Vern Edwards

Whoa! Nietzsche! 😯

Uh... I think you may have it backwards. Ever hear of the the concept of entropy? The second law of thermodynamics? Disorder, randomness, and uncertainty? 😀

According to Acquisition.govL @formerfed The FAR Council isn't going to review anything, because, with the exception of the acting OFPP Administrator, they don't know enough about it to review it. At best some unknown(s) on their staffs are going to review it. Maybe. All the overhaulers are going to accomplish in the short term is to cast the system into chaos while people try to figure out how to do things under the stripped down (Oops! I meant streamlined) FAR. They're going to replace some parts with some used and ready to fail parts. I've been around long enough to remember the chaos after previous "reforms". So have you, formerfed. But this will be good for laughs.

I have to laugh at the interest in the early work of the FAR overhaulers. So far they've taken about a month to publish revisions of low-hanging fruit like Parts 1, 10, and 34. Let's see what they do with Part 7, Subparts 9.4 and 9.5, Part 12, Parts 15, 19, 22, 25, 27, 32, 42, 44, and 45, and, of course, Subpart 52.2. There's a long and winding road ahead. And who are the people working on this? What are they qualifications? How are they organized? What is their process? Who are their consultants? It is said that acquisition personnel are professionals. Well, would any true profession𑁋such as engineering, law, or medicine𑁋go along with unknowns working on something as important as, say, a new edition of the Restatement of Contracts?

That's an exaggeration. It might be truer to say that nobody thinks about procurement/contracting very much until something goes wrong. However, I think congressional interest in procurement/contracting is much less intense today than it was in the past. During the 1950s through the mid-1990s, congressional interest in procurement/contracting was fairly intense. During those years Congress regularly conducted lengthy hearings and published voluminous investigations of various issues in procurement/contracting, especially defense contracting, and especially about competition and contract pricing. But after the "reform" legislation of the 1990s congressional interest seems to have waned. Since the mid-1990s intense partisanship has led to congressional malfunction, which continues in the present day. Today's Congress is not as interested in routine government functions as it was in the past. It's members now fight over issues of what should be the function, focus, size and political orientation and goals of government. But procurement/contracting is still of concern to some. I think a systematic study of mentions of "procurement" and "contracting" in the Congressional Record over time would support my beliefs.

Army, Navy, or Air Force? There's lots of information online about various PEO organizations. Organization depends largely on what kind of service you're buying. See, e.g.: https://www.slideserve.com/brennan-stephenson/january-10-2008 See chart 11. See also: https://www.google.com/search?q=army+peo+organization+chart&sca_esv=36354fdb691823cb&rlz=1C5CHFA_enUS809US809&sxsrf=AHTn8zor0bWrPxZYRq9kgd2VxzRUtBcRnA%3A1747760662287&ei=FrYsaL6nEf2v0PEPp8DJiQk&oq=DOD+PEO+organization&gs_lp=Egxnd3Mtd2l6LXNlcnAiFERPRCBQRU8gb3JnYW5pemF0aW9uKgIIADIKEAAYsAMY1gQYRzIKEAAYsAMY1gQYRzIKEAAYsAMY1gQYRzIKEAAYsAMY1gQYRzIKEAAYsAMY1gQYRzIKEAAYsAMY1gQYRzIKEAAYsAMY1gQYRzIKEAAYsAMY1gQYR0joHVAAWABwAXgAkAEAmAFMoAFMqgEBMbgBAcgBAJgCAaACB5gDAIgGAZAGCJIHATGgB9wEsgcAuAcA&sclient=gws-wiz-serp#imgrc=ge-FZiFPXHV4sM&imgdii=xzPmWcdsnRV6EM

No problem. Can you tell us something about the specific mission?

I presume that by "PEO" you mean a DOD Program Executive Office. What does the "-S" stand for? Specific? If so, what kind of program? Land, sea, air, space?

It's a DLA reference number. It probably refers to a stock item. I found it in a DLA market research document associated with NSN: 5960-01-230-8457, ELECTRON TUBE, MULTIPACTOR. See page 5, CLIN 0003. I think STO stands for Stock Transfer Order. 072 is probably the order number. ZD might be a packaging code. https://imlive.s3.amazonaws.com/Federal%20Government/ID233410793380925340287053475638761336603/CM18310002%20Market%20Research%20LTC%20Questionnaire.pdf

Do you want to know what streamlining and reform do for us? Consider the history of FAR 16.505, Ordering [under IDIQ contracts]. The original FAR 16.505 (1984) was 134 words in length. The first FAR 16.505 implementing the Federal Acquisition Streamlining Act of 1994 (FASA) was 984 words in length. After the FAR councils' implementation of the Federal Acquisition Streamlining Act (FASA) and the Federal Acquisition Reform Act of 1996 (FARA), and further congressional legislative reactions to GAO reports of agencies' conduct of MATOC/MADOC procurements, FAR 16.505 today is 3,592 words in length. That's how regulations grow. Legislation plants them and agencies fertilize them.

That is historically incorrect. Contractor lobbyists s pushed for some policies and opposed others. The growth in FAR is the result of many factors, especially socio-economic policy and congressional displeasure with contract costs. The influence of the GAO cannot be overstated.

Bloomberg Government has published a review of the early work of the FAR Reform team. They trash it. Unfortunately, I can't provide a link to Bloomberg because it's only available to paid subscribers and extensive quotes would violate copyright. But I can provide a few clips:

@Self Employed 1102s are not the only workers facing challenges today. Ask doctors and nurses. Ask air traffic controllers. Ask school teachers. It's the condition of present-day America, brought on by us, our political system, and our politically-appointed-every-four-years "leaders." Our government is teetering, even as we drift towards war. It was teetering even before the present administration arrived. As a pro, all you can do is hang in there and keep on keeping on. We gotta shore it up. A pro has gotta be a pro at all times and under all circumstances. That's what my sergeant told me in November 1966, after we'd been patrolling and sleeping outside in the rain for a month in a place they told us was called Bồng Son. We were tired, filthy, and fed up. I started crying one night due to sheer weariness, misery, and despair, and he said that I was only making myself wetter. I laughed. So did the other guys. Hang in there.

That's an interesting idea that has been around for a long time. But it simply is not practical. Industries vary in their purchasing methods, and companies vary within industries. Moreover, buying in the private sector and buying in the public sector are different because the public sector pursues broader goals. Moreover, letting good prospects work in industry for two years may result in the loss of some of them. Maybe the best of them. Lastly, even if we assume that the time with industry would be beneficial, how many would have to go through the program for the government at large to enjoy any widespread benefit?

"Revolutionary"! Bureaucrats from Madison Avenue.

What would be "of substance"?

Thinking about FAR applicability... Well, it does not apply to the FAA, which was exempted by Congress in 1996. Why? Because the FAA claimed that its efforts to modernize the air traffic control (ATC) system had been hampered by federal procurement rules. I remember watching the "Today" show in 1996 before going off to teach a class and laughing out loud when the Secretary of Transportation (or the FAA administrator, I'm not sure which) told a reporter that freedom from the FAR would solve their ATC modernization problems. Well, 29 years later, have you read about our "modernized" air traffic control system? Did you see the news about Newark airport yesterday? Read the explanations? FAA acquisition free of FAR has been no better than it was under the FAR, which was bad. The GAO warned congress that freeing the FAA from FAR would not solve the problem. https://www.gao.gov/assets/rced-96-27r.pdf page 1: People conduct acquisitions, not rulebooks. And competence, much less mastery, is not about college degrees and "certified" professionalism based on exams. Yes, yes, there are too many rules and the FAR is too big and badly written. But the time and effort spent editing the FAR and writing manuals should instead be devoted to figuring out how to properly educate and train the acquisition workforce. It does no good to put a manual in front a person who does not understand fundamental concepts, principles, processes, procedures, methods, and techniques, and who won't study, either in a class or on their own time. Our government's incompetence, from top to bottom, which long predates the current president, is going to be the end of us if we don't come to grips with it. INVEST IN PEOPLE! Invest wisely, and demand high-yield returns.

FAR 1.104 is misleading and must be revised. The FAR does not apply to all acquisitions.

It doesn't abolish the councils (small c). The authority to issue the FAR is vested in the GSA Administrator, the Secretary of Defense, and the NASA Administrator. They are "the FAR Council" (big C). But they cannot do that work themselves, so they have appointed staff to help them. We call those staffs "FAR councils" (little c). There will still be "FAR councils" (little c), although they may be called something else, and they will still do the grunt work for FAR-writing. No big change in that regard.

Submit a claim pursuant to the disputes clause in your contract. Don't wait too long. https://www.wifcon.com/discussion/index.php?/forums/topic/4173-significant-government-delays-and-dfas-payment-issues/

There is now a FAR Reform website: U.S. General Services Administra...GSA, OMB, NASA, DoD Launch Revolutionary FAR Overhaul Web...WASHINGTON — In a historic move to rein in government inefficiency and protect taxpayer dollars, President Trump launched the most significant update to federal purchasing rules in over four decades.

@formerfed Did you notice that: the SAM.gov notice was entitled, "FACILITIES SUPPORT SERVICES", the body of the notice described the buy as "Facilities Maintenance Services", the SF18 block 11 entry said: "Facilities Maintenance Services, HVAC, Building Control Systems", CLIN 01000 description said: "Facilities Support Services," the PWS Introduction and Background section said: "one (1) qualified mechanical equipment specialist to provide maintenance and operational support for Heating Ventilation and Air Conditioning (VAC), industrial process equipment, and building control systems[.]" the PWS Scope section said: "The contractor shall provide maintenance and technical support services for the AVAC system, industrial equipment, and building control systems... This includes troubleshooting, repairing, and maintaining various mechanical, electrical, and control systems. The contractor will also be responsible for performing preventive maintenance and system upgrades." The PWS does not contain separate task statements for each function..

Was the preparation of a separate solicitation document consistent with combined synopsis/solicitation?

I'm sorry to see you say that. I'll withhold my comments for a while. What's wrong with it, if anything? If any thing is wrong, would FAR reform prevent it in future solicitations?

@multiagencyktr I do not know of any general rule about this matter. The answer to your question about what the government will have to pay will depend entirely on the terms of the contract. You must negotiate those terms.