BLM Quarry Aggregate RFQ Proposal Gap Analysis and Compliance Risks

Solicitation / RFQ Number

140L4326Q0002

140L4326Q0002 cited in cover letter

Covered

Contract Type

Firm Fixed Price (FFP) commercial services (FAR 12.6)

States FFP; acknowledges FAR 52.212-4(c) changes by mod

Covered

Period of Performance

7/15/2026–10/31/2026

Same dates stated

Covered

Place of Performance

Mt. Reuben Quarry; lat/long; ~24 miles W of Glendale, OR

Same location/lat-long included

Covered

Set-aside

Total Small Business set-aside; NAICS 212319; 500 employees

Affirms NAICS/size standard and SAM eligibility

Covered

Evaluation Factors

Technical Approach; Past Performance; Price

Organized by factors; separate price section described

Covered

Submission Method

Email to specified addresses (blm_or_so_952_mail@blm.gov; babecker@blm.gov)

Mentions submission response generally; does not restate exact email recipients/instructions

Partial

Two-part Quote Requirement

Non-price + price schedule Section B

States two parts and attached pricing schedule

Covered

Crush previously shot rock quantity basis

Approx. 8,000 CY shot rock; produce ~9,500 CY finished

Acknowledges moving previously shot rock; targets 9,500 CY product

Covered

Provide all labor/supervision/equipment/testing/materials

Contractor furnishes all necessary inputs

Price narrative includes all costs incl. testing, disposal/haul-off, roads, dust control

Covered

Site clearing 2 acres; remove trees/brush off-site

Clearing and off-site removal required

Commits to clearing ~2 acres; transport vegetative material off-site as required

Covered

Movement of rock to crushing site

Move shot rock to crusher

Describes feed management moving rock via loader/dozer

Covered

Crushing and stockpiling with access ways

Maintain access ways to stockpiles

Explicitly commits to access ways for inspection/sampling/loading

Covered

Restore Road 33-8-4.0 alignment if disturbed

Replace to acceptable alignment to pre-work

Acknowledges restoration if disturbed

Covered

Noise restriction for NSO habitat (200 ft) Mar 1–Jul 15

No loud noise within 200 ft during window

Acknowledges restriction; notes PoP begins Jul 15 but will treat buffer as constraint unless COR says otherwise

Covered

Contour/blend disturbed areas to natural topography

Blend/match topography in visually sensitive areas

Mentions contouring/blending in final cleanup; could more explicitly address visual sensitivity definitions (blend vs match)

Partial

Concurrent reclamation/stabilization to fullest extent

Implement during operations as feasible

Mentions erosion reduction staged; concurrent stabilization implied but not explicitly committed as ongoing during ops

Partial

Retain vegetation on cut slopes unless hazard

Vegetation retention requirement

Not explicitly addressed

Gap

Stockpiles located stable ground; drainage dispersed; erosion reduction; use topsoil for revegetation if exists

Erosion/sediment controls and topsoil medium

Addresses stable ground, drainage dispersed over vegetated areas, erosion controls (seeding, mulching, silt fences, woody debris) and mentions topsoil generally only in Site Plan depiction; not explicit about salvaging/using topsoil as medium

Partial

Water sourcing under permits; may use BLM sources with fish screening protocols

Water permits/availability verification/fish screening

Commits to obtain permits, verify availability, follow fish screening protocols

Covered

Prohibit soil disturbance in riparian areas

Strictly prohibited

Explicitly commits

Covered

Prohibit placing overburden/soil in riparian/floodplains

Strictly prohibited

Explicitly commits

Covered

Noxious weed prevention – clean equipment entering/leaving infested areas

Equipment vegetation cleaning

Explicitly commits for entering public lands and leaving infested areas

Covered

Cultural/paleo discovery stop-work and report; await written authorization

Immediate report; suspend ops

Explicitly commits

Covered

Access roads responsibility; restore damage at contractor expense

Restore access road damage

Acknowledges approach road maintenance and restoration; also references public/private road restoration in narrative

Covered

Spill response requirements; no soaps/detergents; absorbent materials on hand; notify CO/COR

Detailed spill response procedure

Covers stop source, notify, absorbents, no detergents, containment and waste handling; keep plan on-site

Covered

Stockpile sites approved by COR before stockpiling

COR approval required

States stockpile locations confirmed/approved with COR; Site Plan will depict; but could explicitly commit “no stockpiling begins until COR approval”

Partial

Prepare stockpile sites: clear vegetation/unwanted materials; uniform level area; COR approves topsoil stockpile location in advance

Preparation requirements

Addresses clearing/grade uniform stable surface; does not explicitly address garbage/plastics/boulders removal; topsoil stockpile location approval not explicitly stated

Partial

Stockpile form neat/regular; smallest feasible area

Stockpile geometry

Explicitly commits

Covered

Minimize segregation; lifts ≤3 ft unless CO-approved alternative

Segregation prevention and lift height

Explicitly states horizontal lifts not exceeding 3 ft unless alternative requested and CO approved

Covered

Government may take aggregates for maintenance any time, but not before acceptance

CO may take after acceptance of volume

States coordinate to avoid any Government use prior to acceptance unless otherwise directed; consistent

Covered

All crushed material subject to CO approval before placed on stockpile

CO approval prior to stockpiling

Draft suggests continuous QA/QC and acceptance; does not explicitly state “CO approval before placement on stockpile” (it speaks to acceptance/testing and hold areas)

Partial

Clean-up: remove evidence of operations; no spills; berms in place; riparian unaffected

Clean-up and safety berms

Commits to final cleanup; mentions berms and riparian protection

Covered

Damage repair: do not initiate before notifying CO

Notify CO prior to repair

Not explicitly stated

Gap

Slope requirement: leave ≤ 1/4(H):1(V) and comply with safety regs

Final slopes requirement

Explicitly commits

Covered

Independent testing lab approval

Lab must be approved by CO prior to production

States lab approved by Contracting Officer prior to production

Covered

Sieve analysis frequency

Min 1 per shift until compliance; then every 1,000 CY (or as approved)

Matches frequency; notes COR may approve alternative

Covered

Proctor (moisture/density relationship) test

Once at each source

Commits once at source

Covered

Test records availability

Maintain records; provide to COR/CO as requested

Commits to maintain organized test records on site available to COR

Covered

Site Plan

Submit for approval prior to mobilization; lay out activities (crushing, storage, access, drainage, fueling/resupply); 3 copies; allow 5 working days

Commits to submit prior to mobilization; provides content elements; commits to 3 copies and allows full review period; does not explicitly state 'allow 5 working days' (implied)

Partial

Safety Plan

Submit for approval prior to mobilization; appoint Safety Manager; identify nearest emergency facilities with phone; first aid supplies on site

Commits; includes Safety Manager, emergency facilities, first aid, comms

Covered

Spill & Emergency Response/Clean-Up Plan

Submit for approval 14 days prior; keep on site

Commits explicitly

Covered

Submission address

BLM Medford District Office physical address provided

Draft references BLM Medford District Office but not address; offers electronic if COR authorizes

Partial

Pre-work conference readiness

Contractor should describe outline at pre-work conference

States readiness to attend and describe layout/operational concept

Covered

Work hours limitation

½ hour before sunrise to ½ hour after sunset; no weekends/federal holidays unless COR authorizes

Explicitly commits

Covered

Access closure

No work/deliveries during closure until reopened unless instructed

Not explicitly acknowledged

Gap

Environmental interruption of work (suspend work order; no comp; time continues)

H.3.1 terms

Draft mentions fire/weather interruptions; does not acknowledge no monetary compensation / time counting during normal suspensions

Partial

Endangered species stoppage

Gov may direct discontinue if listed species discovered

Explicitly acknowledges stop-work possibility

Covered

Written work progress plan at prework conference

Provide written plan of workforce/schedule; acceptable to Gov

Not explicitly committed as a deliverable

Gap

Stop Work Order clause awareness (52.242-15)

Incorporated by reference

Discusses delays and recovery; not explicit about compliance with stop-work order process

Partial

Green procurement maximum use

Use EPA CPG/USDA biobased/ENERGY STAR/FEMP where applicable

Not addressed

Gap

52.223-1 Biobased Product Certification (offeror cert)

By signing offer, certifies biobased products used/delivered comply

Not explicitly provided as a certification statement in quote (beyond generic compliance)

Gap

52.223-2 Reporting of Biobased Products

Annual reporting to SAM.gov with CO copy by Oct 31; final report at end

Not addressed

Gap

52.223-23 Sustainable Products and Services compliance

Ensure sustainable products/services used as direct costs comply; review GPC

Not addressed

Gap

CLIN 1 Mobilization/Demobilization (LS)

Provide unit price and total; round to nearest cent

Says completed schedule attached; no numbers in body

Partial (attachment referenced, not evidenced)

CLIN 2 Site Clearing (2 ACRES)

Provide unit price and total

Attachment referenced only

Partial

CLIN 3 1 1/2 Minus Aggregate Stockpiled (9500 CY ±15%)

Provide unit price and total; acknowledge VEQ clause applicability

Acknowledges ±15%; states unit pricing fair across estimate; references VEQ clause

Covered (narrative) / Partial (pricing not shown)

No extra charges beyond quoted price

FFP; only CO mods adjust

Explicitly states no additional costs except by written modification per 52.212-4(c)

Covered

CPARS points of contact within 30 days after award

Provide name/title/phone/email for access

Commits to provide CPARS POCs within 30 days after award; protect as source selection sensitive

Covered

Protect CPARS information as source selection sensitive

Clause requires protection and internal access control

Explicitly commits to protect

Covered

IPP electronic invoicing mandatory unless waiver requested with quote

Must register/use IPP; waiver request only if unable

States will invoice via IPP and will not require waiver

Covered

IPP attachments

Invoice by CLIN; final invoice must state 'FINAL'

Explicitly commits

Covered

Means & methods / plan of work

Describe realistic plan, resources, and methods

Detailed means/methods and sequencing for mobilization, clearing, feed management, crushing, stockpiling, erosion controls

Covered

Logical sequencing with interdependencies

Include sequencing/interdependencies

Mobilize→clear→grade pad→move shot rock→crush/screen→stockpile→cleanup; identifies critical path separately

Covered

List specific equipment availability

Must list specific equipment availability

Mentions types (crushing spread, loaders, dozer, water truck, service truck, fuel containment) but not make/model, counts, availability/ownership/backup specifics

Partial

List crew(s) size and composition working concurrently

Must list crew size/composition

Mentions ‘experienced crew’, superintendent, operators, dozer operator; no headcount/roles-by-shift or concurrent crew plan

Partial

Daily production rate required

Must state daily production rate required

States baseline 600–900 CY per production day; ties to completion within PoP

Covered

Conformance to CX/Decision Record

Must comply with CX (BLM-OR WA-M070-2025-0001-CX) and Decision Record

Explicitly cites CX ID; commits to comply

Covered

Work confined to pit / approved areas

No work outside pit areas

States strictly within quarry/approved pad/stockpile areas; avoid riparian

Covered

Schedule identifying milestones

Submit a schedule with milestones

Narrative milestones described; no schedule artifact (dates/durations) included

Partial

Identify critical path

Schedule must identify critical path

States critical path: mobilization/site prep → sustained crushing → cleanup/demob

Covered

List available equipment and crew(s) size/composition

List equipment and crew(s) used

General description only; lacks explicit lists and counts

Partial

Delay recovery approach

Address how will meet completion date if delays occur

Provides recovery tactics (second loader shift within authorized window, optimize traffic patterns, maintenance timing, prioritize quality corrections)

Covered

Work Progress Plan deliverable at prework conference (Section F.2)

Provide written 'work progress plan' to COR; acceptable to Gov

Mentions being prepared to describe site layout and operational concept; does not explicitly commit to providing a written work progress plan at prework conference

Gap

Contractor QC narrative

Describe QC methods

Independent lab, process control, hold area, records availability

Covered

QC/QA interface

Coordinate with Government QA sampling/acceptance

Mentions COR coordination for acceptance, inspection access, CO QA checks; but could be more explicit on CO approval before stockpile placement and QA hold points

Partial

Decision-making when quality impacts cost/schedule

Must describe decision-making

Explicitly states compliant path default even if cost/schedule impacts; superintendent elevates for resources

Covered

Subcontractor QC control (if used)

How manage subcontractor QC if subcontracting contemplated

Addresses written expectations, daily oversight, avoid unauthorized disturbance/weed risk

Covered

Identify safety goals

Must identify safety goals

Discusses safety plan, stop-work authority, daily tailgates; does not define measurable safety goals (e.g., zero lost-time incidents)

Partial

Identify high risks & mitigations

Must identify potential high risks and mitigation

Identifies heavy equipment interaction, wildfire, spill potential; mitigations listed

Covered

Proposed staffing for QC personnel & safety manager

Must propose staffing

Names on-site Safety Manager; QC via plant operators + independent lab; does not specify dedicated QC tech/personnel counts/qualifications

Partial

Three projects within last 3 years as Prime

Provide 3 similar projects, prime, within last 3 years

Provides 3 project narratives as prime; dates are placeholders not populated

Partial

Required data fields per project

Agency, contract #, title/description & location, award date, initial/completed amount, completion date, actual completion date, final rating or reference (full contact)

Template includes all required fields but not completed (placeholders)

Partial

Final performance ratings and/or references

Must include final ratings and/or references

Includes rating placeholders and reference placeholders

Partial

Address adverse past performance and corrective actions

If adverse exists, explain corrective actions

Provides narrative that minor issues were corrected; no specific adverse instances or CPARS excerpts

Covered (general) / Partial (specifics missing)

Government may use CPARS/PPIRS/other sources

Acknowledgement implicit

Mentions CPARS access authorization

Covered

K.1 Signature extension for JV/partnership

If JV/partnership, all reps sign

Draft includes statement about providing signatures if applicable

Covered

SAM reps/certs current

Offeror to ensure SAM reps/certs current and accurate

Draft commits SAM current/accurate

Covered

52.204-24 / 52.204-26 covered telecom representations

Boxes/representations may need completion if not in SAM annual reps

Not included in draft response text (may be in SAM; not evidenced)

Partial (evidence missing)

52.209-11 delinquent tax/felony (corporations) representation

Complete if applicable / as required

Not included

Partial (evidence missing)

52.203-98 internal confidentiality agreements representation

Representation by submission

Not included explicitly

Partial (likely via SAM; not evidenced)

52.223-1 biobased certification (again in Section L)

Certification by signing offer

Not explicitly stated

Gap

1510-52.222-71 Migrant Seasonal Agricultural Workers Protection Act registration number (if applicable)

Provide within 5 days after award if applicable

Not addressed

Gap/Conditional

Oregon Farm/Forest Labor Contractor’s License (Section H.10)

If state requires, obtain/maintain; evidence within 10 days after award

Not addressed

Gap/Conditional

Technical evaluation downgrade

Missing explicit equipment list and crew size/composition required by Section L.2.1 could be scored lower under Technical Approach and Schedule/Resources

High

High

Critical

Noncompliant quote package

Missing sustainability/biobased certifications and reporting commitments (52.223-1/2/23; H.7) may be treated as nonresponsiveness or post-award compliance risk

Medium

High

High

Past performance not creditable

Placeholders without completed reference/rating data may prevent meaningful evaluation; could be treated neutral or unacceptable depending on completeness expectations

High

Medium

High

Prework conference deliverable gap

No explicit commitment to provide written work progress plan (F.2) could create performance/admin friction and reflect poorly in technical review

Medium

Medium

Medium

Access closure / environmental suspension misunderstanding

Not acknowledging H.1/H.3.1 rules (no work during closures; no comp for normal suspensions) could create future dispute risk

Medium

Medium

Medium

SOW nuance compliance risk

Not explicitly addressing vegetation retention on cut slopes; CO-notification before damage repair; CO approval before stockpile placement may lead to QC/acceptance issues

Low

Medium

Low-Medium

License/registration conditional noncompliance

Oregon labor license / MSPA registration number (if applicable) not addressed could delay award/trigger default risk if later found required

Low

High

Medium

Add explicit equipment list with availability

Provide a table listing each major piece of equipment (crusher/screener/conveyors, loaders, dozer, water truck, service truck, fuel truck/containment), quantities, ownership (owned/leased), backup/contingency availability, and readiness/maintenance approach

Section L.2.1(a) and (b)

Improves technical score; reduces perceived execution risk

Add explicit crew plan (size/composition) and concurrent operations

Provide headcount by role (superintendent, plant operator(s), loader operator(s), dozer operator, mechanic/service, water truck driver, safety manager, QC/testing coordinator) and describe concurrent coverage by shift/day

Section L.2.1(a)/(b)/(c)

Meets mandatory narrative elements; strengthens realism and schedule confidence

Include a milestone schedule artifact

Add a 1-page schedule (Gantt or milestone table) with phases: mobilization, clearing, pad prep, production start, steady-state production, final testing/acceptance, cleanup, demob; include critical path and float assumptions

Section L.2.1(b)

Directly satisfies ‘submit a schedule’ requirement

Explicitly commit to providing the written Work Progress Plan at prework conference

Add a statement that the Contractor will provide the COR a written work progress plan detailing workforce and schedule, acceptable to Government, at the pre-work conference

Section F.2.0

Closes a clear deliverable gap; reduces admin risk

Strengthen QC/QA interface language around approvals

State that (1) stockpile sites and topsoil stockpile location will be approved by COR before use; (2) crushed material will not be placed on stockpiles until CO approval as required; (3) Government may run gradations any time; define hold points and notification workflow

Section C.3.1, C.3.1.3, C.3.1.6

Reduces acceptance disputes; demonstrates clause/SOW mastery

Add missing SOW compliance commitments (minor but score-relevant)

Add explicit commitments to: retain vegetation on cut slopes unless safety/maintenance issue; remove garbage/plastics/boulders from stockpile sites; notify CO before initiating repairs to damaged roadways; acknowledge access closure rule

Section C.1.3(D), C.3.1.3, C.3.3, H.1.0

Closes small gaps that can be used as discriminators

Add sustainability/green procurement compliance section

Add a short section committing to maximum use of EPA CPG/USDA BioPreferred/ENERGY STAR/FEMP items where applicable as direct costs; reference GPC review; include 52.223-1 certification statement and 52.223-2 reporting commitment (as applicable to purchases)

Section H.7; 52.223-1; 52.223-2; 52.223-23

Reduces compliance risk; demonstrates readiness for post-award reporting

Ensure representations/certifications are evidenced or explicitly referenced

If relying on SAM annual reps, state that all applicable reps/certs in SAM are current and incorporate by reference; optionally attach a completed checklist confirming applicability for 52.204-24/26, 52.209-11, 52.203-98, etc.

Section K provisions; 52.212-3 instructions

Reduces risk of ‘missing’ proposal elements and evaluator uncertainty

Complete past performance details (remove placeholders)

Replace placeholders with actual contract data; include CPARS ratings (where available) or attach letters; ensure references have full contact info; clearly identify projects within last 3 years

Section L.2.1 Past Performance

Maximizes past performance confidence and scoring