QAs 3rd Set of Clarification Questions.docx

3rd Round of Questions and Answers for the GEITA11 Solicitation No. FA8903-12-R-8000:

1. Question #10 in the recent Q&A indicates that ALL Team Members must submit labor rates, not just those performing 20% of the work. We have a concern that these rates will then be averaged equally in Attachment L-6 to create a Total evaluated price. If a team member is not anticipated to perform a significant portion of work, we are concerned that their rates will receive equal value in the Pricing Model. Since this is an LPTA procurement, what would prevent a firm from obtaining a teaming partner with extremely low labor rates, proposing to have them accomplish a very small portion of work, and receiving the benefit of lowering their TEP in a manner which would not be representative of future contract pricing? Similarly, this approach seems to unduly penalize specialized "niche" firms which may bring a certain specific capability to the team, but have higher labor rates as a result. These firms would only be utilized to fill select, specialized roles, but their higher rates would be averaged equally across the pricing model, thereby creating an artificially high Total Evaluated Price that is again not representative of future contract pricing. We feel both issues potentially create an unfair advantage/ disadvantage, as the government intends to eliminate firms solely on the basis of the TEP as a first Step (Question/Response #79, Initial Q&A).

Would the government consider either 1) utilizing only the Prime's rates for evaluation of TEP (since they must perform greater than 50% of the contract work) or 2) utilizing a weighted average in the Pricing Model, assigning a weight to Team Member labor rates based upon the estimated or proposed percentage of work to be performed by the specific Team Member? We feel that these methodologies offer a more representative indication of future contract costs.

Answer: The government’s intent is not to eliminate firms solely on the basis of the TEP as part of the first step as explained in the answer to question #79.

We considered these approaches during development of the pricing model and found them not viable for this procurement. There may be some advantages/disadvantages to individual offerors under this pricing model but it places all offerors on a common baseline. The GEITA11 Pricing Model approach in an LPTA, there is no trade-off for specialty labor that would be higher priced, higher quality than the minimally required labor stated in the RFP. It is the contractor’s business decision to determine what level of labor mix to propose in order to meet the minimum labor qualifications and technical requirements of the RFP and yet not price themselves out of the competition.

2. Section 5 - Cost/Price. Team Members may submit financial statements in sealed envelopes. If the team members submit their information in a sealed envelope, how do we add the data to the CD copy? The CD is supposed to be a complete copy of the hard copies. Do you just need a copy of the sealed envelope and a brief statement to see the hard copy?

Answer: The government requires hard copies and electronic (CD-ROMs) copies of the financial statement information. The proprietary financial information submitted by the prime on behalf of any team member may be submitted in a sealed envelope; however, the prime shall ensure that two electronic copies (CD-ROMs) are included in the sealed envelope/package or submitted separately. The e-copies (CD-ROMs) and hard copies of the financial statements shall be mailed to:

772 ESS has two (2) physical addresses. Please use one of the appropriate addresses below.

If using USPS Mail, use the following mailing address:

772d Enterprise Sourcing Squadron/PKS ATTN: Mr. Kim Walton 2261 Hughes Ave Ste 163 Lackland AFB TX 78236-9861

If using Couriers/Physical Address (Fed Ex, DHL, and UPS) use the following address:

772d Enterprise Sourcing Squadron/PKS ATTN: Mr. Kim Walton 3515 S. General McMullen, Bldg 171 San Antonio, TX 78226-2018

3. Whereas the Government’s answer to question set 2, number 9, states that in Volume III – Cost/Price, the “Prime and all team members must provide a narrative only IAW 5.4.4,” the response to question 19(h) says that Section L, 5.3.1 Estimating System, “applies to the prime and ALL team members,” and Table 2.2 lists 5.3, 5.5, and 5.6 as tabbed sections to be included in the proposal. We would like to ask for the Government’s preferred contents and organization for this volume so we can ensure our response is complete and easy to review.

Answer: Please follow the instruction of section-L paragraph 5.2 entitled “Volume Organization” to create the pricing volume of the proposal.

4. For the purposes of the GEITA acquisition is the FOA AFCESA considered a separate entity or just a client of the AFCEE?

Answer: Currently, AFCESA and AFCEE are separate FOAs supporting the Air Force Civil Engineer.

5. Reference question 91 from the initial Q&A responses. In more direct language, it appears the use of DCMA auditing of small businesses for financial responsibility may be a method to attempt to set an artificial “floor” on the NAICS code. Has the government established a dollar value for a minimally acceptable financial capacity for this acquisition? If so, what is it and how was it established?

Answer: The acquisition team has not set a specific minimum dollar standard for the financial capability risk assessment. The Defense Contract Management Agency (DCMA) will conduct the capability risk assessment based on their internal procedures and guidelines. The capability risk assessment has nothing to do with the NAICS size standard. The NAICS codes are used to classify and quantify economic activity for potential offerors. The Government will use the results of the financial capability risk assessment to determine the offeror’s financial responsibility prior to obtaining a contract award.

6. Reference question 87. Full disclosure of the financial model is most welcome, but it was not clear when the solicitation was released that the model contained in L-6 was in fact the full model. Based on evaluation of the cost model, a couple of concerns become evident. This model does not appear to have any sensitivity with regard to the nature of the work anticipated. I.E. We decide to use a specialty contractor for a particular element of the PWS with inherently higher than normal rates. The impact of this specialty contractor tends to increase our effective price potentially excluding us from the competitive range. We request the government restructure the cost model to allow for sensitivity with respect to the magnitude of the type of work that is anticipated?

Answer: Comment noted, however, in an LPTA, there is no trade-off for specialty labor that would be higher priced, higher quality than the minimally required labor stated in the RFP. It is the contractor’s business decision to determine what level of labor mix to propose in order to meet the minimum labor qualifications and technical requirements of the RFP and yet not price themselves out of the competition. The GEITA11 pricing model approach assures all contractors are on a level playing field in regards to price.

7. Use of a simple average also reduces the sensitivity of the model. A large team with a single outlier specialty contractor suffers less impact than a small team. Once again, we request the government change the model to add price sensitivity for the type and magnitude of the work anticipated?

Answer: Comment noted, however, in an LPTA, there is no trade-off for specialty labor that would be higher priced, higher quality than the minimally required labor stated in the RFP. It is the contractor’s business decision to determine what level of labor mix to propose in order to meet the minimum labor qualifications and technical requirements of the RFP and yet not price themselves out of the competition. The GEITA11 pricing model approach assures all contractors are on a level playing field in regards to price.

8. Regarding Q#131 original and Q#31 of the second round of questions. Use of the term “regardless of size in terms of supported Contracted Man year Equivalents (CMEs) or cost” appears to add a new criterion to section M 2.1.2(b). The cited paragraph does not stipulate to an overall level of effort equivalency, nor does the cost data requested in L-3 give insight as to the dollar value of the effort expended with respect to geographic dispersion. Please clarify the intent of this comment as it relates to the section M.

Answer: The response to question #131 in the initial set of Q&As, refers to Section M, page 4 of 7, paragraph 2.1.2(a). The response to questions #31 in the second round of Q&As, refers to the workforce management plan and is addressed in section M, paragraph 2.1.1 (a) through (d). There is no new requirement to section M, paragraph 2.1.2(b) in regards to level of effort equivalency or cost data.

9. “To clarify Question #13 on the March 27th Q&A for the GEITA11 Solicitation, our team respectfully requests that multiple task orders under IDIQ or BPA contracts be allowed to be grouped into a single work effort in Table L-1 and the Corporate Experience Narrative. Our team members have multiple (over 10) IDIQ contracts directly related to performing A&AS services. Our firms have performed a significant numbers of task orders on each of these IDIQ/BPA contracts (nearly 500 collectively). Selecting and describing 10 (or even 20-30) individual task orders does not allow us to show the depth and breadth of experience each of our firms have obtained during performance of all task orders under these IDIQs over the past three years. Also, many of these task orders are specific to one type of work or mission support area. However, permitting firms to write up/describe multiple (30+) task orders performed under an ID/IQ contract as a single major work effort would allow us to clearly and concisely demonstrate our total team corporate experience across the entire PWS tasks and Mission Areas. While we completely understand that the government does not want firms to write up basic IDIQ contracts, and wants to see the actual specific work that our team has performed, we feel that we should be allowed to combine multiple task orders issued under a BPA or IDIQ contract into one major work effort in Table L-1 and L-2, as well as the corporate narrative. Additionally, by allowing firms to combine multiple task orders, we feel that the corporate experience narrative can more clearly and succinctly demonstrate relevant corporate experience. Would the government reconsider allowing multiple task orders under an IDIQ or BPA contract to be written/presented as a single major work effort?”

Answer: It is not necessary for an offeror to show the entire depth or breadth of their experience as long as they meet the minimum corporate experience requirements. Since this acquisition is LPTA, no credit will be given for exceeding the minimum requirement. A major work effort used to populate the table in attachments L-1 and L-2a shall be consistent with the definition of a major work effort and include performance of at least one mission area and four mission support tasks as presented in L-2a. Task orders cannot be combined for the purposes of populating the table in Attachments L-1 and L-2a.

The description of corporate experience should describe the details of the major work efforts that cover the required minimum PWS mission areas and mission support tasks. For the purposes of writing the corporate experience narratives, offerors may combine individual major work efforts to summarize the team’s experience provided that a minimum of two major work efforts are from the prime, and one major work effort for each team member expected to perform 20% or more of the work are provided. Any remaining major work efforts may be distributed among the team, at the discretion of the offeror. Information presented in the corporate experience narrative must correlate/track to major work efforts present in L-1 and L-2a.

10. I wanted to clarify the requirement of how much work the prime has to do on the GEITA 11 solicitation # FA8903-12-R-8000. It was my understanding the prime and the small business tier 1 partners are required to do 50% of the awarded work. I have been trying to find this answer in the solicitation and have not been able to find the answer. Any help on this clarification would be greatly appreciated.

Answer: The joint venture, whether formal or informal, must be evidenced in writing between the business concerns explaining the relationship. The government may not presume that a small business prime and its small business first tier subcontractors have an informal joint venture arrangement. An informal joint venture is interpreted to include what is commonly called a "team" which is most frequently manifested in teams formed by a lead prime contractor with one or more first tier subcontractors. This is interpreted due to the 13CFR121.103(h) statement "SBA may also determine that the relationship between a prime contractor and its subcontractor is a joint venture, and that affiliation between the two exists, pursuant to paragraph (h)(4) of this section."

Therefore, the performance of work requirements (FAR 21.219-14, Limitations of Subcontracting) apply to the cooperative efforts of either a formal joint venture which is classified as a small business or a small business prime contractor and its first tier small business subcontractor, when each concern is small under the NAICS code assigned to the contract.

FAR Clause 52.219-14, Limitations on Subcontracting, states that at least 50% of the cost of the contract performance incurred for personnel shall be expended for employees of the concern. The small business prime contractor is responsible for performing this percentage.

13CFR121.103(h) states that a joint venture may or may not be in the form of a separate legal entity and must be in writing.

13CFR125.6(i) states that when an offeror is exempt from affiliation under 13CFR121.103(h)(3) and qualifies as a small business concern, the performance of work requirements set forth in this section apply to the cooperative effort of the joint venture, not its individual members.

13CFR121.103(h)(3) is where the exception to affiliation rules can be found. GEITA11 is valued at $950M and the size standard is $14M. IAW 13CFR121.103(h)(3)(i)(B)(1), two or more small business concerns may submit an offer as a small business without regard to affiliation as long as all are small under the NAICS code for the acquisition.

11. Reference RFP Section L, 5.4.2, and attachment L-6, Pricing Model, page 4/18.

Question: The Offeror is required in RFP Section L Section L, 5.4.2, to complete the pricing model worksheets (Attachment L-6) to calculate the Offeror’s total evaluated price. The spreadsheet as designed is for a prime and multiple teaming members. In the case of the Prime being an unpopulated Joint Venture (JV), consisting of two venturers, the spreadsheet is not useful as designed. Both members have equal standing in the JV. As designed, only one member of the JV will be able to submit indirect rates for ODC’s and Subcontracts (L-6, Pricing Model, page 4 of 18). Because we are unpopulated JV, each venturer will be providing direct labor using its own FFP fully burdened rates as well as its own indirect rates for ODCs and subcontracts. Will you redesign Attachment L-6 to allow for all JV members to provide their indirect rates for ODCs and subcontracts? If not, will you clarify in the instructions how an unpopulated JV is to prepare Attachment L-6 with respect to?

Answer: The pricing model will not be modified to allow for multiple indirect rates for other direct cost and subcontracts costs. For purposes of computing the subcontracts and other direct cost on atch-L-6, the pricing model, only the prime’s (JV) indirect rate(s) will be used. In the event the unpopulated JV does not have its own indirect rate(s), the JV must use an average indirect rate comprised of the two JV member’s rates to compute the other direct cost and subcontracts costs in the pricing model.

In accordance with section-L, paragraph 5.5, the prime (JV) is required to have an approved accounting system to perform on CPFF type contracts. The JV must decide which venturer’s accounting system will be utilized and approved to perform as the prime.

12. Reference RFP Section L, 5.4.1., Rate Tables.

Comment: The instructions in 5.4.1 require Offerors to add their profit rates into the fully burdened rates for attachments L-4 and L-5 Rate Tables. To require Offerors to propose fully burdened labor rates inclusive of profit results in Offerors having to assess the technical, management, schedule and other resources necessary at a GEITA11 program level as opposed to a project or task order level. The level of profit should be based on an Offeror’s specific technical and management approach at the task order level. This is based on project variances such as periods of performance, mix of professional versus non-professional labor required, regulatory influences driven by different project locations, level of subcontract participation and complexity of the work to be performed. For these reasons, we request profit be excluded from the fully burdened hourly rates and instead to be negotiated at the task order level.

Answer: Comment is noted; however, IAW Section-M, paragraph 2.2(c)(1)(i), the fully burdened labor rates to be submitted are considered maximum rates that can be used on any task order/modification. Contractors can therefore propose a lesser rate(s) at any time at the task order level to be competitive. Consequently, profit shall be included in the fully burdened labor rates.

13. Your responses to Question # 49 (posted 15 Mar 2012) and Question #2 (posted 27 Mar 2012) are unclear. The dual answers provided in #49 are mutually exclusive. Your response in Question #2, “…All 11 mission areas (a technical service was deleted) and all 17 PWS Support Tasks listed on L-2a will be used to evaluate the information submitted on the L-2a table for corporate experience” further convolutes the issue.

Some Mission Areas may require written descriptions of non-asterisked PWS Support Tasks to demonstrate support to the Mission Area. For example, there are three Mission Areas on the Sample CE Matrix Table L-2b of the PWS, which have no projects in any of the seven asterisked PWS Support Task columns. Thus, to demonstrate support to the Mission Area, a company must write about the non-asterisked PWS Support Tasks on Table L-2.

a. Are you saying that offerors are not to submit narratives (detailed descriptions) that include discussion of the 11 non-asterisked PWS Mission Support Tasks?

Answer: For purposes of evaluation under corporate experience, the narratives must support the work that was performed on the 11 mission areas and the seven mission support tasks denoted with an asterisk. If a major work effort is used to populate attachment L-2a and it does not include any of the seven asterisked mission support tasks, then the narrative should include the details of the specific mission area and the associated non-asterisked mission support tasks.

b. Are you saying that if offerors submit narratives (detailed descriptions) for the 11 non-asterisked PWS Mission Support Tasks to demonstrate support of the Mission Area, they will not be evaluated as part of the Corporate Experience subfactor?

Answer: Detailed descriptions of the teams experience in supporting the 11 non-asterisked PWS mission support tasks will not be evaluated as part of the corporate experience subfactor for those major work effort that include an asterisked mission support task. If a major work effort is used to populate attachment L-2a and it does not include any of the seven asterisked mission support tasks, then the narrative should include the details of the specific mission area and the associated non-asterisked mission support tasks.

c. If the answer to either question above is “yes”, please clarify how/if offerers should substantiate the information being claimed in the non-asterisked columns of L-2a table.

Answer: Attachment L-1 will be used to populate contractor codes in attachment L-2a. For non-asterisked mission support tasks, additional substantiation is not required beyond what is provided in attachment L-1 and L-2a.

d. May offerers include projects not included in the L-2a table to focus on the asterisked support tasks?

Answer: No, work efforts used for the detailed description must be included on attachment L-1 and L-2a in order to determine if they meet the definition of "major work effort".

14. XXXX has reviewed the recent set of Q&A's posted on the FBO website – and we have some serious concerns that the new answers have now further complicated and confused the requirements for a compliant proposal submission. I offer as evidence the following information:

CONCERNING FINANCIAL DOCUMENTS SUBMISSION BY PRIME AND 20% PARTNERS INITIAL GUIDANCE

Section L, 5.6 Financial Documents (a). The Offeror shall provide the last three (3) years of financial statements, and year-to-date financial information through the last quarter available. If audited, reviewed, compiled or certified financial statements are available, these shall be submitted.

(b). The above information shall be provided for the Prime and Team Members performing 20% or more of the proposed contract effort. If the Prime is a combination of firms (for example, a partnership or joint venture), discuss the financial responsibilities among the companies. Historical and year-to-date financial data shall be submitted for each company that makes up the Prime, and the ability to fund contract performance shall be addressed for the combined firm. For Team Members performing 20 percent or more of the proposed contract effort, the financial statements may be submitted in sealed envelopes. The Prime and Team Members financial documents referenced in paragraph (a) above shall be submitted immediately upon receipt of the solicitation but no later than 15 days after the release date of the solicitation.

2.3.10.3 Electronic Copies (E-Copies)

(d.) Total e-copy requirements will include four (4) CD-ROMS; three (3) CDs for the master volume copy in searchable text format and one copy of the Fully Burdened Labor rates in Microsoft Excel format.

****XXXXX complied with the initial RFP by providing our documents in sealed envelopes from XXXXX and ALL of our 20% partners. NO MENTION in 2.3.10.3 of "Financial Documents" as part of a CD submission.***

GUIDANCE FROM Q&As 03-15-2012, In response to Question 71:

Q71. For the Company Financial Statements requested in Section L, 5.6(b), where would the government like the Financial Statements sent? Are hard copy or electronic versions of the forms preferred?

A71. Hard copies and electronic documents are required to be submitted. Electronic copies shall be submitted to the GEITA11 email address at afcee.geita11@us.af.mil <mailto:afcee.geita11@us.af.mil>. The hard copies of the financial statements will be mailed to:….….

****Based on this, XXXXXX had our team submit the financial statements ELECTRONICALLY to the email address given. NO change in CD submission requirements.****

GUIDANCE FROM Q&As 2nd Set of Questions, 27 Mar 2012, In response to Question 16:

Q16. We have already sent Financial Statements for prime and team members, who will perform 20% or more of the proposed contract effort, in sealed packages to the address in the SF33 by the deadline stipulated in the solicitation. Does this satisfy instructions/evaluation for Sec L 5.6(a)/(b)?

A16. …..Additionally, the electronic copies (CD-ROMs) of all financial statement documentation must be mailed to:

The proprietary financial information submitted by the prime on behalf of any team member may be submitted in a sealed envelope; however, the prime shall ensure that two electronic copies (CD-ROMs) are included in the sealed envelope/package.

****THIS IS THE FIRST MENTION OF THIS REQUIREMENT FOR CD-ROMs OF ALL FINANCIAL STATEMENT DOCUMENTATION.****

Answer: The financial statement documentation is part of the cost/price volume III as per section-L, table 2.2. Cost/price volume III information to include the financial documentation is required per Section-L, paragraphs 2.3.10.3(a) and (b) which require that all proposal volumes be submitted on CD-ROM(s).

To clarify, the electronic copies (via email) of the L-9 form entitled “Financial Capability Risk Assessment Pre-Review Form” shall be sent to the GEITA11 email address at afcee.geita11@us.af.mil. Additionally, the electronic copies (CD-ROMs) and hard copies of the financial statement documentation must be mailed to:

If using USPS Mail, use the following mailing address:

772d Enterprise Sourcing Squadron/PKS ATTN: Mr. Kim Walton 2261 Hughes Ave Ste 163 Lackland AFB TX 78236-9861

If using Couriers/Physical Address (Fed Ex, DHL, and UPS) use the following address:

772d Enterprise Sourcing Squadron/PKS ATTN: Mr. Kim Walton 3515 S. General McMullen, Bldg 171 San Antonio, TX 78226-2018

The proprietary financial information submitted by the prime on behalf of any team member may be submitted in a sealed envelope; however, the prime shall ensure that two electronic copies (CD-ROMs) are included in the sealed envelope/package or submitted separately.

15. CONCERNING COST PROPOSAL NARRATIVE. GUIDANCE FROM Q&As 2nd Set of Questions, 27 Mar 2012:

Question 9: With regard to the cost proposal narrative are only team members required to provide narrative for all areas of section 5 (5.1.1 through 5.4.6)? Answer: No, Prime and all team members must provide a narrative only IAW 5.4.4.

Provide narrative only for area 5.4.4 under which the Team members would support with narrative the basis of estimate for all direct and indirect factors to include profit? Answer: Yes.

Question 19: Does Section L, 5.3.1 Estimating System apply to “All Team Members” or “Prime and Team Members who will perform 20% or more of the proposed contract effort”? Answer: It applies to the prime and ALL team members.

Does Section L, 5.4.3 apply to “All Team Members” or “Prime and Team Members who will perform 20% or more of the proposed contract effort”? Answer: It applies to the prime and ALL team members.

Does Section L, 5.4.4 apply to “All Team Members” or “Prime and Team Members who will perform 20% or more of the proposed contract effort” Answer: It applies to the prime and ALL team members.

Does Section L, 5.4.5 apply to “All Team Members” or “Prime and Team Members who will perform 20% or more of the proposed contract effort”? Answer: It applies to the prime and ALL team members.

***** These answers seem contradictory. Question 9 indicates proposal narrative for 5.4.4, and Question 19 indicates proposal narrative for the other cited sections. Which is correct? ****

Answer: the answers to questions #9 and #19 of the 2nd set of Q&As are not contradictory. They are both correct. The following items for each paragraph are required:

5.3.1 (Estimating system) – Provide a summary description of the estimating system for the prime and all team members.

5.4.3 (Application base for Fully burdened FFP labor Rates) - Indicate the application base for indirect rates and/or factors. This applies to the prime and all team members.

5.4.4 (Basis of the Proposed Rates and Factors) - Describe and provide the basis of estimate for the proposed direct and indirect rates and factors and provide narrative support for all elements. This includes all direct and indirect factors to include profit for the prime and all teaming members.

5.4.5 (Treatment of Other than Labor Cost) - Describe the treatment of all non-labor cost (subcontracts, materials, ODC, etc.) with respect to applicable burdens and profit. This applies to prime and all team members.

BOTTOM LINE: The answers to these two different sections have been answered differently in different Q&A documents, and sometimes within the same Q&A document. Could you please clarify the exact answers for these two items?

Answer: See above answer for Q&A# 15.

My suggestion:

1. Financial Statements: hard copies in sealed envelopes OR email submissions ok. CD-ROMs not required.

2. Cost proposal narrative – At a minimum, the offeror and teammates must submit narrative that supports their rate build-ups. Some paragraphs may be responded to by the subcontractors as "Determined by the Prime" and then the Prime should include narrative in their Cost Volume. Other paragraphs MAY say N/A. It's up to the subcontractor to justify their build-ups per normal government requirements.

3. Subcontractors should provide a Master Copy CD-ROM of the Cost Volume only (with information and narrative on rate build-ups per government requirements) in PDF format, AND a GEITA11 Labor Rate CD-ROM with the subcontractor's L-4 and L-5 AND, if they desire, their labor rate build-up spreadsheet (if they have one). These should be submitted in sealed envelopes along with the Prime's bid.

Answer: Suggestions were noted but not incorporated.

16. The worksheets in GEITA11_Section_L-4_and_L-5_(Fully_Burdened_FFP_Labor_Rates) have a column for Contractor Labor Category. Since the categories provided in the solicitation are so general, each category could include numerous internal categories for each teaming member.

a. Would the government consider deleting that column?

Answer: No

b. If that column is not deleted, would it be acceptable to group a company’s internal categories into a general category without having to provide the complete list of internal company categories that are included?

Answer: It would be acceptable to group a company’s internal categories into a general category, however we would require you provide a complete list of internal company categories that make up the general categories. Please provide that with your Section L, paragraph 5.4.4, Narrative.

17. If a team member does not submit pricing for a certain labor category in the base proposal, could they later submit a task order proposal including this labor category?

Answer: No

a. If the team member can bid the labor category at the task order level, will the base contract be modified to incorporate the new labor category and rate or will the labor rate apply to the individual task order only?

Answer: No, the base contract will not be modified. The labor rate would apply to the individual task order only.

18. I wanted to get clarification if possible. It might be too late but it doesn’t hurt to ask. If we leave a page blank and use the statement “this page intentional left blank” would this count as a page because of the writing on the page or should we leave the page completely blank and not include this blank statement so it does not count as a page.

Answer: In accordance with section-L, paragraph 2.3.11.3(b) and (c). Each side of each sheet that displays printed material shall be counted as 1 page for page limitation purposes. Therefore, if you do not want the page to count towards the page limitation, leave it blank.