A16_-_Limited_Sources_Justification_-_Redact_-_SAM_Posting_1.pdf

Department of the Interior Bureau of Safety and Environmental Enforcement

LIMITED SOURCES JUSTIFICATION (LSJ)

Federal Supply Schedule Program - FAR 8.4

(Mandatory for Acquisitions > SAT) (Optional for Acqs. SAT)

This acquisition is being conducted under the authority of the Multiple-Award Schedule Program pursuant to Title III of the Federal Property and Administrative Services Act of 1949 and Title 40 U.S.C. 501, Services for Executive Agencies [FAR 8.405-6(c)(1)].

1. Bureau and Contracting Activity [FAR 8.405-6(c)(2)(i)]

2. Description of Supplies or Services [FAR 8.405-6(c)(2)(iii)]

3. Requisition No.

4. Cost Estimate (including options)[FAR 8.405-6(c)(2)(iii)]

5. Name of Proposed Source(s)

6. REQUESTING OFFICE CERTIFICATION

I certify that this recommendation contains the information required by FAR 8.405-6(c) and its contents are accurate.

Date:Phone No:Signature:Requesting Office Rep. (Name &Title)

7. ACQUISITION OFFICE CERTIFICATION

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

Signature: Phone No: Date:Contracting Officer (Name) ignature:

Department of Interior (DOI), Bureau of Safety and Environmental Enforcement (BSEE), Acquisition Operations Branch (AOB) on behalf of the Bureau of Ocean Energy Management

The purchase of a study to provide Maintenance, Training, and Support for BOEM’s Market Simulation Model and Offshore Environmental Cost Model (OECM) with a base period of performance of eighteen (18) months plus two additional 18 month option periods. MarketSim is an Excel-based model that estimates the energy commodity price changes expected to occur with new OCS oil and gas production and then calculates the displacement of energy market substitutes that would occur given those price changes. The OECM is an Access-based model that uses the levels of OCS activity from exploration and development (E&D) scenarios.

44016025 Industrial Economics 2067 Massachusetts Ave Cambridge, MA 02140-1340

UEI: F1BNQ68LSJ61

$899,710

05/13/2025Kristen Strellec 703 787-1625

William Rilee 703-787-1757WILLIAM

RILEE

Digitally signed by WILLIAM

RILEE

Date: 2025.05.13 14:05:32 -04'00'

5/13/2025

Identify the authority being used to justify restricting consideration to a limited number of vendors [FAR 8.405-6]. Provide a narrative justification associated with the respective authority. Refer to block number 12 for additional justification details.

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

9. FAR 8.405-6(a)(1)(i)(B) – Only one source is capable of responding due to the unique or specialized nature of the work.

10. FAR 8.405-6(a)(1)(i)(C) – The new work is a logical follow-on to an original FSS order or BPA, and the original order or

BPA was placed in accordance with applicable FSS ordering procedures. The original order or BPA must not have been previously issued under sole-source or limited-sources procedures.

11. FAR 8.405-6(b) – An item peculiar to one manufacturer is required.

Industrial Economics, Incorporated is unique as they developed the original MarketSim and OECM as well as performed all recent updates to the models, and they have knowledge and expertise with the project that no other company currently possesses. A different contractor would have to reverse engineer and/or duplicate Industrial Economics already performed efforts in order to perform the services being requested under this new requirement. Additional effort would be needed from another vendor to include understanding the intricate details of the data, assumptions, user interface and coding within the models which are unique to Industrial Economics. This would cost considerable additional time and money and delay the answering of key questions about the models (including those related to recent lawsuits against BOEM) as well as the final development of properly functioning updated models.

12. JUSTIFICATION (Attach additional pages if needed)

(a) Nature and/or description of the action being approved [FAR 8.405-6(c)(2)(ii)] [Prepared by Program Office]

(b) Determination by the Acquisition Office Contracting Officer that the order represents the best value consistent with FAR 8.804(d) [FAR 8.405-6(c)(2)(v)] [Prepared by Contracting Officer]

(c) Description of the market research conducted among schedule holders, and the results of the research, or a statement why market research was not conducted [FAR 8.405-6(c)(2)(vi)] [Initiated by the Program Office and finalized in collaboration with the Contracting Officer]

BSEE intends to award a sole source order to the vendor under their GSA Schedule 47QRAA20D0044.

The Contracting Officer determined that the anticipated price will be fair and reasonable based on the vendor's GSA Schedule pricing. Prices of products on the GSA Schedule have already been determined to be fair and reasonable at the contract level.

The Contracting Officer will perform a price analysis to determine that the price, at the time of award, represents the best overall value to the Government and is fair and reasonable.

The prior order was awarded under GSA Multiple Award Schedule 541611 “Management and Financial Consulting, Acquisition and Grants Management Support, and Business Program and Project Management Services.” Various other GSA schedules were reviewed under 541511 to see if they could be applicable to this requirement and none were found besides Industrial Economics. The program office consulted other Government representatives who have had similar requirements and general knowledge of the of BOEM requirements and no other vendors could be identified besides Industrial Economics to meet the needs of this requirement. The Dynamic Small Business Search system was used and no vendors were identified with either MarketSim or OECM expertise. SAM.gov was searched and no other vendors were identified to have expertise with OECM or MarketSim other than Industrial Economics.

12. JUSTIFICATION CONTINUED (Attach additional pages if needed)

(d) Statement of the actions, if any, the agency may take to remove or overcome any barriers that led to restricted consideration before any subsequent acquisition for supplies and services is made [FAR 8.405-6(c)(2)(viii)] [Initiated by the Program Office and finalized in collaboration with the Contracting Officer]

(e) Any other facts supporting the justification [FAR 8.405-6(c)(2)(vii)] [Prepared by the Program Office and Contracting Officer]

The program office will continue to engage in market research to see if any other models exist or developed that provide the support and data utilized in this requirement to see if alternative solutions exist. At this time, none are known.

None.

14. Competition Advocate (Name & Title)

APPROVE

DISAPPROVE

(Phone No.)

(Date)

15. Head of the Contracting Activity (Name & Title)

(Date)

(Phone No.)

(Signature)

(Signature)

(Signature)

APPROVE

DISAPPROVE

16. Departmental Senior Procurement Executive (Name & Title) APPROVE

DISAPPROVE

(Phone No.)

(Date)

O ve r $7

,0

O ve r

$1 m ill io n

O ve r $7 m ill io n (Signature)13. Chief of the Contracting Office (Name & Title)

APPROVE

DISAPPROVE

(Phone No.)

(Date)O ve r

SA

T

APPROVALS [FAR 8.405-6(d)]

703-787-1324 Douglas Marr Deputy Associate Director for Acquisitions Management

703-787-1523

Rebecca L. Kruse Branch Manager, Acquisition Operations Branch Acquisition Management Division

REBECCA

LEAKE

KRUSE

Digitally signed by

REBECCA LEAKE

KRUSE

Date: 2025.05.14 10:26:09 -04'00'

DOUGLA

S MARR

Digitally signed by

DOUGLAS MARR

Date: 2025.05.16 08:36:10 -04'00'

INSTRUCTIONS FOR COMPLETING FORM

Block No.

Identify Bureau initiating the requirement and Acquisition Office processing the requirement.

- Bureau of Safety and Environmental Enforcement (BSEE), or Bureau of Ocean Energy Management (BOEM)

Provide a clear, concise description of the product(s) and/or service(s) to be procured, including the delivery schedule and/or the period of performance (including all option periods). Always include the estimated value of the order or BPA in Section 4 below. This provides the reviewing and approving official with a better understanding of the scope, magnitude, and complexity of the requirement.

4 Include all applicable options and system life-cycle costs.

Include more than one source as a proposed vendor, unless you are citing FAR 8.405-6(a)(1)(i)(B). For example, if the procurement is based on unusual and compelling need, you must still contact as many potential sources as is practicable unless the justification for urgency contains detailed documentation to show that it is not practicable under the circumstances to solicit additional sources.

6 & 7 Obtain certification from the requesting office and contracting officer prior to submitting for approval.

8-11

Check the box next to the justifying authority. Only one authority can be cited.

- Include an explanation of the contractor's unique qualifications, the nature of the acquisition that requires the use of the same vendor as part of a logical follow on, or the reasons for urgency and an explanation of how using the procedures would result in unacceptable delays. This is the most important part of the LSJ because it demonstrates that the prospective contractor has unique qualifications and/or specialized capabilities or expertise that is not prevalent elsewhere on the schedules. If the order contains a brand name specification, the ordering activity must show evidence that the Request for Quotation and the following information was posted on GSA e-

Buy. You must explain what unique qualifications and special capabilities the vendor possesses.

- When FAR 8.405-6 (a)(1)(i))(A) is cited, provide data, estimated cost, or other rationale as to the extent and nature of the harm to the government following schedule procedures would cause.

- When an urgent or compelling need exists, discuss the nature of the urgency. Discuss how any follow-on work will be competed (mandatory). Also, provide supporting rationale and a concise description of the extent, nature, and impact of the unacceptable delay.

- When FAR 8.405-6 (a)(1)(i)(C) is cited for logical follow on, include an estimate of the duplicative cost and methodology used to formulate the estimated cost.

- The justification on pages 3 and 4 must be clear and concise as to how the cited authority is related to the acquisition.

- When applicable, include documentation that demonstrates the prospective vendor's unique qualifications to provide the required supply of service.

12(a)

Describe the type of action being issued, e.g., Federal Supply Schedule (FSS) order or blanket purchase agreement (BPA) for supplies, services not requiring a statement of work, or services that require a statement of work. Also, identify the contemplated contract type, i.e. firm fixed price, time and materials, etc. Provide sufficient information so the reviewer clearly understands the proposed approach under consideration.

12(b) The Contracting officer needs to determine, after considering the level of effort and the mix of skills available for the tasks needed, that the proposed order or BPA represents a reasonable total price and will be the best value for the government. Include explanation of what techniques will be used to determine prices fair and reasonable.

INSTRUCTIONS FOR COMPLETING FORM

Block No.

12(c)

Market research requires collecting and analyzing product/service information on the technical capabilities and prices/costs from appropriate FSS contracts. If market research was not conducted, the reasons why it was not conducted should be stated.

If above the SAT, a copy of the proposed LSJ prepared in accordance with this guide; if an exception permitted by 8.405-6(b)(3)(ii) exists, documentation of the exception should be provided here in lieu of the E-buy posting.

12(d)

Describe actions taken, or that will be taken, to remove or overcome any barriers to competition before any subsequent acquisitions for the supplies or services required, including challenges to restrictive data markings, data rights, preparation of a performance based work statement, etc. If planning a competition, include the estimated date when the competitive procurement will occur. If this is a follow-on order, state the measures initiated to eliminate or reduce competitive barriers.]

12(e) Provide any additional documents that will support the justification.

If any person required to sign-in these blocks does not approve, the procurement shall not proceed any further and the justification shall be returned to the requisitioner through the contracting officer. All signatures required on the form (as applicable to the particular acquisition) must appear in order for the procurement to proceed.

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