F11_MISC_JOFOC_posting_(final)(20240710)_Redacted_1.pdf

LIMITED-SOURCES JUSTIFICATION

AUTHORITY: FAR 8.405-6 and 40 U.S.C 501

Solicitation Number 0040669144

This acquisition is conducted under the authority of the Multiple Award Schedule Program.

1. Identification of the agency and contracting activity, and specific identification of the document as a “Limited-Sources Justification.”

Department of the Interior, Interior Business Center, Acquisition Services Directorate, Division 5, on behalf of the Office of Environmental and Policy Compliance (OEPC).

2. Nature and/or description of the action being approved. This is a logical follow-on of an existing contract, 140D0421F0741.

The contractor considered for this requirement is:

BB&E, Inc.

235 E. Main St, Ste 107 Northville, MI 48167-2661

SAM UEI: JCHUL8M1HHK5

POC: Naila Hosein, nhosein@bbande.com, 248.378.8081

3. A description of the supplies or services required to meet the agency’s needs (including the estimated value). OEPC requires technical contract support in the areas of sustainability and environmental compliance.

Base award will be twelve (12) months from date of award with three (3) twelve (12) month option periods as well as the option of exercising FAR 52.217-8 clause up to six (6) months.

The value for the base and three options is anticipated at .

4. The authority and supporting rationale (see 8.405-6(a)(1)(i) and (b)(1)) and, if applicable, a demonstration of the proposed contractor’s unique qualifications to provide the required supply or service.

FAR 8.405-6(a)(1)(i)(C) – In the interest of economy and efficiency, the new work is a logical follow-on to an original Federal Supply Schedule order (140D0421F0741) the original order was placed in accordance with the applicable Federal Supply Schedule ordering procedures. The original order was not previously issued under sole-source or limited-sources procedures.

OEPC requires policy, guidance, oversight, and governance for the programs Department wide.

Assistance is needed in the areas of policy and guidance development, implementing an organizational Environmental Management System, establishing metrics, developing communications tools and training, I.T. support to update the Department’s SharePoint site and websites, and technical assistance with improving the program. The extra cost to Gov. could be 1.5 times the amount of the IGCE. There is a significant learning curve with the systems the contractor will need to use -additionally, there will be at a minimum 30–45-day delay in just gaining access to the systems, which would then put the government at risk with a gap in service for this requirement.

5. A determination by the ordering activity contracting officer that the order represents the best value consistent with FAR 8.404(d).

GSA has already determined the prices of supplies and fixed-price services, and rates for services offered at hourly rates, under schedule contracts to be fair and reasonable. Therefore, it is not required to make a separate determination of fair and reasonable pricing, except for a price evaluation as required by 8.405-2(d). By placing an order against a schedule contract using the procedures in 8.405, the ordering activity has concluded that the order represents the best value (as defined in FAR 2.101) and results in the lowest overall cost alternative (considering price, special features, administrative costs, etc.) to meet the Government’s needs.

Although GSA has already negotiated fair and reasonable pricing, the contracting officer shall seek additional discounts before placing this order (see 8.405-4).

6. A description of the market research conducted among schedule holders and the results, or a statement of the reason market research wasn’t conducted.

Market Research was conducted June and July of 2024. It was determined that Other contractor’s are capable of performing this work on the contract, however with BB&Es familiarity with the EPA ECHO Database, environmental compliance tracking programs, Federal Environmental Laws, and Executive Orders such as 13990, 14008, 14030, 14057, and OEPCs internal systems, the contractor has extensive knowledge and adequate past performance with the government to continue this work. A sole source requirement provides the government with the least amount of risk and a logical follow on to fulfill OEPCs needs.

7. Any other facts supporting the justification.

The request for quote will not be released on eBuy. This order shall be awarded utilizing a multi-award BPA that has been determined to be a sole source to one of the four BPA contractors. See information previously provided within this document justifying the sole source award.

8. A statement of the actions, if any, the agency may take to remove or overcome any barriers that led to the restricted consideration before any subsequent acquisition for supplies and services is made.

OEPC will continue to monitor the commercial market for alternatives to awarding this as a sole source requirement. However, at this time, there is no other contractor that can meet OEPCs needs.

9. The ordering activity contracting officer’s certification that the justification is accurate and complete to the best of the contracting officer’s knowledge and belief.

I certify this justification is accurate and complete to the best of my knowledge and belief.

Debra Slasor, Contracting Officer

10. Evidence that any supporting data that is the responsibility of technical or requirements personnel (e.g., verifying the Government’s minimum needs or requirements or other rationale for limited sources) and which form a basis for the justification have been certified as complete and accurate by the technical or requirements personnel.

I certify the technical data which forms a basis for this justification is complete and accurate and meet the Government’s minimum needs.

Veronica Dickerson, COR

VERONICA DICKERSON Digitally signed by VERONICA DICKERSON Date: 2024.07.10 09:11:43 -04'00'

DEBRA SLASOR Digitally signed by DEBRA SLASOR Date: 2024.07.10 11:31:32 -04'00'

11. For justifications under 8.405-6(a)(1), a written determination by the approving official identifying the circumstance that applies.

FAR 8.405-6(a)(1)(i)(C).

Note, IBCM-AQD-6900-015 Justifications for Limiting Competit needs CO approval—effective date 4/30/24.