Justification_for_Exception_to_Fair_Opportunity_(Goldbelt).pdf

Source Selection Information See FAR Part 2.101 and 3.104

For Official Use Only

Contract No. HSCG44-12-D-TEDSSD/ HSCG44-15-J-001006

Justification for Exception to Fair Opportunity

Contract Number: HSCG44-12-D-TEDSSD Task Order Number: HSCG44-15-J-001006 Contractor Name: Goldbelt Falcon, LLC (DUNS No. 167091599) Title of Task Order: “Engineering Services Support for Core Technologies Navigation Systems Branch at C3CEN (CT-N1)”

Estimated Amount: $1,248,326

In accordance with FAR 16.505(b)(2)(ii)(B), the following is provided as explanation to support an exception to the fair opportunity process under the Technical Engineering Development and Support Services (TEDSS) Indefinite Delivery/Indefinite Quantity (IDIQ) contract.

(1) Agency and Contracting Activity.

The Department of Homeland Security (DHS), United States Coast Guard (USCG), Command, Control, Communications, Computers and Information Technology Service Center (C4IT SC), C4IT Service Center Acquisition Office, Command, Control, and Communication Engineering Center (C3CEN), 4000 Coast Guard Blvd., Portsmouth, VA 23703.

(2) Nature and/or description of the action being approved.

The nature of this action will be to modify Task Order No. HSCG44-15-J-001006 to exercise FAR Clause 52.217-8, Option to Extend Services, to extend the period of performance by six (6) months, covering the period of February 16, 2018 through August 15, 2018. The clause was included in the contract, but the price of the 6-month extension was not evaluated prior to award.

This extension is necessary to provide for continuity of services for the “Engineering Services Support for Core Technologies Navigation Systems Branch at C3CEN (CT-N1).” These services are currently being performed by Goldbelt Falcon, LLC under the task order and the period of performance expires on February 15, 2018.

(3) Description of Supplies/Services to meet the agency’s needs (including the estimated value).

This requirement is for an extension of services under the task order to allow for continuation of “Engineering Services Support for Core Technologies Navigation Systems Branch at C3CEN (CT-N1).” The objective is to obtain engineering services to study, manage, engineer, integrate, and document C4IT systems. Engineering encompass three primary areas: provide engineering, integration, testing, documentation development and management of projects to engineer electronic navigation systems for Coast Guard cutters and boats; provide legacy system support services to SMEF personnel, field technicians, Depot level technicians and system users; and provide CG DCMS 2.0 Modernization support services. These engineering services provide support of the Coast Guard’s over-arching requirement for electronic navigation systems aboard all Coast Guard cutters and boats. These mission essential services cannot be stopped without negative impact to the Coast Guard’s cutter operational capability. If there is a disruption of services, it will cause significant impact for lifecycle support of C4IT systems onboard Coast Guard cutters and boats. Support activities required and logistics may be deferred; casualty response will be affected and failed system may not be replaced and/or repaired in a timely manner.

(4) Identification of the Exception to Fair Opportunity.

The statutory authority permitting an exception to the Fair Opportunity process is 41 U.S.C. § 4106(c)(3), as implemented by the Federal Acquisition Regulation (FAR) 16.505(b)(2)(i)(C), which states that “The order 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.”

Goldbelt Falcon is currently providing the services under this task order. Unacceptable delays will occur if the Government has to solicit other vendors, evaluate their proposals, award a new contract, and transition to a new contractor in the limited timeframe prior to a follow on being in place. The Government is currently working on a competitive follow on contract for these services. The loss of these services would adversely affect cutter operational capability. The Government cannot run two source selections at the same time, especially when one is for a follow on contract and the other is for continuity of operations for only six months. Thus, exercising FAR Clause 52.217-8 with the incumbent is in the best interests of the U.S. Coast Guard to ensure continued daily operations.

(5) Determination by the ordering activity Contracting Officer that the anticipated cost to the Government will be fair and reasonable.

The Contracting Officer has determined that the anticipated price for the six (6) month extension period will be fair and reasonable, as the extension of services will continue at the current rates, which were previously determined fair and reasonable at the time the task order was awarded.

Travel pricing will also be appropriately evaluated for reasonableness.

(6) A description of the market research conducted among schedule holders and the results or a statement of the reason market research was not conducted.

Market research was not conducted as this is an extension of current services while a competitive follow-on is being procured. Market research was conducted for the follow on.

(7) Any other facts supporting the justification.

There are no additional facts applicable to this requirement.

(8) A statement of actions, if any, the agency may take to remove or overcome any barriers that led to the exception to fair opportunity.

There are no barriers to the exception to fair opportunity. The USCG is currently working on the follow-on procurement, which will be competed under the One Acquisition Solution for Integrated Services (OASIS) multiple award IDIQ, to ensure full and open competition is maximized.

(9) Contracting Officer’s Certification.

I certify that the data supporting the recommendation to modify the task order to extend the period of performance is accurate and complete to the best of my knowledge and belief.

Jessica L. Coltz Date Contracting Officer

(10) Technical/Requirements Personnel Certification.

I certify that this requirement meets the Government’s minimum need and that the supporting data, which forms a basis for the justification, is accurate and complete.

Manuel J. Ortega Date Contracting Officer’s Representative

(11) Legal Review and Concurrence:

I have reviewed this justification and deemed it legally review.

Shandra J. Kotzun Date Procurement Law Attorney

(12) APPROVAL:

Katherine Timberlake Date Command Procuring Activity Competition Advocate