47QSCC18A000B Mod 005 LSJ_redacted.pdf

LIMITED-SOURCES JUSTIFICATION

BRIDGE (PERIOD OF PERFORMANCE EXTENSION)

GSA SCHEDULE CONTRACT 47QSHA18D000G

BPA 47QSCC18A000B

The General Services Administration (GSA) makes this Limited Sources Justification (LSJ) pursuant to Federal Acquisition Regulation (FAR) 8.405-6(a)(1)(i)(A).

I. IDENTIFICATION OF THE AGENCY AND CONTRACTING ACTIVITY

Client Agency: General Services Administration (GSA) Office of General Supplies and Services (GSS) Office of Retail Operations (RO)

Contracting Activity: Central Office Acquisition Division

Office of General Supplies and Services GSA Federal Acquisition Service 1800 F Street, NW Washington, D.C. 20405

II. NATURE AND DESCRIPTION OF THE ACTION BEING APPROVED

Action. The action being approved is a modification to Blanket Purchase Agreement (BPA)

47QSCC18A000B, to extend the performance period for an additional four months, with two, three-month option periods.

Background. This BPA was originally awarded to W. W. Grainger (Grainger) on May 25, 2018 as a logical follow-on pursuant to FAR 8.405-6(a)(1)(i)(C) - In the interest of economy and efficiency, the new work is a logical follow-on to an original Federal Supply Schedule order provided that the original order was placed in accordance with the applicable Federal Supply Schedule ordering procedures, as well as the Contract Continuity Initiative under MAS 51V contract number

47QSHA18D000G. This logical follow-on BPA has a performance period (including options) which will expire on August 1, 2022. As of Modification 004, this requirement is for 4PL support at the

Pacific Northwest (PNW) location at Joint Base Elmendorf-Richardson (JBER), Alaska.

Several events contributed to the delay in awarding a timely, fully competed, follow-on BPA to this current requirement. GSA had initially re-competed this effort under RFQ QSAB-RFQ-19001 in

2019, which was protested and resulted in a restructuring of GSA’s acquisition strategy. The protest filed in response to QSAB-RFQ-19001 was sustained on January 16, 2020. GSA’s response to this decision included a restructuring of our acquisition processes, to include the creation of a new MAS

SIN to better accommodate the needs of the 4PL Program and its customers. Resulting from the protest sustainment, GSA had been unable to issue a new RFQ (in support of all the locations under this existing PNW BPA) until there were enough eligible vendors under the 4PL SIN who could compete and provide adequate competition. The MAS 4PL SIN was created and went live in June

2020, however, GSA’s historical commercial 4PL providers were then tasked in obtaining modifications to their respective MAS contracts to add the 4PL SIN, enabling GSA to re-compete this effort under the newly created 4PL SIN. Additionally, the timeline required for 4PL SIN creation and 4PL vendor onboarding created a backlog of other higher priority requirements, higher in priority based on their enterprise-level sales projections and even faster-approaching performance period expiration dates. Thus, the follow-on for this specific requirement was further delayed. The requirements package for this requirement was received by the contracting activity in mid-July, 2021.

In December of 2021, GSA finalized its requirements package and issued the revised RFQ for this requirement under 47QSCC-21-Q-5002. Based on the 4PL team’s standard acquisition milestones

(which includes a 12-month cradle-to-grave acquisition timeline) the “Go Live” date for the re-competition of this effort was anticipated to occur in July 2022. However, a Pre-award Protest was filed with the Government Accountability Office (GAO) in February 2022, and it is anticipated that a Post-award Protest will also be filed with GAO which would extend the “Go Live” date by an additional total of 200 days (100 days each for both the Pre-Award and Post-Award protests). In addition, any incoming contractor (if not the incumbent) would have 120 calendar days to stand up the JBER location under a new BPA award. To account for the GAO Pre-award/Post-award protest window and the transition to a new contractor (if necessary), continued BPA coverage under this

BPA is potentially required until June 2023. As a result, in order to avoid a lapse in service at the remaining PNW location in JBER, GSA is issuing this limiting source extension to the current BPA for a maximum of 10 months (4-month base period of performance with two, 3-month option periods), with contract coverage through June 1, 2023.

In summary, GSA has been diligently pursuing a strategy for providing 4PL services under a new procurement approach since 2019 but has encountered several unavoidable delays. This modification to allow continued performance is necessary to avoid delays, gaps in coverage, and to ensure continuity of critical supplies and services for the Department of Defense.

III. DESCRIPTION OF THE SUPPLIES/SERVICES REQUIRED TO MEET THE

AGENCY’S NEEDS (INCLUDING ESTIMATED VALUE)

Under the current Schedule 51V Hardware Superstore BPA, Grainger provides GSA and its products and related in-store services including, but not limited to, on-site management, maintaining adequate inventory levels, stocking/restocking of shelves, customer service, and processing referral orders for non-stocked and not-in-stock industrial related items.

Based on average quarterly sales for the JBER location, the estimated value of this BPA extension is

IV. AUTHORITY AND SUPPORTING RATIONALE

Authority. FAR 8.405-6(a)(1)(i)(A).

Supporting Rationale:

This action is conducted under the authority of the MAS 51V program and in accordance with FAR

8.405-6(a)(1)(i)(A) – An urgent and compelling need exists, and following the procedures would result in unacceptable delays. Absent a modification, BPA 47QSCC18A000B will expire on August

1, 2022, leaving inadequate time to onboard and transition a new vendor, a process that normally requires 120 calendar days to complete for locations outside the 48 contiguous states. Transition and onboarding activities include, but are not limited to, sourcing of material, installation of shelving, security access requirements, and transport/staging of inventory. Consequently, a modification to bridge performance was determined as an effective mechanism to continue contract coverage until such time that the Government is able to onboard a new vendor for this location.

The 4PL program has been integrated into JBER. The absence of this BPA would preclude JBER customers from accomplishing the following:

Maintaining ground equipment in a state of readiness, which would result in fewer equipment being available to perform mission essential activities. The materials and services provided by this BPA complement the repair and overhaul of equipment, which includes the storage, handling, or use of hazardous materials.

Many customers rely on official government requisition programs such as DoDAAC/MILSTRIP to purchase material which cannot be used as a purchase method with local commercial vendors. Additionally, the DoDAAC/MILSTRIP requisition process reduces the customer's administrative burden associated with use of GPC as well as mitigates the risk of purchase limits associated with use of a GPC. GSA, through the 4PL program and specifically this BPA, provides customers alternative Government-only purchasing methods to increase customer’s operational efficiency.

This BPA provides in excess of 3,500 on-the-shelf industrial materials and 900,000 products available via referrals used to support daily operations. Some of these items are not available in the quantities required due to limited procurement alternatives via local source and limitations using GPC.

The DoD achieves efficiencies through an enterprise approach to obtain industrial material through the 4PL program. An interruption in this support would return material requirements to both the base and unit level to conduct a large number of individual procurements for which they are no longer staffed to support. This gap in procurement support will significantly increase the risk that required products will not be available in the quantities and timeframes needed to meet their mission requirements.

This BPA provides approximately 175 mission critical products in support of the F-22 and F-35 aircraft squadrons for the USAF in Alaska.

DoD and Federal agencies (Coast Guard, ARCTEC Missile Command, National Oceanic and Atmospheric Agency, Federal Aviation Administration, etc.) rely heavily on the logistical support and expertise provided by GSA, via this BPA with Grainger, to include the coordination and arrangement of transportation documentation to ship material by barge, military or commercial air, from JBER to remote locations throughout the Aleutian Islands. Many agencies arrange for seasonal bulk orders to avoid winter weather transportation limitations and such ordering activities occur in Q3 around the time of BPA expiration.

GSA works with the US Army Range Control in support of their training readiness center to provide generators, material handling sub-equipment, batteries, lumber, etc. through this BPA.

This BPA supports the Department of Natural Resources (DNR) and the Bureau of Land Management (BLM) for mission critical industrial products in preparation for fire season.

Not extending this BPA will force DNR and BLM to order outside of Alaska and create risk associated with lead time to receive critical products.

V. DETERMINATION BY THE ORDERING ACTIVITY CONTRACTING

OFFICER THAT THE ORDER REPRESENTS THE BEST VALUE CONSISTENT

WITH FAR 8.404(d).

The undersigned Ordering Activity Contracting Officer has determined that this BPA modification represents the best value and results in the lowest overall cost alternative (considering price, special features, and administrative costs) to meet the Government’s needs. To date, Grainger has performed at a under BPA 47QSCC18A000B and is the only vendor with the capability and employees at the BPA location to deliver the necessary products and services while ensuring contract coverage continuity. In addition, per FAR 8.404(d), Grainger’s MAS prices are fixed and have already been determined to be fair and reasonable, for all products sold under this BPA.

VI. DESCRIPTION OF THE MARKET RESEARCH CONDUCTED AMONG

SCHEDULE HOLDERS AND THE RESULTS

GSA considered alternatives to this limited sources BPA modification, such as leveraging other established 4PL BPAs to support the location covered by the BPA; however, the JBER location would be outside the geographical and/or contractual scope of any other 4PL BPA.

An open market procurement was determined not feasible for the 4PL program. Utilizing a MAS solution is designed to accommodate orders/BPAs for the 4PL program, by providing a viable solution for obtaining the necessary products and services in accordance with standard commercial practices, based on input from industry partners. More importantly, fulfilling this requirement via the open market does not allow for the requisition-based vehicles that the program relies on.

Additionally, the MAS program ensures that the products and services required under any resulting

BPA are within the scope of the negotiated products and services under the SIN(s), and that all prices have already been determined fair and reasonable to allow for rapid ordering and deployment of services that an open market vehicle would not accommodate.

VII. OTHER FACTS SUPPORTING THIS JUSTIFICATION

Grainger has approximately of VMI under BPA 47QSCC18A000B prepositioned at the

JBER location, which functions as part of the 4PL supply chain for hardware and industrial products and supplies.

Local individual procurements for these supplies are not available or feasible.

VIII. STATEMENT OF ACTIONS THE AGENCY MAY TAKE TO REMOVE OR

OVERCOME ANY BARRIERS THAT LED TO THE RESTRICTED CONSIDERATION

The barriers that led to the necessity of this document are specified in the sections above and are considered both rare and largely unavoidable, resulting in the need to create a new SIN under the

FSS program. Also, although protest periods are often built into our acquisition timelines, whether or not they are submitted are out of the control of the acquisition team. Due to the delays specified earlier in the document, the re-competed follow-on requirement was already on a tight timeline and even slightly behind schedule with or without a pre- or post-award protest. The acquisition team will continue to account for protest periods both before and after award while calculating the acquisition timelines. Additionally, now that the MAS 4PL SIN has been awarded, the acquisition team is better positioned to release future solicitations with additional cushion to mitigate or eliminate the possibility of requiring future limited sources justifications. The follow-on requirement supporting the location specified in this limited sources justification is currently being re-competed, utilizing

FAR 8.4 procedures under the MAS 4PL SIN. There are currently six industry partners awarded a contract under the MAS 4PL SIN. Of the six, four of the industry partners are Large Businesses and two are designated as Small Businesses. All industry partners are afforded the opportunity to bid on

4PL program requirements (unless determined to be suitable for a set-aside) and GSA ensures adequate competition is available via robust market research and advance notices to both 4PL SIN holders and commercial vendors interested in becoming 4PL SIN holders.

Technical/Requirements Personnel Certification:

I certify that the requirements for this acquisition, as depicted in the Statement of Work of this BPA and that the supporting data, which forms the basis for the justification, is accurate and complete.

William Crenshaw Date

Director of Operations

Retail Operations Branch

CONCUR:

Paul Mack Date

Director

Retail Operations Branch

Contracting Officer’s Certification:

I hereby certify that this justification is accurate and complete to the best of my knowledge and belief, and determine on the basis of the findings above that the limited sources approach is in accordance with the requirements and is in the best interest of the Government.

Dion Duarte Date

Contracting Officer

Central Office Acquisition Division

APPROVED:

Based on the aforementioned discussion for the use of other than full and open competition, I find that the foregoing circumstances justify limiting sources in accordance with FAR 8.405-6(a)(1)(i)(A) and approve this justification.

Carolyn M. Long Date

Branch Chief, Retail Operations Acquisition Branch

Stephen A. Smith Date

Director

WRITTEN DETERMINATION BY THE APPROVING OFFICIAL:

I find that the foregoing circumstances justify limiting sources in accordance with FAR 8.405- 6(a)(1)(i)(A) and approve this justification.

Mark L. Dunkum Date Competition Advocate