Fuels SAD-AF2 JA_Other Than Full and Open_29 May 2026_Approved_Redacted.pdf
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- Justification and Approval for Other than Full and Open Competition Fuels SAD-AF2 Bridge Contract
- Solicitation number
- CEHNC-26-0012
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This is a FAR Part 6 Justification and Approval document for a non-competitive sole-source bridge contract. The Defense Logistics Agency – Energy (DLA-E), through USACE Engineering and Support Center Huntsville (CEHNC), seeks approval to award a 10-week Firm-Fixed-Price (FFP) standalone contract to Weston Solutions, Inc. (CAGE 2M222) for fuel systems preventative and corrective maintenance services within the South Atlantic Division supporting the Air Force. The contract period runs from May 16, 2026 through July 10, 2026, with award projected for May 15, 2026. Services include scheduled preventative maintenance of federal petroleum facilities and systems in compliance with United Facilities Manual (UFM) 3-460-03, as well as corrective maintenance and emergency repairs to ensure mission-critical fuel delivery capability across multiple Air Force installations within the USACE South Atlantic Division. The justification cites Title 10 U.S.C. §3204(a)(1) (Only One Responsible Source) as the authority, with contract funding provided through Defense Working Capital Funds (DWCF).
The bridge action results from a mandatory Competition in Contracting Act (CICA) stay following GAO protests of a competitively awarded contract (W912DY26CA005, awarded to Pond Constructors, Inc. on March 2, 2026). The government determined that onboarding a new contractor would create unacceptable delays and duplicate start-up costs including mobilization, security clearances, and site-specific training, estimated at significant amounts. Market research conducted May 4-13, 2026 included publication of a Notice of Intent to Sole Source and review of three contractors' capabilities statements; however, responses confirmed that none could obtain mandatory pre-performance approvals without creating a service gap. Weston's existing personnel are already trained, cleared, and integrated with government teams, eliminating the ramp-up period a new contractor would require. The contract covers six contract line items (CLINs): quarterly recurring maintenance, semi-annual recurring maintenance, annual recurring maintenance, minor and emergency repairs, other technical administrative requirements, and required personnel. Post-award publication of this justification is planned per RFO 6.301.
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CUI
Control Number: CEHNC-26-0012
Procurement Sensitive – See RFO 2.101 and 3.104-1
FAR Part 6 Justification and Approval for Other than Full and Open Competition
1. Requiring Activity: Defense Logistics Agency – Energy, 8725 John J. Kingman Road, Fort Belvoir, Virginia 22060
2. Contracting Activity: USACE Engineering and Support Center, Huntsville (CEHNC), 300 Secured Gateway SW, Redstone Arsenal, Alabama 35898
3. Description of Action: DLA – E Fuels, through USACE CEHNC, has a continued requirement for fuel systems preventative and corrective maintenance services within the South Atlantic Division in support of the Air Force. CEHNC requests approval to issue a non-competitive short-term standalone Firm-Fixed- Price (FFP) bridge contract to Weston Solutions, Inc. (hereafter referred to as "Weston"), CAGE 2M222, 1400 Weston Way, West Chester, Pennsylvania 19380-1492. Projected award is 15 May 2026 for a 10-week period of performance, fully funded using Defense Working Capital Funds (DWCF).
4. Authority Cited: Title 10 U.S.C. §3204(a)(1) as implemented in RFO 6.103-1 (formerly FAR 6.302-1) – Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.
5. Description of Supplies/Services: CEHNC executes system maintenance in accordance with (IAW) United Facilities Manual (UFM) 3-460-03 which outlines maintenance of petroleum fuel system procedures and standards. This maintenance is critical for maintaining operational fuel systems for the Air Force across the USACE South Atlantic Division area of responsibility (AOR). The contractor is required to provide vital preventive maintenance and corrective maintenance repair services to sustain robust fueling capability in support of Defense Logistics Agency – Energy (DLA-E) capitalized federal petroleum facilities and petroleum systems. The work to be performed is structured around performance-based outcomes.
Preventative maintenance - The work entails the maintenance of federal petroleum facilities and petroleum systems ensuring these systems are in compliance with codes, criteria, regulations, and laws of the United States and its outlying areas in order to meet several preventative and corrective maintenance requirements. In addition to a well-maintained system or facility, the preventative maintenance portion of the work will include written reports detailing evaluated systems.
Corrective maintenance - The work entails service orders for minor repairs of deficiencies to petroleum facilities, petroleum systems, and supporting DLA-E capitalized facilities as well as emergency response capability to ensure the safe and reliable accomplishment of the applicable Fuels delivery mission. Repairs may be requested by each of the DLA Capitalized Sites for components, equipment, or systems in support of the Fuels delivery mission.
The scope of services required shall be strictly limited to those actions essential for maintaining operational readiness and preventing mission degradation during the 10-week period of performance.
The requirements are outlined in the Performance Work Statement. Specifically, the work includes:
a) The performance of scheduled, mission-essential preventative maintenance; and
b) Response to any emergent, unforeseen service requirements critical to sustaining the mission.
Anticipated preventative maintenance events, along with the estimated values by contract line item number (CLIN) are shown in Tables 1 and 2 that follow:
Table 1: Anticipated Preventative Maintenance Events by Site
Control Number: CEHNC-26-0012
Procurement Sensitive – See RFO 2.101 and 3.104-1
The Government received capabilities statements from three (3) contractors in response to the Notice of Intent to Sole Source posted from 6 -13 May 2026. While these responses provided valuable market research and further validated the incumbent's pricing as fair and reasonable, these responses also confirmed that onboarding a new vendor for a 10-week bridge period would result in a substantial duplication of costs and unacceptable mission delays. More specifically, a review of the responses indicated that none of the three contractors were capable of complying with and obtaining approval of all mandatory pre-performance requirements without creating a gap in service. Therefore, Weston Solutions, Inc. remains the only responsible source capable of fulfilling this short-term requirement without mission disruption.The approved justification will be published post-award in accordance with RFO 6.301, Availability of the Justification.
Effective competition: No effective competition is anticipated for this short-term standalone bridge. The action is being executed on a sole-source basis to the incumbent, Weston Solutions. This is the only viable course of action to ensure the seamless continuity of mission-critical Fuels services during the mandatory CICA stay of performance.
Subcontracting competition: Because this action is a short-term continuation of existing services, the incumbent will primarily leverage their already established, trained, and vetted network of subcontractors who possess direct experience with the specific site requirements. However, the Government will continue to monitor performance to ensure that the prime contractor obtains as much competition as possible for any new, unforeseen subcontracting opportunities that arise during the 10-week performance period.
8. Actions to Increase Competition:
Successful Competitive Action: The bridge action covered by this justification was recently the subject of a full and open competition under Solicitation W912DY26RA017. The competitive action resulted in an award on 2 March 2026. This current sole-source action is a temporary bridge resulting from a CICA stay.
Future Strategy: Upon resolution of the pending protests, the Government will proceed with the competitively awarded contract or take appropriate corrective action as recommended by the
GAO.
Ongoing Market Research: In addition to the recently completed competitive action, the Government is proactively developing a long-term contract vehicle designed to significantly enhance the competitive environment for future Fuels requirements, centering on the establishment of a dedicated Fuels Multiple Award Task Order Contract (MATOC) with periodic "on-ramping" provisions.
9. Market Research: Market research was conducted from 4 May 2026 to 13 May 2026 to determine the extent of competition and if there were any mandatory sources. This effort included the Contracting Officer’s publication of a Notice of Intent to Sole Source on 6 May 2026 and review of capabilities statements submitted in response to the Notice. The results indicate the existence of capable contractors able to perform the PWS work. However, any contractor other than the incumbent would require a significant and costly ramp-up period, leading to a duplication of costs and unacceptable delays for a 10-week bridge. More importantly, the submission, review and approval of all mandatory pre-performance requirements by any of the three responding contractors would create a gap in service. Therefore, awarding this short-term standalone contract to the incumbent is the most economical, efficient, and operationally sound approach.
10. Interested Sources: To date, no other sources have written to express an interest in this 10-week bridge acquisition, as it is a direct result of a CICA stay pending GAO protest resolution.
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