Consolidation Memorandum - SPE7LX22R0017.pdf

Consolidation Determination CL21200002/SPE7LX22R0017

CUI

Source Selection Information-- See FAR 2.101 and 3.104 activity of these items. In an effort to promote small business participation the Government will solicit this procurement as split award to multiple awardees. A separate contract will be awarded to each successful offeror.

Steps have also been taken to include small businesses in the acquisition strategy are listed as follows:

o Sources Sought notice was posted on Sam.gov on September 28, 2021, until October 7, 2021.

o A subcontracting plan in compliance with FAR 19.704 is required should the project be awarded to a large business. As a result, teaming arrangements between interested large businesses and small business subcontractors may be developed. In accordance with FAR 19.705-7, the contract will include a provision for liquidated damages in accordance with 15 U.S.C. 637(d)(4)(F), which may be imposed if a large business awardee fails to make a good-faith effort to comply with its subcontracting plan.

In accordance with FAR 7.107-2(a)(3), this consolidation determination has been coordinated with the Agency’s Office of Small Business. DD Form 2579 was reviewed and signed by the Small Business Administration (SBA) on December 7, 2021.

Benefit Analysis:

The details of the proposed approach are discussed in the Acquisition Plan. The proposed acquisition approach results in the following benefits:

1. Acquisition Cycle: Administrative Lead Time (ALT) will be reduced because items will not have to be procured via individual purchase orders (spot buys) each time a requirement arises.

Requirements will source automatically to the proposed LTC using DLA’s automated procurement system, which will generate delivery orders against the contract. As of October 2021, in the DLA Land and Maritime Supply Chain, the average ALT for delivery orders on LTC was 3.0 days, 70.6 days for small manual buys, 71.1 days for all manual purchases, and 20.5 for Procurement Automated Contract Evaluation (PACE) awards. Using this data for comparison, there is a minimum savings of 67.6 days when comparing the proposed LTC approach to small manual buys,

68.1 days compared to all manual purchases, and 17.5 days compared to PACE awards.

2. Relationship Management: Orders from a LTC will provide a continuous relationship between the contractors and the contracting activity. After award issuance, the contract(s) will be assigned to a Basic Contract Administrator (BCA). The BCA and an Administrative Contracting Officer (responsible for post award actions on delivery orders) will be responsible for ensuring Purchase Requests are sourced properly to this contract and tracking delivery. The BCA will also be responsible for exercising any options until contract expiration. Having a primary contact within the administration area will ensure that potential quality/delivery issues will be resolved more efficiently and quickly than individual spot buys. Also, contractors are more likely to be proactive in seeking avenues to resolve quality/delivery discrepancies since the items are on contract for an extended period of time.

Consolidation Determination CL21200002/SPE7LX22R0017

Source Selection Information-- See FAR 2.101 and 3.104

Another less consolidated contracting strategy would be to procure these items using Automated Indefinite Delivery Contracts (IDCs). However, Auto IDCs have a $250,000 threshold per item and are typically shorter than LTCs. NSN 2540-01-329-8072 has a ADV of and NSN 2590-01-598-7783 has a ADV of therefore these NSNs should not be placed on Auto IDCs. This approach would therefore not achieve the efficiencies and other benefits of the proposed approach.

A third approach that is only slightly less consolidated than that proposed is to separately solicit for and award individual LTCs for each NSN. While this approach seeks to leverage the contract, administration advantages of long-term delivery order contracts, it provides very little practical difference from the first alternative above. This approach would require greater resources both to award and administer (even if the contracts were awarded to the same vendor) and would take substantially longer to award than the proposed approach. Therefore, this alternative contracting strategy is substantially less beneficial than the proposed approach because it significantly decreases efficiencies during the pre-award cycle and provides no better benefits associated with competition than the proposed approach, as both approaches allow for the individual evaluation and award of each NSN.

Determination:

For the reasons stated above, I hereby determine:

a. This proposed acquisition constitutes a consolidation of contract requirements.

b. The contract requirements being consolidated exceed $2 million.

c. There are benefits of consolidating the contract requirements, which include both quantifiable and non-quantifiable benefits.

d. The expected benefits do not meet the thresholds for a substantial benefit at FAR 7.107- 2(d)(1), but are critical to the Agency’s mission success.

e. The procurement strategy provides for maximum practicable participation by small business.

f. The consolidation of contract requirements is necessary and justified.

LINDA J. KELLY Date Chief of the Contracting Office Strategic Acquisition Programs Directorate

KELLY.LINDA.J

O.1230137320

Digitally signed by

KELLY.LINDA.JO.1230137

Date: 2022.01.03 10:17:55 -05'00'