A07 JA Redacted_.pdf

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Justification for Exception to Fair Opportunity - Nationwide Shred
Solicitation number
HS002123C0007
Issued by

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This justification document approves a sole source contract award to Griffin Resources, LLC for nationwide shredding services for 60 field offices of the Defense Counterintelligence and Security Agency. The services include on-site destruction and recycling of designated paper materials containing personally identifiable information at each location, in accordance with National Archives and Records Administration guidelines. Griffin Resources, as a qualified HUBZone small business, will transport shredded byproducts from each site to recycling facilities. The proposed one-year base contract valued at approximately $4 million, includes four one-year option periods and a potential six-month extension. Market research through two requests for information on SAM.gov identified Griffin Resources as the only capable HUBZone small business. The justification and approval was signed in February 2023, and the related sole source contract was awarded to an unknown vendor in the same month.

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JUSTIFICATION AND APPROVALS FOR OTHER THAN FULL AND OPEN

COMPETITION

Nationwide Shredding for Field Offices

1. Identification of the agency and contracting activity.

The Defense Counterintelligence and Security Agency (DCSA) Office of Acquisitions (AQ) located at 27130 Telegraph Road, Quantico, Virginia 22314, proposes to enter into a contract on a basis of other that full and open competition to meet the needs of a nationwide shredding requirement for DCSA's Personnel Security Background Investigation Operations Support directorate. This document is a justification for other than full and open competition.

2. The nature and/or description of the action being approved. (i.e., sole source, limited competition, establishment of a new source, etc.)

The pmpose of this document is to obtain the necessaiy approvals for a sole source acquisition in accordance with (IA W) Federal Acquisition Regulation (FAR) 6.302-5, authorized or required by statute. The procurement strategy is to issue a fom-fixed-price (FFP) contract sole sourced to Griffin Resources, LLC IA W FAR Paii 12, Acquisition of Commercial Items, FAR Subpa1i 13.5, Simplified Procedures for Ce1iain Commercial Products and Commercial Services, and FAR 19 .1306, HUB Zone sole-source awai·ds.

3. Description of the supplies or services required to meet the agency's needs (including estimated value).

This is a consolidated, follow-on effo1t The previous contracts were awai·ded using two

(2) IDIQ contracts. HS002119D0005 was issued to suppo1i 55 Background Investigations (BI) field offices under DCSA. HS002119D0 131 was issued to suppo1i the BI field offices within the DC area of operations for DCSA.

DCSA's BI directorate requires the continued service of the proper destruction and recycling of designated paper material that may contain personally identifiable info1mation (PII) for 60 nationwide locations IA W National Archives and Records Administration (NARA) guidelines. All shredding must be perfo1med on-site and is subject to DCSA oversight. The conti·actor shall ti·anspo1i the shredded byproduct to a recycling facility once the shredding is complete.

IA W FAR 19 .1306, Griffin Resources has been found to be a qualified HUBZone small business concern capable of meeting the requirement. The proposed conti·act action will have a period of perfonnance of a one (1) year base period, four ( 4) one-yeai· options periods, and a potential for a six (6) month extension IA W FAR 52.217-8, option to extend se1vices. The estimated value for the total conti·act (base period and options) is

4. Identification of the statutory authority permitting other than full and open competition.

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41 USC 1901 authorizes agencies to contract without full and open competition under certain circumstances. For this acquisition, other than full and open competition is permitted IA W FAR 6.302-5, Authorized or required by statute. IAW FAR 6.302-5(b)(5), sole source awards under HUBZone Act of 1997, Griffin Resources has been found to be a HUBZone small business concern capable of meeting the requirement.

5. A demonstration that the proposed contractor's unique qualifications or the nature of the acquisition requires use of the authority cited.

IA W FAR 19 .1306, Griffin Resources has been found to be a qualified HUBZone small business concern capable of meeting the requirement. More specifically, there is no reasonable expectation that offers would be received from two or more HUBZone small business concerns; the anticipated price of the contract will not exceed $4.5 million; the requirement is not currently being perfo1med by an 8(a) paiiicipant under the provisions of subpaii 19 .8 or has been accepted as a requirement by SBA under FAR Subpa1i 19.8; the acquisition is greater than the simplified acquisition threshold; the HUBZone small business concern has been detennined to be a responsible contractor with respect to perfonnance; and an award can be made at a fair and reasonable price.

6. Description of efforts made to ensure that offers were solicited from as many potential sources as is practicable. Include whether or not a SAM.gov announcement was made and what response, if any, was received, or include the exception under FAR 5.202 if not synopsizing. Describe whether any additional or similar requirements are anticipated in the future.

fu December of 2021, DCSA AQ posted a Request for fufo1mation (RFI) to SAM.gov in order to locate potential sources for the nationwide shred requirement. DCSA released an additional RFI in September 2022. Collectively, Griffin Resources was the only HUBZone small business concern to respond to the RFis.

A notice of intent was also posted to the Government Point of Entry 15 days prior to the solicitation release IA W FAR 5.203(a). No responses were received to the notice on intent. A notice of the sole source award with a redacted copy of this justification and approval memo will be made publically available within 14 days of contract award.

7. The anticipated dollar value of the proposed acquisition, including options if applicable, and a determination by the contracting officer that the anticipated cost to the government will be fair and reasonable.

The anticipated dollai· value of the proposed acquisition, including all options, is approximately-. In dete1mining a fair and reasonable price, the Contracting Officer will perfo1m a price analysis in accordance with FAR 15 .404-1 (b ). Price analysis may include comparison to historic pricing, market research, established price lists, or other means to detennine fairness and reasonableness.

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8. A description of the market research conducted (FAR Part 10) and the results or a statement of the reason market research was not conducted.

fu December of 2021, DCSA AQ posted a Request for fufonnation (RFI) to SAM.gov in order to locate potential sources for the nationwide shred requirement. DCSA released an additional RFI in September 2022. Collectively, Griffin Resources was the only HUBZone small business concern to respond to the RFis.

A notice of intent was also posted to the Government Point of Entry 15 days prior to the solicitation release IA W FAR 5.203(a). No responses were received to the notice on intent.

9. Any other facts supporting the use of other than full and open competition.

DCSA AQ has coordinated with the DCSA Office of Small Business Programs to detennine that a FFP contract sole sourced to Griffin Resources, LLC IA W FAR Pait 12, Acquisition of Commercial Items, FAR Subpa1i 13.5, Simplified Procedures for Ce1iain Commercial Products and Commercial Services and FAR 19 .1306, HUB Zone sole-source awai·ds, is within the best interest of the Government. A DD2579 was signed by the DCSA Office of Small Business Pro grains on 3 J anuaiy 2023.

10. A listing of the sources, if any, that expressed, in writing, an interest in the acquisition.

DCSA AQ released an RFI to industry on SAM.gov in December 2021. AQ received three (3) responses. The responses were from Iron Mountain (lai·ge business), Source America (Other than small, AbilityOne), and Stericycle (large business). Of the three (3) responses, only the large businesses, Iron Mountain and Stericycle, stated that they were capable of executing the requirement.

The most recent RFI was released to industry on SAM.gov in September 2022. AQ received three (3) responses. The responses were from Griffin Resources (small business HUBZone), Document Security Solutions (8(a) Service-Disabled Veteran-Owned Small Business (SDVOSB)), and Stericycle (large business). Of the three (3) responses, Griffin Resources and Stericycle were the only companies that stated they were capable of executing the requirement. Document Security Solutions stated in their RFI response that they are only capable of providing service to 43 of the 60 locations. Collectively, Griffin Resources was the only HUBZone small business concern to respond to market research.

11. A statement of the actions, if any, the agency may take to remove or overcome any barriers to competition before any subsequent acquisition for the supplies or services required, if subsequent acquisitions are anticipated.

Due to the relevant, additional, market research conducted, the procedure for sole source acquisition is the most appropriate procurement avenue at this time.

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Certification

Program Official:

I ce1iify that the facts and representations under my cognizance, which are included in this justification and which fo1m a basis for this justification, are complete and accurate.

t, • ! • �•I-• ••

X Date: 2023.02.1612:09:15-05'00'

Proqram Senior Official (or desiq nee):

Contracting Officer:

I certify that this justification is accurate and complete to the best of my knowledge and belief. Since this effort exceeds the simplified acquisition threshold, but does not exceed $750K, this certification serves as approval.

X

Contractinq Officer

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File details come from the government source that posted it. Updated .