Smart Procurement Review & Recommendations By the Information Technology Association of Canada March 30, 2015 As Canada’s national ICT business association, the Information Technology Association of Canada (ITAC) champions the development of a robust and sustainable digital economy in Canada. A vital connection between business and government, we provide our members with the advocacy, networking and professional development services that help them to thrive nationally and compete globally. A prominent advocate for the expansion of Canada’s innovative capacity, ITAC encourages technology adoption to capitalise on productivity and performance opportunities across all sectors. A member-driven not-for-profit, ITAC has served as the authoritative national voice of the $150-billion ICT industry for 60 years. More than 33,500 Canadian ICT firms create and supply goods and services that contribute to a more productive, competitive and innovative society. The ICT sector generates one million jobs directly and indirectly and invests $4.8 billion annually in R&D, more than any other private sector performer. © 2015 Information Technology Association of Canada Smart Procurement ••• Smart Procurement ITAC Recommendations: 1. Improve Business Processes and Rules of Engagement 2. Enhance Transparency Background ITAC wishes to acknowledge the work of both Public Works and Government Services Canada (PWGSC) and Shared Services Canada (SSC) in advancing the Smart Procurement initiative. ITAC views Smart Procurement in terms of the outcomes achieved for government, citizens and industry. Our members believe that outcomes can be measured in terms of: • Robust competition for government requirements; • The government achieving its business objectives for citizens; and • The ability of our members to make a reasonable return on investment. A reasonable return on investment in turn drives where top ICT talent and resources flow. As well, it fuels and funds innovation by industry. ITAC recognizes that the federal Government has special responsibilities and public policy requirements to consider in procurement. At the same time, public sector ICT procurement accounts for the largest single share of ICT procurement in the Canadian economy and accordingly, it has a significant impact on the overall prosperity and productivity efficiencies of Canadian industry. 3. Align with Commercial Practices for terms & conditions. 4. Improve Evaluation Procedures & Selection Methodologies 5. Improve Security Processing 6. The continued incorporation of appropriate strategies for SMEs within federal IM/IT procurement framework 7. Improve Design of Service Delivery Frameworks, Metrics, Options evaluated, for Outcomes for Canadians 8. Review the Access of Suppliers to Fairness Monitors 1 Smart Procurement ••• This brief provides ITAC feedback on those elements of Smart Procurement which our members have experienced so far and their insights on the application of Smart Procurement in the ICT sector to date. It applies to federal government information management and technology requirements and also includes government service delivery and business transformation initiatives. Generally, there is a high dependence on leveraging information technology and management systems for internal and external government services. Concrete examples are being provided which illustrate areas where our members have had concerns and would like to see further refinements in the application of the Smart Procurement Initiatives. Examples are provided in Appendix A. Refinements to Smart Procurement Early Engagement ITAC fully supports SSC and PWGSC’s move for early industry engagement. In fact, ITAC proposed a collaborative procurement model to both PWGSC and SSC which has been adopted for much procurement. However, suppliers are finding a significant amount of communication is not held sufficiently early in the process. Also, it is one-directional whereby suppliers have provided inputs but have not received government feedback or closure on their ideas. ITAC members make a significant contribution to the SSC and PWGSC industry committees, specifically the Information Technology Infrastructure Roundtable (ITIR) and its 2 current sub committees, the Architecture Framework Advisory Committee, and the Procurement Benchmarking Advisory Committee, as well as the now disbanded Committees on Smart Sourcing and Innovation. ITAC is also an active participant on PWGSC’s Supplier Advisory Committees. Suppliers who participate on a voluntary basis receive minimal feedback as to how the outputs from their participation are used or why their recommendations are rejected. During procurement processes, ideas put forward with a view to expanding competition are frequently rejected with a curt “no” response without any rationale or explanation. Our members understand the rules on transparency and the challenges associated with obtaining open dialogue amongst competitors at Industry Days. We also appreciate the divergent ideas and opinions that PWGSC and SSC receive from supplier “one on one” meetings and that it is a considerable challenge to sort through the various inputs to arrive at optimal solutions for the enterprise of the federal government. 2 Smart Procurement ••• While we appreciate early engagement and participation on various SSC forums, bid costs for the Government and for ICT firms that participate in these processes, particularly those that are short listed, have become very high. Restrictions such as requiring that supplier resources must all be physically present at supplier meetings for short listed firms versus joining through a conference call put unnecessary stress on businesses. Substantive elements of the procurement such as the liability to be assumed, penalty structures, supplier evaluation criteria, and other terms and conditions are being discussed too late in the procurement process. This is a problem for industry as these business fundamentals are important considerations for suppliers in determining whether they should make the investment associated with an opportunity pursuit. In the interests of ensuring that Smart Procurement be perceived and experienced by the Government and the ICT industry to its full potential, our members are providing the feedback that follows: ITAC Observations on Early Engagement Desired Improvements 1. Business Processes and Rules of Engagement 1. Improve Business Processes and Rules of Engagement Three process improvements for better processes and rules of engagement for managing collaborative processes and Industry Committees are recommended. 1.1 Absence of feedback and closure for industry experts who participate on SSC Committees 1.1 Improve feedback and disclosure Our members are providing access to top experts in ICT to SSC Committees. They would like to understand how their inputs are being processed, being used for decision making and they wonder why some ideas put forward are rejected. 1.2 Government business owners are not engaged in the dialogue to provide meaningful discussion on the business rationale behind certain requirements. 1.2 Ensure that government business owners are engaged in dialogue with industry to discuss outcomes sought and the rationale for requirements. 3 Smart Procurement ••• 1.3 Government limits dialogue too early in the process. ITAC members have often been advised that it is not possible for any informal questions or discussion once an RFI has been issued. While we support rules for fairness and transparency, they do not require all conversation to end until an RFP has been released. 1.3 Maintain open lines of communication with industry until a formal RFP is issued, subject to fairness to all suppliers. Hallmarks of a better process and rules of engagement for managing consultation.  Provide feedback and closure for industry participants as to how inputs are translated into outputs  Communicate government business objectives and problems that are the drivers for the specific procurement  Extend & open formal questions until a formal RFP is issued 2. Transparency concerns 2.1 Substantive business elements are solidified too late in the process (Example: finalizing Limitation of Liability requirements at time of final RFP release to a short list of bidders) 2.2 Government could share more information on the procurement earlier in the process (example selection methodology) Ideally, each procurement should include a clear schedule published the first day of the Review and Refine Requirements (RRR) stage, a minimum of 1 opportunity to meet one on one with the Crown and the time to comment on each draft RFP document 2.3 Suppliers’ inputs are at times, not taken into account 2.4 Government participants gravitate to inputs already supporting their preconceived government positions 2.5 While lengthy discussions about 2. Requesting enhanced transparency Hallmarks of enhanced transparency:  Consistent engagement  Engagement time periods commensurate with significance of the procurement & impact on the ICT supply chain  Active listening for both parties and sharing more information earlier;  Government develops an approach to better weight and process diverse inputs  Business fundamentals to be identified earlier in the collaboration process to allow firms to make timely investment decisions. 4 Smart Procurement ••• technical requirements may take place, some RFPs are being released with elements that unnecessarily limit competition and/or add unnecessary costs to the solutions 3. Terms and conditions 3. Requesting alignment with commercial practices for specific terms and conditions such as Limitation of Liability (LOL) and IT Supply There is a misalignment with commercial business Chain Security etc. practices for specific procurement terms and conditions. Examples of specific areas of concern are identified below. 3.1 Limitation of liability (LOL) is a major concern for ITAC’s members 3.1.1 The LOL for many federal government’s requirements significantly exceeds the levels established for our members’ large commercial clients of comparable stature. 3.1.2 There is an absence of joint management of risk in that the government itself is unable to mitigate many risks but would expect a supplier to be able to do so. There are other ways within large project scopes for industry and government to jointly manage risk which would not drive up prices to the same extent as requiring higher LOL thresholds. The practice of pushing either finalization or resolution of this critical contract term late in the procurement processes is a problem for Industry. It frequently requires approvals from the Chief Executive Officers of international companies often outside of Canada. Hallmarks of Alignment with commercial Practices for LOL and risk management:  Sharing risk assessments with short listed companies  Government working with short listed companies to identify strategies within the project framework to address risk  A separate stream of work outside of each procurement opportunity to establish principles for the contentious terms and conditions  Meaningful dialogue about LOL levels  Earlier identification of LOL, so firms can make a bid/no bid decision  LOL levels set at comparable levels for other large commercial clients of comparable stature  Comparable terms and conditions should be used for large business transformation projects which usually have heavy ICT enablement as those used for traditional IM/IT projects ITAC has raised this as an area of concern to government (SSC and PWGSC) for the last several years; however, despite commitments and good intentions to discuss, there has been little progress 5 Smart Procurement ••• in addressing this issue. The solution industry puts forward to government as a result of dramatically high LOL may be different than the solution presented for a reasonable LOL. An unreasonable LOL may also result in a no bid decision from potential bidders who may not be able to find a way to manage the Hallmarks of Alignment with commercial risks associated with the LOL, reducing the level Practices for service levels and basis of payment: of competition. 3.2 4. Exorbitant penalties for unnecessarily high service levels agreements out of line with industry standards  Realign service level agreements and associated penalties with industry standards for operations of comparable scale and scope to government operations 3.3 Basis of Payment - Requesting fixed prices for work where there is too much risk for the suppliers to be able to provide fixed prices  A willingness to work with suppliers to ensure that the basis of payment aligns with the business risk and that there is congruence between the basis of payment and the Statement of Work. 3.4 No guarantee of revenue, or volume metrics provided in the terms and conditions make it impossible for bidders to assess the business case, or for officers of the company to approve a competitive bid price. This leads to higher prices, and reduced competition as bidders drop out of the process due to the lack of a business case.  The guarantee of revenue and/or business volume to be awarded needs to be discussed early in the process, and clearly stated in the RFP. Evaluation Procedures and Selection Methodologies are problematic 4.1 Technical Scoring of Proposals Transformative and other procurement requirements necessitate some of the highest skills of any opportunities in Canada and these skills sets are undervalued in the allocations of points to the technical evaluation and its prominence in the overall selection methodology. 4. Improve the Evaluation Procedures and Selection Methodologies for Procurement to weight outcomes Hallmarks of Alignment of Improved Evaluation Procedures and Selection Methodologies:  A willingness to put more emphasis on the technical merit and capabilities versus making price the determining factor 6 Smart Procurement ••• 4.2 Financial Scoring of Proposals - There are times when the financial evaluation templates do not necessarily lead to sensible results. 4.3 Selection of Suppliers - For transformative IT projects, suppliers believe that they are being too heavily driven by price and government is not recognizing the inherent risk and unknowns as solutions are complex. (See Example 1. ETI) 4.4 Weighting of Options - Options are sometimes under weighted in the financial scoring grid in comparison to their cost in the total solution and consequently suppliers load more costs into the options.  PWGSC and SSC take greater due diligence in establishing the financial scoring of proposals and developing the financial grids for completion  Greater emphasis be placed on the technical proposal versus putting the preponderance of weighting on the financial aspect  Aligning the financial weighting of options in line with their estimated value within the total solution . 5. Security requirements for the members to be part of the Federal IT Supply Chain are causing concern, along with delays in the processing of security clearances 5. Clarify the supply chain security requirements, so that the benchmark to be met is known and improve security clearance processing. Hallmarks for Improvements to the Requirements: 5.1 Within the context of ensuring the security of the ICT Supply Chain, the criteria for acceptance or rejection of a supplier is hidden under a veil of national security. Acceptance decision criteria are not well documented or published.  A methodology for suppliers to be able to verify the acceptability of a potential subcontractor or secondary supplier (a type of quick check) for inclusion in their supply chain is required 5.2 The “2” strikes you’re out aspect of the Government ICT Supply Chain Security approach is too punitive when suppliers have no way of verifying up front whether or not a supplier will be acceptable.  If greater transparency of unacceptable suppliers is not possible, relaxation of the “2” strikes rule be adopted 5.3 Firms that receive contracts may have to experience lengthy delays in the processing of their personnel due to government  Improving timelines for file processing where companies win a contract and cannot start work due to security processing, 7 Smart Procurement ••• workloads. This can result in the loss of resources put forward due to their acceptance of other work. putting these cases at the front of the line  Process be reviewed to look at reducing the cost, administration and processing timelines 5.4 The registration process for Controlled Goods for independent contractors requires the completion of 2 documents and providing supporting documentation. In the past there was not a fee to register. However, now with the upcoming $700 annual fee; this will be quite a burden for companies in the technical and professional services areas which often need to establish teams to undertake project work. Benefits for Canadians A key concern for ITAC members is that changes in federal government procurement do not inadvertently impact the potential for the Canadian ICT to support a robust and innovative delivery capability. Rather, as the federal government introduces changes, they should be mindful of the role of procurement to also support innovation, improve productivity and foster efficiencies in a way that enhances the Canadian ICT supply chain. ITAC members span large, medium and small enterprises and aboriginal and non- aboriginal businesses, across the spectrum of original equipment manufacturers, software publishers, distributors, solution providers and professional and technical services providers. In 2013, the total IT spend in Canada was approximately $47.17B. The federal government accounted for approximately 6.8% and when all levels of government are included this percentage was approximately 9.5% of the total Canadian ICT spend. While the federal government percentage may not seem high, the federal government and Canadian financial institutions jockey for the 1st and 2nd largest single clients of the IT industry in Canada. They both, therefore, have a considerable impact on the health of the Canadian ICT supply chain and, indeed, the Canadian economy. ITAC members understand the federal supply base of ICT suppliers will shrink considerably as the government moves to modernize, standardize, rationalize and simplify the GOC enterprise 8 Smart Procurement ••• infrastructure and application landscape. ITAC members are concerned about the potential impact on their companies, as well as Canadian competitiveness. ITAC and its members are actively participating in the current review of socioeconomic benefits by the Procurement Benchmarking Advisory Committee. We support the idea of using the procurement process to produce socioeconomic requirements for Canadians. As part of this process, it is important to ensure that rated requirements in procurements are not seen as the only mechanism to produce socioeconomic benefits. It is also important to review the overall structure and approach to procurements to ensure there are opportunities for all types of businesses, large and small, to compete. ITAC Observations for Benefits for Canadians Desired Improvement 6. Changes in federal ICT procurement have the potential to significantly impact SMEs and aboriginal companies 6. Requesting the continued incorporation of appropriate strategies for SMEs and aboriginal companies and to support innovation within federal ICT procurement framework Changes in federal ICT procurement appear to be significantly impacting SMEs and aboriginal companies. Careful consideration and efforts to understand the associated implications of change on the ICT supply chain are required. The Government should avoid attempts to “customize” the supply chain model that exists to serve the commercial marketplace. 7. Procurements could achieve better service delivery outcomes for Canadians • When considering sourcing options, the total cost of ownership is often not considered or undervalued. Many of the procurements that have occurred have focused on low prices for the base hardware, software or applications without considering the cost to install and operate a solution. There have been Hallmarks for improvements:  Ensure that the approach to produce socioeconomic benefits is based on a broad approach to provide competitive opportunities for all types of businesses.  Efforts are taken to understand the implications on the companies that make up the ICT supply chain and to align with the marketplace generally, where possible. 7. Design of Service Delivery Frameworks and options evaluated, for outcomes for Canadians Hallmarks for improvements in this area:  PWGSC and SSC ensure that the total cost of ownership (TCO) is considered within the overall procurement strategies  More flexibility be shown when suppliers put forth suggestions during the 9 Smart Procurement ••• unrealistic make or buy business cases for government requirements where the labour, cost of operating facilities and sunk etc. costs have been excluded • There are times when the government has been unwilling to share business cases and their risk assessments for projects     • • While we appreciate that the “Total Cost of Ownership” elements of a business case are open to interpretation, nevertheless, we urge the Government of Canada to take a holistic total cost of ownership approach in establishing its business cases.  procurement process; there appears to be a tendency to say “no” to requested changes Suppliers have access to government business cases and have the opportunity to suggest improvements Move to fully loaded business cases Sharing of business cases and risk assessments early in the engagement Ask industry to help improve business cases Government identifies early to suppliers the business outcomes they are seeking and allows suppliers to provide early inputs We also believe that if industry has a chance to comment on the business cases early in the process, valuable industry insights on the Total Cost of Ownership can be provided. Independent Advice The seeking of independent advice is considered essential by ITAC in moving forward with the GOC enterprise ICT transformation. ITAC supports the use of Third Party Experts to provide estimates, benchmarking, validation, advice, evaluations, oversight, and fairness monitoring. In fact, ITAC believes that the government should more broadly interpret independent advice and come to the industry experts to obtain advice. Our members have generously given their time to participate on the SSC Advisory Committees and we will continue to do so. Our observations relating to areas where we believe independent advice should be further leveraged follow. 10 Smart Procurement ••• ITAC Observations on Independent Advice 8. Concerns around how fairness monitors are used in procurement processes • • There is a concern that fairness monitors are not accessible to suppliers and are not really independent owing to their contractual relationship with the Crown. When suppliers are concerned that a process may be biased, allowing the supplier direct access to fairness monitor would ensure the fairness monitor is engaged and aware of the concerns of specific suppliers. Desired Improvement 8. Provide suppliers with access to fairness monitors Hallmarks of the use of fairness monitors  Suppliers have access to Fairness monitors to identify their concerns directly  Fairness Monitors are empowered to respond to fairness related concerns raised by suppliers Closing Remarks Smart Procurement requires that all stakeholders take ownership of their contributions to the end goal to procure smartly. ITAC appreciates the opportunity to submit this paper as we believe it will assist the government to advance the Smart Procurement initiative even further. We know that our members also have a role to play in addressing the identified improvements and we look forward to working together to make Smart Procurement a reality for industry and government. ITAC welcomes any feedback from PWGSC and SSC and, to that end, we would propose a session to review the recommendations, as well as discussions in the SSC ITIR and the PWGSC Supplier Advisory Committees. Our members are committed to continuous improvement to achieve the most effective smart and collaborative procurement systems possible. 11 Smart Procurement ••• Appendix A - Examples of ITAC Concerns Example 1 - SSC Email Transformation Initiative (ETI) Solicitation # 2BOKB-12-3327/C Illustrates multiple concerns Collaboration occurred between Summer 2012 and close of RFP in April 2013. This project was designated by the government officials as PCRA level 4 Project (transformative) which is the highest complexity rating that can be assigned to a government project. Yet the government identified an overall selection methodology in the RFP designed for a routine project. A significant issue for bidders was the limitation of liability (LOL) being requested which only became known once the RFP was released. During the bid response period, bidders requested changes in the LOL and although it was lowered, it still included a limit that was in excess of commercial practices for a comparable requirement. By this time, the short listed firms, having spent over $1M on the process, had little choice but to continue. The email RFP process created a very tight timeline that the qualified supplied respondents with sufficient time to perform a thorough analysis of the risks associated with the high LOL, the 70%price/30% selection methodology, the penalty structure for late deliveries and other terms and conditions. Had all of the fundamentals of the deal been known up front and with sufficient lead time, it is questionable as to whether all 4 short listed suppliers would have submitted proposals. The procurement process should be completed early enough to allow the potential bidders to have all the facts in order to complete their analysis in order to make an informed bid/no bid decision. This bid also highlighted the focus on selecting a vendor with the lowest evaluated price to the exclusion of other factors having a significant impact on the successful project delivery. Example 2 - DND Defence Renewal Requirement Illustrates concern 1 DND issued a major RFI on their renewal Program covering their Entire Operations which was subsequently withdrawn. There were components related to IM/IT and yet the first ITAC members heard about this requirement was when this RFI was posted. As such, many did not have a chance to input in the early process components. 12 Smart Procurement ••• Example 3 - SSC Strategic Advisory Services - Sourcing & Benchmarking Solicitation 2BOKB3/544 Illustrates concern 1 This RFP was considered by ITAC members to be a strategic requirement and of significance to our members yet there was no collaboration associated with this requirement. Example 4 - ESDC Student Loan Requirement RFP PW-$$XQ-006-27913, Illustrates multiple concerns ESDC entered into a highly collaborative process with industry, over a 1 to 2 year period. During the collaborative period, there were indications that there would be a limitation on liability; however, when the RFP was released there was unlimited liability. During the bid process, there were requests to limit liability with examples of other government business service delivery requirements for IM/IT and Real Property service delivery services whereby the government accepted to limit liabilities; however, these requests were denied. Additionally, after a long discussion on the requirement, the first time the supplier community saw the selection methodology of 60% price/40% technical was when the RFP was issued. This is a significant concern that these types of decisions are being made without any discussion with industry. Example 5 – SSC Internet Interconnection Services No. 10026415/B Illustrates multiple concerns For this requirement SSC was actually seeking to award contracts to two suppliers; however, the competitive process resulted in only one supplier bidding. The requirements of the RFP were challenging for suppliers to justify a business case to bid. In particular: the work guarantee was low in comparison to the size of the bid; the security requirements were not clearly defined and were unrealistic considering the service (Internet) sought, and there were high investment costs required for customization of operational requirements to support a basic Internet service. Example 6 - PW-14-00617660 Data Centre Server and Storage Infrastructure Illustrates concern 1 Initially this RFI came out for the first time on Feb.16, 2014 with a closing of March 9, 2014. It covered a 13 Smart Procurement ••• significant number of sub elements. This RFI was identified by to be of strategic significance to ITAC members as it had the potential to cut out many medium sized suppliers who would have to scramble to work with partners. After ITAC intervention, an extension was granted to the end of March; however, even this time period was tight given it was government year-end and suppliers were very busy at this time. Despite the SSC position that there is no longer a government year-end for ICT, there were significant year procurements undertaken. Example 7 - Permanent Resident Card for CIC RFP # B8362-120420/B Illustrates multiple concerns There were suppliers who invested more than a year pursuing the above opportunity, responding to draft RFPs, having met with federal employees, only to find when the final RFP was released there was a mandatory “ made-in Canada” requirement for the solution. This requirement did not surface during the collaborative process. Example 8 - Limitation of Liability in High Performance Computing RFP - Solicitation No. 2B0KB-123816Borden Data Centre Illustrates concern around terms and conditions As a result of the collaborative RRR phase on this procurement, the limitation on liability was set at $15 million. This is exactly the approach that ITAC is recommending for complex and bundled solution procurements. In such instances, it makes sense to determine a reasonable risk management approach through consultation. This is the best way to protect the Government from undue risk, while ensuring cost savings. However, after a question about a clerical numbering issue of the clause, and without further consultation, the limitation of liability was changed to something similar to the approach for the commodity grouping for "large Computer Systems". This was problematic for a number of reasons: The new cap on liability is significantly out of line with industry standards, and is very likely to reduce the competitive response on this RFP and/or significantly increase costs to the Crown; • The new approach is contrary to discussions in the collaborative procurement phase, impacting confidence in this process; • The solution sought in this RFP does not fit the commodity grouping category. Rather the solution is complex, including multiple systems and co-location services. There is a misinterpretation in the application of the clause, as agreed to by ITAC at the time. The cap for the commodity grouping was intended to apply to individual call-ups for commodities, and not to the RFP procurement of large, complex solutions. • 14 Smart Procurement ••• Example 9 - PWGSC Integrity Framework Illustrates concern around engagement • • PWGSC issued significant changes to its Integrity Framework in March 2014 without consulting industry with respect to the impact such changes may have on the industry. We view this as counter to the concept of Smart Procurement and collaboration. A similar issue occurred previously in 2012, when PWGSC introduced into the Integrity Framework the criminal records consent forms for all Bidders’ Directors, without consultation. After extensive intervention by industry, consultations and adjustments were made to make sure the requirements were more workable. This could have been avoided on both occasions if the industry had been engaged prior to issuance of the policies. Example 10 - SSC Data Centre Networks (DCN) Industry Engagement Illustrates concern around engagement and other concerns In February 2014, SSC held an Industry Engagement Day attended by approximately 80 companies followed by one on one industry/SSC meetings in March 2014. The consultation covered 2 streams - data center interconnections (DCI) and data center network (DCN). This was followed by many companies making written submissions. It was obvious that many companies were interested in these requirements and had solutions/services that they would like to have considered through a competitive procurement process. Despite a number of companies actively following up on the next steps for procurements, information was not forthcoming. Procurement proceeded for data centre awards (Barrie data centre awarded to IBM, Borden data centre retrofit and expansion work also competed and awarded) and it was obvious that the data centres would need to be connected. Despite more questioning, SSC remained silent on the status of the DCI and DCN requirements, while companies continued to follow-up and pursue the future opportunities. It now seems that SSC will be awarding over $4M of contracts to few suppliers under a sole source national security exemption for DCN and DCI (to connect Barrie and Borden) much to the surprise and disappointment of several key companies with viable solutions. It appears that, despite the supplier interest shown at the industry day and the regular follow-up, SSC made a decision on a sole source strategy which it never communicated to industry nor gave industry the chance to provide feedback. 15 Smart Procurement ••• There was a lack of transparency and companies spent time, energy and money pursing an opportunity that was sole sourced under a national security exemption, almost one year after the Industry day. 16