Pakistan International Airlines

Transcription

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2 Bidding Documents for Purchase of ATR72/ Simulator (Ref: DCP/Purchase/Sim-ATR/Jun-2016) Pakistan International Airlines

3 Table of Contents SECTION A - INSTRUCTIONS TO BIDDERS Scope of Bid Parties qualified to apply Technical Specifications of the ATR72/ Simulator Cost of Bidding Bidding Documents Clarification on Bidding Documents Amendment to Bidding Document Extension in Submission Dates Offers for Simulator Submission of Bid Tender Proceedings Bid Related Details: Deadline for Submission of Bids: Late Submission of Bids: Modification and Withdrawal of Bids: Opening of Bids: Bid Read Out: Preliminary Examination of Bids: Qualification: Deliberations with Bidders: Correction in Bids Evaluation of Bids Unsuccessful Bidders: Ranking of Bids: Letter of Acceptance PIA s Right Signing of Contract Agreement SECTION B GENERAL CONDITIONS OF CONTRACT Scope of Agreement Governing Law Disputes Civil Aviation Authority Requirements Payment Terms Taxes Integrity Pact Notices Indemnities Force Majeure SECTION C EVALUATION OF BIDS Technical Evaluation Criteria Financial Evaluation Criteria Methodology for Assessing Lowest Evaluated Bid Annex - I Annex - II Annex - III Annex - IV Annex - V Bidding Document for Purchase of ATR Simulator Page 2 of 20

4 This document is divided into three sections. Preamble The first section gives interested parties an overview of the process and explains in detail as to how they should submit their bids and how their bids will be evaluated by PIA along with the details of PIA s requirement in terms of the simulator acquisition. The second section contains general terms which shall form the basis of the agreement between PIA and the successful bidder. The third section covers the interested bidders with an overview of PIA s evaluation process to maintain complete transparency and criteria that would be used to determine the best suited offer. The annexure contained thereafter are the standardized formats on which PIA expects to receive the actual offers from the interested bidders. Bidding Document for Purchase of ATR Simulator Page 3 of 20

5 Section A - Instructions to Bidders 1. Scope of Bid Pakistan International Airline (PIA) invites sealed bids from interested parties for the acquisition of new/used Full Flight Simulator as below: Simulator Type: ATR72/ Engine Model PW127 Certification Standard Level D Delivery Schedule: Immediate but not later than July Parties qualified to apply Manufacturer/Owner/Lessor having legal right to sign the agreement. 3. Technical Specifications of the ATR72/ Simulator General Requirements Type/Variant ATR Standard Approval Level ATR72/ Currently Applicable ATR ZFT (Zero Flight Time) Level - D FFS Qualification Standard Currently Applicable: Federal Aviation Authority (FAA) CFR Part 60 /European Aviation Safety Agency (EASA) CS-FSTD A /International Civil Aviation Organization (ICAO) Doc 9625 edition 3 Engine 127 E/F/M Visual System Laser/LED/LCOS/Non LCOS Projector Based with 200 x 40 / Field of View Control Loading Aircraft Systems Simulation Digital/Electrical Control Loading All aircraft systems covered by all ATA chapters shall be simulated as per approved data. Motion System Instructor Station Electro-hydraulic / Electric Motion System Forward Facing Concept (FFIOS)/Side Facing with two high resolution color touch LCDS with all accessories including writing surface, capable of multi weather Bidding Document for Purchase of ATR Simulator Page 4 of 20

6 and Line Oriented Flight Training (LOFT) scenarios, Flight Management System (FMS) flight plan copy/ load functions, Automatic Terminal Information Service (ATIS), Traffic Collision Avoidance System (TCAS), wind shear prediction and detection + UPRT (Upset Recovery Training) No. of Malfunctions No. of Airport Models Instrument Fit TCAS Fit 150 Standard + 50 Customized Complete Visual Library. 20 customized Airports Electronic Flight Instrument (EFIS) Version 7.1 or Higher Special Aircraft Systems Weather Radar, Enhanced Ground Proximity Warning System (EGPWS), GNSS/GPS Windshear models etc. Additional Capabilities Smoke Generation, UPS, and Electronic Crew Debrief Station Installation Certification PIA Training Centre, Flight Simulator Building near Terminal #1 JIAP Karachi Certification by EASA and PCAA 4. Cost of Bidding The bidder shall bear all costs associated with the preparation and submission of its bid and PIA will in no case be responsible or liable for those costs, regardless of the conduct or outcome of the bidding process. 5. Bidding Documents For the purpose of this bidding process, the term Bidding Documents shall include: i) Invitation for Bids ii) Instructions to Bidders iii) General Conditions of Contract iv) Special Conditions of Contract v) Evaluation of Bids vi) Annexures a) Bidder s Profile (Annex I ) b) Technical Proposal (Annex II ) c) Financial Proposal (Annex III ) d) Form of Bid (Annex IV ) e) Integrity Pact (Annex V ) Bidding Document for Purchase of ATR Simulator Page 5 of 20

7 The bidders are expected to examine all the above prior to submission of their bid. The Instructions to Bidders will not be part of Contract and will cease to have effect once the Contract is signed. 6. Clarification on Bidding Documents A prospective bidder requiring any clarification(s) in respect of the Bidding Document shall notify PIA in writing. PIA will respond to any request for clarification which it receives earlier than five (5) days prior to the deadline for the submission of bid. 7. Amendment to Bidding Document At any time prior to the deadline for submission of bid, PIA may, for any reason, whether at its own initiative or in response to a clarification requested by a prospective bidder, modify the tender document by issuing addendum(s). 8. Extension in Submission Dates At any time prior to the deadline for submission of bid, PIA may, for any reason, whether at its own initiative or to provide prospective bidders reasonable time, in which to take an addendum into account, at its discretion extend the deadline for submission of bids. 9. Offers for Simulator Bidders can submit bid for brand new and/or used simulator, award of contract will be based on the lowest responsive evaluated bid. 10. Submission of Bid Interested bidders will have to submit their offer in sealed envelopes either in person or through courier. Each offer should be clearly marked as Bid for Acquisition of ATR72/42-500Simulator. In case the bidder wants to send the bid electronically, they can the same on fleet@piac.aero in either PDF or MS Word format. The electronic document in either format should be password protected and the bidder will have to send the password on the same address on or before the closing time of bid submission. PIA shall not be responsible for delay in electronic submission of bids to the address mentioned above, for any reason whatsoever. 11. Tender Proceedings Single Stage One Envelope tendering process shall apply as detailed below: Each bid shall comprise one single envelope containing, separately, Technical Proposal and Financial Proposal. All bids received shall be opened and evaluated in the manner prescribed in the bidding document. Bidding Document for Purchase of ATR Simulator Page 6 of 20

8 i) Technical Proposal: Technical Proposal shall comprise of the following along with the covering letter on the official letter pad of the bidder; a) Bidder Profile: A brief company as per Annex I. b) Technical Information: The technical information of simulator as per Annex II. c) Form of Bid: Duly completed and signed by the bidder as per format provided in Annex IV. No alteration is to be made in the Form of Bid except in filling up the blanks as directed. d) Integrity Pact: The bidder shall sign and stamp the Form of Integrity Pact provided at Annex V which is a mandatory requirement of Government of Pakistan. Failure to comply with this requirement shall result in automatic rejection of the bid. e) Product / Spare Support Package: Additional Support Package (Training or any other available credit, spares support against RSPL, financing, etc) if any, may be provided. f) Requirements for Installation of Simulator: Bidder shall provide the requisites for installation of Simulator at PIA Training facility at Karachi. ii) Financial Proposal: The Financial proposal should include cost of simulator and as per the requisite given in Annex III. 12. Bid Related Details: Below information should be noted while preparing and submitting the bids. i) Currency of Bid: All the prices provided in the bid as per 10 (ii) above shall be in US Dollars (US$). ii) Bid Validity: The bid shall have to be valid for a period of 90 days from closing date of tender. iii) Language of Bids: The bids prepared by the bidder and all correspondence and documents relating to the bid, exchanged between the bidder and PIA shall be written in the English language. If a document is in any other language other than English then bidder shall provide a true copy of that document in English. iv) Format and Signing of Bids: The bidder shall prepare one set of the bid typed or written in indelible ink and shall be signed by the Authorized Representative of the bidder (who should be an employee of the bidder). Bidding Document for Purchase of ATR Simulator Page 7 of 20

9 v) Sealing and Marking: Technical Proposal and Financial Proposal should be clearly marked. The envelope should bear the name and address of the sender and clearly marked as Purchase of ATR72/ Simulator. If the envelope is not sealed and marked, PIA will assume no responsibility for the bid s misplacement or premature opening. 13. Deadline for Submission of Bids: Bids must be received by PIA at the following address no later than 1500 Hrs (Pakistan Standard Time) on 11 July 2016: Director Corporate Planning PIA Head Office, Karachi Airport Karachi, Pakistan Phone: fleet@piac.aero 14. Late Submission of Bids: Any bid received by PIA after the bid submission deadline time, for any reason whatsoever, shall be rejected and returned to the bidder. 15. Modification and Withdrawal of Bids: The bidder may modify or withdraw its Bid after submission, provided that written notice of the modification or withdrawal is received by PIA prior to the deadline prescribed for bid submission. No Bid may be modified or withdrawn in the interval between the deadline for submission of bids and the expiration of period of Bid Validity. 16. Opening of Bids: Pakistan International Airlines will open the bid on 11 July 2016 at 1530 Hrs (Pakistan Standard Time) in PIA Head Office, Jinnah International Airport, Karachi 75200, Pakistan in the presence of bidders who choose to attend the bid opening. Bidders are encouraged to attend and for clarity it may be noted that only direct employees of the bidders would be allowed to attend the bid opening. 17. Bid Read Out: Following details of each bid shall be read out in front of all the participants present during the bid opening: i) Bidder s name ii) Bids offered for Simulator Type iii) Bidder s status (i.e. Manufacturers, Owners, Operators etc.) iv) Price v) Other support package (if any) Bidding Document for Purchase of ATR Simulator Page 8 of 20

10 18. Preliminary Examination of Bids: PIA will examine the bids to determine whether they are complete and generally in order. Prior to the detailed evaluation of bids: i) PIA will examine the Bids to determine whether; a) the Bid is complete and does not deviate from the scope, b) any computational errors have been made, c) the Bid is valid till required period, d) the Bidder/Manufacturer is eligible to Bid and possesses the requisite skill and experience. e) the Bid does not deviate from basic technical requirements and f) the Bids are generally in order. ii) A bid is likely not to be considered if it is materially and substantially different from the Conditions/Specifications of the Bidding Documents. 19. Qualification: In addition to the above, PIA will ascertain to its satisfaction whether bidders, whose bids meet the requirements of Bidding Documents, are qualified to satisfactorily perform the contract. This will take into account: Bidder s eligibility as per Clause 2 of Section A Bidder s financial strength, technical capabilities and past performance. Whether bidder is currently the owner directly or indirectly, of the simulator being tendered. Documentary evidence submitted by the bidder. Previous experience of manufacturing / delivering similar simulator (Bidders be asked to provide referral from their current / past customers. Other information as PIA deems necessary and appropriate. 20. Deliberations with Bidders: No bidder shall be allowed to alter or modify his bid after the bids have been opened. However the procuring agency may seek and accept clarifications to the bid that do not change the substance of the bid. Any request for clarification in the bid, made by the procuring agency shall invariably be in writing. The response to such request shall also be in writing. 21. Correction in Bids In case any arithmetic error is found in the bid, it shall be rectified as follows: i) If there is a discrepancy between the unit price and total price or between Bidding Document for Purchase of ATR Simulator Page 9 of 20

11 ii) iii) subtotals and total price that is obtained by multiplying the unit price and quantity, the unit or subtotal price shall prevail and the total price shall be corrected. If there is a discrepancy between the words and figures the amount in words shall prevail. If the bidder does not accept the corrected amount of bid as determined above, the bid shall be rejected. 22. Evaluation of Bids All bids shall be evaluated in accordance with the evaluation criteria and other terms and conditions set forth in the prescribed bidding documents. For the purposes of comparison of bids quoted in different currencies, the price shall be converted into a single currency specified in the bidding documents. The rate of exchange shall be the selling rate, prevailing on the date of opening of bids specified in the bidding documents, as notified by the State Bank of Pakistan on that day. The bids will be evaluated to determine the Lowest Evaluated Bid as per Section C. 23. Unsuccessful Bidders: Bidders whose offers have been rejected on grounds of being substantially nonresponsive or those that do not meet the requirements shall be informed accordingly. 24. Ranking of Bids: After completing the evaluation of the offered bid(s) for each type of simulator shall be listed separately in ascending order starting from the lowest evaluated bid. 25. Letter of Acceptance The Letter of Acceptance will be issued to bidder whose offer for simulator is determined as the lowest evaluated bid. In case the lowest evaluated bidder withdraws its offer or is unable to deliver for any reason the second lowest bidder will be selected. 26. PIA s Right PIA reserves the right to reject all bids and to annul the bidding process at any time prior to award of Contract. PIA upon request from bidder, who submitted a bid, shall communicate the grounds for its rejection of all bids, but is not required to justify those grounds. Notice of the rejection of all bids shall be given to all the bidders. 27. Signing of Contract Agreement The terms and conditions highlighted under Section B - General Condition of Contract (of this Tender Document) shall form the basis for the Agreement. Bidding Document for Purchase of ATR Simulator Page 10 of 20

12 Section B General Conditions of Contract Following terms and conditions shall be an integral part of the Purchase Agreement to be signed between PIA and the successful bidder to whom the contract has been awarded. 1. Scope of Agreement The Agreement shall be on terms and conditions as explained in this Section B General Conditions of Contract. 2. Governing Law Governing Law of the Purchase Agreement shall be agreed mutually between PIA and the Bidder. However, it should not be in conflict with the laws of Pakistan. 3. Disputes Any dispute between the parties shall be resolved under International Chamber of Commerce - Amicable Dispute Resolution (ICC ADR) Rules, failing which the parties shall try to resolve these differences through ICC Arbitration which should not be in conflict with the laws of Pakistan. 4. Civil Aviation Authority Requirements Seller must comply with the requirements of Pakistan Civil Aviation Authority (PCAA) and FAA / EASA prior to the Delivery of simulator 5. Payment Terms i) Currency of Payment: All the payments between the two parties shall be in US Dollars. ii) Invoice: Seller shall send the invoice at least fifteen days before the due date. 6. Taxes Where a Tax Avoidance Agreement (Double Taxation Treaty) exists between the respective countries of the Lessee/Buyer and the Bidder; and the Buyer is obliged by law to deduct taxes against payments to the Bidder, the Lessee/Buyer will bear the tax incidence and shall make gross payments to the Bidder, without any deduction of tax chargeable in Pakistan. However, the bidder undertakes to pass on the benefit of tax credit obtained under the relevant clauses of the tax treaty to the Buyer, after filing of income tax return in its country, on the basis of proof of taxes paid by the Lessee/Buyer on behalf of Bidder in Pakistan. In the absence of such tax treaty, the Lessee/Buyer shall deduct the amount of applicable taxes from payments due to the Bidder and deposit the same with taxation authorities in Pakistan and shall make gross payments to the Lessor, without any deduction of tax chargeable in Pakistan. Bidding Document for Purchase of ATR Simulator Page 11 of 20

13 All other taxes, duties, levies and imposts arising from or relating to such payments outside Pakistan shall be borne by the Bidder. 7. Integrity Pact The Agreement shall contain a covenant and confirmation by the Bidder that it has not obtained and/or induced the procurement of the Purchase Agreement through any corrupt business practices. The wordings of this clause are given at V. No change in the test of integrity pact is allowed. 8. Notices All the notices during the lease term to be exchanged between PIA and Bidder shall be in writing and sent by courier, fax or Indemnities The Agreement shall have appropriate coverage to provide indemnity for PIA and Bidder as per the normal aviation practice. 10. Force Majeure Both parties shall agree to appropriate incidents to define Force Majeure and its implications on the performance of the Agreement by either party. Bidding Document for Purchase of ATR Simulator Page 12 of 20

14 Section C Evaluation of Bids In order to ensure that the acquisition process is conducted in fair and transparent manner, following Evaluation Criteria will be followed to determine the best suitable offer for PIA in efficient and economical manner: 1. Technical Evaluation Criteria Following Criteria will be used for Technical Evaluation. General (10%) Vintage Brand New YOM YOM Points Engine Variant ATR74/42 ATR72 or 42 Points 10 5 Delivery & Installation 09 months 12 months 12+ months Motion & Control Loading (5%) Motion Type All Electrical Hybrid Hydrostatic Points Control Loading Electrical Actuators Hydraulic Actuators Points 10 5 Instrumentation (5%) Instrumentation Aircraft Instrument as per PIA Inventory Simulated Instrument Points 10 5 Visual (10%) Projector (30%) Laser Projector Based LED Projector Based LCOS Projector Based Points Field of View (10%) 220 * * 40 Points 10 7 Image Generators (10%) COTS Availability COTS Non-Availability Points 10 5 Operating system diagnostic Capabilities Yes No Points 10 5 Library Models (LM) (50)% LM with 20 PIA Customized Airports LM only Points 10 5 Bidding Document for Purchase of ATR Simulator Page 13 of 20

15 Host Computer (5%) Computer Off the Shelve COTS Non COTS Points 10 5 Operating system Built in diagnostic Capabilities Yes No Points 5 1 Hardware and Software Back up Capabilities Yes No Points 5 1 Instructor Station (10%) Instructor Station Design Forward Facing Side Facing Points 10 5 Instructor Station Capabilities as per PIA Training Completely Partial Points 10 1 Field Service Engineer (5%) Six Months Three Months Not Provided Points Spares and Test Equipment (10%) Complete Provisioning for Critical Spares and QTG Test Equipment Incomplete Provisioning for Critical Spares and QTG Test Equipment Points 10 5 Additional Capability (10%) Smoke Generation Yes No Points 5 1 Electronic Crew De Brief system Yes No Points 5 1 UPS with 20 minutes Backup Yes No Points 10 1 Warranty and Product Support (10%) Warranty 4-5 Years 2-3 Years 1 Year Less than 1 Year Points Product Support 15 Years Years 5-9 Years Less than 1 Year Points Operation & Maintenance Training of FFS and Visual (10%) Yes No Bidding Document for Purchase of ATR Simulator Page 14 of 20

16 Points 10 1 Manufacture Experience - (10%) Level-D Simulators Built Less than 5 Points Level-D Simulator of same type Built Less than 5 Points A = Points obtained x Financial Evaluation Criteria The financial comparison will be based on Net Present Value of Project Cash Flows over the Lease term: Marks will be calculated as per following formula: B = PVx / PVy x 100 PVx = Net Present Value of Cash Flow of offered Simulator PVy = Highest Net Present Value of Cash Flow amongst all offered Simulators. 3. Methodology for Assessing Lowest Evaluated Bid Following methodology will be used for assessing the Lowest Evaluated Bid: X = [(A x TEW] + [(B x FEW] Where, X = Net Outcome A = Marks obtained in Technical Criteria B = Marks obtained in Financial Criteria TEW = Technical Evaluation Weightage = 40% FEW = Financial Evaluation Weightage = 60% The offer with highest Net Outcome will be considered as the Lowest Evaluated Bidder. Bids shall be listed in ascending order starting from the lowest evaluated bid. The bidder(s) whose offered simulator is determined as the lowest evaluated bid for simulator will be considered as the Lowest Evaluated Bidder(s). Bidding Document for Purchase of ATR Simulator Page 15 of 20

17 Annex - I Bidder Profile Bidder/s should provide the following detail on their company letter head. Name of the Company: Head Office Address: Local Office Address (If any) (Address in Pakistan) Contact / Focal Person: Name: Designation: Telephone: Fax: Type of the Company: 1. Public 2. Private 3. Other List of Customer Airlines / Training Centers: Financial Health (Provide Last three years Annual Reports): Signature: Print Name: Date: Title: Company Stamp: Bidding Document for Purchase of ATR Simulator Page 16 of 20

18 Annex - II Technical Information 1. Simulator Availability The bidder will have to confirm the delivery schedule by which the simulator will be installed at Karachi. 2. Product/Spare Support Package The bidder should provide the details of, if any, Product/ Spare Support Package that it is offering to PIA. 3. Simulator Specifications Bidders would be required to provide all the latest version of technical information including standard technical specifications, options available and the related documentation / drawings thereof. 4. Requirements for installation of Simulator at PIA Facility Bidder would be required to ensure that the Simulator should be installed at PIA Training Centre Facility (i.e. Flight Simulator Complex). Installation should be complete in all respect including commissioning, testing and acceptance by EASA/ FA and PCAA. Bidding Document for Purchase of ATR Simulator Page 17 of 20

19 Annex - III Financial Proposal 1. General The Financial Proposal shall be read in conjunction with the conditions of tender together with the Technical Proposal. 2. Currency US Dollars (USD). 3. Rates i. Unless otherwise stipulated, the amounts provided by the bidder shall not be subject to adjustment. ii. The whole cost of complying with the provisions of the Contract shall be included in the items provided in the Financial Proposal. iii. The bidder shall be deemed to have obtained all information which may affect the bid value. 4. Price i. The price of Simulator should include all the requirements for ready for training at Karachi including technical requirements highlighted in this document including Technical Specification of ATR72/ Simulator (Section A, Clause 3). ii. Price for additional options/features including but not limited to data package, spare support, maintenance training, field service representative, testing tools and equipment, upgrade option etc. are to be provided as part of the financial proposal. iii. iv. Proposal for financing this acquisition including ECA financing, if available, should be provided separately. If the bidder can provide the Simulator on operating / financing lease the detailed terms and conditions should be provided. Bidding Document for Purchase of ATR Simulator Page 18 of 20

20 To: Annex - IV Form of Bid Stage Bid Date: Ref: DCP/Purchase/Sim-ATR/June-2016 Director Corporate Planning Pakistan International Airlines Dear Sir, Having examined the Bidding Documents, we, the undersigned, offer for acquisition of ATR72/42-500Simulator as per following delivery schedule under the tender reference DCP/Purchase/Sim-ATR/Jun-2016 in full conformity with the said Bidding Documents against the terms and conditions mentioned in the Financial Proposal Annex III. We undertake, if invited to do so by you, and at our own cost, to attend a clarification meeting at a place of your choice. We agree to abide by this Bid, for a period of 90 days from the date fixed for submission of bids as stipulated in the Bidding Documents, and together with the above written undertakings, it shall remain binding on us. We undertake, if our bid is accepted, to install the Simulator as per the dates mentioned in our bid. Until a formal contract is prepared and executed between us, this bid, together with your written acceptance thereof and your notification of award shall constitute a binding contract between us. We understand that you are not bound to accept the lowest or any bid you may receive. Signature of Authorized Person Name : Position: Official Seal Dated this day of, 20 Bidding Document for Purchase of ATR Simulator Page 19 of 20

21 Integrity Pact Annex - V [Name of Bidder] hereby declares its intention not to obtain or induce the procurement of any contract, right, interest, privilege or other obligation or benefit from Government of Pakistan or any administrative subdivision or agency thereof or any other entity owned or controlled by it (GoP) through any corrupt business practice. Without limiting the generality of the foregoing, [Name of Bidder] represents and warrants that it has fully declared the brokerage, commission, fees etc. paid or payable to anyone and not given or agreed to give and shall not give or agree to give to anyone within or outside Pakistan either directly or indirectly through any natural or juridical person, including its affiliate, Representative, associate, broker, consultant, director, promoter, shareholder, sponsor or subsidiary, any commission, gratification, bribe, finder s fee or kickback, whether described as consultation fee or otherwise, with the object of obtaining or including the procurement of a contract, right, interest, privilege or other obligation or benefit in whatsoever form from GoP, except that which has been expressly declared pursuant hereto. [Name of Bidder] certifies that it has made and will make full disclosure of all agreements and arrangements with all persons in respect of or related to the transaction with GoP and has not taken any action or will not take any action to circumvent the above declaration, representation or warranty. [Name of Bidder] accepts full responsibility and strict liability for making any false declaration, not making full disclosure, misrepresenting facts or taking any action likely to defeat the purpose of this declaration, representation and warranty. It agrees that any contract, right, interest, privilege or other obligation or benefit obtained or procured as aforesaid shall, without prejudice to any other right and remedies available to GoP under any law, contract or other instrument, be voidable at the option of GoP. Notwithstanding any rights and remedies exercised by GoP in this regard, [Name of Bidder] agrees to indemnify GoP for any loss or damage incurred by it on account of its corrupt business practices and further pay compensation to GoP in an amount equivalent to ten time the sum of any commission, gratification, bribe, finder s fee or kickback given by [Name of Bidder] as aforesaid for the purpose of obtaining or inducing the procurement of any contract, right, interest, privilege or other obligation or benefit in whatsoever form from GoP. Signature of the Bidder (Name, Title and Address) (Official Seal) Bidding Document for Purchase of ATR Simulator Page 20 of 20