Consolidation DF 419 CSB AE v7 Final_Redacted.pdf

CUI // SP-PROCURE // FEDCON

Controlled by: U.S. Army Controlled by: MICC–Fort Campbell (CCMI-CBR-CM) CUI Category: General Procurement and Acquisition

Distribution/Limited Dissemination Controls: FEDCON POC: Evan M. Rea, evan.m.rea.civ@army.mil

1 AUG 24

CONSOLIDATION OF CONTRACT REQUIREMENTS DETERMINATION

FOR ARCHITECTURAL AND ENGINEERING (A&E) SERVICES

419TH CONTRACT SUPPORT BRIGADE (CSB)

(As prescribed by Federal Acquisition Regulation (FAR) 7.107-2 and Army Federal

Acquisition Regulation Supplement (AFARS) 5107.107-2)

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, there must be a written determination that the consolidation is necessary and justified in accordance with (IAW) 15 United States Code 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.

2. Introduction. The Mission and Installation Contracting Command (MICC) Fort Campbell plans to conduct a procurement for A&E Services for the 419th CSB. Market research demonstrates consolidation this procurement is both necessary and justified.

FAR 2.102 defines consolidation as

a. 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 offers are solicited; or (ii) requirements of the Federal agency for construction projects to be performed at two or more discrete sites; or

3 AUG 24

W9124C18D0003 Burgess and Niple Unrestricted $10M 13 September 2018 – 12 September 2023

W9124C18D0004 Stantec Consulting Services, Inc Unrestricted $10M

13 September 2018 – 12 September 2023

W9124C18D0005 Garver, LLC Unrestricted $10M 13 September 2018 – 12 September 2023

W911SA24D2004

Short Elliott Hendrickson (SHE) - Tepa Engineering Services (Tepa ES) JV, Limited Liability Corporation

(LLC)

Small Business $15M 15 April 2024 – 14 April 2029

4. Results of Market Research.

a. Consolidation Business Case Analysis.

I. Category Management is the business practice of buying common goods and services as an enterprise to eliminate redundancies, increase efficiency, and deliver more value and savings from the Army's acquisition programs. As a component of the Army Reform Initiative, category management is central to improving Army services contracting processes to consistently provide best value, and will enable us to save time, money, and manpower for higher Army priorities.

II. In a memorandum dated 8 April 2019, SUBJECT: Directive for Implementation of Category Management, the Secretary of the Army directed category management implementation to improve Army contracting processes and support data analytics, and enable the Army to save time, money, and manpower for higher priorities.

III. The Army strategic sourcing program promotes an organized, systematic, and collaborative approach to sourcing services. Collaboration improves the transparency of requirements across the enterprise, reduces the proliferation of redundant business arrangements for acquiring similar services, and increases alternative business arrangements that may be better suited to individual requirements.

IV. In addition to satisfying emerging requirements with existing strategic sourcing contract vehicles, category management also involves establishing contract vehicles which further of the Army’s overall category management directive.

V. The 419th CSB directed THE MICC Fort Campbell to establish an A&E strategic sourcing contract solution for the entire 419th CSB.

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The Government does not maintain Table of Distribution and Allowances (TDA) authorizations in the necessary type and amount to make this a viable alternative.

While some supporting activities may possess a single TDA slot for an architect or engineer, none hold authorizations to account for the different disciplines (e.g., civil, structural, mechanical, etc.) necessary to satisfy A&E requirements.

This alternative would result in mission failure as sites would not be able to develop their own plans or conduct their own studies.

b. Individual Single Award IDIQ Contracts.

Rather than consolidate, 419th CSB offices could develop their own single-award or multiple-award IDIQ contracts to satisfy A&E requirements.

Procurement history demonstrates some 419th CSB offices satisfied A&E requirements with this strategy.

Procurement history demonstrates that this strategy resulted in awards to other than small business firms.

This alternative would not improve or enhance performance or efficiency and would cost unnecessary time as offices establish their own solutions.

This alternative is counter to strategic sourcing guidance and does not support the small business community.

This alternative could divert dollars from small business firms to other than small business firms.

If a 419th CSB office does not organically possess an A&E contracting skillset, this alternative could result in mission failure.

c. Individual Firm-Fixed-Price Contracts.

The Government could forego establishing any IDVs and conduct stand-alone procurements.

Procurement history demonstrates some 419th CSB offices satisfied A&E requirements with this strategy.

Rather than relying on an IDV, offices would instead satisfy A&E requirements only when the Government identifies a definitive requirement.

This alternative increases acquisition cycle time as each new opportunity requires synopsis, convening an evaluation board, and performing evaluation of many SF 330s (as opposed to seven (7) IDV awardees).

This alternative would not improve or enhance performance or efficiency and would cost unnecessary time as offices establish their own solutions.

This alternative is counter to strategic sourcing guidance and does not support the small business community.

This alternative could divert dollars from small business firms to other than small business firms.

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If a 419th CSB office does not organically possess an A&E contracting skillset, this alternative could result in mission failure.

d. United States Army Corps of Engineers (USACE) Offload.

The 419th CSB could forego establishing any IDVs and offload all A&E requirements to USACE.

USACE district offices generally maintain a robust A&E contract suite.

USACE often awards these contracts to other than small business firms.

Procurement history demonstrates some 419th CSB offices satisfied A&E requirements with this strategy.

This alternative is counter to strategic sourcing guidance and does not support the small business community.

This alternative could divert dollars from small business firms to other than small business firms.

Because USACE traditionally charges customers a service fee, this alternative results in higher costs for 419th CSB supported activities.

An additional risk is USACE rejects a given requirement due to capacity issues. In this instance, 419th CSB supported activities would experience mission failure and lose access to allocated funding.

6. Consolidation Benefit Analysis.

a. FAR 7.107-2(c)(1), Quality improvements that will save time or improve or enhance performance or efficiency.

As the Army continues to experience appropriation and personnel reductions, the Government must develop contracting solutions that proactively gain efficiencies.

A 419th CSB A&E contract suite affords greater opportunities for synergizing among individual office team members.

A 419th CSB A&E contract suite keeps contract holders engaged in Department of Defense work. Over time, learning curve improvements should result in higher quality products at reduced costs.

A synergized A&E effort throughout the 419th CSB leads to flattened communication, shared lessons learned, more robust execution, and an overall better product for the Government and industry.

As the contracting activity executing the Category Management solution, THE MICC Fort Campbell can act as a subject matter expert, offering mentorship and guidance to other 419th CSB offices. This solution ultimately enables offices lacking organic A&E experience to meet mission requirements.

b. FAR 7.107-2(c)(2), Reduction in acquisition cycle times.

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A strategic sourcing A&E multiple-award IDIQ (MAIDIQ) contract suite will generate time savings and enhance performance and efficiencies across the 419th CSB footprint.

FAR 5.203(d) states “Agencies shall allow at least a 30 day response time from the date of publication of a proper notice of intent to contract for architect-engineer services…” Establishing a strategic sourcing A&E MAIDIQ contract suite eliminates this requirement for all TOs (see FAR 5.202(a)(6)).

c. FAR 7.107-2(c)(4), Any other benefit.

The Government anticipates executing this requirement as a total small business set-aside (SBSA). See paragraph b. below.

As a 100 percent SBSA, this consolidation produces a net-positive outcome for the small business community.

As demonstrated in the procurement history, some offices within the 419th

CSB satisfied their A&E requirements with awards to other than small business firms.

Consolidation ensures more dollars go to small business firms and ultimately supports the Federal Government’s commitment to the small business community.

7. Considerations, Facts, Reasoning Supporting the Determination. MICC Fort Campbell coordinated this consolidation with the supporting Office of Small Business Programs (OSBP). OSBP confirmed concurrence with this strategy and will provide concurrence on Defense Department (DD) form 2579, “Small Business Coordination Record,” supporting this consolidation.

8. Summary. As detailed throughout, consolidation is in the best interest of the Government. Consolidating requirements satisfies strategic sourcing mandates, provides quality and time improvements, and directs more dollars to small business firms.

8 AUG 24

DETERMINATION

Based on the foregoing rationale, I hereby determine, pursuant to FAR 7.107-2 and AFARS 5107.107, that the consolidation of the requirements for A&E services is both necessary and justified and will serve the best interests of the Government. This consolidation is critical to the agency’s mission success and the strategy provides for maximum practicable participation by small business.

DOUGLAS N. RALPH, JR.

COL, LG

Senior Contracting Official