11. CONTRACT ID CO~E
I
AMENDMENT OF SOLICITATIONIMODIFICATION OF CONTRACT
3. EFFECTIVE DATE
2. AMENDMENTIMODIFICATION NO.
10-Jul-2013
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6. ISSUED BY
4. REOUISITIONIPURCHASE REO. NO.
CODE
M95494-13-RC-22E38
PAGEl OF PAGES
I
1
2
5. PROJECT NO. (If applicable)
N/A
1
7. ADMINISTERED BY (/fother than Item 6)
I
CODE
S0602A
RCO Quantico
DCMA DENVER
3250 Catlin Ave
Quantico VA 22134-5001
Denver Federal Center Building 16, 6th Avenue and
Kipling Street, P.O. Box 25586
raymond.griffith@ usmc.mil 703-784-1922
Denver CO 80225-0586
8. NAME AND ADDRESS OF CONTRACTOR (No., street, county, State, and Zip Code)
I
9A. AMENDMENT OF SOLICITATION NO.
CH2M HILL, INC
9127 South Jamaica St.
9B. DATED (SEE ITEM 11)
Englewood CO 80112
lOA. MODIFICATION OF CONTRACT/ORDER NO.
[X]
NOO178-11-D-6490-MUT1
CAGE
CODE
OCAV6
lOB. DATED (SEE ITEM 13)
J
FACILITY CODE
27-Sep-2012
11. THIS ITEM ONLY APPLIES TO AMENDMENTS OF SOLICITATIONS
]The above numbered solicitation is amended as set forth in Item 14. The hour and date specified for receipt of Offers [ ] is extended, [ ] is not extended.
Offers must acknowledge receipt of this amendment prior to the hour and date specified in the solicitation or as amended, by one 01 the following methods:
(a) By completing Items 8 and t5, and returning one (1) copy 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 ACKNOWLEDGEMENT 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)
SEE SECTION G
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 tOA.
[J
[J
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).
[J
C. THIS SUPPLEMENTAL AGREEMENT IS ENTERED INTO PURSUANT TO AUTHORITY OF:
LXI
D. OTHER (Specify type of modification and authority)
Bilateral; FAR 52.217-9 and 52.243-1
] is not, [ X ] is required to sign this document and retum 1 copies to the issuing office.
E. IMPORTANT: Contractor [
14. DESCRIPTION OF AMENDMENTIMODIFICATION (Organized by UCF section headings, including solicitation/contract subject matter where feasible.)
SEE PAGE 2
15A. NAME AND TITLE OF SIGNER (Type or print)
16A. NAME AND TITLE OF CONTRACTING OFFICER (Type or print)
Marty L. LaMaster, Regional Contracts Manager
DeCarol Blocker, Contracting Officer
15B. CONTRACTOR/OFFEROR
15C. DATE SIGNED
t6B. UNITED STATES OF AMERICA
16C. DATE SIGNED
IslMarty L. laMaster
09-Jul-2013
BY
10-Ju1-2013
(Signature of person authorized to sign)
NSN 7540-01-152-8070
PREVIOUS EDITION UNUSABLE
ls/DeCarol Blocker
(Signature of Contracting Officer)
30-105
STANDARD FORM 30 (Rev. 10-83)
Prescribed by GSA
FAR (48 CFR) 53.243
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GENERAL INFORMATION
The purpose of this bilateral modification is to:
1. Update the Statement of Work and update pricing for eLINs 6001AA, 6001AB, 9002AA, and 9002AB.
2. Exercise and fully fund Option Period One (1).
A conformed copy of this Task Order is attached to this modification for informational purposes only.
The Line of Accounting information is hereby changed as follows:
The total amount of funds obligated to the task is hereby increased
CLIN/SLIN
Type Of Fund
5001AA
O&MN,N
500lAB
O&MN,N
5001AC
O&MN,N
6000AA
O&MN,N
6000AB
O&MN,N
6001AA
O&MN,N
6001AB
O&MN,N
$-
From ($)
By ($)
--- ---
To ($)
The total value of the order is hereby increased fro~ by
CLIN/SLIN
5001AA
500lAB
5001AC
6000AA
6000AB
6001AA
6001AB
----
From ($)
By ($)
To ($)
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SECTION B SUPPLIES OR SERVICES AND PRICES
CLIN - SUPPLIES OR SERVICES
For FFP Items:
Item
PSC Code
Supplies/Services
5000
To provide Labor
for ECE
5000AA R425
To provide Labor
(Base Year) in
support ECE
(O&MN,N)
5000AB R425
Optional Prepare
HQMC EMA MANUAL
(O&MN,N)
5000AC R425
Optional HQMC EMS
AUDIT (O&MN,N)
5001
To provide Labor
for ECE
5001AA R425
To provide Labor
(Option Year 1)
in support ECE
(O&MN,N)
5001AB R425
Optional Prepare
HQMC EMA MANUAL
(O&MN,N)
5001AC R425
OPTIONAL HQMC EMS
AUDIT (O&MN,N)
For ODC Items:
Item
PSC Code
Supplies/Services
6000
To provide Labor
for ODC
6000AA R425
To provide ODC
(Base Year) in
support ECE - The
Offeror shall
utilize the
government
estimate as a
placeholder for
travel as the
CLIN is
COST-REIMBURSABLE
. (O&MN,N)
6000AB R425
To provide Travel
(Base Year) in
support ECE Offeror shall
utilize the
Qty
Unit
Unit Price
Total Price
- -'- - 1.0
LO
1.0
LH
1.0
LH
1.0
LH
1.0
LH
1.0
LH
Qty
Unit
- -
Est. Cost
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government
estimate as a
placeholder for
travel as the
CLIN is
COST-REIMBURSABLE
· (O&MN,N)
6001
To provide ODC
for ECE
6001AA R425
To provide ODC
(Option Year 1)
in support ECE Offeror shall
utilize the
government
estimate as a
placeholder for
travel as the
CLIN is
COST-REIMBURSABLE
· (O&MN,N)
6001AB R425
To provide Travel
(Option Year 1)
in support ECE Offeror shall
utilize the
government
estimate as a
placeholder for
travel as the
CLIN is
COST-REIMBURSABLE
· (O&MN,N)
- -
For FFP Items:
Item
PSC Code
Supplies/Services
Qty
Unit
8002
To provide Labor
for ECE
8002AA R425
To provide Labor
(Option Year 2)
in support ECE.
(O&MN,N)
Option
1.0
LH
8002AB R425
Optional Prepare
HQMC EMA MANUAL
(O&MN,N)
Option
1.0
LH
8002AC R425
OPTIONAL HQMC EMS
AUDIT (O&MN,N)
Option
1.0
LH
Unit Price
--
For ODC Items:
Item
PSC Code
Supplies/Services
Qty
Unit
Est. Cost
Total Price
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9002
To provide
ODC/Travel
(Option Year 2)
9002AA R425
To provide ODC
(Option Year 2) Offeror shall
utilize the
government
estimate as a
placeholder for
travel as the
CLIN is
COST-REIMBURSABLE
. (O&MN,N)
Option
9002AB R425
To provide Travel
(Option Year 2) Offeror shall
utilize the
government
estimate as a
placeholder for
travel as the
CLIN is
COST-REIMBURSABLE
. (O&MN,N)
Option
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SECTION C DESCRIPTIONS AND SPECIFICATIONS
STATEMENT OF WORK
1.0 BACKGROUND
The purpose of this Statement of Work (SOW) is to provide support for the Headquarters, US Marine
Corps (HQMC) Environmental Compliance Evaluation (ECE) Program. The ECE program is used by
HQMC to monitor, ensure, and improve compliance at Marine Corps installations worldwide.
1.1 OBJECTIVES
The Objectives of this task order are as follows:
a
Conduct Active Installation ECEs;
b. Update the existing installation unique TEAM Guide software checklists as required to accomplish the
audit schedule using the Web Compliance Assessment and Sustainment System (WEBCASS);
c.
Maintain a matrix of Active Installation activities in conjunction with ECEs at active duty installations and
MARFORRES HQ;
d. Facilitate USMC transition to TEAM Guide checklists, usage of WEBCASS,and provide corrections
to checklists applicable to the USMC to include USMC policy and Environmental Management System (EMS)
checklists.
e.
Draft the HQMC response to the installations' Benchmark Plan Of Action and Milestones (POA&Ms).
2.0 APPLICABLE DOCUMENTS AND DIRECTIVES
2.1 MCO P5090.2A w/change 3- Marine Corps Environmental Compliance and Protection Manual 2.2
Navy Correspondence Manual, SECNAVINST 5216, as modified by HQMC
2.3 Marine Corps Directives System, Marine Corps Order (MCO) 5215.1
2.4 Environmental Program Management Policy (EPM-POL) checklist
2.5 TEAM Guide Checklists
2.6 Installation orders, plans, documents, permits, and records
2.7 All applicable documentation (Federal, State, Local and Final Governing Standards information) as
required in support of the Environmental Compliance Evaluation Program
3.0 REQUIREMENTS
The work to be performed under this task order involves access to and handling of material at the
unclassified level. All material developed by the Contractor during this contract shall become the property
of the Headquarters, U.S. Marine Corps. The Contractor shall be required to abide by the disclosure
standards set forth in DFARS 252.204-7000 and to complete Employee Confidentiality and
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Non-Disclosure forms. The Contractor shall not release information to regulators or the media. Any
information release shall come from USMC Government employees only. Audit reports and government
documents shall not be distributed to any external agencies except as directed by HQMC.
3.1 TASK 1: CONDUCT BENCHMARK ENVIRONMENTAL COMPLIANCE EVALUATION (BCEs)
AT ACTIVE DUTY INSTALLATIONS
The Contractor shall assist with execution of the Active Installation Benchmark ECEs per paragraph 4.2.
Planned dates for the ECE for Installation audit are annotated on the schedule. Any schedule changes shall be
effected via bilateral contract modification which can be adjusted with the concurrence of both the TOM
and the contractor.
Each ECE team will be comprised of both HQMC and Contractor personnel. The Contractor shall also
designate a Contractor ECE Team Leader for each ECE. The Contractor shall provide a team of auditors
to evaluate all ECE media areas except those media areas evaluated by the HQMC ECE Team Leader (i.e.
EPM-ECE, EPM-TNG, and EPM-POL) or supplemental HQ representatives. The Contractor ECE team
shall consist of an ECE Team Leader, EMS Evaluator, Senior Evaluators, and Evaluators (see paragraph
3.1.12). Auditors shall be selected to address specific environmental media and the need for regional
expertise appropriate to the installation. Evaluators shall normally be assigned more than one
environmental media area during the ECE. The Contractor shall identify the specific ECE team and their
respective assignments for Government approval not later than 30 calendar days before each ECE.
Site audits shall be conducted using WEBCASS (USMC) and TEAM GuidelUSMC checklists via
REGS CAN software. All required software shall be made available to the contractor for audit use.
3.1.1 Pre-ECE Coordination. Prior to conducting each ECE, the Contractor shall conduct thorough
pre-audit coordination with the HQMC Corps ECE Team Leader and the ECE Coordinator at the
audited installation. This coordination shall include identification of ECE personnel and assignments,
review of the installation's pre-visit questionnaire, review of previous ECE data, review of applicable
TEAM Guide and MCO and State specific supplements and local requirements, development of a site visit
schedule, completion of any required training, and any other logistical, administrative or security issues.
3.1.1.A ECE Questionnaire. The Contractor shall modify the existing pre-ECE questionnaire for each
Installation (Deliverable 001) to include questions regarding the EMS review and to ensure that changes to
federal, state and local regulations are properly addressed. This information shall be used to establish the
scope of the EMS review for each particular installation and determining which commands, tenants and
activities are participating in the host installation's EMS and shall be subject to the EMS review. This
questionnaire shall also allow the EMS reviewer to determine what major elements of the installation's
EMS are in place prior to the on-site phase of the ECE. The Contractor will modify the ECE
Questionnaire to include the documents and records the Installation should post to the USMC's
Environmental Management (EM) Portal prior to the ECE to allow the Evaluators an opportunity to
complete a document review (3.l.l.B) prior to the ECE. Other information in the Questionnaire includes
environmental program points of contact information, periods of non-availability during the ECE, security
and access requirements, and locations of briefings and working space for the team. The Evaluators will use
the information in the Questionnaire and the document review to coordinate with the Installation, prepare
the Work Plan in effort to prepare to conduct the ECE.
3.1.1.B Document Review. The Contractor shall review any policy, personnel, administrative,
licensing/permitting, or other documentation which the audited installation provides to the auditor prior to
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the onsite portion of the ECE via the EM Portal, similar to the "desk audit" phase of the ISO 14001
registration process. This helps to minimize down-time upon arriving at the installation, facilitates
immediate data collection at the site, and improves the overall quality of the on-site audit. The
government shall allow a maximum of 16 hours per Evaluator for pre site audit preparation time; to be
performed at contractor's site. Contractor shall maximize the use of EM Portal and document review
prior to the on-site visit to effectively plan and execute ECE field efforts.
3.t.t.C ECE Work Plan. Prior to each ECE, the Contractor shall prepare a site-specific ECE Work
Plan (Deliverable 002), and coordinate this Plan with both the Marine Corps team leader and the
installation's designated ECE coordinator. This Plan shall include: the completed pre-ECE questionnaire;
auditors' media assignments; installation points of contact for each media (including times of
non-availability); a daily schedule indicating key meetings, deadlines, and media evaluation timeframes; and
team travel, safety and logistical guidance.
3.1.2. In-Briefs and Out-Briefs. Contractor shall provide HQMC Team Lead with the Command
In-brief (Deliverable 003), a Preliminary Out-Brief (Deliverable 004) of the ECE which presents all
findings and is presented to all staff, and a Command Out-Brief (Deliverable 005). The draft Command
In-Brief shall be provided 5 business days prior to the ECE, and the In-Brief will be conducted on the first
day of the audit, the Preliminary Out-Brief will be prepared and conducted the next to the last day of the
ECE, and the Command Out-Brief shall be conducted on the last day with the draft prepared on the day
before the final briefing. The Contractor will prepare Out-Briefs that and current benchmark ECE by
finding, class, and protocol; analyzes root cause leveraging root cause assignments made in WEBCASS;
identification of highest risk findings based on ECE results; a summary of the overall health of the .
environmental management system (EMS); and provides the path forward for Installations in preparing
POA&Ms.
The Contractor shall attend both briefs as directed by the HQMC ECE Team Leader. Typically, the
HQMC Team Lead shall conduct the briefings and address general or policy-related questions. The
Contractor's team leader shall answer questions or address technical issues as directed by the HQMC, and
Contractor. The Contractor shall assist the HQMC Contractor in preparing a PowerPoint slideshow
presentation for all briefs. The out brief slideshows shall incorporate digital photographs of positive
comments and deficiencies identified during the evaluation.
3.t.3 Daily Out-Briefs. All ECE personnel shall attend daily out briefs, where they shall advise the
HQMC ECE Team Leader and installation staff of the status of their protocol evaluations, what sites/units
were visited during that day, any potential deficiencies or positive comments observed, any areas they
require assistance with, and their planned actions for the following day(s).
3.1.4 ECE Checklists. Each ECE TEAM Guide checklist contained within the 14 protocols shall be
evaluated by the contractor. The Contractor shall complete all assigned checklists during the scheduled
time period and shall review regulated facilities, activities, permits, records, and other documents
covered under their respective media areas. HQMC's goal is for the ECE Team to evaluate one-third
of applicable sites and assets (i.e., aboveground storage tanks, hazardous waste accumulation areas,
water treatment plants, etc ... ) during the ECE. The Contractor shall also interview key staff associated
with each protocol. As part of this evaluation, the contractor's team members shall review and validate
the findings identified during previous ECE which the government will provide, as well as Corrective
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Actions contained in the installation's POA&Ms. All results and recommendations shall be documented
in WEBCASS and photographed by the contractor.
Contractor members shall enter detailed information into WEBCASS for all findings. Findings may be:
Class I - A violation of applicable Federal, State, and local requirements that could result in
a Notice of Violation (NOV), a fine, or other civil or criminal enforcement action.
Class II - Not in compliance with future Federal, State, or local requirements that could
result in a NOV, a fine, or other civil or criminal enforcement action after the date the requirement
is enacted.
Class III - Failure to follow non-punitive provisions of applicable standard operating
procedures, MCO, Department of the Navy (DON) and Department of Defense (DOD)
directives, or may be caused by poor management practices.
Issues - Beyond the capability of the installation or unit to correct on its own; requires
higher HQMC coordination or intervention to resolve. Issues may include a finding common to
several installations or units that requires a higher HQMC policy change, inter-service
coordination requirements, or action on the part of other agencies external to the Marine Corps.
Repeat - Previously identified and addressed/closed [mdings which are subsequently
re-identified. The intent is to highlight problems that have not received adequate corrective action;
these findings are considered a higher compliance risk.
Management Practices (MPs) - General recommendations that promote more effective,
efficient, and safer ways to maintain environmental compliance. These may reference practices
and procedures identified at other Marine Corps or Federal installations.
Positive - An installation practice that is clearly proactive, exceeds normal standards, and is
an exemplary way of addressing environmental requirements. HQMC may use positive findings
to communicate best management practices to other installations throughout the Marine Corps.
Information entered into WEBCASS will include: identification of the installation I facility I asset, what
guidance the finding is referenced against (i.e., TEAM Guide or MCO Supplement); a summary of the
finding, detailed description, date, observed location, responsible command/tenant/unit, finding type, and
ECE Code; a verification of the regulatory citation in WEBCASS; a risk ranking (i.e., impact, likelihood,
environmental threat, regulatory risk); association of the finding with the practice and aspect inventory
information; identification of Root Cause code and preparation of root cause description and justification
(Deliverable 007); preparation of recommended Corrective Action, Preventative Action, any Pollution
Prevention recommendations. Evaluator will populate an audit log to identify the interviews, site visits, and
document reviews completed during the ECE. Findings shall be associated with their practice and aspect
from available installation PAl data. The Contractor shall also prepare an executive summary for each
protocol area against which findings are identified and will load into WEBCASS. Contractor shall enter all
findings data in time to allow a thorough review by the Marine Corps team leader and installation
environmental office prior to inclusion in the draft ECE Report (Deliverable 012). The Contractor shall
enter all information into WEBCASS by the last day of the ECE. The HQMC ECE Team Leader will issue
a draft ECE Report on the final day of the ECE and will submit to the HQMC Program Managers for their
review of [mdings. HQMC Program Managers will have five (5) business days to review findings. The
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Contractor will reconcile any comments and coordinate with the HQMC ECE Team Leader to publish the
ECE Report via WEBCASS to allow the Installation's response to findings by loading POA&Ms.
3.1.5 Digital Photography. Digital photography (Deliverable 006) is a key element of the ECE data
collection and documentation process. The Contractor will provide ditigal photo no more than 8MB and
will post to WEBCASS. The cameras shall remain in the custody of the Contractor at all other times.
ECE team members shall take digital photographs of potential deficiencies, positive findings, and other
key aspects of their respective media areas. The format and quality of the required pictures shall be
sufficient to adequately document the deficiency identified. Team members must be aware of any security
restrictions governing photography at each installation. Team members shall assign descriptive names
(using a standard notation) to all photographs and enter further descriptive information for each using a
"memo" file.
3.1.6 Contractor-Supplied Equipment. The government shall supply the Contractor with support
materials necessary to conduct the ECEs. This shall include links to WEBCASS, REGSCAN and EM
Portal shall be installed, as needed, and for overseas audits or audits where wireless internet is unavailable.
Contactor shall provide laptops with air-cards to access internet, digital cameras with flash memory cards, a
portable laser printer, one or more CD-RW drives, laptop and digital camera for use during ECEs.
3.1.7. POA&M. Installation commanders shall provide a plan of action and milestones (POA&M) to the
TOM via WEBCASS within 60 days of the respective installation ECE out-briefs. The POA&M identifies the
installation's proposed efforts to address deficiencies identified during the ECE. Contractor shall use
WEBCASS to review and comment on proposed efforts (Deliverable 008) prior to forwarding to the
HQMC ECE Team Leader.
No changes shall be made to any part of the ECE report by the Contractor. The Contractor shall
research any rebuttal comments by the installation, allow the ECE Evaluators to provide input and
explanation and then submit to HQMC for their review and comments. The Contractor shall not call the
installation staff without frrst discussing the need to call with the HQMC ECE Team Leader. These
recommended comments shall be provided to the Government for review within 45 days of the contract
notification to the contractor. Additional comments shall be entered by the contractor, and these
comments shall then be distributed by the Government, to the respective installation commanders.
3.1.8 TEAM Guide Transition Assistance. As part of the ECE, the contractor shall provide
familiarization for installation staff on the use ofWEBCASS, the TEAM Guide checklists and REGSCAN
functionality as it is applicable to the USMC. Installation training shall be coordinated with the ECE
Coordinator and may be provided by the ECE Team on a one-on-one basis with the Environmental
Program Managers to raise awareness and understanding on how to use REGSCAN and checklist features
found within the tool.
3.1.9 ECE Critiques. Installation Commanders shall provide critiques of the Contractors performance
within two (2) weeks of the ECE installation out-briefs. These critiques are sent to HQMC, via WEBCASS.
After review by HQMC, a copy of the critiques shall be provided to the Contractor. The Contractor shall
review these critiques and identify any trends or items of interest that suggest a need for Corrective
Actions (Deliverable 009). The Contractor shall brief the TOM on any recommended Corrective
actions, especially if they involve recommended changes to the existing statement of work. The
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Contractor shall document concerns and recommended Corrective action in the monthly Progress and Status
Reports in accordance with paragraph 4.3. The HQMC ECE Team Leader and TOM shall review these
recommended Corrective Actions, and give implementation guidance directly to the Contractor, to the
extent that changes to the statement of work and funding levels are not required.
3.1.10 Installation Practice Matrix. In conjunction with the ECEs, the Contractor shall associate
practices and aspects to findings entered into WEBCASS (Deliverable 010). The Evaluators will use the
information within the PAl Rating fields within WEBCASS and will select the appropriate aspect and
practice for the finding.
3.1.11 EMS Evaluation. Concurrent with each Active Installation ECE, the Contractor shall review the
status of the installation's Environmental Management System (EMS) in accordance with applicable DoD and
Marine Corps policy/guidance. This review shall include a review of EMS documentation, as well as interviews
with installation, tenant, and Contractor personnel participating in the EMS. The Contractor shall ensure
that the Contractor conducts the EMS Review. The contracts shall have applied knowledge of the
Marine Corps EMS framework and have successfully completed EMS Lead Auditor training prior to
contract start date.
3.1.12 ECE Evaluator Requirements. The Contractor ECE team shall consist of an ECE Team Leader,
EMS Evaluator, Senior Evaluators, and Evaluators. Education, training and qualifications of the
Contractor's ECE personnel are the responsibility of the Contractor. The minimum educational and training
requirements to be an Evaluator include a Bachelor's degree, eight hours of training in environmental auditing
procedures, and sufficient current knowledge of at least one ISO 1400 media checklist. More than half the
team members must possess a bachelor's degree in Environmental! BiologicallPhysical Science, Engineering,
or Management. The contractor shall have in-depth knowledge of the USMC EMS and installation EMS
implentation. The Contracting Officer may, upon written request of the Contractor, waive the education
requirements for an acceptable combination of education and experience. The Contractor for each
auditor shall have minium one year of environmental auditing experience. The Contractor Employee for
each audit shall be Senior Evaluators.
In addition to the Evaluator requirement, Senior Evaluators also require a minimum of three years of
environmental auditing experience and shall have demonstrated the technical ability to interpret and analyze
Federal, State, and Local environmental laws and regulations. In addition to Senior Evaluator requirements,
Contractor shall also have completed an EMS Lead Auditor course. The Contractor shall also perform the
Environmental Management System review.
3.3 TASK 3: ATTEND USMC CONFERENCESIMEETlNGS
The Contractor shall send one representative to one USMC-sponsored conferences or meetings per fiscal
year (meeting/working group is estimated to be no more than one week in length). The purpose of this
attendance is to ensure that the ECE Program Manager is abreast of current environmental!facilities topics.
The contractor shall be given greater than 30 days notice prior to scheduled conference dates. All travel
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costs shall be approved, in writing by the TOM, a minimum of 20 days prior to travel date.
3.4 TASK 4: TEAM GUIDE CHECKLIST SUPPORT
The contractor shall allocate 96 hours during the course of the contract year for providing
recommendations and improvements to the TEAM Guide checklists in order to ensure that USMC
environmental audit requirements are sufficiently addressed Coordination can be made through the HQMC
or directly with the Army Corps of Engineers Construction Engineering Research Laboratory (CERL) as
directed (Deliverable 011).
3.5 TASK 5: COMMON ACCESS CARD (CAe)
In order to access WEBCASS and installation information on EM Portal (usmc.mil domain), CAC cards
shall be required for assigned auditors. The contractor shall satisfy USMC Requirements Deer's
attachment # 3 to obtain CAC cards for up to 12 assigned lead auditors and shall complete necessary
administrative requirements. No more than 36 hours shall be spent to accomplish this task. Task 3 shall
be completed within 30 days from contractor award of the commencement of the contract and shall be
facilitated by the TOM.
3.6 TASK 6 PREPARE HQMC EMS MANUAL AND PROCEDURES
The contractor shall be given greater than 30 days notice prior to the execution of this task option. The
contractor shall prepare a HQ-Ievel EMS Manual and Procedures (Deliverable 013) that shall address
environmental program requirements at HQMC. The plan shall be based on USMC EMS criteria as defined
in MCO 5090.2A. The product shall be available for review within 30 days after completion of the on-site
portion, and reviewed by TOM for content. The contractor shall have 30 days from receiving HQMC
comments to make required changes to this document.
3.7 TASK 7 HOMC EMS AUDIT
The contractor shall be given no less 30 days notice prior to the execution of this task option. The
contractor shall conduct an EMS audit ofHQMC's EMS. This audit shall be conducted by two (2)
Contractor for a period of 3 days at HQMC, Washington, DC. Findings shall be entered into WEBCASS to
address non-conformances with USMC standards, deviations from the HQ EMS plan, and
recommendations and shall be available to HQMC within 30 days of the audit (Deliverable 014).
3.8 TASK 8: PROGRESS AND STATUS REPORTS
The Contractor shall deliver Monthly Progress Reports (Deliverable 015) for this contract by the 10th
of each month (addressing the previous month). The initial report shall be submitted the month following the
issuance of the contract. The Progress and Status Reports shall include the information in Section 4.3, at a
minimum.
4.0 DELIVERABLE
Number
iRef. Para ~eliverable Title
Format
Distribution
0001
~.1.l.a
~ORD
TOMffEAM
IECE
PUESTIONNAlRE
LEADER(E
~eliverable Date
~DAYS
~USINESS PRIOR
CONTRACT NO.
DELIVERY ORDER NO.
AMENDMENT/MODIFICATION NO.
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0002
3.1.1.c
rECE WORK PLAN WORD
COPIES)
TO AUDIT
TOM/TEAM
5 BUSINESS DAY
LEADER(E
IPRIOR TO AUDIT
COPIES)
0003
3.1.2
IN BRIEF
POWERPOINT
TOM/TEAM
5 BUSINFSS DAYS
LEADER(E
PRIOR TO AUDIT
COPIES)
0004
3.1.2
PRELIMINARY
OUT BRIEF
POWERPOINT
TEAM LEADER
48 HR. PRIOR TC
(ECOPIES)
COMPLETION 01
AUDIT
0005
3.1.2
OUT BRIEF
POWERPOINT
TEAM
LEADER(E
COPIES)
24 HR. PRIOR
TO
COMPLETION
OF AUDIT
0006
3.1.5
DIGITAL
PHOTOGRAPHY
WEBCASS
TOM/TEAM
LEADER
24 HR. PRIOR TO
COMPLETION OF
AUDIT
0007
0008
3.1.4
3.1.7
ROOT CAUSE
WEBCASS
DETERMINATION
RESPONSIVE POAM WEBCASS
TOM/TEAM
24 HR. PRIOR TC
LEADER
COMPLETION 01
TOM/TEAM
LEADER
AUDIT
45BUSINESS
DAYS AFTER
fNOTIFICATION
TO THE
:( IN'
0009
3.1.9
CRITIQUES
TOMRESPONSE
WEBCASS
'~ArT()R
TOM/TEAM
30 BUSNESS DAYS
LEADER(E
AFTER AUDIT
COPIES)
0010
0011
0012
3.1.10
3.4
3.5
INSTALLATION
PRACTICE
WEBCASS
MATRIX
UPDATES TO ECE WORD
TEAM GUIDE
CHECKLIST
ECEREPORT
WEBCASS
TOM/TEAM
30 BUSINESS
LEADER (
~AYS PRIOR TO
AUDIT
TOM/CTEAM
5 BUSINESS DA ):
LEADER(E
IFROM RECEIPl
COPIES)
FROM ENGINEER
TOMITEAM
5 BUSINFSS DAYS
AFTER
CONTRACT NO..
DELIVERY ORDER NO.
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LEADER
COMPLETION OF
ECE
OOP 3.6
iEMSMANUAL
AND
PROCEDURES
WORD
TOM/TEAM
LEADER
(2 COPIES)
001~
3.7
001 ~ 3.8
30 BUSINESS
DAYS NOTICE
EMS AUDIT
WEBCASS
TOM/TEAM
LEADER
TBD
MONTHLY
STANDARD
TOM/TEAM
LEADER
lOTII OFEACH
PROGRESS
REPORTS
CONTRACTOR
FORMAT
FOLLOWING
(ECOPIES)
MONTH
The majority of deliverables are tied to specific calendar events vice number of workdays from
commencement of this SOW and as specified in the ECE Schedule
4.1 GENERAL GUIDENCE
a. The schedule for all deliverables shall be presented and maintained as part of the Monthly Status Reports
submitted to the Government and updated as required to assist both the Government and the Contractor in
program management of this contract.
b. All deliverables shall be provided in electronic media using WEBCASS, Microsoft Office or Adobe
Acrobat (.pdf) format as may be directed by the TOM.
c. All publications and support materials shall be prepared in accordance with MCO P5215.1 (Marine
Corps Directives System) and the Navy Correspondence Manual as modified by HQMC (provided as GFl).
Delivered in both electronic form and "camera ready" formats as required.
d. The ECE report will be prepared using WEBCASS. It shall consist of the following sections as a minimum:
(1)
Executive overview prepared by the Marine Corps and Contractor's ECE Team Leader, not to exceed
four pages;
(2)
Protocol executive summaries prepared by the Contractor's ECE team, three to eight sentences per
protocol, providing a management-level summary of the most significant issues;
(3)
All media specific deficiencies; and
(4)
Audit log.
e. Provide recommended Higher Headquarters comments, on the installation POA&M within 30
Calendar days of receipt from the government. WEBCASS will be used for this task.
f. Develop and maintain a matrix of all activities being conducted at active installations. Draft versions of
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this matrix may be delivered to HQMC as needed, and an Interim Final version will be delivered 30 days
after completion of each fiscal year's Active Installation Benchmark ECE.
4.2. SCHEDULE
When ECEs are scheduled to begin on a Monday the Contractor shall plan for weekend travel as
necessary. The Contractor will plan appropriately for overseas travel by coordinating with the HQMC
ECE Team Leader on required arrival and departure dates. HQMC will provide the Contractor with
specific dates upon award.
ECE Schedule Base Year (9/28/12 - 9/27/13)
San Diego, CA
MCB Camp Butler, Japan
7
~amp Mujuk, Korea
3
~CB Hawaii, HI
5 Days
5
9 Days
MCB Camp Lejeune and MCAS
New River, NC
8
15 Days
M CB Quantico, VA
6
10 Days
MWTCBridgeport, CA
4
10 Days
Blount Island Command, FL
MCAS Beaufort
4
5 Days
5
8 Days
ECE Schedule Option Year 01 (9128/13 - 9127/14)
GCC Twenty-Nine Palms
MCAS Iwakuni, Japan
6
6
10 Days
CATC Camp Fuji, Japan
3
5 Days
MCB Camp Pendleton, CA and
MCAS Camp Pendleton, CA
7
2
13 Days
8 Days
9 Days
ECE Schedule Option Year 02 (9/28/14 - 9127/15)
9 Days
6
9 Days
5
9 Days
CONTRACT NO.
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AMENDMENT/MODIFICATION NO.
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~CAS
5
9 Days
MCLB Barstow, CA
5
9 Days
MARBKs, Washington DC
3
6 Days
Cherry Point, NC
Changes to this schedule may be made with the concurrence of Contractor and the contractor. Other
timelines are specified under the requirements for each task.
4.3 PROGRESS AND STATUS
Deliver the report by the 10th of each month (addressing the previous month). The initial report shall be
submitted the month following the issuance of the contract. The reports SHALL contain the following data:
a. Complete study title and contract number.
b. Executive Summary covering the specific reporting period
c. Contract Progress Report.
I.
Objectives Covered
2. Contracting Officer's Representative
3 . Identification of Program Manager and TOM
4. Principal Contract Performers
5. Work Progress Accomplished During Reporting Period, identified by individual tasks
6. Work Planned for Next Reporting Period
7. Reports, Briefings, and Meetings During Reporting Period
8 . Problem Areas and Recommended Solutions identified by individual tasks
d. Contract Schedule Status.
e. Financial Status Report.
1.
Percent of Authorized Ceiling Funds Expended
2.
Estimated Cost to Complete Contract
3.
Direct Labor Dollars Expended by task
4.
Other Direct Cost Expenditures by task
a. Subcontractor Expenses
b. Other Costs
5.Total Funds Expended by task.
5.0 GOVERNMENT FURNISHED RESOURCES
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5.1 GOVERNMENT FURNISHED INFORMATION
The Government will provide the Contractor with all reasonable available infonnation requested concerning
this SOW and the documentation as identified in Section 2.0.
The Contractor shall protect all GFl (technical data) provided by the Government from public disclosure in
accordance with the marking contained thereon. The Contractor shall provide adequate physical or
software protection to audit infonnation stored on their IT systems so as to preclude access by any
person or entity not authorized by the Department of the Navy.
5.2 GOVERNMENT FURNISHED FACILITIES I PROPERTY
5.2.1 In perfonnance of this contract, the Contractor shall have access to a workspace at the individual
installations for the ECE team; however, the Contractor shall be responsible for supplying and safeguarding
its supplies and materials necessary in the perfonnance of this contract.
5.2.2 The Contractor shall perfonn all site work without interruption of nonnal operating business hours of
each individual installation.
5.2.3 The Government shall provide workspace for the ECE team but shall not guarantee the availability of
any supplies, equipment, or services at the installations.
6.0 TRAVEL
Site visits shall be scheduled in coordination with the schedules listed in 4.3.
6.1 All travel shall be in accordance with the Joint Federal Travel Regulations.
6.2 The infonnation shall include plan of departure of personnel and of rental cars. Notes: The Government
shall not allow costs for any less than 3 contractor employees per rental car.
7.0 Enterprise-Wide Contractor Manpower Reporting Application (ECMRA)
The contractor shall report ALL contract labor hours (including subcontractor labor hours)
required for performance of services provided under this contract for the (NAMED
COMPONENT) via a secure data collection site. The contractor is required to completely fill in
all required data fields using the following web address: https;//doncmra.nmci.nayy.miI
Reporting inputs will be for the labor executed during the period of performance during each
Government fiscal year (FY), which runs October 1 through September 30. While inputs may be
reported any time during the FY, all data shall be reported no later than October 31 of each
calendar year. Contractors may direction questions to the help desk, linked at:
https:lldoncmra,nmci.navv.mil
CONTRACT NO.
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SECTION D PACKAGING AND MARKING
P~amig'afiltt; ijl'a*ll1lfi'shaUfbe;inaccordane~:wlll;:se~fi~t1tNQf,;S~p'oi1"'MuJtrPleAward 'IOtQ
contaCt
CONTRACT NO.
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SECTION E INSPECTION AND ACCEPTANCE
E-1.1 - The resulting task order shall designate a Task Order Manager (TOM) who shall perform
inspections and final acceptance for the Government. In addition to the Contracting Officer, the
TOM, to be identified in Section G, is the only person empowered to inspect and accept work under
the resulting task order.
E-1.2 - Inspection and acceptance of all services shall be performed by the Government. Payment
shall not be made under the resulting task order for services performed without formal acceptance
by the TOM.
E-1.3 - All deliverables produced under the resulting task order shall meet applicable standards,
quality acceptance criteria, and will be accepted or rejected, in writing, by the TOM within twenty
(20) days of receipt unless a different period is specified in the task order.
E-1.4 - The TOM is accepting authority. Failure by the Government to give written notice within
twenty (20) calendar days will constitute acceptance by the Government. If rejected, the
Government will list the task order deficiencies in a letter of rejection to the contractor.
E-1.S - Task order deficiencies shall be corrected within a time period agreed upon between the
TOM and the Contractor. The deliverable will not be considered as having been accepted until
such task order deficiencies have been corrected. Deficiencies in deliverables shall be corrected at
no additional cost to the Government. If a time cannot be mutually agree upon between parties,
the Contracting Officer reserves the right to unilaterally establish a date for delivery.
CONTRACT NO.
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SECTION FDELIVERABLES OR PERFORMANCE
The periods of performance for the following Items are as follows:
5000AA
9/2812012 - 912712013
5000AB
912812012 - 912712013
5000AC
912812012 - 912712013
5001AA
9/2812013 - 912712014
500 lAB
9128/2013 - 912712014
5001AC
9/28/2013 - 9127/2014
6000AA
9128/2012 - 9127/2013
6OO0AB
912812012 - 9/2712013
6001AA
9128/2013 - 912712014
6001AB
9/2812013 - 912712014
CLIN - DELIVERIES OR PERFORMANCE
The periods of performance for the following Items are as follows:
5000AA
912812012 - 912712013
5000AB
9128/2012 - 912712013
5000AC
912812012 - 912712013
5001AA
912812013 - 912712014
500 lAB
9/2812013 - 912712014
5001AC
9/28/2013 - 912712014
6000AA
912812012 - 912712013
6000AB
912812012 - 9/2712013
6001AA
912812013 - 912712014
600 lAB
912812013 - 9127/2014
The periods of performance for the following Option Items are as follows:
8002AA
912812014 - 9/2712015
8002AB
912812014 - 912712015
8002AC
912812014 - 912712015
9002AA
9/2812014 - 912712015
9002AB
912812014 - 912712015
CONTRACT NO.
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AMENDMENT/MODIFICATION NO.
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SECTION G CONTRACT ADMINISTRATION DATA
USMC WIDE AREA WORKFLOW IMPLEMENTATION (AUG 2006)
To implement DFARS 252.232-7003, "ELECTRONIC SUBMISSION OF PAYMENT REQUEST (MAR
2007)", the United States Marine Corps (USMC) utilizes Wide Area WorkFlow-Receipt and
Acceptance (WAWF-RA) to electronically process vendor requests for payment. This application
allows DoD vendors to submit and track Invoices and Receipt/Acceptance documents electronically.
The contractor is required to utilize this system when processing invoices and receiving reports
under this contract/order, unless the provision at DFARS 252.232-7003(c) applies. The contractor
shall (i) ensure an Electronic Business Point of Contact is designated in Central Contractor
Registration at http://www.ccr.govand(ii)registertouseWAWF-RAatthehttps:llwawf.eb.mil
site, within ten (10) calendar days after award of this contract or modification. Step by step
procedures to register are available at the https:llwawf.eb.mil site.
The USMC WAWF-RA point of contact (POC) for this contract is Danielle Tulloss, and can be
reached at telephone number (703) 784-3594; email address [email protected].
The contractor is directed to use the 2-in-1 format when processing invoices and receiving reports.
When entering the invoice into WA WF-RA, the contractor shall fill in the following DoDAAC fields
or DoDAAC extensions:
The Contracting Office provides the following to assist the contractor with entering data in
WAWF-RA, as follows:
Contract Number
NOO178-11-D-6490
Delivery Order
MUT1
Cage Code/Ext
Pay DoDAAC
Issue Date
Issue By DoDAAC
M00264
Admin By DoDAAC
M00264
Ship To Code/Ext
Ship From Code/Ext
MOO088
(Normally leave Blank)
LPO DoDAAC
"Leave Blank"
Acceptor Email Address
Inspect By DoDAAC/Ext
[email protected]
571-256-2808
"Leave Blank"
In some situations the WAWF-RA system will pre-populate the "Issue By DoDAAC", "Admin By
DoDAAC" and "Pay DoDAAC". Contractor shall verify those DoDAACs automatically entered by the
CONTRACT NO.
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WAWF-RA system match the above information. If these DoDAACs do not match, then the contractor
shall correct the field(s) and notify the Contracting Officer of the discrepancy (jes). Step by step
WAWF-RA invoicing procedures for "Combo," "2-in-1," and "Cost Voucher" are available at the USMC
paperless site at http://www.marcorsyscom.usmc.mil/sites/pa/ under "Vendor Interface" section. On
the Vendor Interface page click on "WAWF-RA" header at the top of the page. Under downloads on
the WAWF-RA page that appears, click the appropriate document either "Combo," "2-in-1," or "Cost
Voucher" to download the instructions.
NOTE TO CONTRACTOR:
Before closing out of an invoice session in WAWF-RA, but after submitting the document or
documents, the contractor will be prompted to send additional email notifications. Contractor shall
click on "Send More Email Notification" on the page that appears. Add the acceptor's/receiver's
email address (Note this address is their work email address not their WAWF-RA organizational email
address) in the first email address block and add any other additional email addresses desired in the
following blocks. This additional notification to the Government is important to ensure the
acceptor/receiver is aware that the invoice documents have been submitted into the WAWF-RA
system.
NOTE: The POCs identified above are for WAWF-RA issues only. Any other contracting
questions/problems should be addressed to the Contracting Officer or other person identified in the
contract to whom questions are to be addressed.
(End of clause)
U3 -DD 250 RECEIVING REPORT SUBMISSION THROUGH WIDE AREA WORKFLOW - RECEIPT
AND ACCEPTANCE (WAWF-RA)
NOTICE TO RECEIVERS/ACCEPTORS OF SUPPLIES AND/OR SERVICES:
It is the responsibility of the receiving activity to electronically submit to DFAS through W A WF-RA the DD-250,
receipt/inspection and acceptance of supplies and/or services. Electronic submission shall be initiated no later than
7 days after receipt.
For further explanation refer to the following websites:
https://wawf.eb.mil
http://www.marcQfsyscom.usmc.miUsies/pa/receipts.asp
Technical POC: Captain Anne Braden
Email: [email protected]
Phone: 571-256-2815
TOM POC: Joanna Rockhill
Email: [email protected]
Phone: 517-256-2808
CONTRACT NO.
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AMENDMENT/MODIFICATION NO.
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Accounting Data
SLINID
PR Number
Amount
M0008812RCFE114
5000AA
LLA :
AA 1721106BSS1 251
95490
067443 2D BSS1 08812RCFE114 08812RCFEl14
Standard Number: M0008812RCFEl14
M0008812RCFEl14
5000AB
LLA :
AA 1721106BSS1 251
95490
067443 2D BSS1 08812RCFEl14 08812RCFEl14
Standard Number: M0008812RCFEl14
-
M0008812RCFE114
5000AC
LLA :
AA 1721106BSSl 251
95490
067443 2D BSSl 08812RCFEl14 08812RCFEl14
Standard Number: M0008812RCFEl14
M0008812RCFEl14
6000AA
LLA :
AA 1721106BSSl 251
95490
067443 2D BSSl 08812RCFEl14 08812RCFEl14
Standard Number: M0008812RCFE114
M0008812RCFE114
6000AB
LLA :
AA 1721106BSSl 251
95490
067443 2D BSSl 08812RCFEl14 08812RCFEl14
Standard Number: M0008812RCFEl14
BASE Funding 868124.46
Cumulative Funding 868124.46
MOD 01
M9549413RC22E38
5001AA
LLA :
AB 1731106BSSl 251 67895 067443 2D M95494 49413RC22E38
Standard Number: M9549413RC22E38
M9549413RC22E38
5001AB
LLA :
AB 1731106BSSl 251 67895 067443 2D M95494 49413RC22E38
Standard Number: M9549413RC22E38
M9549413RC22E38
5001AC
LLA :
AB 1731106BSS1 251 67895 067443 2D M95494 49413RC22E38
Standard Number: M9549413RC22E38
M0008812RCFE114
6000AA
LLA :
067443 2D BSSl 08812RCFEl14 08812RCFEl14
AA 1721106BSSl 251 95490
Standard Number: M0008812RCFEl14
M0008812RCFE114
6000AB
LLA :
067443 2D BSSl 08812RCFEl14 08812RCFEl14
AA 1721106BSSl 251
95490
Standard Number: M0008812RCFEl14
M9549413RC22E38
6001AA
LLA :
AB 1731106BSSl 251 67895 067443 2D M95494 49413RC22E38
Standard Number: M9549413RC22E38
M9549413RC22E38
6001AB
LLA :
AB 1731106BSS1 251 67895 067443 2D M95494 49413RC22E38
CONTRACT NO.
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AMENDMENT/MODIFICATION NO.
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Standard Number: M9549413RC22E38
MOD 01 Funding
CONTRACT NO.
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SECTION H SPECIAL CONTRACT REQUIREMENTS
KEY PERSONNEL
SUBSTITlITION OF KEY PERSONNEL
H-1. The Contractor hereby agrees to assign to the contract those persons whose
resumes were submitted with this proposal who are necessary to fill requirements of
the contract. No substitutions shall be made except in accordance with this section.
H-1.2 The Contractor agrees that during the first one hundred and twenty (120) days of
the contract performance period, no personnel substitutions shall be permitted
unless such substitutions are necessitated by an individual's sudden illness, death,
or termination of employment. In any of these events, the Contractor shall promptly
notify the KO in writing, and provide the information required as stated below. All
proposed substitutions shall be submitted in writing to the KO. This written notification
shall be submitted at least fifteen (15) days, thirty (30) days if a security clearance is to
be obtained, in advance of the proposed substitutions to the KO.
H-1.3 All requests for substitutions must provide a detailed explanation of the
circumstances necessitating the proposed substitutions; a complete resume for the
proposed substitute, and any other information requested by the TOM to approve or
disapprove the proposed substitution - without the KO approval, substitutions cannot
be made.
H-1.4 All proposed substitutes must have qualifications that are equal to or higher
than the qualifications of the person being replaced. The KO shall evaluate such
requests and promptly notify the Contractor of his recommendation.
H-1.5 In case of unsatisfactory contractor performance, the contractor will take
appropriate corrective action within ten (10) business days of formal notification to
correct the problem as identified by the TOM. In the event that the problem remains
unresolved in excess of ten (10) working days, the KO will be notified by the TOM so
that appropriate action is taken, to include employee removal from current contract if
warranted. The Program Manager shall ensure that all Government owned property is
returned to the TOM should a contractor employee be removed.
H-1.6 Key personnel are understood to be those four (4) individuals for whom
resumes were submitted and evaluated as part of the technical proposal submission
Example of: Key personnel are Project Manager, Systems Manager, Operations
Manager, and Database Manager.
H-1.6.1 FAR 9.505-4 (b) A contractor that gains access to proprietary information of
other companies in performing advisory and assistance services for the Government
must agree with the other companies to protect their information from unauthorized
use or disclosure for as long as it remains proprietary and refrain from using the
information for any purpose other than that for which it was furnished. The contracting
officer shall obtain copies of these agreements and ensure that they are properly
CONTRACT NO.
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executed.
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SECTION I CONTRACT CLAUSES
52.217-9 -- OPTION TO EXTEND THE TERM OF THE CONTRACT. (MAR 20(8)
(a) The Government may extend the term of this contract by written notice to the
Contractor within 30 days prior to completion of the base period; provided that the
Government gives the Contractor a preliminary written notice of its intent to extend at
least 60 days before the contract expires. The preliminary notice does not commit the
Government to an extension.
(b) If the Government exercises this option, the extended contract shall be considered
to include this option clause.
(c) The total duration of this contract, including the exercise of any options under this
clause, shall not exceed three years.
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SECTION J LIST OF ATTACHMENTS
QSAP
ECE
PASTPERFORMANCE
ECEACRE
NONDISCLOSURE_AGREEMENT
ORGANIZATIONAL CONFLICT OF INTEREST