State of New Hampshire NG9-1-1 Network RFP Questions & Responses RFP Division of Emergency Services and Communications

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1 Reference: Section 1.2 State of New Hampshire Posted to State Purchasing Website on March 26, 2015 Question 1: The RFP requires the vendor to commence work by June 30, How does the State define commence work? Answer: Kickoff Meeting. Reference: Section 1.2 Question 2: Section 1.2 states that the vendor should be fully prepared to commence work by June 30, The Schedule of Events lists the anticipated notice to proceed as early July Please confirm the schedule and anticipated date to commence work. Answer: Best case date is June 30, 2015, depending on contract negotiations and G&C approval dates. Reference: Section 1.3 Question 3: Maintenance of the existing system would seem more appropriately available through the incumbent provider. This requirement may preclude other vendors apart from the incumbent from being able to assume that responsibility. Is that what the State intends or can this requirement be reconsidered? Answer: Yes, the winning vendor will be required to maintain the current network from the period of the end of the current contract in October. This may be done by the successful Bidder if they possess the capability or via a sub-contracted vendor who possesses the ability. In the event that there is a gap between the new network going live and the old network being taken offline, the old network will still need to be maintained. DESC wants a single POC to go to for support. Reference: Section 1.6 Question 4: The RFP indicates that the details of a Contractor s proposal are last in order of precedence in the event of conflict or ambiguity among the Contract materials. However, if details of a proposal do not take priority over the terms of the RFP, the purpose of responding to the RFP will be negated. The State can assess the details of the proposal in making its determination of the acceptability of such details in selecting the successful proposal for the project. Please confirm whether the potential order of precedence can be negotiated and/or adjusted. Answer: The order of precedence can be adjusted at the time of contract negotiations. Page 1 of 17

2 Reference: Section 4.1, 4.2 Question 5: Section 4.1 provides the address for shipping proposals as 110 Smokey Bear Boulevard. Section 4.2 lists the mailing address for Mr. Brown as 33 Hazen Drive. Please confirm the address to be used for shipping proposals to Mr. Brown. Answer: Please use the 33 Hazen Drive, Concord, NH address. All mail and packages are received there and delivered to DESC through internal delivery. Reference: Section 4.1 Question 6: The RFP states that the electronic copy should be in Microsoft Word and PDF format. Are any pieces of the proposal required to be submitted in Word format, or can we submit the entire proposal in PDF format? Answer: The entire proposal may be submitted in PDF format. Reference: 4.1, Question 7: Section 4.1 specifies the Cost Proposal is a separate document from the Proposal. Section 4.17 lists the Cost Proposal to be provided in Section VII of the Proposal. Does the State intend for the Cost Proposal to be included within the Proposal and as a separate volume? Answer: The Cost Proposal should be delivered as a separate volume only. Reference: Question 8: Are the instructions for Section VII of the Proposal the instructions for the Cost Proposal as a separate document? Answer: Yes Reference: 4.3 Question 9: The RFP states that answers to inquiries and any requested changes to terms and conditions will be posted to the website. Please confirm the URL of the website is Answer: Confirmed Reference: 4.11 Question 10: The RFP states that single sign-on (SSO) access is ideal. For which systems does the State want SSO? Page 2 of 17

3 Answer: This language was included as part of the standard State of NH template, however this type of security feature is not applicable to the network function being sought in this RFP. Reference: 4.15 Question 11: The RFP indicates that the details of a Contractor s proposal are last in order of precedence in the event of conflict or ambiguity among the Contract materials. However, if details of a proposal do not take priority over the terms of the RFP, the purpose of responding to the RFP will be negated. The State can assess the details of the proposal in making its determination of the acceptability of such details in selecting the successful proposal for the project. Please confirm whether the potential order of precedence can be negotiated and/or adjusted. Answer: The order of precedence can be adjusted at the time of contract negotiations. Reference: Question 12: The RFP indicates the text on the cover page should include Next Generation System. This appears to be the title of RFP Please confirm the text to appear on the cover page should instead be Network for NH NG Answer: Confirmed Reference: Question 13: If we cannot make any clarifications to the Terms and Conditions, how should we incorporate standard license terms and conditions? Answer: The State s P-37 (standardized contract structure) dictates the standard license terms. We cannot negotiate the terms and conditions as these are set to facilitate the P-37 NH Standardized Contract format and is established by the AG s office. Reference: Question 14: In the RE line, the Transmittal Form Letter lists the Proposal Invitation Name as Network for NH NH Will the State provide a revised Transmittal Form Letter with the correct name? Answer: The RFP, as published, is in error on page 17, under Cover Page. Under Response to RFP it should state Network for NH NH The RE line, found on page 18, is correct as published. Reference: Page 3 of 17

4 Question 15: The RFP states that Section VI of the proposal should include information described in Sections E-2, E-3, and E-4 of Appendix E. Appendix E does not appear to contain these sections. Please provide the requirements. Answer: Please place the following on page 37, following section E Subcontractor Information : E-2 Team Organization and Designation of Key Vendor Staff Provide an organizational chart depicting the Vendor Project team and Project organization. This chart shall identify specific key staff of the Vendor, any Subcontractors, and the Agency roles and shall identify all positions at least one (1) level below key staff. Define the responsibilities, length of assignment, the percentage of time that the resource will be dedicated to this Project for that length of assignment and whether the resource is local (does not require travel expenses when working on the Project) for each of the roles depicted in the organizational chart. Key staff who must be identified by name include: Project Principal; Project Manager; Quality Assurance Manager; Assistant Project Manager; Installation Manager; and Maintenance Manager. A single team member may be identified to fulfill the staff requirement in multiple areas, with the exception of Project Manager. E-2.1 State Staff Resource Worksheet Append a completed State Staff Resource Worksheet to coverage of organization. The required format follows. Table E-2: Proposed State Staff Resource Hours Worksheet State Role Initiation Configuration Implement. Project Close Out Total Project Manager Position 1 Position 2 Position 3 Position 4 Page 4 of 17

5 Position 5 State Total E-3 Candidates for Project Manager Qualifications of the Project Manager are particularly critical. Therefore, the Agency requires that the Project Manager be clearly identified. The Agency requires that the Project Manager and Installation Manager be assigned full time, on site for the duration of installation of the Project. The Maintenance Manager shall be assigned full time, onsite from go live through Provisional Project Acceptance. For the Project Manager candidate, provide a resume not to exceed three (3) pages (does not count towards overall page limit) in length addressing the following: The candidate s educational background; An overview of the candidate s history; The candidate s project experience, including project type, project role and duration of the assignment; Any significant certifications held by or honors awarded to the candidate; and At least three (3) references, with contact information that can address the candidate s performance on past projects. E-4 Candidates for Other Key Vendor Staff Roles Provide a resume not to exceed two (2) pages (does not count towards overall page limit) in length for each key Vendor staff position on the Project team. Each resume should address the following: The individual s educational background; An overview of the individual s history; The individual s project experience, including project type, project role and duration of the assignment; Any significant certifications held by or honors awarded to the candidate; and At least three (3) references, with contact information, that can address the individual s performance on past projects. Reference: Question 16: There does not appear to be a Requirements table in Appendix C. Please confirm that only the Deliverables table should be addressed for Section III of the proposal. Answer: Only the Deliverables table should be addressed. Reference: Page 5 of 17

6 Question 17: The RFP states that Section IX of the proposal should include extra materials as referenced in Appendix D - Topic O - Product Literature. There does not appear to be a Topic O in Appendix D. Please provide the description or requirement for these extra materials. Answer: Delete Section IX: Appendix (p. 20). It will not be used in this RFP. Reference: C-2-A-1 Question 18: Please clarify the requirement for PSAP trunks to access a three-port conference bridge from the Bidder public switched network. Typically, the PSAP is in control of the conference bridge, not the incoming trunk. Answer: DESC is looking for on call transfer to establish a 3 party bridge that, once established, our calltaker will eventually drop off the bridge leaving the caller and local dispatch center connected, freeing up our trunk/line. Reference: C-2-A-2 Question 19: What is the BPE? Answer: This was mistyped. It should be CPE (Customer Premise Equipment). Reference: C-2-A-5 Question 20: Please clarify the requirement for PSAP trunks to access a three-port conference bridge from the Bidder public switched network. Typically, the PSAP is in control of the conference bridge, not the incoming trunk. Answer: DESC is looking for on call transfer to establish a 3 party bridge that, once established, our calltaker will eventually drop off the bridge leaving the caller and local dispatch center connected, freeing up our trunk/line. Reference: F-1 Question 21: Referencing Table C-3 on page 34, some of the deliverables listed (for example, coordination with network provider) are difficult to assess a specific payment amount. We typically have specific payment milestones for projects such as this (i.e., milestones for hardware delivery, installation, and system acceptance). Would the State consider these milestones and deliverables for Table F-1? Answer: Yes Reference: F-2 Page 6 of 17

7 Question 22: The RFP references positions identified in the Proposed Position Worksheet. Where can we find this worksheet? Answer: See response to question #15. Reference: F-2 Question 23: Please confirm we can add rows to table F-2. Answer: Confirmed Reference: F-3 Question 24: Does the State want third-party hardware costs and professional services included in this table? Answer: Yes Reference: Appendix H Question 25: It is understood that a definitive contract must be agreed upon and entered into by the parties for the project. Will the State agree to negotiate the terms of the State-proposed form of contract with the selected vendor? Answer: No Reference: 6.3 Question 26: Will the State agree that access to books and records can be limited to only those records that are relevant to the inquiry for compliance, that other records may be redacted (or will be held in strict confidence by the State), and that any access should only be upon reasonable notice, not more frequently than once a year, and during regular business hours in a manner so as not to unreasonably interfere with the Contractor s normal business operations? Answer: 6.3 of the P-37, states that If this Agreement is funded in any part by monies of the United States, the Vendor shall comply with all the provisions of Executive Order No ( Equal Employment Opportunity ), as supplemented by the regulations of the United States Department of Labor (41 C.F.R. Part 60), and with any rules, regulations and guidelines as the State of New Hampshire or the United States issue to implement these regulations. The Vendor further agrees to permit the State or United States access to any of the Vendor s books, records and accounts for the purpose of ascertaining compliance with all rules, regulations and orders, and the covenants, terms and conditions of this Agreement. Page 7 of 17

8 The State, for itself or on behalf of the United States, cannot agree to limit the scope of access of any of the Vendor s books, records and accounts for the purpose of ascertaining compliance with all applicable rules, regulations and orders, and covenants, terms and conditions of the resulting Contract. Reference: 8.2.4, H-25.5, H-25.6 Question 27: Typically, a Contractor would have notice and a reasonable opportunity to cure any breach before it is deemed an event of default. Will the State entertain notice and cure for the Contractor before possible termination? Answer: Sections H Termination (pp ) covers termination procedures and includes notice and cure specifications. Reference: Question 28: Fire and extended coverage insurance for customer locations might significantly affect solution cost. Is this what the State intends or can this requirement be reconsidered? Answer: The amount of coverage may be agreed to and specified in Appendix C. However, it is not likely that a decrease in coverage will be agreed to by the State (p. 48). Reference: H-25.5 Question 29: This section states that a preliminary work plan should be included with the proposal; however, the proposal instructions in Sections 4.17 and 4.18 do not specify a work plan. Please confirm. If a work plan is included, in which section should it be placed? Answer: See section H-25.5 Work Plan, pages 52-53, for details. Work plan should be included in Section III Responses to Detailed Requirements and Deliverables (p. 19). Reference: H-25.8 Question 30: Our solution includes standard license terms and conditions, which do not fully align with this section. Will the State entertain negotiating these details? Answer: The State s P-37 (standardized contract structure) dictates the standard license terms. We cannot negotiate the terms and conditions as these are set to facilitate the P-37 NH Standardized Contract format and is established by the AG s office. Reference: H-25.9 Question 31: This section references Appendix G-1 for Testing Requirements. Appendix G-1 relates to Security. Please clarify. Page 8 of 17

9 Answer: For testing requirements this should actually ref. Appendix G2 and to find that please see Addendum B: Department of Information Technology Standards document also listed on the website as Addendum #2 for RFP DOS The DESC would like these followed where applicable and should be viewed as minimal requirements. The DESC have requested as a deliverable in Table C3 on pages a written Test Plan, this test plan should demonstrate the successful bidder s best recommended practices for the entire solution proposed. Reference: H-25.9 Question 32: This section states that a test plan should be included with the proposal; however, the proposal instructions in Sections 4.17 and 4.18 do not specify a test plan. Please confirm. If a test plan is included, in which section should it be placed? Answer: See page 19 section III: Responses to Detailed Requirements and Deliverables. The proposed test plan is a deliverable listed on Table C3. Reference: H Question 33: Does the software need to be archived and/or version controlled through Harvest Software, or is an equivalent archival and version control solution acceptable? Answer: This language was included as part of the standard State of NH template, however this type of software archiving and version control is not applicable to the network function being sought in this RFP. Reference: H Question 34: Our solution includes standard warranty terms and conditions, which do not fully align with this section. Will the State entertain negotiating these details? Answer: The State s P-37 (standardized contract structure) dictates the standard license terms. We cannot negotiate the terms and conditions as these are set to facilitate the P-37 NH Standardized Contract format and is established by the AG s office. Reference: H , Paragraph 9 and 10. Question 35: These paragraphs appear somewhat duplicative. Can the State please confirm which paragraph should apply? Also, typically a Contractor would have notice and a reasonable opportunity to cure any breach before it is deemed an event of default. Will the State entertain notice and cure for the Contractor before possible termination? Page 9 of 17

10 Answer: On page 60, delete the paragraph that immediately precedes section H Administrative Specifications, beginning with the words If the Vendor fails to correct a Deficiency... The paragraph immediately before this one, beginning with the same words more fully covers the same material. Sections H Termination (pp ) covers termination procedures and includes notice and cure specifications. Reference: H Question 35: This paragraph appears to suggest that the State is looking to own all materials under the Contract. Please confirm that it is not the intent of the State to own proprietary technology/software provided by Contractors, as the State should only be receiving a license to such Contractor-owned or provided proprietary materials. Answer: Confirmed. Reference: H Question 36: The language of the RFP refers to the State receiving a right to produce, publish, or otherwise use... software, source code, modifications Such rights are broader than are typically granted for software licenses. Please confirm that it is not the intent of the State to receive rights to source code or rights to modify Contractor-owned or provided proprietary materials. Answer: Confirmed. Reference: H Question 37: Please confirm what standards and procedures of the Department of Information Technology and the State are specifically intended to be referenced. Answer: see Addendum B: Department of Information Technology Standards document also listed on the website as Addendum #2 for RFP DOS The DESC would like these followed where applicable and should be viewed as minimal requirements. The DESC requests the successful bidder s to include their best recommended practices for the entire solution proposed. Reference: H Question 38: These provisions seem to be duplicative of Section 8 (on Page 46). Can the State please confirm which set of termination provisions it intends to have apply. Page 10 of 17

11 Answer: On page 60, delete the paragraph that immediately precedes section H Administrative Specifications, beginning with the words If the Vendor fails to correct a Deficiency... The paragraph immediately before this one, beginning with the same words more fully covers the same material. Reference: H Question 39: Early termination can result in other costs apart from work completed (for example, for contractual commitments made to other suppliers). Will the State agree to cover such other possible costs for an early termination of the Contract made for its convenience? Answer: H Termination for Convenience (p. 68) discusses the State s obligation to pay for Deliverables for which Acceptance has been provided prior to the date of termination for which no separate price is stated to be paid. Please see this section for a more full explanation. Reference: H Question 40: Early termination can result in other costs apart from work completed (for example, for contractual commitments made to other suppliers). Will the State agree to cover such other possible costs for an early termination of the Contract made for its convenience? Answer: H Termination for Convenience (p. 68) discusses the State s obligation to pay for Deliverables for which Acceptance has been provided prior to the date of termination for which no separate price is stated to be paid. Please see this section for a more full explanation. Reference: H Question 41: The language of the RFP in this section suggests that upon any termination of the Agreement the State should be delivered software related to the Contract. Typically, rights to use of software only vest upon payment in full from the licensee. Please confirm that condition precedent of payment in full is consistent with the State s understanding as to its rights to use of software in the event the Contract is terminated. Answer: This language was included as part of the standard State of NH template, however there is no software to be utilized directly or licensed for use by the DESC, thus it is not applicable to the network function being sought in this RFP. Reference: H Question 42: Will the State agree to negotiate reasonable, reciprocal exclusions from possible liability for the Contractor? Page 11 of 17

12 Answer: H Termination for Convenience (p. 68) discusses the State s obligation to pay for Deliverables for which Acceptance has been provided prior to the date of termination for which no separate price is stated to be paid. Please see this section for a more full explanation. Reference: H-25.1 Question 43: Please confirm that the non-waiver of defenses or immunities does not apply to the rights of the Contractor to enforce the terms of the Contract against the State. Answer: Contractor s contract rights are set by the State. Reference: H Question 44: Please confirm that the non-waiver of defenses or immunities does not apply to the rights of the Contractor to enforce the terms of the Contract against the State. Answer: Contractor s contract rights are set by the State. Reference: H Question 45: Certain Contractors may be public companies whose stock is traded on public stock exchanges. For such companies, certain ownership accordingly can change in any given day. Please confirm that it is intended that restrictions on changes in ownership should apply only to actual changes in control. Answer: This provision is not targeted toward publicly traded stock ownership changes. Instead it is focused on change of controlling interest. So, if sufficient stock changed whereby the controlling interest or balance of power changed, this provision would be in effect. Reference: H Question 46: Generally, the escrow agent has their own Escrow Agreement, which would be a third party agreement between the State, the Vendor and the escrow agent. Please confirm that the State will agree to negotiate with the Vendor in good faith to limiting the triggering event for any release of source materials from escrow to the Vendor materially breaching its maintenance and support obligations for the software when such breach is not cured within a mutually agreed upon period after written notice of the breach is provided. If so, please confirm that the escrow agreement is not required to be submitted with the proposal but will be mutually agreed upon award. If a proposed escrow agreement is required with the proposal, in which section should it be placed? Page 12 of 17

13 Answer: This language was included as part of the standard State of NH template, however there is no software to be utilized directly or licensed for use by the DESC, thus it is not applicable to the network function being sought in this RFP. Therefor an escrow agreement is not required. Reference: E-2, E-4 Question 47: Please provide instructions for Sections: E-2: Team Organization and Designation of key Vendor staff; E-3: Candidates for Project Manager; and E-4: Candidates for key Vendor staff Roles, of Appendix E: Standards for Describing Vendor Qualifications Answer: See response to question #15. Reference: C-2 Question 48: Please provide the current number of circuits and trunks from the carriers currently connected into the Concord and Montgomery Tandem Central offices. This inventory would identify carrier by type (wireless, wireline, VOIP). Section C2 of the RFP requires: Phase one consists of maintaining the same or replication of the existing legacy network and resources. An inventory of the current inbound circuits from each carrier is required to replicate the existing legacy network and resources. Answer: This specific information is not available from the current provider due to Customer Proprietary Network Information (CPNI). This speaks directly to the type, quantity and cost of services that are purchased by the customers or other service providers when interconnecting with us for 911 purposes. It is also covered by their individual interconnection agreements with each provider and any non-disclosure requirements in said agreement. That said the successful bidder should plan for at minimum diverse and redundant interconnections to each control switch from every carrier providing telecommunication services in the State of NH. Reference: C-2-A-1 Question 49: Would proposals with SIP trunking containing either PDIF-Lo per NENA i3 or standard ANI or ESQK/ESRK be acceptable? Answer: No. The DESC will keep the NIF and LIF functionality of the LNG in-house and has addressed this functionality with RFP The DESC is looking for the NG9-1-1 Network Provider to supply SIF functionality (converting analog to SIP) only. Page 13 of 17

14 Question 50: Please provide instructions for clarification on how Table C-2 should be populated including definitions for the column headers M/O and Y/M/N. Answer: M/O is for Mandatory or Optional and all items should be marked M for Mandatory. Items that are not marked should be considered Mandatory. The potential vendor should respond to Appendix C-2 in the Y/M/N column with a Y for Yes is the proposal complies, N for No if the proposal does not comply, or M for Maybe with description of how the proposal may comply. *********************************************************************** Bidder s Conference Questions: Question 101: Does the State need to have the new network service in place or a new contract in place by October? Does the network need to be completely cut over by October 2015? Answer: The new network must be in place before the end of the existing network contract currently with FairPoint. The target implementation deadline date should be beginning of October The current contract ends October 11, Question 102: Is there a scheduled date for G&C to have the contract for approval? Answer: There are 2 G&C meeting in June and one in July. The exact G&C meeting will depend on the length of the negotiations. Question 103: Are any of the independent LECS ready to make the jump to SIP trunks today? This has been described as being in phase 5. Is the intent to have some of the carriers jump directly to SIP? Answer: None that the DESC are aware of. Our intent is for the Network Vendor to SIP-groom all traffic and let the carriers migrate when they are ready. Question 104: Is there something that is changing in FairPoint s network preventing the contract from being extended? Answer: No. The contract cannot be extended per instructions from G&C. Question 105: Is the current arrangement for FairPoint under tariff or ICB? Answer: ICB Question 106: What wireless carriers are actively operating in the State today? Page 14 of 17

15 Answer: Verizon Wireless, Sprint, T-Mobile, AT&T, US Cellular and resellers of these services. See below for a list of wireless telecommunications service companies providing service in NH (paying surcharge). Bandwith.com BullsEye Terlecom BYO Wireless Caused Based Commerce, Inc. Cellco (Verizon Wireless) Consumer Cellular Credit Union (Quarterly) Cricket Communications Defense Mobile Corp Flash Wireless Garmin USA Globalstar USA Greatcall, Inc. KDDi America MetroPCS Massachusetts (T-Mobile) MetTel of NH (MetropolitanTele) New Cingular Wireless PCS LLC (ME) NH#1 RCI (US Cell Mgmt #425) NH RSA 2 (Verizon) OnStar Corp. Cellular Ooma PNG Telecommunications Puretalk Holdings RNK Telecom Rural Cellular Corporation Atlantic Solavei, LLC Sprint Spectrum LP (Sprint Nextel) Ting, Inc, T-Mobile Northeast (ANYBILL) Working Assets Fundings Pay Annually (Yearly) Question 107: On the wire line side, what s the flow-through process for the ALI data? Are the originating service providers sending their service information to FairPoint and then FairPoint uses a third party? Answer: The DESC operates and manages all wireline database activities. As such, service providers interface directly with a DESC website to upload their service order activity. Question 108: How is the selective routing being done if not by FairPoint s system? How is the load balancing done? Page 15 of 17

16 Answer: Selective routing and load balancing is done via the network provider. Since New Hampshire only has 2 primary PSAPs, all calls are delivered to one of these two locations. Load balancing is accomplished by primarily routing traffic from one tandem to our Concord office, and from the other tandem to the Laconia office. Question 109: In December 2013, the FCC put out regarding disparate providers and regional PSAP s. Is the State looking to provide completely separate network providers into the PSAP s as part of the solution? Answer: The intention is for call transfer to local agencies to first be attempted over the ESI net which will likely be over the DESCs Carrier over Ethernet network provided by Fairpoint. The successful bidder will provide backup network for transferring those on ESInet and primary for those agencies not on the ESInet over PSTN. Question 110: Do the PSAP s currently have disparate services from different providers? Answer: Today the PSAPs are served by disparate services (each PSAP is serviced by two redundant and geographically diverse Central Offices). However, they are the same provider. Question 111: Related to the disparate providers spoken of in FCC s , currently, all service providers connect to FairPoint s system. The RFP did not speak to having different service providers as recommends. Would the State entertain two or more networks to provide disparate connections? Should we include this as an option? Answer: The DESC will entertain proposals for alternate provider delivery systems that would increase the reliability, diversity and redundancy of the system, but that is not specifically called for or asked for in this RFP. Yes, it can be included as an option, it can be included as an essential part of your complete proposal (to ensure reliability requirements are met), but it must be proposed with a full network proposal not as an add on only. Question 112: The RFP requires incoming trunks to be able to access multi-port conference bridges. Can you provide more of an explanation on that requirement? Are we talking about normal 3-way conference transfers? Answer: DESC is looking for on call transfer to establish a 3 party bridge that, once established, our calltaker will eventually drop off the bridge leaving the caller and local dispatch center connected freeing up our trunk/line. Question 113: Regarding a tertiary route coming in, does the State have a preference as to the operator company that is used? [Required by statute to be in-state] Answer: No, there is no preference; however, it is required by statute to be in-state. Page 16 of 17

17 Question 114: Regarding Text-to-911, is it the State s intention to continue using the existing text-to-911 program (TCS Gem Interfacing) or is the intention to look at alternatives? Answer: The DESC will not continue using TCS Gem for text messaging. The DESC has required that text messaging be part of a new NG9-1-1 CPE solution in RFP At that time, the text messaging solution should be integrated with the CPE most likely coming in MSRP. Page 17 of 17