ETFO Amend 1_HDTRA119F0039 Georgia_CA REDACTED VERSION_Redacted.pdf
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- Attached to
- DTRA Exception to Fair Opportunity GLBP Increment II Federal contract opportunity
- Solicitation number
- HDTRA1-19-F-0039
- Issued by
- Defense Threat Reduction Agency
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Def nse Thr a Reduc on Ag ncy 7 n K p v VA 1
August 16, 2021
EXCEPTION TO FAIR OPPORTUNITY JUSTIFICATION
Amendment 1 - Georgia Land Border Project Increment II
1. Nature and/or Description of the Action
The Defense Threat Reduction Agency’s (DTRA) Weapons of Mass Destruction Proliferation Prevention Program (WMD-PPP) seeks an exception to fair opportunity (ETFO) for additional work on the Georgia Land Border Project Increment II (GLBP-II). The GLBP-II task order (TO) HDTRA1-19-F-0039 is currently executed under the Cooperative Threat Reduction Integrating Contractor (CTRIC) III Multiple Award Indefinite Delivery/Indefinite Quantity (ID/IQ) contract vehicle. The TO was solicited to all six ID/IQ holders and WMD-PPP received bids from five Offerors. The TO was awarded to Parsons Government Services International (Parsons) on March 5, 2019.
The TO was initially awarded for $12,349,963.61 (inclusive of all options) with a period of performance (PoP) through March 4, 2021. The current contract ceiling is $15,783,463.18 (inclusive of all options) with a PoP through November 4, 2021. The adjustments were due to:
August 2019: added $691,403.91 to accommodate equipment changes/specifications and construction requirements after detailed site surveys and final design reviews; DTRA approved an ETFO for this action on August 7, 2019.
December 2019: added $458,693.31 to implement the FLIR camera depot facility after the design phase identified equipment missing from the plug number; DTRA approved a Request for Equitable Adjustment for this increase.
June 2020: added $199,590.56 to adjust the Video Surveillance approach and include Fiberoptic Installation Equipment.
February 2021: added $2,083,811.79 under FAR clause 52.217-8 Option to Extend Services.
WMD-PPP is now planning to procure equipment to allow the Operative Technical Agency (OTA) to install and integrate up to five additional Mobile Surveillance Systems (MSS) for the Special Tasks Department which patrols Georgia’s Administrative Boundary Lines. Through GLBP-II, WMD-PPP has already provided equipment to OTA for the integration of four MSS of the same design for the Border Police of Georgia (GBP). WMD-PPP is also planning to construct an MSS Integration and Maintenance Facility (IMF) for the OTA which will ensure the proper maintenance and sustainment of equipment and capabilities provided by WMD-PPP as well as other United States Government (USG) donors. To accommodate this addition, this amended ETFO requests an additional increase in the amount of ; establishing a new contract ceiling of and extending the PoP through March 4, 2023. The CTRIC III ID/IQ Ceiling is $970,000,000.00 with $445,358,127.33 in remaining value and has an ordering period through June 4, 2023. Therefore, this action is within the ID/IQ PoP and ceiling value.
HDTRA1-19-F-0039
Exception To Fair Opportunity
2. Description of the Supplies/Services Required
The focus of the TO is to improve the command and control, WMD detection, surveillance, and interdiction capabilities of the Government of Georgia (GoG) along its maritime and green borders. Project efforts such as delivering equipment, equipment-related training, building border sector facilities, and providing a maintenance facility will enhance capabilities in command and control, communications, surveillance, WMD detection, and interdiction, and ensure that the GoG can sustain and build upon these capabilities for the long term.
DTRA proposes to continue the use of the current CTRIC TO with Parsons for the additional scope of work. The additional work includes the following:
Procurement of equipment for up to five MSS Construction of an MSS IMF
PoP extension through May 4, 2022 Estimated dollar value of increase -
3. Exception to Fair Opportunity
The statutory authority for this ETFO and all adjustments identified in Section 1 – Nature and/or Description of the Action, is identified under FAR 16.505(b)(2)(i)(C). The additional activities must be issued on a sole-source basis in the interest of economy and efficiency as a logical follow-on to an order issued under the contract, provided that all awardees were given a fair opportunity to be considered for the original order.
4. Justification Rationale
Parsons was awarded the TO through a competitive solicitation under the CTRIC III ID/IQ and they are currently implementing the TO’s required tasks, to include procurement of various equipment.
Parsons recently procured the same equipment for the OTA to integrate four MSS of the same design. As part of the equipment list validation process for the previous procurement of the MSS equipment, Parsons’ engineers closely coordinated with the OTA to ensure all items from their design were listed and compatible. While all items are commercially available and other companies would be capable of procuring the same items, it would cost the government more time and money for someone other than Parsons to do this work. For a new company to perform this work, if they do not have a registered office in Georgia it would require Embassy resources to support VAT exemption and customs clearance (putting an unnecessary burden on Embassy resources as well as creating the possibility for delays), while Parsons already has a registered office and can execute these tasks without support. Another company would also have to establish a dedicated program management office (PMO) team to confirm requirements, procure the materials, and conduct delivery and transfer of property, while Parsons existing program management infrastructure would require minimal increased level of effort to support the additional procurement. Parsons also already has an established relationship with OTA as well as all of the vendors for each piece of equipment. A new company would require significantly more USG involvement in the requirements confirmation and overall coordination processes.
While there are other companies that would be able to execute this equipment procurement, no other option would be as cost effective or as minimally burdensome to USG time and resources as awarding this to Parsons as part of GLBP-II. No additional efficiencies are expected through competition for this task and DTRA can use real costs as a means to evaluate the appropriateness of proposed costs.
HDTRA1-19-F-0039
Exception To Fair Opportunity
The MSS IMF would provide the OTA with a proper facility to integrate MSS using the equipment mentioned above as well as equipment from other USG donors. On the current TO, Parsons has established a maintenance facility for other equipment at the same location planned for this facility. On the current TO, they have also successfully completed other construction efforts in Georgia, demonstrating their familiarity with Georgian laws and regulations. While construction of the MSS IMF is not complex and could be undertaken by another performer, it would not be as economically efficient. The additional cost to the USG to issue a new contract/TO Award as well as costs incurred by the performer for mobilization and PMO establishment is not expected to be recovered through competition, especially since Parsons has already achieved notable efficiencies.
5. Market Research
An updated Market Research was conducted in August 2021. The market research determined that the tasks could be performed by CTRIC III and non-CTRIC companies.
6. Other Supporting Facts
Parsons established a relationship of trust with the OTA through their work providing equipment and a maintenance facility for the current TO. As with the previous additiona work, this existing relationship will save time and effort and ensure a seamless inclusion of the new work. The final price of this contract action to the Government will be determined to be fair and reasonable based on the IGCE and cost and/or price analysis. The award of this effort to any other contractor would result in anywhere from an estimated $298,405 to $364,718 increase in cost to the government, based on duplication of various tasks including partner coordination on equipment, coordination with vendors on identical equipment, identifying and vetting construction firms, mobilizing, etc.
Such duplication of the previous work would be unreasonable and untenable under the budget for this mission.
7. Subsequent Actions
Due to the nature of this work as well as the work that fell under previous modifications, DTRA believes that it is important for a single implementer to continue to progress the GLBP- II requirements, objectives and goals. DTRA has determined that competing these additional requirements will not provide a tangible and evident benefit to the Government with respect to economy and efficiency and will substantially increase the risk to cost and schedule. As a logical follow-on to a previously and fairly competed TO, DTRA recommends an ETFO approval to facilitate a sole source modification to the existing GLBP-II TO. In the event that additional requirements of this type do arise, DTRA will evaluate at that time to determine if they can be competed.
Technical Certification
I certify that the data and information forming the basis for this justification are accurate and complete to the best of my knowledge and belief.
Program Manager
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