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. • • • 2 7. The subagreement does not include Article 8 (Project Design) or Article 12 (Labor Standards) of Appendix C-1. 8. Section X of the subagreement has been rewritten from Appendix C-1, Article 11 (Subcontracts), and is not acceptable. 9. Section XI of the subagreement does not include age as a basis of non-discrimination as required by Appendix C-1 Article 13 (Equal Employment Opportunity). 10. Section XIV of the subagreement has been rewritten from Appendix C-1, Article 16, (Gratuities) and is not acceptable. Reference to employees of the State has been improperly deleted. 11. We note that a copy of the subcontract between your engineer and Louis Fontenot and Associates for the amount of $55,000.00 was not in- cluded with the application documents. You are reminded that your engineer will be responsible for compliance with all procurement regula- tions applicable to his subcontract including the determination of the reasonableness of the cost. 12. The subagreement does not identify the time for performance and ` certify to the sufficiency of personnel and facilities as required by 40 CFR 35.937-9(b). 13. Review of the Cost/Price Summary (EPA Form 5700-41) revealed the following discrepancies. Unless otherwise noted, the following apply to both the prime and subcontractor. a. The firm should submit documentation detailing the estimating system(s) used to determine the total hours of each employee. The hourly rates should also be documented. b. The firm should submit supporting data showing how they arrived at the 30~ indirect cost rate, which in our experience appears to be low. Fontenot's indirect cost total should be $11,307 and also extended to the totals column. Busch's indirect cost total should be $67,710.