B.04.21 DLA FIS Consolidation Memo_DDRT_DDWG_20220919 CF Signed.pdf

DEPARTMENT OF THE ARMY

U.S. ARMY CORPS OF ENGINEERS, CHARLESTON DISTRICT

DETERMINATION AND FINDINGS REQUEST FOR CONSOLIDATION

W912HP22R6001

SINGLE AWARD TASK ORDER CONTRACTS

FOR FACILITY SUPPORT SERVICES

DEFENSE LOGISTICS AGENCY

Federal Acquisition Regulation (FAR) 2.101 defines consolidation or consolidated requirement as a solicitation for a single contract, a multiple-award contract, a task order or a delivery order to satisfy - (i) two (2) or more requirements of the Federal agency for supplies or services that have been provided to or performed for the Federal agency under two (2) or more separate contracts, each of which was lower in cost than the total cost of the contract for which offers are solicited, or (ii) requirements of the Federal agency for construction projects to be performed at two or more discrete sites. FAR 7- 107-2(a) requires that consolidation of requirements with an estimated total dollar value exceeding $2 million shall be supported by a written determination that consolidation is necessary and justified in accordance with 15 U.S.C. § 657q.

I have reviewed this requirement and associated market research and determined in accordance with 15 U.S.C. § 657q and FAR 7.107-2 that consolidation is both necessary and justified. This approval is made in accordance with the approval thresholds set forth in Army Federal Acquisition Regulation Supplement (AFARS) 5107.107-2, Consolidation. My review resulted in the following findings:

FINDINGS

1. Introduction:

The U.S. Army Corps of Engineers (USACE), Charleston District, proposes to solicit and award Firm Fixed Price (FFP) Single Award Task Order Contracts for recurring facility support services and for additional non-recurring services in the amount of $15M each at two (2) sites. The planned duration for these contracts is a total of five

(5) years, consisting of a one (1) year base ordering period plus four (4) options for ordering periods of one (1) year each. The FFP contracts will meet facility support services using the North American Industry Classification System (NAICS) code 561210, Facilities Support Services, in support of Defense Logistics Agency (DLA) facilities through one distinct contract at each of the two following locations: Red River, Texas and Warner Robins, Georgia. This procurement constitutes consolidation of requirements per FAR 7.107-2 in that a single solicitation will be used to obtain offers for a single contract to satisfy two (2) or more separate requirements for services that have previously been provided and performed under two or more separate contracts and involves services at two or more discrete sites. The Charleston District has conducted an acquisition history analysis and market research that demonstrates consolidation of requirements in this procurement is both necessary and justified.

2. Description of Procurement Action:

a. Project Description: The Charleston District presently provides facility support services for Red River, TX and Warner Robins, GA. The Charleston District is currently using independent GSA contracts for services at the two existing sites. These contracts have led to added costs and inefficiencies when no single contractor is operating as the lead for all facility support services at a DLA site. USACE intends to advertise one (1) solicitation and award two (2) regional Single Award Task Order Contracts (SATOCs) as shown below. This course of action is the most effective, efficient, and least costly means of meeting its mission objectives.

Southeast Central

Warner Robins AFB, GA Red River, TX

The purpose of this acquisition is to establish a procurement tool that will enable USACE to provide highly responsive support necessary for DLA to meet its mission needs and improve overall operations for the two sites. The contract will provide performance-based facility support services and minor repair services. Facility support services encompass an array of services, including, but not limited to, preventative maintenance, system inspections, testing and certification, f ire protect ion, electrical , paving, plumbing, and HVAC. Repair work via service calls/IDIQ task orders will include roof repairs, refinishing of wall surfaces, repairing and replacement of heating and cooling systems, replacing tile and carpeting, and similar types of work.

b. Acquisition Strategy/Procurement Summary: To meet the needs of DLA, the District intends to award two (2) regional Firm Fixed Price (FFP) SATOCs for recurring facility support services. The SATOCs are $15M each and will have a total ordering period of five (5) years: (1) base year and four (4) one-year options. Task orders issued under these contracts will be Firm Fixed Price. The period of performance for individual task orders may extend beyond the life of the base contract, but in no case will a task order be placed once the ordering period of the base has expired. The contractor shall perform the work in accordance with the scope and delivery schedule negotiated per each task order. Market Research was conducted through a Sources Sought that was advertised, and through additional research. Through this research it was determined that this acquisition would be 100% set-aside for Small Businesses.

This acquisition approach supports the Small Business Administration’s (SBA) Small Business Program and is in the best interest of the Government with respect to timeliness, oversight, and administrative costs.

c. Applicability of Consolidation: As stated above, Sec 1671 of the FY13 NDAA amended the definition of consolidation as set forth in Sec 44 of the Small Business Act, 15 U.S.C. § 657q. In accordance with the statute, “consolidation of contract requirements, with respect to contract requirements of a Federal agency means a use of a solicitation to obtain offers for a single contract or a multiple award contract - (A) to satisfy 2 or more requirements of the Federal agency for goods or services that have been provided to or performed for the Federal agency under 2 or more separate contracts lower in cost than the total cost of the contract for which the offers are solicited;

or (B) to satisfy requirements of the Federal agency for construction projects to be performed at 2 or more discrete sites. Consolidation of requirements with an estimated total value exceeding $2M must be justified (DoD Class Deviation 2013-O0021, Contract Consolidation, dated 1 October 2013). Consolidation applies to this procurement because SATOCs will be used to provide a variety of facility support services that have previously been provided and performed under 2 or more separate contracts.

d. Requirements Being Consolidated: The requirements being consolidated for the proposed SATOCs include all supervision, labor, transportation, tools, materials, supplies, vehicles, and equipment necessary to perform facility support for the following services at DLA facilities located within the continental United States.

Examples of this work include, but are not limited to, the following:

Facilities Investment (SRM- sustainment, restoration, and modernization) Custodial Pest Control Refuse Collection and Recycling Grounds Maintenance

e. Procurement History: On 16 October 2009, the DLA and SAC signed a Program Management Plan (PgMP) that would allow SAC to be the primary District to provide the services needed to meet its continuous facility maintenance program needs. DLA then approached SAC to provide a facilities maintenance performance-based type contract to meet the needs of the DLA site at Warner Robins, Georgia (DDWG). The services were being provided using in-house and base support and by using Government Purchase Cards. In FY 2011, Charleston District awarded a facilities maintenance service contract to Native Energy and Technology, Inc. (W912HP-11-D-0003). This contract was an 8(a) ANC sole source with an award amount of $16,170,707.00. The awarded contract was scheduled to expire on 7 April 2016, prior to which the FAR Clause 52.217-8, Option to Extend Services, was exercised to extend the contract for an additional 6 months at a cost of $1,370,357.08. This action extended the expiration date for the contract to 7 October 2016.

Currently DLA is provided services by SAC through two different contracts, each covering a single site. The Red River, Texas contract covers five years and roughly $2.4M annually for a total of $12M, and Warner Robins, Georgia, contract is a five-year duration and provides for $2.2M annually for a total of $11M.

f. Rationale for Consolidation:

(1) Consolidation is a more desired approach to meet DLA’s mission objectives, increase efficiency, streamline processes, ensure operational continuity, decrease costs and provide faster response times. Using two (2) SATOCs in accordance with FAR 19.502-2, that consolidate the requirements for facility investment, custodial, pest control, refuse collection and recycling, and grounds maintenance, will provide an acquisition tool to enable these services to be cost effectively and efficiently provided. FAR Subpart 16.5 – Indefinite Delivery Contracts, establishes a preference for making multiple awards of indefinite- quantity contracts. The use of awarding multiple award task order contracts combines multiple requirements into one solicitation with multiple awards to several contracts. Use of an ID/IQ contract is appropriate in accordance with FAR 16.501-2(a), when exact times and/or exact quantities of future deliveries are not known at the time of award. FAR 16.504(b) indicates that the Contracting Officer may use an indefinite-quantity contract when the Government cannot predetermine, above a specified minimum, the precise quantities of supplies and services that the Government will require during the contract period, and it is inadvisable for the Government to commit itself for more than a minimum quantity. The Contracting Officer should use an indefinite-quantity only when a recurring need is anticipated. It is anticipated that the proposed SATOCs will be used to fulfill customer requirements for facility support services for two (2) locations. Consolidating these requirements into two

(2) site SATOCs is advantageous to the Government, and using the preferred method of awarding a MATOC is not advisable for the following reasons:

• The use of a MATOC would not provide a lesser degree of consolidation, as all projected requirements would still be consolidated under the MATOC.

• Consolidation of mission objectives to provide preventive maintenance, service call, ID/IQ task order and municipal services is based on the premise that physical, operational maintenance of each facility is the primary purpose for these contracts, and provision of municipal services is secondary. Separating these requirements into individual regional or site-specific contracts does not provide a betterment over the previous contract structure that was in place.

• The decision to focus on two (2) SATOCs is based on the relative proximity of the sites in each region, allowing the Contractor the opportunity to be able to reasonably access each site within one workday.

• Combining the various requirements into the site contracts enables more efficient and cost-effective management, control and direct oversight of the contractors and services being performed.

• Limiting the number of awarded contracts enables the local facility staff to have more effective control over the number of contractors accessing the facility, which minimizes potential security threats.

• Limiting the number of prime contractors enables uniformity and conformity with executing contract requirements consistently across all regions.

• Creating a large pool of smaller contracts does not incentivize proven http://farsite.hill.af.mil/reghtml/regs/far2afmcfars/fardfars/far/16.htm contractors to respond to the acquisitions and increases the risk of quality performance, as evidenced by the procurement and performance history of previous acquisitions for these services.

(2) Consolidation also meets the Quantitative benefits as required in FAR 7.107-

2 Consolidation. This savings is provided in the Cost Savings Tables 1 through Table 3 found on Pages 9 and 10 of this Consolidation Memo.

3. Applicable Statutes/Regulations:

15 U.S.C. § 657q, FAR 7.107-2, and AFARS 5107.170-3.

4. Results of Market Research:

To determine market interest and capability, and the effects the proposed consolidation might have on competition, the District used various methods to gather the necessary market information: 1) A query of the Dynamic Small Business search engine; 2) A Sources Sought posted to SAM.gov; and 3) Historical data. A detailed discussion of these efforts and the information gathered is provided in paragraphs a and b, below.

Based on the results of this collective effort, the market research clearly demonstrates that the proposed consolidation has no adverse impact on competition and does not present an additional cost risk to interested parties. Based on the results of the market research, it is determined that adequate competition is feasible and probable. Market research also showed that there would be no adverse effect to competition among small businesses. Market research indicated that there are capable companies willing and able to meet the requirements.

a. Dynamic Small Business Search. On 24 August 2022, a query of the

Dynamic Small Business search engine was conducted using NAICS 561210. Over one thousand (1000) companies were found, but when a keyword search was done with “Preventative Maintenance,” it brought the results down to seven (7) contractors.

b. Sources Sought: The sources sought was posted on SAM.gov on 7 July 2022 with responses due 27 July 2022. The purpose of this sources sought was to determine the interest and capability of potential qualified small businesses, to include 8(a), HUBZone, Woman-Owned, Service-Disabled Veteran Owned, and other small businesses, under NAICS 561210. Respondents were required to provide information demonstrating their ability to perform the specified facility support services, and if they would be able to provide those services at the 3 different DLA locations. 16 contractors responded to the sources sought by the date requested. All respondents were small businesses, two (2) of which were Women Owned Businesses. There were six (6) respondents that were also considered Service-Disabled Veteran Owned Small Businesses (SDVOSB), and three (3) that were considered to be 8(a) Small Businesses. Of these 12, one (1) was determined technically unacceptable due to its reliance on another company’s experience and resources. There were two (2) companies that were considered technically unacceptable due to their inability to demonstrate an ability to perform work at multiple sites. Of the remaining nine (9) companies, all demonstrated an ability to provide services simultaneously at multiple locations.

5. Alternative Contracting Approaches Considered and Rationale for Rejection:

In concluding that the award of (2) two small business set aside SATOC contracts is the best solution to fulfill DLA mission requirements for facility support services, the Charleston District analyzed whether there were alternative contracting approaches that would involve a lesser degree of consolidation or no consolidation at all.

a. Alternative 1, Two (2) Single Award Task Order Contract (SATOC)

Contracts: A SATOC provides an acquisition vehicle that allows the Government to complete numerous minor repair, and maintenance projects with a single, competitively awarded contract at a minimum cost. The benefits of the SATOC approach substantially exceed the disadvantages of consolidation for the reasons outlined below. In addition to minimizing acquisition time, performance and schedule risks, cost risks are minimized through open and thorough discussions of the description of work for each task order.

(1) Quality: A SATOC allows a single prime contract to facilitate a reduction in efforts related to quality assurance and contract administration for each respective region.

One prime contractor performing quality control across its entire enterprise has shown to result in an overall improved quality of service.

(2) Acquisition Cycle: The use of a SATOC will streamline the process by shortening the procurement lead-time by eliminating the pre-award activities required to solicit stand-alone requirements. Furthermore, past experience with this customer indicates they routinely have a need for small projects requiring repairs. The service call aspect this SATOC offers the customer will be quite valuable in reducing the acquisition cycle and allow a quicker response to accommodate the needs of the customer. A SATOC will capture most administrative requirements as part of the base contract without reproduction in each task order and reduce administrative cost in the monthly billing cycle. Also, at award, Contract Line Item (CLIN) prices are binding for the life of the contract with no further negotiation required, allowing for a streamlined process to execute work. As compared to awarding a stand-alone contract “C” type contract which on average could take up to 6 months, it is estimated that placing task orders under a SATOC reduces acquisition time from 6 months to 30 days on average for each project.

This time reduction is crucial because the SATOC contracts will be providing public work type functions meaning a lot of work is not known in advance (ex. storm damage repair, chiller replacement, boiler repairs, etc.). The ability to quickly repair critical items to keep a facility usable to support DLA distribution tempo is vital along with a single contractor performing PM functions in addition to repair orders.

(3) Terms and Conditions: Other than request for proposal (RFP) requirements and proposal submissions, there is essentially no difference between the contractual terms and conditions for construction or repair project executed under a SATOC or a “C” contract; however, in accordance with FAR 16.505 (10)(i), SATOC task orders, are not subject to Agency or Government Accountability Office (GAO) protests under $10M. On the other hand, all “C” contracts, regardless of value, are subject to protest for any number of reasons. “C” type contracts may put procurement and award schedules at greater risk of delay than task orders under SATOCs.

(4) Cost: A SATOC offers significant savings opportunities in terms of administrative costs. A comparison of the estimated administrative costs savings is presented in Table 1 below.

b. Alternative 2, Multiple Award Task Order Contract (MATOC): The use of a

MATOC combines multiple requirements into one solicitation with multiple awards to several Contractors. In evaluating this alternative, the District determined that using a MATOC would not provide a lesser degree of consolidation, as all projected requirements would still be consolidated under the MATOC.

(1) Quality: A MATOC would facilitate a more competitive environment throughout the life of the contract via task order competitions for individual requirements.

The ability to work with a single contractor directly, as would be the case with a SATOC, provides significant advantages. For example, multiple contractors on site results in increased likelihood of conflicts between companies as to the quality of work completed by the other. Multiple contractors also create repetitive learning curves, and the potential for access control issues in secure locations. A single contractor onsite will streamline the QA process and warranty concerns.

(2) Acquisition Cycle: The majority of these requirements typically do not develop for execution purposes until the last quarter of the fiscal year, some as late as September. A lead time of approximately 90 days is needed to successfully execute a task order under a MATOC; for a SATOC it is 30 days or less, dependent upon the circumstances. Therefore, use of a MATOC would place execution of a significant portion of anticipated contract work at risk of failure, the end result of which is a loss of funds.

(3) Terms and Conditions: This is an unacceptable risk given that a MATOC does not provide for a lesser degree of consolidation.

(4) Costs: Additional resources and greater oversight by the Government is also necessary when dealing with multiple contractors versus a single contractor. This translates into a significant increase in time and costs for which there are no discernible benefits. The small dollar value of the proposed procurement also makes the use of a MATOC impractical. Based on the market research, the District is assured adequate competition exists to award a single contract valued at $20M; however, the same cannot be said of a MATOC where that same $20M in capacity must be shared by multiple contractors.

c. Alternative 3, Multiple Stand-Alone ‘C’ and ‘P’ Type Contracts: The District also considered the award of multiple stand-alone contracts. While this approach varies little to what the customer is currently experiencing, it does provide a lesser degree of consolidation, or no consolidation at all if individual contracts are awarded for single requirements. The benefits of the SATOC approach substantially exceed the disadvantages of consolidation for the reasons outlined below.

(1) Quality: As already noted under Alternative 1, the ability to work with a single contractor directly on a SATOC tool provides significant advantages in comparison to multiple stand-alone contracts. While there is some assurance of successful performance through competing each requirement, this benefit may be offset if the Charleston District is frequently awarding contracts to new contractors and cannot establish long-term relationships with contractors performing construction under the SATOC.

(2) Acquisition Cycle: Stand-alone contracts are administratively burdensome in that it adds days to the procurement process. Historically on our Preventative Maintenance contracts for DLA, a task order can be executed in less than 30 days.

Depending on complexity, a stand-alone contract or purchase order, it takes anywhere from an average of 45 – 150 days to award.

(3) Terms and Conditions: Other than request for proposal (RFP) requirements and proposal submissions, there is essentially no difference between the contractual terms and conditions for construction or repair project executed under a SATOC or a “C” contract.

(4) Cost: Additional resources and greater oversight by the Government is also necessary when dealing with multiple contractors versus a single contractor.

This translates into a significant increase in time and costs for which there are no discernible benefits.

d. Cost Savings: Per 15 U.S.C. § 657q(c)(2)(B), “savings in administrative or personnel costs alone do not constitute a sufficient justification for a consolidation of contract requirements” unless the total amount of the cost savings is expected to be substantial in relation to the total cost of the procurement. In this case, cost savings are substantial in relation to the total cost of the procurement. Table 1 shows the pre-award cost savings between awarding four consolidated contracts vs awarding contracts for individual services (non-consolidation). Table 2 shows the post-award cost savings between awarding four consolidated contracts vs awarding contracts for individual services (non-consolidation).

Table 3 sums Tables 1 and 2 together to show total cost savings.

Table 1- Pre-Award Cost Savings, Consolidation vs Non-consolidation

SAC In-House Costs of Approach

Consolidation VS Non-Consolidation

Stand Up FPP/SATOC (per contract)

Award from “C” or “P” type RFP

Procurement Action & Associated In-house Labor Effort

Funds Reqd

Procurement Action & Associated In-house Labor Effort

Funds Reqd

CECT-SAC Labor Funds $26,000 CECT-SAC Labor Funds $5,000

CESAC-PM/CESAC-EN Labor Funds

$39,000 CESAC-PM/CESAC-EN Labor Funds

$15,000

SSEB Labor Funds (Note 1) $26,000 SSEB Labor Funds $7,000

Other (more if discussions req’d) $9,600 Other (more if discussions req’d) $5,000 http://uscode.house.gov/view.xhtml?req=granuleid%3AUSC-prelim-title15-section657q&amp%3Bamp%3Bamp%3Bnum=0&amp%3Bamp%3Bamp%3Bedition=prelim

Other (more if debriefings are req’d) $6,000 Other (more if debriefings are req’d) $6,000

Subtotal $106,600 Subtotal (per RFP) $38,000

IDIQ Task Order RFP Estimated (note 3) 154

CECT-SAC Labor Funds $2,000 Program, Total $5,852,000

CESAC-PM/CESAC-EN Labor Funds

$3,000

Subtotal (per TO) $5,000

TO’s Estimate (Note 2) 75

Subtotal $375,000

Total Cost of Approach for One regional Contract

$481,600

Program

Regional Contracts (#) 2

Program, Total $963,200

Note 1: Assume 3 board members for 1 week plus 1 board member for additional 2 week Note 2: Assume 15 task orders per year for 5 years and each task order performs work at 2 different sites Note 3: Assume one maintenance and one facility service contracts per site (4 total) plus 225 RFP’s for repair work

Table 2- Post-Award Cost Savings, Consolidation vs Non-consolidation

Action Funds Reqd

Action Funds Reqd

Invoicing (per contract) Invoicing

CESAC-PM/CESAC-EN Labor Funds $200 CESAC-PM/CESAC-EN Labor Funds $200

TO’s Estimate (Note 1) 85 TO’s Estimate (Note 3) 410

Subtotal $17,000 Subtotal $82,000

TO QA TO QA

CESAC-PM/CESAC-EN Labor Funds $3,250 CESAC-PM/CESAC-EN Labor Funds $3,250

QA Estimate (Note 2) 50.5 QA Estimate (Note 4) 278

Subtotal $17,875 Subtotal $1,072,500

Total Cost of Approach for One regional Contract

$165,825 Program, Total $903,582

Program

Regional Contracts (#) 2

Program, Total $331,650

Note 1: 15 TO’s for FFP plus 2 TO’s for IDIQ per year Note 2: One visit per quarter for FFP and 50% of repair Note 3: 4 invoices/month (48/year or 240 per 5 years) for FFP plus 270 (17 TO x 5 yrs x 2 sites) invoices for repairs Note 4: One visit per quarter per site (2) plus 100% of repair

Table 3- Summary of Cost Savings, Consolidation vs Non-consolidation

Pre-Award Cost Savings $963,200 Pre-Award Cost Savings $5,852,000

Post-Award Cost Savings $331,650 Post-Award Cost Savings $903,582

Total $1,294,850 Total $6,755,582

Consolidation of the requirements will result in substantial benefits estimated at 25% of the total contract value of $30M, with approximately $6.7M in savings, as demonstrated in Table 3 as the difference between the estimated non-consolidation and estimated consolidation costs of approach. The benefits exceed the requirements per FAR 7.107-2(d)(i) of 10% of the estimated contract value, for contracts below $94 million. For each of the 2 contracts, the average cost savings is estimated to be $3.3M. The average contract value for each contract is $15M, 10% of which is $1,500,000, showing that the cost savings requirement as defined by the FAR for each contract is exceeded.

Although the three (3) alternative contract types listed above clearly possess their respective advantages, this benefit analysis undoubtedly demonstrates that the benefits from consolidating the types of services to be included in the RFP for the subject requirement, via the procurement of a SATOC, substantially exceed the benefits of each of the alternative strategies. A summary of the costs/benefits of each of the alternatives is presented below in Table 4.

Table 4 – Alternatives Analysis Summary

Alternative1 Alternatives 2/3

3 SATOC

Awards

Multiple Award Stand Alone

Quality Average to High Low

Acquisition Cycle * Base Contract – 140 Days Task orders - 30 days or less

90 days or less

Terms and Conditions No Difference No Difference

Administrative Cost Lowest Highest

6. Bundling Analysis:

a. Definition of Bundling: FAR 2.101 defines bundling as consolidating two or more requirements for supplies or services, previously provided or performed under separate smaller contracts, into a solicitation for a single contract that is likely to be unsuitable for award to a small business concern due to: (i) The diversity, size, or specialized nature of the elements of the performance specified; (ii) The aggregate dollar value of the anticipated award; (iii) The geographical dispersion of the contract performance sites: or (iv) Any combination of the factors described in paragraphs (i) through (iii) of this definition.

b. Applicability of FAR Bundling Definition: Although by FAR definition this acquisition does meet the definition of bundling, market research and small business interest has shown that these requirements can be awarded to a single contractor to perform. As a result, these procurements will be solicited as a 100% Small Business Set-Aside.

c. Definition of the Competition in Contracting Act (CICA) Bundling Principle:

This principle, as developed by the Government Accountability Office (GAO) case law, focuses on whether the combined requirement (new, old, or otherwise) restricts competition, and whether the agency is consolidating or bundling a new requirement unnecessarily. In order to justify CICA Bundling the agency must show "a reasonable basis for why the bundling is necessary to meet the agency need." (Vantex Serv., Inc., B-290415, Aug 8, 2002 and Outdoor Venture Corp., B-299675;B- 299676, Jul 19, 2007.)

d. Applicability of CICA Bundling Principle: In this procurement, the CICA Bundling Principle is applicable, but necessary to meet the agency’s need to deliver its customer’s mission objectives, increase efficiency, streamline processes, ensure operational continuity, decrease costs and provide faster response times. The CICA requires solicitations to provide for full and open competition except where restrictions on competition are necessary to satisfy the procuring agency's needs. In such a case, restrictions on competition are allowed but only to the extent necessary to satisfy the agency's needs. Bundled procurements combine separate requirements into one contract; thus, they have the potential to restrict competition, thus being in violation of CICA by excluding firms that can provide only a portion of the bundled requirement.

However, substantial cost savings achieved through the reduction of duplicative efforts and operational efficiency can be a reasonable basis for restricting competition where requirements are bundled. Here, using two (2) SATOCs will consolidate the requirements for facility investment, custodial, pest control, refuse collection and recycling, grounds maintenance, and pavement clearance (snow removal), and will provide an acquisition tool to enable these services to be procured more cost effectively, and services more efficiently provided.

7. Considerations, facts, and reasoning supporting the determination: All facts, considerations and rationales have been covered previously in the findings. The DD2579 has been signed by the Contracting Officer and Deputy for Small Business.

As demonstrated by the signatures below, the Contracting Officer and SAC Deputy for Small Business concur that consolidation of this requirement is both necessary and justified.

8. Summary: Based on the market research and analysis of the three (3) alternatives provided herein supports the conclusion that consolidation of the DLA Facilities Support Services is justified and necessary based on acquisition regulation and guidance. The SATOC acquisition approach will enhance the contracting tools available to DLA and allow maximum flexibility that provides a means to meet its mission. The strategy of soliciting these SATOCs as total Small Business Set-Asides, strikes a balance of maximizing the opportunity to acquire the services needed, while providing optimum small business opportunities.

The following signatures indicate concurrence with the contents of this document.

Caleb Brewer, Project Manager

Brian Nutter, Assistant District Counsel

Tonya Willis, District/Center Deputy for Small Business Programs

Charlene Figgins, Chief of Contracting