A16_JOFOC_Sole_Source_Justification_FAR_13_501_CA_5-2-24_CA_FINAL_FULL_1.pdf

United States Department of the Interior

INTERIOR BUSINESS CENTER

Washington, DC 20240

SOLE SOURCE JUSTIFICATION

SIMPLIFIED PROCEDURES FOR CERTAIN COMMERCIAL ITEMS

AUTHORITY: FAR 13.501(a), 41 U.S.C. 1901

140D0424Q0450

1. Identification of the agency and the contracting activity, and specific identification of the document as a “Sole Source Justification.”

This document is a sole source justification for the Department of the Interior, Interior Business Center, Acquisition Services Directorate, Division 5, Branch 5 on behalf of the Department of Defense (DoD), Air Force Civil Engineer Center (AFCEC).

2. Nature and/or description of the action being approved.

This non-severable service requirement is on behalf of the DoD, AFCEC program. The proposed action is to award a sole source Firm-Fixed-Price (FFP) contract to Quaternary Resource Investigations, LLC (QRI) for Environmental Assessments (EA) for Vance Air Force Base (AFB), Oklahoma and for Laughlin AFB, Texas. The action will be a new requirement.

3. A description of supplies or services required to meet the agency’s needs (including the estimated value).

The action is for a new requirement to develop two (2) EA: one for Vance AFB, Oklahoma and one for Laughlin AFB, Texas to support the Fighter Bomber Fundamental (FBF) training program as part of the Air Education Training Command (AETC). The two (2) EA will analyze the potential environmental impacts associated with new airspace to support critical training requirements as defined by the Department of the Air Force (DAF).

As part of this effort, the Contractor will be responsible for generating an EA and Finding of No Significant Impact (FONSI), if supported by the analysis, for Vance AFB, Oklahoma, and Laughlin AFB, Texas. The Period of Performance for the Vance and Laughlin AFB Airspace EAs is 36 months (5/30/24

– 5/29/27) with no option years. The total estimated value is $1,494,956.38.

4. An identification of the statutory authority permitting sole source acquisition.

This is an acquisition conducted under the authority of the Simplified Procedures for Certain Commercial Items. The statutory authority permitting sole source acquisition is 41 U.S.C 1901 as implemented by FAR 13.501(a)(1)(ii).

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

Environmental Impact Analyses that involve airspace proposals have an added level of complexity as they require the evaluation of two (2) major federal actions simultaneously (one for the DAF and one for the FAA). As a result, defining and establishing a successful methodology is critical to an effective NEPA process and outcome.

Similar work is currently being completed by QRI using the U.S. Army Corps of Engineers (USACE) Indefinite Delivery, Indefinite Quantity (IDIQ) contract. The DAF was told that they cannot continue to use the USACE IDIQ for this effort as that contract is at capacity. USACE Contracting is no longer awarding any task order on that vehicle, precluding the DAF from securing the necessary expertise for this environmental impact analysis.

QRI, has the subject matter expertise to successfully perform the complex, airspace environmental impact analyses associated with this effort. QRI is currently working with AETC on the FBF program. QRI’s foundational knowledge of AETC’s FBF training program and requirements is unique and reflective of their expertise. The FBF program was established 3 years ago at which time QRI began developing the program in tandem with DAF. Incorporating this exclusive knowledge into the Vance and Laughlin Airspace analyses will provide great benefit to the DAF with regards to cost savings and time efficiencies.

The DAF will be able to use QRI’s unique expertise to develop and complete the Vance and Laughlin EAs that would ensure consistency across the FBF program, minimize schedule, mission delays, and provide cost savings by incorporating established knowledge and processes into the two (2) new EAs.

The accomplishment of the Vance and Laughlin AFB Airspace EA will be an extension of the FBF program requirements analyzed through the Joint Base San Antonio (JBSA)Randolph Airspace EA which was completed by QRI. The foundational information relating to the FBF program training and critical mission requirements were developed and analyzed under the JBSA Randolph EA and will be incorporated and expanded in both the Vance and Laughlin Airspace EAs.

This shared information will result in a cost savings to the DAF through the reduced effort of developing the Description of the Proposed Action and Alternatives (DOPAA). As part of the DOPAA development, QRI would have already established sound doctrine on the FBF program, the purpose and need for the proposed action, and the background of the training requirements as they relate to pilot readiness and National Defense Strategy. The DOPAA development portion of the EA is usually one of the heaviest costs of the overall effort ranging from 20% to 30% of the total project costs. However, by using QRI who has FBF knowledge and expertise, the DOPAA development for both Vance and Laughlin EAs is expected to be close to 10% of the total effort—an estimated cost savings of approximately $120,000 to $150,000. There will be additional cost savings integrated into the data collection and analyses, along with fewer meetings involving the Federal Aviation Administration (FAA) and the proponent.

There is currently a pilot shortfall within the DAF. The Secretary of the Air Force (Sec AF) shifted training requirements to assist in meeting this deficit. It is time critical that the FBF program requirements get established in order to fulfill and meet pilot readiness goals and objectives. Using QRI will allow the DAF to streamline the National Environmental Policy Act (NEPA) requirements when analyzing the two

(2) EA airspace proposals for Vance and Laughlin AFBs. This time savings in the development of the EAs will assist the DAF in meeting pilot readiness in support of the United States of America National Defense Strategy.

QRI’s unique FBF historical knowledge and expertise are critical for nurturing collaborative relationship with the FAA regarding both Vance and Laughlin Airspace EAs. Furthermore, QRI’s familiarity with the FBF program will significantly benefit the DAF during joint meetings with the FAA.

To begin working with a new Contractor at this stage in the program would cost the DAF 3 years of development and delay mission readiness. Because pilot readiness is critical to the National Defense, time is a valuable commodity to this effort. QRI provides a depth of knowledge that allows the Department of the Air Force (DAF) to continue to move forward in meeting National Defense Strategy goals as defined by the Secretary of the Air Force for pilot readiness. QRI began developing the FBF program with the DAF 3 years ago. This experience will have a direct positive impact on the mission requirements including program costs and mission readiness.

6. A description of efforts made to ensure that offers are solicited from as many potential sources as practicable, including whether a notice was or will be publicized as required by FAR Subpart 5.2 and, if not, which exception under FAR 5.202 applies.

Market research was conducted in March 2024 by the Program Officer and the Contracting Officer (CO).

A Notice of Intent (NOI) to Sole Source was posted to SAM.gov on March 19, 2024, and closed on March 25, 2024 (see sections 8 and 10 for more information). No additional capable contractors were identified.

7. A determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable.

The CO determines that the anticipated price(s) will be fair and reasonable based on comparing the proposed pricing to the Independent Government Estimate (IGE), historical labor rates, pricing from previous similar contracts and other available catalog pricing.

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

Market research conducted by the Program Office and CO revealed that the services required are not available through mandatory use vehicles nor from mandatory sources such as AbilityOne or Federal Prison Industries. Additionally, these services are not available via the General Services Administration (GSA) Schedule.

An NOI was posted on SAM.gov on March 19, 2024, and closed on March 25, 2024. Three responses were received: Aerostar Environmental and Construction LLC; Stell Environmental Enterprises, Inc.;

and Vernadero Group Inc. All responses were reviewed by the Program Office, and it was determined that none of the contractors could meet the requirements (see Part 10 for additional details).

9. Any other facts supporting the use of other than full and open competition, such as:

Not applicable.

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

Aerostar Environmental and Construction LLC, Stell Environmental Enterprises, Inc. and Vernadero Group Inc. expressed an interest in the acquisition.

Upon reviewing the three NOI responses, the results showed the parties who responded were not capable of meeting this requirement.

• Aerostar Environmental and Construction LLC - has no active DAF Special Use Airspace NEPA experience related to FBF training. All submitted experience focused on Air National Guard, USACE/U.S. Army, and U.S. Navy NEPA efforts. While similar in nature, this requirement is looking for efficiencies that provide cost and time savings that are critical to meet National Defense Strategy goals and objectives.

• Stell Environmental Enterprises, Inc - has no active DAF Special Use Airspace experience related to FBF training. All submitted experience focused on U.S. Army and U.S. Navy effort with little to no special use airspace focus. While similar in nature, this solicitation is looking for efficiencies that provide cost and time savings that are critical to meet National Defense Strategy goals and objectives.

• Vernadero Group Inc - has no active DAF Special Use Airspace experience related to FBF training. While submitted special use airspace DAF NEPA experience is similar in nature; it was completed in a different FAA Service Area than this requirement and the DAF is looking for efficiencies that provide cost and time savings that are critical to meet National Defense Strategy goals and objectives.

No additional capable contractors were identified as the work required is specialized and has high visibility. QRI, has the subject matter expertise to successfully perform the complex airspace environmental impact analyses associated with this effort. It is not expected that any other vendors will have the capability to meet this requirement.

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.

The Government performed market research to identify businesses capable of providing the necessary services to fulfill this requirement. While only one source can satisfy this requirement, throughout the life of the contract, the Program Office, as well as the CO, will make every effort to identify other sources for this service. If additional services are needed, the agency will research the industry to remove or overcome barriers to competition.

12. Contracting officer certification that the justification is accurate and complete to the best of the contracting officer’s knowledge and belief.

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

Digitally signed by MORGAN SCHICKLER Date: 2024.04.09 11:01:51 -04'00'

Morgan Schickler (Contracting Officer) Date

13. Requirements personnel certification.

I certify that the technical data which forms a basis for this justification is complete and accurate and meets the Government’s minimum needs.

DIVINE.ROBIN.DESIREE.1278139

Digitally signed by

DIVINE.ROBIN.DESIREE.1278139642

Date: 2024.04.10 07:46:05 -05'00'

Robin Divine (Program Office) Date

14. Reviews and Approvals

Concur

Michael McGuire (Branch Chief) Date

Concur

Sarah Rumney (Division Chief) Date

Approve

Michael Farrell (Bureau Competition Advocate) Date

MORGAN SCHICKLER

MICHAEL MCGUIRE

Digitally signed by MICHAEL

MCGUIRE

Date: 2024.04.23 13:14:37 -04'00'

SARAH RUMNEY

Digitally signed by SARAH

RUMNEY

Date: 2024.04.25 07:24:54 -04'00'

MICHAEL FARRELL Digitally signed by MICHAEL FARRELL Date: 2024.05.02 13:59:02 -04'00'