Justification for P42 ISWM Redacted.pdf
PDF 195 KB Posted
- Solicitation number
- J4ISWMP42
About this file
This is a Justification for Limiting Sources, prepared by the Air Force Test Center at Edwards Air Force Base, for a sole-source acquisition of Integrated Solid Waste Management (ISWM) services. The Department of the Air Force intends to award a firm-fixed-price commercial services contract to Waste Management of California, Inc. (WM) for the collection, transportation, and disposal/diversion of non-hazardous solid waste streams, including Municipal Solid Waste and Construction & Demolition debris at Air Force Plant 42 (AFP 42) in Palmdale, California. Services must be performed in accordance with the Performance Work Statement and all applicable federal, state, and local regulations.
The contracting officer determined that only one responsible source is reasonably available under RFO 6.103-1(b). The justification is based on the Resource Conservation and Recovery Act (RCRA) at 42 U.S.C. § 6961, which mandates that federal agencies comply with all state and local requirements for solid waste disposal. Market research dated 19 March 2026 confirmed that the City of Palmdale has granted an exclusive franchise agreement to WM for all commercial solid waste collection and disposal services within its jurisdiction, making WM the sole legally authorized provider in the local area. No other contractor can legally transport and dispose of AFP 42's solid waste in the local market. The contracting officer will determine price fairness and reasonableness using WM's publicly available 2025-2026 commercial rate schedules for the City of Palmdale as the baseline. No notice of proposed action will be publicized, as waste collection qualifies as a utility service under RFO 5.101(b)(1)(vi) when only one source is available.
View the file
On GovTribe
Work with this file
- Download the original file
- Contacts named in this file
- Similar government files
- Ask GovTribe AI about this file
Text version
DEPARTMENT OF THE AIR FORCE
HEADQUARTERS AIR FORCE TEST CENTER
EDWARDS AIR FORCE BASE CALIFORNIA
Sent via email
05 June 2026
FROM: CHRISTOPHER BARNES, DAF.
Contracting Officer, AFTC/PZIOB christopher.barnes.50@us.af.mil
SUBJECT: JUSTIFICATION FOR LIMITING SOURCES FOR A COMMERCIAL ITEM
ACQUISITION UNDER RFO 12 – INTEGRATED SOLID WASTE MANAGEMENT (ISWM)
SERVICES
1.0. Identification of Agency and Contracting Activity. Department of the Air Force, Air Force Test Center (AFTC), Edwards Air Force Base, CA.
2.0. Nature and/or Description of the Action Being Approved. This document justifies limiting the number of sources in the acquisition of a firm-fixed-price commercial services contract for Integrated Solid Waste Management (ISWM) at Air Force Plant 42 (AFP 42), Palmdale, CA. This justification is prepared in accordance with Revolutionary FAR Overhaul (RFO) 12.102(a). The acquisition will be conducted as a sole-source award to Waste Management of California, Inc. (WM).
3.0. Description of Services. The requirement is for the collection, transportation, and disposal/diversion of non-hazardous solid waste streams, including Municipal Solid Waste and Construction & Demolition debris. Services must be performed in accordance with the Performance Work Statement and all applicable federal, state, and local regulations. The
4.0. Authority and Rationale for Limiting Sources.
4.1. Authority. The authority for this action is RFO 6.103-1(b) One responsible source, which permits limiting sources when the contracting officer determines that only one source is reasonably available to satisfy agency requirements.
4.2. Rationale. Market research, documented in the Market Research Report dated 19 March 2026, confirms that Waste Management, Inc. is the only source capable of providing the required off-base disposal services in a manner that complies with federal law.
The basis for this determination is the Resource Conservation and Recovery Act (RCRA) at 42 U.S.C. § 6961. This federal statute contains a broad waiver of sovereign immunity and mandates that federal agencies must comply with all state and local requirements, both substantive and procedural, respecting the disposal of solid waste.
The solid waste generated at AFP 42 must be transported from the federal installation and disposed of at a state- and locally-permitted landfill. Market research confirms the City of Palmdale has granted an exclusive franchise agreement to WM for all commercial solid waste collection and disposal services within its jurisdiction.
Pursuant to RCRA, the Air Force is required to adhere to this local legal framework for off-base disposal.
Therefore, to meet its obligations under federal law, the Air Force must use the services of the sole authorized local provider. No other contractor can legally transport and dispose of AFP 42's solid waste in the local area, and as such, no other source’s services can satisfy the agency’s requirement to dispose of its waste in accordance with applicable law.
One AFMC…Powering the World’s Greatest Air Force
5.0. The contracting officer will determine the price to be fair and reasonable. A high degree of confidence in this determination exists, as the Independent Government Estimate (IGE) was developed using WM’s own publicly available 2025-2026 commercial rate schedules for the City of Palmdale. In accordance with RFO 12.204(a) Price reasonableness, this comparison to established commercial pricing provides a robust baseline for the price analysis.
6.0. Market Research. Market research was conducted in accordance with RFO Part 10 and is detailed in the Market Research Report. The research confirmed the sole-source market environment is a result of a legally binding local franchise agreement, which is made applicable to AFP 42 through the requirements of RCRA.
7.0. Other Facts. In accordance with RFO 5.101(b)(1)(vi), a notice of proposed action is not required for the acquisition of utility services when only one source is available. As waste collection is a utility service and the exclusive franchise makes WM the only available source, no notice will be publicized.
I hereby determine that the circumstances of this contract action deem it to be a sole-source acquisition.
The rationale provided in this justification is accurate and complete to the best of my knowledge and belief.
CHRIS BARNES, DAF
Contracting Officer & Lead Contract Specialist AFTC/PZIOB at Edwards AFB
File details come from the government source that posted it. Updated .