A16_-_JOFOC_DJ_Case_Drupal_Dev_and_Support_(1)_1.pdf

FWS Form 3-0051 (Rev. 5/12/2021) U.S. Fish and Wildlife Service

JUSTIFICATION AND APPROVAL FOR OTHER THAN

FULL AND OPEN COMPETITION (JOFOC) - OVER SAT

JOINT ADMINISTRATIVE OPERATIONS

Acquisitions Operations

1. Agency and Contracting Activity (FAR 6.303-2(b)(1)).

3. Description of Supplies/Services (FAR 6.303-2(b)(3)).

2. Nature/Description of Action (FAR 6.303-2(b)(2)).

In accordance with FAR 6.302, the proposed contractual action is pursuant to the statutory authority identified in section 4 of this document. This template is required for actions over the Simplified Acquisition Threshold (SAT) (unless the procurement is acquired as a limited source IAW FAR 8.405-6 or is an Exception to Fair Opportunity IAW FAR 16.505(b)(2)).

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.

4. Statutory Authority Permitting Other than Full and Open Competition (FAR 6.303-2(b)(4)).

(check one)

Authority FAR Coverage Application 41 U.S.C. 1901 FAR 13.501 Only one responsible source using

Simplified Acquisition Procedures (above SAT but below $7M)

41 U.S.C. 1903 FAR 13.501 Special emergency procurement authority

41 U.S.C. 3304(a)(1) FAR 6.302-1 Only one responsible source and no other supplies or services will satisfy agency requirements

41 U.S.C. 3304(a)(1) FAR 6.302-1(c) Application for brand-name descriptions

41 U.S.C. 3304(a)(2) FAR 6.302-2 Unusual and compelling urgency

41 U.S.C. 3304(a)(3) FAR 6.302-3 Industrial mobilization; engineering, developmental or research capability; or expert services

41 U.S.C. 3304(a)(4) FAR 6.302-4 International Agreement

41 U.S.C. 3304(a)(5) FAR 6.302-5 Authorized or required by statute

41 U.S.C. 3304(a)(6) FAR 6.302-6 National Security

41 U.S.C. 3304(a)(7) FAR 6.302-7 Public Interest

5. Demonstration of Contractor’s Unique Qualifications (FAR 6.303-2(b)(5)).

6. Description of Efforts Made to Maximize Competition (FAR 6.303-2(b)(6)).

7. Determination of Fair and Reasonable Cost (FAR 6.303-2(b)(7)).

8. Description of Market Research Conducted (FAR 6.303-2(b)(8)).

9. Any Other Supporting Facts (FAR 6.303-2(b)(9)).

Program / Project Officer

13. Contracting Officer Certification and Approval: (All Values) FAR 6.304(a)(1)

Based on the above justification, I hereby certify that the circumstances of this contract action deem only one source reasonably available and approve the use of sole source acquisition procedures for this purchase.

Contracting Officer

10. Listing of Interested Sources (FAR 6.303-2(b)(10)).

11. Actions Taken to Remove Barriers to Competition (FAR 6.303-2(b)(11)).

12. Technical/Requirements Certification: FAR 6.303-2(c)

I certify that the supporting data under my cognizance which are included in the justification are accurate and complete to the best of my knowledge and belief.

14. Approval by Chief of Contracting Office (>SAT)

Based on the foregoing justification I hereby approve this procurement.

Chief of Contracting Office

15. Approval by Senior Chief of Contracting Office (>$700K)

Based on the foregoing justification I hereby approve this procurement.

Senior Chief of Contracting Office

16. Approval by Head of Contracting Activity (>$700K) FAR 6.304(a)(2)

Based on the foregoing justification I hereby approve this procurement.

17. Approval by Senior Procurement Executive (>$68M) FAR 6.304(a)(4)

Based on the foregoing justification I hereby approve this procurement.

Senior Procurement Executive

Head of Contracting Activity

The work under this contract entails continuous improvement to operational sites as well as maintenance actions that aim to keep systems in line with frequently updated industry standards. Performing these actions efficiently requires a comprehensive understanding of the Service's enterprise system architecture and organizational makeup. Contractors are expected to perform support functions in the following areas (including, but not limited to): Site Building & Configuration of Drupal Core Components; Refinement & Extension of Drupal’s Content Management Functionality; Improvement & Integration with Media Management tools; Management of Apache SOLR and Faceted Search; Development Support for Custom Modules and Functionality; and Maintenance support on routine software and security updates.

The period of performance is structured as a 1 base year + 3 option years, to allow for out-year flexibility in maintaining operational support services, while also allowing the service to be reactive to a potentially changing landscape.

Text4: Due to the large scale knowledge transfer required to hand off support of FWS Drupal web operations D.J. Case and Associates is determined to be the only responsible source to support this work to avoid extensive additional cost and burden to the government. It is anticipated that a transition of this work to another contractor would require a 6-12 month on-boarding process that maintenance timelines are not conducive to without greatly increasing cost and risk. These efforts would be expected to require 50-100% ($200k-$400k ballpark estimate) greater cost to the government in the first year due to the need to maintain concurrent contracts and increase capacity.

As FWS's Drupal environment continues to progress, key support actions will be expected of the contractor including a full scale upgrade to Drupal 10 (next major software version; all sites), version upgrade to PHP (which has uncertain consequences on custom developed modules), and a migration to a new cloud host. With this, FWS's Drupal environment consists of numerous system integrations and custom developed module components that bring uncertain consequences during updates - these consequences are able to be addressed more efficiently by the developers who created them. Environment wide changes/updates of this nature require intimate knowledge of the system architecture that is not feasibly obtained without a long form off-boarding engagement. Additionally, D.J. Case maintains a leading role in a Refuges/Visitor Services improvement initiative that directly ties into the enterprise Drupal environment. FWS does not want to encourage rethinking of established designs and content management strategies and sees the introduction of a new development support team as a significant risk at this time. Continuing work with the incumbent contractor avoids likely schedule delays and cost increases, and allows FWS to remain confident that these crucial operational support tracks will be effectively supported.

Due to D.J. Case's support of FWS web operations, they have also grown to maintain an in-depth understanding of FWS IT operations and the surrounding organizational makeup. This allows for efficient problem solving that would otherwise be expected to incur greater costs throughout the course of the contract. While this cost is undefined As the enterprise Drupal environment is still maturing and stabilizing, FWS see's the continued support of this development team as the only responsible source. The intent beyond this contract action will be to aim for environmental stability and staging of future maintenance processes for the flexibility of a smoother, lower risk support transition.