A16_Sole_Source_Justification.pdf
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- AK-DIV OF CONSERV PLNG & PLCY-AECOM CONT
- Solicitation number
- DOIFFBO260051
About this file
This is a Single Source Justification form (FWS Form 3-0034) submitted by the U.S. Fish and Wildlife Service for a sole source acquisition under the Simplified Acquisition Threshold (SAT). The form documents the justification for awarding a contract to AECOM without competitive bidding for continued consulting services related to the Izembek Land Exchange project and associated litigation support.
AECOM has provided instrumental support to FWS since 2010 on the Izembek Land Exchange project, including preparation of environmental impact statements, subsistence analysis, and litigation support. The current contract expires March 30, 2026 and cannot be renewed. The justification cites project sensitivity, confidentiality requirements, and AECOM's 16 years of accumulated project knowledge and administrative records as reasons no other consultant can effectively perform the work. FWS determined that no other capable contractors possess the necessary historical experience and understanding of project nuances, and that onboarding alternative contractors would require significant time and effort to learn the project and administrative record. AECOM's rates are based on current GSA contract terms and estimated hours were deemed fair and reasonable by FWS. The form was recommended by Program Officer Bobbie Skibo on February 6, 2026, and approved by Contracting Officer Joshua Stuart on March 6, 2026.
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Text version
FWS Form 3-0034 (Rev. 10/2020) U.S. Fish and Wildlife Service
1. Description of Need
3. Other Capable Sources
2. Market Research Conducted
Pursuant to FAR subpart 13.106-1(b)(1)(i) and (ii), for purchases not exceeding the Simplified Acquisition Threshold (SAT), Contracting Officers may solicit from only one source if the circumstances deem only one source is reasonably available (e.g., urgency, exclusive licensing agreements, brand name, or industrial mobilization).
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.
SINGLE SOURCE JUSTIFICATION
(UNDER SAT)
JOINT ADMINISTRATIVE OPERATIONS
Acquisitions Operations
4. Barriers to Competition
5. Contractor's Qualifications
6. Determination of Fair and Reasonable Cost
7. Recommendation and Certification by Program Office
Based on the above justification, I recommend this acquisition to be conducted using sole source acquisition procedures. I hereby certify that this justification is accurate and complete to the best of my knowledge and belief.
Program / Project Officer
8. Contracting Officer Certification and Approval: Under SAT
Based on the above justification, I hereby certify and approve the use of sole source acquisition procedures under FAR Part 13 for this purchase.
Contracting Officer
| Text3: Although other capable contractors exist, AECOM is the only company with the historical and recent project experience necessary to carry out this work. |
| Text2: Due to the level of sensitivity and necessary confidentiality associated to this project, no other consultant has the experience, knowledge of the project or the records and documents that could be requested during litigation and coordination and implementation of the 2025 Land Exchange. FWS did not contact other consultants or do any other market research because the work requires the consultant who has been assisting the project and tracking the project for the last 16 years, and especially the last 2 to 3 years when AECOM prepared the Draft Supplemental EIS and assisted with the 2025 Land Exchange, ANILCA Section 810 Subsistence Analysis and ESA consultations. |
| Text1: AECOM has been instrumentally involved as an extension of the FWS staff since 2010 on the Izembek Land Exchange project. AECOM prepared the 2013 Final EIS, the 2024 Draft Supplemental EIS, and assisted FWS with the 2025 Land Exchange, ANILCA Section 810 Subsistence Analysis in 2024 and 2025, and ESA consultations. The contract for the current work expires on March 30, 2026, and cannot be renewed. |
As of March 30, 2026, FWS will still be in active litigation for three lawsuits and will be implementing the 2025 Land Exchange for Izembek National Wildlife Refuge. To support the FWS throughout the next phases of the project, we are seeking this single source follow on contract with AECOM due to their highly valued institutional and corporate knowledge of the 2025 Land Exchange, the administrative record, the documents that supported the land exchange, and the history of the project. AECOM would add the necessary capacity with: 1. responding to Freedom of Information Act requests, 2. compiling documents from the Administrative Record and other historical files, and 3. ongoing facilitation, coordination and implementation of the 2025 Land Exchange including writer/editor support as directed by FWS staff (e.g., document preparation, technical editing, and 508 compliance).
Preserving institutional and corporate knowledge is vital for maintaining continuity with project stakeholders and fulfilling the direction provided in Executive Order 14153 and Secretarial Order 3422 titled “Unleashing Alaska’s Extraordinary Resource Potential,” which directs that “(a) The heads of all executive departments and agencies, including but not limited to the Secretary of the Interior;…shall exercise all lawful authority and discretion available to them and take all necessary steps to…: (xi) facilitate the expedited development of a road corridor between the community of King Cove and the all-weather airport located in Cold Bay.”
| Text4: FWS issued a competitive request for proposals in 2023 to GSA contract holders. AECOM was the successful bidder. AECOM has maintained a close working relationship with FWS on the land exchange since then. As a result, no other contractor would provide the level of knowledge and support that AECOM can. Other contractors might be willing to accept the work, but it would take them many months and much effort to learn the project and administrative record and would cause more work for FWS staff to onboard instead of providing support. | |
| Text6: AECOM’s rates and estimated hours are fair and reasonable. AECOM is proposing current GSA rates and FWS has reviewed the estimated hours and found them to be a reasonable estimate of the hours required to provide the ongoing support. | |
| 2026-02-06T14:36:35-0900 | |
| BOBBIE SKIBO |
| 2026-03-06T11:40:14-0700 | |
| JOSHUA STUART |
Text5: As stated above, AECOM is the most qualified firm to perform the work and has an outstanding track record. AECOM is currently providing the support to FWS and is most familiar with the project history and administrative record.
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