47QSCC19A0003 Mod 007 LSJ_Redacted.pdf

General Services Administration Federal Acquisition Service

General Supplies and Services Central Office Acquisition Division

Retail Operations Acquisition Branch

LIMITED SOURCES JUSTIFICATION

DESCRIPTION OF ACTION - BRIDGE (PERIOD OF PERFORMANCE

EXTENSION)

GSA SCHEDULE 51V CONTRACT NUMBER: 47QSHA18D000G

GSA BPA NUMBER: 47QSCC19A0003

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

1) Identification of Agency and Contracting Activity

Client Agency:

General Services Administration (GSA) General Supplies and Services (GSS) 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

2) Nature and/or description of action being approved

Action. The action being approved is a modification to Blanket Purchase Agreement (BPA) 47QSCC19A0003, to extend the performance period for an additional six months, with one three-month option period.

Background. This BPA was originally awarded to Grainger on January 22, 2019 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 had a performance period (including options) which expired on December 1, 2019.

GSA had initially re-competed this effort in 2018 under RFQ QSRA-RFQ-18002, and again in 2019 under RFQ QSAB-RFQ-19001. Both RFQs were protested and resulted in a re-structuring of GSA’s acquisition strategy.

Limited Source Justification

Of particular note, 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 their acquisition process, to include the creation of a new MAS SIN to better accommodate the 4PL Program and GSA’s customers. As of June 8, 2020, the new MAS SIN had been created, but GSA’s industry partners were still working to obtain modifications to add the SIN to their MAS contract to enable GSA to re-compete this effort under the new SIN. Because of this, GSA had been unable to issue a new USMC RFQ immediately upon receipt of the protest sustainment, as there were no vendors currently under the SIN who could legally compete.

Based on the projected timeline, the “Go Live” date for the re-competition of this effort is not expected to occur until . As a result, in order to avoid a lapse in service at the existing USMC locations, GSA is issuing this limiting sources extension current BPA for a maximum of nine months.

In sum, GSA has been diligently pursuing a strategy for providing 4PL services under a new procurement approach.

3) Description of Supplies/Services Required to Meet the Agency’s Needs

Under the current Schedule 51V Hardware Superstore BPA, Grainger provides GSA and its customer the U.S. Marine Corps (USMC) with vendor- owned/vendor- managed inventory (VMI) and related in-store services including on-site management and inventory levels, stocking/restocking of shelves, customer service, processing referral orders for items such as paints, preservatives, sealants, adhesives, oils and abrasives, power tools, accessories, hardware, building supplies, safety products, precision tools and equipment, machinery and tooling components, tool holding and work holding equipment, outdoor equipment and accessories, material handling, fire- fighting and rescue equipment, and protective gear.

Grainger has approximately of Vendor Managed Inventory (VMI) prepositioned at the locations covered by BPA 47QSCC19A0003, which functions as part of the USMC’s 4PL supply chain for hardware and industrial products. Local individual procurements for these supplies are not available or feasible. The 4PL supplies are necessary for USMC’s equipment and facilities maintenance, hazardous material handling, and support pre-deployment exercises, training and deployment of USMC Expeditionary Units, Special Purpose Marine Air-Ground Task Forces, as well as Depot Level Maintenance Centers.

Based on average annual sales, the estimated value of this BPA extension is .

4) Authority and Supporting Rationale

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

FAR 8.405-6(a)(1)(i)(A) – An urgent and compelling need exists, and following the procedures would result in unacceptable delays.

Absent modification, BPA 47QSCC19A0003 will expire on February 1, 2021, leaving inadequate time to onboard and transition a new vendor, which includes sourcing, installation, security access requirements, and transport/staging inventory for USMC activities (discussed above). Consequently, a modification to bridge performance was determined as an effective mechanism to continue contract coverage.

The 4PL program has been integrated into the USMC supply chain. The absence of this BPA would preclude the USMC 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 such as corrosion resistant paint; the USMC is no longer resourced nor positioned to procure and store these items. A gap in BPA coverage will cause a work stoppage for the Depot Level Maintenance Center activities who rely heavily on corrosion resistant paints for ground equipment deployed on ships.

● The production and use of Additive Manufactured (AM)-derived parts and other items may be adversely impacted. AM (also known as 3d printing) is the process of joining materials to make objects from 3d model data, usually layer upon layer, as opposed to subtractive (traditional) manufacturing methodologies. Vendors and store locations provide machines and materials used by Marines to supplement intermediate and depot level maintenance on equipment. Examples include Marine Aviation Logistics Squadron (MALS) -16’s use of 3D printers to replicate aircraft replacement parts, MCAGCC 29 Palms fabrication lab’s use to replicate equipment repair parts, and the Exercise Operations Training Group’s use to replicate material for breaching exercise training.

● This BPA provides in excess of 12,000 industrial materials 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.

Examples include: Corrosion resistant paints, specialized tools and tool sets, water pumps used for water reclamation plants operated on USMC installations, and gases used for welding and heating older facilities.

● The USMC achieves efficiencies through an enterprise approach to obtain industrial material through the 4PL program. An interruption in this support would return material requirements to the base-level 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.

5) 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 modification order 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 level under BPA 47QSCC19A0003, and is the only vendor with capability and employees at the BPA locations to deliver the necessary products and services. In addition, per FAR 8.404(d), Grainger’s 51V schedule prices are fixed prices already determined to be fair and reasonable,

6) Description of the Market Research Conducted Among Schedule Holders and the Results of the Research

GSA considered alternatives to this limited sources BPA modification, such as leveraging other established 4PL locations to support the seven locations covered by the BPA; however these other locations would be outside the geographical and 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.

7) Other Facts Supporting the Justification

N/A

8) 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 the Supplies or Services is Made

GSA developed a new MAS 4PL SIN as a result of the protest received under QSAB-RFQ- 19001. GSA continues to monitor the number of vendors that have transitioned to the new SIN. GSA will implement USMC’s requirements for the renewal of the follow-on BPA.

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

GSA/FAS/GSS/QSR

CONCUR:

Paul Mack Date Director Retail Operations Branch

GSA/FAS/GSS/QSR

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.

Carolyn M. Long Date Contracting Officer (Senior Unlimited Warrant) Central Office Acquisition Division GSA/FAS/GSS/QSABA