fair_opportunity_exception_justification SPPS Bridge final_Redacted.pdf

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HQ United States Central Command Strategy, Plans and Policy Support Bridge
Solicitation number
FA481426F0044b
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This is a Justification for an Exception to Fair Opportunity document supporting a sole source bridge task order under GSA OASIS+ contract 47QCA25DU142. The Department of the Air Force, Air Mobility Command (AMC), 6th Contracting Squadron is issuing a one-month bridge contract valued at $2,760,201.30 to Gemini Industries Inc (200 Summit Drive, Burlington, MA, 01880) to provide Strategy, Plans, and Policy Support Services to U.S. Central Command (CENTCOM). The bridge action is necessary to maintain uninterrupted mission-critical support while a Government Accountability Office (GAO) protest on the recently awarded follow-on contract is resolved. A Competition in Contracting Act (CICA) stay prevents performance under the newly awarded contract, creating an urgent operational need. The contract includes a one-month base period (9 March 2026 – 8 April 2026) and five one-month option periods extending through 8 September 2026.

The services required include headquarters support for strategy, planning, exercises, and policy coordination in areas such as conventional and special operations forces logistics, communications synchronization, counter weapons of mass destruction, irregular warfare, and joint operational planning and execution (JOPES). The justification invokes FAR 16.507-6(b)(1) for the urgent need exception, as the services directly support combat operations and strategic planning essential to CENTCOM mission execution. The Contracting Officer determined pricing is fair and reasonable through comparison to the previously awarded competitive contract rates, with no escalation proposed. The incumbent contractor possesses necessary security clearances, operational knowledge, and established processes to ensure continuity without disruption. Upon resolution of the GAO protest, the Government intends to proceed with a competitive acquisition for the follow-on requirement to ensure all eligible contractors receive fair opportunity to compete.

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Justification for an Exception to Fair Opportunity or to Use Brand-Name Restriction

CONTROLLED UNCLASSIFIED INFORMATION

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0005 Strategy, Plans, Exercises, and Policy Support Services/JOPES 1 month $ 0006 Strategy, Plans, Exercises, and Policy Support Services/Logistics 1 month $ 0007 Strategy, Plans, Exercises, and Policy Support Services/Special 1 month $ Technical Operations (STO) 0008 Strategy, Plans, Exercises, and Policy Support Services/Communication 1 month $ Synchronization 0009 Senior Staff Coordination Services/Contractor Site Lead 1 month $ 0010 Plans and Staff Coordination Services 1 month $ 0011 Senior Strategy Plans, Exercises, & Policy Services Irregular Warfare 1 month $ 0012 Travel 1 Lot 0013 Contract Access Fee (CAF) 1 Lot $ Total: $

Base Month PoP 9 March 2026 - 8 April 2026

Option Month One 9 April 2026 - 8 May 2026 $

Option Month Two 9 May 2026 - 8 June 2026 $

Option Month Three 9 June - 8 July 2026 $

Option Month Four 9 July - 8 August 2026 $

Option Month Five 9 August 2026 - 8 September 2026 $

(4) Identification of the exception to fair opportunity and the supporting rationale:

Revolutionary FAR Overhaul 16.507-2(a)(1) requires the Contracting Officer to provide each awardee a fair opportunity to be considered for each order or BPA valued above the micro-purchase threshold according to paragraph (c) and 16.507-3 through 16.507-5, unless a sole source order or BPA is justified and approved according to 16.507-6. The specific exception that precludes the fair opportunity process for this acquisition is RFO 16.507-6(b)(1): "The agency need for the supplies or services is so urgent that providing a fair opportunity would result in unacceptable delays." The Government recently awarded the follow-on Strategy, Plans, and Policy Support Services contract; however, a post-award protest was filed with the GAO . The protest triggered an automatic stay of performance in accordance with the Competition in Contracting Act (CICA), which prevents performance under the awarded contract while the protest is pending.

The services under this requirement are mission essential and directly support combat operations, including strategic planning, policy coordination, and operational support activities required for ongoing mission execution. A lapse in these services would significantly disrupt planning and coordination activities that support operational objectives within the CENTCOM Area of Responsibility.

Due to the CICA stay and the time required for the GAO protest process to conclude, the Government must implement a short-term bridge contract with the incumbent contractor to ensure continuity of mission support. Providing fair opportunity to all contract holders for this short-duration requirement would introduce delays that would likely result in a lapse in mission-critical services.

The incumbent contractor possesses the necessary cleared personnel, operational knowledge, and established processes to continue performance without disruption. Awarding the bridge contract to the incumbent contractor represents the most efficient and least disruptive means of maintaining uninterrupted support while the protest is resolved.

the contracting activity.

Accordingly, the Contracting Officer has determined that the Government's need for continued support constitutes an urgent requirement, and that applying the exception to fair opportunity under RFO 16.507-6(b)(1) is necessary to ensure uninterrupted v 18 Jan 2024 CONTROLLED UNCLASSIFIED INFORMATION Page 3 of 6v 18 Jan 2024 CONTROLLED UNCLASSIFIED INFORMATION Page 3 of 6 mission support while the protest process is resolved.

(5) Contracting Officer's determination that the anticipated cost to the Government will be fair and reasonable:

The Contracting Officer has determined that the anticipated price for the proposed bridge contract is fair and reasonable. Price reasonableness was determined using price analysis techniques in accordance with RFO 15.404-1(b). Specifically, the Government compared the proposed bridge pricing to the previously awarded contract prices for the same services under the current contract, which were determined fair and reasonable at the time of award through competition.

The proposed bridge effort maintains the same scope of work, labor categories, and level of effort as the existing contract, and the contractor has proposed pricing consistent with the rates currently in effect under the incumbent contract with no escalation.

Based on a comparison of the proposed price to historical prices paid for the same services, the Contracting Officer has determined the anticipated price for the bridge contract to be fair and reasonable in accordance with RFO 15.404-1(b)(2)(i).

(6) Other facts supporting the justification:

The need for this bride action arose as a direct result of a post-award protest filed with the GAO on the recently awarded Strategy, Plans, and Policy Support Services contract, which triggered an automatic stay of performance pursuant to the CICA Act. As a result, the Government is prohibited from proceeding with performance under the awarded task order while the protest is pending unless the stay is overridden.

The services provided under this requirement are critical to ongoing operational activities supporting combat operations. These services provide direct support to strategic planning, policy development, coordination, and analytical activities necessary to enable CENTCOM leadership and staff to execute mission requirements. A lapse in services would disrupt ongoing planning and coordination activities and could adversely impact mission execution.

The incumbent contractor has the cleared personnel, operational knowledge, and established processes necessary to continue performance without interruption. Awarding a short-term bridge contract to the incumbent will allow the Government to maintain continuity of mission support while minimizing operational risk and avoiding the delays associated with onboarding a new contractor for a temporary period of performance.

The bridge action will be limited in duration and scope to the minimum period necessary to maintain mission support while the GAO protest is resolved and the Government determines the appropriate path forward for the follow-on requirement. This approach ensures continuity of critical services while preserving competition for the long-term requirement once the protest process concludes.

(7) Actions the agency may take to remove or overcome any barriers to increasing fair opportunity before any subsequent acquisition for the supplies or services:

There are no known barriers restricting fair opportunity for the follow-on requirement. The Strategy, Plans, and Policy Support Services requirement was previously competed, and the Government intends to proceed with the competitive acquisition once the pending GAO protest is resolved and the associated CICA stay is lifted or otherwise addressed.

The bridge contract is limited in scope and duration solely to maintain continuity of mission-critical services during the protest period. This action does not alter the scope of the requirement or restrict competition for the follow-on acquisition.

Upon resolution of the protest, the Government will proceed with the appropriate competitive acquisition strategy in accordance with RFO requirements, thereby ensuring that all eligible contract holders are afforded fair opportunity to compete for the requirement to the maximum extent practicable.

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(8) Program Manager's certification that supporting data is accurate and complete:

As evidenced by my signature below, I certify that any supporting data contained herein, which is my responsibility, is both accurate and complete.

(9) Contracting Officer's certification that the justification is accurate and complete:

As evidenced by my signature below, I certify that the justification is accurate and complete to the best of my knowledge and belief.

(10) Approving Official's determination that one of the circumstances in FAR 16.505(b)(2)(i) applies to the order.

As evidenced by my signature below, I hereby determine that the fair opportunity exception checked on page 1 applies.

Date

10 Mar 2026

Program Manager Jeffrey Price

CENTCOMJ5/813-529-3245

Signature

Date

12 Mar 2026

Contracting Officer LaKeisha Gamble

6 CONS/PKB, (813) 828-4783

Signature

Date

12 Mar 2026

Chief of the Contracting Office (COCO) Michael Terranova

6 CONS/PK, (813) 828-4752

Signature

PRICE.JEFFREY.ALAN.

1046066797

Digitally signed by

PRICE.JEFFREY.ALAN

Date: 2026.03.10 14:33:45 -04'00'

GAMBLE.LAKEISHA.

NICOLE.1257945410

Digitally signed by

GAMBLE

Date: 2026.03.13 10:32:00 -04'00'

TERRANOVA.MICH

AEL.1384936829

Digitally signed by

TERRANOVA

Date: 2026.03.12 13:01:42 -04'00'

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