Class_Justification_FairOppExcep_1202SC21R0001 Type 2IA IDIQ-Signed.pdf

National Type 2IA Firefighter Crews

Page 1 – Justification for Exception to Fair Opportunity

Class Justification for Exception to Fair Opportunity United States Department of Agriculture

FAR 16.505 (b)(2)(i)(A)

1. Identification of the agency and the contracting activity.

USDA Forest Service – Procurement & Property Services (PPS), Incident Procurement Operations, Logistics Contracting Branch. 3833 S. Development Ave., MS1100, Boise, ID 83705.

2. The nature and/or description of the action being approved.

The USDA Forest Service intends to award up to 42 multiple-award Indefinite Delivery-Indefinite Quantity (IDIQ) contracts with fixed-price hourly rate Contract Line Item Number (s) (CLIN) for commercially available Type 2-IA Firefighter Crews under solicitation number 1202SC21R0001. This fair opportunity exception will apply to task orders issued under those contracts for fire suppression related activities and all-hazard incidents only (ordering procedures outlined in Section C.3.1 of the contract). As described in the ordering procedures of the contract, the contractors will be ordered based on closest available resource and a rotation within the host unit if more than one crew is at that Host Unit Coordination Center (HUCC).

The exception will not apply to task orders issued for project work (ordering procedures outlined in Section C.3.2 of the contract).

3. A description of the supplies or services required to meet the agency’s needs (including estimated value).

(a) The intent of this requirement is to provide the services of commercially available Type 2 Initial Attack (IA) qualified 20-person wildland firefighter crews on a nation-wide basis, for fire suppression activities, All-Hazard incidents, and Severity/Preparedness assignments. These crews are utilized for assignments that involve the protection and management of public lands. The categories of work contemplated under this contract include wildland fire preparedness, pre-suppression assignments, fire suppression activities with an emphasis on Initial Attack, large fire support, and All-Hazard incidents that are managed using the Incident Command System (ICS).

(b) The effective period of the resultant contract(s) will be from date of award through 31 December 2021. At the Government’s option, the contract(s) may be renewed for four (4) additional one-year periods, not to exceed four renewal periods (5-year maximum potential contract plus an additional six months if Option to Extend Services FAR 52.217-8 is exercised).

(c) The estimated value including all options of this requirement is $148M

4. Identification of the exception to fair opportunity and supporting rationale.

FAR 16.505(b)(2)(i)(A) - the agency need for supplies or services is so urgent that providing fair opportunity would result in unacceptable delay.

Contracted resources are critical to cooperative interagency incident management operations and are used along with Type 2 IA Federal and Cooperator crews to contain initial attack fires at a smaller acreage, thus keeping the cost of the fire down by not requiring a large, long duration and expensive response, as well as better protecting values at risk from the fire. While all awardees have the potential for an order at any time, the primary criteria for order award is the “closest forces concept” (as opposed to fair opportunity). Providing an opportunity for awardees to provide proposals for orders would delay the performance start, thereby putting acres and personnel at greater risk.

5. A determination by the Contracting Officer that the anticipated cost to the Government will be fair and reasonable.

Existing contract rates will be used for all orders placed under the contracts. All rates are found to be fair and

National Type 2IA Firefighter Crews

Page 2 – Justification for Exception to Fair Opportunity reasonable at time of award so there is no further need to do a fair and reasonable determination at the order level.

6. Any other facts to support the justification.

Resources under the Type 2 Initial Attack (IA) Firefighter Crew contract are IA resources and as such are dispatched (ordered) via the closest forces concept, as described in the Federal Wildland Fire Management Policy and Program Review Report https://www.doi.gov/sites/doi.gov/files/migrated/pmb/owf/upload/1995- Federal-Fire-Policy.pdf, Goal

· Federal agencies shall maintain sufficient fire suppression and support capability.

Actions Federal agencies will:

· Develop and utilize, to the maximum extent possible, the concept of closest initial attack forces and interagency staffing for wildland fire suppression and support, optimizing the use of the Federal and non-Federal work force. Qualified contractors are a component to be considered in suppression and support planning.

7. A statement of actions, if any, the agency may take to remove or overcome any barriers to competition if subsequent acquisitions are anticipated.

The crew requirements and dispatch (ordering) approach is dictated by the National Wildfire Working Group (NWCG). The NWCG would need to modify their procedures to allow for a fair opportunity ordering approach by the Geographical Area Coordination Center (GACC) and other ordering offices.

Certifications & Approval

Supporting data that form the basis for and included in this justification is certified accurate and complete.

SHANE GREER

National Fire Crew Program Manager

The information contained in this justification is certified accurate and complete to the best of my knowledge and belief.

BRYCE PITCHFORD Digitally signed by

BRYCE

PITCHFORD

Date: 2020.11.23 10:35:28 -07'00'

BRYCE N. PITCHFORD

Contracting Officer

R. Shane Greer Digitally signed by R. Shane Greer Date: 2020.11.12 07:04:29 -07'00' http://www.doi.gov/sites/doi.gov/files/migrated/pmb/owf/upload/1995-Federal-Fire-Policy.pdf http://www.doi.gov/sites/doi.gov/files/migrated/pmb/owf/upload/1995-Federal-Fire-Policy.pdf

National Type 21A Firefighter Crews Additional Reviews & Approvals

Procuring Activity Competition Advocate (if over $750,000, but not exceeding $15 million). I have reviewed this justification and find it to be accurate and complete to the best of my knowledge and belief. Therefore, unless additional approvals are required as prescribed below, as advocate for competition fo� thr: ng :ivity, I hereby approve this j usti fl cation.

� lt ),t,.J ',,Z.uL \ GEORGA. SEARS Procuring Activity Advocate for Competition/MASCO Head of the Procuring Activity (if over $15 million, but not exceeding $75 million). I have reviewed this justification and find it to be accurate and complete to the best of my knowledge and belief. Therefore, unless additional approvals are required as prescribed below, as Head of the Procuring Activity, I hereby approve this justification.

DOROTHY (DEE DEE) LILLY Head of the Procuring Activity United States Department of Agriculture Senior Procurement Executive of the Agency (if over $75 million). I have reviewed this justification and find it to be accurate and complete to the best of my knowledge and belief. Therefore, as the Senior Procurement Executive, I hereby approve this justification.

TIFFANY J. TAYLOR Senior Procurement Executive United States Department of Agriculture

Page 3 - Justification for Exception to Fair Opportunity

1/27/2021

1/27/2021