A17_Limited_Sources_Justification_MORA_Ohana_REDACTED_1.pdf

United States Department of the Interior

NATIONAL PARK SERVICE

DENVER SERVICE CENTER

CONTRACTING SERVICES

1 DENVER FEDERAL CENTER, BUILDING 50

P.O. BOX 25287

DENVER, COLORADO 80225-0287

IN REPLY REFER TO:

MORA 313019/312439

June 18, 2025

Limited Sources Justification Over SAT(FAR 8.405-6(c))

PR Number TBD

In accordance with FAR 8.405-6(c), the following information is provided:

1. Identification of the Agency and the Contracting Activity: Department of the Interior (DOI), National Park Service (NPS), Denver Service Center (DSC), Contracting Services (CS) Division.

2. Nature and/or description of the action being approved: The NPS DSC intends to limit sources and award an Order to ACE Consulting Company LLC (ACE) of 608 Keene Centre Drive, Nicholasville, KY 40356. This Order is a logical follow-on to original Order 140P2024F0392 against 47QRAA21D003G, which previously provided for fair opportunity to all General Services Administration (GSA) small business contractors on schedule 541330ENG. This logical follow-on Order is for the continuation of the originally anticipated Construction Management (CM) / Construction Management Representative (CMR) Support Services through the conclusion of the MORA 313019/312439/331809 construction project to rehabilitate Ohanapecosh Campground in Randle, WA.

3. A description of the Supplies or Services required to meet the Agency’s needs, including the estimated value:

This action is for the continuation of CM/CMR Support Services to assist NPS and DSC with the oversight, administration, and management of the MORA 313019/312439/331809 construction project at Mount Rainier National Park to rehabilitate Ohanapecosh Campground.

Construction efforts began in March 2025, requiring Full-Time/On-Site CMR Support for approximately 365 calendar days through March 2026. Under the original Order for this requirement, support services were intended to be accomplished by one (1) CMR. However, the original CM/CMR Support Services Order is reaching capacity due to the CMR working additional hours and ACE providing an additional CMR to adhere to an accelerated construction work effort to complete construction before seasonal weather shuts down operations. A logical follow-on /sole-source to ACE is necessary to see the construction project through to completion to meet the accelerated construction work schedule.

The estimated value for these continued commercial services is $314,740.00.

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: The authority for this action is FAR 8.405-6(a)(1)(C). This requirement/Order must be issued on a sole-source basis in the interest of economy and efficiency, as the continuation of work is a logical follow-on to an original Federal Supply Schedule (FSS) Order through GSA; provided that the original Order was placed in accordance with the applicable FSS ordering procedures.

The relationship between the original Order and this logical follow-on Order is that of the CM/CMR Support Services initially contemplated for one (1) CMR for the MORA 313019/312439/331809 construction project. Due to the unpredictable nature of construction projects and accelerated construction work effort to complete construction before seasonal weather shuts down operations, two (2) CMRs are necessary.

A need still exists for CM/CMR Support Services to see the construction project through to conclusion, in which services were originally contemplated at the time of initial award; therefore, this continuation of commercial services is considered to be a logical follow-on to the initial Order placed. At this time, 211 additional days of CM/CMR Support Services are required to see the construction project through to completion and to allow for proper close-out procedures. ACE is the only CM Firm that has the complete and full understanding of day-to-day operations, history, and project management software to ensure the MORA 313019/312439/331809 construction project is not delayed, impeded, restricted, or confined by the replacement of a suitable CM Firm/CMR to meet the intent and comply with the concepts developed by the entire project team.

5. A determination by ordering activity contracting officer that the order represents the best value consistent with 8.404(d). The CO has determined that issuing the Order to ACE represents the overall best value and will result in the lowest overall cost, considering price and administrative efforts, to meet the Government’s needs. This Order will be placed in accordance with FAR 8.404 - “Use of Federal Supply Schedules.” GSA has already negotiated fair and reasonable pricing rates and discounts to these GSA rates will be requested from the CM Firm. Additionally, prior to issuance of the Order, the Ordering Activity will consider the level of effort and mix of labor proposed to perform the specific tasks being ordered to determine that the total price is fair and reasonable. The CM Firm’s labor mix and level of effort will also be compared to the Independent Government Cost Estimate (IGCE). Level of effort will be determined technically acceptable, and pricing will be in accordance with current GSA Schedule billing rates. All other direct charges will be negotiated for a fair and reasonable price to be documented as such prior to execution.

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 was not conducted due to the fact that ACE has intimate knowledge or current operations and any attempt to select a new CM Firm/CMR would have significant impacts to the schedule, budget, and management overall. The original Order was competed amongst all small business contractors under MAS Engineering Services Category 541330ENG, utilizing GSA eBuy. The accelerated schedule by the Construction Contractor has created the need to for additional support services with ACE in order to ensure proper oversight of construction activities.

7. Any other facts supporting the justification: The CM Firm and CMR have demonstrated the technical capabilities required, performed satisfactorily, and provided fair and reasonable pricing to-date. There is no evidence or rational not to proceed with this logical follow-on Order to be sole sourced to ACE. Continuation of these commercial services results in the lowest cost and risk to the Government. Conversely, not proceeding as stated poses additional risks and costs that are unnecessary and cannot be supported or validated.

8. A statement of the actions, if any, the agency may take to remove or overcome any barriers that led to the exception to fair opportunity before any subsequent acquisition for the supplies or services is made: This agency will continue to use competitive procedures for all future CM/CMR Support Service requirements and ensure they are competed to the maximum extent practicable.

9. Certification by Technical or Requirements Personnel:

I certify that any supporting data that is the responsibility of technical or requirements personnel (e.g verifying the

Government’s minimum needs or requirements or other rationale for an exception to fair opportunity) which form a basis for the justification have been certified as complete and accurate:

Signature________________________________________ Date _______________________

Gregory Kaiser, Project Manager, NPS DSC

I certify that the justification is accurate and complete to the best of my knowledge and belief:

Signature _______________________________________ Date _____________________

Dayna Omiya, Contracting Officer, NPS DSC

Reviewed/Concur/Approved by:

Signature_____________________________________ Date ___________________

Name: Shannon Blackburn, Chief of the Contracting Office, NPS DSC

For orders exceeding SAT, but not exceeding $750,000, this certification serves as the Approval of the justification.