be by Contractual Document Action (CDA)" and should be timely with respect to the pre-ship review. Recommend formal decision within 24 hours of the conclusion of the preship review.

The pre-ship review and subsequent activities are typically schedule sensitive. The host satellite and manufacturer will need to know that decisions regarding acceptability of the pre-ship review will be timely, or they will otherwise price the schedule risk accordingly.

Reject – This information is in the CIP, and is being released in an updated post to FBO

SOW 13 SOW-39 Reduce the requirement for QPRs after completion of IOT and transition to operations to quarterly reporting.

Formal meetings covering the breadth of QPRs for an operational transponder would be unnecessarily costly.

Reject – quarterly meetings are necessary to give the government insight into contractor progress