G-3 Justification for an Exception to Fair Opportunity Reconcile AFC Signed 20 Sep Redacted.pdf

Justification for an Exception to Fair Opportunity Under FAR 16.505(b)(2)

1. Contracting Activity: Department of the Army, Army Contracting Command- Redstone Arsenal (ACC-RSA), CCAM-MLP, Redstone Arsenal, AL 35898-5000.

2. Description of Action: The U.S. Army Aviation and Missiles Command (AMCOM) G-3 requests approval to award a task order modification to task order W31P4Q-21-F-0333, non-competitively, to Axient LLC (formerly Quantitec), 360A Quality Circle, Suite 100, Huntsville, Alabama 35806, Commercial and Government Entity (CAGE) Code: , under GSA’s One Acquisition Solution for Integrated Services (OASIS) Unrestricted Multiple Award Contract (MAC), Pool 1. This contract was awarded competitively as a hybrid Time and Material (T&M) and Fixed Price effort (FP). The request is for approval to issue a new contract modification to increase the period of performance (PoP) by six months from 24 September 2024 to 23 March 2025, pursuant to FAR Subpart 16.505(b)(2)(i)(C) and to authorize a corresponding increase in ceiling of $4,680,668.48 from to . Although FAR 52.217-8, Option to Extend Services, was included in the base award and the hours associated with the extension were evaluated for task order risk, a Justification for an Exception to Fair Opportunity is required because the six-month extension under FAR 52.217-8 was not evaluated as part of the initial price evaluation. The awardee, Axient, provided the hours associated with a six (6) month extension in its proposal, but it was not a requirement of the solicitation because the requiring activity did not request it. The funding available for this continued effort will be fiscal year 2024 Operation and Maintenance, Army (O&M) funds.

3. Description of Supplies/Services: The AMCOM G-3 mission is to enable AMCOM organizations with a work environment that minimizes the environmental footprint that houses all employees in quality facilities. The AMCOM G-3 serves as the primary staff action office supporting the synchronization and coordination of all AMCOM directed missions and support requirements. The G-3 mission consists of the Futures, Strategy and Concepts Division; Airworthiness and Quality Management Division; Current Operations and Readiness Division; Organizational Inspection Program and the Corrosion Program. AMCOM G-3 serves as the principal staff to focus on process improvement to Decrease Soldier Burden, Improve Operational Availability, Reduce Logistics Footprint, Enhance Safety, decrease Life Cycle Costs and enable Expeditionary Aviation Forces. The total estimated cost of the six-month extension is $4,680,668.48.

4. Authority Cited: The statutory authority permitting an exception to fair opportunity is 10 U.S.C. § 3406(c)(3), as implemented by Federal Acquisition Regulation (FAR) 16.505(b)(2)(i)(C). This task order (TO) must be issued on a sole-source basis in the interest of economy and efficiency because it is a logical follow-on to an order already issued under the contract, provided that all awardees were given a fair opportunity to be considered for the original order.

5. Reason for Authority Cited:

This justification supports the authority cited above in that the extension of the PoP and associated ceiling increase is a logical follow-on to an existing OASIS task order which was placed in accordance with applicable ordering procedures. This contract PoP extension is critical for continuance of the G-3 mission consisting of the Futures, Strategy and Concepts Division; Airworthiness and Quality Management Division;

Current Operations and Readiness Division; Organizational Inspection Program and the Corrosion Program; and to continue serving as the principal staff element to focus on process improvement to Decrease Soldier Burden, Improve Operational Availability, Reduce Logistics Footprint, Enhance Safety, decrease Life Cycle Costs and enable Expeditionary Aviation Forces. Without the contract PoP extension, the G-3 mission will be negatively impacted in its ability to receive technical expertise in the areas of Reliability Centered Maintenance (RCM), Prognostic/Predictive Maintenance (PPMx), Sustainment Analysis Program/Project Management, Policy, Automation Systems, Army Working Capital Fund (AWCF) Investment, corrosion control, care of supplies in storage (COSIS), corrosion coatings, Nondestructive testing, Reliability, Availability and Maintainability (RAM), Item Unique Identification (IUID), The Army Maintenance Management System – Aviation (TAMMS-A) and Maintenance Consolidated Database System (MCDS).

6. Efforts to Obtain Competition: A contract requirement package (CRP) for the competitive follow-on was accepted by ACC-RSA on 05 June 2024. Based on the above-mentioned facts, it is not feasible to utilize another source for this brief PoP extension since only Axient personnel have the immediate in-depth knowledge and experience necessary to meet the TO requirements in the time available. The current contract expires 23 September 2024. There are no efforts to obtain competition for this extension at the current time. A Request for Information (RFI) was published on 06 June 2024 for the follow-on requirement under the Expedited Professional and Engineering Support Services (EXPRESS) program. Eight (8) EXPRESS Technical Domain primes provided a response.

a. Effective competition: The re-compete will be Full & Open Competition. Under FAR 5.202(a)(6) and FAR 16.505(a)(1), this modification action is exempt from pre-award synopsis requirements.

b. Subcontracting competition: Since this is a modification to an existing Part 16 task order, all contract clauses currently in the base task order will apply to this modification.

7. Actions to Increase Competition: The follow-on TO CRP was accepted by ACC-RSA on 05 June 2024 and will be competitively awarded as Full & Open Competition under the EXPRESS Program to provide technical support to AMCOM G-3. The ACC-RSA anticipates the follow-on TO to be awarded by 18 June 2025. This proposed action will result in a six-month PoP extension with the incumbent to allow continued support, without a break in service, to AMCOM G-3 under the OASIS platform.

8. Market Research: In accordance with FAR 10.002, as described above in paragraph 6, market research was conducted for the proposed follow-on EXPRESS task order.

Based on that market research, the Contracting Officer signed the Market Research Report/Commerciality Determination (MRR/CD) on 11 December 2024 for the follow-on.

Because of the brief nature of this proposed modification, no separate market research was conducted.

9. Other Facts:

a. Procurement history. The current task order, resulting from request for proposal W31P4Q-20-R-009, was competitively awarded using Unrestricted Multiple Award Contract (MAC), Pool 1 on 24 September 2021 for three (3) years through 23 September 2024 to Quantitech LLC (now Axient), CAGE Code 0S9B5, with a total ceiling of $29,679,173.93.