Federal PRI and E911 Telecom Proposal Compliance Gap Review

10.0(a)

Incumbent provider is AT&T (context).

Proposal references incumbent disconnect actions but does not name AT&T.

Covered

Not a contractor requirement; informational. No issue.

10.0(b)

Site switch: Avaya S8710 multi-Media Server, CM R14.

Proposal: supports 'Avaya S8710 (CM R14)'.

Covered

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10.0(c)

Primary long distance carrier: MCI/Verizon (0222).

Proposal: preserve access to primary long-distance carrier via PIC in accordance with LOA; does not explicitly name MCI/Verizon (0222).

Partially Covered

Consider explicitly acknowledging current PIC carrier/code (0222) and that LOA governs.

10.0(d)-(g)

Engineering assumptions: DID/DOD trunks monthly call volumes 100%; ACD 5 minutes; CCS for engineering; peak calling hours 0700-1500 Mon-Fri.

Proposal: references 100% monthly call volumes, avg 5-minute duration, CCS assumptions, and peak hours 0700–1500 M–F.

Covered

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10.0(h)

Intra-LATA toll calls connected via long distance carrier.

Proposal: commits intra-LATA toll calls via long distance carrier; references Appendix 10.

Covered

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10.1 DID

Provide DID blocks: (309) 782-0000–9999 (10,000); (309) 644-5000–8999 (4,000); (309) 206-1000–2998 (1,999); total 15,999.

Proposal Section 7 lists all blocks and total 15,999.

Covered

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10.2.1 Line #1

309-786-3437, Loop Start, 2-wire; demarc Switch Room, BLDG 350, 2695 Rodman Ave.

Proposal states two lines in Appendix 10 as loop-start 2-wire analog at Building 350 switch room demarc; does not list the two specific telephone numbers.

Partially Covered

Add explicit commitment to provision these exact TNs to reduce ambiguity.

10.2.1 Line #2

309-786-5383, Loop Start, 2-wire; demarc Switch Room, BLDG 350, 2695 Rodman Ave.

Same as above.

Partially Covered

Same recommendation.

10.2.2 E911 Trunk

Provide E-911 PSAP Locator ID Trunk between BLDG 350 Switch RM/DEMARC RM 161 and PSAP system.

Proposal Sections 3 and 14: commits to 'E911 PSAP Locator ID trunk connectivity' and Building 350 Switch Room/DEMARC Room 161; validate ANI/ALI/route.

Covered

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10.3 PRI Trunks

Provide ISDN PRI DS-1 trunks listed (15 total) with 23 two-way B-channels per PRI; Wink, B8ZS, ESF; demarc Building 350 switch room; circuit IDs listed.

Proposal Section 3: commits DS-1 PRI with B8ZS, ESF, Wink; 23 two-way B-channels; interoperability with Avaya. Section 14 commits 'full complement of ISDN PRI DS-1 trunks listed in Appendix 10'.

Partially Covered

Proposal does not explicitly confirm quantity = 15 circuits nor list/acknowledge each circuit ID. Add explicit acknowledgement of all 15 PRI circuit IDs and quantities.

10.4 Diversity / OC Circuits

Not applicable.

Proposal notes will provide diversity if required in future updates.

Covered

No conflict.

1.0 Scope

Provide local exchange access, analog/digital access transport, inter/intra-LATA interconnect; provide all facilities/equipment/materials/maintenance/test equipment/design to demarcations in Appendix 10; include operator assistance, directory assistance, E911; official Government use only (no residential/non-Gov).

Sections 1, 3: commits to furnish services; provide all transmission facilities/equipment/materials/maintenance/test equipment/design/implementation; preserve operator assistance, directory assistance, E911; 'limited to official Government use' and excludes residential/non-Gov.

Covered

Directory assistance explicitly mentioned in Exec Summary; good.

2.0 Documents

Obtain and follow latest revisions/additions to referenced documents and applicable regulations.

Section 2: states will align with latest revisions of referenced docs; comply with FCC/PUC and safety/environmental requirements.

Covered

Consider explicitly stating process to track revisions/updates (controlled baseline) (see recommendations).

3.0(a)

Appendix 10 identifies all services required including characteristics, quantities, locations.

Sections 1, 3, 14 reference Appendix 10 and commit to baseline services at cutover.

Covered

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3.0(b)

COR monitors/accepts services; coordinate with COR before installing/removing/changing equipment.

Sections 12, 10: commits coordination and 'no installation/removal/equipment change occurs without prior coordination with COR'.

Covered

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3.0(c)

Gov provides rack space and power limited to two relay racks at demarc; coordinate if additional rack space needed.

Section 4 references coordinating rack/power/grounding/labeling; does not explicitly acknowledge 'two relay racks' constraint or coordination trigger for additional space.

Partially Covered

Add explicit acknowledgement of rack space limitation and approach if more space is needed.

3.0(d)

Equipment must be upgradeable/expandable; modularly expandable/reducible; no forklift upgrades.

Section 11: 'upgradeable and expandable... modular configurations... without forklift upgrades'.

Covered

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3.1.1

Provide KO installation & cutover plan on first day of CLIN 0001; do not commence until Govt accepts plan; complete within 120 days after acceptance; issue disconnect orders after successful activation/testing of each circuit.

Section 4: commits plan day 1, wait for acceptance, complete within 120 days, disconnect orders after activation/testing; circuit-by-circuit transition.

Covered

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3.1.2 / 3.1.2.1

Provide subscriber lines (and foreign exchange lines if applicable) per Appendix 10.

Section 3 and 14: provides two loop-start 2-wire analog lines terminated at Building 350 demarc; does not explicitly address foreign exchange lines (not in Appendix 10 baseline).

Covered

Foreign exchange lines appear 'as applicable'; proposal coverage sufficient for Appendix 10 baseline.

3.1.2.2

Commercial subscriber line basic services must include: dial tone, DID, DOD, DTMF, equal access, block 900/976, block operator assist (0+/00+), E911/911 and 311 where available, non-published DN, referral service 3 months, block DACC & directory assistance, block third-party billing, block 10-10, block collect, block automatic call return.

Section 6: lists dial tone, DID/DOD, DTMF, equal access, blocking 900/976, operator assistance blocking (0+/00+), E911 and 311 where available, non-published DN, referral service 3 months, block DACC/DA, block third-party billing, block 10-10, block collect, block automatic call return.

Covered

Proposal also states blocking implemented at network level.

3.1.2.3

Make available additional line features as specified in Appendix 10.

Proposal does not explicitly state it will 'make available' additional features per Appendix 10; it focuses on baseline 'no additional features' for the two lines.

Partially Covered

Appendix 10 lines state 'no additional features' for initial lines; still, SOW requires availability if later specified. Proposal should commit to providing additional features when ordered/modified.

3.1.2.4

CENTREX CBFP as specified in Appendix 10; minimum CENTREX backups maintained for emergency E911 to DES.

Section 6: 'Where CENTREX feature packages are required by Appendix 10, we will provide CBFP... maintain minimum CENTREX backups for emergency E911 services to DES.'

Covered

Wording is conditional; acceptable if Appendix 10 may or may not require CENTREX. If Appendix 10 does require, consider removing conditionality.

3.1.2.5

Gov performs relocations; Contractor performs database updates for E911 address changes when required.

Section 8: commits to database updates for address changes for E911 purposes when required; notes Gov relocations and contractor updates.

Covered

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3.1.2.6

Provide exchange access trunks as specified in Appendix 10.

Sections 3 and 14: commits to ISDN PRI DS-1 trunks and interconnection behaviors.

Covered

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3.1.2.7

Exchange access trunk basic services include: DID/DOD, two-way dialing, channelization (per WO), trunk busy tones, DTMF MF 2/6 and dial pulse signaling, access services, block DACC, trunk group establishment, automatic trunk member selection, alternate route selection, block third-party billing, access to 1-800 and GETS, Caller ID.

Section 6: covers DID/DOD, two-way dialing, channelization 'as applicable' (not explicit), DTMF capability (does not explicitly mention MF 2/6 and dial pulse), block DACC, trunk group establishment and sizing (via traffic engineering), access to 1-800 and GETS, Caller ID mentioned. Alternate route selection and trunk member selection not explicit; trunk busy tones not explicit.

Partially Covered

Several trunk-specific technical behaviors are not explicitly committed (MF 2/6 & dial pulse, trunk busy tones, member selection algorithms, alternate route selection, explicit channelization per work order).

3.1.3

Provide transport channel services per Appendix 10; includes wide range (analog, ISDN, DS-1/DS-3, OC-1/3; expandable to OC-12/48).

Sections 3, 11: provides DS-1 PRI and mentions future growth (DSX-3/fiber panels) and future OC-12/OC-48 as applicable.

Covered

Proposal could more explicitly acknowledge full enumerated service types are supportable 'when ordered via mod/Appendix 10 updates'.

3.1.4

Circuit termination includes MDF for analog, DSX-1 for T1, DSX-3 for T3, fiber panels, Cat3/5 RJ-45 fields; use wall-mounted blocks; circuits must be permanently tagged with circuit ID/telephone number and work order number.

Section 5: analog/low rate to contractor terminal blocks; electrical protection; high rate to contractor-provided DSX-1; mentions DSX-3/fiber panels for growth; permanent tagging with circuit ID/telephone number and work order number.

Covered

Cat3/5 RJ-45 fields mentioned in SOW; proposal mentions DSX/fiber but not RJ-45 fields (likely N/A).

3.1.4.1

Terminate analog/low rate to contractor blocks; Govt provides space; OSP copper entering demarc must be electrically protected.

Section 5: commits termination to contractor blocks in Govt space; electrical protection/grounding/protector modules.

Covered

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3.1.4.2

Terminate digital circuits to contractor DSX-1/DSX-3/fiber patch panel.

Section 5: DSX-1 provided; DSX-3/fiber where applicable for future growth.

Covered

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3.1.4.3

Test circuits after installation; provide test results to COR in writing; document circuit characteristics in CSR.

Section 10: commits to test each circuit; provide results in writing; document in Customer Service Records.

Covered

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3.1.5

Provide local services within local calling areas; areas/zones at least those defined by current provider/PUC; not limited by prefixes; areas not reduced; if different, coordinate with COR/KO; LATA boundary not restricted to contractor service area; connect to intra-LATA exchange areas and inter-LATA carriers essential.

Sections 2, 3: commits comply with PUC; 'without restricting service to any contractor-defined service boundary'; commits interconnection intra-LATA and inter-LATA carriers; preserves PIC.

Covered

Proposal does not explicitly mention 'not limited by prefixes' nor the approval process if areas differ; consider adding.

3.1.5.1

Designate PIC for all long-distance per LOA issued by KO.

Sections 3, 7, 14: commits PIC designation per LOA; preserve primary long-distance carrier.

Covered

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3.1.6

Provide number portability for subscriber lines and local exchange DID; provide additional DID block within existing NXX until exhausted; comply with FCC/PUC mandates; note dependencies (FTS 2001/DSN).

Section 7: commits full number portability; ports DID ranges and totals; provides additional block within existing NXX until exhausted; conforms to FCC/PUC; references FTS 2001 and DSN dependencies.

Covered

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3.1.7

Government designates demarcation; typical is Government DCO.

Section 5: demarc typically Government Dial Central Office; Building 350 per Appendix 10.

Covered

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3.1.7.1-3.1.7.3

Circuit extension rules: provide extension via termination/contractor transport; if Govt cable available contractor provides termination/equipment/conditioning; if not, contractor provides transport.

Section 5: commits to coordinate extensions; use Govt cable when available with contractor termination/conditioning; provide contractor-owned/leased transport when not available.

Covered

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3.1.8

Provide/install all transmission equipment/cables; coordinate with COR; install per safety codes; wiring to Govt power, ground master, termination frames.

Sections 4, 5, 12, 13: coordination with COR; references grounding and power availability; general safety compliance; does not explicitly commit to wiring/connecting to Govt power connection points/ground master/termination frames responsibility.

Partially Covered

Add explicit statement accepting responsibility for wiring/connection to Govt power/ground points and termination frames as required by SOW.

3.1.9

Provide 24x7 POC; COR classifies outages; respond within 1 hour; restore per category; if cannot meet, immediately notify COR.

Section 9: 24x7 POC; respond within 1 hour; restore within 4/8/24 hours and 2 days; notify COR if cannot meet; provides status/cause/ETR.

Covered

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3.1.10

Provide diversity as required by Appendix 10.

Section 9: states will engineer redundant paths if required in future Appendix 10 updates; coordinate with COR.

Covered

Appendix 10 says 'Not applicable' for diversity/OC circuits; conditional statement is fine.

3.1.11

Provide operator assistance incl. subscriber line verification, barge-in, call extension, other exchange access functions.

Section 6: commits operator assistance incl. verification, barge-in, call extension.

Covered

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3.1.13

Provide E911 access; transmit ANI/ALI to PSAP; update MSAG with Govt updates; outgoing city trunks must provide ANI proper format for ALI retrieval by primary/backup PSAP; hearing impaired assistance; provide 911/E911 where available through local org.

Section 8: commits E911 access and ANI/ALI to PSAP; validate during cutover with evidence; MSAG updates; outgoing trunks provide ANI proper format; hearing-impaired assistance; 311 where available.

Covered

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3.2 / 3.2.1-3.2.3

Future services after mod acceptance: emergency 1 day, priority 5 days, routine 10 days.

Section 11: commits to 1/5/10 day provisioning after mod acceptance and coordination with COR.

Covered

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3.2.4

Perform traffic measurement and traffic analysis as required.

Sections 1, 11, 14: commits traffic measurement/analysis; CCS assumptions; coordinate recommendations with COR.

Covered

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3.3

Create/update local service records (CSR/comm service records); provide to COR/KO upon request; update within 10 working days after activation/deactivation.

Section 10: commits accurate records; provide upon request; updates within 10 working days.

Covered

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3.4.1

Project manager available M–F 0700–1700 local to meet COR on-site; has full authority to effect service changes requested by Govt.

Section 12: assigns PM with full authority; available M–F 7–5 on-site interchange.

Covered

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3.4.2

Assist COR with testing/implementation of new circuits/expansions; cooperate with other vendors; develop installation/activation plans with COR when expansion needs additional equipment/testing.

Section 10 and 12: commits assistance with testing/implementation; cooperate with other vendors; coordination on expansions.

Covered

Could strengthen by explicitly stating will develop installation/activation plans with COR for expansions requiring additional equipment/testing.

3.4.3

Provide 24-hour POC telephone number for outages and services prior to cutover.

Sections 9 and 12: provides 24-hour POC number for outages and coordination prior to cutover.

Covered

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3.5

Follow base regulations/policies re security/safety/environmental; comply with all applicable regs.

Sections 2 and 13: commits compliance with base regs and OSHA/NFPA/ANSI/EPA; hazardous materials controls.

Covered

Security is referenced broadly; see note on NE/Ns Security GR-815 under Documents.

3.5.1

Must have safety and health plan compliant with Federal/State/local/Army requirements.

Section 13: states maintains compliant safety and health plan; will provide upon request.

Covered

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3.5.2-3.5.5

Safety/environmental: meet with civil eng/safety/bioenv before work in asbestos/hazardous areas; follow Army procedures; MSDS approval before bringing hazardous materials; no ozone depleting chemicals; obtain work clearance before trenching/digging/modifying; barricades, spoil placement, shoring/sloping; protections near sidewalks/roads; restore excavations; confined space coordination/testing/ventilation; contractor must not handle/dispose hazardous waste.

Section 13: addresses meetings, Army procedures, MSDS approval with 'no exceptions' incl subs, no ozone-depleting chemicals, work clearance before trenching, barricading/shoring/sloping/road protections/restoration, confined space testing/ventilation, and states will not handle/transport/dispose hazardous waste.

Covered

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3.5.6

Accident/incident reporting: record/report facts to COR for property damage/injury; secure scene until released; cooperate with investigation.

Not explicitly addressed in proposal.

Gap

Add explicit commitment to accident/incident reporting, scene security, and investigation cooperation.

3.5.7

Section 508: services exempt under FAR 39.204(d).

Not mentioned.

Covered

No action needed; exemption noted in SOW. Optional to acknowledge.

G-01

3.5.6 Accident/Incident Reporting

Compliance Gap

No explicit commitment to record/report accidental damage or injuries to COR; secure accident scene until released; cooperate with investigations.

Creates contractual non-alignment; could trigger noncompliance finding during performance and increases safety/claims management risk.

G-02

3.1.2.7 Trunk Basic Services

Technical Gap / Incomplete commitment

Does not explicitly commit to: trunk busy tones; DTMF MF 2/6 and dial pulse address signaling; automatic trunk member selection methods; automatic trunk group alternate route selection; explicit channelization 'as specified by work order'.

These are minimum trunk behaviors; omission can lead to acceptance disputes, interoperability issues with Avaya, and operational call completion problems.

G-03

3.1.8 Wiring/Connection Responsibilities

Responsibility Ambiguity

General coordination/grounding is discussed, but not an explicit statement that contractor will wire/connect to Government power connection points, ground master connection points, and termination frames as required.

Could cause scope disputes during installation (who performs final power/ground/termination connections) and delay cutover.

G-04

3.0(c) Rack Space Constraint

Constraint Acknowledgement Gap

Does not explicitly acknowledge demarc rack space limitation (two relay racks) and coordination path if more space is needed.

Risk of design assuming more footprint; could trigger redesign, delays, or inability to install within provided space.

G-05

Appendix 10.2.1 Specific TNs

Specificity Gap

Does not explicitly list the two TNs (309-786-3437, 309-786-5383) being provisioned; only references 'two commercial subscriber lines listed in Appendix 10.'

Weakens verifiability and can complicate porting/CSR accuracy and acceptance testing documentation.

G-06

Appendix 10.3 PRI Quantity & Circuit IDs

Specificity Gap

Commits to PRI parameters and 'full complement' but does not explicitly confirm 15 PRIs and does not acknowledge/list each PRI circuit ID from Appendix 10.

May create disputes on exact inventory to deliver at cutover and complicate circuit-specific testing, tagging, CSR creation, and disconnect sequencing.

G-07

3.1.5 Prefix Limitation Statement

Minor Requirement Nuance

Proposal states no contractor-defined boundary restriction, but does not explicitly state local service areas 'shall not be limited by prefixes that may change' nor the approval workflow if areas differ.

Low likelihood but could be used to challenge service area compliance if calling scope changes or prefixes are re-assigned.

G-08

3.1.2.3 Additional Line Features Availability (future/ordered)

Forward Coverage Ambiguity

Proposal focuses on baseline 'no additional features' lines; does not clearly commit to making available additional features when specified by future Appendix 10 changes or contract modifications.

Could limit Government flexibility and create negotiation friction for later feature enablement.

G-09

Appendix 10.0(c) Long Distance Carrier Identifier

Specificity Gap

Does not explicitly acknowledge MCI/Verizon (0222) as current primary carrier while stating PIC per LOA.

Low/medium risk; could cause confusion during cutover if LOA expects preservation of current PIC code/carrier settings.

R-01

G-02

PRI/trunk service behaviors may not meet minimum trunk basic service requirements (signaling behaviors, routing selection), leading to failed acceptance tests or degraded call completion.

Medium

High

High

Add explicit compliance statement addressing each 3.1.2.7 bullet; include Avaya interoperability test cases demonstrating busy tone, MF/dial pulse support (if applicable), member selection, and alternate route selection.

R-02

G-06

Ambiguity about the exact PRI inventory (15 circuits and their IDs) could cause partial delivery at cutover or documentation mismatch (tagging/CSR/testing).

Medium

High

High

Insert an Appendix 10 replication table in the proposal listing each PRI circuit ID/quantity/demarc and stating 'will provide all at cutover'.

R-03

G-03, G-04

Installation delays due to unclear responsibilities for power/ground/termination connections and physical rack footprint constraints at demarc.

Medium

Medium

Medium

Explicitly accept 3.1.8 responsibilities; provide equipment footprint/rack units and confirm fit within two relay racks, or describe coordination if more space is required.

R-04

G-01

Safety/compliance nonconformance due to missing explicit accident/incident reporting and scene security commitments.

Low

High

Medium

Add a safety incident reporting subsection mirroring 3.5.6 language; ensure subcontractors are included.

R-05

G-05

Porting/provisioning confusion for the two analog TNs and potential CSR inaccuracies.

Low

Medium

Low

List the two TNs and state whether they will be ported or newly assigned; align with CSR and tagging approach.

R-06

G-08

Government may be unable to obtain additional features quickly when later specified because proposal does not clearly commit to availability.

Medium

Medium

Medium

Add an 'Additional Features' commitment: provide any GR-520/feature items or Appendix 10 specified features upon order/modification and within 3.2 timeframes.

REC-01

Add a dedicated subsection titled 'Accident/Incident Reporting and Investigation' that explicitly commits to: record/report to COR all facts for accidental Gov property damage or injury; secure accident scene/wreckage until released by COR/KO; cooperate fully with investigations.

3.5.6

Closes a clear compliance gap; reduces safety/claims risk and strengthens demonstrable SOW adherence.

REC-02

Insert a bullet-by-bullet compliance response for Exchange Access Trunks Basic Services, explicitly addressing: trunk busy tones; MF 2/6 and dial pulse address signaling (state supported/not applicable with justification); channelization per work order; trunk group establishment; member selection method; alternate route selection; block DACC; block third-party billing; 1-800; GETS; Caller ID.

3.1.2.7

Eliminates technical ambiguity and improves acceptance-test readiness for trunking behaviors.

REC-03

Add an 'Appendix 10 Service Inventory Table' reproducing Appendix 10 items: the two subscriber TNs, the E911 PSAP Locator ID trunk, and all 15 PRI circuits with their circuit IDs, demarc location, and technical parameters; state 'all delivered at cutover'.

3.0(a), Appendix 10.2.1, 10.2.2, 10.3, 3.1.4 tagging/testing/CSR

Improves verifiability, avoids disputes over quantities/IDs, and supports tagging/testing/CSR creation.

REC-04

Explicitly acknowledge demarc rack space/power constraint: 'two relay racks' and confirm proposed equipment footprint fits; if additional space is needed for future expansions, commit to coordination with COR per SOW.

3.0(c)

Reduces installation feasibility risk and aligns with Government-provided space limitations.

REC-05

Add explicit statement: contractor will be responsible for wiring/connecting to Government power connection points, ground master connection points, and termination frames for terminal blocks, consistent with applicable safety codes and COR coordination.

3.1.8

Prevents scope ambiguity during installation and improves readiness for on-site execution.

REC-06

Strengthen service-area compliance language to explicitly state: local/foreign exchange access areas will not be limited by prefixes that may change; local service areas will not be reduced; if differences are identified, coordinate with COR/KO for approval.

3.1.5

Closes a nuanced but explicit requirement and reduces later disputes over calling scope/boundaries.

REC-07

Add a short commitment statement that additional subscriber line features will be made available when specified in Appendix 10 or ordered via modification/work order (even if initial lines have no additional features).

3.1.2.3, 3.2

Ensures future flexibility and demonstrates full-scope responsiveness beyond baseline cutover.

REC-08

Optionally acknowledge current primary long-distance carrier identifier (MCI/Verizon 0222) while reiterating that PIC will be set per KO-issued LOA; describe validation step during cutover testing.

Appendix 10.0(c), 3.1.5.1

Reduces risk of PIC misconfiguration and supports smoother cutover/acceptance.

REC-09

Add a brief 'Document/Standards Control' statement describing how the offeror will ensure it has and follows the latest revisions of the referenced GR/TR/ANSI/NFPA/OSHA materials (e.g., controlled library, periodic review).

2.0, 2.1.x, 2.1.20

Strengthens demonstrability of compliance with the 'latest revision(s)' obligation and supports auditability.