A16_JOFOC_Under_SAT_1-_VAFO_-_Maurice_Stephens_Final_Phase_-_signed_-_redacted_1.pdf

JUSTIFICATION & APPROVAL FOR OTHER THAN FULL AND OPEN COMPETITION

for SIMPLIFIED ACQUISITIONS OVER THE MICROPURCHASE THRESHOLD (See FAR

Part 2) UP TO SAT (See RFO FAR 12.102 (a))

Date: April 30, 2026 Solicitation Number: 140P4226R0017

1. Nature and/or description of the item/service being procured and its intended use (include the anticipated cost):

Department of the Interior (DOI) – Philadelphia MABO on behalf of the Valley Forge National Historical Park (VAFO) has a requirement for the completion of the Adaptive Reuse of the Maurice Stephens House. The work includes:

A. Masonry, Paving and Site Preparation Work

The contractor shall:

• Cut out existing masonry foundation to the updated elevation and add flagstone cap at Northeast ramp to allow for an ADA compliant ramp.

• Extend walkway to lower entrance per updated drawings

• Update grading along new walkway to allow for water drainage away from the building, which includes grate covers as required.

B. Millwork, Carpentry and Painting Work

The contractor shall:

• Furnish and install two (2) new metal railings at the northeast ramp as required for ADA compliance, per applicable code and regulations.

o Includes installation of necessary blocking for railing installations at walls.

o Includes Paint per industry standards for exterior metal railing, which includes at least one (1) prime coat and two (2) top coats-of paint at least or other applicable finish for exterior applications.

• Furnish and install one new door at opening 150.

o Includes demolition of existing door installed in opening 150.

o Reframe doorway opening 150 as necessary.

o Removal and reinstallation of Cedar Siding at opening 150 as necessary.

• Reframe northside deck to adjust for ramp modifications in order to meet ADA compliance requirements.

Government Estimate:

2. Sole Source Justification rationale (Check one and explain below):

X Only one responsible source.

☐ Urgent and compelling circumstances exist. Include critical delivery or performance dates, and when you became aware of the requirement. Provide a specific statement of the impact on Government operations, financial or otherwise, if the required delivery or performance dates are not met.

☐ Other:

Explain:

In accordance with Revolutionary FAR Updates (RFO), which was implemented through DOI-AAAP- F012 and RFO FAR 12.102 (a) For acquisitions valued at or below the simplified acquisition threshold (SAT), document the decision that only one source is available and the basis for the decision.

VAFO as a requirement for the Adaptive Reuse of the Maurice Stephens House, which included a new building that was being constructed outside of the Federal Government through the Lessee of the Maurice Stephens House. Lessee currently has a contract with International Management Consultants, Inc. for the construction of new building at the Maurice Stephens House for visitor use.

The nature of the work identified above was not included in the Lessee Contract for the construction of the new building. As this work directly impacts the work and the completion of the new Lessee Building being constructed by International Management Consultants, Inc., only International Management Consultants, Inc. is being considered.

As authorized by RFO 1.102 (b)(2) and (c), awarding a sole source contract to International Management Consultants, Inc. is a business decision, poses the least amount of risk, and is in the best interest of the Government.

3. Market Research. Please explain the results or why one was not performed. State whether any other offers were received, or anyone expressed interest:

The CO conducted an SBA search for file purposes as the work needed to be completed, and the SBA search that revealed 897 small business contractors under the NAICS Code 236220 – Commercial and Institutional Building Construction in the Commonwealth of Pennsylvania (PA), which to this Contracting Officer (CO) reasonably concluded as the correct NAICS code to use. While there are multiple vendors available, because International Management Consultants, Inc. is already working on the existing new building under a separate Lessee contract outside of the Department of the Interior, awarding directly to International Management Consultants, Inc. on a sole source basis is considered to meet the agency’s mission most efficiently and effectively (RFO 1.102 (a)(1)).

Further, due to the other work being performed by International Management Consultants, Inc. on the new building at the Maurice Stephens House, the VAFO Park Staff has had the opportunity to interact with them daily during all phases of the construction of the new building. Continuing to work with International Management Consultants, Inc. would be the most effective way to value time of the VAFO Park Staff and promote the merit of a contractor who has worked very successfully on the construction of new building. This continued working relationship would balance the interests and objectives of the taxpayer dollars and satisfy the VAFO Park Staff (RFO 1.102 (a)(2)).

Lastly, there is significantly less risk, because International Management Consultants, Inc. is already working on the new building at the Maurice Stephens House, and all this new work directly ties into that building (RFO 1.102 (c)). The risk of potentially causing warranty issues should the work required under this contract cause damage to the work provided by International Management Consults, Inc. on the new building through the Lessee Contract. For example, this project calls for the complete replacement of a door and reframing of a door opening that was already installed on the new building by International Management Consultants, Inc. to meet the corrected elevation changes for ABA compliance. This door replacement will also cause for the removal and reinstallation of cedar siding on a project that has not been completed or turned over to the lessee. If something fails after the work is completed, and two (2) different contractors are used, there would be a battle between two (2) different contractors on whose responsibility it would be.

Per RFO FAR 1.102 (a)(1) and EO 13834 on efficient federal operation, the Government is required to minimize administration operating costs and make the things more efficient. While competition is preferred, only International Management Consultants, Inc. has been found capable of providing the required construction services to complete the final phase of the Maurice Stephens House project..

4. If this is a determination for sole source, the contracting officer certifies:

a. Only one source is available, or urgent and compelling circumstances exist.

b. The anticipated price will be determined fair and reasonable using the price analysis techniques described in original FAR Part 13.106-3(a), as authorized by RFO 1.102 (b)(4), because the RFO does not fully address construction under RFO Part 12 in this CO’s opinion, and creates inconsistencies, which can reasonably be eliminated by using the original FAR 13 fair and reasonable determinations for simplified acquisition procedures under the SAT.

(Signature) _______________________________________ (Date)__________________________

Name & Title: __________________________________________

(Signature) _______________________________________ (Date) ___________________________

Name: Brian McCabe Contracting Officer

Over $50,000: (if applicable)

(Signature) _______________________________________ (Date) ______________________

Name: __________________________________________

Warranted Individual 1 Level Above Contracting Officer