NPS Backflow Testing Quote Compliance Gap Analysis (FAR Part 12)

Document type

Vendor quotation narrative + price placeholders

RFQ package (SF18 + continuation + FAR provisions/clauses + SOW + program policy + attachments excerpts + wage determination)

Aligned roles for RFQ-to-quote compliance mapping

Procurement method / regime

Acknowledges FAR Part 12, FFP

States FAR Part 12, FFP commercial services

Aligned

Primary requirement theme

Backflow assembly inspection/testing/maintenance + optional repairs

Same

Aligned

Quote evaluation factors

Addresses technical narrative and prior experience; price placeholders

Price, Technical capability, Prior experience; preliminary review for completeness

Price not finalized in draft (placeholders) is a material completeness risk

Geography/operational constraints

Park-wide; North Rim seasonal; Inner Canyon

Same

Aligned

Test all designated backflow assemblies; record pass/fail; identify deficiencies

0010

Explicitly included; methodology describes verifying inventory fields, recording readings, pass/fail, deficiencies

Covered

Also addresses HOAL option list generally

Basic maintenance during testing; attempt basic troubleshooting (clean seals, debris check) when fail

0010

Explicitly commits to troubleshooting limited to cleaning seals/checking debris; re-test

Covered

Good alignment with SOW 7.2

Optional repairs/replacements only after COR+CO approval via contract modification; awardee shall not execute otherwise

0020

Explicitly states no repairs/replacements absent written approval and modification; treats as NTE for invoicing only

Covered

Strong alignment

Repair/replacement may include installation of new assemblies where required by regulation

0020

Mentions 'code-required new installation' and will include in deficiency scoping; commits to performing if authorized

Covered

Consider explicitly referencing 'installing new assemblies where one may not exist but should by regulation' per SOW 2.2

Option item exercise timing (option line item; exercise within 3 months per 52.217-7; anticipated exercise date noted)

0020 Option

Acknowledges CLIN 0020 as option/NTE; no explicit acknowledgment of option exercise mechanism/time window

Partial

Low-medium: not usually required, but confirming understanding reduces ambiguity

Conformance with USC FCCCHR Manual (10th Ed) and ADEQ procedures

Explicit commitment; methodology cites USC FCCCHR and ADEQ rules

Covered

Low

None

Comply with A.A.C. R18-4-215

Acknowledges ADEQ requirements and A.A.C. compliance generally

Covered

Low

Add explicit citation 'A.A.C. R18-4-215' in regulatory compliance section for clarity

Calibration/certification of test equipment; documentation in submittals

States calibrated differential pressure gauges; documentation submitted; available on request

Covered

Low

None

Testing tag content for passing assemblies (serial, date, tester cert #, company contact, and any additional chemicals)

Includes serial/date/tester cert#/company/contact; does not address 'any additional chemicals' element

Partial

Medium: tag content mismatch could cause deliverable rejection

Clarify how 'additional chemicals' will be captured on the tag (e.g., 'None' default; or fire/boiler additives noted); confirm alignment with park’s tag template

If an assembly fails: attempt basic troubleshooting (clean seals, debris check)

Explicitly included and bounded as non-invasive

Covered

Low

None

Any assembly containing lead must be noted as requiring replacement (EPA Lead and Copper Rule Improvements)

Mentions lead-free parts for replacements; does not explicitly state process to identify/flag lead-containing assemblies during inspection/testing

Gap

High compliance risk: failure to flag lead-containing assemblies violates spec requirement

Add an explicit procedure: how lead presence will be determined (manufacturer/model lookup, component marking, dates, portable testing if used) and how it will be reported (Unique ID flagged in consolidated report + deficiency report)

Repair/installation must follow latest National Plumbing Code and best practices

States compliance with all codes; mentions code-required new installation; does not explicitly name National Plumbing Code in repair section

Partial

Low-Medium

Add explicit statement that repair/installation will comply with the latest National Plumbing Code as required by SOW 7.2

Fire suppression assemblies: conform to NFPA 25 and 72; treat 'should' as 'shall'

Explicitly commits to NFPA 25/72 and treating 'should' as 'shall'

Covered

Low

None

All deviations require written CO approval prior to implementation

States strict accordance with solicitation/SOW/clauses; does not explicitly restate CO deviation approval rule

Partial

Low-Medium

Add explicit compliance line: 'No deviations will be implemented without prior written CO approval'

Tester must submit annual testing/repair records package within 5 business days of test completion (program document)

Potentially applicable operational expectation (not explicitly repeated in SOW deliverables section)

Not stated; the quote focuses on final report deadline 5 Dec 2026

Gap

Add internal commitment for interim submission cadence (e.g., weekly or within 5 business days per batch) to align with program expectations and reduce acceptance risk

Two photos must show side profile including isolation valves #1 and #2 (program document)

More specific than SOW photo requirement; could be enforced by GRCA program reviewers

States side profile showing location context; does not mention isolation valves

Partial

Clarify that side-profile photo will include isolation valves where present/visible; if not possible, note in report

Potable vs reclaim water test kit segregation (program document)

Important if reclaim water devices exist; inventory includes various uses

Not addressed explicitly

Gap

Add statement: potable test gauges will not be used on non-potable/reclaim systems; if any reclaim systems encountered, dedicated labeled kit and report notation will be used

Tester certification recognized authorities (ABPA, ASSE, IAPMO, etc.) per program document

May influence acceptability of tester credentials

States state-recognized consistent with ADEQ; does not list recognized authorities

Partial

Add list of certifying bodies and confirm testers hold current credentials acceptable to ADEQ/GRCA (attach copies)

Checklist for Quote Submittal included as first page

Solicitation requires the checklist page completed and first in package

Not included; narrative references submission requirements but does not reproduce/complete checklist page

Gap

High: quote may be eliminated in preliminary review as incomplete

Insert the solicitation checklist page as page 1, with checkboxes completed and cross-referenced to sections/attachments in the quote package

Completed and signed SF18

Signed acknowledgement of SF18

Signature block provided; states 'for inclusion with signed SF18' but does not include executed SF18

Partial

High: may be considered non-responsive

Attach the fully executed SF18 (signed/dated) to the submission package and reference it in the cover letter and checklist

Signed amendments (SF30) if applicable

Offeror must check SAM.gov and acknowledge amendments

Mentions amendments generally; no explicit amendment acknowledgment list or signed SF30 attachments

Partial

Medium-High: amendment non-acknowledgment can render quote non-responsive

Add an 'Amendment Acknowledgment' section listing each amendment number/date and include signed SF30s (or explicit written acknowledgment if permitted)

Price Schedule – use attached price schedule; do not edit

Must use blank bid schedule structure; alternate quotes not accepted

Provides CLIN 0010/0020 prices in required structure but uses placeholders; states not altering forms

Partial

High: placeholders or missing totals prevent evaluation; unbalanced pricing risk cannot be assessed

Complete the Government-provided price schedule form exactly (no edits) with final numeric amounts; ensure total equals CLIN0010 + CLIN0020 NTE

Completed provisions in solicitation as applicable

Multiple FAR provisions require completion/representation/certification

Provides narrative acknowledgment and completes 52.209-11 representation; does not explicitly complete 52.203-18, 52.209-2, 52.222-48/52, 52.225-20/25, 52.240-90, etc.

Partial

High: missing certifications may be treated as incomplete quote package

Provide a dedicated 'Representations & Certifications' appendix that either (a) includes completed provision texts/checkboxes, or (b) references provision paragraph identifiers with required responses as allowed by 52.252-1

Capabilities statement / project narrative (limit to two pages)

Technical capability narrative limited to 2 pages

Provides a detailed narrative likely exceeding 2 pages when formatted

Potential Conflict

Medium: may be deemed noncompliant with instructions; could impact evaluation

Condense the technical narrative to ≤2 pages and move supporting detail (QC plan, reporting examples, file naming samples) to labeled appendices if permitted

Prior experience – three references within past five years; include POC contact information; include water purveyors

No more than 3 references; include water purveyor references

Provides three projects and POC placeholders; does not explicitly state water purveyor among them (one is municipal water utility which qualifies)

Partial

Medium: missing real POC details could reduce confidence or fail verification

Replace placeholders with actual contact info; explicitly label at least one reference as a 'water purveyor' and describe similarity in scope/inventory size

Submission method and deadline

Submit via email by 8 July 2026 1:00PM AZ; questions due 1 July 2026

Acknowledges electronic submission requirements; does not restate due date/time explicitly in a compliance statement

Partial

Low-Medium: administrative error risk

Add a compliance statement confirming submission to the specified email and before the deadline; include time zone

SAM active registration + UEI

Must be active at close, award, and throughout performance; small business status required by solicitation narrative

States active SAM and UEI/CAGE; commits to maintaining active SAM; asserts small business under NAICS identified

Partial

Medium: solicitation text contains internal inconsistency (not set-aside vs 100% set-aside; NAICS mismatch)

Verify solicitation’s controlling language and NAICS (221310 per solicitation narrative) and ensure the SAM record reflects correct NAICS and small business status; add a note addressing the solicitation inconsistency without challenging terms

IPP invoicing / waiver

IPP required; waiver only if unable (must be requested with quote)

Commits to IPP use and states no waiver will be requested

Covered

Low

None

Complete inspections within 45 days from start of inspections

Explicit commitment; scheduling approach described

Covered

Includes caveats for access/flight availability; acceptable if communicated

No federal holidays or weekends unless approved; request ≥3 weeks in advance

Explicitly commits and repeats 3-week notice requirement

Covered

None

Inspection hours 0700-1800; housing 0800-1700

Explicitly commits

Covered

None

North Rim closed to public Dec 1 to May 15 (seasonal constraint)

Acknowledges seasonal constraints; plans schedule accordingly

Covered

None

Report due date: no later than 5 Dec 2026

Explicitly commits

Covered

None

Helicopter services: up to 2 personnel; two round trips per inspection cycle; no cost; specified Inner Canyon locations

Explicitly acknowledges and plans batching

Covered

Low

None

Repairs flights negotiated case-by-case

Explicitly acknowledges

Covered

Low

None

Flight requests must be made 4 weeks in advance via Flight Request Form (Attachment 4)

Explicitly commits; references provided form

Covered

Low

None

Flights may be delayed/canceled due to weather/SAR/firefighting priorities

Explicitly acknowledges; adds contingency planning

Covered

Low

None

Flight Request Form requires aviation safety training compliance, passenger weights, cargo, MRA, charge codes, signatures

Mentions aviation safety training compliance and weights/cargo; does not mention MRA/charge codes/signature workflow (division chief/superintendent)

Partial

Medium: administrative delay risk for scheduling flights

Add a flight admin plan: who completes/signs the form, how MRA will be addressed, and how required fiscal info/charge code will be coordinated with the COR/NPS process

1452.201-70 CO authority / COR limitations / correspondence copies

CO only can modify; COR monitors; contractor must copy CO & COR; notify CO within 3 days if COR exceeds authority

States will route technical coordination through COR; only CO executes changes; does not address 3-day notice or copying correspondence

Partial

Add explicit commitments: copy CO and COR on correspondence; notify CO in writing within 3 days if direction exceeds COR authority

1452.228-70 DOI Liability Insurance amounts and certificate contents + 30-day cancellation notice

Maintain required amounts; certificate names Contractor + USA; includes contract #, CO name/address; 30-day notice of cancellation/modification

Commits to proof of insurance naming parties; certificate identifies contract # and CO info; does not state amounts or 30-day endorsement explicitly

Partial

State the exact coverage minimums and confirm the 30-day cancellation/modification notice endorsement will be included

ATV prohibition; UTV permitted

No ATV use; UTV allowed definition

Explicitly acknowledges ATV prohibition; states use permitted UTVs/foot/aviation

Covered

None

IPP electronic invoicing; waiver only if needed (request with quote)

Register and use IPP; attach PDF invoice with contract #, dates of service, date of invoice, letterhead, pricing breakdown

Commits to IPP without waiver; states will provide required attachments/supporting docs

Covered

Add explicit statement that invoice PDF will include contract #, dates of service, invoice date, and pricing breakdown

Service Contract Labor Standards (52.222-41) and wage determination compliance

Pay required wages/fringes; proper classifications

Commits to SCLS compliance and wage determination; mentions Coconino County, AZ

Covered

None

52.232-40 accelerated payments to small business subcontractors

Flow-down/administration expectation

Not addressed

Gap

Add a statement committing to comply with accelerated payments clause where applicable and flow down requirements to subs

52.222-54 E-Verify

Enrollment/use as required

Acknowledges E-Verify generally

Partial

Add explicit statement of E-Verify enrollment and use for covered employees, if applicable

Safeguarding / Basic Safeguarding of Covered Contractor Information Systems (52.240-93)

Protect covered information systems; implement safeguarding controls

Mentions safeguarding requirements generally but provides no control description

Partial

Add a short safeguarding appendix describing how any Government information (inventory lists, facility details) will be stored, access-controlled, and transmitted

Set-aside contradiction: SF18 header says 'THIS RFQ IS NOT A SMALL BUSINESS SET-ASIDE' while Section I states '100% total small business set-aside' and includes 52.219-6

Eligibility/representation risk; could affect responsiveness if vendor misrepresents status

input_proposal.docx asserts small business; could be wrong if header controls

Confirm via SAM.gov notice and/or contracting office Q&A which is controlling; in quote, state your actual business size status and that your SAM status reflects it, without disputing terms

Solicitation number inconsistency: references 140P1526Q0089 and also 140P6426Q0062

Could cause mislabeling of documents/invoices/insurance certificates

input_proposal.docx consistently uses 140P1526Q0089

Add a compliance note: all submitted documents will reference RFQ 140P1526Q0089 unless amended/clarified by CO; consider asking CO to confirm correct solicitation number

NAICS ambiguity: early draft proposal says 'NAICS code identified in solicitation'; solicitation narrative specifies NAICS 221310

SAM/size standard alignment; evaluation eligibility

input_proposal.docx does not explicitly cite 221310

Explicitly state NAICS 221310 and confirm small business size standard compliance in SAM

R1

Quote rejected as incomplete at preliminary review

Missing completed checklist page as first page; missing executed SF18/SF30; incomplete provision certifications

Medium

High

High

Assemble a fully compliant submission package with checklist, signed SF18, signed amendments, completed provisions, and final price schedule

R2

Noncompliance with '2-page' technical narrative instruction

Technical narrative likely exceeds limit

Medium

Medium

Medium

Condense narrative to 2 pages; move detail to appendices only if permitted; ensure the 2-page narrative stands alone

R3

Deliverable rejection due to missing required fields in individual reports

Fields not explicitly enumerated; risk of omission (File Number, equipment serial, etc.)

Medium

High

High

Provide a sample report template that includes every required field; run QC checks against that field list

R4

Specification noncompliance for lead-containing assemblies identification

No explicit process to detect/flag lead-containing assemblies

Medium

High

High

Add lead identification/flagging procedure and reporting outputs; coordinate with COR on acceptable identification method

R5

Aviation scheduling delays

Partial coverage of flight request admin requirements (MRA, fiscal charge codes, signature workflow)

Medium

Medium

Medium

Add flight admin plan and early coordination steps; submit requests >4 weeks when possible

R6

Insurance certificate rejected

Missing explicit DOI minimum limits and 30-day cancellation notice endorsement commitment

Low-Medium

Medium

Medium

Explicitly cite coverage amounts and endorsement requirements and provide a sample certificate if available

R7

Misrepresentation/eligibility risk due to set-aside contradiction

Solicitation internal inconsistency

Low-Medium

High

Medium

Confirm with CO; state factual status and SAM record; avoid conflicting assertions

Schedule of Values

NTP-required submittal

Not explicitly provided; narrative references scheduling but not a 'Schedule of Values' deliverable

Gap

Add a Schedule of Values submittal artifact or explicitly state it will be submitted and define its structure (CLIN 0010 milestones / deliverable-based values)

Schedule

NTP-required submittal

Commits to master schedule + daily look-ahead; kickoff meeting; 45-day completion window

Partial

Provide an example schedule (Gantt or calendar) as an attachment and state it will be finalized at kickoff and submitted for acceptance

Certified tester list (name, qualification dates, certification numbers)

NTP-required submittal

Commits to submit names, cert numbers, expiration dates; references ADEQ-consistent credentials

Covered

Include qualification dates explicitly (the SOW asks for dates of qualifications) and attach copies/cards if allowed

Test report format/form

NTP-required submittal

Commits to submit format for review and incorporate COR comments

Covered

Include a sample form matching required fields to accelerate acceptance

Individual inspection/testing report (digital PDF) per assembly

Deliverable

Commits to individual PDFs only; no grouped reports

Covered

None

Hard copy of each inspection report, duplex, bound or in binder

Deliverable

Commits to front/back printed, bound or 3-ring binder

Covered

None

Consolidated report (Excel/CSV) + compliance summary PDF

Deliverable

Commits to consolidated Excel/CSV and compliance summary PDF

Covered

Ensure compliance summary contents are defined (e.g., counts, pass/fail rates, out-of-compliance list)

Deficiency report: deficiencies, required repairs, cost estimate

Deliverable

Commits to deficiency list tied to Unique ID; corrective action narrative, parts list, cost estimate

Covered

None

Testing equipment calibration certification

Deliverable/submittal

Commits to calibrated gauges; keep documentation; submit calibration certificates

Covered

None

Replacement parts/assemblies: must include certification of parts and origin of supplies

Deliverable upon repair/mod

Commits to lead-free NSF/ANSI 61/372 and 'certification of parts and domestic origin' for submittals

Covered

Explicitly align wording to 'certification of parts and origin of supplies' (may be domestic or otherwise per trade agreements)

Individual PDF per device; no grouped reports

Explicit; states grouped disallowed and will not submit grouped

Covered

None

None

PDF file naming: Unique ID + date YYYYMMDD

Explicit commitment; matches requirement

Covered

None

None

Required individual report data fields (Unique ID, file number, connection type, hazard type, manufacturer, size, model, serial, test date, results, pressure readings, method, calibration date, equipment serial, repairs made, corrective action, tester name & ID)

States will collect many inventory attributes and readings; does not explicitly enumerate all required fields including 'File Number' and 'Test equipment serial number' in one place

Partial

Medium: missing explicit field list can lead to format mismatch

Include a field-by-field compliance matrix and sample report form showing every required field explicitly, including File Number and test equipment serial number

Photo requirements: two JPGs ≥6 megapixels; 1) info plate/serial; 2) side profile/location context; filenames include Unique ID + YYYYMMDD + _1/_2

Explicitly commits to ≥6MP; correct photo types; correct filename pattern

Covered

None

None

Consolidated report Excel/CSV using Attachment 1 format; verify/update/complete missing info in each column

Explicit commitment; will use inventory as baseline and correct missing attributes

Covered

None

None

GPS coordinates projected in NAD 1983 UTM Zone 12N

Explicit commitment; states NAD 1983 UTM Zone 12N required

Covered

None

None

Consolidated report includes needed parts/repairs; corrective actions include description, parts required, special conditions/constraints

Explicitly commits; deficiency report/quote package described

Covered

None

None

High

Add the completed 'Checklist for Quote Submittal' as page 1 and cross-reference where each required item is found in the package

Addendum to 52.212-1 (Checklist)

Reduces risk of elimination at preliminary review; improves evaluator usability

High

Attach executed SF18 and any amendment acknowledgments (signed SF30s as applicable); include a one-page amendment log

Addendum to 52.212-1; SF18/SF30 instructions

Ensures responsiveness and prevents amendment non-acknowledgment issues

High

Finalize pricing with numeric CLIN 0010 FFP and CLIN 0020 NTE on the Government-provided price schedule form (unedited) and ensure totals match

Price Schedule instruction; Award Selection price reasonableness/unbalanced pricing

Enables evaluation; reduces unbalanced line item concern

High

Provide a completed provisions/certifications appendix for all applicable FAR provisions listed (beyond 52.209-11), using 52.252-1 approach if not submitting full text

Section VI Provisions by reference

Prevents administrative gaps and potential nonresponsiveness

High

Add an explicit procedure to identify and flag any lead-containing assemblies as requiring replacement, and show how this will appear in the consolidated report and deficiency report

SOW 7.2 lead requirement

Closes a direct technical compliance gap

Medium

Condense the technical narrative to comply with the 2-page limit and move supporting artifacts (QC checklist, sample report templates, file naming examples) to appendices if permitted

Addendum to 52.212-1 (capability statement limit)

Avoids instruction noncompliance; keeps key content visible

Medium

Add a sample individual report template explicitly listing every required field, and a sample consolidated spreadsheet column mapping to Attachment 1

SOW 7.5.1 & 7.5.3

Improves acceptance probability and reduces rework

Medium

Explicitly commit to DOI insurance minimum limits and 30-day cancellation/modification endorsement; include a sample certificate if available

1452.228-70

Reduces mobilization delays and administrative rejection risk

Medium

Add a flight request administrative plan addressing MRA, passenger weights, cargo limits, fiscal charge codes, and signature workflow coordination

Flight Request Form + SOW 3.1

Reduces Inner Canyon schedule risk

Medium

Resolve/acknowledge solicitation inconsistencies (set-aside status, solicitation number, NAICS) by confirming your factual status and requesting CO clarification if needed

SF18 header vs Section I; solicitation numbering; NAICS

Reduces eligibility/administrative errors

Low-Medium

Add commitments aligned to GRCA program expectations that may be operationally enforced (e.g., photo includes isolation valves where possible; potable vs non-potable test kit separation; interim submission cadence)

GRCA Cross-Connection Control Program embedded in solicitation_text.docx

Improves acceptance by GRCA stakeholders beyond minimum SOW text