J&A_BB8119_REDACTED.pdf

Justification and Approval (l&A} For Other Than Full and Open Competition

10 U.S.C. 2304(c)

Pursuant to the requirements of the Competition in Contracting Act (CICA) as implemented by Federal Acquisition Regulation (FAR) Subpart 6.3, and In accordance with the requirements of FAR 6.303-1, the use of a statutory authority under FAR Subpart 6.3 is justified by the following facts and rationale required under FAR 6.303-2:

1. Agency and Contracting Activity.

The Department of Homeland Security (OHS), United States Coast Guard (USCG), Shore Infrastructure Logistics Center (SILC) proposes to enter into a purchase contract with Vanguard Modular Building System for the procurement of existing modular buildings on a basis other than full and open competition.

2. Nature and/or Description of the Action Being Approved.

The USCG has a requirement for modular building space (office, work site, shower/toilet) to support Port Security Unit (PSU) 308, at an estimated cost of $278,558.00.

Proposed Contractor: Vanguard Modular Building System -----Eontractor-Address:---3-Great-Valley Pkwy,-Ste-170,-Malvern,-PA-19355---- ---

3. Description of Supplies/Services.

The requirement is to purchase temporary modular building space while planning efforts are currently underway for a permanent solution, but "new" facilities are not on the horizon for at least 5-7 years. On 31 December 2007, PSU 308 was asked to vacate leased facilities on Trent Lott Air National Guard Base, Mississippi. The unit is utilizing temporary modular buildings on Stennis International Airport (SIA) property provided by Vanguard Modular Building Systems through a contract originally awarded on 21 May 09 in the amount of $207,088.00 (base year with 3 option periods; for a total of 24 months). ·A follow-on contract was awarded on 27 July 11 in the amount of $147,662.00 (base year with 2 option periods; for a total of 18 months.

PSU 308 has a 20-year lease for a warehouse on SIA. The existing modular buildings meet three organizational space requirements including general office space, work site, and shower/toilet needs. This procurement provides the only facilities of this type for the unit.

4. Identification of the Justification and the Rationale.

The statutory authority permitting other than full and open competition is 10 U.S.C 2304( c), implemented by FAR Subpart 6.302-1 entitled "Only One Responsible Source and No other Supplies or Services will Satisfy Agency Requirements". Establishing another 5-year lease agreement (base year with four option years) is not a cost effective or flexible option. The current estimate to issue a new contract to lease the modular buildings for up to 5 years is $585K, which does not include the removal costs or C4IT systems installation costs required to transition to new modular buildings. Anything other than a sole source contract will negatively impact PSU 308 operations due to the considerable down-time required to remove the existing modular buildings and install new ones, plus the disruption associated with the shift of C4IT equipment, furniture, and other PSU gear.

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5. Determination That the Nature of the Acquisition Require Use of Authority Cited.

The Contracting Officer determined that issuing the contract to Vanguard Modular Building Systems represents the best value and lowest overall · cost alternative, considering price, administrative costs, and C4IT costs, to meet the Government's needs.

The Circumstances restricting competition for this acquisition are that an award to an alternate contractor would negatively impact operations while simultaneously incurring greater expense to the Government. PSU 308 is fully operational within present facilities. Removing existing modulars would result in complete disruption to the unit operations. More than 90% of PSU 308's staff is comprised of reserved personnel. As such, they have limited drill weekends to perform critical training evolutions and maintenance operations. Disrupting any of the unit's 12 drill weekends due to lack of a facility would impose operational risk; displacing necessary boat maintenance, small arms training, general mandated training, and necessary administrative functions. Operational risks would likely to be compounded due to simultaneous lapses in personnel qualifications.

6. Description of efforts made to ensure that offers are solicited from as many potential sources as is practicable.

A FedBizOpps notice of intent and thisJ&A will be publicized as required by FAR 6.305(d)(l).

-- ----- ---------------- ___________ J _____________ ~---- ·------- ----------------------------·----~--

7. Determination by the Contracting Officer that the Anticipated Cost to the Government will be Fair and Reasonable The Contracting Officer determined that the anticipated procurement price will be fair and reasonable.

8. Description of Market Research Market Research was used to determine that the cost estimate of the modular buildings was fair and reasonable based on the age and condition of the buildings.

9. ~ny Other Facts Supporting the Use of Other Than Full and Open Competition.

The Government will achieve cost savings by awarding a sole source contract for the modular buildings in lieu of establishing a new 5-year lease contract.

a. 5-Year Lease Contract

b. Purchase Cost

c. Cost Savings

$585,000.00 $278.558.00 $306,442.00

Based on the above Information, the Government will realize a cost savings of approximately $306,442.00 by awarding a sole source contract to Vanguard Modular Building Systems.

Additional potential savings realized through sole sourcing include the costs associated with storage of organization resources while awaiting facility establishment, the costs associated with relocating stored organization resources into alternate facilities, the costs for potential requirement for new furniture/office equipment due to facility configuration disparities, and the ·costs associated with establishment of C4IT equipment.

10. A listing of the Sources, if Any That Expressed, in Writing, an Interest in the Acquisition.

Vanguard Modular Building System is the only source of interest.

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 Supplies or Services Required.

Not Applicable

12. Contracting Officer's Certification.

In accordance with FAR 6.3, I certify that the data supporting the recommended use of other than full and open competition is accurate and complete to the best of my knowledge and belief.

Date Contract Specialist

10. Technical/Requirements Personnel Certification.

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Date

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APPROVAL:

3 BhJhllJlJJiiiilli!ii.1&3..Sil ou-USCG.rn=C 3 Dale: 2017.01.18 1105:33--05'00'

Date Contracting Officer