For HCA-SPE Rvw-Aprvl-Sgntr JOFOC Bridge 68HERH21D0002 PHILIS_Final.pdf

Justification for Other Than Full and Open Competition – Bridge Extension and Ceiling Increase Prepared In Accordance with RFO Subpart 6.104-1 and EPA Policy (EPAAP) Subsection 6.3.1

1. RFO 6.104-1(a)(1), Identification of the agency and contracting activity:

Agency: Environmental Protection Agency (EPA) Contracting Activity: Office of Finance and Administration (OFA)

Office of the Chief Procurement Officer (OCPO) Land, Enforcement, and Air Division (LEAD)

Program Office: Office of Land and Emergency Management (OLEM) Office of Superfund and Emergency Management (OSEM) Environmental Response Team and Chemical, Biological, Radiological, and Nuclear Division (ERT-CBRN)

Program POC: Stuart Willison, OLEM/OSEM/ERT-CBRN

Project Identification: ERT-CBRN Portable High-Throughput Integrated Laboratory Identification System (PHILIS) Operations and Maintenance Support

Proposed Source(s): Consolidated Safety Services Incorporated (CSS) Contract/Order No: EPA Contract No. 68HERH21D0002

Task Orders – 68HERH21F0185, 68HERH21F0187, and 68HERH21F0188

2. RFO 6.104-1(a)(2), Nature and/or description of the action being approved:

This justification for other than full and open competition (JOFOC) is requested to issue a sole source bridge extension for a maximum of 18 months and commensurate ceiling increase in the estimated value of $581,089.25 to EPA’s indefinite-delivery/indefinite quantity (IDIQ) contract 68HERH21D0002 (and associated active Task Orders 68HERH21F0185, 68HERH21F0187, and 68HERH21F0188) beyond their current expiration date of September 1, 2026 to ensure continued support of EPA's on-site chemical analysis capabilities for emergency responses and mission critical ongoing maintenance of the PHILIS labs and instrumentation as the Agency completes the competitive PHILIS follow-on.

The requested bridge extension is intended to be executed as a bilateral modification to the existing contract and associated task orders for an additional 12 months of performance (September 2, 2026 – August 31, 2027).

This justification also includes an optional extension period of six (6) months (September 1, 2027 – February 28, 2028) and associated ceiling.

3. RFO 6.104-1(a)(3), A description of the supplies or services required to meet the agency’s needs (including the estimated value):

(i) Required Services to Meet the Agency’s Needs

The general mission of EPA’s ERT-CBRND is to provide multidisciplinary technical expertise to the Superfund program including homeland security activities and emergency response. The primary function of ERT-CBRND is to provide expert scientific engineering and technical support for:

Execution of the Agency’s Primary Mission Essential Function to respond to environmental and health threats:

o Prevent, limit mitigate or contain chemical, oil, radiological, biological and/or natural or man-made disasters in designated zones of the United States, and provide environmental monitoring, assessment, and reporting in support of overall domestic incident management.

Providing timely and effective remote and direct field support at contaminated sites (e.g., remedial, removal, and federal facilities).

Managing operation of deployable national assets and fixed/mobile laboratories, providing analytical support and developing new methods for environmental sampling and testing.

ERT-CBRN owns and operates portable, mobile labs, referred to as the PHILIS program that provides onsite analytical support for chemical contaminants that can be used to inform the first responder during times of need. The PHILIS laboratories are designed to detect Chemical WarRFOe Agents (CWAs), Pharmaceutical Based Agents (PBAs), and Toxic Industrial Chemicals (TICs). The PHILIS Program provides on-site mobile laboratory capabilities to support EPA’s mission of protecting human health and the environment by responding to chemical natural disasters, terrorist events, and accidental chemical and toxic releases, without the need to transport large numbers of samples to remote locations to add to the Nation’s resiliency under numerous current and future laws, regulations, policies, and Presidential Directive. The PHILIS program also provides contracted commercial laboratory sample analysis for excess capabilities that the other laboratories cannot analyze or do not have the capabilities to perform.

The PHILIS laboratories act as the EPA’s mobile assets under the Environmental Response Laboratory Network (ERLN), which participates in exercises and responses within the Inter-agency Consortium of National laboratories (ICLN). Consequently, it must always maintain the highest operational readiness standard and be capable of applying the highest quality, scientifically vetted analytical methods and data processing for the Agency. Contractor support is required due to the highly specific subject matter expertise required for analytical analysis, operational maintenance, and data analysis, which is not currently available within the Agency.

Critical services under 68HERH21D0002 that must continue include the support of the Environmental Response Team and CBRN Division (ERT-CBRN) PHILIS laboratory systems are currently being supported under the following three (3) task orders:

68HERH21F0185 for Chemical Laboratory Support in analyzing contaminated samples following sample collections for Chemical WarRFOe Agents (CWAs) and Toxic Industrial Chemicals (TICs) resulting from terrorist events or accidental chemical and toxic releases, without the need to transport large numbers of samples to remote locations through rapid deployment to an affected location to support consequence management

68HERH21F0187 for Biological Laboratory Support in analyzing contaminated samples following sample collections for Biological Agents (BIOs), pathogens, and bacteriological samples (BIO) resulting from terrorist events, natural disasters or accidental releases through rapid deployment to an affected location to support consequence management

68HERH21F0188 for General Support, providing general administrative and office support for the daily and emergency response operations and maintenance activities of the PHILIS systems on a 24-hour basis.

In addition to the above-listed existing work that must continue without disruption, this request also includes capacity for OLEM/OSEM ERT-CBRND to execute in-scope mission-critical work that may arise during the bridge performance period.

(ii) Estimated Value

The estimated value of the requested bridge extension, inclusive of labor and other direct costs, is delineated as follows:

Type Duration Period Estimate

Base extension of existing support 12 months September 2, 2026 – August 31, 2027 $5,707,468 Option extension period of existing support 6 months September 1, 2027 – February 28, 2028 $2,853,754

Total Estimate for 18 Month Continuation of Existing Support $8,561,202

Additional, In-Scope Support $856,120

Total Estimate for Bridge Extension for 68HERH21D0002 for Continuation of Existing Support $9,417,322

The estimated amount for the requested bridge extension is based upon the actual costs incurred during the last 12 months of performance under the existing, active task orders (68HERH21F0185, 68HERH21F0187, and 68HERH21F0188). The cost estimates above include capacity for additional anticipated in-scope work under the contract based on the program’s projections for work that are anticipated to arise during the above stated bridge period of performance.

When accounting for the total current available capacity (i.e., unfunded ceiling) in the amount of $822,873.99 under 68HERH21F0187 and 68HERH21F0188, and the $8,013,358.96 available in unused capacity under the IDIQ contract, the net estimated value of the requested contract ceiling increase is $581,089.25, representing only a 2% increase to the contract ceiling. Refer to Section 9(ii) herein for additional information.

4. RFO 6.104-1(a)(4), Identification of the statutory authority permitting other than full and open competition:

This Justification for Other Than Full and Open Competition (JOFOC) is being issued pursuant to the authority granted by 41 U.S.C. 3304(a)(1): Only one responsible source and no other supplies or services will satisfy agency requirements, as implemented by RFO Subpart 6.103-1.

In addition, extensions to existing three (3) task orders (68HERH21F0185, 68HERH21F0187, and 68HERH21F0188) will also be executed pursuant to RFO 52.216-22(d) Indefinite Quantity (OCT 1995) of the contract to continue current services through and beyond the bridge ordering period expiration, which currently only allows existing task order performance to continue for up to 30 days beyond the IDIQ contract ordering period expiration date. Accordingly, this justification includes a revision to paragraph (d) of the clause to allow existing task order performance to continue for up to 365 days beyond the IDIQ contract ordering period expiration date provided that any extensions executed under this authority can be done without any future increases to the IDIQ ceiling.

5. RFO 6.104-1(a)(5), A demonstration that the proposed contractor's unique qualifications or the nature of the acquisition requires using the authority cited:

The mission critical on-site mobile and fixed laboratory services being performed under the current contract must maintain full operation capability, fully operational and available at all times (24 hours a day, 7 days a week) to respond to chemical, biological, and radiological natural disasters, terrorist events, and accidental chemical and toxic releases. Successful operation of the PHILIS program requirements under this contract requires contractor personnel to be thoroughly trained in PHILIS operations and in the employment of Standard Analytical Protocols. While there are other firms in the market who provide chemical and biological laboratory testing and analysis services, the time needed to issue a new competitively awarded vehicle covering the full scope and magnitude of the PHILIS program requirements is not available with only days remaining in the current contract performance period. The learning curve would be substantial and impractical for a new company who is unfamiliar with the existing projects currently being supported and the strict protocols required to operate under this contract to be introduced with only days remaining in the current contract performance period. It is not feasible to award an interim contract solution this close to expiration of the existing contract and task orders. This approach would likely result in duplicative costs on the Government and contractor’s part that would not be recovered through any savings that might be attained through competition. As stated in Section 8 herein, there are contractors under other active EPA vehicles that may have the expertise to provide the services required under this contract and the existing task orders, but do not have the bandwidth to accommodate the scale of scope required. Accordingly, there are presently no other contractors other than CSS capable of supporting the immediate needs of the PHILIS program without causing detrimental and significant impacts and delays (detailed in Section 9 herein) to the program’s emergency response mission. Accordingly, there is currently only one responsible source, CSS, to obtain the specific knowledge and experience necessary to ensure no adverse impact to the sustained levels of existing support currently provided under this contract. A lapse in critical contract support services provided under this contract would inhibit the Agency’s ability to respond and support emergency response activities performed in support of Agency’s mission. Accordingly, the Contracting Officer has determined that the only way to ensure the mission critical on-site mobile and fixed laboratory services performed under the current contract continue uninterrupted is to obtain continued support for these services through the current contractor, CSS.

6. RFO 6.104-1(a)(6), A description of efforts made to ensure that offers are solicited from as many potential sources as possible, including whether a notice was or will be publicized as required by Part 5 and, if not, which exception under Part 5 applies.

Since this justification is for an extension to an existing IDIQ contract, 68HERH21D0002, offers will not be solicited from any additional sources beyond CSS, neither for the continuation of existing services and support currently provided under task orders, nor any new task orders that may be issued under the IDIQ contract.

As required by 41 USC 1708, Procurement notice, a notice of the proposed contract actions requested herein was posted on July 31, 2026 at the Government Point of Entry (GPE) (https://www.SAM.gov). A copy of the notice is attached hereto and is available at the following link:

https://sam.gov/opp/5540c156db0947ce98672bb03152ac4c/view. The notice will close on August 14, 2026.

In accordance with RFO Subpart 6.301(b), within 14 days after issuing the bridge IDIQ contract extension, this justification will be published (i.e., made publicly available). The justification will be posted at the Government Point of Entry (GPE) (https://www.SAM.gov) for a minimum of 30 days.

Any responses received to the notice or justification will be recorded and retained as a listing of interested and/or prospective sources to be included in EPA’s market research for the future recompete, which will be conducted as competitive acquisition.

7. RFO 6.104-1(a)(7), A determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable:

The existing support services that are currently being performed by CSS under 68HERH21D0002, which was competitively awarded in accordance with the policies and procedures governing competitive acquisitions under RFO Part 15, Contracting by Negotiation, on March 1, 2021. At the time of contract award, the fully loaded fixed labor rates, escalation factor, indirect rates (on other direct costs, or ODCs), and total anticipated cost to the Government under the current contract were determined to be fair and reasonable as they were proposed under a competitive environment.

The government estimated amounts for the requested extension are based upon actual experienced costs incurred during the last 12 months of performance under the existing task orders. Those amounts are consistent with previously approved historical pricing paid for the same or similar services as documented over the last five (5) years of actual expenditures under the contract, plus the appropriate and reasonable amount of escalation over the elapsed time.

The Contracting Officer, in collaboration with the cognizant technical personnel, will ensure that the magnitude of effort and proposed cost for the requested contract extension and each of the task order extensions be fair and reasonable, based on analysis and comparison with available historical data on actual costs under the existing task orders. However, given that the contract was originally competed and awarded five (5) years ago wherein the proposed/awarded costs were based on labor and indirect rates current at that time likely to have now changed, the labor rates and indirect rates (on ODCs) must be based on current pricing information.

Consequently, for the proposed non-competitive bridge contract extension, the contractor’s proposal will be evaluated in accordance with RFO 15.404 price analysis requirements and procedures including the use of cost analysis techniques, as necessary, for use of updated price/cost information, and to evaluate data other than certified cost or pricing data to determine cost reasonableness or cost realism, as necessary. The EPA contracting office will also perform other means of rate verification using information obtained through agency internal sources, such as the Policy & Compliance Branch’s Acquisition Training, Financial Analysis & Closeout Section within EPA, and external sources such as the Defense Contract Management Agency (DCMA) or the Defense Contract Audit Agency (DCAA). Nevertheless, the anticipated labor rates for the extension are expected to be in line with the rates the Government has historically paid the contractor over the life of the contract, escalated appropriately and reasonably for currency. Pricing proposed for the task order extensions will be required to be consistent with (equal to or less than) the labor rates and indirect rates established at the contract level that have been determined to be fair and reasonable, thereby resulting in reasonable pricing for the task orders. The performance of price analysis in addition to cost analysis (if needed) will ensure overall price reasonableness.

8. RFO 6.104-1(a)(8), The market research conducted (see part 10) and the results or a statement of the reason market research was not conducted:

Market research was conducted to determine if there were other existing EPA contract vehicles with sufficient scope and capacity to accommodate the services required beyond September 1, 2026. Market research identified the Response Engineering and Analytical Contract (REAC, 68HE0321D0001), which provides scientific, technical, logistical, and analytical advisory and assistance support to the Emergency Response Team (ERT) staff and regional response personnel and is similar in scope to 68HERH21D0002. However, REAC does not have the bandwidth to accommodate the scale of scope required and would not be able to assume responsibility of and/or maintain the PHILIS requirements for the contractor fully operational and available at all times (24 hours a day, 7 days a week) to respond to chemical, biological, and radiological natural disasters, terrorist events, and accidental chemical and toxic releases. Accordingly, the results of the market research indicate that the services provided by CSS under 68HERH21D0002 are not available on any other active EPA vehicle.

Market research was also conducted to formulate the estimated value for the requested bridge extension, which is based on historical expenditures under the existing task orders.

9. RFO 6.104-1(a)(9), Any other facts supporting the justification:

(i) Rationale

The current contract, 68HERH21D0002, was awarded on March 1, 2021 with a 60-month ordering period that is and was originally scheduled to expire on March 1, 2026. The contract was awarded at a ceiling of $30,341,432.00 (inclusive of all labor and ODCs) that was sufficient at the time of award for performance of the required on-site mobile and fixed laboratory capabilities for a maximum period of performance end date of March 1, 2026. On January 14, 2026, a 6-month extension was executed to extend the ordering period end date to September 1, 2026 pursuant to the authority of RFO 52.217-8, Option to Extend Services, of the contract at no increase in the contract ceiling.

Acquisition planning discussions for the competitive recompete began during Year 4 of the five-and-a-half-year contract when there was more than sufficient time to re-compete this requirement prior to the current contract and task orders expiring. Since acquisition planning discussions commenced, however, multiple programmatic and procurement factors required analysis, re-evaluation, and fielding of new ideas and alternatives. Actions included review of strategic plans, assessment of current goals to ensure alignment with the Administration’s priorities, implementation of new executive orders and guidance, shift of resources to support new core mandates, as well as engaging and communicating with stakeholders and public partners.

All these necessary actions required time to execute and, therefore, delayed the follow-on re-procurement effort.

The PHILIS program supports EPA emergency response and removal actions with the ability to detect Chemical WarRFOe Agents (CWAs), Pharmaceutical Based Agents (PBAs), Biological Agents (BIOs), and Toxic Industrial Chemicals (TICs). The PHILIS program provides on-site mobile laboratory capabilities to support EPA’s mission of protecting human health and the environment by responding to chemical, biological, and radiological natural disasters, terrorist events, and accidental chemical and toxic releases, without the need to transport large numbers of samples to remote locations to add to the Nation’s resiliency under numerous current and future laws, regulations, policies, and Presidential Directive. The PHILIS contract also provides contracted commercial laboratory sample analysis for excess capabilities the PHILIS laboratories cannot analyze or do not have the capabilities to perform. The PHILIS laboratories also serve as the EPA’s mobile assets under the Environmental Response Laboratory Network (ERLN), which participates in exercises and responses within the Interagency Consortium of National laboratories (ICLN). The primary task is to identify and quantify CWAs, PBAs, BIOs, and TICs below health/ecological risk-based levels in air, gaseous vapors, liquids, surface wipes or solid/sludge/sediment samples (and mixtures of these phases) at high-throughput levels. PHILIS is expected to operate indefinitely anywhere sample analysis is required.

Unless the extension to the contract and ceiling increase is approved, the PHILIS program which provides mission critical emergency response services will no longer be available to support EPA’s mission of conducting emergency responses and removal actions after September 1, 2026, and consequently, the following critical capabilities unique to the PHILIS program will no longer be available to the EPA Regions and their communities:

Loss of on-site analytical method capability: After a major disaster (natural, terrorist events, and accidental), PHILIS can rapidly on-site mobile laboratory capabilities to support EPA’s mission of protecting human health and the environment by responding to chemical and toxic releases, without the need to transport large numbers of samples to remote locations.

Loss of quick decision-making and information capabilities for on-scene coordinators and response personnel: PHILIS has a unique capability to be on-site of an incident indefinitely, and has been deployed for months at a time, until a response is either descoped or completed. This capability has been used many times, (e.g., Red Hill and East Palestine Train derailment).

Loss of Chemical WarRFOe Detection Capability: PHILIS, to the best of the program’s knowledge, is EPA’s only lab that will be able to analyze samples on-site for chemical warRFOe agents (CWAs). This capability has been used several times in the past and it is crucial to maintain readiness, especially during nation’s on-going events. PHILIS can arrive on scene much quicker in many instances than samples can be shipped for analysis to commercial labs, which keeps down costs and saves time during an emergency response.

The detrimental impact of an interruption in these critical services is significant as indicated above. The need to continue the mission critical analytical services in response to environmental and natural disasters related to or involving chemical incidents to protect human health, welRFOe, and the environment under the contract and existing task orders outweighs the time and resources that have been necessary to implement Administration priorities and a potentially consolidated competitive re-procurement.

Over the life of the current contract and task orders, CSS has developed a strong knowledge base and acquired expertise related to the program, processes, and strict protocols that are critical in providing the required on-site mobile and fixed laboratory capabilities. The experience and familiarity with existing projects and strict analyses protocols enable CSS to continue providing seamless support without having a need to ramp up and expend the time and costs associated with training and developing personnel, which would be the case with any other contractor. Expiration of the current contract and task orders will render the Agency incapable of providing mission critical emergency response support services, such as those detailed in Section 3. herein and above. Additionally, the PHILIS program is in the process of receiving new labs. CSS is in the process of accepting and transferring all the equipment over to the new labs. If CSS were not able to complete the new lab onboarding process, PHILIS will be unable to function, which will require EPA to reduce their asset availability to the Regions, resulting in a waste of significant amount of Government funding (to the tune of millions) if the PHILIS program does not continue to operate.

Although there are other contractors under existing EPA vehicles, best-in-class vehicles, and other preferred and mandatory sources (e.g. GSA Multiple Award Schedules, namely the Scientific Management and Solutions - Testing and Analysis Category 541380 for Testing Laboratory Services and One Acquisition Solution for Integrated Services Plus (OASIS+)) that may be capable of performing the current PHILIS program requirements indicated in Section 8 herein,, there are no other contractors capable of stepping in to support the immediate needs that are currently being performed under the existing contract and task orders without causing detrimental delays to the program’s mission. Award to a source other than the incumbent would cause the Agency to incur additional, duplicative, or excessive costs that are not expected to be recovered during the bridge period of performance. Specifically, the government has already incurred costs associated with the current technical expertise associated with the incumbent. The incumbent possesses unique, program-specific knowledge of the current systems and government requirements that they have gained over the life of the current contract and task orders’ period of performance. Recreating this knowledge base in the short amount of time (30 days) left in the current contract and task orders performance periods would cause unnecessary duplication of previously incurred costs. During transition, which can take up to 90 days for a new contractor, the government would experience reduced productivity while continuing to pay full contract rates for diminished performance. Since this program runs on an emergency response model, it would take significant time and government resources to transition to a new contractor to ensure they are able to perform effectively. The new contractor would require time and government resources that are not available to gain familiarity with existing systems and tools and required analysis.

Therefore, at this time, extending the period of performance of the current contract and existing task orders for a maximum of 18 months at a commensurate ceiling increase to ensure the PHILIS program remains fully operational and readily available to respond to chemical, biological, and radiological natural disasters, terrorist events, and accidental chemical and toxic releases with CSS is the only viable option to maintain the critical mission emergency response support services that are needed for the Agency’s protection of human health, welRFOe, and the environment until a new competitive awarded vehicle is in place.

(ii) Cost

Current contract ceiling: $30,341,431.96 To date, three (3) Task Orders have been issued utilizing $22,328,073.00 (or 74%) of this ceiling, leaving $8,013,358.96 in available ceiling to utilize under the extension. Of the utilized ceiling, $21,505,199.01 has been obligated of which $19,916,331.10 has been expended. The values include the $100,000.00 contract minimum guarantee that has been funded and expended and is not associated with any specific task order for purposes of this justification.

Current estimated bridge extension cost is $9,417,322.20 (for a maximum of 18 months, inclusive of a continuation of existing support plus additional, in-scope support that may be required), as delineated below:

TO No.

Ceiling

Obligated

Current Available Capacity

18 Mo Estimate

Needed Ceiling Increase

68HERH21F0185 $19,861,591.00 $19,861,591.00 $0.00 $7,749,304.20 $7,749,304.20

68HERH21F0187 $913,783.00 $234,408.01 $679,374.99 $51,430.50 -$627,944.49

68HERH21F0188 $1,452,699.00 $1,309,200.00 $143,499.00 $1,616,587.50 $1,473,088.50

TOTAL $22,228,073.00 $21,405,199.01 $822,873.99 $9,417,322.20 $8,594,448.21

When accounting for the total current available capacity (i.e., unfunded ceiling) in the amount of $822,873.99 under 68HERH21F0187 and 68HERH21F0188, and the $8,013,358.96 available in unused capacity under the IDIQ contract, the net estimated value of the requested contract ceiling increase is $581,089.25, representing only a 2% increase to the contract ceiling.

(iii) Period of Performance

Existing contract ordering period end date / task order period of performance expiration date:

September 1, 2026

Requested bridge extension period of performance: September 2, 2026 – August 31, 2027 (Base extension of 12 months) and September 1, 2027 – February 28, 2028 (Optional extension of up to 6 months)

(iv) Follow-on

Formulation of the competitive and potentially consolidated recompete requirement is currently on-going.

As requested herein, in the event the competitive follow-on is not issued prior to February 28, 2028, or transition to a successor or multiple successor contractors is not completed by that date, the Government intends to leverage the authority of RFO 52.216-22(d) Indefinite Quantity (OCT 1995) of the contract to continue services for up to 365 days beyond the IDIQ contract ordering period expiration date provided that any extensions executed under this authority can be done without any future increases to the IDIQ ceiling.

(v) Previous Bridge. Not applicable.

10. RFO 6.104-1(a)(10), A listing of the sources, if any, that expressed an interest in the acquisition in writing:

Because the notice of the proposed contract actions as required by RFO Subpart 5.101(a) has not yet closed, the Agency has not yet and may not receive any written expressed interest from any sources other than the incumbent. However, as stated in Section 6 herein, any responses received to the notice or justification (after posting in accordance with RFO Subpart 6.301(b)) will be recorded and retained as a listing of interested and/or prospective sources to be included in EPA’s market research for the future recompete, which will be conducted as competitive acquisition.

11. RFO 6.104-1(a)(11), A statement of the actions, if any, the agency may take to remove or overcome any barriers to competition before any subsequent acquisition for the supplies or services required.:

No barriers to future competition exist as the follow-on competitive requirement will be solicited from as many sources as practicable. EPA’s requirements for the recompetition will be procured in compliance with all the requirements of a competitive acquisition.

JESSICA WHITE WHITE

Digitally signed by JESSICA

12. RFO 6.104-1(a)(12), Contracting officer certification that the justification is accurate and complete to the best of the Contracting Officer's knowledge and belief.:

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

Jessica White Contracting Officer

13. 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:

The undersigned hereby certifies that all 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 limiting sources) and which form a basis for this justification is complete and accurate:

STUART WILLISON WILLISON

Date: 2026.08.06 13:02:08 -04'00'

Stuart Willison Contracting Officer Representative (COR) OFA/OCPO/LEAD/OLEM & OECA Procurement Branch

JOAN ROGERS ROGERS

Digitally signed by JOAN

STEFAN

Digitally signed by STEFAN

MARTIYAN

Date: 2026.08.13 15:34:15 -04'00'

Justification for Other Than Full and Open Competition - Bridge Prepared In Accordance with RFO Subpart 6.104-1 and EPA Policy (EPAAP) Subsection 6.3.1

Contract No. 68HERH21D0002 And Task Orders 68HERH21F0185, 68HERH21F0187, and 68HERH21F0188

CONCURRED:

CELIA VAUGHN

Digitally signed by CELIA

VAUGHN

Date: 2026.08.12 00:59:24 -04'00'

Celia Vaughn OFA-OCPO Senior Policy Advisor

CONCURRED:

Joan B. Rogers Agency Advocate for Competition Environmental Protection Agency

APPROVED:

Stefan Martiyan Director, Office of the Chief Procurement Officer (OCPO) Head of Contracting Activity and Senior Procurement Executive Environmental Protection Agency