MT_Amendment_19-R-0164.pdf

AMENDMENT OF SOLICITATION/MODIFICATION OF CONTRACT

Except as provided herein, all terms and conditions of the document referenced in Item 9A or 10A, as heretofore changed, remains unchanged and in full force and effect.

15A. NAME AND TITLE OF SIGNER (Type or print)

30-105-04EXCEPTION TO SF 30

APPROVED BY OIRM 11-84

STANDARD FORM 30 (Rev. 10-83) Prescribed by GSA

FAR (48 CFR) 53.243

The purpose of this amendment is to modify verbiage in sections B and L. Section L changes are highlighted in RED FONT. If you have previously submitted a proposal you may revise it up until solicitation close date and time. All other terms and conditions remain unchanged and in full force and effect.

1. CONTRACT ID CODE PAGE OF PAGES

J 1 11

16A. NAME AND TITLE OF CONTRACTING OFFICER (Type or print)

16C. DATE SIGNED

BY 15-Aug-2019

16B. UNITED STATES OF AMERICA15C. DATE SIGNED15B. CONTRACTOR/OFFEROR

(Signature of Contracting Officer)(Signature of person authorized to sign)

8. NAME AND ADDRESS OF CONTRACTOR (No., Street, County, State and Zip Code) X N0017419R0164

X 9B. DATED (SEE ITEM 11)

07-Aug-2019

10B. DATED (SEE ITEM 13)

9A. AMENDMENT OF SOLICITATION NO.

11. THIS ITEM ONLY APPLIES TO AMENDMENTS OF SOLICITATIONS

X The above numbered solicitation is amended as set forth in Item 14. The hour and date specified for receipt of Offer is extended, X is not extended.

Offer must acknowledge receipt of this amendment prior to the hour and date specified in the solicitation or as amended by one of the following methods:

(a) By completing Items 8 and 15, and returning 1 copies of the amendment; (b) By acknowledging receipt of this amendment on each copy of the offer submitted;

or (c) By separate letter or telegram which includes a reference to the solicitation and amendment numbers. FAILURE OF YOUR ACKNOWLEDGMENT TO BE RECEIVED AT THE PLACE DESIGNATED FOR THE RECEIPT OF OFFERS PRIOR TO THE HOUR AND DATE SPECIFIED MAY RESULT IN REJECTION OF YOUR OFFER. If by virtue of this amendment you desire to change an offer already submitted, such change may be made by telegram or letter, provided each telegram or letter makes reference to the solicitation and this amendment, and is received prior to the opening hour and date specified.

12. ACCOUNTING AND APPROPRIATION DATA (If required)

13. THIS ITEM APPLIES ONLY TO MODIFICATIONS OF CONTRACTS/ORDERS.

IT MODIFIES THE CONTRACT/ORDER NO. AS DESCRIBED IN ITEM 14.

A. THIS CHANGE ORDER IS ISSUED PURSUANT TO: (Specify authority) THE CHANGES SET FORTH IN ITEM 14 ARE MADE IN THE

CONTRACT ORDER NO. IN ITEM 10A.

B. THE ABOVE NUMBERED CONTRACT/ORDER IS MODIFIED TO REFLECT THE ADMINISTRATIVE CHANGES (such as changes in paying office, appropriation date, etc.) SET FORTH IN ITEM 14, PURSUANT TO THE AUTHORITY OF FAR 43.103(B).

C. THIS SUPPLEMENTAL AGREEMENT IS ENTERED INTO PURSUANT TO AUTHORITY OF:

D. OTHER (Specify type of modification and authority)

E. IMPORTANT: Contractor is not, is required to sign this document and return copies to the issuing office.

14. DESCRIPTION OF AMENDMENT/MODIFICATION (Organized by UCF section headings, including solicitation/contract subject matter where feasible.)

10A. MOD. OF CONTRACT/ORDER NO.

2. AMENDMENT/MODIFICATION NO. 5. PROJECT NO.(If applicable)

6. ISSUED BY

3. EFFECTIVE DATE

15-Aug-2019

CODE

NSWC IHEODTD N

4081 N. JACKSON RD

BLDG 841

INDIAN HEAD MD 20640-5116

N00174 7. ADMINISTERED BY (If other than item 6)

4. REQUISITION/PURCHASE REQ. NO.

CODE

See Item 6

FACILITY CODECODE

EMAIL:TEL:

N0017419R0164

SECTION SF 30 BLOCK 14 CONTINUATION PAGE

The following items are applicable to this modification:

SUMMARY OF CHANGES (FINAL)

SECTION B - SUPPLIES OR SERVICES AND PRICES

CLIN 0001

The CLIN extended description has changed from:

First Article - MK85 Motor Tube In accordance with the Statement of Work and Drawings.

To:

First Article - MK85 Motor Tube In accordance with the Statement of Work and Drawings. The Offeror shall prepare its proposal for the production of 1638AS301-1 motor tube configuration only.

CLIN 0002

PRODUCTION QTY (BASE YEAR) In accordance with the Statement of Work and Drawings.

PRODUCTION QTY (BASE YEAR) In accordance with the Statement of Work and Drawings. The Offeror shall

CLIN 0004

(OPTION-1) PRODUCTION QTY In accordance with the Statement of Work and Drawings.

(OPTION-1) PRODUCTION QTY In accordance with the Statement of Work and Drawings. The Offeror shall

CLIN 0006

(OPTION-2) PRODUCTION QTY In accordance with the Statement of Work and Drawings.

(OPTION-2) PRODUCTION QTY In accordance with the Statement of Work and Drawings. The Offeror shall

CLIN 0008

(OPTION-3) PRODUCTION QTY In accordance with the Statement of Work and Drawings.

(OPTION-3) PRODUCTION QTY In accordance with the Statement of Work and Drawings. The Offeror shall

CLIN 0010

(OPTION-4) PRODUCTION QTY In accordance with the Statement of Work and Drawings.

(OPTION-4) PRODUCTION QTY In accordance with the Statement of Work and Drawings. The Offeror shall

SECTION L - INSTRUCTIONS, CONDITIONS AND NOTICES TO BIDDERS

The following have been modified:

INSTRUCTIONS, CONDITIONS AND N

IHD 195 - SECTION L PROPOSAL REQUIREMENTS (FEB 2000) (NAVSEA/IHD)

SECTION L - INSTRUCTIONS, CONDITIONS AND NOTICES TO OFFERORS

The following has been modified: All changes are in RED font

1.0 OVERVIEW

The purpose of this requirement is to provide for the manufacture of the Mk 85 Motor Tube. The MK 85 Motor Tube is an item designed as a container for the wiring, the ignition, the propellant, and the nozzle of a rocket motor.

1.1 Contract Award

1.1.1 The Government intends to award one (1) Firm Fixed Priced (FFP), Indefinite Delivery, Indefinite Quantity (IDIQ) contract with one base and four option years, as a result of this solicitation and in accordance with Section M, to the responsible Offeror whose proposal represents the Best Value to the Government, utilizing a trade-off process in accordance with the Factors and Sub-factors set forth in this solicitation. The Offeror shall provide required items with specific details In-Accordance-With (IAW) individually written Delivery Orders issued by the Government within the scope of the Statement of Work (SOW) and resulting contract.

1.1.2 The Government may reject any or all proposals if such action is in the Government’s best interest.

1.1.3 The Government reserves the right to award a contract based on initial offers and without holding discussions, but reserves the right to hold discussions at the Government's discretion; therefore, the Offeror’s initial proposal should contain the Offeror’s best terms from a cost/price and technical standpoint.

2.0 NOTICES TO OFFERORS

Each Offeror must (1) submit an offer, (2) submit information that addresses the evaluation factors, and (3) submit supporting price data. The Government will evaluate each Offeror's understanding of the Government's requirements and ability to perform the work on the basis of its proposal. It is the Offeror's responsibility to provide information and evidence that clearly demonstrates its ability to meet the solicitation requirements. Unless otherwise allowed, the Offerors shall submit all questions by 4:30PM EST no later than 10 calendar days of solicitation closing.

Interested Offerors must request the drawing package in writing. E-mail the following information to Tracy.R.Scott@navy.mil:

-Name -Title -Company name and address -DUNS and CAGE numbers -E-mail address

This procurement includes controlled unclassified information (CUI) that the Government will provide upon request as a .piz file. Offerors must convert this file to a /zip file. The Government will send a separate email with the password to access these files.

3.0 INSTRUCTIONS FOR SUBMISSION OF OFFERS

3.1 Submission

3.1.1 Submission, modification, revision, and withdrawal of proposals

(i) The Offeror shall submit the following information in both hard copy and electronic copy format;

failure to do so will render an offer ineligible for award:

1. Four (4) copies of the Technical Volume I.

2. Two (2) copies of Past Performance Volume II, including Past Performance Matrix, and Past

Performance Questionnaire.

3. One (1) copy of the Price Volume III, containing the completed and signed RFP package, with all representation certifications executed, and with prices in Section B.

(ii) Any proposal modification or revision not received/submitted by the exact time specified for receipt of offers is “late” and may not be considered. The solicitation will close at the exact date and time specified in the solicitation and Offerors will be unable to submit their proposal after that time.

(iii) Proposals may be withdrawn by written notice to the Contracting Officer provided such notice is received prior to contract award. Withdrawals are effective upon receipt of notice by the Contracting Officer.

4. Two (2) copies of the Small Business Subcontracting Plan Volume IV (If applicable)

Failure to submit a complete proposal prior to the solicitation closing date and time may render the proposal unacceptable.

3.2 Offer Expiration Date

Proposals in response to this solicitation shall be valid for 270 calendar days.

4.0 PROPOSAL FORMAT

4.1 General

Offerors must comply with the detailed instructions for the format and content of the proposal; proposals that do not comply with the detailed instructions for the format and content of the proposal may be considered non-responsive and may render the Offeror ineligible for award. Format shall comply with the following information:

8.5 x 11 inch paper Single-spaced typed lines 1 inch margins 12-point Times New Roman Font text

Offerors are instructed to clearly label all files with Volume number, company name and a unique identifying name which is reflective of the contents of the file (i.e., VOL. III, ABC COMPANY, PRIME COST PROPOSAL). Please keep the file names consistent for all volumes.

The Offeror shall submit proposals in hard copy to:

NSWC IHEODTD

4081 N. Jackson Road Indian Head, MD 20640-5115 Code 022TS Attn: Mrs. Tracy R. Scott

The Offeror shall also submit one proposal with four (4) separate volumes and cover letter in email to:

Tracy.R.Scott@navy.mil

4.1.1 Page Numbering

The Offeror shall use a standard page numbering system to facilitate proposal references. Number consecutive pages within sections. Charts, graphs and other insert materials shall be page-numbered as part of the page numbering system.

4.1.2 Page Limitations

Page limitations are identified for each volume/section of the proposal, as described in paragraph 5.0 below and will be treated as maximums. If exceeded, excess pages will not be read or considered in proposal evaluation. When both sides of a sheet display printed material, it shall be counted as two pages. Graphs, charts, and tables are included in the page count. The following are not included in the page limitations:

(i) Title/Cover pages

(ii) Tables of contents

(iii) Glossaries of abbreviations and acronyms

(iv) Subcontracting agreements, letters of intent, resumes, and subcontract agreements

(v) Proposal Cross-Reference Tables

4.2 Cover letter, provided as a separate file, of the proposal must provide the following:

(i) The solicitation number;

(ii) Cage Code;

(iii) The name, address, e-mail address, and telephone and facsimile numbers of points of contact for the Offeror and teaming subcontractors;

(iv) Names, titles, and telephone and facsimile numbers (and electronic addresses if available) of persons authorized to negotiate on the Offeror’s behalf with the Government in connection with this solicitation;

(v) Name, title, and signature of person authorized to sign the proposal.

(vi) A statement that the Offeror consents, meets and agrees with all terms, conditions, requirements, provisions, and amendments included in the solicitation. Offerors must meet all requirements at the time of proposal submission; or provide with their cover letter an acceptable plan to meet the requirements by the start date of the contract performance. Failure to meet all requirements at the time of proposal submission or provide an acceptable plan to meet the requirements by the start date of the contract performance may remove the Offeror from consideration of award. The following elements of the technical proposal shall be addressed in the cover letter:

• Organizational Conflict of Interest (OCI) Certification/Mitigation Plan: The Offeror shall certify compliance with the OCI clause HQ L-2-0005 - Notification Of Potential Organizational Conflict(s) Of Interest (NAVSEA) (JUN 1994). If a potential conflict of interest exists at any tier, each potential prime Offeror is requested to notify the Contracting Officer within 14 days of the date of this solicitation and present an acceptable plan to neutralize any potential mailto:Tracy.R.Scott@navy.mil organizational conflict of interest. Those Offerors deemed to have a conflict of interest may be ineligible for award.

• Small Business Subcontracting Plan: The Offeror shall propose at least 5% to small businesses.

4.3 Cover Page, Table of Contents, Proposal Cross-Reference Table

Each proposal volume must include a Cover Page and a Table of Contents. The Cover Page shall identify the solicitation number, amendment number, proposal volume and title, and the Offeror’s name. Volume I shall include a Master Table of Contents and a Proposal Cross-Reference Table. The Proposal Cross-Reference Table shall indicate the required proposal content by solicitation section/page number and the section/page number where this content appears in the proposal.

4.4 Glossary of Abbreviations and Acronyms

Each volume shall contain a glossary which includes all abbreviations, acronyms and their corresponding definitions.

4.5 Price Information

Pricing information of any kind shall only be included in Volume III, Price Proposal. The Offeror shall submit all Price summary and back-up spreadsheets in MS Excel format.

5.0 PROPOSAL ORGANIZATION

The Factors below are in descending order of importance.

VOLUME I – TECHNICAL (Factor 1) (Not to Exceed 75 pages)

The Offeror shall prepare its proposal for the production of 1638AS301-1 Motor Tube configuration only.

The Offeror shall address each sub-factor listed below, which are listed in descending order of importance. Offerors are to ensure that only Technical information is contained within Volume I. The technical proposal shall not exceed 75 single sided pages, not less than 12-point Times New Roman. The technical proposal shall not contain any hyperlinks or electronically imbedded links or price information. The Government will only evaluate the first 75 single-sided pages. The Offeror’s technical proposal must demonstrate an understanding of all requirements covered in the Statement of Work (SOW) and RFP terms and conditions. The resultant Offeror’s proposal will be incorporated into the contract by reference and the Offeror shall perform in accordance with the technical proposal presented with its proposal.

The technical proposal shall contain information/documentation in sufficient detail to enable evaluation based on the factors/sub-factors listed in Section M, Clause entitled Best Value Evaluation and Basis for Award and as detailed below. To this end, each technical proposal shall be specific, detailed and complete as to clearly and fully demonstrate that the prospective contractor has a thorough knowledge and understanding of the requirements and has valid and practical solutions for technical problems. Statements that paraphrase the specifications or attest that standard procedures are inadequate to demonstrate how the Offeror will comply with the requirements of the specifications, and this clause.

The Offeror shall describe how it plans to accomplish the tasks associated with the following sub-factors:

SUB-FACTOR 1: MANUFACTURING PROCESSES

1. The Offeror shall specifically address the processes for the following critical processes expected during manufacture of the motor tubes:

1. Machining close tolerance metal parts.

2. Acquisition of all materials

3. Motor Tube Painting

4. Hydrostatic testing at 3500 psi for the internal surfaces.

2. The Offeror shall describe the overall manufacturing approach including production processes, procedures, material handling and controls for the fabrication of the motor tube including, but not be limited to, a description of such items as jigs, fixtures, instruments and facilities required during the manufacturing process.

3. The Offeror shall provide a list of sub-contractors that “Potentially” could be used to support the manufacturing of the Integral Bulkhead Motor Tube and cross-reference them to the process flow diagram in requirement number 1.

4. The Offeror shall provide a detailed description of each sub-contractor’s proposed manufacturing/processing for the Integral Bulkhead Motor Tube. The description should detail the entire process from receipt of material to the delivery of the finished product. The list should also include the company name, address, technical point of contact and phone number.

5. The Offeror shall describe the test program including in-process testing, inspection procedures, special test equipment including environmental test equipment, and test equipment calibration that will be implemented to verify compliance with the requirements in the performance specification and SOW. Offerors are advised that no special test equipment will be furnished by the Government.

6. The Offeror shall identify any foreseeable problem areas in the manufacturing set up process that will affect the delivery schedule.

SUB-FACTOR 2: MANAGEMENT AND SCHEDULE

1. The Offeror shall provide an organizational chart(s) that identifies management and the lead technical personnel for each functional area (e.g., engineering, manufacturing, QA, procurement) that will support this procurement and their level of involvement.

2. The Offeror shall describe the proposed plan for liaison with the Government, including schedule control processes that maintain visibility of the work progress and reporting of problems and schedule slippages.

3. The floor personnel, at a minimum shall possess knowledge in reading and interpreting specification drawings or blueprints; demonstrate certification or equivalency of a machine level 1 of the National Institute of Metalworking Skills (NIMS).

4. The Offeror shall provide a production schedule for qualification and manufacturing of the motor tubes required by the solicitation indicating at a minimum:

a. Facility set up (the arrangement of tooling, machinery, input and control of supplies and materials that efficiently support the manufacturing process) ;

b. Tooling and test equipment designs/procurement;

c. First Article Testing

d. Material acquisition, including long lead items;

e. Fabrication;

f. Inspection and testing;

g. Delivery of hardware in accordance with Government Schedule;

h. Preparation and delivery of Data Items in accordance with Government schedule.

SUB-FACTOR 3: FACILITIES

1. The Offeror shall describe the facility or facilities that the Offeror plans to use to accommodate the flow of manufacturing for the prime and any Subcontractors; including the capability for assembly, testing, and storage.

2. The Offeror shall describe the fabrication, assembly, and test facilities and provide an overall floor plan of these facilities.

3. The Offeror shall provide a list of their facility’s equipment (owned and/or currently leased) that will be required to manufacture the Integral Bulkhead Motor tube.

4. The Offeror shall provide plans to accommodate the flow of manufacturing for the prime and potential subcontractors: including the capability for testing and storage.

5. The Offeror shall describe the fabrication and test facilities and provide an overall floor plan of these facilities.

SUB-FACTOR 4: QUALITY ASSURANCE (QA) PLAN (Not included in the page limit)

1. The Offeror shall describe the type of documentation that will be used to identify, record and dispose of non-conforming material, in-process rejects and characteristic discrepancies.

2. The Offeror shall provide a copy of their Quality Management Plan (QMP) tailored to the requirements of the SOW for production of the motor tubes required by the solicitation that meets the requirements of ISO 9001:2015. This document does not count against the page limitation of the technical proposal.

VOLUME II – PAST PERFORMANCE (Factor 2) (No Page Limit)

Past performance, information shall be provided for the Prime and all subcontractors in order to develop an Offeror's past performance rating.

Past performance information is one indicator of an Offeror’s (to include prime and subcontractors) ability to perform the contract successfully. In the evaluation of an Offeror’s past performance, the Government reserves the right to use relevant performance within the past five years. Relevant and timely past performance information in the Contractor Performance Assessment Reporting System (CPARS), and the Past Performance Information Retrieval System (PPIRS) (http://www.ppirs.gov/) including the Federal Awardee Performance and Integrity Information System (FAPIIS) will be considered during the evaluation of an Offeror’s past performance.

Using the Past Performance Matrix (as listed in Section J), the Offeror and all subcontractors shall provide a separate list of relevant contracts that were performed within the last five years. Contracts that are in PPIRS are preferred. The list for the Prime shall contain no more than seven relevant contracts. In addition, each subcontractor shall complete a separate matrix and provide no more than seven relevant contracts. The identified relevant contracts shall focus on performance that is relevant to the current solicitation requirements cited in the Scope of this solicitation. Relevancy includes similarity of item, complexity and dollar value. With respect to relevancy, more relevant past performance will typically be a stronger predictor of future success and have more influence on the past performance confidence assessment than past performance of lesser relevance. If the Offeror has no relevant past performance within the last five years or cannot provide a list of relevant contracts, then the Offeror must provide an explanation.

Past Performance Questionnaires (as listed in Section J) only apply to relevant contracts for which performance information is not available through PPIRS. The Offeror and subcontractors shall submit the Past Performance Questionnaire to all of their references listed on the Past Performance Matrix that have NO PPIRS contracts, and shall request the references to complete the Past Performance Questionnaire and return it directly to:

NSWC IHEODTD

http://www.ppirs.gov/

4081 N. Jackson Road, Bldg. 841 Indian Head, MD 20640-5115 Code

022TS

Attn: Tracy R. Scott

Past Performance Questionnaires may also be emailed to contract Tracy.R.Scott@navy.mil as the preferred method of delivery. Offerors shall submit all questionnaires by the closing date and time of the solicitation.

REMINDER: It is imperative that Offerors label all pricing files with Volume III, company name and unique identifying name that is reflective of the contents of the file.

In order to facilitate the evaluation of Past Performance the Offeror must complete the required information below:

(a) Pursuant to FAR 42.1502, this contract is subject to DoD's Contractor Performance Assessment System (CPARS). CPARS is an automated centralized information system accessible via the Internet that maintains reports of contractor performance for each contract. CPARS is located at https://www.cpars.gov. Further information on CPARS is available at that website.

(b) Under CPARS, the Government will conduct annual evaluations of the contractor's performance. The contractor has fourteen (14) days after the Government's evaluation is completed to comment on the evaluation. Day 15 after the evaluation sent to the contractor the evaluation is available in PPIRS with or without the contractor comments.

The evaluation is marked “Pending”. Contractor may send comments on days 15-60 if not previously provided. If contractor sends comments, PPIRS is updated to reflect contractor comments and “Pending” marking removed. Day 61 evaluation sent to Assessing Official (AO) and contractor may no longer send comments. The opportunity to review and comment is limited to this time period and will not be extended. Failure to review the report at this time will not prevent the Government from using the report.

(c) The contractor may request a meeting to discuss the CPAR. The meeting is to be requested via e-mail to the CPARS Program Manager no later than seven days following receipt of the CPAR. A meeting will be held during the contractor’s 60-day review period.

(d) The CPARS system requires the Government to assign the contractor a UserID and password in order to view and comment on the evaluation. Provide the name(s) of at least one individual (not more than two) that will be assigned as your Defense Contractor Representative for CPARS.

Name Phone E-mail Address (optional)

(e) Any changes in designated contractor personnel shall be the sole responsibility of the contractor to notify the contract specialist, AO and the CPARS Focal Point when changes occur.

VOLUME III – PRICE (Factor 3) (No Page Limit)

REMINDER: It is imperative that Offerors label all price files with Volume III, company name and a unique identifying name, which is reflective of the contents of the file.

This volume is the only volume that shall contain price information. There is no limitation on the number of pages or print size for the cost proposal. The Offeror shall clearly identify all Attachments submitted under Volume III (Factor 3).

The Price Volume shall include the completed RFP document, with Section B, pricing filled in. The Offeror shall include any available pricing information to facilitate the price analysis in evaluating the proposal in the Price Proposal (i.e., price breakdown, catalog pricing, past pricing history, etc.).

mailto:Tracy.R.Scott@navy.mil https://www.cpars.gov/

The price information shall include data regarding the general financial condition of the Offeror and specific plans for financing the proposed contract. The Government has no plans to provide any financial assistance.

The Price Volume shall also include all executed representation certifications.

Volume IV – SMALL BUSINESS SUBCONTRACTING PLAN (Factor 4) (No page limit) (For Other Than Small Businesses Only)

There is a mandatory subcontracting goal of 5% for this requirement.

The Offeror shall submit a Small Business Subcontracting Plan in accordance with FAR clause 52.219-9. This volume applies to other than small businesses only. The Government will evaluate the plan as either acceptable or unacceptable and will evaluate as part of the FAR Part 9.1 Responsibility Determination. The Government will only evaluate the plan submitted by the apparently successful offeror. The Small Business Specialist and the Contract Specialist will perform the evaluation. The Government reserves the right pursuant to FAR 9.105-1(c) (3) and 19.705-3 to confer with the Offeror on elements of the Small Business Subcontracting Plan in order to determine Responsibility prior to award. These conversations will not constitute discussions as defined in FAR 15.306(c).

The Offeror shall provide the Small Business Subcontracting Plan concurrent with submission of the Offeror’s proposal and the Government incorporate it into the task order. The individual plan shall contain the following:

A. Total Proposed Value of Offer B. Total Amount to be Subcontracted C. Breakdown by Business Type ($ and %) D. Large Business/other than Small Business E. Small Business

• Small Disadvantaged Business

• HUBZone Small Business

• Women-Owned Small Business

• Veteran-Owned Small Business

• Service-Disabled Small Business

F. Major types of services/items that are going to be subcontracted to small business and which type of small business.

The Offeror shall provide an explanation as to why, if any goals cannot be met. The Government will evaluate the individual subcontracting plan as part of the FAR 9.1 Responsibility Determination.

(End of Summary of Changes)