Rescue 21 Maintenance Contract

VHF Marine Band radios, protocol, radio communication theory, practical advice; AIS; DSC; MMSI; EPIRB.
Posts: 9767
Joined: Fri Oct 09, 2015 12:25 pm
Location: Michigan, Lower Peninsula

Rescue 21 Maintenance Contract

Postby jimh » Tue Dec 06, 2016 8:09 am

General Dynamics was recently awarded a three-year contract to provide to the Coast Guard technical services for maintenance of the RESCUE 21 radio system. Here is the press release:

The contract allows for $125,600,000 in fees to General Dynamics. Let's look at this cost on a basis of daily expense. In three years there are 1,095-days. This means the daily cost of RESCUE 21 system maintenance is going to be

$125,600,000 / 1095-days = $114,703-per-day to be spent on maintenance of the RESCUE 21 system.

General Dynamics has about 100,000 employees. Their annual sales in 2015 were $31,469,000,000. This suggests the gross annual revenue per employee is about $3,146,900. On that basis we can estimate the number of employees that will work on RESCUE 21 by figuring the annual RESCUE 21 revenue. The $125,600,000 three-year contract means an annual revenue of about $41,866,667. This suggests that if General Dynamics will have their typical ratio of revenue-to-employee, there will be

$41,866,667-annual revenue / $3,146,900-per-employee = 13.3-employees

working on this contract.

Let us assume that General Dynamics people will work an eight-hour day providing these services. This means the hourly rate for their service on the basis of an eight-hour work day will be

$114,703-per-day / 8-hours in a day = $14,338-per-hour.

Divided by the 13.3-employees, this suggests the cost of this contract on the basis of an hourly labor rate will be about

$14,338-per-hour / 13.3-employees = $1,078-per-hour-per-employee working on the RESCUE 21 maintenance.

As the old saying goes--that's nice work if you can get it. Actually, the hourly rate might be higher because I figured it on the basis of 365-days worked per year. If the employees only work five days a week, the rate will be proportionally higher.

This contract is not for construction of new facilities. It is just a maintenance contract to maintain the system that was already delivered and paid for. [See additional postings below for further information on the nature of the work to be performed under the contract. There will be some new equipment installed in a limited number of facilities under this contract, mainly related to converting to the modern P25 APCO digital radio standard.]

Posts: 9767
Joined: Fri Oct 09, 2015 12:25 pm
Location: Michigan, Lower Peninsula

Re: Rescue 21 Maintenance Contract

Postby jimh » Tue Dec 06, 2016 9:59 am

After quite a bit of searching, I believe I have found more information on this contract award. See

Justification for Other than Full and Open Competition Under 10 USC 2394(c)(1)
FAR6.302-1 Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements

Curiously, the above document has been redacted and in many instances dollar amounts have been blacked out.

If the above link does not work, try this one:

Posts: 626
Joined: Tue Oct 27, 2015 9:57 pm
Location: LSD Lower Slower Delaware

Re: Rescue 21 Maintenance Contract

Postby porthole » Tue Dec 06, 2016 10:38 am

2016 World Cat 230DC
1999 Outrage 21, Yamaha SW Series II 200
1997 Outrage 18, Yamaha 125
1983 15 SS, Honda 50
1980 42 Post
1983 34 Luhrs 340 SF

Posts: 9767
Joined: Fri Oct 09, 2015 12:25 pm
Location: Michigan, Lower Peninsula

Re: Rescue 21 Maintenance Contract

Postby jimh » Tue Dec 06, 2016 12:06 pm

[I found it annoying that the contract award explanation was not in a text format but was, rather, in rasterized text, or scanned text. This is frustrating because rasterized text cannot be indexed and searched for keywords. I then took the scanned document and used Optical Character Recognition software to convert it to text. I then reviewed and corrected the text. I also explain a few of the odd acronyms used. Below I provide the text of the contract justification notice as actual text, instead of a picture of text. This should get this information into a form where it can be more easily read and, more importantly, indexed and searched--jimh]

[From the PDF scanned text version linked above]

Justification for Other than FulI and Open Competition
Under 10 U.S.C. 2304 (c)(I)
FAR 6.302·1 Only One Responsible Source and No Other Supplies or
Services Will Satisfy Agency Requirements

Pursuant to the requirements of the Competition in Contracting Act (CICA) as
implemented by FAR 6.3 and in accordance with the requirements of FAR 6.303-1, the
justification for the use of the statutory authority under FAR 6.302-1 (a)(2)(iii)(A) is
justified by the following facts and rationale required under FAR 6.303-2 as follows:

(1) Agency and Contracting Activity.

The Department of Homeland Security (DHS), United States Coast Guard (USCG), C4IT
Service Center (C4ITSC) Contracting and Procurement Office, proposes to enter into a
new contract on the basis of other than full and open competition.

(2) Nature and/or description of the action being approved.

The USCG has a requirement for continued support and sustainment of the Rescue 21
Coastal (R21-C) system at an estimated cost [redacted]. This J&A
approves $153M of this cost to be awarded on a sole source basis to extend from the date
of contract award for 36 months (July 1,2016 through June 30, 2019).

The following information is provided:

(a) Type of action: Contract with a hybrid of CLINS [contract line item numbers] which includes Firm Fixed-Price
(FFP), Cost Plus Fixed Fee (CPFF), and Time and Material (T&M) CLINS;

(b) Amount: Support and sustainment of the R21-C system for $153M;

(c) Type of funding: Support and sustainment of the R21-C system using Operations
and Maintenance funds;

(d) Year of funding: [redacted] from FY 2016, [redacted] from FY 2017, [redacted] from FY
2018, and $[redacted] from FY 2019; and

(e) The USCG anticipates award of this sole source contract to General Dynamics
Mission Systems (GDMS) (formerly GDDS and GDC4S), 8201 East McDowell
Road, Scottsdale, Arizona, 85257.

(3) Description of Supplies/Services.

This non-commercial services requirement for sustainment of the R21-C system will
provide for all management, engineering services, personnel, labor, materials, and
equipment to support and maintain the R21-C system, subsystems and equipment
required to perform organizational and depot level maintenance, including information
assurance, system design maintenance, engineering escalation, technology refreshment,
and obsolescence management, for all fielded R21-C systems and equipment described

The R21 Coastal VHF/UHF communication and DF/DSC system consists of the

--32 USCG Sector (SCC) equipment suites (Backroom servers & (3) operator
consoles per Sector)

--167 USCG Station equipment suites with (I) operator console per

--258 Remote Fixed Facilities (RFF's) with typical configuration of 5 VHF
transceivers, 1 UHF transceiver, voice & data servers, digital processors, data
switches, RF filters, RF interference mitigation, Direction Finding, equipment
huts, tower, tower lighting, environmental sensor, antennas, and standby
power generation subsystems

--4 Disaster Recovery (DR) mobile equipment suites (portable RFF, portable
tower/antenna, portable satellite communication suites, & portable generator

--1 Disaster Recovery (DR) R21-C Sector Command Center equipment suite at
USCG OSC Martinsburg, W VA

--1 Rescue 21 Coastal Operator Training Simulation suite with 60 student work
stations at TRACEN Petaluma, CA

This requirement will also support USCG efforts to make system design changes that
substantially reduce R21-C proprietary interfaces and software.

Additionally, this sole source contract will deliver technology refreshment and
obsolescence management/sustainment engineering activities for the legacy R21-C
system to include hardware and software integration of R21-C APCO P25 compliant
VHF and UHF radios at R21-C Remote Fixed Facilities (RFFs) and an APCO P25
compliant radio control subsystem to the proprietary legacy R21-C Direction
Finding/Digital Selective Calling (DF/DSC) subsystem located at USCG Sectors.

The three-year sole source contract will support Low-Rate Initial Production (LRIP)
deployment of new P25 compliant VHF and UHF radios at selected R21 Coastal RFFs
and a new P25 compliant radio system to three USCG Sectors.

The R21-C communication and direction finding system is an advanced command,
control, and communications system that provides dual mode (digital and analog) VHF
and UHF communications to meet USCG operational, reliability, and maintainability
requirements specified in the R21 Operational Requirements Document (ORO) approved
July 2008 and the R21 Performance Specification (P-Spec).

The R21-C system provides simultaneous VHF/UHF communications, direction finding
(DF), and digital selective calling (DSC) functionality for maritime users in the
continental United States, Hawaii, Guam, and Puerto Rico.

Sustainment of the R21-C radio communication and DF/DSC system shall ensure the
R21 critical functions listed below are provided at the specified availability, measured
monthly by USCG Sector Area of Operational Responsibility (AOR).

Rescue 21                            Operational
Critical Functions Availability

Receipt of distress and
emergency alerts (VHF-FM Ch 16) 99.5%

Digital Selective Calling (DSC) data 99.5%

VHF-FM Maritime Voice Communications 99.5%

UHF Voice Communications 99.5%

Protected Communications 99.5%

Caller Position Location.
Single Line-of-Bearing
(LOB) Information) 99.5%

Archiving/Recording Functions 99.5%

It is anticipated the sole source contract will include hybrid CLINS which includes FFP
sustainment CLINS and Technology Refresh/Obsolescence CLINS of a T&M or CPFF
nature. The sustainment CLINS will be FFP as there is sufficient historical information
on costs, system access, availability, reliability, and maintainability for GDMS to
ascertain a reasonable price without unnecessary risk. Technology Refresh and
Obsolescence CLINS will be negotiated as FFP when possible and as Time and Material
(T&M) or Cost Plus Fixed Fee (CPFF) when sufficient uncertainty exists for technology
refreshment and lor obsolescence efforts.

The required funding for the sole source contract is shown in the following table:

3-Year Contract (36 months):

The Period of Performance (POP) for this requirement is a 6-month base with two 12-
month options and a third option for 6 months. The total estimated value for this
requirement is planned as follows:

[All data in table redacted]

The technical representatives have verified that the requirement for the 3 year sole source
action, as detailed in the performance work statement, represents the Government's
minimum requirements.

(4) Identification of the justification and the rationale.

This acquisition is being conducted under the authority of IO.U.S.C. 2304(c)(1), as
implemented by the Federal Acquisition Regulation (FAR) Subpart 6.302-1 titled "Only
One Responsible Source and No Other Supplies or Services Will Satisfy Agency
Requirements; specifically FAR 6.302-1 (a)(2)(iii)(A)."

(5) Demonstration that the nature of the acquisition requires use of the authority cited.

Uninterrupted R21-C functionality is required for the USCG to facilitate national
compliance with the International Maritime Organization's Safety of Life at Sea
(SOLAS) treaty. A lack of SOLAS compliance, besides [affecting] safety problems, also puts
in jeopardy other roles of the USCG including national security (i.e. Secret Service
details, DOD security evolutions, events of national significance, etc.), national disaster
response, and that of Port State Control agency for the United States. In this capacity, the
USCG ensures SOLAS compliance for all U.S. port facilities as well as all U.S. flagged
vessels including offshore drilling rigs using R21-C and Vessel Traffic Services systems.

Background: The major system acquisition strategy for initial development and
deployment of R21 capabilities consisted of a two-phased approach designed to broaden
competition and reduce Government cost risk. Phase I, Concept and Technology
Development (C&TD), utilized full and open competition in 1999 to award contracts to
three different vendors to develop preliminary designs for the R21 system. These vendors
included Motorola (later bought by General Dynamics), SAIC, and Lockheed Martin.
Upon successful completion of the Phase I contracts in February 2002, R2l formally
entered Phase II, the Capability Development and Demonstration (CD&D) and
Production and Deployment (P&D) Phase. The USCG held a limited competition, open
to the three successful Phase I contractors, for the development of a final production
design and the building, designing, testing, and deployment of the whole R2l system.
GDDS was awarded the Phase II Indefinite Delivery/Indefinite Quantity (IDIQ) contract
in September 2002. The base period of the R21-C Phase II contract ended on September
30, 2014, with complete deployment of a R21 -C system that meets mission requirements.

The solicitation for both the Phase I and II contracts included FAR Provision 52.227-15
"Representation of Limited Rights Data and Restricted Computer Software." In
accordance with this clause, both Motorola and GDC4S included in their proposal
submissions a list of data and computer software that are subject to Restricted Rights.
These lists were incorporated into their respective contracts via Section K. In addition,
Motorola identified in its proposal for Phase I that if chosen[,] the company would
purchase specific capital items (approximately worth [redacted] and privately-owned
software [redacted] for purposes of project execution. These items would be
purchased with private funds, not with the government's funds. This software thus
became proprietary to Motorola and subject to restricted rights for the government.
GDC4S obtained this software from Motorola when it acquired the division during Phase
I of the Rescue 21 Project.

All software, source code, and technical data (other than commercial software and the
Motorola proprietary software) developed during the performance of the Phase II contract
is subject to FAR Clause 52.227-14 Rights in Data-General, and the government retains
unlimited rights to use, disclose, reproduce, and distribute copies to the public for any
purpose and to have or permit others to do so. However, the Rescue 21 system is a hybrid
of proprietary software/source code, software and source code developed under the
performance of the Phase II contract, and commercial computer software. As such, it is
subject to the restrictions placed on each type of software, source code or technical data.

Rescue 21-C is a search and rescue system with specific coverage and Operational
Availability (Ao) requirements; any interruptions in system functionality could severely
impact the USCG's ability to carry out its fundamental mission of saving the lives of
mariners in distress. Under the longstanding GDMS maintenance contract, the R21-C
system meets both coverage requirements and Operational Availability for all critical
functions (Channel 16, VHF, UHF, Digital Selective Calling (DSC), Direction Finding,
and Archive/Retrieval). GDMS developed, and therefore holds restricted rights to, critical
segments of the software source code, scripts, configuration files. and interface data. As
designed, all of the R21-C subsystems and components are inextricably linked and rely
on the proprietary software and data to operate. GDMS is the only company capable of
supporting the Rescue 21-C system as currently configured.

Currently, a sole source contract is in place with GDMS. It was awarded on March 30,
2012, to provide for the support and sustainment of the R2l-C system while deployment
of the base period of the R21-C Phase IT contract was completed and to ensure continued
life-cycle support for the fielded R21-C system. This contract will end June 30, 2016.
The conditions necessitating the current sole source contract to GDMS still remain.

Even before the deployment of the R21-C system was completed in 2014, the Coast
Guard was assessing strategies to reduce R21-C sustainment costs and improve the ability
to compete significant portions of the system operation and maintenance requirements
without endangering mission requirements. This can be done through this sole source
contract to GDMS, along with additional contract actions identified in the R2l
Acquisition Plan (AP), where annual sustainment costs will gradually shift from [redacted]
sole source to GDMS to [redacted] sole source to GDMS by July 2024.

During this 3-year sole source contract to GDMS, system changes will eliminate existing
proprietary components, software, and interfaces as well as decouple tightly integrated
segments of the existing GDMS R21-C architecture, which will result in two subsystems.

The first will be a radio subsystem with an open architecture based on commercial
standards. There will be no proprietary/custom components associated with the radio subsystem.
The radio sub-system will be deployed to three USCG Sectors during this 3-year
sole source contract. The second sub-system will be a DF/DSC sub-system which will
remain proprietary to GDMS. This subsystem hosts the proprietary source code upon
which the GDMS R21-C technical solution is based. It was through the use of this
privately developed baseline that GDMS successfully competed for the original Rescue
21 contract. Currently, no commercial standard is available for this subsystem.

Additional contracts identified in the R21 AP will facilitate deployment of the R21-C
change to two major subsystems (radio and DF/DSC) to the remaining 29 USCG Sectors
and transition to competition based, operation and maintenance of R21-C at all 32 USCG

By this approach, R21-C will meet operational requirements; leverage the investment
already made in this critical, lifesaving system; and promotes the maximum amount of
competition for continued sustainment of the R2l-C system.

In accordance with FAR 6.302-1(a)(2)(iii)(A), Only One Responsible Source and No
Other Supplies or Services Will Satisfy Agency Requirements, for DoD, NASA and the
USCG, services may be deemed to be available only from the original source in the case
of follow-on contracts for the continued provision of highly specialized services when it
is likely that award to any other source would result in substantial duplication of cost to
the Government that is not expected to be recovered through competition.

As currently configured, no other source can maintain the R21-C system because they
will not have access to the proprietary data necessary for system maintenance. A
company could potentially introduce a new system, but that system would have to be
developed, tested, and fielded at Coast Guard expense because there is no other market
for the R21-C requirements. The Coast Guard spent $[redacted] over 13 years to successfully
deploy the R21-C system. There is no compelling argument to indicate it would not take
similar time and money to transition to a new R2l-C system and during that transition,
the current system would have to remain operational.

(6) A description of the efforts made to ensure that offers are solicited from as many
potential sources as is practicable.

A Sources Sought Notice was issued via FedBizOpps, on October 13,2015, covering this
sole source action. The USCG needed to determine whether there are any other sources
that can meet the Coast Guard's technical and schedule requirements for modification and
sustainment of the R21-C system. The USCG requested interested companies provide a
capability statement detailing how they would gain access to support system baselines
and the proprietary monitoring system; detail how all modification and sustainment
capabilities will be fully operational by July 2016; and detail how they would gain access
to proprietary GDMS software elements, or reproduce existing software to support
division into a Radio Subsystem and DFIDSC Subsystem.

(7) Determination by the Contracting Officer that the anticipated cost to the Government
will be fair and reasonable.

The Contracting Officer has determined that the anticipated cost to the Government for
the supplies/services will be fair and reasonable based on prior acquisition history. For
example, the supplies and services to be provided under this proposed contract have been
provided by GDC4S (now GDMS) to the USCG under contract DTCG23-02-DNDRS02
for nine years and under contract HSCG23-11-C-ANS 104 for three years. This
historical data limits pricing risks to both the USCG and GDMS. The USCG will also
utilize historical contract pricing as a basis for determination of fair and reasonableness
of proposed pricing. Additionally, certified cost and pricing will be obtained. GDMS
has a DCMA approved Cost Accounting System and the USCG will utilize DCMA
Forward Pricing Rate Recommendations (FPRR) in its determination of fair and
reasonableness. An audit will be conducted if necessary.

(8) Description of market research.

The customer conducted market surveys to identify new sources of supply and services
necessary to maintain the system. Additionally, the C4IT Service Center hosted two
Industry Days; one in November 2014 and one in February 2015. During both events,
several vendors shared concerns regarding the requirements of the acquisition and
questioned the type of system, technical, and design information available to them in
order to propose on the current system and competitively compete with the incumbent.
Multiple vendors described familiarity and experience deploying and supporting systems
adhering to open commercial standards (i.e. APCO P25, T1A-I02.BAHA).

The feedback received from prospective vendors is consistent with the Coast Guard
Technical Authority's determination, in paragraph 9 below, that the proprietary design of
the R21-C system does not allow for a third party contractor to maintain it without
unacceptable risk to Coast Guard mission. The system changes described in paragraph 5
will eliminate proprietary components/software and reduce the interdependence of the
tightly integrated segments of the existing R21-C architecture; promoting the maximum
amount of competition for continued sustainment of the R21-C system.

(9) Any other facts supporting the use of other than full and open competition.

The Technical Authority (CG-6) concluded that the Government or a third party
contractor cannot maintain or modify the existing R21-C software (SW) without detailed
knowledge of the SW structure and a complete set of R21-C SW source code, scripts,
configuration files, and interface data. The Technical Authority determined that the
operational and technical risks were too great to USCG mission execution. To advance a
new software support and hardware integration program, associated workforce, and
qualify a third party vendor to meet USCG R21 operational requirements is not viable
with the current tightly integrated proprietary design and with available Government
owned intellectual property without unacceptable technical and operational risk at the
USCG Sector mission execution level.

(10) A listing of the sources. if any, that expressed, in writing, an interest in the

Two responses were received from the USCG's Source Sought Synopsis published in
FedBizOpps on October 13,2015. One response was from SAIC and the second response
was from Motorola Solutions. The responses did not comply with the requirements of
the RFI. Neither company provided the information requested to assure the USCG they
can modify and sustain the existing system prior to the planned transition without causing
unacceptable delays in the transition to competition and negatively impacting the
availability of the Rescue 21 safety-of-life system,

(11) A statement of actions, if any, the agency may take to remove or overcome any
barriers to competition before any subsequent acquisition for required supplies or

As described in paragraph 5, the Coast Guard has prepared a comprehensive plan to
remove current barriers to competition without introducing significant technical and
operational risk to the Government before any subsequent acquisition for sustainment of
the R21-C system. This plan includes another five year, sole source contract with GDMS
as detailed in the Acquisition Plan, The estimated value of this contract is [redacted].

Once this sole source contract and additional contract actions identified in the R21-C AP
are complete, the DF/DSC sub-system will remain proprietary to GDMS. It is estimated
that an annual [redacted] sole source contract with GDMS will continue to be required. The
remaining requirements for maintenance and support of R21-C will be competed, The
estimated annual competitive maintenance and support costs will be [redacted].

Throughout this R21-C transition-to-competition effort, re-procurement data and
appropriate intellectual property will be acquired to enable competitive sustainment of
the R21-C system.

(12) Contracting Officer 's Certification.

I certify that the data supporting the recommended use of other than full and open
competition is accurate and complete to the best of my knowledge and belief.

[Name and signature redacted]
Contracting Officer
C4ITSC, TISCOM Contracting and Procurement Branch

(13) Technical/Requirements Personnel Certification.

I certify that this requirement meets the Government's minimum need and that the
supporting data, which forms a basis for the justification, is accurate and complete.

[Name and signature redacted]
RMS Product Line Manager
Technical Representative

(14) Legal Review and Concurrence:

I have reviewed this justification and deemed it legally sufficient.

[Name and signature redacted]
Procurement Attorney


[Name and signature redacted]
USCG Procurement Activity Competition Advocate

[Name and signature redacted]
Chief Procument Officer
Department of Homeland Security

Posts: 24
Joined: Thu Dec 24, 2015 8:15 pm

Re: Rescue 21 Maintenance Contract

Postby alloyboy » Tue Dec 06, 2016 2:39 pm

Not to worry. It is all being paid for with printed money. Just print some more.

Posts: 9767
Joined: Fri Oct 09, 2015 12:25 pm
Location: Michigan, Lower Peninsula

Re: Rescue 21 Maintenance Contract

Postby jimh » Tue Dec 06, 2016 5:03 pm

To give some comparison of this contract cost to the cost to acquire other assets, consider the acquisition cost for the Coast Guard of one RESPONSE BOAT, SMALL, II (RB-S-II). This is the 28-foot boat that has been replacing the old 25-foot S.A.F.E. boats for several years. The initial contract award for these boats resulted in a per-boat cost of about $342,000. We can figure how many days of RESCUE-21 maintenance it takes to spend the same amount:

$342,000 X $114,703-per-day = 2.98-days

That means that every three days of the General Dynamics maintenance contract of RESCUE 21 costs as much as getting a new Response Boat. Let's see, over 1095/3 days, the USCG could have gotten 365 new Response Boat, Small-II boats. I am sure they don't need that many boats, but, heck, the life span of each boat is going to be at least ten years. The life span of the daily cost of the maintenance contract on RESCUE 21 is one day. At the end of every three days that money is spent and you don't have any real asset to go forward with, other than perhaps a few radio parts or some software. With the boats, every three days you get a boat that will last at least ten years and possibly much more.

Since the RB-S-II boats have radios, and their range is about ten miles, if you had 365 of them spaced 20-miles apart--so their radio coverage would overlap--you could cover 7,300-miles of shoreline with their radios.

More about the RB-S-II acquisition at

Posts: 626
Joined: Tue Oct 27, 2015 9:57 pm
Location: LSD Lower Slower Delaware

Re: Rescue 21 Maintenance Contract

Postby porthole » Wed Dec 07, 2016 10:09 am

I nominate Jim for the new cabinet position of Secretary of Common Sense government spending, accountability and waste control.
2016 World Cat 230DC
1999 Outrage 21, Yamaha SW Series II 200
1997 Outrage 18, Yamaha 125
1983 15 SS, Honda 50
1980 42 Post
1983 34 Luhrs 340 SF

Posts: 9767
Joined: Fri Oct 09, 2015 12:25 pm
Location: Michigan, Lower Peninsula

Re: Rescue 21 Maintenance Contract

Postby jimh » Wed Dec 07, 2016 10:42 am

PORT--thanks. I have not heard from any executive branch officials, so I won't hold my breath.

One curious aspect of RESCUE 21 maintenance: every RFF installation I have visited has been on a leased site. The site owner is doing the "maintenance"--cutting the lawn, painting the tower, replacing the tower lights that burn out, fixing the fence, paying the taxes on the land, plowing the snow on the road leading to the site--all that sort of stuff. The site owner paid for all the facilities to be built: the tower, the power service, the fence, the infrastructure on the site.

I am sure there are a few RESCUE 21 sites, probably in some remote place in Alaska, where the government owns the land, bought and installed the tower, built the helipad, and so on, but I suspect that the majority of the sites are on leased towers. The lease payments to the site owners for using their towers in RESCUE 21 are just part of the operational cost of the system. No one knows how much that adds up to. But this $125-million for technical services, that is a lot of technical service being furnished.