Control Number: G-26-006

JUNE 2025

JUSTIFICATION REVIEW DOCUMENT

FAR Part 6 Justification and Approval for Other than Full and Open Competition

Program/Equipment: Indefinite Delivery Indefinite Quantity (IDIQ) for Civil and Structural Engineering Work within USAG Ansbach

Authority: Title 10 United States Code (U.S.C.) §3204 as implemented in Federal Acquisition Regulation (FAR) 6.103-1, Only one response source and no other supplies or services will satisfy agency requirements.

Amount: This modification does not add funding but raises the ceiling amount of the IDIQ and will extend the original period of performance (1 April 2021 – 31 March 2026) by six (6) months (30 September 2026). The estimated amount for the ceiling raise is

Reviews: I have reviewed this justification and find it adequate to support other than full and open competition.

Program Manager/Program Executive Officer:

2) Logistics: A gap in service would force the DPW to defer critical maintenance and repair actions, leading to a backlog of work and potentially exacerbating facility degradation. Furthermore, a new contractor would require a significant mobilization and transition period to become familiar with USAG Ansbach’s specific infrastructure and procedures, causing further delays even after a new contract is awarded.

3) Cost: Delaying necessary engineering and repair projects can lead to higher costs in the future as facility conditions worsen. The cost associated with responding to potential emergency failures resulting from deferred maintenance would greatly outweigh the cost of this modification.

b. Alternatives: The Contracting Officer analyzed multiple alternatives to a modification of the current IDIQ which includes the following:

1) Blanket Purchase Agreement (BPA): While a BPA can offer flexibility, current acquisition policies place restrictions on their use for requirements of this nature and scope, making it an inefficient vehicle for these services.

A BPA would not be a suitable or timely alternative.

2) Standalone Contract Action: Engineering requirements are often fluid and cannot always be defined far in advance. An IDIQ or other strategic vehicle such as a MATOC provides the flexibility to issue task orders as needs arise. Issuing multiple standalone contracts for each emergent requirement would be administratively burdensome, inefficient, and would not provide the rapid response capability afforded by the existing IDIQ.

3) Task Orders Prior to IDIQ Expiration: While regulation allows for issuing task orders up to the last day of the ordering period, the contract ceiling is expected to be reached concurrently with the expiration of the ordering period. This leaves no capacity for additional task orders to cover the bridge period.

c. Impact if not approved: As described in section 6a, if the IDIQ is not modified, it will result in a significant service gap. This will halt progress on mission-essential engineering projects, risking degradation of garrison infrastructure, delaying crucial and time-sensitive MILCON projects, and negatively impacting mission readiness and support to Soldiers and their families.

7. Efforts to Obtain Competition: The Contracting Officer is already processing the acquisition for the MATOC, which will be competed under full and open competition to ensure the Government receives the best value for its long-term requirements. This modification is solely a bridge action to prevent a lapse in service and will commence without changes to any terms and conditions except those listed in this document.

8. Market Research: Market research is being conducted as part of the follow-on IDIQ acquisition process. Additionally, an RFI was posted to SAM.gov on 25 March 2026 IAW DFARS PGI 206.103-170 as part of the modification effort to convey the Government’s intent and gauge interest, results of which will be used as part of the follow-on IDIQ effort. The RFI closed on 30 March 2026, and no public response was posted on Sam.gov. Further, the Contract Specialist and Contracting officer identified in the RFI received no emails or inquiries regarding the posted RFI.

9. Interested Sources: The RCO maintains a comprehensive vendor list for construction and engineering services. Based on previous solicitations for similar work, there is a robust list of general contractors and specialized engineering firms that are expected to express interest in the follow-on competitive acquisition.

10. Other Facts: Due to the unforeseen circumstances listed above, a modification to extend the ordering period and raise the IDIQ ceiling is critical to successfully support urgent infrastructure Maintenance, and at prices consistent with the original contract prices determined to be fair and reasonable. The RCO will simultaneously progress with a follow-on MATOC through competitive procedures and ensure transition to the new contract as soon as possible. In consideration of all challenges listed herein, the Contracting Officer concepts of FAR 1.102(a), Guiding Principles for the System, as a framework for this decision with meticulous attention to all applicable compliance requirements and sound business practices to ensure continued mission execution and the most effective use of taxpayer dollars.

14. Contracting Officer Certification: I certify that this justification is accurate and complete to the best of my knowledge and belief.

Approval

Based on the foregoing justification, I hereby approve the procurement of Indefinite Delivery Indefinite Quantity (IDIQ) for Maintenance of Family Housing Quarters, USAG Bavaria, Grafenwoehr Military Community - Tower Barracks on an other than full and open competition basis pursuant to the authority of Title 10 U.S.C. §3204 as implemented in 6.103-1, Only one responsible source and no other supplies or services will satisfy agency requirements. The estimated value of the modification is for a period of performance extended through 30 September 2026. The approval is subject to availability of funds, and provided that the supplies and/or services herein described have otherwise been authorized for this acquisition.