A16_ND_RMP_Revision_and_EIS_Limited_Source_Justification_Redacted_2.pdf
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This Limited Source Justification (LSJ) document from the Bureau of Land Management (BLM) requests a new contract with Environmental Management and Planning Solutions Inc (EMPSi) for a Resource Management Plan (RMP) Revision and associated Environmental Impact Statement (EIS). The 24-month contract will focus on updating the 2025 RMP for the North Dakota Field Office, specifically addressing new directives and pending litigation related to energy and critical minerals. BLM is pursuing a sole source procurement under Federal Supply Schedule procedures, citing EMPSi's unique qualifications and prior experience with the existing RMP, including specialized tools like air quality models, geodatabases, and a Reasonably Foreseeable Development scenario for oil and gas activities. The contract is estimated to be over $250,000, with BLM asserting that using EMPSi will save approximately $350,000 and avoid a six-month project delay compared to onboarding a new contractor.
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United States Department of the Interior
BUREAU OF LAND MANAGEMENT
https://www.blm.gov
MIT D OURC U IF CA ION ( J)
G A BPA o o e tim te ove 250,000
This document sets forth the justification and approval as required by FAR 8.405-6.
1. d n i a ion o h Ag ncy a d h on r c i g Ac ivi y: The Department of the Interior, Bureau of
Land Management (BLM), North Dakota Field Office/Dickinson, North Dakota, requests the BLM National Operations Center, Denver, Colorado, to contract on a limited or sole source basis.
2. N ur an /o scr i n o e c ion b i g pproved: This is a request for a new contract/BPA Order (firm fixed price) through other than full and open competition to Environmental Management and Planning Solutions Inc (EMPSi).
3. A escr i n o h p l e r rvice e u d e ng h Ag cy’ e , nc u i g e tim te va ue: This is a request to contract for Planning and NEPA Services (through the NOC
BPA) for a Resource Management Plan Revision and associated Environmental Impact Statement (EIS) at an IGE total of for 24 months (1 year and 4 months for project completion, with additional time for project closeout). This will allow the BLM to comply with recent Executive and Secretarial Orders and to respond to pending litigation.
4. An d t f cation of the t tutory thor ty rmitti g the th n fu l n op n co etit n:
Th u i ion s u mi d ursuant o h u r y o 41 U C 2 1 as imp men d und r h M l le Awar ched le rogra AR 8.40 - ub e o :
FAR 8.405-6(a)(1)(i)(C) In the interest of economy and efficiency, the new work is a logical follow-on to an original Federal Supply Schedule order provided that the original order was placed in accordance with the applicable Federal Supply Schedule ordering procedures. The original order or BPA must not have been previously issued under sole-source or limited-sources procedures.
upp r g io a e: The proposed revision to the 2025 RMP is a direct follow-on to prior work completed by EMPSi (Contract No. 140L0618A0014; Order No. 140L0619F0272 – competed via full and open competition under the FY18 NEPA BPA Program). The revision addresses new direction and pending litigation, specifically targeted towards energy and critical minerals. Given the targeted nature of this revision, the BLM anticipates that many existing decisions and analyses from the 2025 RMP can be carried forward, leveraging work already performed by EMPSi. The Contractor has already developed specialized tools tailored to this planning effort, including geodatabases, templates, and analytical GIS models to facilitate efficient analysis and production. Replicating these tools under a new BPA holder would require significant time and resources, resulting in unnecessary costs and delays.
T e ut o ty a d su p rting atio e (see 8.405 6(a)(1)( ) nd (b)(1) a d, f p c le, n r on of e p opo n ac or u i ue ua i ca i n o p ovi e h r ui e up y r v e. In addition to #4 above, EMPSi’s extensive experience over the past five years demonstrates a comprehensive technical understanding of the 2025 RMP, the 1988 RMP, and the specific considerations relevant to the BLM in North Dakota. This expertise also includes experience with the air quality models created between 2019 and 2024. EMPSi contributed to the development of and application of the BLM Western US Photochemical Air Quality Models for 2028 and 2032, a Cumulative Hazardous Air Pollutants Model, and a Comprehensive Emissions Inventory. EMPSi’s experience with these models, analyses, and documents is critical for ensuring the accuracy and reliability of air quality analyses in any follow-on work. Their existing technical knowledge of model assumptions, data inputs, and predictive capabilities specific to North Dakota is not something other BPA holders currently possess. This knowledge will streamline follow-on work at an efficiency for the government and allow for a more direct comparison across alternatives. As outlined in FAR 8.405-6 (a)(1)(i)(C), it is anticipated that duplicating components of the Chapter 4 Environmental Consequences Analysis and portions of the Biological Assessment would require additional time and resources, with an estimated duplicative cost of approximately $350,000.
Furthermore, the time required for contract awarded and plan revision would be expected to extend the project timeline by roughly six months. This delay would likely result in additional adverse impacts on both the state and federal government, including increased costs associated with contracting services and delays in leasing, development, and production from currently deferred leases.
EMPSi developed the Reasonably Foreseeable Development (RFD) scenario for oil and gas activities in the 2025 RMP. This RFD, like the air quality models and emission inventory, is a cornerstone tool for this ongoing planning effort. EMPSi’s intimate knowledge of the RFD’s methodology, data sources, and assumptions equips them to update it as part of this follow-on work as needed in a more efficient manner than other BPA holders. Similar to EMPSi’s experience with the existing air models and emissions inventory, their experience with the Oil and Gas RFD will streamline the process at an efficiency for the government and allow for a more direct comparison across alternatives.
5. A ete n t o by the r i g ctivity cont cti g ff c that t e o rep ents th be t v lue nsi en wi h 8.404(d) The Contracting Officer determines that the anticipated price will be fair and reasonable based on a complete analysis of the quote submitted by EMPSi in accordance with FAR 8.405-2(d). By signing the justification the Contracting Officer makes a determination that the c n Ch mpe n Adv e Rev ew nd p v i le)
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