CI_Init_ADWR_Willcox_AMA_10-31-25__1_.pdf

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Attached to
AZ|CTR079478
Contract number
CTR079478
Issued by
Arizona

About this file

This document is a Competition Impracticable (CI) Procurement Authorization form from the State Procurement Office in Arizona, specifically involving the Arizona Department of Water Resources (ADWR). The requesting party is Paul Evans, Procurement Manager, seeking authorization for a procurement with WestWater Research as the supplier.

The procurement is for an "Economic Feasibility of the Willcox AMA Management Goal" service with an estimated cost of $130,000 for a 36-month contract term. ADWR currently has an existing NPTQ (Contract CTR073000) with approximately $58,000 spent to date, and this new project will immediately expire the existing contract. The pricing was previously determined fair and reasonable, with the contractor quoting a fixed price increase of 5%. The procurement is part of ADWR's ongoing work to develop a management plan for the Willcox Active Management Area (AMA), with goals including supporting the regional economy, mitigating land subsidence, and reducing groundwater overdraft by at least 50% by 2075. The State Procurement Administrator, David Steuber, approved the request on 10/31/2025, with an approved expiration date of 3/1/2029.

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Page 1 of 2 SPO Form 101 Standard Work (Rev 10.17.23)

Standard Work

Owner

Form Number Version

Process

No. Action Action Detail/Key Points

State Procurement Office, Compliance Unit

SPO Form 101 - Competition Impracticable Authorization Revised 10/17/23

Standard Work/Instructions for completion and submittal of the SPO 101 form. The form is available on the

1 State Governmental Unit Name of the requesting State Governmental Unit (SGU; agency, board, or commission)

2 Requestor Name of the requestor 3 Email Email of the requestor 4 Title Job title of the requestor 5 Telephone Telephone number of the requestor

6 Service(s)/Material(s) Description of service(s)/material(s) or Contract title (eProcurement Label) 7 Supplier Name of supplier(s) 8 Contract ID eProcurement contract number (if available)

9 CI Type Select applicable option:

- Authorization Request for a new CI

- Modification pursuant to R2-7-E303(E) for a CI modification

SPO website: For Agencies > Resources > Standard Forms and Documents

Form Completion Process

SECTION I - State Governmental Unit Request

Sections I through III to be completed by the requesting State Governmental Unit:

SECTION II - Background

Page 2 of 2 SPO Form 101 Standard Work (Rev 10.17.23)

10 Requesting Term Specify contract term or extension period, as applicable, based on the CI 11 Estimated Cost Forecasted expenditures for the duration of the CI term

12 Rationale

Select applicable option in accordance with A.A.C R2-7-E303(A):

- Compliance with A.R.S. §§ 41-2533, 41-2534, 41-2538, or 41-2578 is impracticable

- Compliance with A.R.S. §§ 41-2533, 41-2534, 41-2538, or 41-2578 is unnecessary

- Compliance with A.R.S. §§ 41-2533, 41-2534, 41-2538, or 41-2578 is contrary to public interest

- Documented lack of suppliers

- Procurement requires an open and continuous availability of offerors

Provide details of the procurement need, reason for the competition impracticable, and how the proposed procurement is advantageous to the State

Detail information regarding the rationale selected in the previous section;

State Governmental Unit use of the material(s) or service(s); if mandatory state contracts were explored; the limitation which led to the competition impracticable, and how the State would benefit from the procurement. If there is previous contract which requires modification pursuant to R2-7-E303(E) or contract that reached beyond the maximum 5-year term, provide the contract number and copy of that CI.

Describe the procurement process, strategy to promote competition, and determination that the price is fair and reasonable

Detail strategy for the proposed procurement, considered competition, reason for selecting specific supplier, and negotiations strategy.

I have conducted research and determined that no mandatory state contract is available for the service(s)/material(s)

Check the box confirming research was conducted. If the CI pertains to a modification pursuant to R2-7-E303(E), leave field empty.

If needed, I have attached additional documents/clarifications/explanations to the request

Check the box to indicate that there are additional documents attached to the request. Either as separate documents in the original email request or attached directly to the PDF submitted.

17 Signature Signature of the authorized requestor 18 Date of Request Specify the date of request

19 Determination

Select applicable option in accordance with A.A.C. R2-7-E303(D):

- Request Authorized Pursuant to R2-7-E303

- Request Authorized with Conditions/Restrictions R2-7-E303

- Request Returned for Additional Information

- Request Denied

20 Approved Expiration Date Specify the date or term of expiration

21 Comments, conditions, or restrictions (as applicable) Complete as needed

22 Print Name Printed name of the approver 23 Title Job title of the approver 24 Signature Signature of the approving authority 25 Date of Approval Specify the date of approval

Use section as necessary (or attach additional information and check box 16)

Used by any party in case the fields within the form were insufficient

SECTION III - Justification

SECTION IV - Approval

Section IV to be completed by the Procurement Authority:

"STATE GOVERNMENTAL UNIT NOTICE: This is an official written determination in response to a procurement authorization request.

A copy of the form shall be maintained by the State Governmental Unit and the State Procurement Office.

Upon completion, Requestor shall forward the signed form to the Contract Owner.

Contract Owner shall upload the signed approval version of this form in the eProcurement system.

If anticipated expenditure is above State Governmental Unit's delegation, forward document to SPOCompliance@azdoa.gov."

Page 1 of 4 SPO Form 101 - Competition Impracticable Procurement Authorization (Rev 10.17.23)

Procurement Determination:

Competition Impracticable Authorization A.A.C. R2-7-E303

SECTIONS I THROUGH III MUST BE COMPLETED BY THE REQUESTOR

USE ADDITIONAL PAGE AS NECESSARY

SECTION I - State Governmental Unit Request

SECTION II - Background

1. State Governmental Unit

2. Requestor 3. Email

4. Title 5. Telephone

6. Service(s)/Material(s)

7. Supplier

8. Contract ID

9. CI Type

10. Requesting Term 11. Estimated Cost

Arizona Department of Water Resources

Paul Evans on behalf of Agency paul.evans@azdoa.gov

Procurement Manager 602.771.8632

36 month from contract execution $130,000.00

- Authorization Request for a new CI

Page 2 of 4 SPO Form 101 - Competition Impracticable Procurement Authorization (Rev 10.17.23)

SECTION III - Justification

12. Rationale

13. Provide details of the procurement need, reason for the competition impracticable, and how the proposed procurement is advantageous to the State

- Compliance with A.R.S. §§ 41-2533, 41-2534, 41-2538, or 41-2578 is impracticable

Page 3 of 4 SPO Form 101 - Competition Impracticable Procurement Authorization (Rev 10.17.23)

14. Describe the procurement process, strategy to promote competition, and determination that the price is fair and reasonable

15. I have conducted research and determined that no mandatory state contract is available for the service(s)/material(s)

16. If needed, I have attached additional documents/clarifications/explanations to the request

17. Signature 18. Date of Request

In accordance with the Procurement Rules, the Arizona Uniform Terms and Conditions must be made a part of all Contracts. If you will be required to sign a software licensing agreement or sign any other agreement containing terms and conditions, these will need additional review to ensure that the terms and conditions do not invalidate the Arizona Uniform Terms and Conditions. Approval of this request does not allow for agencies to exceed their dollar acquisition amount of delegated authority.

10/29/2025

Page 4 of 4 SPO Form 101 - Competition Impracticable Procurement Authorization (Rev 10.17.23)

TO BE COMPLETED BY PROCUREMENT AUTHORITY

SECTION IV - Approval

19. Determination

20. Approved Expiration Date

21. Comments, conditions, or restrictions (as applicable)

22. Print Name 23. Title

24. Signature 25. Date of Approval

STATE GOVERNMENTAL UNIT NOTICE: This is an official written determination in response to a procurement authorization request.

A copy of the form shall be maintained by the State Governmental Unit and the State Procurement Office.

Upon completion, Requestor shall forward the signed form to the Contract Owner.

Contract Owner shall upload the signed approval version of this form in the eProcurement system.

If anticipated expenditure is above State Governmental Unit's delegation, forward document to SPOCompliance@azdoa.gov.

3/1/2029

David Steuber State Procurement Administrator

David Steuber (Oct 31, 2025 11:05:36 PDT)

- Request Authorized Pursuant to R2-7-E303

10/31/2025 https://na1.documents.adobe.com/verifier?tx=CBJCHBCAABAAqpP4zNEB8gx4OmzmFJ6PBCdpWXqS5Jk8

Page 5 of 4 SPO Form 101 - Competition Impracticable Procurement Authorization (Rev 10.17.23)

26. Use section as necessary (or attach additional information and check box 16)

SW DRAFT SPO Form 101 CI & SW 10.13.2023 - Google Sheets.pdf
DRAFT SPO Form 101 CI & SW 10.13.2023 - Google Sheets.pdf
Text6: Economic Feasibility of the Willcox AMA Management Goal
Text7: WestWater Research
Text8: TBD
Text11: On January 8, 2025, the Willcox groundwater basin was designated as a subsequent

Active Management Area (AMA), pursuant to an order issued by the Director of the Arizona Department of Water Resources (ADWR) in late 2024. In accordance with statutory requirements, a management plan for the Willcox AMA must be promulgated within two years of the designation—no later than 2027. Following promulgation, conservation programs and regulatory requirements are to be implemented within an additional two-year period, by 2029. To that end, ADWR is engaged in ongoing collaboration with stakeholders within Willcox AMA to develop a management plan that will advance the area’s statutory management goal. Together with the community, ADWR has developed a draft goal that currently reads:

“To support the long-term viability of the regional economy, mitigate land subsidence, and extend the life of the aquifer by reducing groundwater overdraft by at least 50% by 2075.”

To assist in meeting the Willcox AMA management goal, conservation programs and related requirements will be included in the management plan to help facilitate a reduction of groundwater use. However, any implemented conservation program or requirement must prove economically feasible. ADWR is interested in understanding the economic feasibility of conservation requirements in two time periods. First, as there will be five management plans spanning a length of 10 years each to meet the management goal, ADWR is interested in understanding economic feasibility for the first 10 years. The second time period will consider the term of the draft management goal, through 2077.

To understand the economic feasibility of a mandatory reduction of groundwater use in the Willcox AMA.

ADWR is requesting that WestWater Research, LLC (WestWater) develop a proposed scope of work, due to their current historical knowledge of research required that is held under the current NPTQ (CTR073000). This contract was effective on 7/26/2024, and the required services have not yet been completed.

Therefore, would be advantageous to the State, as it saves time, funds; knowledge that continues from the NPTQ would not be lost, and no additional Contractor(s) are required.

Text12: ADWR has an NPTQ (CTR073000) with a current spend of approximately $58,000 to date. This CI will incorporate Contract CTR073000, and the new project that is required. Therefore the NPTQ will expire effective immediately upon execution of the direct contract.

ADWR will proceed with an RFP moving forward with any new projects to promote competition for these services.

The pricing was previously determined fair and reasonable through their NPTQ. The Contractor has quoted a fixed price increase of five-percent (5%).

Text15:
2025-11-01T00:06:32+0000
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