B.04.Consolidation_Determination_W912EE26BA003.pdf

CUI

Department of the Army U.S. Army Corps of Engineers, Vicksburg District

Determination and Findings for Consolidation

Lease of One Cutterhead, Hydraulic Pipeline Dredge (Not Less than 24-Inch Diameter), Fully Operated with Attendant Plant and Personnel, with a Draft Not to Exceed 9 Feet, for Construction and Maintenance Dredging within the Vicksburg District – MS River Harbors

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 or more requirements of the Federal agency for supplies or services that have been provided to or performed for the Federal agency under two or more separate contracts, each of which was lower in cost than the total cost of the contract for which the 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 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 of this requirement is both necessary and justified. This approval is made in accordance with the approval thresholds set forth in Army Federal Acquisition Regulation Supplement (AFARS) 5107.170-3, “Consolidation of Contract Requirements.” My review resulted in the following findings:

Rationale

1. Consolidation may provide substantial benefits to the Government. However, because of the potential impact on small business participation, before conducting an acquisition that is a consolidation of requirements with an estimated total dollar value exceeding $2 million, a written determination shall be made that the consolidation is necessary and justified in accordance with 15 U.S.C. § 657q, after ensuring that -

a. Market research has been conducted;

b. Any alternative contracting approaches that would involve a lesser degree of consolidation have been identified;

c. The determination is coordinated with the agency's Office of Small Disadvantaged Business Utilization or the Office of Small Business Programs;

d. Any negative impact by the acquisition strategy on contracting with small business concerns has been identified; and

e. Steps are taken to include small business concerns in the acquisition strategy.

FINDINGS

2. Introduction: The U.S. Army Corps of Engineers (USACE), Vicksburg District (MVK), plans to consolidate requirements for construction and maintenance dredging at multiple discrete sites on the Mississippi River, Red River, and Ouachita-Black Rivers. This procurement constitutes a consolidation of requirements per 15 U.S.C. § 657q(a)(2)(B) in that work performed under the proposed contract will involve construction at two or more discrete sites. MVK has conducted analysis and market research that demonstrates consolidation of requirements in this procurement is both necessary and justified.

3. Description of the Procurement Action:

a. Project Description: The work consists of furnishing, delivering, and operating one (1) cutterhead, hydraulic pipeline dredge (not less than 24-inch diameter), fully operated with attendant plant and personnel with a draft not to exceed 9 feet for construction and maintenance dredging within the Vicksburg District or other districts within the Mississippi Valley Division.

This procurement will meet construction and maintenance dredging requirements under North American Industry Classification System (NAICS) code 237990, Other Heavy and Civil Engineering Construction, Dredging and Surface Cleanup Activities, with a size standard of $37M. The construction period will not exceed 365 calendar days.

b. Acquisition Strategy/Procurement Summary: The procurement will be advertised as unrestricted with the intent to award one (1) Firm Fixed-Price (FFP) contract. The estimated value of this procurement is $12,000,000. MVK has historically utilized both stand-alone contracts and Multiple Award Task Order Contracts (MATOCs) for similar requirements to successfully execute projects on tight schedules at reasonable costs. No MATOC is available for the award of any dredging task orders, so the use of a FFP contract is in the best interest of the Government with respect to timeliness, oversight, and administrative costs.

c. Procurement Taxonomy and Small Business Impact: This procurement falls under NAICS Code 237990 – Other Heavy and Civil Engineering Construction; Dredging and Surface Cleanup Activities, with a size standard of $37M. The Product Service Code (PSC) for this acquisition is Z1KF – Maintenance of Dredging Facilities. The impact of consolidating these requirements on small business is expected to be minimal. From past acquisition history to include FY25, dredging contractors qualified to satisfy these requirements are other than small businesses who self-perform dredging work. Limited opportunities exist for small business subcontracting in dredging; subcontracts for supplies such as fuel and services such as towing and welding are restricted by geographical proximity to the location of work.

d. Applicability of Consolidation: This requirement meets the definition of consolidation requirements, which is described as a solicitation of a single contract to satisfy the requirements of the Federal agency for construction projects to be performed at two (2) or more discrete sites.

The total estimated value of the requirements exceeds the $2M threshold. By consolidating these requirements, MVK will be able to efficiently coordinate and respond to the dynamic requirements of construction and maintenance dredging at Mississippi River ports and harbors at a significant savings of cost and time. This also allows contractors to organize their work more efficiently and offer lower unit cost with a more effective economy of scale.

e. Requirements Being Consolidated: Requirements for maintenance dredging of shallow draft navigation projects at multiple locations within MVK’s, area of responsibility. MVK has a need for dredging at various Mississippi River ports and harbors from Rosedale Harbor, MS to Claiborne County Port, MS and at various lock and dams and revetments along the Red River and Ouachita/Black Rivers.

f. Procurement History: Prior to 2019, MVK utilized sealed bidding to award stand-alone construction contracts for shallow draft maintenance dredging (Table 1). In 2019, MVK issued a solicitation that resulted in awarding a MATOC to one small business and three large businesses.

Contracts W912EE19D0004, W912EE19D0005, W912EE19D0006, and W912EE19D0007 had an ordering period of three years and a combined capacity of $45M (Table 2). These contracts expired in 2022 (Table 3).

That same year MVK issued another consolidated procurement, resulting in a follow-on MATOC to four large businesses. Contracts W912EE22D0003, W912EE22D0004, W912EE22D0005, and W912EE22D0006 had an ordering period of five years and a combined capacity of $49.5M (Table 4). A historic low water event in 2023 resulted in the award of three task orders against this MATOC, using over $24M of the MATOC’s combined capacity of $49.5M. Two more dredging task orders were awarded against the MATOC in 2024, using nearly $17M of the remaining combined capacity (Table 5). At the end of 2024, approximately $8.5M combined capacity remained.

With the average cost of recent dredging task orders exceeding $8M, it was decided that there was not sufficient combined capacity remaining on the existing MATOC to cover the award of any future task orders, that the MATOC would be closed out, and that consolidated construction contracts using sealed bidding procedures would be used for dredging requirements until a new MATOC could be established. In 2025, two firm fixed-price construction contracts were awarded to meet MVK’s dredging requirements for the year (Table 6). The current award amount of these two contracts is $16.8M, and work is expected to be completed one year from the date of award.

Each contract and task order listed in the tables below include some degree of consolidation.

Awards for Mississippi River Harbors typically include work at seven discrete work sites. Awards for Red, Ouachita, and Black Rivers include work at two discrete sites, at a minimum. In some years, only one award was made, and these awards included the discrete work sites on the Mississippi River and on the Red, Ouachita, and Black Rivers (2019 and 2021).

Table 1. MVK Historical Construction Contract Awards

Year Contract Number/Contractor Award

Amount Small

Business?

W912EE-12-C-0002

Great Lakes Dredge & Dock Company, LLC/Red, Ouachita, and Black Rivers

$ 2,936,140.00 No

W912EE-12-C-0004

Pine Bluff Sand & Gravel Company/Mississippi River Harbors

$ 3,983,002.00 No

W912EE-12-C-0007

Inland Dredging Company, LLC/Red, Ouachita, and Black Rivers

$ 3,221,000.00

No

W912EE-12-C-0020

Great Lakes Dredge & Dock Company, LLC./Mississippi River Harbors

$ 6,148,691.00 No

W912EE-14-C-0003

Great Lakes Dredge & Dock Company, LLC. /Red, Ouachita, and Black Rivers

$ 2,512,063.00

2014 W912EE-14-C-0009

Weeks Marine, Inc./Mississippi River Harbors

$ 4,390,701.00

W912EE-14-C-0011

$ 2,547,001.00

Yes

W912EE-16-C-0001

Great Lakes Dredge & Dock Company, LLC. /Red, Ouachita, and Black Rivers

$ 1,599,580.00

W912EE-16-C-0005

Pine Bluff Sand & Gravel Company /Red, Ouachita, and Black Rivers

$ 4,132,371.00

W912EE-16-C-0007

Pine Bluff Sand & Gravel Company/Mississippi River Harbors

$ 3,418,401.00

W912EE-17-C-0001

$ 3,216,000.00

2017 W912EE-17-C-0009

4H Construction Corp./Mississippi River Harbors

$ 4,701,100.00

W912EE18C0008

Crosby Dredging, LLC//Red, Ouachita, and Black Rivers

$ 4,502,517.00 Yes

W912EE18C0009

Inland Dredging Company, LLC//Red, Ouachita, and Black Rivers

$ 3,247,000.00

Total $50,555,567.00

Table 2. MVK Historical FY 19 MATOC Awards Year Contract Number/Contractor Award Amount Small

Business

2019 W912EE19D0004

Inland Dredging Company, LLC $45 Million Combined

Yes*

2019 W912EE19D0005

Crosby Dredging, LLC

$45 Million Combined

No

2019 W912EE19D0006

Great Lakes Dredge & Dock Company, LLC

$45 Million Combined

No

2019 W912EE19D0007

Weeks Marine

$45 Million Combined

No

*Based on gross receipts, Inland Dredging was a small business concern under NAICS code 237990 at the time of award.

Table 3. MVK Historical Dredge Task Orders Awarded Against FY 19 MATOC Year Task Order/Contractor Current Award

Amount Small

Business?

2019 W912EE19F0069

Inland Dredging Company, LLC Mississippi River Harbors

$3,954,652.23 Yes*

2020 W912EE20F0048

Great Lakes Dredge & Dock Company, LLC

Red and Ouachita/Black Rivers

$6,428,200.00 No

2020 W912EE20F0091

Crosby Dredging, LLC

Mississippi River Harbors

$12,992,085.50 No

2021 W912EE21F0053

Inland Dredging Company, LLC

Mississippi River Harbors

$5,374,390.00 Yes*

2022 W912EE22F0033

Inland Dredging Company, LLC

Mississippi River Harbors

$5,583,451.07 No

2022 W912EE22F0035

Crosby Dredging, LLC

Red and Ouachita/Black Rivers

$5,138,817.47 No

Total $39,471,596.27 *Based on gross receipts, Inland Dredging was a small business concern under NAICS code 237990 at the time of award.

Table 4. MVK FY22 MATOC Awards

Year Contract Number/Contractor Award Amount Small Business

2022 W912EE22D0003

Inland Dredging Company, LLC

$49.5 Million Combined

No

2022 W912EE22D0004

Crosby Dredging, LLC

$49.5 Million Combined

No

2022 W912EE22D0005

Great Lakes Dredge & Dock Company, LLC

$49.5 Million Combined

No

2022 W912EE22D0006

Weeks Marine

$49.5 Million Combined

Table 5. MVK Task Orders Awarded Against FY22 MATOC Year Task Order/Contractor Current Award

Amount Small

Business?

2023 W912EE23F0025

Inland Dredging Company, LLC Mississippi River Harbors

$6,999,842.39 No

2023 W912EE23F0026

Crosby Dredging, LLC

Red and Ouachita/Black Rivers

$9,509,488.12 No

2023 W912EE23F0093

Crosby Dredging, LLC

Red and Ouachita/Black Rivers

$7,542,730.25 No

2024 W912EE24F0059

Inland Dredging Company, LLC Red and Ouachita/Black Rivers

$8,269,171.13 No

W912EE24F0060

Inland Dredging Company, LLC.

Mississippi River Harbors

$8,652,367.48 No

Total $40,973,599.37

Table 6. MVK Current Dredge Contracts

Year Task Order/Contractor Current Award Amount

Small Business?

2025 W912EE25CA003

Inland Dredging Company, LLC Red and Ouachita/Black Rivers

$9,798,900.00 No

2025 W912EE25CA004

Inland Dredging Company, LLC

Mississippi River Harbors

$7,059,000.00 No

Total $16,857,900.00

f. Rationale for Consolidation:

(1) In order to be determined necessary and justified, the benefits of the consolidated acquisition must substantially exceed the benefits that would be derived from alternative contracting approaches that involve less consolidation. Such benefits may include qualitative or quantifiable cost savings or price reductions as well as other benefits, regardless of whether quantifiable in dollar amounts, to include quality improvements that will save time or improve or enhance performance or efficiency, reduction in acquisition cycle time, better terms or conditions, or any other supportable benefit. Benefits that are quantifiable are considered substantial if they meet the dollar amounts set forth in FAR 7.107-2(d). The estimated cost of this acquisition is $12M. Pursuant to FAR 7.107-2(d)(1)(i), for acquisitions in which the estimated contract value (including options) is $94 million or less, the quantitative benefits must be equivalent to ten percent of the estimated contract or order value (including options). Ten percent of $12M is $1.2M, therefore, the quantitative financial benefits from consolidation must exceed $1.2M. If the quantifiable benefits do not meet these thresholds, the approving authority may determine that consolidation is necessary and justified if critical to the agency’s mission success and procurement strategy provides for maximum practicable participation by small business. For this procurement, the quantifiable benefits of consolidation exceed the standard set forth in FAR 7.107-2(d). While there are substantial cost benefits associated with this consolidation, these benefits also significantly increase the likelihood of mission success, reduce acquisition cycle times, provide improved quality that will enhance performance or efficiency, as outlined in FAR 7.107-2(c), and are substantial. The dredging program is critical to the mission of USACE in that it provides navigable Federal waterways which are vital to many aspects of Arkansas’s, Louisiana’s, and Mississippi’s economies. MVK’s decision to consolidate the requirements under the proposed solicitation is also based on the anticipated cost savings of mobilization and demobilization (mob/demob) costs.

(2) Consolidation of projects gives contractors an opportunity to execute projects more efficiently, which in turn boosts MVK’s ability to complete its dredging mission successfully.

When two or more projects are combined, the solicitation usually allows a longer performance period to give the contractor the option of performing the discrete sites in series or concurrently.

This longer period gives the contractor flexibility in determining how the work is sequenced, and it also gives them the opportunity to take on additional work if they are performed concurrently.

This flexibility also reduces the contractor’s risk of performance, which results in lower costs to the contractor and could consequently result in savings to the Government.

(3) Having the flexibility to consolidate individual projects enhances the Government’s ability to meet customer needs efficiently, timely and at a lower overall cost without having any adverse impacts on the quality of the work. When scheduling windows present a challenge to the completion of multiple projects in proximity by multiple contractors, consolidating the requirements enables one contractor to perform and schedule the work to meet the deadline. This method will substantially increase the probability that projects will be completed, in a timely manner and per contract specifications.

4. Applicable Statutes/Regulations: 15 U.S.C. § 657q, DFARS 207.170, and AFARS

5107.170.

5. Results of Market Research: Market research was conducted to determine those sources that could fulfill the Government’s requirement IAW FAR 10.002(b)(2). To ensure that small business concerns are given appropriate opportunities to participate as prime contractors and subcontractors in federal procurements, MVK conducted market research that supplemented MVK’s knowledge of capabilities based on prior similar acquisitions. MVK annually bids one to two cutterhead dredge contracts per year against the existing MATOC. Solicitations for these dredge projects have typically yielded two to three proposals from the existing MATOC holders.

Currently, the pool of contractors capable of meeting the equipment requirements is limited. The following contractors were FY22 Dredge MATOC holders: Great Lakes Dredge and Dock Co.

(Large Business), Weeks Marine (Large Business), Inland Dredging Company, LLC (Large Business), and Crosby Dredging, LLC (Large Business). Based upon procurement history, the targeted pool of contractors is fully capable of performing the consolidated requirement and their ability to compete will not be negatively impacted by this approach. Based on the above market research, and extensive historical experience and knowledge of the contractors within this industry, MVK is confident that all these businesses can perform the requirement whether it is consolidated into a MATOC or awarded under individual stand-alone consolidated contracts.

6. Alternate Contracting Approaches Considered and Rationale for Rejection: MVK considered the potential impact of multiple unconsolidated awards. The primary disadvantage in not consolidating multiple shallow draft dredging sites into a single award is the cost of paying for multiple mobilizations and demobilizations (mob/demob). Other disadvantages of not consolidating this requirement are the increased administrative costs associated with awarding separate contracts for each work site and scheduling problems with dredging contractors. Further rationale for the rejection of alternate contracting approaches with a lesser degree of consolidation or no consolidation are detailed in the section below, which compares the benefits of consolidation with the costs of not consolidating these requirements.

7. Consolidation Benefit Analysis

Table 7 – Time Savings Comparison of In-house Procurement to Award One (1) FFP versus Seven (7) FFP Individual Contracts.

One (1) FFP Contracts Seven (7) Individual Contracts Invitation for Bid (IFB) 90 days) X 1 contracts

IFB (90 days) X 18 contracts 630

Total – 90 630

a. Cost Savings. Pursuant to FAR 7.107-2(d) - Benefits.

(1) Benefits that are quantifiable in dollar amounts are substantial if individually, in combination, or in the aggregate the anticipated financial benefits are equivalent to- (i) Ten percent of the estimated contract or order value (including options) if the value is $94 million or less; or (ii) Five percent of the estimated contract or order value (including options) or $9.4 million, whichever is greater, if the value exceeds $94 million.

(2) Benefits that are not quantifiable in dollar amounts shall be specifically identified and otherwise quantified to the extent feasible.

(3) Reduction of administrative or personnel costs alone is not sufficient justification for consolidation unless the cost savings are expected to be at least 10 percent of the estimated contract or order value (including options) of the consolidated requirements, as determined by the SPE or CAO (15 U.S.C. 657q(c)(2)(B)

b. (a) Tables 8 and 9 below compare the estimated administrative and personnel costs required for a consolidated FFP contract (historically IFB) to those of 7 individual FFP contracts.

Mississippi ports and harbors dredge awards typically consolidate seven discrete work sites.

These costs are based on standard labor costs developed by MVK Contracting for FY18-current procurements, along with historical average procurement support costs for Cost Engineering Division, Programs and Project Management Division (PPMD), and Engineering and Construction Division for acquisition coordination, document review, Independent Government Estimate (IGE) development and site visit attendance. The in-house costs were derived from historic FFP contract acquisitions for this type of work using the labor rates for the different disciplines mentioned above and the combined total costs associated for each activity required from project conception to award.

(b) Based on information provided by the MVK Contracting Division, as shown in Table

8 below, the total cost required to award one (1) FFP contract equals $320,000. As shown in Table 9 below, awarding seven (7) individual FFP contracts would cost $2,240,000. As shown in Table 10 below, the one (1) single FFP method would reduce the close-out cost by $30,000.

Table 8 – Cost to Award One (1) Consolidated FFP Contract

ORGANIZATION LABOR

Contracting ($30K each) $30,000 Cost Engineering ($30K each) $30,000 Engineering ($30K each) $30,000 Construction ($30K each) $30,000 Mobilization and Demobilization ($200K each) $200,000 Subtotal $320,000 Total Cost to Award One (1) Consolidated FFP Contract $320,000

Table 9 – Cost to Award Seven (7) Individual FFP Contracts

ORGANIZATION LABOR

Contracting ($30K each) $210,000 Cost Engineering ($30K each) $210,000 Engineering ($30K each) $210,000 Construction ($30K each) $210,000 Mobilization and Demobilization ($200K each) $1,400,000

Subtotal $2,240,000 Total Cost to Award Seven (7) Individual Contracts $2,240,000

Table 10 – Cost Savings Comparison of In-house Labor for One (1) Consolidated FFP contract vs

Seven (7) Individual FFP contracts

Acquisition Approach

1 Consolidated FFP Contract Cost

7 Individual Contracts Cost

Cost per Procurement of FFP contract $320,000 $2,240,000 Contract Close Out ($5K each) $5,000 $35,000 Subtotal $325,000 $2,275,000 Other In-House Labor ($30K each) $30,000 $210,000

Total $355,000 $2,485,000 Cost Savings to Award One (1) Consolidated Contract vs Seven

(7) Individual Contracts

$2,130,000

As demonstrated in Table 10, the costs of awarding seven (7) contracts is approximately seven times the cost of awarding one (1) consolidated contract and the benefit well exceeds the 10% quantifiable benefit required by FAR 7.107-2(d). In sum, MVK estimates the use of one (1) consolidated FFP contract would generate $2,130,000 in labor savings for the life of the consolidated contract. A FFP contract maximizes the opportunity to acquire high quality professional services at competitive prices while minimizing acquisition time, performance, and schedule risks.

Table 11 – Analysis Summary

BENEFIT 1 Consolidated FFP 7 Individual FFP

Quality High High Acquisition Cycle 90 days 630 days

Administrative Cost Low High

7. Bundling:

Bundling (FAR 7.107-3) and/or Substantial Bundling (FAR 7.107-4) are not applicable to this procurement. A bundled requirement is considered necessary and justified if the agency would obtain measurably substantial benefits as compared to meeting its agency’s requirements through separate smaller contracts or orders. Substantial Bundling is any bundling that results in a contract with an estimated value of $8 million or more for the Department of Defense. This acquisition does not meet the definition of bundling since the government is not attempting to consolidate two (2) or more requirements previously provided or performed under separate contracts into a single contract unsuitable for small business. The selected approach is capable of fulfilling all requirements under the FFP contract.

8. Considerations, Facts, Reasoning Supporting the Determination:

A DD2579 has been signed by the Contracting Officer and Deputy for Small Business. Both concur that consolidation of this requirement is necessary and justified. Consolidation will result in a significant savings of cost and time, as well as accommodate river stage dependent construction and environmental windows. Consolidation will allow contractors to more effectively organize their work, lower unit costs due to economy of scale, and more efficiently schedule their equipment and resources to achieve an efficient regional approach to meet the needs of the Corps of Engineers Mississippi River Sediment Reduction Structure programs.

Moreover, consolidation of this requirement is both necessary and justified because the benefits of consolidation are critical to the success of MVK’s mission.

9. Summary:

(1) Although this FFP solicitation constitutes consolidation of dredging requirements at seven

(7) discrete sites into one (1) consolidated FFP contract, this approach provides the best combination of competitive procedures, timely acquisition, cost efficiency, quality, and capable prime contractors to execute maintenance dredging on the MVK navigation channels.

(2) For the reasons indicated above this consolidation is necessary and justified and is critical to the agency’s mission success. There is a maximum of $2,130,000 in cost benefit associated with this consolidation; also, these necessary and justifiable benefits significantly increase the likelihood of mission success, reduce acquisition cycle times, provide improved quality that will enhance performance or efficiency, as outlined in FAR 7.107-2(c), and are substantial. The dredging program is critical to the mission of USACE in that it provides navigable Federal waterways which are vital to many aspects of Mississippi’s economies.

(3) Other alternatives noted above were considered, however, they would result in significantly higher costs and increased acquisition cycle time. Additionally, it is significantly less burdensome for the District’s Contracting and Construction Divisions to administer a consolidated scope of work for dredging at multiple locations on the J.B.J. Waterway than numerous stand-alone contract actions. The findings of the market research and the documentation provided herein support the conclusion that consolidation of requirements is both necessary and justified, based on sound business judgment in view of the size, complexity, and potential number of efforts to be executed in support of MVK’s Dredging program, and the consolidated approach provide advantages that substantially exceed the benefits of an approach that provides less consolidation.

10. Program Manager/Requiring Activity Justification: Market research has been conducted utilizing dynamic online searches in conjunction with a comparison of historical data from previous procurements of similar size, scope and complexity and the determination has been made that there is not a reasonable expectation of receiving offers from two (2) or more responsible small business concerns that are competitive in terms of fair market prices, quality, and delivery. The market research does not support a further set-aside of the requirement based on small business socioeconomic categories. Based on customer recommendation and agency needs, the Contracting Officer has recommended this procurement be advertised as unrestricted.

Lease of One Cutterhead, Hydraulic Pipeline Dredge (Not Less than 24-Inch Diameter), Fully Operated with Attendant Plant and Personnel, with a Draft Not to Exceed 9 Feet, for Construction and Maintenance Dredging within the Vicksburg District – JBJ Waterway

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

Assistant District Counsel

Demetric Erwin Deputy for Small Business Programs

R. Ellis Screws Contracting Officer, Construction and A-E Branch

Lease of One Cutterhead, Hydraulic Pipeline Dredge (Not Less than 24-Inch Diameter), Fully Operated with Attendant Plant and Personnel, with a Draft Not to Exceed 9 Feet, for Construction and Maintenance Dredging within the Vicksburg District – JBJ Waterway

Based on the foregoing rationale, I hereby determine, pursuant to the Federal Acquisition Regulation Supplement 7.107-2 and Army Federal Acquisition Regulation Supplement 5107.107, that the consolidation of the requirements for construction and maintenance dredging is both necessary and justified and will serve the best interests of the Government.

Davita S. Baloue Chief, Vicksburg District Contracting Office