!ID02140034_Mod_014_JEFO_MNIS_ML,TC,CA_5.30.2017_JU_TR_SS_Redacted_for_FBO_Redacted.pdf

ITSS Order ID ID02140034

JUSTIFICATION FOR AN EXCEPTION TO FAIR OPPORTUNITY

(IAW FAR 16.505)

I. Agency and Contracting Organization:

U.S. General Services Administration, Region 02 FAS Assisted Acquisition Services One World Trade Center, 55th Floor New York, NY 10007-0089

II. Description of Action:

GSA Region 02, on behalf of U.S. Southern Command (USSOUTHCOM), is seeking approval to procure and award a Firm-Fixed Price order to Alliant SB CTA, LLC (ASC) for Multi-National Information Sharing (MNIS) User Support under the Alliant Small Business (ASB) Governmentwide Acquisition Contract (GWAC), number GS06F0601Z.

III. Description of Supplies/Services:

5.1.10.2.2. Multi-National Information Sharing (MNIS) User Support.

The Contractor shall provide Multi-National Information Sharing (MNIS) support for SOUTHCOM headquarters, Navy SOUTH (NAVSO) at Naval Air Station, Mayport, FL and SCO-Colombia MNIS CENTRIXS sites in Attachment 16. Contractor tasks shall include maintaining close liaison with the SCJ6 Staff, NAVSO Staff, and the SCO Commander supporting meetings and conferences related to multinational-operations;

coordinating and preparing plans and annexes for on-going or near term contingency operations. The Contractor shall perform maintenance and logistics tasks in NAVSO and SCO Colombia. The Contractor MNIS Support shall include developing and presenting multinational operations-related recommendations to senior leadership based on operational assessments; resolve procedural and operational problems; as well as, respond to and track recurring and nonrecurring User, Maintenance or Logistics issues related to use of MNIS systems at NAVSO, as well as the SCO Commanders and SCJ6 staff elements.

Historical support, to include that currently provided under ITSS order number ID02140034 – through the end of Option Period 1 only, has entailed two resources in Colombia and one in Mayport to support O&M and logistical activities throughout the USSOUTHCOM AOR. In regards to Inter-American Naval Telecommunications Network (IANTN), this support includes supporting host nation users and assets in over 15 countries throughout the USSOUTHCOM AOR.

The requirement was previously expected to be needed only through Option Period 1, but due to the severely delayed migration from Bi-lateral Colombia (BLCOL) CENTRIXS to Battlefield Information Collection and Exploitation Systems –Extended (BICES-X), has been so severely delayed, and overcome by other initiatives that the United States Southern Command (USSOUTHCOM) commander has directed his Chief Informatino Officer (CIO)/J6 that MNIS support must continue indefinitely. A list of CENTRIXS assets in Colombia can be found below:

ROUTERS………………………………

SWITCHES………………………….……..52

CRYPTO…………………………………...42

VOICE OVER IP PHONES………………..70

WORKSTATIONS……………………

PRINTERS………………………………

SCANNERS………………………………..56

VSATS……………………………………...06

SERVERS…………………………………..09

SECURE VIDEOTELECONFERENCE.…..17

USSOUTHCOM has committed to provide funding to procure the services that they seek.

The services to be procured under this action are estimated by the Government to be valued at $2,077,766.40 through the remaining life – Option Periods 2 through 6 - of the order. Per period, the estimated cost is:

Option Period 2 $410,304.00 Option Period 3 $412,646.40 Option Period 4 $414,316.80 Option Period 5 $418,329.60 Option Period 6 $422,169.60 Total: $2,077,766.40

IV. Identification of the Exception and Supporting Rational:

FAR 16.505(b)(2)(i)(E) For orders exceeding the simplified acquisition threshold, a statute expressly authorizes or requires that the purchase be made from a specified source.

The statute expressly authorizing the purchase from the specified source is the Veterans Benefits Act of 2003 (15 U.S.C. 657f), Procurement program for small business concerns owned and controlled by service-disabled veterans

(a) Sole source contracts In accordance with this section, a contracting officer may award a sole source contract to any small business concern owned and controlled by service-disabled veterans if-

(1) such concern is determined to be a responsible contractor with respect to performance of such contract opportunity and the contracting officer does not have a reasonable expectation that 2 or more small business concerns owned and controlled by service-disabled veterans will submit offers for the contracting opportunity;

(2) the anticipated award price of the contract (including options) will not exceed-

(A) $5,000,000, in the case of a contract opportunity assigned a standard industrial classification code for manufacturing; or

(B) $3,000,000, in the case of any other contract opportunity; and

(3) in the estimation of the contracting officer, the contract award can be made at a fair and reasonable price

The subject requirement was intended to be a part of an overarching Enterprise IT support order, and was included in the Performance Work Statement (PWS) issued with the solicitation, but was mistakenly removed from the PWS, via an amendment to solicitation, due to Government error. The RFQ closed with the requirement removed, and the erroneous removal of the requirement was not discovered until performance under the order resumed, several months after award, after a protest-related Competition in Contracting Act (“CICA”) Automatic Stay was lifted. Subsequently, on Modification 002 the Enterprise IT support order, services were provided for through the end of Option Period 1, when the need for the requirement was expected to end.

Subsequently, the dynamic landscape has changed, and the deployment of the system that was to replace MNIS has been severely delayed and is thought to no longer be functionally capable of replacing the functions performed by MNIS.

The support is an integral part of the overall IT support currently being provided by incumbent ASC, on ITSS task number ID02140034, from which it had mistakenly been eliminated.

The authority used to add the requirement, for the Base Period and Option Period 1, of ITSS task number ID02140034, via Modification 002, is the same authority being cited for this action. The following is a summary of why this authority is valid for the current action.

Market research previously conducted by both the Requiring Agency and by the GSA revealed responsible SDVOSB firms capable of performing the full ID02140034 requirement, and it was set-aside for SDVOSB’s under the ASB GWAC. Four SDVOSBs submitted offers. ASC was the successful offeror. The approximate value of the full ID02140034 award is $283,000,000.00 over approximately seven years.

Subsequently, GSA conducted another acquisition for IT support, again for USSOUTHCOM, as an SDVOSB set-aside under the ASB GWAC, based on initial response from SDVOSB contract holders under the ASB GWAC. Four SDVOSBs had expressed interest via responses to a Request for Information (RFI)/Sources Sought, conducted during market research for this second SOUTHCOM acquisition. The solicitation was open for 30 days. One offer was received in response to the RFP. The offeror was ASC. ASC was the successful offeror. The approximate value of the order (ID02150025) is $8,500,000.00 over approximately five years.

one of the four firms initially expressing interest in the second IT support requirement, but subsequently declining to submit an offer, offered the following reasons for not submitting an offer:

First, they thought they had the right team to effectively compete, but then reconsidered that position. Second, they felt that had they made a proposal it may have had a lower probability of winning. And, third and finally, they had several other, larger opportunities that they were working on during the solicitation timeframe.

The three causes of outlined for this firm previously expressing interest in a higher value requirement than the presently contemplated action, therefore are:

- Considered they did not have the right team; and,

- Felt they had a low probability of winning; and,

- Had several other larger offers that they were working on during the solicitation timeframe.

It is the contracting officer’s expectation that there would be a similar outcome to the competitive acquisition of support for this requirement, which has an approximate estimated value of $2,077,766.40 over approximately 60 months. This is significantly smaller than the ID02150025 requirement, which was indicated to be relatively small compared to other business being pursued by SDVOSBs. Even if some firms, via an RFI/Sources sought, indicate an interest in performing the requirement, it is likely that potential Offerors will mimic the performance of firms not submitting offers on ID02150025, for reasons similar to those stated by For instance, first, they may realized that the ASC team have the right team to effectively compete, and that they may be at a disadvantage in that regard, leading to the second reason cited by

, which is that they may therefore feel they have a lower probability of winning, and thirdly, this is a fairly small opportunity compared to other larger opportunities considered relatively too small an opportunity, compared to other opportunities which may be available. In substantiation of the expectation that firms may have other opportunities which they’d be working on currently, which would take precedence over this effort as had been the case during the ID02150024 solicitation timeframe, a review of opportunities available through GSA eBuy under the Alliant Small Business contract, during the ID02150025 solicitation timeframe (11/10/15 to 12/10/15), as well as a recent 30-day window (4/23/17 to 5/23/17), was undertaken. The results, obtained through eBuy Open, reflect fourteen non-cancelled solicitations during the ID02150025 solicitation window and nineteen non-cancelled solicitations during the recent 30-day window period. While it is not feasible to assess the estimated value of these awards, it is likely that a sizeable number are larger than the estimated value of this action. GSA conducted research to substantiate this expectation, and found the most recent data readily available, published in 2015, reflects average Task Order values under the Alliant Small Business GWAC ranging from $5,000,000 to $139,000,000, with the average Task Order award value calculated as $32,773,584.91. The source for this information is: https://govtribe.com/post/2015/2/10/parsing-gsa-alliant-part-3-small-business-breakdown. The estimated value of the current MNIS requirement is approximately an order of magnitude less than recently published average value of Alliant Small Business orders. It is unlikely that potential Offerors would prioritize bid and proposal efforts on this requirement over larger value opportunities.

The contracting officer, therefore, does not have a reasonable expectation that offers will be received from two or more Offerors.

ASC is a responsible contractor with respect to performance of the contract opportunity.

V. Fair and Reasonable Determination:

Rates for this effort match the rates offered under the ID02140034 order previously awarded to the contractor. GSA has already determined the rates for services offered at hourly rates, discounted from the awarded rates under the contractor’s ASB contract to be fair and reasonable. Based on the best value determination made in support of the award of ID02140034, and the identical rates for the proposed labor categories for the contemplated effort, as well as the overall close proximity of the proposed price to the Government’s estimated price, I hereby determine that the anticipated cost to the Government will be fair and reasonable.

VI. Other Facts:

The MNIS requirement is supportable with three resources. The overall order into which this effort will be folded, ID02140034, requires approximately 250-300 resources, to include substantial administrative, quality control, and management resources that will integrate the performance of the MNIS requirement in an overarching IT solution for USSOUTHCOM. The Government’s estimated cost for performance of the requirement is based on its incorporation into the overarching IT Support order. It is expected there would be additional efforts and costs associated with the performance of the MNIS requirement by a contractor other than ASC, under a separate order.

Additional cost could be expected in administration, quality control, and management.

Additionally, the Government would incur additional administrative costs associated with administration of two orders.

The requirement was (erroneously) removed from the ID02140034 PWS and RFP solicitation only after it had been approved for consolidation of requirements as part of the TCSC contract. There is no need to address consolidation analysis requirements anew, due to the current situation.

THOMAS

CORLEY

Digitally signed by THOMAS CORLEY DN: c=US, o=U.S. Government, ou=General Services Administration, cn=THOMAS CORLEY, 0.9.2342.19200300.100.1.1=47001000023373 Date: 2017.05.30 10:06:18 -04'00'

CHARLES ADE

Digitally signed by CHARLES ADE DN: c=US, o=U.S. Government, ou=General Services Administration, cn=CHARLES ADE, 0.9.2342.19200300.100.1.1=47001000031577 Date: 2017.05.30 11:33:56 -04'00'

Joe Urbanik Digitally signed by Joe Urbanik DN: cn=Joe Urbanik, o=FAS, ou=GSA, email=joe.urbanik@gsa.gov, c=US Date: 2017.05.30 12:00:45 -04'00'

THERESA RAMOS

Digitally signed by THERESA RAMOS DN: c=US, o=U.S. Government, ou=General Services Administration, cn=THERESA RAMOS, 0.9.2342.19200300.100.1.1=47001000214557 Date: 2017.06.01 11:23:44 -04'00'