CUI_Belvoir JA 2025_80_Redacted.pdf

Control No.: MICC 2025-80

Justification Review Document For Sole Source - FAR 13.501

Program/Equipment: Fort Belvoir, Directorate of Public Works requires a solid waste/refuse follow-on (bridge) contract in support of Fort Belvoir.

Authority: Simplified Procedures for Certain Commercial Items, Title 41 United States Code 1901 as implemented in Federal Acquisition Regulation 13.501(a)(1)(ii), sole source under the authority of the simplified procedures for certain commercial items

Amount: $943,841.00

Prepared by: Julia Woltjen COM: 520-851-1061 Contract Specialist Date: 4/28/2025 julia.r.woltjen.civ@army.mil

Contracting Officer: Jodi E. Woods COM: 520-669-7095 Contracting Officer Date: 4/28/2025 jodi.e.woods.civ@army.mil

Technical: Vijay Ivatury COM: 703-806-0061 Contracting Officer Representative Date: 4/28/2025 vijay.m.ivatury.civ@army.mil

Requirements: Yun Heo COM: 703-806-3017 Director, Directorate of Public Works Date: 4/28/2025 yun.heo.civ@army.mil

Reviews: I have reviewed this justification and find it adequate to support other than full and open competition.

Program Manager/ Director, Directorate of Public Works:

Yun Heo COM: 703-806-3017

_________________________________ Date: See digital signature

Small Business Professional:

DeeAndra L. Heath COM: 703-806-4603

____________________________________ Date: See digital signature

HEO.YUN.1055893400 Digitally signed by HEO.YUN.1055893400 Date: 2025.05.22 16:29:49 -04'00'

HEATH.DEEANDRA.L

ASHEA.1065512145

Digitally signed by HEATH.DEEANDRA.LASHEA.1065512145 Date: 2025.05.23 09:51:28 -04'00'

FAR 13.5 Sole Source Justification and Approval

1. Contracting Activity: U.S. Army Mission and Installation Contracting Command (MICC)-Fort Belvoir, 9410 Jackson Loop, Bldg. 1425, Fort Belvoir, VA 22060.

2. Description of Action: The Directorate of Public Works (DPW) requests a firm-fixed-price contract with WB Waste Solutions, LLC. The Government projects award by the end of May 2025 and fiscal year 2025 Operations and Maintenance, Army (OMA) funds will be used. An acquisition plan is not required because this procurement does not meet the threshold at Defense Federal Acquisition Regulation Supplement 207.103(d)(i)(B).

3. Description of Supplies/Services: The Contractor shall perform refuse disposal service from Fort Belvoir. Dumpster/Receptacle drop-off and pick-up is required as a means to remove trash and other designated materials. The Contractor shall conduct multiple unscheduled collections, disposals, and relocations of containers for special events, clean-up operations or other occasions which the contractor shall respond within 24 hours. Refuse service must be performed in a manner which will not interfere with the dignity of the receptacle locations.

Period of Performance: 01 JUN 2025 – 31 MAR 2026 Value: $943,841.00

4. Authority Cited: Simplified Procedures for Certain Commercial Items, 41 U.S.C.1901 as implemented by FAR 13.501(a), only one responsible source is capable of performing the requirement.

5. Reason for Authority Cited:

a. Background. Bates Trucking company is the incumbent solid waste contractor.

The Director of Bates Trucking company is also the Vice President of WB Waste Solutions. The Director of Bates Trucking company has provided written documentation to MICC-Fort Belvoir requesting that WB Waste Solutions perform the services associated with this justification in lieu of Bates Trucking company. This written request from Bates Trucking did not meet the legal requirements for a novation. If the requirement were to proceed through the standard full and open competition process, there would be an unacceptable delay or break in service. The additional time needed to complete a procurement process would have significant negative consequences, such as jeopardizing critical service, potentially wasting taxpayer money, and causing health and safety harm to Fort Belvoir patrons. Awarding a sole source contract to WB Waste Solutions, LLC will ensure there is no break in service and the government will not incur any duplication in costs. WB Waste Solutions, LLC is already equipped with the necessary material, equipment, and labor that is required for these services for this interim 10-month period and is the only source that could perform the requirement without a substantial duplication of costs or unacceptable delay. The current contract ends on 31 May 2025; the requested 10-month bridge contract will prevent a break-in-services until the new Base Operations (BASOPS) Support Contract can be awarded and a transition occurs with the incoming vendor. The Senior Contracting Official approved the consolidation Determination & Findings on 23 June 2023 that allowed incorporating the solid waste/refuse requirements into the follow-on BASOPS procurement.

The Mission Installation Contracting Command - Installation Readiness Center (MICC-IRC) is procuring the new BASOPS Support Contract for Fort Belvoir. The anticipated award date and phase-in for the BASOPS Support Contract was originally estimated to begin in July 2022. With new services that were added to the BASOPS requirement causing changes, delays, and further revisions, and the requiring activity requesting that new contracts be targeted for award in only the second or third quarter of the fiscal year, it is now projected that the BASOPS Support Contract will be awarded by the end of January 2026 and will begin full performance by 1 April 2026. The current interim bridge contract for solid waste/refuse service is set to expire 31 May 2025 and a 10-month gap in refuse/solid waste collection exists between the end of the current contract and the follow-on BASOPS contract vendor reaching a full-performance level of service.

b. Alternatives. Awarding a bridge contract to WB Waste Solutions, LLC will avoid a substantial break-in service and will save the Army from incurring duplication of costs of approximately $70,000 over the 10-month period. Additionally, any vendor other than WB Waste Solutions would be required to obtain and have available the following material and equipment to support this requirement: 1) the front load trash truck that is estimated at $250,000, 2) three trash compactors which cost a total of $210,000, 3) installation and hook up for compactors (electrical, mechanical and hydraulics) at each location, which is estimated at $150,000, 4) three drivers (one for front load, two for the compactors, estimated at $180,000, and 5) two roll-off trucks to haul the compactors to the landfill at an approximate cost of $150,000. Due to the requirements changes delaying the BASOPS follow-on contract, and the phasing out of solid waste/refuse services as an unconsolidated/standalone contract, any competitive action or sole source action by the government to another contractor would result in an unacceptable delay. A competitive action would take approximately 5 months to award a competitive small business set-aside contract for solid waste: 1) a minimum of six weeks for the required activity to resubmit the requirements documentation; 2) three weeks to generate a request for proposal with all appropriate reviews; 3) four weeks to solicit proposals; and 4) another four weeks to conduct discussions and make award. The standard procurement process would lead to substantial cost duplication that is not expected to be recovered through competition

c. Impact if justification is not approved. With the current contract end of service occurring on 31 May 2025, Fort Belvoir cannot go without solid waste services. The absences of trash collection services would lead to an accumulation of trash which leads to an increase in pests, illness, rodents, which puts the health and safety of the Fort Belvoir populace at risk.

6. Efforts to Obtain Competition: Though market research indicates additional firms exist with capabilities to conduct the work, the challenge of avoiding a break-in-service when considering a new vendor seems to be nearly impossible to avoid. The MICC-Fort Belvoir posted a source sought notice on SAM.Gov on 15 May 2025 and has not received any responses. The intent of the source’s sought notice was to provide information about the interim effort and seek any industry recommendation that could help mitigate startup cost and service breaks that are a significant barrier to competition for a short-term effort.

a. Effective competition. Due to the time constraints involved with procuring this contract, it is not feasible to promote full and open competition.

b. Subcontracting competition. No subcontractors are involved in this contract.

7. Actions to Increase Competition: This is the second bridge contract necessary to preclude a break-in-service until the follow-on BASOPS contract and full performance begins prior to the end of January 2026. This solid waste/refuse requirement will be included in the new BASOPS contract as part of the consolidation efforts identified by the Fort Belvoir DPW. The consolidation request was approved, and the MICC-IRC is procuring the revised BASOPS requirement.

8. Market Research: Based on the market research conducted on 05 May 2025, previous market research conducted for the previous bridge contract W91QV124C0008, and use of the small business administration dynamic small business search, firms have been found under the 562111 NAICS that have self-certified their responsibility. These firms may be capable of performing the services required. However, given the time constraints with the expiration of the current contract on 31 May 2025 and the projected award date for the follow-on contract, a bridge contract with WB Waste Solutions, LLC will be required to avoid a break-in-service.

9. Interested Sources: To date, no other sources have written to express interest in the acquisition.

10. Other Facts:

a. Procurement history.

Contract number: W91QV1-24-C-0008 Vendor: Bates Trucking Company, Inc./WB Waste Solutions LLC Requirement: Solid Waste Award date: 29 December 2024 Competitive Status: Sole-Source (Small Business) Authority: FAR 13.5

Contract number: W91QV1-22-C-0034 Vendor: Bates Trucking Company, Inc.

Requirement: Solid Waste Award date: 30 January 2022 Competitive Status: Sole-Source (Small Business) Authority: FAR 13.5

Contract number: W91QV1-17-C-0003 Vendor: Bates Trucking Company, Inc.

Requirement: Solid Waste Award date: 1 January 2017 Competitive Status: Small Business set-aside

Contract number: W91QV1-11-C-0065 Vendor: Bates Trucking Company, Inc.

Requirement: Solid Waste Award date:29 September 2011 Competitive Status: Small Business set-aside

11. Technical Certification: I certify that the supporting data under my cognizance, which are included in the justification, are accurate and complete to the best of my knowledge and belief.

________________________________ Date: See digital signature Vijay Ivatury Contracting Officer Representative

12. Requirements Certification: I certify that the supporting data under my cognizance which are included in the justification, are accurate and complete to the best of my knowledge and belief.

Yun Heo Director, Directorate of Public Works

13. Fair and Reasonable Cost Determination: I hereby determine that the anticipated cost or price to the Government for this contract action will be fair and reasonable. This determination will be made using the IGCE. As a part of this basis, certified cost or pricing data is not required because the item and/or services being acquired are considered commercial.

Jodi Woods Contracting Officer

14. Contracting Officer Certification: I certify that this justification is accurate and complete to the best of my knowledge and belief.

Jodi Woods Contracting Officer

HEO.YUN.1055893400 Digitally signed by HEO.YUN.1055893400 Date: 2025.05.22 16:32:11 -04'00'

WOODS.JODI.EAR

LYNE.1048918391

Digitally signed by

WOODS.JODI.EARLYNE.1048918

Date: 2025.05.23 07:59:32 -04'00'

WOODS.JODI.EAR

LYNE.1048918391

Digitally signed by

WOODS.JODI.EARLYNE.1048918

Date: 2025.05.23 08:00:14 -04'00'

IVATURY.VIJAY.

M.1200707199

Digitally signed by

IVATURY.VIJAY.M.1200707199

Date: 2025.05.27 06:38:12 -04'00'