A16_JOFOC_-_140D0424Q0650_Redacted_1.pdf

LIMITED-SOURCES JUSTIFICATION

AUTHORITY: FEDERAL ACQUISITION REGULATION 8.405-6

and 40 UNITED STATES CODE 501

SOLICITATION #140D0424Q0650

This acquisition is conducted under the authority of the Multiple Award Schedule Program.

1. Identification of the agency and contracting activity, and specific identification of the document as a “Limited-Sources Justification.”

This document is a Limited-Sources Justification executed by the Department of Interior (DOI), Interior Business Center (IBC), Acquisition Services Directorate (AQD), Division 5, Branch 2, Team 2 for the Department of Defense (DoD), Department of the Air Force

(DAF).

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

This non-severable service requirement is on behalf of the DoD, DAF. The proposed action is to award a sole source Firm-Fixed-Price (FFP) contract to Vernadero Group Incorporated (Vernadero) for Environmental Assessments (EAs) for Koke’e Air Force Station (AFS), Waimea, Hawaii, one for Kaena Point Satellite Tracking Station, Waianae, Hawaii, and one for Ka’ala AFS, Wahiawa, Hawaii. The action will be a new requirement.

3. A description of the supplies or services required to meet the agency’s needs

(including the estimated value).

The action is for a new requirement to develop three (3) EAs: one for Koke’e Air Force Station (AFS), Waimea, Hawaii, one for Kaena Point Satellite Tracking Station, Waianae, Hawaii, and one for Ka’ala AFS, Wahiawa, Hawaii. The DAF is proposing to renew/reacquire existing land parcels on the islands of Kauai and Oahu, Hawaii to continue operations of radar and satellite tracking. The efforts support the DAF by preparing EAs that are technically and legally sufficient pursuant to provisions of the National Environmental Policy Act of 1969 [(NEPA), Title 42 United States Code (USC) Section 4321 et seq.], implemented by Council on Environmental Quality (CEQ) Regulations [Title 40, Code of Federal Regulations (CFR) 1500-1508], as updated, the 2023 Fiscal Responsibility Act’s amendments to NEPA, and 32 CFR 989, Environmental Impact Analysis Process (EIAP). As part of this effort, the Contractor will provide services resulting in an EA (for each location) with either a Finding of No Significant Impact (FONSI), a mitigated FONSI, or a determination that an Environmental Impact Statement is required. If analysis indicates the potential for significant environmental or socio-economic impacts the Contractor shall recommend to the DAF Government project lead one of the following:

Mitigation measures to minimize impacts to less than significant (incorporated as part of the EA document). Implementation of the No Action Alternative. Withdrawal of the EA and the preparation of an Environmental Impact Statement (EIS). The Period of Performance is 36 months from issuance of award. The total estimated value is

4. The authority and supporting rationale (see 8.405-6(a)(1)(i) and (b)(1)) and, if applicable, a demonstration of the proposed contractor’s unique qualifications to provide the required supply or service.

FAR 8.405-6(a)(1)(i)B - Only one source is capable of providing the supplies or services required at the level of quality required because the supplies or services are unique or highly specialized.

Given the unique nature of the land lease renewals combined with the highly regulatory environment of Hawaii, Vernadero would be able to apply their unique and specialized experience in this area. Vernadero successfully performed similar unique work to support large congressional land withdrawal renewals (Juniper Butte Land withdrawal Renewal, 2021). Additionally, Vernadero efficiently navigated the coordination and consultation requirements within the Hawaii stringent regulatory community to support multiple environmental impact analyses ranging from basing and beddown actions to new combat training requirements.

These efforts were originally awarded using various IDIQ contract vehicles, across multiple districts within the US Army Corps of Engineers (USACE).

However, the USACE is no longer supporting the DAF with environmental impact analysis efforts in Hawaii due to capacity issues.

The accomplishment of the three (3) EAs would focus on evaluating the proposed land lease renewals within the high regulated Hawaiian environment. The unique and specialized experience applied by Vernadero to the proposal from their previous congressional land withdrawal renewal and multiple environmental impact analyses will be beneficial to the Government.

Vernadero’s experience would result in a cost savings to the DAF through the reduced effort of developing the Description of the Proposed Action and Alternatives (DOPAA) and the identification of potential impacts on resources. As part of the DOPAA development the Contractor would have already established sound regulatory understanding as it relates to land lease renewals, the purpose and need for the proposed action, and statutory drivers and selection standards for alternative development as it relates to the National Defense Strategy. The DOPAA develop portion of the EA usually is one of the heaviest costs of the overall effort ranging from 20 to 30% of the total project costs. However, by using their previous experience, knowledge of the Hawaiian regulatory community, and expertise; it would be expected that the Government would realize a cost savings of 5 to 8% in the development of the DOPAA. The expected savings would be further compounded by an economies of scale, in which the Contractor would use information and direction from the Government to inform the creation of all three

(3) DOPAAs eliminating duplication of effort. Therefore, the costs savings for this effort is expected to be closer to 10% of the total effort. This would be an estimated cost savings of approximately $90,000 to $100,000 for the DOPAA.

There would be other cost savings integrated into the data collection and analyses, as well as reduced meetings with regulatory community and the proponent.

Due to rising global threats, it is imperative that the US maintain satellite tracking and surveillance systems. The DAF has identified these land lease renewals to support the continued operation of radar and satellite tracking to be foundational to National Defense Strategy. It is time critical that the land lease renewal EAs be completed to support critical National Defense Strategy goals. Using Vernadero will allow the DAF to streamline the NEPA requirements when analyzing the three

(3) proposals for Kaua’i and O’ahu, Hawaii. This time savings in the development of the EAs will assist the DAF in the continued critical operations of the radar and satellite tracking systems in support of our National Defense Strategy.

5. A determination by the ordering activity contracting officer that the order represents the best value consistent with FAR 8.404(d).

Pursuant to FAR 8.404(d) Pricing, “GSA has already determined the prices of supplies and fixed-price services, and rates for services offered at hourly rates, under schedule contracts to be fair and reasonable. Therefore, ordering activities are not required to make a separate determination of fair and reasonable pricing, except for a price evaluation as required by 8.405-2(d).” In accordance with FAR 8.405-2(d) Evaluation, the Contracting Officer will consider the level of effort and the mix of labor to perform a specific task being ordered and for determining the total price reasonable.

The Contracting Officer will utilize Vernadero’s GSA Federal Acquisition Service Authorized Federal Supply Schedule (FSS) price list as the determination.

6. A description of the market research conducted among schedule holders and the results or a statement of the reason market research was not conducted.

Market research indicates the services are available in the commercial marketplace.

However, competition is not appropriate for this acquisition as only one source is capable of providing the services required at the level of quality required because the services are unique or highly specialized. It is in the best interest to support the mission of DAF to be foundational to the National Defense Strategy in preparing EAs that are technically and legally sufficient pursuant to provisions of NEPA, USC, CFR, the 2023

Fiscal Responsibility Act’s amendments to NEPA, EIAP, and Hawaii Environmental Policy Act. The impact of the EAs have an effect and impact at every level of local, state, tribal and federal agencies. Vernadero has the required experience to successfully satisfy the requirements specific to NEPA activities in Hawaii, as well as expertise with Support Land Lease Renewals. Vernadero successfully performed similar unique work to support large congressional land withdrawal renewals (Juniper Butte Land withdrawal Renewal, 2021). Additionally, Vernadero efficiently navigated the coordination and consultation requirements within the Hawaii stringent regulatory community to support multiple environmental impact analyses ranging from basing and beddown actions to new combat training requirements. This acquisition history of similar requirements was provided by DAF.

There are no DOI or DoD Mandatory Use vehicles applicable to this requirement. The required services are not available through the procurement list maintained by the Committee for Purchase From People Who Are Blind or Severely Disabled. A review of the Schedule Products and Services located on the Unicor.gov website revealed that these services are not available from the Federal Prison Industries.

7. Any other facts supporting the justification.

A Request for Quotation is not anticipated to be released on GSA e-buy as procedures will be limited following FAR 8.405-6(a)(1)(i)B. In limiting sources, only one source is capable of providing the services required at the level of quality required because these services are highly specialized.

8. A statement of the actions, if any, the agency may take to remove or overcome any barriers that led to the restricted consideration before any subsequent acquisition for supplies and services is made.

For future acquisitions for the same or similar requirements, AQD and DAF will conduct comprehensive market research to understand the current market landscape and available vendors; utilize market surveys, industry days, and request for information (RFI) processes to gather data; and broaden the understanding of available solutions and vendors.

By systematically addressing these elements, the agencies can effectively remove barriers that previously led to restricted consideration, fostering a more competitive and inclusive acquisition process.

9. The ordering activity contracting officer’s certification that the justification is accurate and complete to the best of the contracting officer’s knowledge and belief.

12. Reviews and Approvals

Approve

JeanMarie Marriam Contracting Officer

JEAN MARIE

MARRIAM

Digitally signed by JEAN

MARIE MARRIAM

Date: 2024.06.21 12:53:53 -04'00'