0040637534_JA_v3_posted_1.pdf

JUSTIFICATION AND APPROVAL, PR 0040637534

Justification for Other Than Full and Open Competition (FAR 6.3)

1. Contracting Agency and Activity. The Department of the Interior, United States Geological Survey, Office of Acquisition and Grants, Sacramento Branch plans to contract by means other than full and open competition. This document sets forth the justification and approval for use of one of the exceptions to full and open competition allowed under the Competition in Contracting Act (CICA) of 1984.

2. Nature of Action Being Approved. The action being approved is a new contract with a base three-month period of performance and three additional optional three-month periods of performance for a total potential period of performance of one year. The intended awardee is Hensel Phelps Services.

3. Description of Supplies or Services. The USGS requires Operations and Maintenance (O&M) services at its facilities at Moffett Field, CA. The contractor will be expected to inventory USGS facilities, develop a preventive maintenance program which will be the basis of a subsequent acquisition, and execute the preventive maintenance program for potentially up to a year if all options are exercised. All serviceable assets are to be maintained in accordance with manufacturers’ recommendations so that manufacturer warranties are preserved. The scope of work also includes “break/fix” services as necessary on a time and materials basis. The requiring program office is the Office of Management Services.

4. Estimated Dollar Value. The estimated dollar value is $1.2M if all options are exercised.

5. Statutory Authority. The proposed action may be awarded without full and open competition under 41 U.S.C. 3304(a)(1) as implemented in FAR 6.302-1.

6. Rationale Supporting Use of Citation in No. 5.

The USGS is nearing the end of its years-long effort to relocate from its former campus in Menlo Park, CA to Moffett Field, CA. There has been significant construction/renovation at Moffett Field in preparation for this move; significantly:

• Approximately 50,000 gross square feet (GSF) of new-build laboratory space (building 800);

• Approximately 100,000 GSF of renovated office space across two floors and part of the basement of historic building 19; and

• Approximately 40,000 GSF of warehouse space (bay 1 of building N144).

There are several other small spaces which do not merit listing individually.

Hensel Phelps Construction Company (HPCC), a division of Hensel Phelps, built the laboratory with substantial completion occurring in December 2023. The office space was renovated in two phases. The second floor was renovated in 2019-2020 by a construction company that is no longer in business. The first floor and part of the basement were renovated by HPCC with substantial completion July 2024, but that work also included moderate scope on the second floor. The warehouse is being renovated by another construction company, expected substantial completion November 2024, but that space includes very little expected preventive maintenance scope.

Hensel Phelps also has a services division, Hensel Phelps Services (HPS), which specializes in facilities operations, maintenance, and management, and which is the intended awardee here.

HPS can partner with and leverage HPCC’s experience having built USGS’ facilities which require O&M services to effectively first define and then (for a short term) execute a facilities preventive maintenance program. Any other company would have to start from scratch with no knowledge of the facilities or the assets within them. Meanwhile, USGS does not currently have any in-house capability to perform necessary preventive maintenance and hundreds of assets are ageing out of warranty. There is no incumbent facilities operations specialist or laboratory facilities manager; human resources recruitments are pending for both positions. HPS can immediately and simultaneously begin performing simple routine maintenance such as filter changes, coil cleanings, etc. and writing a detailed Facility Operations Manual which will inform future USGS personnel and form the basis of a Performance Based Work Statement which can be used in a future acquisition. USGS cannot prepare this document internally nor expect another contractor to do so in order to meet mission timelines. Facilities must be kept in a state of repair as they are not only an expensive Government asset, but contain life/safety systems for employees, contractors, and visitors.

7. Other Information. As stated above, USGS does not have in-house personnel at this time with the detailed knowledge of these facilities required to develop an actionable PWS for a competitive acquisition. Previous facilities at Menlo Park were GSA-owned and thus there was no USGS facilities manager with comparable responsibilities to transfer to Moffett Field. HPS can provide us with the necessary requirements development services and short-term execution to act as a bridge to in-house personnel and a future contractor.

8. The Efforts to Identify Additional Sources Including the Market Research Conducted.

The original plan was a fair opportunity task order competition under GSA’s best-in-class (BIC) building maintenance and operations (BMO) GWAC. There are nineteen (19) vendors on the BMO Zone 5 small business suite, but only three (3) of them responded to a sources sought notice posted in the fall of 2023. This plan, however, was predicated on USGS being able to internally develop a technical requirements package and having an in-house facilities manager in place, neither of which have occurred.

9. Future Plans to Permit Competition. One of the primary deliverables expected from this action is a Facilities Operations Manual which can be used as the basis of a Performance Based Work Statement in a planned future competitive acquisition, whether through GSA’s BMO or otherwise. We expect this year-long contract to be enough time to develop the requirements document and solicit/award a new contract.

10. Recommendation and Certification from Program Office

Based on the above, I recommend this acquisition be conducted on the basis of other than full and open competition. I certify that technical data which form a basis for this justification that are the responsibility of technical or requirements personnel are complete and accurate.

/s/

JOHN BROWN

Chief, National Center Operations Branch

11. Certifications from the Contracting Officer

The anticipated cost to the Government will be fair and reasonable, analyzed and documented in further detail when a final proposal is received. Proposed hourly rates for the T&M break/fix tasks are reasonable; we will examine the asset list and preventive maintenance task list to determine an appropriate expected level of effort and overall price.

All the requirements of the Competition in Contracting Act, (41 U.S.C. 3301 et seq), as implemented in the Federal and Interior Acquisition Regulations, have been considered in preparing this justification. This justification is accurate and complete to the best of my knowledge and belief.

JEFF CARAVELLI

Contracting Officer

12. Approvals

SASHA KLINGLER

Chief, Office of Acquisition and Grants, Sacramento Branch

JENNIFER KELLEY

Bureau Competition Advocate

JUSTIFICATION AND APPROVAL, PR 0040637534