JOFOC_Redacted_1.pdf

LIMITED-SOURCES JUSTIFICATION

AUTHORITY: FEDERAL ACQUISITION REGULATION 8.405-6

and 40 UNITED STATES CODE 501

SOLICITATION #140D0425Q0019

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 an Environmental Assessment (EA) at Tinker Air Force Base (AFB), Oklahoma City, Oklahoma. 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 an EA for Tinker AFB. The DAF is proposing to beddown the E-7 Airborne Warning and Control System (AWACS) fleet to replace the E-3 AWACS fleet. The E-3 AWACS fleet (27 aircraft) would be retired and up to 26 E-7A aircraft would be beddown over the span of approximately 10 years. The EA will analyze the potential environmental impacts associated with beddown of the AWACS fleet. The efforts support the DAF by preparing an EA that is 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 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:

SOLICITATION #140D0424Q0650

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, 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 “Speed to Ramp” timeline, the decision for E-7A will require an expedited beddown. The assessment scope encompasses evaluating impacts on biological resources, including the Northern Long-eared bat and Tricolored bat, both currently listed as endangered species. Vernadero brings a unique and specialized expertise in assessing such impacts, having previously conducted similar work in support of endangered species conservation for DoD, Navy (Port Hueneme CBC base, 2024). Vernadero successfully performed similar unique work to support this endangered species protection for DoD, Navy (Port Hueneme CBC Base, 2024) and DoD, DAF (Seymore Johnson Air Force Base, North Carolina, 2024), task order GS-10F-033T/ W912HN23F1016. Additionally, Vernadero efficiently navigated the coordination and consultation requirements supporting NEPA for DAF beddown actions, as well as, completing supported studies, modeling, and resources surveys. 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 due to capacity issues.

In accordance with 32 Code of Federal Regulations (CFR) 989, the proposed action does not qualify for a Categorical Exclusion, and therefore requires further environmental analysis. This will likely negatively impact cultural resources with potential to impact air quality, safety, hazardous materials/waste, biological, geological, and socioeconomic resources at Tinker AFB. The unique and specialized experience applied by Vernadero to the proposal from their previous contracts 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 use, air quality, biological resources, and environmental restoration. 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, 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 economy of scale, in which the Contractor would use information and direction from the Government to inform the creation of this DOPAA eliminating duplication of effort. Therefore, the costs savings for this effort is expected to be closer to 10% of the total effort.

The FY23 National Defense Authorization Act (NDAA) included the retirement of the E-3 AWACS fleet starting in FY23 and finishing by the end of FY28. Congress divested a portion of the E-3 fleet and redirected that funding to procure and field its replacement. The E-7A Rapid Prototype Requirements Document (RPRD) was approved in FY21 and the Air Force subsequently chose the E-7A Wedgetail as the replacement for the E-3. To meet the Air Force “Speed to Ramp” timeline, the basing decision for E-7A requires an expedited beddown. The chosen location must be able to accommodate simulator standup and personnel by January 2026, one year prior to first E-7A aircraft arrival. Using Vernadero will allow the DAF to streamline the NEPA requirements when analyzing the proposed action. This time savings in the development of the EAs will assist the DAF in the continued critical operations 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. The impact of the EA has 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 at Tinker AFB, as well as expertise with biological resources. Vernadero successfully performed similar unique work to support large congressional land withdrawal renewals (Juniper Butte Land withdrawal Renewal, 2021). This acquisition history of similar requirements was provided by DAF.

A Notice of Intent to Sole Source (NOI) was posted to SAM.gov on October 18, 2024 specifically requesting interested vendors were required to have experience with services related to specific activities at Tinker AFB, as well as experience with species on the endangered or threatened lists. The information would assist in determining whether competitive procedures could be used for this acquisition. No responses were received by the response due date. One response received after the deadline, contained no substantive information relevant to this requirement, and only inquired about potential future sole source opportunities.

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.