Kirk Rowdabaugh (Chair), NASF,
Arizona State Forester
Alice Forbes (Vice-Chair), U. S. Forest Service
Allen Deitz (Executive Secretary), NWCG IRM Program Management Office
Jim Erickson, Intertribal Timber Council
Mike Long, National Association of State Foresters
Larry Hamilton, Bureau of Land Management
Mike Hilbruner, USFS — Fire Systems Research
Edy Williams-Rhodes, National Park Service (10/20/04)
Phil Street, Fish and Wildlife Service
Sue Vap (for Edy Williams-Rhodes, 10/19/04), National Park Service
Lyle Carlile, Bureau of Indian Affairs
Hugh Wood, U. S. FIre Administration
Guests Attending:
Barry Mathias, NWCG IRM Program Management Office
Don Artley, National Association of State Foresters
Phyllis Krietz, U.S. Fire Administration
October 19, 2004
Gerry Day, Northwest Coordination Center
Paul Schlobohm, Fire Danger Working Team, Chair
Greg Mandt, National Weather Service
LeRoy Spayd, National Weather Service
Wayne Mitchell, Fire Weather Working Team, Chair
Heath Hockenberry, Fire Weather Working Team
Sam Lombardo, U.S. Fire Administration
Gordon Sachs, U.S. Fire Administration
Lisa Makar, U.S. Fire Administration
October 20 , 2004
Sue Vap, National Park Service
Mike Daugherty, U.S. Fire Administration
All agencies are in the editing phases for agency-specific manual changes. Results will be shared among agencies after edits are completed. The Red Book Chapter 1 editing is finished; scheduled for publication in January.
The Agency Administrator’s Guide has been reviewed against the glossary. The Glossary review is done; changes submitted to IOSWT. The Task Group agreed to recommend to the NWCG and the NFAEB to approve the glossary as the sole source glossary for fire management after IOSWT makes changes.
The Group is currently working on updating the National Interagency Agreement for Fire Management. Updates will go back to NFAEB for a decision in December.
A draft of the internal review process for preparedness reviews is due the end of December (Broyles is lead).
Historically, the assignment period has been 21(+) days until a couple of years ago when the standard was changed to a 14-day period. 21-day assignments are much more cost effective, but the cost effectiveness must be balanced against safety.
Treating extended assignments as individual exceptions helps manage that balance. As currently written, the policy allows for the possibility of extension. This year was exceptional and was manageable with the policy as is. Adding language to the Mob Guide will enable people to anticipate the possibility of an extension when dispatched to Alaska – this year, crews were caught unprepared for extended assignment periods.
Decision: Keep the policy intact; modify the Mob Guide to add language identifying the potential for extension of Alaska assignments.
Action: Alice Forbes to follow up with Kim Christianson for Mob Guide modifications. The proposed modifications to Mob Guide are to be reviewed by NMAC for acceptance.
The NWCG requested the Fire Danger and Fire Weather Working Teams to further develop “Option C” presented at the January 2003 NWCG meeting. Option C, presented in the report, “Alternatives for Combining the Fire Danger and Fire Weather Working Teams,” proposed replacing the two working teams with one new working team with an increased scope encompassing weather, fire danger, fire behavior, climatology, predictive services, and smoke.
The proposed Fire Environment Working Team (FENWT) will integrate weather, behavior and danger, coordinated with predictive services, air/smoke management, fuels management and the National Weather Service.
The FENWT will include three standing committees to address Fire Behavior, Fire Danger, and Fire Weather. The working team will serve as steering group and coordinator for the three committees, and as liaisons with external groups, committees, strategic partners, NWCG, and NASF.
The proposed management structure for the working team consists of a chair and vice chair, executive secretary, facilitator, and NWCG Liaison. The chairs would periodically rotate. The executive secretary and facilitator roles are proposed to be position job duties (justified by work volume) – not just adjunct duties. The secretary and facilitator would provide continuity, coordination and stability to the team. The NWCG Liaison needs to be an active participant.
A draft FENWT charter was presented to the NWCG for consideration.
NWCG members expressed support for the organizational concept, but not for NWCG budget/funding for the proposed positions. Members do support agency contributions of positions’ time for participation.
Interagency representation on committees needs to be ensured in the charter. It was requested that wording be added to the charter to ensure (“strive for”) agencies are represented on the committees.
Concerns were expressed about how research is represented – should it be represented by a single member on the team or by individual reps from each Research Strategic Partner. It was requested that wording be inserted into the charter to add a research representative to the team membership with duties defined as representing the broad view of research across research entities.
The intent for the FENWT chair to be a separate member not serving as one of the other member roles was clarified. The wording of “Chair responsibility” addressing representation may be too vague – requested inserting “agency” after “NWCG” in the final chair responsibility.
Decisions:
Accept the proposed management structure with no NWCG budget for facilitator or executive secretary.
Modify charter to ensure agencies are represented on committees. Modify charter to add member representing research. Modify charter to clarify chair responsibility.
FENWT Charter approved as amended.
Paul Schlobohm appointed as Chair to the new team.
Alice Forbes appointed as Liaison. Hugh Wood will replace Alice Forbes as Liaison to the WFIWT.
Action: Paul Schlobohm to draft NWCG letter regarding sunsetting the FDWT and FWWT and the chartering and startup of the FENWT. Draft to Alice Forbes for review; then to the NWCG Executive Secretary for distribution.
The IMT Technical Assistance Program is a program to develop IMTs at state, regional and local levels. The program is aimed at a standardized, all-hazards approach across response communities based on the ICS and NIMS.
There is a need for Type-3 teams at state and metro-area levels; Type 4 teams at city and county levels; and Type-5 teams at local village and township levels.
The Type-3 program includes a shadowing experience of Type 1 or Type 2 IMTs during major incidents coordinated through NIFC under MOU with USFA and USFS. Type 3 position-specific training, including position task books, is planned for FY 05 development. Training will be based on the NWCG model. Certification will be done by State or other appropriate entities. Refresher/sustainment training is planned for development in FY 06.
The NASF Fire Committee proposes NWCG be more proactive in looking at developing equivalencies of training and experience in local fire departments – similar to what was done with the FCOG (Australia).
There are on-going questions on how to tap into the resources of the local departments for use in wildland fire activities – how to make it easy for local departments to support the wildland fire need. Identifying equivalencies can save money by avoiding duplications of training and can help identify qualified local resources.
Most local fire department training curricula are based on NFPA standards, so there shouldn’t be many differences among the local curricula – but a detailed look is needed to validate this assumption.
Leadership training is an area that has raised current concerns – many local curricula include leadership training that could be equivalent, rather than requiring essentially duplicate training.
There are concerns about how to maintain the equivalencies after they are established – monitor and maintain as training changes.
Action: USFA (Hugh Wood, lead) to develop a cooperative agreement to fund and lead a pilot effort with NWCG, NFPA, IAFC, and USFA to look at a few select courses (I-courses and some S-courses, esp. leadership training) from a small number of states to scope the work needed to develop equivalencies. NIMS Integration Center also should be involved.
Action: Kirk Rowdabaugh to request agenda time at the next NASF meeting (Jan 10, 2005) for a briefing on IQCS.
The Critical Infrastructure Protection (CIP) Program is located at the US Fire Administration’s Emergency Management and Response (EMR) Information Sharing and Analysis Center (ISAC).
ISAC Membership includes all emergency management, emergency medical services, fire, including wildfire, and hazardous materials responder agencies and their members, all of whom constitute the Emergency Services Sector of the nation.
The CIP Program and its ISAC are promoting proactive activities to protect people, physical entities, and communication/cyber systems and are promoting methods and resources to deter or mitigate attacks against critical infrastructures.
The EMR-ISAC mission is to promote critical infrastructure protection and the deterrence or mitigation of attacks by providing timely and consequential CIP information to the senior leaders of the emergency services sector.
EMR-ISAC publishes Sensitive CIP Notices (For Official Use Only). These contain emergent, actionable information For Official Use Only regarding threats to and vulnerabilities of the Emergency Services. Notices are forwarded through a secure portal quickly after receipt from the DHS.
To obtain Sensitive CIP Notices for organizational leaders, identify those who have the need to know and develop a spreadsheet of all contact info (name, email address, USPS mail address, physical location of office, phone numbers) for the identified individuals. Forward spreadsheet to the EMR-ISAC (emr-isac@dhs.gov) or call 301-447-1325 for assistance
DHS preference is for DHS to have the list and distribute directly to ensure most timely distribution, rather than having notices centrally screened (at NIFC) and distributed to selected fire personnel. The central screening and distribution may be appropriate for the InfoGrams.
The CIP Process Job Aid, a user-friendly guide to support the implementation of the CIP process, is accessible at: http://www.usfa.fema.gov/fire-service/cipc/cipc-jobaid.shtm. Also available from this site is Homeland Security Advisory System Preparedness Guide.
Actions: Sam Lombardo to forward spreadsheet template to Allen Deitz. Allen will coordinate with NWCG members to gather contact names/info to return to the EMR-ISAC.
The IBPWT was not formally tasked with this action after the May NWCG meeting. IBPWT hasn’t addressed it, but plans to work on it this fall.
Working team taskings should be in writing from the NWCG Chair (or WT Liaison) to the WT Chair. Kirk prefers all correspondence to go through the NWCG Executive Secretary for tracking.
Decision: Defer this topic to the January NWCG meeting. Address again with the results of the December WFLC meeting.
Action: Lyle Carlile, IBPWT Liaison, to advise the IBPWT to wait for tasking from January meeting.
A template has been drafted by the IBPWT; the team feels the draft is ready for legal review.
Discussion: May not be ready for legal review. Mike Dougherty (per Alice Forbes) has concerns on language regarding disaster declarations and charge-back processes (paragraphs 6 & 11) and feels the interoperable telecommunications are problematic.
The Federal authorities can be captured in the template; but it is not feasible to capture all the State authorities. Suggest including Federal authorities in the template.
Action: Lyle Carlile will give comments to Hallie Locklear [add Federal authorities and Mike Dougherty’s changes] to incorporate into the template. After updating, IBPWT to distribute to NWCG members for another review. After review, send to FS (Forbes) and DOI/BLM (Hamilton) for legal review.
IBPWT was requested to study the best use of contract crews and engines in light of current cost containment objectives. IBPWT feels it is unable to address this issue at this time due to the size and complexity of the issue. Several other studies have been done; FS OIG is currently conducting an audit.
The IBPWT proposes to wait until current FS OIG audit is finished and report is released, then ask NWCG to re-assess.
This was reported as accomplished in the June submittal to WFLC.
Decision: Drop until OIG audit is completed. Address when/if it arises again.
The IBPWT feels the IIBM Handbook already sufficiently addresses the agreements. The Team requests further direction and clarification on this taking from the NWCG.
Members were asked to consider if the current processes are working with Kirk Rowdabaugh located outside the Boise area. Consensus was expressed that, in general, the processes are working, but can be improved.
Members agreed upon the following suggestions for improving meetings:
Agenda items should only come from members; working team items should come through the respective WT Liaison.
Agenda requests should include an estimate of needed time so agenda can be time scheduled. To facilitate scheduling, any constraints on days/times should also be identified with agenda item request.
Add an open-forum / round-robin item for members to bring up last minute items. Schedule toward the end of the meeting.
Meeting hosts should look for locations/facilities with good internet connectivity (high-speed, if possible) and cell-phone coverage. If not available, attendees need to know in advance.
During meetings, ensure actions and decisions are recorded before moving on to the next agenda item. Members are comfortable with informality, as long as decisions are well recorded.
Longer breaks during meetings would allow work (phone calls, etc.) to be done; everyone needs to make effort to reconvene on time. Suggested 30 minute mid-morning and mid-afternoon breaks with a 90 minute lunch break. Meeting days will be planned for 8:00 am – 5:00 pm.
Members agreed upon the following suggestions for improving business procedures between meetings:
For time-critical issues, email the issue/document to members for short-term review/comment (5 days) with feedback through Kirk Rowdabaugh for incorporation. The final (draft) then routed back to members for last-minute review (2 days) before distribution (especially important for content changes). Final document distribution by/through the Executive Secretary.
NWCG decision documents are distributed to members who are then responsible to take the documents to (and through) their respective agencies. The NASF Fire Director (Don Artley) distributes documents to the States via NASF distribution list.
Final NWCG documents will be posted on the NWCG Web site.
The NWCG Working Team/Advisory Group chairs held a one-day, group meeting on September 22, 2004, to exchange information and discuss issues of common concern.
The chairs are requesting agenda time at the May NWCG meeting to present issues and recommendations to the Parent Group.
Decision: One or two representatives are invited to present issues and recommendations at the Spring 2005 meeting.
The Safety & Health and Fire Use Working Teams do not have consensus on the April 2004 memo sent to NWCG. The teams feel more work is needed before they can make a valid recommendation.
NWCG members agree this is a planning process issue and it is up to the planning agency to identify needed resources, including safety officer, for the burn.
Action: Mike Long to draft short letter to both teams stating the NWCG position that the assignment of a safety officer to prescribed burns is a planning process issue and is adequately covered in the planning process.
A proposal to update the IRM-PMO charter was discussed in the last IRMWT meeting. The IRMWT will try to have a draft updated charter for presentation to NWCG at the January meeting. This raises a question of whether the PMO charter should be updated by the IRMWT or should the NWCG commission a group to look at updating the charter?
Decision: Revision of the NWCG IRM-PMO charter should be at the initiative of the NWCG Parent Group – not the IRMWT.
The Contract Group has decided the work/rest guidelines apply to crews and engines, but do not apply to showers and caterers. Bus drivers are covered by DOT regulations.
Multiple, uncoordinated Web page efforts have been on-going in support of incidents. These efforts are building public expectations. Costs for these efforts are escalating. There is a need some general guidelines.
Questions arise about who is paying for the ISPs, who is “in charge” or coordinating the efforts, and who is the business lead? Should this be addressed by NWCG, NMAC, NFAEB, or who?
NWCG could work to develop interagency standards or task the NFAEB to provide guidance to the ICs, however, the NMAC/GMAC would provide broader input from the fire community.
Action: Refer the issue of incident Web pages to NMAC/GMAC. Alice Forbes will carry the issue to Kim Christensen.
Questions arose during the 89 th meeting about the appropriate instrument (charter or MOU) and signatories.
Action: Phil Street to take draft updated NWCG MOU to Sherry Garey (BLM Grants/Agreements Specialist) for review. Bring final draft of the correct instrument to the January NWCG meeting.
The National Wildland Fire Enterprise Architecture (NWFEA) Steering Group has funding commitments and is ready to launch the NWFEA project. Project deliverables are the As-Is and To-Be architectures, a Transition Plan, and the NWFEA program infrastructure. The project team will include the four PMO positions.
A Systems Coordination Group is being formed under the IRMWT. The group has PMO representation (Al Borup, Application Architect). The group will address issues of systems as they transition from development to O&M.
DOI is requiring certified project managers be assigned to each DOI project. To fulfill this requirement, BLM-NIFC is proposing to add a full-time, certified project manager to staff. This position would manage multiple projects through deputy or assistant project managers assigned to individual projects.
The Fire Occurrence Reporting Project business study has begun. Contracting is in process. The project should ramp-up quickly as soon as the contract is finalized.
The NWCG Data Architect is proposing a non-monetary group award to the NWCG Unit ID Data Custodians. Permission is requested to use the NWCG logo; it is proposed to give the award from the NWCG (Parent Group) rather than from the DAWG. Forest Service will process and fund the award.
Decision: NWCG supports the proposal and gives permission for use of the NWCG logo on the award.
Action: Alice Forbes to follow up with Judy Crosby to process a non-monetary group award through the FS.
A strategy paper for developing a training delivery package for volunteer and rural fire departments is being presented to the IOSWT and TWT at their meetings this week. It was noted these actions cannot be accomplished by a small group of people. The NWCG could be the catalyst if it is given the appropriate priority.
Statutory authority does not constrain the ability to develop a reserve cadre. Current efforts are sporadic and unorganized. Need is to do it in a coordinated manner on a national scale. Only constraint appears to be the availability of funding for a national effort.
A national pilot using suppression/EFF funding may be feasible. Need to focus on the high-priority positions needed to be developed.
Issue 2 – Efficient interagency response:
Clear consistent policy on qualifications for local/rural FD personnel: Being addressed by the IOSWT in the 310-1 update. The IOSWT is drafting a policy statement to be presented for approval at the January NWCG meeting.
Equivalencies for RFDs: The NFPA standards are frequently the standards RFDs are required to meet, not the NWCG standards. The outcome of the Training WT proposal regarding equivalencies will have significant impact on this issue.
Re-issue of national mobilization policy for initial attack: Completed. NWCG reissued the policy (3/22/04). The IOSWT will include language in the 310-1 update.
State/local participation in FPA: Completed. Alaska, Montana, and Oregon have agreed to participate.
Not many states/local jurisdictions are being included in FPA. This action is for the FPA tool to allow/enable inclusion/participation of state and local jurisdictions – not to actively involve them – just enable their participation. Federal partners in some areas are not including state/local resources in the mix.
Action: Don Artley to follow up to change the implementation plan status to reflect what is complete/what is not complete. I.e., Design complete – Implementation not complete.
Local FD participation in NWCG: still being worked – discussions with IAFC and USFA.
NWCG is tasking IBPWT to re-address some issues with the Mutual-Aid Agreement template
Completed. A mutual aid reporting requirement has been added to NFPORS.
It is unclear whether NFPORS requires entry of this field or leaves it as an optional entry.
Action: Kirk Rowdabaugh would like to see copies of the Federal policy statements directing development of agreements with local FDs. Agency Fire Directors to provide Kirk with copies.
Reimbursement of RFD personnel for regional/national mobilization: work is in process. Currently, States cover costs pending re-imbursement from Federal agencies. Issues arise when States are unable to cover costs.
Issue 3 – Emergency communications capability:
No action to date. Conference call scheduled with NWCG RNAG.
same as a.
The FCCA (Forestry and Conservation Communications Association) has agreed to consider the frequency issue. However, it appears to have very limited chance for success.
Issue 4 – Coordinated federal and state assistance:
A coordination group has been organized and is active.
Work is still in process. It will be difficult to change the matching requirements of the VFA program to match the RFA program – will likely require legislation.
A single application form has been agreed upon for VFA & RFA programs.
NFPORS has been modified to accommodate tracking the grant and cost-share program accomplishments.
USFA is not currently tied into the NWCG fire reporting requirements project. The NWCG project is scoped to include the USFA in the business study. NWCG aim is a single system for use by all. There is a need to get the IAFC involved for local fire departments participation.
same as e.
Efforts to raise the screen priority for state and local governments with regard to federal excess property is on track – currently awaiting final congressional action.
The NWCG Glossary of Wildland Fire Terminology update is done, the glossary is ready to go. The Team expects to send the glossary to NWCG for review within the month. IOSWT will also present to NWCG an issue paper regarding the need for a “Super Glossary”.
The IOSWT currently is meeting with the TWT to address the 310-1 update. Many requests for additional positions have been received. Some are for positions that are not nationally mobilized, but are positions the proponents want to standardize.
The Team is preparing a proposed policy statement addressing the use of local FD personnel on large fires. The policy statement will be sent to NWCG for the next meeting.
Leadership training courses (L-courses) are controversial as added training to states. The training is perceived as good, but the economics of funding and time is of concern.
The Team is struggling with the work volume to keep up with it in a timely manner. Some issues take a year to address and formulate responses with volunteer group meeting three times per year. The 310-1 update is consuming much of the available time/energy. When the big items (410-1, glossary, and 310-1) are done, time should be available to address the many smaller issues.
Team membership changes have impacted participation with several external committees. As new members come up to speed, this should stabilize.
The TWT is discussing leadership training – may be coming to NWCG with a request for budget adjustment. The Team is running into a number of issues with conversion to all-risk.
The TWT has been prioritizing workload/efforts based on safety.
The Forest Service (USDA FS F&AM briefing paper, October 12, 2004) is recommending the NWCG assemble and direct a NIMS Transition Working Team to develop a transitional training program to help wildland fire agencies understand NIMS and the National Response Plan (NRP); to provide recommendations on potential disposition of I-courses; and the develop plans for engaging wildland afire agencies in the ongoing development and implementation of the NIMS and the NRP.
The recommendations are aimed at ensuring the NWCG NIIMS will continue to be the source documents for NIMS, rather than NIIMS being driven by NIMS.
During discussion, it was noted that NIIMS cannot form the basis for NIMS without being fully documented. There are bits and pieces, but has never been assembled into a current and comprehensive document/set of documents. During its development, NIIMS never kept pace with FIRESCOPE and other local/municipal standards for such as hazmat.
It is not realistic to expect NIIMS to be the driver of NIMS; rather NWCG needs to get involved in the driving of NIMS. A proactive NWCG approach to get involved on steering/executive groups driving the NIMS efforts was suggested. Addressing the perceived fire bias of ICS is also needed.
At the January meeting, NWCG will work to reach a decision on how to proceed with involvement in NIMS.
Action: Alice Forbes to work with USDA/FS personnel currently involved with DHS initiatives to engage them as an NWCG point person to assess the need and opportunity for more formalized participation by OWFC and NWCG. Brief the NWCG at the January meeting.
Action: Hugh Wood to set up a briefing from the DHS NIC (NIC Director or other) at the January NWCG meeting.
Success is predicated on planning and implementing an aggressive landscape scale vegetative management program and nine key recommendations:
Improved Capacity and Capability: Change Federal agency policy to require employee support of incident management and develop incident management positive requirements for unit level agency administrators.
Type 3 IMTs: Significantly increase the number of Interagency Type 3 incident management teams.
Training: Streamline the NWCG fire training and qualifications program to reduce redundancy & more effectively focus on the needs of the various positions.
Legal Authorities: Improve and standardize the legal authorities to allow effective implementation of incident management across all levels of government.
NMAC IMT Management: The National MAC becomes responsible for standardization & mobilization of Type 1 and Type 2 incident management teams.
Non-traditional Partnerships: Actively seek partnerships with other federal agencies (i.e. EPA, Coast Guard, FEMA) to improve capacity for the development and utilization of incident management personnel for fire and non-fire incidents.
Improved Hiring Authority: Reduce dependency on retirees and improve the temporary emergency hiring authorities.
Standardized Contracts: Standardize pay rates, contracts, performance standards and common definitions of inherent government functions.
Complex Incident Management: Develop a new model for managing complex incidents that utilizes social values, significant resource values & cost/benefits in the decision making process.
An interagency implementation strategy will be required to address the specific aspects of this recommendation such as: chain of command, pay/grade structure, methods to include state and local government participation, duty stations, and administrative support structure.
Analysis Conclusion The analysis did not find a silver bullet. None of the alternatives analyzed were affordable based on the current funding levels and structure. None reduce the reliance on the agency “militia” or increase the capacity at the local level to complete natural resource work. None of the alternatives provide a career path for employees interested in working in large incident management.
However, the team determined that hiring and developing a small number of employees with large incident management as their primary responsibility would result in significant benefits if implemented along with the key recommendations presented.
Action: Schedule presentation of final NIMO report for NWCG review and deliberation at the January meeting.
Decision: Approve the FY05 budget as adjusted, total at $1,207,000, pending final budget appropriations.
Action: Alice Forbes will request additional funds for FS share of adjusted budget ($1,207,000). DD: Oct 27, 2004 (Wed)
Action: NWCG conference call to address final budget: October 28, 1:00 PM Mountain Time, if FS funds not available.
Notes from October 28, 2004 conference call: Additional FS funding is not available. (FS funding of the Medical Standards position is confirmed (NFAEB issue).) DOI agencies are able to cover their proportionate shares of the needed funding.
Working teams are encouraged to be fiscally responsible and to try to come in within or under budget for the year. Teams should hold down costs by meeting in cost-effective locations.
Decision: Add $5,000 FY05 state travel funding for the Social Science Advisory Group.
Decision: Release budget as adjusted (total $1,212,000). Budget expenditures and funding to be re-assessed at the May meeting.
Action: Kirk Rowdabaugh to contact Jim Hubbard (OWFC) to discuss funding needs and options.
Jim Hubbard moving to OWFC (as of November 1); will be replaced by Jeff Jahnke as chair of the Fire Committee. Jahnke will sit on the WFLC.
NPS
There is a growing concern about the need to address national resources contract and contractor issues. Unsure if this is an issue most appropriately addressed by NFAEB or NWCG, or other group.
FS
Predictive Services meeting in Boise (NICC briefing room) next week. Fire Directors are welcome to attend.
Retirements coming up: Rich Wands, Buck Latapie, Mike Funston, and three ICs from region 5
FS-Fire Research
Working through next 6 months to assess what “we” are doing with fire research (driven by performance budgeting). Results of stakeholder groups show:
managers: social science side needs bolstering
continued high interest in science delivery
need to ensure basic research continues
BLM
Budget – there has been concerns expressed about some of the funding going into NFPA (or other organizations). These organizations are not required to abide by the Federal contracting regulations that agencies must follow – looking at need to require organizations to follow Federal contracting regulations
