J_A_-_Curation_Assistance_FINAL_9_24_25_1.pdf

United States Department of the Interior

BUREAU OF LAND MANAGEMENT

https://www.blm.gov

JUSTIFICATION AND APPROVAL

FOR ACQUISITIONS UNDER THE SIMPLIFIED ACQUISITION PROCEDURES

This document sets forth the justification and approval as required by 13.106-1(b)(1) & (2).

1. Contracting agency and activity.

The Department of the Interior, Bureau of Land Management (BLM) Utah State Office, Natural Resources Division, requests the Utah State Office to contract on a sole source basis.

2. Nature and/or description of action being approved.

This requirement is for the approval of a new sole source, base plus four (4) option years contract with the University of Utah, Natural History Museum of Utah (NHMU) located at 201 Presidents Circle, Salt Lake City, UT 84112-9049, UEI LL8GLEVH6MG3.

3. Description of supplies or services.

The associated contract covers assistance with preparing the Cerberus Collection archaeological objects for curation so they can be accessioned at partner repositories in perpetuity.

The Contractor will need ample expertise in preparing objects for curation and the staff to accomplish the workload; the equipment, materials, and space to prepare the objects for curation;

a climate controlled, secure facility to temporarily curate the objects in and work in while the objects are being prepared that meets Department of the Interior policy and 36 Code of Federal Regulations (CFR) Part 79-Curation of Federally-Owned and Administered Archeological Collections requirements; and a location in close proximity to the BLM Utah State Office (UTSO) to facilitate the transport of the collections boxes in batches throughout the term of the contract and BLM Utah’s continued access to the collections. The services also include freezing objects in a large walk-in freezer for pest management purposes before beginning work, general management of the curation facility, protection from unauthorized access to the materials, and access for appropriate BLM Utah personnel as needed.

4. Estimated dollar value.

The estimated 5-year total for these services is $268,080.00, for a base year estimate of $53,616.00 and $53,616.00 for each option year thereafter.

https://www.blm.gov/

5. Statutory authority.

_X_ 41 U.S.C. 1901 – Simplified acquisition procedures (use when the simplified procedures for purchases of property and services for amounts (1) not greater than the simplified acquisition threshold

____41 U.S.C 1903 – Special emergency procurement authority (applies when in support of a contingency operation as defined in section 101(a) of title 10 or to facilitate the defense against or recovery from nuclear, biological, chemical, or radiological attack against the United States).

6. Rationale supporting use of the authority stated in paragraph 5.

NHMU is uniquely qualified to provide required services to the BLM UTSO based upon the following:

The contract is a continuation of a requirement for curation assistance for the Cerberus Collection. NHMU is the contractor that was awarded the original 2020 contract and has been completing the contract work for the last five years. NHMU has already established processes and procedures for the work on this contract, has hundreds of Cerberus Collection boxes under their care for this contract work, and is currently working on preparing two batches of objects for curation.

The complexity of the contract work dictates that BLM Utah must utilize a top curation team to complete the work on this contract to ensure quality work is performed. NHMU is one of the top repositories in the region, with their stringent curation policies, their ability to comply with curation policies of multiple different repositories throughout the Southwest. NHMU have permanent onsite curation staff, including archaeological curators, assistant curators, and collections managers who have extensive knowledge and expertise in preparing objects for curation, rehousing collections, cataloging collections, managing collections, preparing associated records, and updating collections data. The staff also have access to other experts in related fields that can assist with the curation of certain types of objects if needed.

NHMU houses multiple collections for BLM Utah as well as other federal bureaus and agencies, demonstrating that the Contractor is well equipped to suitably care for the materials being worked on under this contract as exhibited in the facility features, staff expertise, and history of care for important archaeological collections. Additionally, the Contractor is excelling in their ability to appropriately care for BLM Utah owned museum collections and facilitating curation of hundreds of boxes of archaeological artifacts that are currently being temporarily curated at the Contractor’s facility.

Facilities/Repositories performing curation for federal agencies and collections must conform to 36 CFR 79-Curation of Federally Owned and Administered Archeological Collections-as stated in 36 CFR 79.6(b) and 36 CFR 79.9. NHMU meets the requirements stated above and is an approved repository, as described in Department of the Interior (DOI) policies and directives found at https://www.doi.gov/museum/museum-policy (see specifically Directive 14, Facility Checklist for Spaces Housing DOI Museum Property and Department Manual 411). As required for any facilities/repositories holding federal collections, the Contractor has been approved to hold federal collections via the procedure outlined in the Directive and Manual above.

Furthermore, the Contractor’s facility is state-of-the-art, ensuring the collections are sufficiently cared for during the duration of the contract. Even though the Contractor will only hold the collections temporarily while preparing them for curation the Contractor must still comply with DOI policy and Federal law regarding caring for and securing collections.

Location of the collection in Salt Lake City, Utah is also a priority for this contract, as BLM UTSO staff will need access to the collection quickly and easily throughout the period of performance for transport under the contract and other ongoing BLM work happening concurrently with this contract. The Contractor’s facility is in proximity to the BLM UTSO, making it possible to easily access the facility and transport boxes to be worked on under the contract, ultimately reducing travel costs and time in transit. In addition, NHMU has performed exceedingly well facilitating BLM Utah’s access to the collections currently at their repository facility. Since BLM Utah will need access to the collections objects while they are being prepared for curation, these two factors are crucial to BLM Utah’s continued access to the collection and overall success of the contract.

Based on all the information presented above, NHMU is the most appropriate entity to prepare the Cerberus Collection for curation.

7. Other information.

This is a continuation of a requirement that NHMU is already preforming and award to any other source would result in a substantial duplication of costs to the government, which would not be recovered through competition. Furthermore, NHMU is already caring for hundreds of boxes under the current curation assistance contract that must continue to be accessed during this new contract and is curating museum collections under a separate contract that must also be accessed for this contract. Establishing a contract with a different contractor and relocating the museum property would be unacceptable as it would significantly increase time and costs for this contract as well as other ongoing contracts with NHMU for temporarily curating Cerberus Collection artifacts that must be accessed during this contract.

8. The efforts to identify additional sources including the market research conducted.

As BLM Utah works with and evaluates repositories in other areas of Utah, the BLM UTSO is aware of the staffing, expertise, and facility specifications at each repository that is certified to hold BLM Utah Museum collections. Not all repositories are interested in helping prepare objects for curation due to staffing limitations and the need to temporarily curate artifacts in their facility under a loan agreement. Many repositories in the region only accept objects that are formally accessioned at their repository and do not have the space to hold the Cerberus Collection.

A search on SAM.gov was conducted order to compare similar requirements to ensure NHMU’s cost was reasonable for the Government. Pre-solicitations and sole source special notices were found for contracts on SAM.gov for long-term curation at repository facilities which included limited curation upgrading and contracts with much broader scopes that included processing artifacts for curation as one of dozens of tasks related to general cultural resources management. A less complex contract from BLM Colorado for long-term curation and limited collections management work to be performed as needed showed a similar cost to this contract.

The only other option for this kind of work with the appropriately qualified and large staff are found in private sector firms that specialize in curation or other large repositories, both which would be out of state. The cost to utilize a private firm or out of state repository would significantly exceed the cost of the work at NHMU due to the need to move the collection boxes a long way or cover per diem for staff to work in Salt Lake City. A private firm would also bill at a higher rate than NHMU for the same work.

Market research indicates that NHMU is the most advantageous place to prepare objects in the Cerberus Collection for curation and care for the collection objects while work on the contract is being conducted. NHMU’s past experience also makes them uniquely qualified to continue work on this project under the new contract.

9. Future plans to permit competition.

The BLM will continue to perform market research as needed prior to exercising option years to ensure that this curation assistance arrangement remains advantageous to the Government.

10. The ordering activity Contracting Officer’s certification that the justification is accurate and complete to the best of the Contracting Officer’s knowledge and belief and evidence that the supporting data that form a basis for the justification have been certified as complete and accurate by technical/program personnel.

I certify that the facts and representations under my cognizance, which are included in this justification, and which form a basis for this justification, are complete and accurate.

_____//Signature on File//__________________ _________________ Diana Barg, Archaeologist Date Contracting Officer’s Representative

I certify that the justification is accurate and complete to the best of my knowledge and belief:

_____//Signature on File//__________________ _________________ Temujene Makua Date Contracting Officer