A16_SSJ_Sprague_Water_Quality_Single_Source_Justification_1.pdf
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- Attached to
- OR-KLAMATH FALLS FISH-WATER NUTRIENT ANALYSIS Federal contract opportunity
- Solicitation number
- 140FS126P0224
About this file
This is a Single Source Justification form (FWS Form 3-0034) for a federal contract under the Simplified Acquisition Threshold (SAT) submitted by the U.S. Fish and Wildlife Service's Joint Administrative Operations, Acquisitions Operations division.
The U.S. Fish and Wildlife Service (KFFWO) requires nutrient analysis laboratory services and associated sampling supplies for water quality monitoring, with a performance period from August 15, 2026, through December 31, 2029. The required services include a full nutrient panel with filtering analyzing total nitrogen, ammonia, nitrate/nitrite, total phosphorus, total dissolved phosphorus, and orthophosphate, with costs based on the SRWQL 2026 price list. The justification identifies SRWQL as the sole source based on its established role as the analytical laboratory for the project's existing nutrient dataset, methodological continuity concerns, data comparability issues inherent to switching laboratories, and unique logistical advantages through its local proximity enabling hand-delivery of samples by Fish and Wildlife Service staff. While other laboratories possess technical capability to perform standard nutrient analysis, competitive solicitation was not pursued due to risks of methodological discontinuity and dataset incompatibility. The document confirms no artificial or unnecessary barriers to competition exist, that the proposed cost is fair and reasonable compared to other qualified laboratories, and that SRWQL's pricing is generally significantly lower than competitors. The justification was certified by Program/Project Officer Megan Skinner on July 17, 2026, and approved by Contracting Officer Chelsea DeVivo on August 13, 2026.
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Text version
FWS Form 3-0034 (Rev. 10/2020) U.S. Fish and Wildlife Service
1. Description of Need
3. Other Capable Sources
2. Market Research Conducted
Pursuant to FAR subpart 13.106-1(b)(1)(i) and (ii), for purchases not exceeding the Simplified Acquisition Threshold (SAT), Contracting Officers may solicit from only one source if the circumstances deem only one source is reasonably available (e.g., urgency, exclusive licensing agreements, brand name, or industrial mobilization).
Instructions: The information in the text boxes are provided as sample language or to indicate a needed fill-in. Sample language should be removed from the final document. All text boxes require information and shall not be left blank.
SINGLE SOURCE JUSTIFICATION
(UNDER SAT)
JOINT ADMINISTRATIVE OPERATIONS
Acquisitions Operations
4. Barriers to Competition
5. Contractor's Qualifications
6. Determination of Fair and Reasonable Cost
7. Recommendation and Certification by Program Office
Based on the above justification, I recommend this acquisition to be conducted using sole source acquisition procedures. I hereby certify that this justification is accurate and complete to the best of my knowledge and belief.
Program / Project Officer
8. Contracting Officer Certification and Approval: Under SAT
Based on the above justification, I hereby certify and approve the use of sole source acquisition procedures under FAR Part 13 for this purchase.
Contracting Officer
Text3: Other laboratories are technically capable of performing the required nutrient analyses (total nitrogen, ammonia, nitrate/nitrite, total phosphorus, total dissolved phosphorus, and orthophosphate); this is not a service requiring unique or scarce expertise. However, no other source can perform this work without introducing a risk of discontinuity into an existing, multi-year dataset. Differences between laboratories in instrumentation, calibration standards, detection limits, and analytical protocols can introduce variability that compromises comparability of nutrient concentrations across sampling years. In addition, no other laboratory offers SRWQL's local proximity, which allows samples to be hand-delivered by U.S. Fish and Wildlife Service staff rather than shipped, eliminating shipping costs and transit time and minimizing the risk of sample degradation or holding-time exceedances. Because this project depends on consistent, comparable data over time and on reliable, degradation-free sample handling, no source other than SRWQL can continue this work without compromising the integrity of the existing dataset or the efficiency of current sampling logistics.
| Text2: Given that SRWQL has served as the analytical laboratory for these projects’ nutrient dataset to date. While other laboratories are technically capable of performing standard nutrient analysis, a competitive solicitation was not pursued because switching laboratories partway through an ongoing, multi-year dataset introduces a risk of methodological discontinuity, and because SRWQL's local location provides a logistical advantage (hand-delivery of samples by U.S. Fish and Wildlife Service staff) that no other laboratory can offer. This determination relies on the Project Officer's direct knowledge of the projects’ sampling and data history and the risks associated with a change in analytical source. |
| Text1: KFFWO has a need for nutrient analysis laboratory services and associated sampling supplies for water quality monitoring. Period of performance for this contract is August 15, 2026 – December 31, 2029. |
Nutrient Analysis
● Full nutrient panel with filtering: total nitrogen, ammonia, nitrate/nitrite, total phosphorus, total dissolved phosphorus, and orthophosphate.
● Costs based on SRWQL 2026 price list.
● We anticipate requesting these analyses for approximately 75 samples annually, subject to water quality conditions and U.S. Fish and Wildlife Service sampling capacity.
Nutrient Analysis Supplies
● Acid-washed bottles (previously used U.S. Fish and Wildlife Service bottles).
● We anticipate requesting approximately 75 bottles annually, subject to sampling needs.
Data management and invoicing
● SRWQL's standard turnaround time and standard reporting format is acceptable.
● Results and invoices will be submitted to U.S. Fish and Wildlife Service (megan_skinner@fws.gov, unless otherwise noted).
| Text4: No artificial or unnecessary barriers to competition have been created in the development of this requirement. The requirement reflects only the specific nutrient parameters and continuity of laboratory source necessary to preserve an existing, multi-year water quality dataset, and is not structured to favor SRWQL beyond what is inherent to maintaining that continuity and to the logistical advantages of a local laboratory. The nutrient analyses themselves are commercially available from multiple qualified laboratories; the limitation to a single source arises solely from the ongoing nature of these projects, the data comparability concerns inherent to switching analytical laboratories mid-project, and SRWQL's unique local proximity, not from any restrictive specification introduced by KFFWO. | |
| Text6: Based on pricing history and comparison with other qualified laboratories, the proposed cost is considered fair and reasonable. Proposed costs are consistent with SRWQL's 2026 price list for the same scope of nutrient analyses and supplies. SRWQL's pricing is generally significantly lower than that of other laboratories offering comparable nutrient analysis services, and SRWQL has been the laboratory consistently used for nutrient analyses elsewhere in the Upper Klamath Basin, further supporting the reasonableness of its costs relative to the regional market. Additionally, because samples can be hand-delivered by U.S. Fish and Wildlife Service staff given SRWQL's local location, this acquisition avoids the shipping and courier costs that would be incurred with a more distant laboratory, further enhancing the overall cost-effectiveness of this acquisition. | |
| 2026-07-17T13:10:46-0700 | |
| MEGAN SKINNER |
| 2026-08-13T16:01:58-0500 | |
| CHELSEA DEVIVO |
Text5: SRWQL is qualified to perform this work based on its established role as the analytical laboratory for these projects’ nutrient dataset to date. SRWQL's continued involvement ensures consistent instrumentation, calibration, detection limits, and analytical protocols across sampling years, which is necessary to maintain the internal consistency and comparability of a long-term water quality dataset used to support trend analysis and water quality assessment. SRWQL's local location further qualifies it uniquely to perform this work, as it allows U.S. Fish and Wildlife Service staff to hand-deliver samples rather than ship them, eliminating shipping costs and transit time and reducing the risk of sample degradation or holding-time exceedances that could compromise data quality.
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