CUI_FSH JA 2023_02_Redacted.pdf

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Control Number: MICC 2023-2 Program: Environmental Remediation

Justification Review Document for Other than Full and Open Competition - FAR Part 6

Program/Equipment: ERMA JR IDIQ Ordering Period Extension

Authority: Title 10 United States Code 2304(c)(1) as implemented in Federal Acquisition Regulation (FAR) 6.302-1, Only one responsible source and no other supplies or services will satisfy agency requirements.

Amount:

Prepared by:

Contracting Officer:

Technical:

Requirements:

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

Program Manager: DSN: 450-1256

Date: See Digital Signature

MICC Legal Counsel:

Program: Environmental Remediation

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Small Business Professional:

Date: See Digital Signature

Director, MICC-Fort Sam Houston:

Date: See Digital Signature

Director FDO-Fort Sam Houston

Date: See Digital Signature

Director, MICC- Small Business Program:

Date: See Digital Signature

Alternate Advocate for Competition:

Program: Environmental Remediation

Justification and Approval for Other than Full and Open Competition � FAR Part 6

1. Contracting Activity: U.S. Army Mission and Installation Contracting Command � Fort Sam Houston (MICC-FSH), 2205 Infantry Post Road, Fort Sam Houston, TX 78234.

2. Description of Action: The U.S. Army Environmental Command (USAEC) requests a firm-fixed-price (FFP) modification to extend the ordering period of the Environmental Remediation Multiple Award (ERMA) Junior, Indefinite Delivery/Indefinite Quantity (IDIQ) contracts. The ERMA Junior (JR) IDIQ contracts were awarded with a five (5) year ordering period and a ten (10) year period of performance from 30 November 2017 through 29 November 2027 for task order performance. The five (5) year ordering period is set to expire on 29 November 2022. The anticipated modification will extend the ordering period of the ERMA JR IDIQ contracts for an additional nine (9) months, which will allow the completion of the competitive acquisition process and award of the follow-on ERMA23 IDIQ contract. This proposed sole source action will result in a contract modification to the following ERMA JR IDIQ Contracts: W9124J-18-D-0001, W9124J-18-D-0002, W9124J-18-D-0003, W9124J-18-D-0004, W9124J-18-D-0005, W9124J-18-D-0006, W9124J-18-D-0007 and W9124J-18-D-0008. MICC-FSH procured the ERMA JR IDIQ as a 100% small business (SB) set-aside and awarded eight (8) FFP IDIQs with a minimum guarantee of $10,000 and maximum ceiling amount of $200 million. The total of all task orders awarded to date is which leaves a remaining ceiling of approximately . MICC-FSH and USAEC are currently working seven (7) requirements which are estimated at thus the remaining ceiling capacity is sufficient for the task orders that will be issued during the ordering period extension. Accordingly, no additional ceiling will be required for the ERMA JR IDIQ contract.

3. Description of Supplies/Services:

a. The ERMA JR IDIQ contract is currently providing support to USAEC with a broad-spectrum of environmental remediation services at various Installations/locations throughout the United States including the territories of Puerto Rico and the Virgin Islands. The ERMA JR IDIQ contract holders perform a wide range of evaluation, investigation, and other remediation services required for sites involving hazardous and toxic waste. Services include the performance of munitions response activities that may involve the remediation and the disposition of munitions and explosives of concern (MEC), which include unexploded ordnance (UXO), discarded military munitions (DMM), and munitions constituents (MC). In addition, contractors also perform Phase II � quantitative assessments on operational ranges to provide information (necessary to support continuity of training and testing). Contractors also perform investigations to determine if there has been a release of munitions constituents of concern (MCOC) to an off-range area, and if that off-range release of MCOC poses an unacceptable risk to

Program: Environmental Remediation human health or the environment. Services do not include chemical warfare materiel (CWM) work; however, the contractors shall be familiar with and be able to recognize CWM to be able to stop work and notify the Army of these potential hazards.

b. ERMA JR IDIQ contract holders also provide services to achieve Remedy-in-

Place (RIP) or Response Complete (RC) as defined and used in the Defense Environmental Restoration Program (DERP) Management Manual. In this instance, the contractors attain a RIP or RC upon finalizing appropriate written documentation certifying that the remedial activities conducted at the site have met the identified response objectives and no further action is necessary, subject to any requirement for remedial action operations (RAO)/corrective measures implementation operations (CMIO) and long-term management (LTM). Other service requirements to be achieved at identified site(s), include but are not limited to, an Army and regulator approved remedial investigation (RI)/Resource Conservation and Recovery Act (RCRA) facility investigation (RFI), an Army and regulator approved feasibility (FS)/corrective measures study (CMS), or an Army approved Phase II Quantitative Range Assessment.

c. ERMA JR IDIQ Ordering Period Extension: Nine (9) months from 30 November

2022 to 29 August 2023.

d. Total Value of Extension: ERMA JR IDIQ Remaining Ceiling is .

4. Authority Cited: Title 10 U.S.C. 3204(a)(1) as implemented in FAR 6.302-1, Only one responsible source and no other supplies or services will satisfy agency requirements.

5. Reason for Authority Cited:

a. As described at FAR 6.302-1(a)(2), when the supplies or services required by the agency are available only from one responsible source, or for DoD, NASA, and the Coast Guard, from only one or a limited number of responsible sources, and no other types of supplies or services will satisfy agency requirements, full and open competition need not be provided for. As further described in FAR 6.302-1(a)(2)(iii)(B), services may be deemed to be available only from the original source for the continued support of highly specialized skills when it is likely that award to any other source would result in unacceptable delays in fulfilling the agency�s requirements. This contract modification to extend the ERMA JR IDIQ ordering period is necessary to complete the competitive acquisition process of the follow-on ERMA23 IDIQ and continue mission critical environmental remediation services necessary to protect, preserve, conserve and restore the Army�s lands/installations for the health and safety of soldiers, families, surrounding communities and the environment.

b. Due to the size and complexity of ERMA23 IDIQ, acquisition planning began

November 2020, 24 months prior to the ERMA JR IDIQ ordering period expiration;

Program: Environmental Remediation however, ERMA23 IDIQ encountered several delays in the development of the requirements documentation due to the addition of a new requirement that did not exist in the ERMA JR IDIQ. This new requirement involves providing remediation services to assess, investigate, study, treat/remediate and monitor an emerging chemical material of environmental concern known as Perflouroalkyl and Polyfluoroalkyl substances (PFAS). PFAS encompasses a suite/class of chemicals which amongst others includes perfluorooctanoic acid (PFOS) and perfluorooctanoic acid (PFOA). PFAS are a diverse group of compounds resistant to heat, water, and oil. These chemicals are persistent, and resist degradation in the environment and as such have been referred to as �forever chemicals.� For decades, they have been used in hundreds of industrial applications and consumer products such as carpeting, apparel, upholstery, food paper wrappings, fire-fighting foams, and metal plating. At high concentrations, certain PFAS have been linked to adverse health effects in laboratory animals that may reflect associations between exposure to these chemicals and health problems in humans such as low birth weight, delayed puberty onset, elevated cholesterol levels, and reduced immunologic responses to vaccination.

c. This information on PFAS has caused federal concern and ongoing federal guidance which in turn has impacted and delayed the development of ERMA23 IDIQ requirements documentation. For example, in 2018, the Department of the Army released guidance to evaluate and initiate investigations and possible response actions to address potential PFAS releases across Army installations. On June 2020, the Office of the Under Secretary of Defense for Acquisition and Sustainment submitted a report for Congress �DoD Remediation Plan for Cleanup of Water Contaminated with PFAS/PFOA� which requests the Secretary of Defense submit a remediation plan for cleanup of all water at or adjacent to a military installation that is impacted with PFAS/PFOA and conduct a study on all impacted water at military installations with PFAS/PFOA. Furthermore, on 10 October 2021, the Environmental Protection Agency (EPA) launched a robust, new PFAS roadmap that will guide the agency�s current and planned activities in 2021-2024 to research, restrict, and remediate harmful PFAS. Then on 06 July 2022, the Office of the Assistant Secretary of Defense released a memorandum with updates to the investigation of PFAS within the Department of Defense Cleanup Program concerning the screening levels of several PFAS compounds found in water and soil. More recently, on 26 August 2022, the EPA issued a proposal to designate two of the most widely used PFAS, known to be PFOA and PFOS, as hazardous substances instead of chemicals of concern under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA).

d. Consequently, the ongoing federal guidance on PFAS such as those outlined in this document and other federal guidance released since 2018, prompted changes and revisions to the IDIQ Performance Work Statement (PWS), sample task order PWS(s), Independent Government Cost Estimate (IGCE) and other USAEC internal documents that are a prerequisite to obtain the Service Contract Approval. For example, USAEC had to obtain and gather information on all preliminary assessments and site

Perfluoroalkyl

Program: Environmental Remediation

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investigations performed at Army Installations to include Active Installations, Reserve Component Installations and Base Realignment and Closure (BRAC) non-excess Installations to estimate the amount of PFAS work required under ERMA23. Information and data were also obtained to estimate the type and scope of remediation work required at Army installations due to the impact of PFAS. Aside from the multiple revisions to the IDIQ PWS to include up-to-date federal law and regulations, and updates to the IGCE to capture accurate costs associated with anticipated PFAS work, the acquisition team also needed to develop a sample task order (STO) that represents PFAS anticipated work and current federal environmental law and regulations. Other delays encountered during the market research stage were the time and effort expended to identify potential sources capable to perform the anticipated work associated with PFAS, and to determine if there was a need for a small business suite and an unrestricted business suite. To determine the sources available in the open commercial market, two (2) sources sought notices (SSN) were posted on the Government-Wide Point of Entry (GPE) through https://sam.gov/. The first SSN was posted from 23 June 2021 through 15 July 2021 and the second SSN was posted from 17 through 29 November 2021.

e. Based on the delays encountered under the ERMA23 IDIQ acquisition process, the follow-on Multiple Award Indefinite Delivery/Indefinite Quantity (MAIDIQ) will not be in place before the expiration of ERMA JR IDIQ’s ordering period which is set to expire on 29 November 2022. The ERMA23 combined Acquisition Strategy/Acquisition Plan was approved by the Deputy Assistant Secretary of the Army for Procurement on 22 September 2022. Based on the remaining major acquisition milestones for ERMA23 depicted under table 1, it is impossible to award the ERMA23 IDIQ by 29 November 2022. USAEC is in critical need of the nine (9) month ordering period extension to the ERMA JR IDIQ to allow continued remediation efforts while MICC-FSH properly and efficiently completes the competitive acquisition process of ERMA23 IDIQ.

Table 1: ERMA23 IDIQ Remaining Milestones

Major Milestones Remaining Date Complete

Acquisition Plan-Strategy Combo Approval 22 SEP 22

Draft RFP Approval 30 NOV 22

Issue Draft RFP 01 DEC 22

Close Draft RFP 30 DEC 22

Source Selection Plan Finalized 09 DEC 22

Solicitation Review Board (SRB) Start 12 DEC 22

Solicitation Review Board (SRB) Complete 31 JAN 23

Issue Solicitation 01 FEB 23

Solicitation Closes 03 MAR 23

Program: Environmental Remediation

Major Milestones Remaining Date Complete

Evaluate Proposals Start (initial) 06 MAR 23

Evaluate Proposals Complete (initial) 07 APR 23

Discussions Start 17 APR 23

Discussions Complete 08 MAY 23

Re-Evaluate Proposals Start 10 MAY 23

Re-Evaluate Proposals Complete 09 JUN 23

POM/PNM; SSDD Complete 10 JUL 23

Contract Review Board Start 13 JUL 23

Contract Review Board Complete 15 AUG 23

Award 29 AUG 23

f. Impact if justification is not approved. If this justification is not approved, USAEC will be unable to execute the seven (7) pending requirements anticipated to be competed and awarded under ERMA JR IDIQ during the ordering period extension.

Delays in awarding these seven (7) task orders for environmental services can result in the Army being non-compliant with state and federal regulations thus creating environmental infractions leading up to fines of day or more. As a result, the approval to extend the ERMA JR IDIQ ordering period through a contract modification will reduce the risk of critical environmental remediation services being delayed thus lessening the risk of violations and fines from regulatory agencies.

g. Alternatives. Below are the alternative contracting approaches and the rationale for rejection.

1) If the justification is not approved, an alternative will be for USAEC to seek contracting support from the U.S. Army Corps of Engineers (USACE) and use of their contract vehicles; however, USAEC�s task order requirements may be at risk of award since this support is not guaranteed as it will be dependent upon the remaining contract ceilings of USACE�s IDIQs and USACE availability of resources to provide the needed contracting support. Additionally, it is not in the best interest of USAEC to utilize the USACE contracts due to the average percent fee charged to process each service requirement. Given the USACE service fee, and the seven (7) requirements being estimated at , USAEC will incur approximately in costs for the acquisition of the needed environmental remediation services. Moreover, because these seven (7) requirements will not be awarded before the ERMA JR IDIQ ordering period expires, USAEC will need to process these requirements through USACE. Re-directing these seven (7) requirements to USACE will also duplicate the time and effort spent on achieving the acquisition progress made with MICC-FSH. Consequently, having to initiate the acquisition process from the beginning through USACE, will further

Program: Environmental Remediation cause unacceptable delays in the award of the needed task orders by approximately seven (7) months. The seven (7) month timeframe is USACE estimated procurement acquisition lead time (PALT) for a requirement based on USAEC experience with USACE�s acquisition process.

2.) A second alternative will be the award of a short-term MAIDIQ however, this alternative will cause unacceptable delays in fulfilling USAEC�s requirements. Acquiring a short-term MAIDIQ will delay the task order awards by about eight (8) months since it can take up to eight (8) months to award a short-term MAIDIQ with a ceiling of according to the DASA(P) PALT generated by the Army�s Virtual Contracting Enterprise (VCE) Paperless Contract File (PCF) milestone tool.

3.) A third alternative will be to procure each individual USAEC requirement as standalone contracts instead of task orders. However, acquiring USAEC�s requirements as standalone contracts will result in unacceptable delays in fulfilling USAEC�s requirements. The procurement of a standalone contract instead of issuing task order will delay the award of requirements by approximately 60 days. According to the Army�s VCE PCF milestone tool, the DASA(P) PALT for a standalone contract and task order estimated at are both forecasted at 105 days after receiving a complete requirement�s packet documentation. However, MICC-FSH estimates the PALT for a task order award to be at least 60 days shorter than the award of a standalone contract due to eliminating the need to prepare a market research report; the preparation, approval and release of a sources sought synopsis, the review of capabilities statements from interested sources, and the development and approval of an acquisition strategy.

h. The approval of the ERMA JR IDIQ extension will not only eliminate the unacceptable delays mentioned above but will also provide costs savings as a result from shorter PALTs, expedited ordering processes, and working with experienced contractors. The ERMA JR IDIQ contractors are a smaller pool of vetted experienced awardees, and several have already been awarded task orders that include options that extend into 2027, as the life of the contract for task order option periods is 10 years.

Consequently, by extending the ordering period by nine (9) months, the ERMA JR contractors can harness efficiencies due to work on existing projects and reduced startup and on-boarding costs, which in turn results in additional Government savings.

6. Efforts to Obtain Competition: In accordance with the Defense Federal Acquisition Regulation Supplement (DFARS) Procedures, Guidance, and Information (PGI) 206.302-1(d), a SSN was published from 26 August 2022 through 12 September 2022.

Although several sources demonstrated their interest through the submission of their capability statements, the time remaining before the ERMA JR IDIQ expires is insufficient for the procurement of a short-term MAIDIQ as previously stated under paragraph 5 of this Justification and Approval (J&A).

Program: Environmental Remediation

a. Effective competition. Thirteen (13) responses (9 small business and 4 other than small business) to the SSN were received from industry and interested sources were encouraged to participate on the follow-on ERMA23 IDIQ acquisition since it will be awarded on a competitive basis with two (2) business suites (100% set aside small business suite and an unrestricted business suite).

b. Subcontracting competition. In accordance with FAR 19.702, subcontracting plans are not required from the current ERMA JR contractors due to being small business firms nor will subcontracting plans be required from the follow-on ERMA23 small business suite IDIQ awardees. Pursuant to FAR Clause 52.219-28, Post-Award Small Business Program Representation, all ERMA JR contractors have re-represented themselves as small businesses and validated that their Representations and Certifications data under the System for Award Management (SAM) are up to date.

Subcontracting plans will be required for the ERMA23 unrestricted business suite from the other than small IDIQ awardees unless a determinations and findings (D&F) is approved detailing the reason(s) why no subcontracting opportunities exist. However, based on this requirement�s procurement history subcontracting possibilities exist.

7. Actions to Increase Competition: The contracting office is actively working the acquisition for the follow-on competitive ERMA23 IDIQ. Aside from the three (3) SSN published for this acquisition in the past two (2) years, a draft request for proposal (RFP) for the follow-on ERMA23 IDIQ will also be released to industry for questions, comments, and suggestions. During the draft RFP, potential offerors will have the opportunity to pre-view and familiarize themselves with the RFP requirements thus increasing competition during the official release of the RFP. To expedite the evaluation of proposals, the Government will limit the size of the proposals, request only the necessary requirements, limit the number of factors/subfactors and ensure selection of factors/subfactors that will easily differentiate between the most and least advantageous proposals. These actions taken by the Government to expediate the evaluation process will further increase competition by encouraging participation from industry because it will reduce the time and effort in the preparation of proposals.

8. Market Research:

a. In accordance with DFARS PGI 206.302-1(d), the market research in support of this J&A included posting of a SSN to the GPE through https://sam.gov.

1) The SSN requested all interested sources to provide the following information:

- Identify whether your firm is interested in competing for this requirement as a prime contractor or not. Identify subcontracting, joint ventures or teaming arrangement that will be pursued, if any.

- Provide a brief outline of past performance/previous experience within the past 5 years on similar requirements to those described in PWS (include size, scope, complexity, timeframe, government or commercial) and indicate if work was performed as a prime contractor or subcontractor.

- Recommendations to improve the Army's approach/specifications/PWS to acquiring the identified items/services.

- Identify how the Army can best structure these contract requirements to facilitate competition, including competition among small business concerns.

- Identify any condition or action that may be having the effect of unnecessarily restricting competition with respect to this acquisition.

2) As mentioned previously, thirteen (13) responses were received in response to the SSN. From the responses submitted, nine (9) were small business concerns. The current ERMA JR IDIQ was procured as a 100% small business set-aside but the follow-on ERMA23 IDIQ will be solicited as a partial set aside in accordance with FAR 19.502-4 - Partial set-asides of multiple-award contracts, with the small business suite being a 100% set-aside. Therefore this action does not have a negative impact on small businesses.

b. Although there were interested sources identified for this action, the current ERMA JR IDIQ ordering period is set to expire on 29 November 2022, which is insufficient time for the award of a short-term MAIDIQ with a estimated ceiling. The DASA(P) forecasted PALT for this type of acquisition is 250 days after the submission of a complete set of requirements documentation according to the VCE PCF milestone tool. Therefore, attempting to award a short-term MAIDIQ will result in unacceptable delays and duplication of costs as noted under paragraph 5 of this J&A.

9. Interested Sources: As mentioned previously, thirteen (13) responses (9 small and 4 other than small business) were received from the SSN published for this J&A. To date, no other sources have written to express an interest.

10. Other Facts:

a. Procurement History.

1) The previous MAIDIQ that supported this requirement was the ERMA Senior (SR) IDIQ which has a five (5) year base ordering period with a ten (10) year period of performance for task order performance from 30 November 2012 through 29 November 2022. The ERMA SR IDIQ was awarded by the Army Contracting Command (ACC) Aberdeen Proving Ground (APG); however, its management, administration and issuance of task orders was transferred to MICC-FSH during the first quarter of FY

2013. The ERMA SR IDIQ had the ability to support FFP, cost-plus-fixed-fee (CPFF), fixed-price incentive fee (FPIF), and cost-plus incentive fee (CPIF) task order efforts.

The ERMA SR IDIQ was awarded with two business suites (a small business suite with one award reserved for a service-disabled veteran owned small business (SDVOSB) and an unrestricted business suite). The minimum guarantee for each suite was $10,000 and the total aggregate maximum ceiling amount for each portfolio was $240 million. The total value of task orders awarded to the small business suite was approximately , and the total value of task orders awarded to the unrestricted business suite was approximately . The small business suite included nine

(9) contractors and the unrestricted business suite included ten (10) contractors as follows:

ERMA SR IDIQ Contractors

Small Business Suite Cage IDIQ Number

1. Bay West, LLC 0W830 W91ZLK-13-D-0002

2. Cape Environmental Management, Inc. 1RW03 W91ZLK-13-D-0003

3. EA Engineering, Science, and Technology, Inc. 7V713 W91ZLK-13-D-0004

4. FPM Remediation, Inc. 3LNB7 W91ZLK-13-D-0005

5. HydroGeoLogic, Inc. 0UFZ2 W91ZLK-13-D-0006

6. J2 USA LLC 6JHS9 W91ZLK-13-D-0007

7. Kemron Environmental Services, Inc. 0GZ69 W91ZLK-13-D-0008

8. PIKA-Arcadis JV 6GRJ2 W91ZLK-13-D-0009

9. Plexus Scientific Corporation 1RFC1 W91ZLK-13-D-0010

Unrestricted Business Suite Cage IDIQ Number

1. AMEC Foster Wheeler Environment 1U1W9 W91ZLK-13-D-0011

2. ARCADIS U.S., Inc 005Q6 W91ZLK-13-D-0012

3. CH2M Hill Constructors, Inc. 0ZKG1 W91ZLK-13-D-0013

4. Environmental Chemical Corporation 0T0F8 W91ZLK-13-D-0014

5. Gilbane Federal 012A2 W91ZLK-13-D-0015

6. Parsons Government Services, Inc. 1BVK6 W91ZLK-13-D-0016

7. Leidos, Inc. DBA: 5UTE2 W91ZLK-13-D-0017

8. CB&I Federal Services LLC 1YQ36 W91ZLK-13-D-0018

9. URS Group, Inc. 1PA91 W91ZLK-13-D-0019

10. Weston Solutions, Inc. 2M222 W91ZLK-13-D-0020

2) This requirement was also previously supported by the Assistant Chief of Staff for Installation Management (ACSIM) MAIDIQ with an ordering period of 30 April 2005 through 30 June 2010 and an end date of 31 December 2015 for task order performance. The ACSIM MAIDIQ was awarded by ACC-APG however, its management and administration were transferred to MICC-FSH during the 3rd quarter of FY 2011. The ACSIM MAIDIQ had the ability to support FFP and fixed-price (FP) with award fee and were awarded with two business suites (a small business suite and an unrestricted business suite). The small business suite had a maximum ceiling amount of $160 million and the unrestricted business suite had a maximum celling amount of $320 million. The total value of task orders awarded to the small business suite was approximately and the total value of task orders awarded to the unrestricted business suite was approximately . The small business suite included five (5) contractors and the unrestricted business suite included six (6) contractors as follows:

ACSIM MAIDIQ Contractors

Small Business Suite Cage IDIQ Number

1. Environmental Chemical Corporation 0T0F8 W91ZLK-05-D-0009

2. Hydrogeologic Inc. 0UFZ2 W91ZLK-05-D-0010

3. Plexus Scientific Corporation 1TLM4 W91ZLK-05-D-0011

4. Toltest Inc. 9Y155 W91ZLK-05-D-0012

5. Kemron Environmental Services, Inc. 0GZ69 W91ZLK-05-D-0013

Unrestricted Business Suite Cage IDIQ Number

1. CH2M Hill Constructors, Inc. 0ZKG1 W91ZLK-05-D-0014

2. Arcadis Inc. 005Q6 W91ZLK-05-D-0015

3. Parsons Infrastructure & Tech Group 1BVK6 W91ZLK-05-D-0016

4. Shaw Environmental, Inc. 1YND6 W91ZLK-05-D-0017

5. Weston Solutions, Inc. 2M222 W91ZLK-05-D-0018

6. URS Group, Inc. 1N9M8 W91ZLK-05-D-0019

Program: Environmental Remediation

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.

USAEC, West & Pacific Environmental Services & Support Division

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.

USAEC, Operations, Planning & Programming Division

13. Fair and Reasonable Cost Determination: I hereby determine that the anticipated cost to the Government for this contract action will be fair and reasonable. This action does not increase the ceiling of the current effort and no funds are required for this contract action. The fair and reasonable determination will be made at the task order level using price analysis to compare the proposed prices received in response to the solicitation, or comparison of the proposed price with prices found reasonable on previous purchases or to the IGCE. USAEC utilizes environmental cost estimators to develop cost to complete (CTC) estimates for sites that require cleanup/remediation work. These CTC estimates assist in the preparation of task order IGCEs. 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.

Contracting Officer

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

Contracting Officer

Approval

Based on the foregoing justification, I hereby approve the contract modification to extend the current Environmental Remediation Indefinite Delivery / Indefinite Quantity ordering period on an other than full and open competition basis pursuant to the authority of Title 10 United States Code 3204(a)(1) as implemented in Federal Acquisition Regulation 6.302-1 - Only one responsible source and no other supplies or services will satisfy agency requirements. The ordering period will be extended from 30 November 2022 through 29 August 2023 with an estimated value of with funding applied at the task order level. The approval is subject to availability of funds, and provided that the services or supplies herein described have otherwise been authorized for acquisition.

Wade C. Cole Senior Contracting Official U.S. Army Mission and Installation Contracting Command, JBSA Fort Sam Houston, TX