PEARS III Draft SIR 693KA9-25-R-00016 Consolidated Vendor Questions and FAA Responses 03.11.2026.xlsx

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Policy, Engineering, Analysis, and Research Contract (PEARS III)
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693KA9_25_R_00016
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This file is a consolidated vendor questions and FAA responses matrix regarding the Draft Statement of Objectives and Requirements (SIR) for the Policy, Engineering, Analysis, and Research Contract (PEARS III), Solicitation Number 693KA9-25-R-00016. The document addresses 60+ substantive questions and clarifications from industry vendors on proposal requirements, evaluation criteria, labor categories, and contract structure, with corresponding FAA responses that will inform the final SIR.

Key clarifications confirmed include: the competition will be structured as a Total Small Business Set-Aside under NAICS 541330 with a $47 million size standard; the proposal will consist of five volumes (Technical, Management, Past Performance, Pricing, and Other Proposal Documentation) with a 34-page maximum for Volume I; past performance requirements will be reduced from four to three examples with no more than one from a subcontractor; the 36-month recency requirement will remain unchanged; the PEARS III contract will involve work at both contractor and government sites as specified in task orders; and labor categories will be revised to align more closely with PEARS II. The FAA confirmed it will remove references to estimated hours in the final SIR, clarify file format requirements as PDF rather than Microsoft Word, correct numbering inconsistencies, delete unnecessary pricing tabs (L-1C), and revise security clearance language. Multiple vendor recommendations regarding page limits (requesting 68 pages instead of 34), accepting state/local government and commercial contracts as relevant past performance, extending recency to 60 months, and adding additional labor category flexibility were noted but the FAA declined to incorporate most of these changes, citing acquisition strategy appropriateness and alignment with AMS guidance.

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Instructions Please use this matrix to provide comments, questions, and suggestions on any of the provided draft SIR documents. Please use the Comments tab to provide all responses to all documentation.

Column A - Document - Provide which document you are making a comment against.

Column B - Page/Tab - Provide the page number for the associated document or tab label for Excel documents Column C - Section/para/Cell - Provide the section/paragraph for pdf documents or cell for Excel documents Column D - Text - Provide the applicable text taken from the respective document Column E - Comments - Provide all comments, questions, and suggestions Column F - Rationale - Provide any rationale/reasoning for the comment or suggested change

Comments

DocumentPage/TabSection/Para/CellTextCommentRationaleFAA Response
Draft SIR7C.1, Paragraph 2They maintain FAA Order 1050.1F (Environmental Impacts: Policies and Procedures)Please change to the latest version, 1050.1G.This is the current order as 1050.1F has been cancelled.This will be corrected in the final SIR.
Draft SIR13C.3.4, Paragraph 7and AJP’s National Airspace Performance Analysis Capability (NASPAC)Please also reference more modern NAS simulation tools than NASPAC like ANG-B7's "System Wide Analysis Capability" (SWAC) or AJR-G's "SIMCORE", which has been derived from NASPAC but has involved significantly more recent FAA investment and modernization.The FAA should reference the current state-of-the art tools and leverage recent FAA multi-year investments and simulation tool modernization to save money and improve results during contract execution.Tools listed are examples and not intended to be an all-inclusive list. Current text will be revised in the final SIR to state: "The Contractor must be able to support the maintenance and enhancement of current models."
Draft SIR13C.3.4, Paragraph 8such as TAAM, ACM, Runway Simulator, etc.Please also reference more extensively used models such as the FAA's ADSIM+ and SIMMOD.The FAA should reference the current state-of-the art tools and leverage recent FAA multi-year investments and simulation tool modernization to save money and improve results during contract execution.Tools listed are examples and not intended to be an all-inclusive list. Current text will be revised in the final SIR to state:"...using operational data and current airport models."
Draft SIR113L.15The POCs for the Government information are: "1. … 2. …"Please update or remove one of the POCs.The 2 POCs are currently exactly the same.The duplicate will be removed in the final SIR
Draft SIR114L.16.(e) Table L-1Please clarify the required file extensions.Table L-1 indicates that volumes I, II, and V should be "Microsoft Word"; however, the specified file extension is PDF. Should the file format for volumes I, II, and V be Microsoft Word (DOCX) or Adobe Acrobat (PDF)?The final SIR will be revised to specify the format submitted to be in PDF .
Draft SIR115L.15L.15 VOLUME I (TECHNICAL) INSTRUCTIONS FOR PROPOSAL PREPARATIONPlease change the Section number to L.17 instead of L.15 and renumber subsequent sections.The previous section was numbered L.16.The final SIR will correct this numbering typo.
Draft SIR119L.18, Paragraph 2Regarding the estimated hours filled into Attachment L002, the FAA is under no obligation to order in accordance with the estimated hours as these are used for evaluation purposes only.Please remove this text.There are no estimated hours in L002, and paragraph M.4.(d) says: "The FAA cost model is not planned for release to Offerors." So we would not expect to see estimated hours in L002.Agree, this statement will be removed in the final SIR.
Draft SIR125M.4.aFor Volume I Technical, the FAA will assign strengths, weaknesses, risks, and deficiencies (see Section M.6) to each of the technical subfactors. The FAA will then assign an adjectival rating (per Section M.5) to each technical subfactor. These three subfactors are considered of equal importance.Please change to the following wording or something similar:
For Volume I Technical, the FAA will assign strengths, weaknesses, risks, and deficiencies (see Section M.5) to each of the technical subfactors. The FAA will then assign an adjectival rating (per Section M.5) to each subfactor 1 technical element. These seventeen elements are considered of equal importance.The current language is inconsistent with other text in the document.The final SIR will correct lead-in reference to three subfactors (should be two) , delete the statement "three subfactors are considered of equal importance" that conflicts with - "Factor 1: Technical – consisting of the following two (2) Subfactors (Subfactor 1 is considered more important than Subfactor 2)" and to correct under Subfactor 1 "the following Sub Factors which are all considered of equal importance:" to cite "Elements" not "Sub-Factors".
Draft SIR128M.4.cVery Relevant - Present/past performance effort involved essentially the same scope and magnitude of effort and complexities this solicitation requires.Please consider changing "essentially the same" to "very similar".The current definition of "Very Relevant" will give the incumbent an unjust advantage in the competition, since it is likely that past performances that are not on the incumbent PEARS II contract may be only be rated as highly as "Relevant". Using "very similar" in the definition for the "Very Relevant" score would be consistent with the current use of "similar" in the definition for the "Relevant" score.These definiations are considered appropriate as stated. No change is considered necessary.
Draft SIR129M.4.cOfferors will be given the opportunity to address any negative performance information resulting from past performance assessment inquiries.Please remove this text or add additional text to explain how is this process will work.We have never seen this opportunity be provided in other FAA RFPs. It would likely only help offerors with negative performance evaluations which should not be the FAA's goal. The process is not explained in the Draft SIR to the same level of detail as other adjudication topics.This text will not be removed. This provision is in accordance with AMS Guidance T3.2.2.3, Section 2, Past Performance, c. Evaluating Past Performance, (4) Disclosure of negative Information and (5) Evaluating Disputed/Negative Information. See: https://fast.faa.gov/PPG_Procurement_Guidance.cfm
Draft SIR130M.4.dThe FAA cost model is not planned for release to Offerors.What is the basis for the FAA's hour distribution? If it is PEARS II then that is unfair to non-incumbents.ClarityThe basis was determined from historical data and future projections.
J002 LCATsAllAllFor all labor categories: "Associate: Required degree +1 year of relevant experience"Please consider adding "Years of academic course work in a major field of study that is directly applicable to the project assignment may be counted towards the experience requirement." to the Substitutions column for the Scientist…, Computer Scientist…, and IT Analyst... labor categories.There is no way for someone right out of school (Bachelors + 0 years of relevant experience) to fit in the current labor categories, which will unnecessarily restrict the population available for FAA's consideration and reduce the winner's ability to most efficiently staff any resultant Task Orders.Your recommendation is noted, however, the FAA believes relevant experience will be required for all labor category levels to successfully perfom the required taskings.
L002 PricingAttachment L-1BRows 29 - 49Please provide more instructions for the "Other Contractor Site" billing rates, which are not mentioned in he current "Tab 1 Instructions". Is this meant to be an additional set of rates covering anyone not in DC? How are staff in multiple locations other than DC be handled?ClarityThe final SIR will be revised to specify Governmment and Contractor site rates for all categories and levels.
L002 PricingAttachment L-1CRows 8 - 10Please remove or clarify the purpose for including cells for fringe, labor, and other overheads .These are not relevant for the anticipated T&M or FFP Task Order awards mention in the Draft SIR.The final SIR will remove this pricing requirement
Draft SIR113-115L.16Table L-1 and associated text instructionsWe recommend a phased approach with advisory downselects to support this requirement.Phased approaches with advisory downselects reduce acquisition burden on both government and industry. According to the Deltek 2025 Clarity report, 57% of government contractors planned to use AI to develop text for proposals and RFIs in 2025, up 16% from the previous year. With the advent of AI and tools to auto-generate proposal content, the number of vendors confident enough, despite lack of history of performance or technical competency, to ‘play the numbers game’ by submitting proposals in greater volumes may increase. This is likely to occur for most requirements, creating a situation where FAA is inundated with proposals that they must evaluate in full unless phases are included, significantly reducing evaluation time.The SIR's acquisition strategy is considered appropriate without any recommended changes.
Draft SIR117-119L.17Section L.17 - entireWe recommend FAA make prior experience the Phase 1 requirement in a phased procurement and use targeted evaluation criteria to obtain maxmium value for the acquisition process from the information provided by offerors. Technical, Management, Price, and Other Proposal Documentation can comprise Phase 2.A phased acquisition approach with advisory down-selects to reduce burden on FAA and industry as well as mitigate protest risk. To efficiently and accurately narrow the pool of vendors, Booz Allen recommends FAA use acquisition best practices and deploy a ‘targeted evaluation criteria’ strategy for Phase 1, instructing offerors that they must provide demonstrated experience in specific areas. This approach enables FAA to quickly assess Offerors on elements that are significant differentiators, improving efficiency in evaluation time.The SIR's acquisition strategy is considered appropriate without any recommended changes.
Draft SIR130M.4(d)The FAA reserves the right to perform price realism in accordance with AMS Guidance T.3.2.3. The FAA reserves the right to conduct cost analysis if necessary to ensure a fair and reasonable price and to support the price realism analysis. This may require the FAA to request additional information from the Offerors.We recommend FAA insert the following additional language into the price realisim paragraph: “The Government reserves the right to reject any proposal that reflects an inherent lack of technical competence or a failure to comprehend the complexity and risks required to perform RFP requirements due to submission of a proposal that is unrealistically high or low in price and/or unrealistic in terms of technical or schedule commitments.”The GAO has made it clear that this language will be upheld in any protest in favor of the government as it provides offerors notice their entire offer may be rejected solely on this basis. Including this language therefore reduces protest risk.This recommended change is not considered necessary.
Draft SIR and L002 Pricing119 and 130L.18 and M.4(d)L.18- "Regarding the estimated hours filled into Attachment L002, the FAA is under no obligation to order in accordance with the estimated hours as these are used for evaluation purposes only." M.4 - "The FAA cost model is not planned for release to Offerors."As currently drafted, L002 does not have any hours. We recommend this attachment continue to not have any hours per the referenced language from M.4(d), and that any LOE used in evaluation not be shared with offerors per acquisition innovation best practices found at PTAI. Providing offerors with the LOE for rates evaluations in IDIQ's enables gamesmanship; offerors will purposely underbid high LOE labor categories to get price down.
https://acquisitiongateway.gov/periodic-table/resources/4934?_a%5Eg_nid=12135
L002 will be revised in the final SIR to require Contractor and Government site rates for all labor categories and levels, no estimated hours will be included.
Draft SIR and L002 PricingTAB L1-CB.3Requirement to provide indirect rates in Tab L1-C; also B.3 - "The types of TOs issued against this contract may include TOs of a Fixed-Price or Time and Material contract type."We recommend tab L1-C be deleted entirely.The IDIQ contemplates T&M and FP task orders only; there is no need to examine contractor indirect rates as the contractor prices are fixed on either a deliverables or hourly basis and are not subject to increase or decrease due to shift in cost. This tab adds additional steps in the evaluation process that add to FAA evaluation burden without providing additional value.The final SIR will remove this pricing requirement
Draft SIRPart IV – LL.20 Small Business Size Standard“The North American Industry Classification System (NAICS) code for this procurement is 541330 Engineering Services - Contracts/Subcontracts Under NEPA 1992. The size standard exception under this code is $47.0 Million.”Please confirm the planned competition approach: Full & Open, Small Business Set‑Aside, or Total Small Business under NAICS 541330 (NEPA 1992; $47.0M).Has FAA determined the competition approach (Full & Open, Small Business Set‑Aside, or Total Small Business) under NAICS 541330 (NEPA 1992; $47.0M)? Recommendation (to document the decision): Add a sentence in Section A or L.20 stating the selected competition type (e.g., “This procurement will be competed as a [Full & Open / Small Business Set‑Aside / Total Small Business] acquisition.”). Impact if unchanged: Uncertainty on competition type drives teaming and pricing risk for small businesses and may delay formation of compliant, competitive teams.The SAM posting provides this information. It will be a Total Small Business Set-Aside.
Draft SIRPart IV – LL.17 Volume III (Past Performance)“The Offeror must provide information to demonstrate the Offeror’s corporate experience on four (4) previous and/or current Federal Government contracts or subcontracts of similar size, scope, and complexity… No more than one of these examples may be performed by the Offeror’s teammate (subcontractor).”Request revising L.17(a) for small-business primes: require at least one (1) relevant project from the small-business prime; permit the remaining up to three (3) to come from proposed first‑tier subcontractors, mentor‑protégé/JV members.Please confirm FAA’s intent to require all four projects from the prime (with only one teammate example permitted). Recommendation (small‑business construct): For small‑business primes, require at least one (1) recent/relevant project from the small‑business prime; allow the remaining up to three (3) to be provided by named first‑tier subcontractors, mentor‑protégé entities, or JV members. Suggested redline to L.17(a): “For small business prime Offerors, at least one (1) example must be performed by the Offeror; the remaining examples may be performed by proposed first‑tier subcontractors, mentor‑protégé participants, or JV members named in the proposal.” Impact if unchanged: At the $47M size standard, limiting team credit to one teammate example materially narrows otherwise qualified small‑business competition and reduces teaming flexibility.L.17, M.4 and L002 will be revised to require three (3) examples of current contracts or subcontracts. Of these, no more than one may be performed by an Offeror's teammate (subcontractor).
Draft SIRPart IV – LL.17 (Recent/Relevant definitions)“Recent is defined as performance that is currently ongoing or completed within the 36 months from the release date of this SIR.”Consider extending recency to 60 months or allowing older but highly relevant projects with substantiation.Please confirm whether “recent” must be within 36 months for every example. Recommendation: Extend recency to 60 months, or allow older but highly relevant examples with substantiation (e.g., same scope/complexity and current team members). Suggested redline to L.17(b): “Recent is defined as ongoing or completed within 60 months of SIR release; the FAA may consider older efforts if the Offeror demonstrates high relevance and continuity of key personnel/capabilities.” Impact if unchanged: Many relevant FAA/DOT efforts fall just outside 36 months; modest flexibility preserves rigor while enabling robust small‑business participation.Confirmed, 36 months remains the requirement.
Draft SIR118 and 128L.17 (118) and M.4 (128)Currently requires 4 Federal contracts of similar size/scopeShould allow state/local government and commercial contractsSmall businesses perform these services for various entities and agencies. MITRE, BOEING, Port Authroities, Airports. This is way too restrictive and negates how much the governmetn can gain with small business help and competitionRefer to the response to Question no. 22.
L001 PPQ118 and 128L.17 (118) and M.4 (128)Requires only contracts as PRIMEShould accept subcontractor experienceSubcontractor experience is also important here. A company can provide great success with subcontracting experience and PP. Perhaps one pastperformance as prime and rest can be as a subcontractorRefer to the response to Question no. 22.
118 and 128L.17 (118) and M.4 (128)36-month recency requirement may be too limitingThis is too limiting for small businesses. Pretty much negates any small business trying to compete36 months is too restrictive. Normally past performances are valid and used for upto 5 years and more in some casesRefer to the response to Question no. 23.
118 and 128L.17 (118) and M.4 (128)Only 1 of 4 past performance examples can be from subcontractorShould allow for more flexibility given the number of successful businesses support the line of businessesWould help government choose the best qualified team and not the best qualified singular companyRefer to the response to Question no. 22.
M.4CBased on the above we are requesting the FAA to reevaluate its requirements entirely on the past performance section. If the FAA wants competitive and all encompassing proposals that are innovative and meaningful that look forward then the FAA should allow small businesses to compete for this procurement. As written there may be 1 or 2 small businesses that can do this work:The FAA has always been pro small business and this is a perfect procurement to continue that trend. We ask the FAA to review these requirements as without the recommended changes small businesses will not be able to put forth a competitve proposal and we know that is not the FAA's intent. This is why eFAST is probably the best avenue to compete this requriement unless highlighted changes are considered.Refer to the response to Question no. 22.
Request adding language explicitly accepting past performance as a subcontractorRefer to the response to Question no. 22.
Allow state, local government, and commercial contracts as relevant experienceRefer to the response to Question no. 22.
Consider reducing from 4 to 3 required examplesRefer to the response to Question no. 22.
Expand recency from 36 to 60 monthsRefer to the response to Question no. 23.
L.17Similarly any updates to section M.4c and L.17 will require updates to the PPQ instructions:Refer to the response to Question no. 22.
Add: "Past performance may include experience as a prime contractor OR subcontractor"Refer to the response to Question no. 22.
Add: "Relevant contracts include Federal, state, local government, and commercial contracts"Refer to the response to Question no. 22.
Clarify what makes commercial/state/local contracts "relevant"Refer to L.17 for the definition of "relevant"
Draft SIR114Section L.16, Table L-1"Volume I (Technical) 34 pages maximum"Technical proposal page limit of 34 pages is insufficient to adequately address 17 distinct SOW elements (C.3.1 through C.3.17). This allows approximately 2 pages per complex technical element. Recommend increasing to 68 pages (4 pages per element) OR allowing separate sub-limits per major SOW category (e.g., 20 pages for modeling/analysis, 10 pages for policy support, etc.).Each SOW element requires demonstration of both technical approach and understanding of complex requirements. Elements like C.3.4 (Modeling and Analysis) involve multiple tools (AEDT, ANOPP, NASPAC, GIS), data sources (ASPM, ETMS, TFMS), and methodologies requiring substantive explanation. Current limit forces superficial responses that don't enable meaningful differentiation or evaluation. Based on experience with similar aviation environmental RFPs, 3-4 pages per element is standard for adequate technical depth.Your recommendation is noted and the FAA may revise the proposal requirements in the final SIR.
Draft SIR118Section L.17(a)"4 previous and/or current Federal Government contracts or subcontracts of similar size, scope, and complexity"Clarify whether "Federal Government contracts" includes: (1) State/local government aviation environmental work, (2) Airport authority contracts, (3) International government organizations (e.g., ICAO, EUROCONTROL), (4) Federally-funded work performed under commercial prime contracts. Much highly relevant aviation environmental work is performed for state DOTs, metropolitan airport authorities, and international aviation organizations.Aviation environmental expertise is often developed through state/local airport environmental assessments, state aviation system planning, and international aviation policy work that may not be direct federal contracts but involves identical technical requirements (NEPA/state equivalents, noise modeling, emissions analysis, etc.). Excluding this work may eliminate highly qualified firms with extensive relevant experience. Recommend either expanding definition or creating separate evaluation credit for "relevant non-federal work."Refer to the response to Question no. 22.
J002 LCATs1Scientist/Engineer/Systems AnalystAnalyst"Minimum Education: Bachelor's degree in science, mathematics, engineering, environmental studies (or related subjects)"Degree field restrictions may exclude highly qualified aviation environmental professionals. Many senior practitioners have degrees in aviation management, public policy, geography, urban/regional planning, or atmospheric sciences—all highly relevant but not explicitly listed. Recommend adding "or demonstrably related field as determined by contracting officer" with examples including: aviation management, public policy, atmospheric sciences, geography, urban planning, and natural resource management.Aviation environmental work is inherently interdisciplinary, requiring expertise in acoustics, air quality, policy analysis, spatial analysis, and systems thinking. Overly restrictive degree requirements may eliminate qualified talent, particularly experienced professionals who entered the field when "environmental studies" programs were less common. Similar FAA contracts (e.g., JPDO, NextGen environmental analysis) have recognized broader degree fields.The J002 LCAT document and associated pricing schedule L002 will be extensively revised in the final SIR and will be more closely alligned with the PEARS II LCAT.
J002 LCATs2-JanAll CategoriesVarious education substitution policies across labor categoriesInconsistent education substitution policies across labor categories create confusion. Scientist/Engineer category states "No education substitution for Ph.D. category" while Computer Scientist/IT Analyst allows "relevant experience without degree or certification is considered." Recommend harmonizing policies OR providing clear rationale for differences in FAA's technical requirements memo.Inconsistency suggests policies were copied from different source documents without integration. This creates potential disputes during performance when task orders require cross-functional teams. For example, environmental modeling work (SOW C.3.4, C.3.11) requires both Scientist/Engineer AND Computer Scientist skillsets—different substitution rules for same work creates inequity.Refer to the response to Question no. 39.
Draft SIR128-129Section M.4(c), Past Performance"Recent is defined as performance that is currently ongoing or completed within the 36 months from the release date of this SIR"36-month "recent" definition may exclude highly relevant major aviation environmental contracts. Large-scale aviation environmental contracts typically span 5-7 years. A contract completed 42 months ago may be more relevant than a small support contract completed 30 months ago. Recommend: (1) Extend "recent" to 60 months, OR (2) Allow 60-month lookback for contracts with original period of performance >3 years, OR (3) Allow older contracts if they demonstrate unique/critical capabilities unavailable elsewhere.Example: A firm that completed a 6-year, $30M aviation environmental modeling contract 4 years ago would be excluded, while a firm with a 1-year, $500K contract completed 2.5 years ago would qualify as "recent." This doesn't reflect actual capability or relevance. Industry standard for A&E past performance is typically 5 years (per FAR 36.6 Brooks Act procedures and QBS guidelines).Refer to the response to Question no. 23.
Draft SIR125-127Section M.4(a), Factor 1, Elements T1-T17"The following Sub Factors which are all considered of equal importance" (referring to Elements T1-T17)All 17 technical SOW elements stated as "equal importance" does not reflect realistic contract work distribution and may distort evaluation. Elements like T4 (Modeling & Analysis), T3 (Noise), T2 (Emissions) likely represent 50-60% of contract value, while T13 (Knowledge Management), T16 (User Support) are supporting functions. Recommend: (1) Identifying 6-8 "core" elements and 9-11 "supporting" elements with different evaluation weights, OR (2) Providing estimated percentage of historical PEARS II work per element to guide proposal focus.Equal weighting incentivizes offerors to allocate proposal space equally across all elements, but this doesn't reflect performance priorities. It also makes evaluation difficult—how does evaluator weight strength in critical modeling capabilities vs. strength in conference support? Additionally, offerors cannot make informed teaming decisions (which elements require subcontractor specialists vs. prime staff) without understanding relative importance. This information would improve both proposal quality and evaluation validity.Refer to the response to Question no. 37.
Draft SIR12-13, 15-16SOW C.3.4, C.3.11"Multiple modeling tools referenced: "AEDT, ANOPP, AAM, RUMBLE, NOISEMAP, TAAM, ACM, Runway Simulator, ASPM, ETMS, TFMS, PDARS, NASPAC, GIS"Numerous specialized modeling tools and data systems referenced throughout SOW but unclear which require demonstrated prior experience vs. ability to learn during performance. Some tools (AEDT, NASPAC) are FAA-proprietary with limited external access. Others (TAAM, GIS) are commercial off-the-shelf. Recommend categorizing tools as: (1) MANDATORY prior experience required, (2) DESIRED prior experience (evaluated favorably), (3) TRAINING PROVIDED (contractor will learn during performance).This directly affects: (1) Teaming decisions—if AEDT expertise is mandatory, firms must team with current AEDT users; (2) Staffing approach—must identify personnel with specific tool experience; (3) Evaluation—how do evaluators assess proposals without knowing which tools are weighted more heavily; (4) Pricing—learning curves affect labor hours. FAA-proprietary tools like AEDT and NASPAC cannot be learned or practiced outside FAA contracts, creating barrier to entry that should be explicit. Commercial tools can be learned pre-award.Tools and data sources listed are examples and not intended to be an all-inclusive list. Specific requirement will be project dependent.
Draft SIR22Section F.6"Place of performance will be at the contractor site"Statement "contractor site" contradicts extensive SOW requirements for on-site FAA support and creates ambiguity for staffing/pricing. SOW clearly requires: (1) Attendance at ICAO CAEP meetings internationally (C.3.1), (2) Support at FAA HQ and regional offices (throughout), (3) Airport site visits for environmental assessments (C.3.5, C.3.6), (4) Conference planning and participation (C.3.17), (5) Technical Operations facility support (C.3.7). Recommend revising to: "Place of performance will be at contractor facilities and FAA/other government facilities as required by individual task orders" and providing estimated percentage breakdown from PEARS II historical data (e.g., 60% contractor site, 30% FAA HQ/regional, 10% travel to airports/meetings).Accurate place of performance description affects: (1) Geographic staffing requirements—need local staff in DC area for frequent on-site support, (2) Cost estimation—on-site work typically includes higher labor rates for DC metro area, (3) Travel budget—unclear what's "travel" vs. "place of performance", (4) Security clearances—extent of FAA facility access determines security processing needs and timeline, (5) Small business participation—local vs. remote work affects teaming opportunities. Current language creates risk of protests if contractor assumes remote work but FAA expects on-site presence.The final SIR will state: "Place of performance will be at Contractor or Government sites, as specified in the task order". Historical data is not considered necessary as the work site assignments will depend on the nature of future requirements that may be different from priosr efforts.
Draft SIR10Section C.2.5"Additional security clearances may be needed for specific Task Orders. Candidates identified for performance under those Task Orders must hold or be eligible to obtain the requisite security clearance."Provide historical data on percentage of PEARS II staff requiring security clearances, typical clearance levels (Secret, Top Secret, SCI), and average processing timelines. Also clarify: (1) Does FAA pay for clearance processing or is it contractor cost? (2) What percentage of anticipated work requires cleared personnel? (3) Are there unclassified alternatives if clearance processing delays critical tasks?Security clearances have significant cost and schedule impacts: (1) Secret clearance processing currently averages 6-12 months, Top Secret 12-18 months per DCSA metrics, (2) Clearance investigation costs $3K-$15K per person, (3) Maintaining cleared personnel requires higher compensation (10-20% premium typical), (4) Small businesses may not have existing cleared workforce. Without guidance on anticipated clearance needs, offerors cannot: accurately price contracts, develop realistic staffing plans, or assess their ability to perform. If >25% of staff need clearances, this should be evaluation factor.The final SIR will remove this requirement.
Draft SIR35Section H.6"Key Personnel and/or facilities may be designated on a TO basis in accordance with AMS Clause 3.8.2-17"No indication of which positions (if any) will be designated as contract-level Key Personnel requiring evaluation in proposal vs. TO-level designation. Typical contracts of this size/complexity designate Program Manager and 1-3 technical leads as Key Personnel. Recommend: (1) Identifying contract-level Key Personnel positions requiring resumes in proposal (suggest: Program Manager, Technical Director, Lead Environmental Analyst), (2) Specifying if the 4 senior staff resumes in Volume I (Section L.15) are intended to be Key Personnel, (3) Clarifying substitution procedures and approval timeline.Key Personnel designation affects: (1) Proposal development—must identify and commit specific individuals, (2) Evaluation—evaluators need consistent information across offerors, (3) Contract performance—Key Personnel substitutions require CO approval and may delay performance, (4) Competitive positioning—firms with strong Key Personnel want evaluation credit. Current ambiguity means offerors don't know if they're committing proposed staff or if they're generic examples. This creates potential for post-award disputes when FAA expects committed personnel but contractor treated them as representative.Key personnel resumes will be only be designated in individual task orders for future work. The final SIR will define the specifc labor category resumes.
Draft SIR118Section L.15, Volume I Instructions"4 resumes (3 page maximum each) and not included in the 34 pages limitation above"Clarify which specific positions the 4 senior staff resumes should represent. Are these: (1) Offeror's choice of 4 best senior staff, (2) Specific required positions (e.g., Program Manager, Technical Director, Lead Scientist, Lead Engineer), (3) Must cover specific SOW areas, (4) Are these committed Key Personnel or representative examples? Also clarify if same resumes can be referenced in Volume II (Management) or must be different individuals.Without position specifications, offerors will submit resumes for different roles, making evaluation inconsistent. Example: Offeror A submits PM + 3 technical leads. Offeror B submits 4 technical specialists (no PM). Both technically compliant but evaluator cannot compare apples-to-apples. Additionally, if these are intended to be Key Personnel (see H.6 comment), this should be explicit. Recommend specifying: Resume 1 = Program Manager, Resume 2 = Technical Director/Chief Scientist, Resume 3 = Lead Modeling/Analysis Expert, Resume 4 = Lead Policy/Regulatory Expert.Refer to the response to Question no. 46.
Draft SIR112-121Volume I Technical InstructionsSection HeadingsPlease update the section numbering.There are multiple sections numbered L.15 and L.16Refer to the response to Question no. 7.
Draft SIR121L.20 Small Business Size StandardThe NAICS code for this procurement is 541330 Engineering Services - Contracts/Subcontracts Under NEPA 1992. The size standard exception under this code is $47 million.Please confirm the size standard exception is $47 million.Confirmed, the NAICS code for this procurement is 541330 (Exception 2) Contracts and Subcontracts for Engineering Services Awarded Under the National Energy Policy Act of 1992 is $47M.
Draft SIR121L.20 Small Business Size StandardThe NAICS code for this procurement is 541330 Engineering Services - Contracts/Subcontracts Under NEPA 1992. The size standard exception under this code is $47 million.Are joint ventures allowed assuming that each firm individually meets the size standard?Yes, the JV is considered small only if each venturer is small under the NAICS size standard, unless a mentor-protege exception applies..
Draft SIR7C.1"They maintain FAA Order 1050.1F (Environmental Impacts: Policies and Procedures)"Please update the reference to FAA Order 1050.1G (FAA National Environmental Policy Act Implementing Procedures).FAA Order 1050.1G replaced 1050.1F.This will be corrected in the final SIR.
Draft SIR24G.2a. Contracting OfficerPlease confirm the spelling of the Contracting Officer's name and email address.It appears there is a typo in either the name or the email address.This will be corrected in the final SIR.
Draft SIR25G.6 Electronic CommunicationsThe Contractor must also ensure that the Contractor's electronic mail has the capability to receive and retrieve attachments.Please confirm maximum file size expected to be required.This will enable us to ensure we have the right systems in place.Refer to L.14 for guidance which states "Files larger than 10Mb must be split into multiple, smaller files to ensure they are received by the FAA".
Draft SIR114L.16(e)Section L.16(e) of the RFP states that each Offeror’s proposal must contain five (5) volumes, I through V, in accordance with Table L-1 (Volume I – Technical, Volume II – Management, Volume III – Past Performance, Volume IV – Pricing, and Volume V – Other Proposal Documentation). However, in Section L.4(a) on page 109, the RFP lists four volumes, omitting the Management volume (Volume II) and identifying Past Performance as Volume II rather than Volume III.Please clarify the required proposal volumes and confirm the correct volume structure throughout the SIR document.The two sections referenced in Column D of this question conflict with one another, so clarity is needed to ensure compliance.The final SIR will correct L.4(a) to list the five (5) volumes listed under L-1.
Draft SIR114L.16, Table L-1, Proposal Volume InstructionsRequired naming convention for Volume III Pricing is currently listed as "Price."Please confirm the required naming convention for Volume III (Pricing).The current instructions do not follow the naming convention used for other volumes (e.g., inclusion of the company acronym and MM_DD_YY format).Confirmed, "Price" is the Volume IV title. The naming convention will be specified as "Vol. IV Price - XXX_MM-DD-YY.excel" in the final SIR.
Draft SIR114L.16, Table L-1, Proposal Volume InstructionsNaming conventionsPlease confirm the following naming convention requirements for the three parts of Volume V as follows:

- Vol V- Exceptions_Deviations_Assumptions - XXX_MM_DD_YY.pdf

- Vol V - Contract_Documents - XXX_MM_DD_YY.pdf

- Vol V - Responsibility_Determination - XXX_MM_DD_YY.pdfMore clarity around naming conventions is needed to ensure compliance.Volume V Part 2 will be corrected in the final SIR to "Vol V- Contract_ Documents XXX__MM-DD-YY.pdf". No other changes are required to this section.
Draft SIR118L.17 Volume III (Past Performance) Instructions for Proposal PreparationThe Offeror must provide information to demonstrate the Offeror’s corporate experience on four (4) previous and/or current Federal Government contracts or subcontracts of similar size, scope, and complexity as the requirements identified in the Section C SOW.Please confirm that FAA contracts are allowed to be included in the Past Performance Questionnaires and that FAA Contracting Officers or Contracting Officers Representatives may be contacted to complete the Past Performance Questionnaire for relevant projects.Past FAA procurements have prohibited the use of FAA references.Check cross reference to #22
Attachment J001Attachment J004 - page 1Past Performance Evaluation Questionnaire InstructionsFor commercial references, send to personnel with duties similar to those for Government contracts.Please confirm that commercial (non-federal) contracts may be used as relevant projects and included in the Past Performance Evaluation Questionnaire.Section L.17 states that the Offeror must provide information on four previous and/or current Federal Government contracts. It does not state that commercial contracts and references are allowed, so there is inconsistency in the requirement.Refer to the response to Question no. 22.
Draft SIR5B.7.1(a) Billing Rates for T&M Task OrdersAttachment J001, Labor Rate Tables, specifies the fixed hourly rate that the Contractor may charge under T&M TOs under this contract. All TOs issued on a T&M basis will be subject to the labor rates set forth in Attachment J001 - Labor Rate Tables. The labor rates in Attachment J001 reflect fully burdened hourly rates for each labor category and will apply to all labor hours regardless of whether the labor hour is expended by the Contractor or by one of its subcontractors. The labor rates in Attachment J001 are fully burdened and include direct labor and all indirect costs applicable, including fringe benefits, overhead, G&A, and profit. These fixed hourly rates will apply to the Prime Contractor and subcontractors. The Contractor may elect to propose lower hourly rates on a TO-by-TO basis.B.7.1(a) refers to Attachment J001, Labor Rate Tables; however, Attachment L002 is the Labor Rate Table workbook. Should the references in B.7.1 refer to Attachment L002?No, the awarded contract will include the successful vendor's L002 renamed to Attachment J001.
Draft SIR118L.18 Volume IV (Price) Instructions for Proposal PreparationRegarding the estimate of hours filled into Attachment L002, the FAA is under no obligation to order in accordance with the estimated hours as these are used for evaluation purposes only.Estimated hours are not provided in Attachment L002 provided with the Draft SIR. Does the FAA intend to include estimated hours for each LCAT in the Final SIR?Providing estimated hours per LCAT will allow the FAA to evaluate pricing proposals consistently among Proposers.Refer to the response to Question no. 19.
Draft SIR118L.18 Volume IV (Price) Instructions for Proposal PreparationThe Offeror’s completed pricing proposal (Attachment L002) must be submitted to the FAA in Excel format.
Regarding the estimate of hours filled into Attachment L002, the FAA is under no obligation to order in accordance with the estimated hours as these are used for evaluation purposes only.Please incorporate language from B.7(a) into L.18 to make the pricing proposal instructions more clear. For example, please confirm that the proposed hourly rates for each labor category will apply to all labor hours regardless of whether the labor hour is expended by the Contractor or by one of its subcontractors. Also confirm that the labor rates proposed by the Contractor in Attachment L002 must be fully burdened and include direct labor and all indirect costs applicable, including fringe benefits, overhead, G&A, and profit.This will provide more clear instructions for the pricing proposal and improve consistency between B.7.1 and L.18.As noted in response to question no. 8 , the reference to estimated hours will be deleted in the final SIR. No further changes to L002 are considered necessary. Section B.7 notes "The fixed hourly labor rates, in Attachment J001, Labor Rate Tables, represent the billing hourly rates of the Contractor and all its subcontractors." and L002 notes the requirement for "fully burdened, direct labor rates for all Labor Categories".
L002 Pricingall tabsInstructionsThe sheets in Attachment L002 are named L-1, L-1A, L-1B, L-1CShould these be named L-002, L-002A, L-002B, L-002C? Attachment L001 is the Past Performance Questionnaire.This change would make them consistent with the Attachment filename.No change to the tab numbering is considered necessary.
L002 PricingTab 1InstructionsNo additional tabs can be added to the J001 template.Should references to the pricing workbook be Attachment L002 or J001?The Draft SIR and its attachments are currently inconsistent in how they refer to the attachment with the Labor Rate Tables.This typo will be corrected to L002 in the final SIR.
L002 PricingAttachments L-1B and L-1CYearly Labor Rate EscalationPlease consider including an allowable escalation rate.This will provide consistency among competing teams.The escalation rates are to be defined by the Offerors based on their projections.
L002 PricingAttachment L-1CAttachment L-1CPlease consider including an estimated other direct costs amount in the instructions so that all proposing firms use the same assumption related to other direct costs.Other Direct Costs are not listed in Attachment L-1C. Including them will provide consistency among competing teams.The final SIR will include FAA estimated Travel/ODC values in Section B.
L002 PricingAttachment L-1ASmall Business, Small Disadvantaged Business, Small Women Owned Business, and SDVOSBDoes the FAA have goals for Small Disadvantaged Business, Small Women Owned Business, and/or SDVOSB participation? If so, please define them.It is not clear whether goals have been set based on the way the Draft SIR is written.There are no such goals for this small business set-aside.
L002 PricingAttachment L-1BAttachment L-1BDoes the FAA intend to incorporate formulas into the pricing workbook?The instructions tab refers to formulas, but they are not included in the Attachment L001 that was provided.Yes, inflation formulas will be added to L001 labor rates that will calculate based on the Offeror's proposed yearly escalation factorw.
J002 LCATsJ002 LCATsJ002 LCATsPlease add a GIS Specialist LCAT.This was included in PEARS II and is critical to a multitude of tasks under this contract.This position is covered under the "IT Analyst category". "Geographic information systems degree", or related subject area", is included in the education list.
Draft SIR112"ITStrategy LLC"This appears to indicate that FAA has a desire for a more technical response than is indicated by Section M4(a), can FAA provide additional context on how to be responsive to such an expert review?This assumption is incorrect. The identification support service Contractor personnel is simply to inform offerors that this vendor may assist in the evaluation process, which is a standard practice. Refer to L.14 for context.
109/110L-4 a)TableThis table indicates there are 4 volumes but L-16 indicates there are 5 volumes. Please indicate which is correct?Refer to the response to Question no 54.
L001 PPQ118L.17 a)"… four (4) previous and/or current Federal Government contracts …"Recommend that the missing text result in sentence reading '… four (4) previous commercial or government contracts …'1) Text is inconsistent with text contained in L001 which allows for commercial contracts and any type of government contract, 2) Unneccesarily restrictive since incumbent firm is unable to meet this requirement (we only have two relevant federal government contracts)Refer to the response to Question no. 22.
119L.18"Regarding the estimated hours filled into Attachment L002, …"Section M.4(d) indicates that the cost model will not be released. Can FAA advise which is correct?Check cross reference to #22
L002 PricingRow 14 and 38No Substitiution for Ph.DRecommend changing this line to be Senior II categoryBy constraining these hours to Ph.Ds (with no other experience categories in the Business segment), this unneccesarily restricts eligible individuals. It is in the governments interest to have at least one additional experience level in this subject area (like was done for scientist and comp/sci labor categories)Refer to the response to Question no. 39.
Add Scientist Int 1Recommend distributing hours from Scientist Associate into both Scientist Associate and Scientist Int IUnder current PEARS II contract many hours are worked by individuals that have between one and 5 years of experience and the absence of the Int I category creates a considerable gap between the two points, requiring proposers to considerably increase rates that will be submitted for Scientist Associate.Refer to the response to Question no. 39.
Row 22 and 46Add category designation for Technical Project ManagerNo experience descriptor on this labor categoryRefer to the response to Question no. 39.
Technical Project ManagerCreate two labor categories for TPM role - one for the actually program manager and the other for the administrative staff that prepare tracking spreadsheets, processing of documents, invoicing, etc.Government can save money by allowing TPM to delegate these tasksRefer to the response to Question no. 39.
J002 LCATsTechnical Project ManagerLack of ability to substitute for missing bachelor degreeRecommend adding ability to substitue relevant experience for missing bachelor degreeProject administration is often performed by project accountants that have not received a bachelors degree - this reduces cost of having technical project manager running the project. Opportunity to produce these cost savings should be included in the labor category descriptions.Refer to the response to Question no. 39.
Draft SIRPage 13C.3.4 (Modeling and Analysis)"Design, develop, implement, and maintain computer databases for the storage and analysis of operational, environmental, and economic data."Will the FAA specify if these databases are expected to reside in a specific cloud environment (e.g., FAA Cloud Services / AWS) or legacy on-premise servers?
We recommend adding a requirement for "Cloud-Native Data Architecture" compliance to ensure scalability.The current text is vague regarding infrastructure. Clarifying this favors vendors who specialize in modern cloud migration vs. legacy server maintenance.Infrastructure type will be project dependent and specified in individual Task Order requirements.
Draft SIRPage 16C.3.11 (Software Design)"The Contractor must conduct requirements analysis, software design, software development... for environmental, operational, and economic modeling..."Does the FAA envision the use of AI/ML, Synthetic Data or Digital Twin technologies to validate these models before deployment?
Recommend explicitly including "Synthetic Data Generation"if it is a desired capability for model validation.Listing specific technology frameworks will allow contractors to be more accurate about the offer and expectations.Framework will be project dependent and specified in individual Task Order requirements.

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