DVT SIR Industry comments and FAA responses Update 16.pdf

DVT Sustainment Program DRAFT Screening Information Request (SIR) 693KA8-23-R00001

Industry Comments and FAA responses on draft SIR released on May 12, 2023

Industry comments and FAA responses on draft DVT SIR released on May 12, 2023:

1. Would the Government please provide order quantity and time frame to allow for more accurate pricing? This would reduce cost to the Government and program risk, particularly given the nature of a twenty-year commitment. Identifying a minimum amount of systems to be supplied per year will significantly reduce the risk and cost for the program.

FAA response: FAA will determine the quantity and timing of the production units based on operational priorities and funding availability.

2. Without performance specifications update, particularly with a fundamental requirement like the design assurance level, it is difficult to gauge the completeness or appropriateness of many elements. This particularly applies to Task Orders 001 and 002 in their entirety and the pricing models. Please provide the updated performance specifications prior to release of the final SIR.

FAA response: FAA will release the final, approved Performance Specifications with the final DVT

SIR.

3. Sections L and M should be part of the draft documents for vendors to provide valuable input to the government. A supplemental draft should be issued including these and the updated equipment specifications.

FAA response: Sections L&M, and the final Performance Specifications will be released with the final DVT SIR.

4. “The following documents apply. Unless otherwise stated in a TO, the latest version of these documents must apply.” Suggest these should be “applicable to the extent specified herein”.

Version shall be current version at time of contract award.

FAA response: FAA will consider the change.

5. “The Contractor’s QA processes must be subject to audit by the FAA and the applicable certifying authority.” Does the FAA anticipate requiring a third-party certification authority for AS9100D?

FAA response: Respondents are expected to be AS9100D certified. FAA does not anticipate a separate, third-party audit to verify that the respondent’s QMS is compliant with AS9100D.

6. “f. Participate in FAA inspection of the system’s quality at the Contractor’s facility before or during the shipment of any system from the Contractor or other facilities.” Recommend this be “Participate in FAA inspection of the system’s quality at the Contractor’s facility before acceptance by the FAA.”

FAA response: FAA will consider the suggested revision in the final DVT SIR.

7. The second paragraph has language for ECPs and SCNs intertwined. Recommend separating them out and clarifying for which instance each applies. The assumption is made that SCNs are applicable to the FAA equipment specs – is that correct? Suggest the FAA clarify how to handle Major and Minor changes, such as:

a. a major change requiring CO approval

b. a minor change (such as obsolete parts replacement activity) needing QRO concurrence only.

c. Will the FAA allow the Contractor to make changes that are forward and backward compatible at the LRU level without approval?

This section potentially should be reduced in content to avoid conflict with TO 002 and should point to the details in TO 002.

FAA response: FAA will consider the suggested revision in the final DVT SIR.

8. RTCA/DO-278A and RTCA/DO-254 CM requirements are contained in this section. Suggest that these be removed from here as it is addressed in TO 002.

FAA response: Rejected. The verbiage in Section C and Task Order 002 is not the same, but they are consistent with one another.

9. “e. Submit Request for Deviation or Waiver” Suggest to be consistent with ANSI/EIA-649C this should be “Submit Request for Variance”

FAA response: FAA will consider the suggested revision in the final DVT SIR.

10. “f. Develop and maintain a Configuration Status Accounting (CSA) information system to report the status of each CI/Protocol Control Information.” Suggest this point to TO 002 for specifics.

FAA response: FAA will consider the suggested revision in the final DVT SIR.

11. “g. Prepare and submit a Configuration Audit Plan and Configuration Audit Summary Report documenting all audit findings for each system.” In order to deconflict SOW and TO 002, recommend reducing content in SOW and point to the detail contained in TO 002.

FAA response: FAA will consider the suggested revision in the final DVT SIR.

12. “The Contractor must ensure that each system complies with HF-STD-001B, Human Factors Design Standard (HFDS), and HF-STD-004A, Standard Practice—Human Factors Engineering Requirements...” Recommend these be limited to the extent specified in the individual equipment specifications.

FAA response: Concur.

13. ARP4754A and ARP4761 are mentioned in this section. In order to deconflict SOW and TO 002, recommend reducing content in SOW and point to the detail contained in TO 002.

FAA response: FAA will consider the suggested revision in the final DVT SIR.

14. “The provision of navigation range service has been assigned Functional Development Assurance– Level (FDAL) A. The provision of navigation azimuth service has been assigned FDAL A.” These FDALs are inconsistent with previously identified requirements. They are specified at a level higher than has been traditionally associated with these systems that are now backup to the primary means of navigation systems. They are specified at a level higher than the primary means of navigation.

FAA response: The FDAL requirement is still under discussion within the FAA.

15. “The provision of navigation range service has been assigned Functional Development Assurance– Level (FDAL) A. The provision of navigation azimuth service has been assigned FDAL A.” These are specifications and should not be in the SOW. It is more appropriate to specify FDAL in the individual equipment specifications.

FAA response: Rejected. The FAA template for Performance Specifications does not require Development Assurance requirements.

16. “The Contractor must comply with the applicable objectives of SAE ARP 4754A, RTCA DO-254, and RTCA DO-278A". In order to deconflict SOW and TO 002, recommend reducing content in SOW and point to the detail contained in TO 002.

FAA response: FAA will consider the suggested revision in the final DVT SIR.

17. In general, the SOW has more content than TO 002. In order to deconflict SOW and TO 002, recommend reducing content in SOW and point to the detail contained in TO 002.

FAA response: FAA will consider the suggested revision in the final DVT SIR.

18. “DVT Systems’ design and installation must comply with FAA Order JO 1050.17A, Environmental Compliance at Air Traffic Organization Facilities, and all relevant Federal, state, and local regulations about protecting the environment, including but not limited to those governing air emissions limits on equipment.” In order to deconflict SOW and TO 002, recommend reducing content in SOW and point to the detail contained in TO 002.

FAA response: FAA will consider the suggested revision in the final DVT SIR.

19. “If the Contractor uses a hazardous or restricted material, (for example, leaded solder), an assessment of the hazard potential of a substance and its decomposition products must be submitted for approval prior to material selection.” Suggest this has a significant impact on product and development cost. What is the approval process? Is the FAA stating to not use leaded solder? Is the FAA stating the product needs to be RoHS compliant?

FAA response: FAA is not restricting the use of leaded solder. The FAA requires the vendor to provide an assessment of the hazard potential. RoHS is a European Union directive that isn’t recognized by Fed OSHA or FAA EOSH standards. Therefore, the DVT Program doesn’t need to be RoHS compliant, just mindful when selecting components with hazardous substances (substitution when possible).

20. In order to deconflict SOW and TO 002, recommend reducing content in SOW and point to the detail contained in TO 002. “k. Develop and maintain a Microsoft Access database for reporting, tracking, and maintaining all records on PTRs;” Suggest deleting “Microsoft Access” from the requirement as there are excellent defect tracking tools available that are not specifically MS Access.

FAA response: FAA will consider the suggested revision in the final DVT SIR.

21. “u. Perform site surveys and completion of a site survey report for each installation site prior to the start of testing;” Please specify the scope of site surveys. Does it include system performance prediction using a specified modeling tool? Is the geographic data provided by the FAA to make an effective analysis? Does the site survey include any remediation of existing conditions? Are these retrofit of existing shelters/sites or are they of new construction? While this is an activity we perform for customers other than the FAA, typically the FAA separately arranges for this. Suggest deleting subparagraph u.

FAA response: The scope of site surveys will be included in Section J-4 (CDRLs/DIDs) in the final

DVT SIR.

22. “w. Verify system integration requirements by integrating the DVT Systems with existing equipment in the NAS; and” Are the systems to integrate with and system integration requirements included in the individual equipment specifications? For example, is there a remote monitoring interface specified?

FAA response: All integrating systems are included in the DVT Systems Performance Specifications:

• FAA-E-37016, Performance Specification, Distance Measuring Equipment (DME) Transponder System

• FAA-E-37012, Performance Specification, Very High Frequency (Vhf) Omnidirectional Radio Range (VOR) System – Conventional (CVOR) and Doppler (DVOR)

• FAA-E-7870, Performance Specification, Tactical Air Navigation (TACAN) Ground Transponder System

• FAA-E-7869, December 10, 2021, Performance Specification, Tactical Air Navigation (TACAN) Antenna System

23. “x. Collaborate with the FAA, perform end-to-end testing, including pre-commissioning flight tests, to ensure that the as-installed system meets performance requirements.” Suggest specifying who provides the flight inspection aircraft and flight time. Contractor is to support the flight test activity.

FAA response: FAA will provide the flight inspection aircraft and flight time. FAA will clarify in the final DVT SIR.

24. “Type Test procedures are a subset of the Qualification Test procedures determined by the Quality Reliability Officer (QRO).” Typically, the QRO selects which item of a Type Test lot to test. Type test procedures should align with the Verification Requirements Traceability Matrix (VRTM).

FAA response: Concur.

25. In order to deconflict SOW and TO 002, recommend reducing content in SOW and point to the detail contained in TO 002.

FAA response: FAA will consider revisions to Section C and the task orders in the final DVT SIR.

26. This section is redundant with TO 002. In order to deconflict SOW and TO 002, recommend reducing content in SOW and point to the detail contained in TO 002.

FAA response: FAA will consider the change in the final DVT SIR.

27. Suggest deleting reference to “Office of Management and Budget Circular A-11" as that does not appear to have relevance to the topic. In order to deconflict SOW and TO 002, recommend reducing content in SOW and point to the detail contained in TO 002.

FAA response: Rejected. The A-11 (2022) references the NTIA certification requirement.

28. Questions:

• Please specify if the equipment is going into an existing shelter.

• If equipment is going into an existing shelter, please specify who is responsible for determining the suitability of that shelter for the new equipment. Also, please specify who is responsible for the remediation of any unacceptable conditions of an existing shelter.

• Please specify if monitoring antenna towers are to be reused or if new are required.

FAA response:

• This will be site dependent. Typically, the installation will be in an existing shelter.

• The vendor will be responsible to deliver a site survey to the FAA, and the FAA is responsible to determine suitability.

• This will be site dependent. Typically, the monitoring antennas towers will be reused. If new towers are required, the FAA will provide them.

29. “h. Document any erratic performance or failures of the system(s) to be replaced and provide that documentation to the FAA prior to commencing the implementation process;” Please specify if this includes flight inspection and who is responsible for that.

FAA response: This item does not include flight inspection. This item refers to the legacy DVT Systems at the site and any potential erratic performance or failure must be documented by the vendor prior to commencement of the installation of the new system(s). The FAA will clarify the language in the final DVT SIR.

30. “j. Install and replace all cables and wiring connectors and provide lightning, bonding, grounding, and shielding protection as required”. Suggest this be broken into two separate requirements. 1) Replace all cables, conduit (?), wiring, and connectors from a demarcation point (for example, the AC power panel). 2) Provide lightning, bonding, grounding, and shielding per FAA-STD-019.

FAA response: Concur. FAA will update in the final DVT SIR.

31. Suggest removing this paragraph from the SOW and including it in the TACAN beacon performance specification. It would be appropriate to include the TACAN Monitor Antenna in the list of equipment to be provided under the contract in section 3 or a new subparagraph under section 3. Suggest that would include VOR monitor antennas as well.

FAA response: Partially agree. TACAN Monitor Antenna can be Commercial Off-the-Shelf (COTS), and this cannot be specified in the Performance Specification. The VOR Monitor Antenna is very specific and designed to FAA specifications.

32. Suggest an introductory paragraph that describes in general terms what the expectations of the program are. (Supply, test, install, and support DMEs, CVORs, DVORs, and TACANs as per requirements specified in FAA-E-37012, Performance Specification Very High Frequency (VHF) Omnidirectional Radio Range (VOR) System – Conventional (CVOR) and Doppler Equipment; FAA- E-37016, Performance Specification Distance Measuring Equipment (DME) Transponder System;

FAA-E-7870, Performance Specification Tactical Air Navigation (TACAN) Ground Transponder System.) Then add a new subparagraph under C.3 that identifies the equipment probably separating out the First Article equipment defined in TO 002 from follow-on production. (The equipment delivered includes all power cabling and connectors, rf cabling and connectors, electronics transmitter/transponder/beacon, antennas, and monitoring antennas as identified in the respective performance specifications. Suggest 3.1 for DMEs, 3.2 for CVORs, 3.3 for DVORs, and 3.4 for TACANs. Add further subparagraphs under each to state what items are expected for each (whether antenna is included or not, whether monitor antenna(s) is (are) included or not, what items may be site-specific, etc.))

FAA response: Concur. FAA will update in the final DVT SIR.

33. “n. Deliver TPS for the DVT Systems’ repair support for each Printed Circuit Board or module that is to be tested with Automated Test Equipment or Functional Test Equipment;” Please specify completely what is desired for a TPS. Note: need to reword the statement if the intent is to have ATE or FTE for all PCBs. (Current wording allows for an exception that is not believed to be desired.)

FAA response: The details will be contained in the logistics CDRLs corresponding to Section C.3.16 and in Section J-4 (CDRLs) in the final DVT SIR.

34. “z. Develop and deliver a TDP IAW MIL-STD-31000, as tailored by the TO(s)/DO(s);” Significant intellectual property rights are contained in the TDP. Suggest providing for escrow of the same rather than delivery only.

FAA response: Refer to Section H.26 Assertion of Data Rights.

35. “bb. Establish a Diminishing Manufacturing Sources and Material Shortages (DMSMS) Program to manage life cycle part obsolescence; cc. Provide detailed DMSMS Health Assessment Reports; dd.

Conduct Parts Obsolescence Management TIMs; These are all a duplication of paragraph 3.5.1.

Suggest narrowing the scope to one or the other.

FAA response: FAA will review Sections 3.5.1 and 3.16 for consistency and will update in the final

DVT SIR.

36. Prospective Vendor is requesting a 1-1 meeting with the FAA to discuss our questions and better understand the FAA’s acquisition strategy for DVT.

FAA response: FAA will schedule a one-on-one meetings with any vendor that responded to the May 2023 draft SIR with questions or comments before June 29, 2023.

37. Would the Government include in its Obsolescence Management approach a commitment to funding of mitigation efforts and approach to requalification?

FAA response: The FAA cannot guarantee a specific funding level. However, the FAA intends to consider obsolescence and technical refresh activities across all phases of the program.

38. Please provide DIDs and further clarification in the SOW and TOs to have consistent bases of estimates and avoid risks of cost growth on T&M and CPFF CLINS.

FAA response: Section J-4 will be provided in the final DVT SIR.

39. Request we see draft Task Orders and Delivery Orders for the rest of the program prior to final SIR release.

FAA response: FAA has selected an IDIQ contract to provide flexibility for activities later in the program.

40. We concur that all labor categories in Table 3 may be involved in the DVT program, however, we suggest reduction of key personnel in Table 3 to Program Manager. (agree that the PM is key to the program, but suggest that the others do not need to meet the stringent requirements of key personnel.)

FAA response: FAA is considering reducing the number of key personnel.

41. References to Section H.11 should be Section H.9.

FAA response: FAA will check for consistency and update in the final DVT SIR.

42. We concur that all labor categories in Table 6 may be involved in the DVT program, however, we suggest reduction of key personnel in Table 6 to Systems Engineer (Test Manager), Safety Specialist (Engineering), Engineer Subject Matter Expert (SAE ARP4754A, RTCA DO-278A, RTCA DO-254). (These disciplines are critical to be identified to the Program, however, we suggest that they do not need to meet the stringent requirements of key personnel.)

FAA response: FAA is considering reducing the number of key personnel.

43. We concur with the contract types for the TO 001 and TO 002 as T&M and CPFF respectively. We suggest the following contract types in relation to the future TOs and DOs:

• Production: FFP with an allowance for adjustment in material cost due to inflation in the electronics industry over the long duration of the DVT contract.

• Installation: T&M – due to the widely varying condition of each site.

• ICDLS: T&M or FFP depending on how the ICDLS is scoped.

• Training: FFP – This can be completely scoped with standard FAA practices.

• Obsolescence Management: T&M – due to turnover of available electronic components for a program of this duration.

FAA response: FAA will consider the comments in the drafts of future task orders.

44. The equipment for the DVT (i.e., DME, VOR and TACAN) is very standard from functional and operational perspectives. The approach defined in the SOW and the Engineering, Design and Development TO seems more appropriate for a development program (including a full engineering development process with SRR, SDR, PDR and CDR) than for the procurement and delivery of standard (COTS) systems. Such approach will drive cost with a likely small benefit for the FAA.

Suggest that an intermediate approach, where such process is followed for specific parts of the systems (e.g., monitoring) may be applied, which would significantly simplify the program, reducing its cost and accelerating its delivery.

FAA response: DVT is not intended to be a COTS acquisition. The FAA will conduct technical reviews as indicated in Section C to ensure the FAA’s requirements in the new performance specifications, are satisfied:

• FAA-E-37016, Performance Specification, Distance Measuring Equipment (DME) Transponder System

• FAA-E-37012, Performance Specification, Very High Frequency (Vhf) Omnidirectional Radio Range (VOR) System – Conventional (CVOR) and Doppler (DVOR)

• FAA-E-7870, Performance Specification, Tactical Air Navigation (TACAN) Ground Transponder System

45. General Comment – The DRAFT SIR is incomplete. Sections L & M and a complete list of CDRL’s (Appendix J-X) are missing. Also, Section C is in outline form. These documents are very important to evaluate the effort required to prepare the proposal, define bid strategy, and determine teaming arrangements. Prospective Vendor has provided some comments on what has been released, and has offered recommendations / suggestions on approaches for FAA to consider regarding some of the missing sections. Please see our attached white paper entitled “Acquisition Evaluation Criteria Considerations”.

FAA response: Sections L&M will be released with the final SIR. Section C is in the standard format for an SOW. FAA is considering the input for the evaluation criteria in the development of Sections L&M and must ensure the input aligns to FAA policy and guidance.

46. General Comment – Prospective Vendor respectfully requests that FAA release a “Final Draft” SIR at least 60 days prior to the release of the FINAL DVT SIR, for final comment. The near Final Draft should include all Sections and Appendices anticipated in the FINAL DVT SIR. Prospective Vendor believes this will result in fewer questions during the RFP, fewer requests for extensions, and higher quality proposals for FAA.

FAA response: FAA will consider the suggestion.

47. Section C (Statement of Work) covers the full life-cycle of the DVT program. However, it appears that the scope of the acquisition is limited to the Engineering Design and Development phase – effectively constrained by Task Order 002. This is a serious deficiency given the importance that production, logistics, training, installation, maintenance and total lifecycle support costs will have on the FAA’s operational budget associated with the DVT systems for several decades to come. To ensure the FAA selects the best value proposal, the FAA must evaluate the entire scope of the DVT Sustainment Program as part of the final SIR.

FAA response: The contract is an IDIQ. Additional task orders will be considered for logistics, training, and production (post-development and testing) based on operational needs and funding availability.

48. The draft SIR includes AMS clause 3.2.2.8-8, which indicates that if the Contractor fails to deliver the supplies or perform the services within the time specified in the contract, the Contractor must, in place of actual damages, pay the Government liquidated damages of $______________ per calendar day of delay (Contracting Officer insert amount). This is HIGHLY unusual in an FAA development program, where there is substantial schedule risk associated with development activities. This clause is not conducive to fostering a long-term collaborative partnership between the Government and its contractor, which is vital for the success of the program. Prospective Vendor STRONGLY recommends that the FAA remove reference to this clause.

FAA response: There are three parts to this clause (a) KTR’s liability if unable to deliver on time (b) KTR’s total liability if contract is terminated due to KTR default, and (c) KTR will not be charged liquidated damages when delayed delivery is beyond the KTR’s control, without fault or negligence of the KTR as defined in the Default clause. This is a Fill-In clause. For Part (a) – FAA may choose to put $0 for liquidated damages and the KTR will be responsible for the actual damages. This section will be filled-in in the final DVT SIR. The entire clause will not be removed, as parts (b) and (c) must remain in the SIR/future contract.

49. The DVT Systems are assigned a security category of High IAW Federal Information Processing Standards (FIPS) 199. Comment: FIPS 199 Security Category is normally defined a Low/Medium/High assignment for each of three Security Objectives: Confidentiality, Integrity, and Availability. The SIR only indicates a single assignment of High. Recommendation: Clarify the Security Category for each of the three Security Objectives, IAW FIPPS 199. Also NIST 800-53 Rev.

5 is released.

FAA response: Security Categories:

• Confidentiality – Low

• Integrity – High

• Availability – High

• System-Level – High

50. Develop and conduct Test Team Training Classes Comment: It is not clear what this entails. Does the contractor have to developed detailed training courses, train FAA personnel, etc., or is this simply to ensure that test technicians are appropriately trained on any unique operations before conducting tests? Recommendation: Please clarify intent and requirements.

FAA response: Refer to Task Order 002: 2.8.10 Test Team Training Class.

51. The Contractor’s warranty under this clause must apply only to those defects discovered by either the FAA or the Contractor for a one-year period from the date of completion of antenna installation and commissioning at the site. Comment: Warranty clauses references antenna installation and commissioning. Should this be DVT System?

FAA response: Correct. FAA will update.

52. Task Order 002, Section 2.8.4.2, Page 24. The Type Test information provided in this table does not match that shown in SIR Section 3, 3.10.1.

FAA response: FAA will update the Type Test sections to be consistent between Section C and Task Order 002 in the final DVT SIR.

53. Key personnel requirements are not released at this time (Attachment J-X). However, Scheduler is an unusual labor role to classify as “Key Personnel”.

FAA response: FAA is still considering the final key personnel.

54. Attachment J-2 is referenced, but not provided. The list of personnel in Table 6 is extensive and beyond the scope of what is typically considered “Key Personnel”. For example, Digital Engineer, Implementation engineer, etc. are not unique or specialized skill sets. Engineering Subject Matter Expert for SAE ARP4754A, however, is a unique skill set. Recommendation: Please reduce the list of Key Personnel to those roles that are associated with unique experience and/or knowledge required for the DVT program.

FAA response: Section J will be provided in the final DVT SIR.