ARCA CCTL Comments:

1.  First, ARCA CCTL would like to acknowledge and agree with the
    comments submitted by SAIC in their entirety. ARCA would
    particularly like to acknowledge the comments made by SAIC on the
    following topics:

    a.  Validation is ill-defined and varies significantly from
        validator to validator

    b.  Complexity is not a well defined term and is subjective in
        nature

    c.  The Validation activities defined and priced within the charts
        currently do not represent current practice.

2.  Second, ARCA CCTL would like to acknowledge and agree with the
    comments from BAE with respect to the potential burden being placed
    on the vendor with respect to this proposal.

3.  Finally, ARCA CCTL submits the following comments in addition to
    those already presented. Please note that these comments are meant
    to illustrate the issues that have not been addressed from a
    practical, contractual and legal basis within this proposal.

    a.  The hourly rate for each level of validator seems extremely high
        for non-profit work. Given this high cost per hour, there is an
        assumption that the normal day to day overhead duties are
        wrapped into that hourly rate. Several comments result from this
        statement:

        i.  There should be no monthly maintenance fee because that
            overhead should be part of the hourly rate

        ii. Can the government provide the cost components that were
            used to build the rate structure? Is an audit performed to
            ensure that all costs are indeed allowable costs? Is there
            an annual review of the allowable costs, as well as a
            comparison against the labor categories to determine that
            the fees are fair and reasonable for the validators
            assigned?

        iii. The man hours associated with the validation activities
             seem inflated and non-realistic. At EAL2 and EAL3 there are
             no test VORs as others have stated. With the level of
             effort percentages provided in the chart the implication is
             that for every 4 evaluations the CCTL would enjoy a
             dedicated, full time validator.

    b.  Contracting for these costs will be very complex (if not
        impossible to negotiate) and will have to include some measure
        of shared responsibility with the CCTL and the evaluation
        sponsor. Otherwise the CCTL is left completely financially
        exposed. This will require a contract between CCEVS and the CCTL
        for potentially each CCTL customer. This will be necessary to
        ensure appropriate T&C's and also in case of required flow down
        of contract requirements.

        i.  What options will be in place to allow CCTLs from halting
            evaluations, postings and certificates for Evaluation
            Sponsors who do not pay validation fees?

    c.  Will there by SLAs associated with validation activities? What
        incentives are there for CCEVS and Validators to perform
        efficiently when inefficiency is financially beneficial? What
        tracking will be in place to ensure that validation hours are
        efficiently spent and that the CCTL concurs with the activities
        performed? What recourse do the CCTL's and the Evaluation
        Sponsors have with respect to poor validator performance?