Final_NPS_Consolidation_Determination_-_Region_2_Cultural_Resource_Management_AE_IDQs_11222_1.pdf

CONTRACT CONSOLIDATION DETERMINATION AND FINDINGS

Project Name: Region 2 Cultural Resource Management Indefinite Delivery Indefinite Quantity (IDIQ) Architect & Engineering (A&E) Contracts Purchase Request Number: 0040562348 Solicitation Number: TBD Bureau and Contracting Activity: National Park Service, Interior Region 2, S. Atlantic Gulf

In accordance with FAR 7.107-2, I have reviewed this requirement and associated market research and determined that consolidation of the referenced contract requirements is both necessary and justified. My review resulted in the following findings:

Description of the Procurement Action:

The National Park Service, Interior Region 2 South Atlantic Gulf, intends to issue a Pre-solicitation Notice for SF-330s for award of Cultural Resources Management IDIQ A&E contracts. The Cultural Resources IDIQ A&E contracts will provide accelerated and simplified procurement of Cultural Resources A&E services The services required include the production of Historic Structure Reports (HSRs), Condition Assessment Reports (CARs), Material Analysis Reports, HABS/HAER/HALS Documentation, Cultural Landscape Reports (CLRs) and Cultural Landscape Inventories (CLIs) produced to the NPS standards. Other related documentary research and physical analyses may also be required, including the development of treatment plans, preservation maintenance plans, cost estimates, power point/presentation documentation; and documentation/consultation for the Historic American Building Survey (HABS), Historic American Engineering Record (HAER) and Historic American Landscape Survey (HALS). The primary place/location of performance for these contracts will be primarily throughout the Southeastern United States in Alabama, Florida, Georgia, Kentucky, Louisiana, Mississippi, North Carolina, San Juan, Puerto Rico, South Carolina, Tennessee, and the U.S.

Virgin Islands.

• Contract type is multiple award IDIQ A&E contracts with an expectation of four or more contracts awarded. Each task order awarded under these contracts shall be awarded using the fair opportunity process unless justification is made to limit competition (e.g., emergency, minimum guarantee).

• The policy and procedures set forth in Federal Acquisition Regulations (FAR) Subpart 36.6 and Brooks Act procedures for A&E Services will apply to this acquisition.

• The IDIQ contracts shall be awarded for a base period of 365 calendar days, with options for four additional 365 calendar day period.

• The total aggregate capacity of these contracts shall not exceed $10,000,000.00. Combined Task Order awards for the base year shall not exceed $2,000,000.00. Combined Task Order awards for each exercised option year shall not exceed $2,000,000.00.

• Typical Task Orders will range from a guaranteed minimum of $500.00 per year and $2,500.00 for the life of the contract.

• Based on the market research conducted, the Contracting Officer has determined that a Small Business Set-Aside is appropriate and suitable for this acquisition.

Results of Market Research Conducted:

The market research conducted consisted of utilizing the SBA’s dynamic small business search results and reviewing ten-year A&E contract award history that fully supports the acquisition strategy, and set-aside determination for this contract.

SBA’s dynamic small business search results revealed that there is a substantial number of small businesses near all the parks positioned throughout Interior Region 2 that appear capable of providing the services sought in this requirement. The criterion used in this assessment:

NAICS 541490 for the states and territories listed above; no more than $8 million average annual gross revenue. The search yielded 760 small businesses that could possibly perform the cultural resources services on this procurement. Search results by specific small business certifications:

• Veteran Owned: 192

• Service-Disabled Veteran Owned: 131

• 8(a) Certified: 55

• HUBZone Certified: 48

• Small Disadvantaged Business: 545

• Woman Owned: 329

A&E contracts awarded from Denver Service Center (DSC), GSA and Interior Region 2 in a period from 2013 to 2021 were researched and analyzed to determine the types of contractors that were awarded region requirements. Current acquisition history over the past several years shows award to three small business contractors and several small businesses under the DSC A&E IDIQ contracts. All task orders were awarded as A/E services under the IDIQs. Also, historical data shows two large and two small businesses under prior A/E IDIQ contracts.

Additionally, these services can be procured under GSA Schedule with limited contractors available for the services. The GSA Schedule only allowed for non A/E services to be procured.

The information collected during our market research phase was used in developing an appropriate acquisition strategy, and to determine the most appropriate socio-economic set-aside for this requirement. The final number of awards will be determined by the quality and quantity of proposals received. The contractor’s capability and capacity may influence the actual number of IDIQs awarded.

Any alternative contracting approaches and rationale for rejection:

Alternative contracting approaches that may involve consolidation to a lesser degree is always a consideration during the acquisition strategy phase for any single, or multiple award IDIQ contracts. The IDIQ contracts are not meant to be a replacement for other IDIQ contracts. In the case of this acquisition, the IDIQs are envisioned to fulfill most of the region’s A&E Cultural Resources requirements. These IDIQ contracts are another procurement tool that uniquely allows for accelerated and simplified procurement of commonly encountered cultural resource tasks and projects, including various architectural, restoration, and landscape architectural reports and planning projects. It is more cost effective to utilize a region specific IDIQ with pricing that is specific to the locations and procuring A/E contractors that specialize in Cultural Resources than to continue to utilize the pricing of other IDIQs such as DSC, that are not tailored to Cultural Resources. IDIQ contracts measurably reduce award and procurement lead times. They are a reliable and flexible, alternative way to procure cultural resource related services that emphasizes simplified, accelerated, and streamlined procedures and processes, as well as long-term partnering and teamwork with selected contractors. The anticipated outcome is multiple award contracts (desire minimum of 4 contractors) with individual task orders being awarded using Fair Opportunity unless a unique circumstance exists to limit competition. The IDIQs are best defined as a program and procurement vehicle, and not simply a contract.

The IDIQ contracts will provide the tools and ability to simultaneously execute multiple small to medium sized task orders. The IDIQ contractors are selected based on qualifications and performance versus low price. The contractors essentially provide other design services, such as surveys, inventories, and reports, for the end-user. A signed and approved DI-1886 is accomplished and includes formal documentation supporting this acquisition strategy.

Any negative impact by the acquisition strategy on contracting with small business concerns has been identified:

Historically, there are minimal negative impacts to local small business concerns due to the acquisition of the IDIQ contracts. Region Contracting Officers award to small businesses in over 95% of our cultural resource requirements. The acquisition strategy for this requirement is a total small business set-aside and all task orders placed against this vehicle will continue to fulfill the Department’s small business performance goals. The IDIQs are anticipated to be the go-to vehicle for a majority of the new cultural resources projects and as a result, there is no degradation in the region meeting or exceeding departmental small business goals. Successful offerors must be capable of accomplishing multiple task orders across multiple geographical areas. Prime contractors may rely on several small business subcontractors to support task order completion. Based on bureau IDIQs performance, the sub-contracting opportunities for local small businesses are expected to be high with little to no negative impact to the local area small businesses.

Steps have been taken to include Small Business concerns in the acquisition strategy for this contract. It is our intent, and a major consideration in any IDIQ contracts, that the successful offeror selected, will be general contractors capable of self-performing a minimum of 30% of the work for typical task orders. Typically, and historically, the remaining portion of the work is generally sub-contracted out to local small business concerns, with the Indefinite Delivery Indefinite Quantity contractors functioning as the prime contractor.

Considerations, Facts, and Reasoning Supporting the Determination:

On 12 April 2017, the Office of Management and Budget released memo 17-22 as a response in fulfilling the requirements of the January 2017 Hiring Freeze Presidential Memorandum and the March 2017 Reorganization Executive order. Section III para-B, “restructure and merge activities” provides direction form the Director of OMB to assess what activities can be restructured, streamlined, and merged to improve the efficiency, timeliness, and quality of services. It also encourages agencies to reduce the duplication of activities of functions across multiple parts of the organization and reduce redundant levels of management or administrative support. The purpose of the IDIQs are to do as the Director requested by consolidating region cultural resources A&E activities in order to streamline and merge functions in order to improve efficiency and timeliness of, as well as, reduce the duplication of activities in writing A&E contracts.

The Interior Region 2, South Atlantic Gulf Contracting Office has had previous success in the use of the IDIQ contracts. Regional Contracting Officer’s awarded nearly $10 Million in A&E Cultural Resources task orders between fiscal year 2016 to 2021. Use of these established sources has reduced the need for non-competitive (such as 8a) procedures. It is the intent of the Contracting Office to award all cultural resources task orders using the fair opportunity process, but with fewer Contracting Officers, Program Managers, delayed confirmation of availability of funds, and the repeated continuing resolution authorities, the trend of receiving requirements late or after the requirement package due date continues without any relief in sight. Cultural Resources packages that are received after deadlines commonly use the established source Cultural Resource Management IDIQ contracts or non-competitive procedures to find a contractor who is able to bid on the requirement using a compressed acquisition timeline.

Allow for a reduced Procurement Acquisition Lead Time (PALT) on all its actions as compared to other acquisition strategies. The annual cutoff date for contracts over $500K is the first week in March. However, the cutoff date for a similar requirement using established IDIQs, is mid- July; providing additional time to submit a fully developed and more detailed requirements package. Current IDIQs have permitted increased time for requirement planning and development. Region stakeholders also have more time to manage and prioritize project funds during final quarter of a budget year. Lastly, the use of the IDIQs eases the administrative and planning burden across an already stretched acquisition team.

Under the strategy of separate contracts, acquisition cycle times are multiplied due to differing period of performances, contracts lengths, and unplanned requirements. Consolidated IDIQ contracts will reduce the number of contracts and will provide for much greater and more efficient program management for the planning, issuance, and management of task orders.

A partnering relationship and business trust will be built between the federal acquisition team and the contractors, leading to increased administrative efficiencies for all stakeholders.

Allow for emergency services to be performed allowing for an expedited contracting process utilizing already established rates vs. the traditional method of having to award a single contract without established rates.

Increased transparency through use of mutually agreeable established rates. These standardized prices/rates result in efficient and effective estimating and design and will also ease in evaluation and determination of fair and reasonable pricing.

Provide efficiencies on performing technical evaluations will be accomplished once the Project Managers have a better familiarization on how the Cultural Resource Management IDIQ contractors bid on projects. Mistakes on bids are less likely to occur with contractor familiarization and with the Project Managers knowing what to watch out for resulting in faster and possibly less expensive projects.

Overall reduction in continuity of processes/formats, multiple site visits can be held in a single day for work being done by the same contractor, repetitive actions should reduce errors such as reports, surveying, and inventories documents.

Summary:

It is my determination that the consolidation required of this contract is necessary and justified because the benefits of proceeding with this acquisition substantially exceeds the benefits that would be derived from any of the alternative contracting approaches as identified in the sections above. Additionally, access to the IDIQ procurement vehicles enhances and improves the ability of acquisition personnel to successfully meet the broad range of various architectural, historical reports, and landscape architectural needs of parks in a timely and cost-effective manner.

CONTRACTING OFFICER CERTIFICATION:

All supporting data provided, and the contents of this justification are complete and accurate to the best of my knowledge and belief.

Contracting Officer Date

HEADQUARTERS SMALL BUSINESS SPECIALIST CERTIFICATION:

Headquarters Small Business Specialist Date

DIRECTOR, OFFICE OF SMALL AND DISADVANTAGED BUSINESS UTILIZATION

CERTIFICATION:

Director, Office of Small and Disadvantaged Business Utilization Date

SENIOR PROCUREMENT EXECUTIVE

Upon the basis of the findings above, I hereby determine, pursuant to the authority of FAR 7.107-2, that the consolidation of contract requirements is both necessary and justified.

Senior Procurement Executive Date