A2 RFO FAR 12.102(b)-Sole Source-Final_redacted.pdf

Local Control Number: W912R1-26-0009

NGB Control Number: 26-010

(Source Selection Information - See RFO FAR 2.101 and 3.104-4)

1 JUN 2023

Justification Review Document For Sole Source Revolutionary Federal Acquisition Regulation (FAR)

Overhaul (RFO) Part 12.102(b) Program/Equipment: District of Columbia National Guard (DCNG) Washington Metro Area Transit Authority (WMATA) SmarTrip Card & Commuter Benefits Program

Authority: 41 United States Code 1901 as implemented in RFO FAR 12.102(b), Restricting competition Table 12-1 for restricting competition under the authority of the simplified procedures.

Amount:

Prepared by:

Typed Name: Phone:

Title: Contract Specialist Date: 12 August 2026

E-mail:

Contracting Officer:

Typed Name: Phone:

Date Reviewed: 13 August 2026 E-Mail:

Technical Representative:

Title: J4 Plans Officer Date Reviewed: 13 August 2026

2 JUN 2023

Reviews

I have reviewed this justification and find it adequate to support other than full and open competition.

Legal Counsel

Signature: _

3 JUN 2023

Sole Source Justification and Approval

Under RFO FAR 12.102(b)

1. Contracting Activity: USPFO-DC-C

2. Description of Action: New firm-fixed-price commercial contract awarded on a sole-source basis to the Washington Metropolitan Area Transit Authority (WMATA) to provide public passenger transportation services in support of the District of Columbia National Guard (DCNG).

3. Description of Supplies/Services: The DCNG requires a comprehensive, turn-key public transit program to support approximately 2,000 personnel executing the official, localized Make DC Safe and Beautiful (MCDSAB) mission, as well as transit to and from the Logistics Support Area (LSA).

The Contractor shall provide reusable, contactless physical transit fare cards (SmarTrip) embedded with the flat-rate unlimited "Public Service Pass" allowing unlimited, high-frequency access to both the Metrorail and Metrobus networks. The cards must be physically secure and restricted from digitization onto personal mobile wallets. The contract includes access to an online administrative portal (SmartBenefits) capable of activating/deactivating cards within 24 hours, and a negotiated 100% refund credit mechanism for completely unused ("untapped") passes during a billing cycle.

Period of Performance: 21 September 2026 31 January 2029 (consisting of a 12-month Base Period and two sequential option periods to keep service active through the end of the mission).

o Base Period: 21 September 2026 20 September 2027 ( , inclusive of card fees) o Option Period 1: 21 September 2027 20 September 2028 o Option Period 2: 21 September 2028 20 January 2029 ( ) Total Estimated Value:

These integrated requirements a turn-key program providing unlimited access to both the Metrorail and Metrobus networks, physical-only cards, and an established administrative portal are proprietary to WMATA and cannot be replicated by any other vendor.

4. Authority Cited: 41 United States Code 1901 as implemented in RFO FAR 12.102(b), Restricting competition Table 12-1 for restricting competition under the authority of the simplified procedures.

5. Reason for Authority Cited: The cited authority, Title 41 U.S.C. 1901 as implemented in RFO FAR 12.102(b), is utilized because this is a commercial service requirement that will be sourced using simplified acquisition procedures.

4 JUN 2023

The Washington Metropolitan Area Transit Authority (WMATA) is the sole owner and operator of the integrated public transit network (Metrorail and Metrobus) within the National Capital Region. As established by interstate compact, no other commercial entity has the legal authority or physical infrastructure to provide the required services.

Therefore, WMATA is the only responsible source capable of meeting the government's needs.

The standard federal mass transit solution, the Mass Transit Benefit Program (MTBP) administered by DOT TRANServe, was evaluated but is legally restricted under 5 U.S.C. § 7905 to home-to-work commuting. MTBP cannot be authorized for operational, mission-based transit. Without a consolidated contract with WMATA, the DCNG would be forced to utilize commercial vehicle rentals or charter buses. These alternatives are logistically impractical for decentralized, 24/7 localized movements and represent a significant premium in taxpayer cost.

Furthermore, procuring these services directly via a FAR Part 12 contract allows the Government to enforce a unique administrative "untapped card" credit mechanism. This mechanism guarantees a 100% credit refund for any card completely unutilized in a billing cycle, preventing the waste of government funds common with traditional stored-value transit cards. Consequently, WMATA is the only responsible source capable of providing the integrated public transit network access required.

6. Efforts to Obtain Competition: In accordance with RFO FAR 5.201, a Notice of Intent to Sole Source will be posted to the Government Point of Entry (SAM.gov). Any capability statements received in response to the notice will be evaluated by the Contracting Officer; however, because WMATA maintains a natural monopoly over public transit infrastructure in the NCR, competition is not legally or logistically feasible.

7. Actions to Increase Competition: Market research confirmed that WMATA is the only source for integrated public transit in the NCR. While a Notice of Intent to Sole Source will be posted to SAM.gov, it is not anticipated that any other source will be able to submit a capability statement that meets the government's requirements, as no other vendor possesses the necessary infrastructure or legal authority.

8. Market Research: Market research was conducted in August 2026 by the J4 Plans Officer. The research evaluated alternative commercial transportation models, including corporate rideshare portals (e.g., Uber for Business, Lyft Pass) and commercial charter shuttle operators (e.g., Reston Limousine). Charter buses were excluded due to static routing limitations which cannot accommodate decentralized individual movements.

Rideshares were excluded because their variable, on-demand surge pricing is cost-prohibitive, with projected monthly costs exceeding per user compared to WMATA's flat-rate pass.

Additionally, a search of the Electronic Document Access (EDA) database was conducted under CAGE code 021F7. Multiple historical awards for direct commercial

6 JUN 2023

13. Contracting Officer Certification:

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

Signature:

Typed Name: Title: Contracting Officer

Approval

Based on the foregoing justification, I hereby approve the procurement of the WMATA SmarTrip Card & Commuter Benefits Program being procured and total dollar value of on an other than full and open competition basis pursuant to the authority of 41 U.S.C. 1901 as implemented by Revolutionary FAR Overhaul 12.102(b), Restricting competition Table 12-1, subject to availability of funds, and provided that the services and property herein described have otherwise been authorized for acquisition.

Signature: _

Typed Name: Title: Chief of the Contracting Office