W912HZ-16-R-0013-0002.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

This solicitation is amended to add a Questions and Answ ers section addressing vendor questions.

1. CONTRACT ID CODE PAGE OF PAGES

S 1 11

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

16C. DATE SIGNED

BY 07-Jul-2016

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 W912HZ-16-R-0013

X 9B. DATED (SEE ITEM 11)

10-Jun-2016

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 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

07-Jul-2016

CODE

ERDC CONTRACTING OFFICE

3909 HALLS FERRY ROAD

VICKSBURG MS 39180-6199

W912HZ 7. ADMINISTERED BY (If other than item 6)

4. REQUISITION/PURCHASE REQ. NO.

CODE

See Item 6

FACILITY CODECODE

EMAIL:TEL:

X 1

W912HZ-16-R-0013

SECTION SF 30 BLOCK 14 CONTINUATION PAGE

SUMMARY OF CHANGES

SECTION J - LIST OF DOCUMENTS, EXHIBITS AND OTHER ATTACHMENTS

The following have been added by full text:

QUESTIONS AND ANSWERS

QUESTIONS AND ANSWERS FOR ERDC SOLICITATION W912HZ-16-R-0013

(Answers are in Bold)

1. On the DD254, Page 2, Block 13, Ref 10g. The second sentence seems to be incomplete.

Personnel with access to NATO ATOMAL ………. DD254 has been corrected by ERDC Security

2. Section 3.6.5 states " Offeror shall identify up to seven (7) of its most relevant contracts or efforts within the past three (3) years". Is this only relevant to the Offeror or can it be a combination of the Offeror & it's subcontractors? For example (3) from the offeror and (3) from the Subcontractor. Please refer to section 3.6.5. There must be evidence in your proposal submission indicating the subcontractor is bound / obligated to support this requirement.

3. Per attachment D, there is no SCI clearance required for the employees. In sections 4.1.13 of the solicitation, it references “appropriate security clearance.” What is the required clearance? Secret. See revised DD254.

4. The Government is asking for a Transition/Phase-In Plan, “should address the Offerors approach to ensure a seamless transition with outgoing contractor.” Question: Block 4 of the DD 254 indicates this is NOT a follow-on contract; so, is there an incumbent contractor for Offeror to transition from? No. See revised Section L.

5. Can the Government provide a two year forecast of Task Order requirements (to include estimated resource requirements, project durations, start/finish dates, etc)? The sample task order PWS has been revised to include a period of performance.

6. Can the Government project the estimated resource requirements by geographical site?

This is a performance based requirement. The government does not specify the type and/or number of personnel.

7. For the past performance references, do contracts have to have been completed or can they be in-progress contracts? They can be “in-progress contracts”

8. Section L, 3.8, references that “legal documents outlining joint ventures or partnering arrangements” should be included. Does that mean copies of TAs (teaming agreements) with our subcontractors? Yes, please include teaming agreements if they are official agreements.

9. There are only three CLINs listed on the SF1449—are these for the sample task order? Are these CLINs for just one year? Was this a mistake? The SF1449 CLINs are for the BASE IDIQ. Each CLIN is for the five year level of effort. No monetary amounts are to be entered by the offeror in Section B. The government will complete Section B at time of award.

10. Are there specific years of experience or education requirements for the labor categories listed in Attachment A? Are specific qualifications up to the Offeror? Per FAR 39.104, When acquiring information technology services, solicitations must not describe any minimum experience or educational requirement for proposed contractor personnel.

11. We understand Vicksburg is Headquarters, but the solicitation references Vicksburg, Alexandria, VA, Hanover, NH and Champaign IL and paragraph 2.6 states work could include any potential Army location. What would some potential locations be? See revised PWS.

12. DD 254- SIPRNET access is required. Are we to assume that means only from a Government facility? Section 4.3 says Government provides all facilities. DD 254 (Block

10) also says we must be able to receive and generate classified material – Does this mean e-mail too? If the contractor has the capability to access SIPRNET from their facility, it can be utilized. Otherwise, SIPRNET access will be from a government facility.

This includes email. Section 4.3 of the PWS has been revised.

13. Does the OPSEC coordinator have to be on-site in Vicksburg or is the position remote?

Remote.

14. Past Performance Requirement states: To the extent that the Offeror intends to subcontract significant portions of the effort, for each subcontractor the Offeror shall identify up to three (3) of the most relevant contracts or efforts within the past three (3) years. Is this in addition to the seven (7) from the Prime? The government assumes the question is referring to Section L 3.6.5 under the technical requirement rather than the Past Performance requirement. Yes, only if relevant to this requirement and There must be evidence in your proposal submission indicating the subcontractor is bound / obligated to support the requirement.

15. Paragraph 3.6.6. Subfactor 3: Management Approach and Processes: The fourth paragraph states: For key subcontractors (defined as any subcontractor or teaming partner that will be performing more than 10% of the work), Does 10% of the work mean at the IDIQ level or task order level? IDIQ level

16. For paragraph 3.3.2 “Use of tabs and dividers is encouraged.”- Do these tabs/dividers count toward page count? No

17. For paragraph 3.4 Formatting and Page Limitations “Times New Roman font type and font size 12 for text pages”. What is the font type and font size for Tables and graphics? Font type and font size shall be appropriate for spreadsheets, charts, tables, diagrams, or design drawings. The font must be legible without electronic enlargement.

18. For paragraph 3.6.3 Introduction states “shall briefly state the purpose and content of the proposal”. Is this to be considered an executive summary? What is the page limit?

Vendors have been known to label this section as an executive summary. Please limit the Introduction to one page or less.

19. Volume III Price Proposal: ODC Cost Rate: it is unclear how we should price this or how it will be evaluated. Can Government provide clarification? See change in section M 2.3

20. Section L requires Section B to be filled out in a manner that is not set up for in the section B format provided, and how do you cost travel by Job when every task order will be different? Page 3 & 4, Section B. No monetary amounts are to be entered by the offeror on SF1449 Section B. The government will complete Section B at time of award. See amendment revised Section L.

21. Can the compensation plan be a separate document as that alone can exceed the page count for the Management Section? Page 78, section 3.6.6, last sentence.

The page limitation has been increased to 40. See revised solicitation.

22. What is the “bidding schedule” to be completed? Page 80, section 3.8, 4th bullet from the bottom of the page. No monetary amounts are to be entered by the offeror in Section B.

The government will complete Section B at time of award. The contractor is only required to complete the schedule of labor categories and rates provided in Attachment A in addition to the Sample Task Order Pricing based on rates in Attachment A. See Revised Section L 3.8.

23. If we current in SAM are we still required to complete Section K? Page 80, section 3.8, 3rd bullet from the bottom of the page. See Amendment. See revised Section L 3.8

24. Section B is not set up for what you request. How are we to provide fully loaded labor rates for all labor categories for five years in Section B? Page 80, section 3.8, last bullet.

No monetary amounts are to be entered by the offeror in Section B. The government will complete Section B at time of award. See Amendment revised Section L

25. Are all labor categories considered FTE’s and do you want fully loaded annual costs for each of the labor categories proposed? Attachment 4. Labor rates need to be fully burdened. The Task Order will be performance based on the appropriate level of effort the task order PWS. Fully burdened FFP labor rates are required per attachment A. The government made the assumption you were referring to attachment A

26. How do we cost ODC’s, which should only be travel, when we do not know the locations we will travel, how long or how frequent? Attachment 4. The government assumes this question is referring to the Price Proposal for the Sample Task Order. Please see revised Sample Task Order PWS.

27. If attachment 4 is not all FTE’s, how are you evaluating total price? Page 81, section 3.8, 1st bullet The government made the assumption you were referring to attachment A.

Please see section M.

28. Why is everything being evaluated for two years when attachment 4 is five years? Page 81, section 3.8, 1st bullet See Amendment. See revised section L 3.8.

29. How do you provide a total cost when the sample task order talks about travel to other locations? To provide a total cost, to include travel, we would need locations, approximate dates and duration, or is the travel to other locations going to be under separate task orders?

Page 81, section 3.8, 2nd bullet, Sample Task Order. See revised Sample Task Order

PWS.

30. What is the period of performance for this sample task order? See revised Sample Task Order

31. How do we cost travel IAW section L of RFP if do not have travel identified? Sample Task Order Section 2.7. The government assumes this question is related to the price proposal for Sample Task Order 0001. Travel locations have been identified in the Sample Task Order PWS. Please see revised Sample Task Order PWS.

32. How many current employees need to be transferred for this task order? Sample Task Order Section 4.2 Sample Task Order has been revised to delete section 4.2

33. In Subfactor 2: Experience the government states “Relevant corporate experience is experience (within the last 3 years) that is of the same or similar scope and complexity to the work described in the Performance Work Statement, and is of the same or similar magnitude (i.e., performing services that, on an annual basis, are at least half the dollar value proposed by the Offeror to perform the Performance Work Statement’s requirements).” When talking about the “at least half dollar value as proposed by the offeror” is the government saying that for the cited reference that at least half the work must be relevant to the USACE PWS in terms of dollar value? Or is the government saying that the cited contract must be at least half the dollar amount as the offeror proposes for the price for the USACE contract? Pg. 76, 3.6.5. $9.9M is the Government’s anticipated not to exceed capacity. However, it is not guaranteed over 5 years.

34. The experience section in the technical volume seems to be basically a past performance citation that would go in the Past Performance volume. Is the government basically asking us to recite our Past Performance twice? If not, how do the two different sections (Subfactor 2: Experience and Past Performance Volume) differ? Pg 76 3.6.5 and Past Performance volume. The Technical and Past Performance proposals are separate and will be evaluated separately in accordance with Section M.

35. When considering past performance from an IDIQ, does the government want us to treat separate task orders as separate past performances? Past Performance Volume. Past performance can be at the Task Order level or IDIQ level with the submittal of an annual appriasil for each.

36. Can you provide an estimate on the level of effort? How often will tasks 3.1 and 3.2 be executed? How many surveys of each size will be performed? PWS 3.1-3.2 Number of surveys is unknown at this time. This is an IDIQ Performance Based contract. Firm Fixed Priced Task Orders will be issued on an individual basis with specific deliverables required.

37. Will personnel be required to reside at Vicksburg, or may they reside at a corporate office in a different state? If a different state, is there still an expectation to work the core hours as specified in section 2.6, or can they work the local equivalent? Personnel are not required to reside on-site at a government facility. This contract will be performance based. Please see revised PWS

38. Is there an incumbent contractor for this work? Is the work a consolidation of work currently performed by multiple contractors? Is this new work involving no incumbent contractor? This is a new requirement. Portions of the work have been satisfied under previous contracts.

39. Are there any OCONUS places of performance anticipated? Will all work locations be on military installations or US Government facilities? There is no OCONUS work anticipated. See section 2.6 of the PWS.

40. Will the Government accept hand delivery of proposals? If so, is the delivery address for hand deliveries the same as that for mailed deliveries? Yes and Yes. Please refer to FAR 52.215-1 Instructions to Offerors for Competitive Acquisition for information concerning late proposals. Offerors are responsible for submitting proposal, modifications, or revisions, so as to reach the Government Office (ERDC) designated in the solicitation by the time specified in the solicitation. See FAR 15.208

41. We assume the instructions for the Technical Approach for both the Base Award Contract and the Sample Task refer to the specific Performance Requirements listed in PWS 3.0, i.e.,

3.1 Cybersecurity and 3.2 Security Engineering, and not the General Requirements (2.0), such as 2.6 Location and Hours of Work. Is this correct? The offeror shall demonstrate its capability to provide a sound technical approach to meet the requirements of the PWS and satisfy the needs outlined for each specific performance objective. See section L3.6.4. Please clearly define your technical approach in the Sample Task Order Proposal.

42. As the sections within Volume I have their own individual page limits, does the Government also want individual sections to be separately numbered? No.

For example:

Volume I - Technical Proposal Subfactor 1 Technical Approach – Pages 1-20 Subfactor 2 Experience – Pages 1-20 Subfactor 3 Management Approach and Processes – Pages 1-20, and so on….

43. How many PPQs may the Prime submit? How many PPQs may we submit from significant subcontractors? Do the PPQs have to be from the same contracts cited in Volume I, Subfactor 2: Experience? The offeror shall determine the number of PPQs to submit when demonstrating relevant past performance. See Section L 3.7

44. As the Base Award contract does not include any employees, we assume the requirement for contractor personnel to carry 8570.01-M certification at IAM III, IAT III and/or IASAE III levels “upon contract award” refers to upon Task Order contract award. Is this correct?

“Upon Contract Award” is the award of the Base Contract.

45. Should contractor employees be certified upon award OR within 6 months of employment?

The Government assumes the questions pertains to 8570.01-M certification. Certifications are required upon award.

46. What 8570/8140 certifications are required and for what roles? See revised PWS Section

4.1.10

47. Is there a page allocation/limit for the Introduction in Volume I? Please limit the

Introduction to one page or less.

48. Will the Government accept files in PDF and XLS format on the required CD-ROM?

Yes.

49. A comprehensive Quality Control Plan is a lengthy document and as such requires a significant number of pages to adequately respond. Will the Government allow the Quality Control Plan to be presented as a non-page constrained attachment to the proposal? The page limit for Subfactor 3 has been increased to 40. See Amendment. See revised Section L.

50. As an SDVOSB company, we find that a 30-day proposal schedule does not allow us adequate time to identify, qualify, and assemble a team of credentialed subcontractor companies. We respectfully request that the Government consider extending the proposal due date to 25 July 2016 to allow time to properly vet teaming partners. See Amendment.

See revised Proposal Due date.

51. The solicitation does not provide a baseline that allows us to determine the number of hours or percentage of work allocated to a subcontractor. Please provide a baseline of estimated hours or number of projects by size that can be anticipated for bidding purposes.

$9.9M is the Government’s anticipated not to exceed capacity.

52. The instructions do not specify the allowable page count for this requirement. What is the allowable page count to meet this requirement? Section L 3.6.3 Introduction. Please limit the Introduction to one page or less.

53. Are the List of Figures, Cross-Reference Matrix, and Glossary of Abbreviations and

Acronyms excluded from allowable page limitations? Yes.

54. Is it the Government's intent that all of the prime and subcontractor experience discussed in Volume I Subfactor 2 be addressed in Volume II - Past Performance? The Technical and Past Performance proposals are separate and will be evaluated separately in accordance with Section M.

55. Will the Government accept proposal delivery via Federal Express, UPS, courier, or hand carry for personal delivery? Yes. Please refer to FAR 52.215-1 Instructions to Offerors for Competitive Acquisition for information concerning late proposals. Offerors are responsible for submitting proposal, modifications, or revisions, so as to reach the Government Office (ERDC) designated in the solicitation by the time specified in the solicitation. See FAR 15.208

56. Is it correct to assume that the references to Section B in the RFP are references to

Attachment A-Pricing Schedule? See revised Section L.

57. Given the parallel nature of L 3.6.5 and L.3.7 requirements, may the offeror provide substantiated relevant experience beyond the three years in the past to satisfy the requirements of L.3.6.5 Subfactor 2?Relevant corporate experience is experience (within the last 3 years) that is of the same or similar scope and complexity to the work described in the Performance Work Statement, and is of the same or similar magnitude (i.e., performing services that, on an annual basis, are at least half the dollar value proposed by the Offeror to perform the Performance Work Statement’s requirements).

58. It is unclear if there is a separate requirement for two distinct past performance narratives, one in Vol I and another in Vol II, especially given that the corporate experience requirements for Vol I, per L.3.6.5, are worded as if they were a past performance requirement. The Technical and Past Performance proposals are separate and will be evaluated separately in accordance with Section M.

59. What is the difference in content requirements between the (up to 7) contracts we are required to describe in Section 2 of the Volume I – Technical Proposal (required by RFP by Section L. 3.6.5) and the contract descriptions we are required to provide to accompany the completed questionnaires in Volume II – Past Performance Proposal (required by RFP by Section L. 3.7). Please see Section L for proposal instructions.

60. Is it the Government's intent that the Offeror uses the same narratives for both purposes, except the completed questionnaire for each Past Performance narrative? Please see Section L for proposal instructions.

61. Please provide copies of the required CDRLs. This solicitation does not contain

CDRLs.

62. Please review the paragraph numbering in Attachment B. Specifically, should there be a

3.2 paragraph following 3.1? See revised Attachment B.

63. The draft DD254 indicates that access to Restricted Data (Item 10b) is required.

However, no security guidance has been provided under Item 13 of the DD254 for this access. Please provide the necessary guidance. Please see revised DD254 and Continuation Sheet

64. Security guidance under Item 13 of the DD254 provides detailed information regarding access to Non-SCI (Item 10e(2) of the DD254). However, on the first page of the DD254, when asked if the “contractor will require access to” Non-SCI, Item 10e(2) for Non-SCI is marked “no”. If access to Non-SCI is needed in support of this contract work, then perhaps Item 10e(2) should be marked “yes”. If access to Non-SCI is not needed in support of this contract work, then perhaps Item 10e(2) should be marked “no” and perhaps the security guidance reference made to it under Item 13 should be removed Please see revised DD254 and Continuation Sheet

65. The draft DD254 indicates that access to NATO Information (Item 10g) is required and provides guidance in Item 13. However, the guidance provided seems somewhat incomplete. For example, the guidance states, “Personnel with access to NATO ATOMAL”. This particular sentence stops here and starts a new sentence that discusses the government program/project manager designated representative. Should more guidance be included here for access to NATO ATOMAL or is this reference accurate as is? Please clarify. See Revised DD254 and Continuation Sheet.

66. The draft DD254 indicates that For Official Use Only Information (Item 10j) is required.

However, no security guidance has been provided under Item 13 of the DD254 for this requirement. See Revised DD254 and Continuation Sheet.

67. On the draft DD254, Items 11a, 11b and 11c are all marked “yes”. Per DSS DD254 preparation guidance for Items 11a, 11b and 11c, “only one box should be checked “yes””.

Which Item is correctly marked “yes”? Please clarify. Please see revised DD254 and Continuation Sheet

68. The draft DD254 indicates that the contractor will be performing services only (Item

11e). However, no guidance is provided in Item 13 of the DD254 that explains the services to be provided or that states the security guidance needed to perform the services. The services to be provide are identified in the PWS.

69. The draft DD254 indicates that Operations Security (OPSEC) Requirements (Item 11j) are required. However, no guidance is provided in Item 13 of the DD254 that explains the requirements. Please see revised DD254 and Continuation Sheet

70. Section L.3.8, Volume III – Cost/Price Proposal:

Bullet four states, “Labor Rates - Fully loaded labor rates must be provided for all FFP labor categories in Section B for the 5 year ordering period.”

o Bullet five states, “As part of the price evaluation, the Government will evaluate the Option to Extend Services under FAR Clause 52.217-8 by adding one-half of the offeror's final year two price to the offeror's total price. Thus, the offeror's total price for the purpose of evaluation will include all two years, and one-half of the second year. Offerors are required only to price the two years. Offerors shall not submit a price for the potential one-half year extension of services period.”

Please confirm that the fifth bullet should reflect the same five year period as is stated in bullet four. See revised Section L 3.8.

71. Section G – G.6 states “Wage determinations will be issued for particular localities with issuance of each task order.” – yet no wage determination was provided with sample task…. Please see revised Section G.

72. Section L Section 3.1 Page 81 Please clarify first bullet on this page. Option to extend is in the cost proposal so this appears to be both redundant and inconsistent. Section L 3.1 is not located on page 81. The government assumes the question is referring the first bullet on page 81 under Section L 3.8. See revised Section L 3.8.

73. Section L Page 7 Section 2.6 states “Locations of work could include any potential Army location”. Instructions in middle of page 81 instruct offeror to propose “factor” for three identified ERDC sites. Questioning whether proposed rates should just be “On-Site” Vicksburg and “Off-Site” for all other geographic locations. See Amendment. Please see revised PWS.

74. 52.216-1 Identifies type of Contract as Firm-Fixed Price IDIQ. Yet with every task order, there will be a cost CLIN for the travel. Is this correct? There will be a CLIN for travel on the task order only if there is a travel requirement.

75. Section L 3.6.5 Subfactor 2: Experience The Offeror shall demonstrate relevant corporate experience related to the evaluation criteria outlined in Section M. Relevant corporate experience is experience (within the last 3 years) that is of the same or similar scope and complexity to the work described in the Performance Work Statement, and is of the same or similar magnitude (i.e., performing services that, on an annual basis, are at least half the dollar value proposed by the Offeror to perform the Performance Work Statement’s requirements). To demonstrate its corporate experience, the Offeror shall identify up to seven (7) of its most relevant contracts or efforts within the past three (3) years, and provide any other information the Offeror considers relevant to the requirements of the solicitation. The government does not see a question, this is a statement.

76. Section M 2.2 Volume II – Past Performance The government is seeking to determine whether the Offeror has experience that will enhance its technical capability to perform and whether the Offeror consistently delivers quality products and services in a timely and cost effective manner. The government does not see a question, this is a statement.

77. Section M Subfactor 2: Experience The proposal will be evaluated to determine the degree of relevance to the requirements of the Performance Work Statement on the basis of similarity in size, scope, complexity, technical difficulty, contract type and period of performance. Only recent experience (within the last 3 years) will be evaluated. The government does not see a question, this is a statement.

78. Section L 3.7 Past Performance Proposal The Offeror shall demonstrate relevant past performance or affirmatively state that it possesses no relevant past performance. Relevant past performance is performance under contracts or efforts within the past three years that is of the same or similar scope, complexity, and magnitude to that which is described in the solicitation (as explained under the Corporate Experience subsection). The government does not see a question, this is a statement.

79. The 2 sections of section L, Section L 3.6.5 and Section L 3.7 and the corresponding 2 sections of M, Section M Subfactor 2 and Section M 2.2 are redundant. As written, the sections indicate that an identical response will satisfy both requirements. The government does not see a question, this is a statement.

(End of Summary of Changes)