# ATTACHMENT J-14

# SMALL BUSINESS, SMALL DISADVANTAGED BUSINESS, AND

# WOMEN-OWNED SMALL BUSINESS SUBCONTRACTING PLAN

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UNITED SPACE ALLIANCE POLICY

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**[ATTACHMENT J-14]{.underline}**

**[MASTER SMALL, SMALL DISADVANTAGED AND WOMEN-OWNED SMALL
BUSINESS]{.underline}**

**[SUBCONTRACTING PLAN]{.underline}**

***United Space Alliance\'s SB/SDB/WOSB Master Subcontracting Plan calls
for proactive, meaningful participation and***

***motivation to provide the maximum practicable utilization of
SB/SDB/WOSB\'s.***

1.  **INTRODUCTION**

    USA and its subcontractors are committed to support NASA's Small,
    Small Disadvantaged and Women-Owned Small Business programs. Insofar
    that NASA must achieve at least 8 percent of total value of prime
    contracts and subcontracts, USA will strive to support this
    objective through semi-annually established subcontracting goals.

    Consistent with the concepts above and NASA's overarching goals,
    which are: **Operational Safety, Mission Success and Schedule, and
    Cost Reduction**, USA will exert its best effort to ensure
    subcontracts awarded in support of the Space Flight Operation
    Contract (SFOC) be made available to business concerns or other
    organizations owned or controlled by socially and economically
    disadvantaged individuals (within the meaning of section 8 (a) (5)
    and (6) of the Small Business Act (15 U.S.C. 637 (a) (5) and (6)),
    including Historically Black Colleges and Universities, where
    appropriate. For purposes of this section, economically and socially
    disadvantaged individuals shall be deemed to include WOSB in order
    to comply with PL 101-507. NASA's Contract Clause G.14 is hereby
    interwoven into this USA Master Small, Disadvantaged and Women-Owned
    Subcontracting Plan, and is intended to be compliant to both FAR
    52.219-9 (August 1996) and Contract stated goals.

2.  

3.  **SUBCONTRACTING PLAN ADMINISTRATORS**

    The Administrators of this plan are responsible for the development
    of procedures to ensure that an effective Small, Small Disadvantaged
    and Women-Owned Small Business (SB/SDB/WOSB) Program is implemented
    and provides for the utilization of Historically Black Colleges and
    Universities, and Minority Institutions (HBCUs/MIs) and is in
    compliance with PL 95-507, 99-66l and other applicable Federal
    regulations. The Administrators will have individual discussions
    with each SB/SDB/WOSB and HBCU/MI supplier when requested or at such
    other times that are deemed appropriate and will direct the supplier
    to procurement personnel responsible for the supplier\'s products or
    services. The Administrators will ensure that qualified

    or qualifiable suppliers are given equal and fair consideration for
    subcontracts. The Administrators will serve as liaisons to cognizant
    Government representatives, company management and other Federal
    agencies. The responsibilities of the administrators are further
    defined in USA's Company Acquisition Procedures. The individuals
    responsible for administering this plan are named in Exhibit \"A.\"

4.  

5.  **SUBCONTRACTING PLAN GOALS**

    a.  Subcontracting plan goals are set forth in Exhibit \"A\" of this
        plan. Goals are expressed as a percentage of total dollars
        planned to be subcontracted to all suppliers.

    b.  Subcontracting plan goals are derived from a detailed
        examination of the prime or subcontract requirements within
        Bills of Material, Hardware Utilization Lists and other
        procurement records. This examination includes an in-depth
        evaluation of the major item procurement, complex articles and
        components to determine the suitability for procurement from
        SB/SDB/WOSB and HBCU/MI concerns.

    c.  Subcontracting plans for subcontracts containing options that
        meet the required threshold of more than \$500,000 (\$1,000,000
        for construction of any public facility) will separately address
        goals for both the basic contract term and each option.

6.  a.  
    b.  
    c.  

7.  **DESCRIPTION OF EFFORTS**

    a.  USA Company Policy No. B-05 states in part that \"It is the
        policy of USA to make all of its purchases on the basis of
        quality, delivery, and price or best value." Additionally, "It
        is also the policy of the company that small business suppliers,
        including those owned by women and by socially and economically
        disadvantaged individuals shall have the maximum practicable
        opportunity to participate in the competitive process for the
        Company's purchases of materials, supplies, and services." The
        Company's Administrators serve as focal points to provide
        technical guidance in carrying out these policies and
        procedures. The Senior Material Executive manages the plan and
        the Administrators will administer the plan. All were
        participants in the development of the plan, concur with its
        approach and are committed to achieving the goals established.

    b.  USA executive management provides SB/SDB/WOSB and HBCU/MI
        Program support and direction via written policy and procedures,
        and reviews statistical information to ensure program
        effectiveness. SB/SDB/WOSB statistics are reported quarterly to
        management for review.

    c.  The SB/SDB/WOSB and HBCU/MI Program goals, objectives, outreach
        efforts and related issues are conveyed in formal and informal
        training sessions to personnel who are in a position to
        implement or influence decisions concerning source selection.
        Individuals who have made significant contributions toward the
        achievement of SB/SDB/WOSB and HBCU/MI objectives are
        periodically recognized.

    d.  USA will actively seek new SB/SDB/WOSB firms and HBCU/MI\'s for
        development as qualified suppliers and will, when appropriate,
        provide specifications, drawings and other pertinent data to
        qualified or qualifiable SB/SDB/WOSB firms and HBCU/MI\'s to aid
        them in preparing their bids.

    e.  USA will also make allowances consistent with contract
        requirements and good procurement practices to permit delivery
        of economical quantities within reasonable delivery schedules.
        When mutually beneficial, USA will provide management and
        technical assistance to SB/SDB/WOSB firms and HBCU/MI\'s. The
        type of assistance offered may include, but not be limited to,
        quality control guidance, technical, manufacturing and financial
        consultation and assistance.

    f.  Commercial and Government source directories and lists are
        obtained by each location and utilized in establishing potential
        bidders lists. USA representatives attend procurement
        conferences, seminars, trade fairs, and other functions to seek
        out additional qualified or qualifiable SB/SDB/WOSB firms and
        HBCU/MI\'s.

    g.  USA\'s Make or Buy Committee meets as necessary to review and
        rule on all Make or Buy decisions. The Senior Material Executive
        responsible for SB/SDB/WOSB Programs participates in the
        Committee meeting to ensure that consideration is given to
        SB/SDB/WOSB firms and HBCU/MI\'s. The Senior Material Executive
        serves as permanent secretary of the Committee.

    h.  USA will set aside procurements for SB/SDB/WOSB concerns in
        accordance with established policies.

    i.  USA agrees to use its best efforts to give Indian organizations
        and Indian-owned economic enterprises as defined in (25
        U.S.C. 1544) the maximum practicable opportunity to participate
        in the subcontracts it awards to the fullest extent consistent
        with efficient performance of its contract (Ref.: FAR Clause
        52.226-1, August 1996).

    j.  The NASA Mentor-Protégé Program encourages USA to assist
        SDB/HBCU/MI concerns in enhancing their capabilities to perform
        NASA contracts and subcontracts. Further, USA fosters the
        establishment of long-term business relationships between USA
        and those entities. In addition, the program increases the
        overall number of those entities that receive NASA contract and
        subcontract awards. USA will make application(s) to NASA to
        participate in the NASA Mentor-Protégé Program to the maximum
        extent practicable in support of the goals specified in Clause
        G.14 of the SFOC and NASA FAR Supplement, Clause 1852.219-77 and
        -79 (December 1994).

> k\. USA will use its best efforts to award subcontracts to small
> business concerns located in rural areas. \"Rural area\" means any
> county with a population of fewer than twenty thousand individuals
> (Ref.: NASA FAR Supplement, Clause 1852.219-74, September 1990).
>
> l\. USA agrees to maintain records on all subcontract solicitations
> over \$100, 000, indicating on each solicitation (where applicable)
> indicating (1) whether small business concerns were solicited and if
> not, why not, (2) whether small disadvantaged business concerns were
> solicited and if not, why not, (3) whether women-owned small business
> concerns were solicited and if not, why not, and (4) if applicable,
> the reason award was not made to a small business concern.

8.  a.  

    b.  USA executive management provides SB/SDB/WOSB and HBCU/MI
        Program support and direction via written policy and procedures,
        and reviews statistical information to ensure program
        effectiveness. SB/SDB/WOSB statistics are reported quarterly to
        management for review.

    c.  

    d.  

    e.  

    f.  

    g.  

    h.  

    i.  

    j.  

## **5. CLAUSE FLOW DOWN**

In compliance with its Government Prime Contracts, USA will: (1) include
in each subcontract that offers further subcontracting opportunity the
clause that is entitled \"Utilization of Small, Small Disadvantaged And
Women-Owned Small Business Concerns,\" and (2) require all
subcontractors (except Small Business concerns) who receive subcontracts
in excess of \$500,000 (\$1,000,000 for construction of any public
facility) to adopt a plan similar to USA\'s subcontracting plan.
Subcontracts for the purchase of Commercial Items, pursuant to FAR Part
12, are not subject to the above referenced clause.

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**6. SUBCONTRACTOR PERFORMANCE**

> a\. USA agrees to secure subcontracting plans, similar to that agreed
> to by USA, from its subcontractors (except SB concerns) that receive
> subcontracts awarded under a Government Prime contract in excess of
> \$500,000 (\$1,000,000 for construction of any public facility). Plans
> received will be reviewed by the Administrator and the cognizant buyer
> for compliance with applicable regulations, and will be kept in the
> case file or in the location Administrator\'s office. Subcontracts
> issued pursuant to FAR Part 12 are not required to submit a
> subcontracting plan.
>
> b\. Subcontractors shall be required to update a subcontracting plan
> by submission of a revised plan whenever there are changes to an order
> in excess of \$500,000 (\$l,000,000 for construction of any public
> facility).
>
> c\. USA may determine, when it is in the best interests of the
> Government, USA and/or the subcontractor, to allow consolidation of
> subcontractor's updates to subcontracting plans on a semi-annual
> basis. Such updates would encompass all modifications over the
> specified time period and reduce administrative effort.
>
> d\. USA will provide notice to subcontractors concerning penalties and
> remedies for misrepresentations of business status as small business,
> women-owned small business or small disadvantaged business for the
> purpose of obtaining a subcontract in all solicitations exceeding
> \$10,000 for requirements issued under government contracts.
>
> e\. USA will encourage subcontractors to use their best efforts to
> award subcontracts to small business concerns located in rural areas.

**7. REPORTS**

USA will submit \"Subcontracting Report for Individual Contracts\"
Standard Form 294, and \"Summary Subcontract Report\" Standard Form 295,
according to the instructions therein. USA, when applicable, will
require its subcontractors to submit such forms.

**8. RECORDS**

USA will maintain records that ensure implementation of an aggressive
and effective SB/SDB/WOSB program and provide management visibility of
program achievement. Examples of such records are:

> a\. SB/SDB/WOSB and HBCU/MI source list guides, and other data
> identifying SB/SDB/WOSB and HBCU/MI concerns.
>
> Primary Source Lists are:

1.  Internal company source lists

2.  U.S. SBA -- Pro-Net

3.  National Minority Supplier Development Council (NMSDC) Source Guides

4.  Regional Minority Supplier Development Councils' listings

5.  Minority Business Development Agency Source Guides

6.  Minority Trade Organizations and Business Associations' listings

7.  HBCU/MI directories

8.  Regional Small Business Development Councils' listing

> b\. Organizations contacted for SB/SDB/WOSB and HBCU/MI sources.
>
> c\. Records to support such efforts as:

1.  Contacts with disadvantaged and small business trade associations

2.  Contacts with business development organizations

3.  Attendance at SB/SDB/WOSB procurement conferences and trade fairs

> d\. Records to support internal activities to guide and encourage
> buyers such as:

1.  Workshops, seminars, training programs, etc.

2.  Monitoring activities to evaluate compliance

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Exhibit \"A\"

UNITED SPACE ALLIANCE, LLC.

**SMALL, SMALL DISADVANTAGED AND WOMEN-OWNED SMALL BUSINESS
SUBCONTRACTING PLAN GOALS**

> **[REFERENCE:]{.underline}** UNITED SPACE ALLIANCE MASTER SMALL, SMALL
> DISADVANTAGED AND WOMEN-OWNED SMALL BUSINESS SUBCONTRACTING PLAN

PRIME OR SUBCONTRACT NUMBER: **[NAS9-20000]{.underline}**

REFERENCE: **[Space Flight Operations Contract (SFOC)]{.underline}**

DESCRIPTION: From Definitized Supplemental Agreements No.'s **[001 to
799]{.underline}**

> INDIVIDUALS RESPONSIBLE FOR ADMINISTERING PLAN:

+-----------------------------------+-----------------------------------+
| ####### Anita V. Crosby           | 321.861.5249                      |
|                                   |                                   |
| Eyvon Austin                      | 281-282-2740                      |
|                                   |                                   |
| Penny White                       | 281-282-4226                      |
+-----------------------------------+-----------------------------------+
| #                                 |                                   |
+-----------------------------------+-----------------------------------+

SUBCONTRACTING PLAN GOALS

**USA has established the following goals for awards to SB/SDB/WOSB
firms:**

  --------------------------------- ---------------------- ---------------
  Total to be Subcontracted         \$4,569,602,471        100.0 %

  A. Large Business (LB)            \$3,353,868,268        73.4%

  B. Small Business (SB)            \$1,215,734,203        26.6%

  1\. SDB                           \$ 407,523,414         8.9%

  2\. Women Owned (WOSB)            \$ 397,680,605         8.7%

  3\. Other SB's                    \$ 410,530,184         8.9%
  --------------------------------- ---------------------- ---------------

C. Indirect purchases:

( ) Are not included in this plan

\(X\) Are included in this plan and were allocated at 100%

> "INFORMATION CONTAINED HEREIN IS PRIVILEGED OR CONFIDENTIAL
> INFORMATION OF UNITED SPACE ALLIANCE, LLC. WITHIN THE MEANING OF 5
> U.S.C. 552 AND AS SUCH, IN THE OPINION OF USA, IS EXEMPT FROM THE
> PUBLIC DISCLOSURE PROVISIONS THEREOF."

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