HTC71119RR003_WASP-135_Draft_PWS_Feedback_Matrix_Gov_Response.xlsx
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- Worldwide Airlift Services Program - 135 (WASP-135) Federal contract opportunity
- Solicitation number
- HTC71119RR003
About this file
This document contains feedback from industry on a draft performance work statement for the Worldwide Airlift Services Program - 135 solicitation. The solicitation will be issued by the United States Transportation Command to establish multiple indefinite-delivery, indefinite-quantity contracts for airlift services including passenger, cargo, and medical evacuation flights utilizing fixed-wing and rotary-wing aircraft. Based on the feedback provided, key aircraft capabilities will be defined at the task order level to provide flexibility given the wide range of potential mission requirements. Minimum performance standards will be established at the contract level, with specific requirements refined upon issuance of individual task orders. Pricing will also occur at the task order stage based on the defined workscope. The performance work statement has been revised to clarify ambiguous language and incorporate industry recommendations to better accommodate variable mission needs under the multiple award indefinite delivery contract vehicle.
Draft PWS Government response to industry feedback.
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Sheet1
| HTC711-19-R-R003 Draft PWS Industry Feedback | |||
| Question # | Reference (para./line item) | Comments/Questions | Government Response |
| 1 | 1.1.1 | Not all mission profiles will require IFR capable aircraft and crews. Suggest adding "and/or" or "as specified by Task Order" to this sentence. "The carrier shall have a current FAA/CAA authorization certificate to operate over routes and into the airfields specified under both Instrument Flight Rules (IFR) and Visual Flight Rules (VFR) conditions and rules." | Agree, PWS language revised. |
| 2 | 1.18 | A later FMC reporting time is better suited for some missions so as not to unduly harm the Contractor. Suggest revising to state "as required by Task Order" or something to that effect. | PWS language revised. |
| 3 | 1.4.1 | Primary Aircraft. - Contractor should be requested at the TO level. It would be in the best interest of the Government if contractor is capable of adding aircraft types suited to the mission at the TO level. | PWS language revised for clarification. |
| 4 | 1.4.3 | Replacement of aircraft should not be unreasonably withheld by the CO. | Requirement remains unchanged. |
| 5 | 4.1.2 | Change to "dual pilot" | Some aircraft types may not require dual pilots. FAR 135 regulation (or CAA equivalent) governs how many pilots are required unless otherwise stipulated at the TO level. |
| 6 | 4.1.2.1 | Again, not all mission profiles require IFR capable aircraft and crews. | PWS language revised. |
| 7 | 4.2 | Too ambiguous. Suggest defining the PAX requirements in an aircraft category table. For example, 135 operations are limited to 19 passengers unless a flight attendant is on board, and is not typical for Rotary Wing operations. | PWS language revised. Any specific requirements will be identified at the TO level. |
| 8 | 4.3 | Too ambiguous. Suggest defining the CARGO requirement in an aircraft category table. | PWS language revised. Any specific requirements will be identified at the TO level. Contractors will be required to provide capabilities of all aircraft by tail number vice an aircraft category table. |
| 9 | 4.5.3 | Is this for ad-hoc Air Ambulance Fixed Wing service or is this section intended to govern rotary wing operations as well? | Applies to both FW and RW. Paragraph denotes minimum requirements applying to both ad hoc and dedicated services. Additional requirements may be identified at the TO level. |
| 10 | 4.5.7 | Makes reference to a 95% reliability rate, which is in conflict with the TBD language included in Sections 1.18 and 2. In addition, a reliability rate of 95% is unrealistic for some mission profiles that potentially could be contracted for under this program. | PWS language revised for clarification. |
| 11 | 4.5 | Please further define Air Ambulance requirements as they differentiate from Medical Evacuation missions as it pertains to type of aircraft used and aircraft configurations. | Comments will be considered for future revisions. |
| 12 | 4.8.2 | 24/7 coverage and response time need additional clarification. For example, will this require double crew to ensure availability around the clock, 365 days a year? Does the aircraft need to mobilize to required location with the N +30 minute response time? | PWS language revised for clarification. |
| 13 | 4.12.1 | Not all mission profiles will require NVG capability. Suggest revising to include "as applicable" or "as dictated by Task Oder" type language. | PWS language revised for clarification. |
| 14 | N/A | General Comment: There are several instances of "Contractor shall" language throughout this PWS. Depending on the individual Task Order Releases and various Scopes of Work to be procured under this IDIQ, this language can be very problematic. Suggest revising the IDIQ PWS to capture only the minimum performance standards at a high level, and further refine the requirements at the Task Order level. Also, because aircraft requirements and missions will vary so widely, we suggest including "as applicable" or "to be determined at Task Order level" type language wherever possible so as not to create a conflict. | PWS language revised for clarification. |
| 15 | N/A | General Comment: It may be beneficial to categorize and define the different type of aircraft to be procured under this vehicle. For example, Rotary Wing aircraft are typically grouped by Light, Medium, Heavy, and Super Heavy based upon lift capacity. The US Forest Services also practices with their Type I, II, and III designations. | Requirements will naturally dictate aircraft able to perform. |
| 16 | N/A | General Comment: The synopsis did not provide detailed information regarding the procurement strategy for industry comment. For example, industry may have valuable comments regarding whether a LPTA or Trade-off basis of award is more advantageous given a particular scope of work. Also, is it the Government's intent to award Firm Fixed Price Task Orders to successful responses to the IDIQ? What sort of pricing format will be requested at the IDIQ level, and will Offerors be afforded the chance to amend that pricing at the Task Order level? Will Offerors be responding to scenario type pricing as part of the IDIQ solicitation process or be providing some sort of catalog or GSA schedule type pricing? | The Government does not intend to require pricing at the IDIQ level for initial contract awards. Pricing will be at the TO level as requirements are generated. |
| 17 | Synopsis | To further clarify intent of WASP and this solicitation, HTC71119RR003 will issue "overall" IDIQ awards to multiple contractors based upon certain minimum qualifications/requirements - and THEN agency will subsequently issue "individual" solicitations and TO (award) based upon specific mission(s)/theater(s) - i.e., definite delivery/quantity and relevant contractor response/qualifications for TO award? | Correct. |
| 18 | Synopsis | Please confirm - do IDIQ awardees have to possess demonstrative capacility prior to award to render ALL types of (catalog) of services described in PWS? OR, is intention to issue individual solicitations to IDIQ awardees based upon certain minimum qualifiations/requirements and providing flexibility that IDIQ awardees do NOT have to necessarily have ALL services defined in PWS (or at time of IDIQ award) - subsequently subject then to individual solicitations, IDIQ awardee response and TO awarded to contractor(s) thereafter? | Awardees do not have to have capability in all areas of the PWS. However, IDIQ holders will only be able to bid on requirements for which they have capability to perform. |
| 19 | 1.1 | Please confirm - Foreign owned/based operators are eligible IDIQ award if AMC/CARB-approved (re: CAA equivalent reference and 1.21.1 reference to "first tier foreign air carriers")? | Foreign owned/based operators are eligible for IDIQ award if AMC/CARB-approved. However, para 1.21.1 does not apply to prime contractors--only first tier subcontractors. |
| 20 | 1.2.5/1.2.6 | Please confirm - individual solicitations and TO may involve active combat theaters/zones? | Refer to para 1.5.4. |
| 21 | 1.3 | Does the F/W and/or Rotary AIR CARRIER (i.e, FAA 135 certificate holder or CAA equivalent) possessing the AOC have to be the Prime contractor for IDIQ award? | Yes. |
| 22 | 1.5 | Please confirm - the min. 24 hr. advance TO mission notice (and additionally various other similar specific operational/mission requirements contained elsewhere in PWS) references "individual" solicitation/TO awards (i.e., "definite) - NOT the IDIQ award itself? | Mission scheduling will be at the TO level. |
| 23 | 4.2 | Please clarify - is agency requiring concurrent aircraft requirements of ALL of the following capabilities: Up to 30 Pax, 7500# cargo weight and 3200nm IFR range? Collectively, those 3 requirements jointly define a very narrow range of qualifying aircraft make/model platforms, particularly the range requirement. Or do these requirements vary based upon specific service(s) defined in PWS and thus not necessarily all required on same aircraft - and if so, please clarify further if possible. | Specific requirements will be defined at the TO level (individual or concurrent services). |
| 24 | 4.3 | Please clarify - is agency requiring concurrent aircraft requirements of ALL of the following capabilities: Up to 30 Pax, 7500# cargo weight and 3200nm IFR range? Collectively, those 3 requirements jointly define a very narrow range of qualifying aircraft make/model platforms, particularly the range requirement. Or do these requirements vary based upon specific service(s) defined in PWS and thus not necessarily all required on same aircraft - and if so, please clarify further if possible. | Specific requirements will be defined at the TO level (individual or concurrent services). |
| 25 | 4.5.1 | Minimum 2hr advance TO mission notice for Air Ambulance services implies 24/7 mission readiness but this requirement is not specifcially defined - please confirm/clarify? | PWS language revised for clarification. 2 hr notification is after TO award. |
| 26 | 4.6 | Please clarify - is agency requiring concurrent aircraft requirements of ALL of the following capabilities: Up to 30 Pax, 7500# cargo weight and 3200nm IFR range? Collectively, those 3 requirements jointly define a very narrow range of qualifying aircraft make/model platforms, particularly the range requirement. Or do these requirements vary based upon specific service(s) defined in PWS and thus not necessarily all required on same aircraft - and if so, please clarify further if possible. | Specific requirements will be defined at the TO level (individual or concurrent services). |
| 27 | 4.6 | Re: reference to "JET", are turbine jet (JET) and/or turbine jet (PROP) fixed-wing aircraft eligible for this solicitation - and/or either or both types of aircraft required for specific services defined in PWS (ex. - Pax vs. Cargo vs. Combi missions)? | Turbine jet (JET) and/or turbine jet (PROP) fixed-wing aircraft are eligible. PWS language revised. |
| 28 | 4.8 | Please confirm - Rotary aircraft are presumed for Medevac services but not specifically defined? | Comments will be considered for future revisions. |
| 29 | Synopsis | In a 14 September 2018 memo, the agency stated, "The Government intends to allow all active FAR-135 IDIQ contracts and subsequent task orders to come to their natural conclusion prior to being competed under the new WASP-135 contract." To clarify - will HTC71119RR003 upon solicitation and IDIQ awards, specifically supercede/replace any active, existing USTRANSCOM TO award? If so, please confirm any such specific contract awards affected? | USTRANSCOM still intends to allow all active FAR-135 contracts to come to their natural conclusion prior to being competed under the WASP-135 program. |
| 30 | Synopsis | Synopsis states there is no small businss set-aside utilized; to clarify, will ANY set-asides be utilized for this solicitation? | Not at the IDIQ level. |
| 31 | 1.2.1 | Please confirm - IDIQ awardees (prime contractors) shall have the right to define/specify and/or change sub-contractors submitted for specific individual solicitation responses (and TO, if awarded and subsequent performance) - so long all solicitation requirements are met/exceeded? Re: 1.2.1-1.2.5, are these terms only applicable to first tier "FOREIGN" subcontractor as appears to be defined in 1.2.1, or all subcontractors? | Confirmed, IDIQ awardees shall have the right to define/specify and/or change sub-contractors. If the Government has concerns with specific subcontractors, appropriate action will be taken to communicate concerns. |
| 32 | Synopsis | ||
| 33 | 1.16 | Under what conditions ("unless otherwise specified"), by way of example(s), would agency grant more than 30 calendar days following TO award to position aircraft worldwide? For example, if an aircraft were lost and/or otherwise unavailable immediately preceding TO award, the collective timeframe for replacement AND deployment might exceed the specified position/deposition window. | The Government cannot answer this question without knowing full details. The end user's requirement will dictate the amount of time allowable for mobilization and deployment. |
| 34 | 1.18.2 | The 0800 daily aircraft status deadline is overly restrictive, and does not provide the end customer or contractor mission flexibility to meet changing mission requirements. If the aircraft is NMC at 0800, but can meet mission requirements later in the day, then is the aircraft NMC or FMC for the day? Recommend that PWS is changed to reflect previous similar PWS language, as this give both contractor and end customer max flexibilty to meet mission demands. Previous PWS statements with regard to NMC status is as follows: NMC is defined as any day the aircraft cannot fly due to carrier-controlled reasons (i.e. maintenance, operations, and crew availability). The aircraft will be considered FMC if it is available for flight as scheduled by the Tasking Authority. An aircraft is not to be considered available unless both the aircraft is FMC and the aircrew is available as defined by the FAA or comparable regulations. In addition, the aircrew must be co-located (same hub) with the aircraft, and be in stand-by status in order for the aircraft to be considered FMC. If an aircraft is reported as FMC and launches on a tasked sortie but returns to base for carrier-controlled reasons without completing a mission leg, and without completing any legs for that day, then the aircraft will be considered NMC for that entire day. Any day an aircraft is NMC for carrier controlled reasons, it will be factored into the carrier’s OR rate, and could impact the monthly Billable Amount. If there are extenuating circumstances, the NMC days can be waived on a case-by-case basis by the USTC-CO after coordination with the COR. | PWS language revised. |
| 35 | 2.1 and 2.2 ORR | The prescribed ORR for both FW and RW is 90%; and presents cost challenges in presenting best value to the USG. A 90% ORR combined with a restrictive 0800 aircraft status call, will push contractors to supply spare aircraft in order to protect themselves from financial penalties OR charge the USG more in order to have readily avail spare parts. For all non-CASEVAC type mission task orders, recommend that either ORR be lowered to 80% or aircraft status call time is adjusted to reflect language stated above. | ORR will be specified at the TO level. 90% was only used as an example. |
| 36 | 4.5.1 | The aircraft and medical crew may be required to be ready for immediate departure (not later than two (2) hours) after confirmed notification of an air ambulance requirement. It is inherently difficult to write a PWS where a contractor will perform pax/cargo/combi movement, with a possible requirment to provide N+2 CASEVAC coverage. The CASEVAC mission should me a separate mission, as any standby requirement will require 24 hour coverage for aircrews. The IDIQ PWSlanguage is fine, however; for task orders, there should be dileneated line between routine pax/cargo/combi and CASEVAC missions. If the intent is to leverage existing assets, and provide standby CASEVAC coverage at times, then task order language needs to be specific with regards to expected notification times with existing aircrews. If a contractor is providing one aircrew to perform routine missions, then it will be impossible for them to provide 24 hour standby CASEVAC coverage with designated response times. | The TO will clearly deliniate which service is being ordered. The 2-hour response time is an Air Ambulance requirement only. Section 4.5.1 only applies to Air Ambulance service which differs categorically from medical evacuation service. Medical evacuation service is outlined in para 4.8, with optional 24/7, N+30 min response time (para 4.8.2) if ordered at the TO level. |
| 37 | 4 | Catalog of services The aircraft reuirements are general in nature, and provide no passenger count, lift capacity, combi capacity, etc. In previous similar PWS, aircraft were lumped into class categories with prescribed performance characteristics. An assumption is that specific aircraft performance specs will be stated in accompanying task orders. If that is the case, it is critical that any aircraft performance characteristics include whether the requirements are individual in nature, or if there is a combined requirement. For instance, if a medium RW requirement is to carry 18 pax minimun, 5,000 lbs in cargo, go 400 miles. Is the requirement for the aircraft to do all at one time or are the requirements individual in nature. Without that clarificaiton in any PWS, questions will be asked; slowing down the acquisition process. | Minimum requirements will be specifically identified at the TO level. |
| 38 | N/A | Will contractors be able bid on certain portions of this opportunity? | Yes. |
| 39 | N/A | Do contractors need additional DOD clearances in order to bid? If so, what clearances are required? | An FCL and DoD/CARB Approval are not required to bid on the IDIQ solicitation. Government intends to do staggered awards to allow for air carriers who are technically acceptable and meet the eligibility requirements to receive an immediate award. Those offerors who are technically acceptable, but are not eligible (i.e., non DoD/CARB-approved) must complete the survey process and be DoD/CARB-approved before contract award. Other regulatory DoD clearances may be required to obtain DoD/CARB Approval or perform operations. |
| 40 | N/A | What is the breakdown between rotary and fixed wing flights? | Unknown. |
| 41 | N/A | What is the overall anticipated volume by aircraft type? | Unknown. The Government identifies minimum requirements and air carriers propose aircraft types to meet those requirements. |
| 42 | N/A | What are examples of routing for flights? | Unknown. |
| 43 | N/A | Is there an example of a routing that is more common? How often has this routing occurred? | Unknown. |
| 44 | N/A | Does the DOD anticipate any need for commercial medical transfers/escorts? | Requirements are identified in the PWS. |
| 45 | N/A | What is the typical patient's medical condition- ALS, BLS, ventilator-dependent? What percentage of each? | Unknown. |
| 46 | N/A | Has the past contract required the operator to transfer patients with infectious diseases (ebola or others)? | Unknown. |
| 47 | N/A | How often are multiple transfers needed the same day? | Unknown. |
| 48 | N/A | What is the average duration of a fixed wing flight? | Unknown. |
| 49 | N/A | Is there an incumbent for this contract and if so, who? | There is no single incumbant contractor. |
| 50 | N/A | Does our current GSA contract factor into the award of this new contract? | No |
| 51 | 1.4.7 | FAR 119.9 Use of business names, stipulates that the "name" OR "operating certificate number" may be used. For OPSEC reason at austere locations where aircraft provided dedicated service, it would make most sense to allow the ai carrier to use its certificate number for identification, rather than the name of the company. Can this paragraph be modified to allow the air carrier to utilize the operating certificate number in place of the contractors name for identification purposes? | |
| Requirement remains unchanged. | |||
| 52 | 1.18.1 - 1.18.2 | These paragraph disconnects the Operational Readiness Rate (ORR) calculated for performance from the billable rate. It also states that a contractor will not be paid for any day an aircraft is NMC for carrier controlled reasons, which implies routine, scheduled aircraft maintenance. While it is understood the Govt's goal is to maximize value of services contracted and ensure aircraft are available at all times, aircraft do require routine maintenance. As these paragraphs are currently written, there is no flexibility for any maintenance days throughout the month. In order to achieve 100% FMC throughout the month to bill the full monthly service rate, a contractor could be forced to: (1) field an alternate aircraft (2 to make 1) toaccount for a few days a month when maintenance is required on the primary aircraft; (2) to build in a few days of NMC per month in the Montly Service Rate amount to account for maintenance, which may or may not actually be required. Regardless, both scenarios drive up cost to the govt because the contractor would be account for an extra aircraft or NMC days. Would the govt consider revising this paragraph to align the ORR with billable service rate example provided in question #3 below? | |
| PWS language revised. | |||
| 53 | 1.18.1-1.18.2 | Cont'd from Question #2: |
ORR Required = TBD (e.g. 90%)
Monthly Billable Service:
31-28 Days FMC (>90% ORR), Billable Amount=Full Monthly Service Rate 27-25 Days FMC (>80% ORR), Billable AMount=80% Monthly Service Rate 24-20 Days FMC (>65% ORR). Billable Amount=65% Monthly Service Rate 19-15 Days FMC (>50% ORR), Billable Amount=50% Monthly Service Rate 14-8 Days FMC (>25% ORR), Billable Amount=25% Monthly Service Rate 7 or fewer Days FMC (<25% ORR, Billable Amount=No Monthly Service Rate
| PWS language revised. | ||
| 54 | 1.18.2 | If an aircraft is reported as NMC at 0800L as required by this paragraph due to routine maintenance and is not scheduled to fly until later in the day AND the aircraft becomes FMC prior to the time it is scheduled to fly, the language in this paragraph implies the aircraft will still be treated as NMC, despite being available to complete the mission as scheduled later in the day. The current language provides no incentive for the contractor to provide the utmost flexibility to the customer by placing significant focus working around the customer's schedule, which may include flights scheduled at various times. The language also deincetives the contractor to conduct maintenance during hours that accomodate the customer's schedule reagrdless of the time of day. As it is currently written, if the contractor is conducting maintenance in the morning to accomodate an afternoon or evening schedule, the aircraft will be considered NMC and the contractor will have no obligation to complete the scheduled flights later in the day because the contractor will already be penalized as NMC for the ORR rate and billable monthly service rate. Will the government consider revising this paragraph to account for the fact that operations occur globally on a 24-hour cycle and aircraft may not be scheduled to fly only in the morning? |
| The reporting requirement of 0800 remains unchanged; however, the ORR calculation language has been revised. | ||
| 55 | 1.18.5.2 | This paragraph does not cite the proper definition of "Flight Time" or "Block Time," but provides a hybrid definition. Most current OCONUS contracts are calculated based on FW "Block Time," which is defined as "Flight hours are calculated from the moment the aircraft moves under its own power (block out) and ends when the aircraft engines are shut down |
after landing (block in)." Will the government consider revising this paragraph to site the proper definition of "Block Time" or "Flight TIme?"
| Requirement remains unchanged. | ||
| 56 | 1.19 | This paragraph states the contractor must be compliant with DFARS 252.2.4-7012, but does not reference NIST 800-171 or specific USTC requirements which have been promulagated recently for other contracts such as the Domestic Charter Part 135 Airlift Services. Will the govt consider revising this paragraph to provide more specificity for contractor compliance? |
| PWS reflects most current cyber security requirements. | ||
| 57 | 4.8.3 | This paragraph establishes the minimum level of care for medical evacuation at the Critical Care Level. Critical Care Transport and Accreditation requires at least one of the medical crew members to be a physician or nurse. By and large, civilian and contractor physicians and nurses are often times less experienced in Point of Injury and Pre-Hospital Trauma Life Support (PHTLS), whereas NREMT-Paramedics with PHTLS training specialize in the type of care required. When the Trans-Africa Airlift Support Contract was competed, Critical Care was also specified; however, in later task orders, it was apparent that the requirement in theater really was for Advanced Life Support transport and accreditation, which can be fullfilled by two NREMT-Paramedics with the appropriate level of certification. As a result, task orders were modified to reflect the level of care needed, vice an arbitrary requirement that necessitated higher level credentialing (physicians and nurses), which was not required. Furthermore, despite the possibility of a lack or real-world expeirence in POI stabilization and en route care by many civilian and contractor physicians and nurses, that level of credentialing is extremely costly for dedicated 24/7 stand-by services, which will increase cost to the government. Will the govt consider revising this paragraph to reflect the minimum level of care as Advanced Life Support, with the potential for higher requirements stipulated in task order requirements? |
| Comments will be considered for future revisions. | ||
| 58 | 4.12.5 | The paragraph referenced states the contractor “shall carry HAZMAT in accordance with (IAW) AFMAN 24-204, and their DOT approvals and exemptions.” U.S. certificated air carriers must carry HAZMAT in accordance with either 49 CFR or ICAO Technical Instructions for the Transportation of Dangerous Goods by Air, which may not be harmonized with AFMAN 24-204. Will the government consider this paragraph to state: "The Contractor shall carry HAZMAT in accordance with IAW AFMAN 24- 204, their DOT approvals and exemptions, and any other applicable guidance, not to exceed the most restrictive regulation." |
| Comments will be considered for future revisions. | ||
| 59 | 4.12.9 | This paragraph does not reference FW or RW aircraft. FW aircraft are very rarely equipped with ballistic protection systems because they typically fly above the reach of small arms fire. Additionally, ballistic protection systems for FW aircraft are not commonly available commercially and add significant weight to the aircraft which can dramatically affect payload availability. Will the govt consider revising this paragraph to provide more specificity. |
| PWS language revised. | ||
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