JA 22P0181 P00011 CLIN 0006 Increase FINAL_Redacted.pdf

The contract was awarded on 30 JUN 2022, inclusive of all options, in the amount of $3,108,220.65. It has been modified ten times as follows: Modifications P00001 and P0002 were executed to accomplish no-cost administrative changes to include correcting the MILSTRIP and incorporating a DD254. Modification P00003 was executed in APR 2023 and added CLINs 0004 and 0005 in the amount of $2,437,804.21. Modifications P00004 and P00005 exercised CLINs 0005 and 0002, respectively. Modification P00006 extended CLIN 0004 for two additional months to result in the amount and period of performance shown in the table above. Modification P00007 performed a no-cost administrative change to correct a line of accounting. Modification P00008 exercised CLIN 0003. Modification P00009 was executed in JUN 2024 and added CLINs 0006, 10003, 1004, 2003, 2004, 3003 and 3004, in the amount of $2,493,895.35. Modification P00010 performed a no-cost change of the period of performance for CLIN 0006.

CLIN 0006, highlighted above, was awarded via Modification P00009 for the following services:

For a 96-hour period the Government will require 24/7 coverage for five (5) CAG positions at all times from the beginning of the period until the end. This period will be executed in a consecutive four day period. Not less than 30 days' notice will be provided prior to execution of this requirement.

These services were necessary to support security requirements during a non-standard configuration of temporary HVAC equipment requiring several security doors to remain open. On 04 SEP 2024, the requiring activity advised the contract specialist that the services could not be accommodated due to a delay in the NAVFAC EURAFCENT construction contract. The contractor was instructed to not perform the services and to await direction on a revised period of performance. On 16 OCT 2024, the requiring activity advised FLSCI Naples C200 that the CLIN 0006 requirements were to be revised as follows:

For a 10-day period from 10 Nov 2024 and 20 Nov 2024, the Government will require 24/7 coverage for eight (8) CAG positions at all times. This additional work has resulted from poorly defined requirements for cold work that needs to take place. The poorly defined work prevented the BOS contractor, Valiant, from providing an appropriately sized cooling unit for the number of spaces where work is required. The change in the number of rooms requiring cold work has resulted in there being a need for additional coverage in spaces that was not originally planned for during modification P00009.

Statutory Authority Permitting Other Than Full and Open Competition.

The statutory authority permitting other than full and open competition is 41 U.S.C. § 1901, as implemented by FAR § 13.501(a)(1)(ii) and in accordance with FAR § 6.303-2.

4. Rationale Justifying Use of Cited Statutory Authority.

This proposed sole source requirement is to establish CLIN 0007 to add 24/7 coverage for a 10-day period. As previously stated, the NAVFAC EURAFCENT construction contract is approximately four months behind schedule.

The initial end date of the construction contract was 30 November 2024. The originally intended work encountered difficulties on-site that were unknown at the time of the award of the initial construction contract, which has pushed the end date of the project to 31 May 2025. The construction labor requires observation by the CSTs and CAGs to ensure compliance with security regulations. SSG must adhere to the Construction Security Plan (CSP) to meet Defense Intelligence Agency (DIA) requirements to receive final facility accreditation for construction. If there were a denial of this extension request, the NAVFAC EURAFCENT construction project would be at risk for further schedule delay, risk of continuity for security accreditation of the SCIFs, and duplication of costs. The current delay in the construction schedule drives the need for an extension of security services to clear and monitor construction personnel on site. To re-compete this requirement, it would require a minimum of 6 months to get to award, coupled with a minimum of three months to get contractor personnel cleared for entry to Europe and even longer to work onboard at NSA Capodichino. This extenuated timeframe needed to re-compete this requirement would further delay an already late construction project. All personnel required by the proposed Modification P00011 are currently on site, possess current visas, and have the necessary accreditation required to work in Italy and are onboard at NSA Capodichino.

As additionally stated above, the continuity required for security of documentation is imperative for SCIF security accreditation. In addition to the delay created by a re-competition, bringing a new contractor onboard would create an unnecessary duplication of cost, as that contractor would need to review and analyze SSG’s previous records for certification and run the risk of not approving the accreditation. If this happens, all construction work of the space would need to be torn down and rebuilt, resulting in waste of tax payer funds.

As these specialized services are in an overseas location, the short turn-around time needed to have the personnel in place, and the continuity of management for the personnel accreditation process necessitate contracting with the existing source for these services. The basic contract was competitively awarded in June 2022. In response, there were three quotes received. SSG’s quote was rated as the best value quote to the Government, with the lowest price, and being rated as having outstanding combined technical/risk and substantial confidence past performance ratings.

The services are specialized, the vendor pool is small, and SSG was selected as the best value contractor that quoted the lowest price to meet the requirement. Had these additional requirements been known at the time of solicitation, the Government has no expectation that the award to SSG would have been different.

5. Description of Efforts Made to Solicit Offers from as Many Offerors as Practicable.

The contracting officer intends to post a synopsis of the intended sole source modification to the Government-wide point of entry (GPE), the SAM website. While the Government has determined not to solicit from more than one source, if any responses are received, it will retain the information to use as market research for any future opportunities.

6. Determination of Fair and Reasonable Cost.

The total estimated value for Modification P00011 is an additional $131,071.65 . The contracting officer has determined that the anticipated cost to the Government of the additional personnel covered by this J&A will be fair and reasonable (See MFR in file).

7. Actions to Remove Barriers to Future Competition.

For the reasons set forth in Paragraph 5, NAVSUP FLCSI has no plans at this time to compete the subject extension.

However, NAVSUP FLCSI fully anticipates competing requirements for similar security services on future construction projects.

8. CONTRACTING POINT OF CONTACT

The contracting point of contact is Mr. Benjamin Hardy, who may be contacted at telephone number +39 081 568- 3979 or via e-mail at Benjamin.n.hardy.civ@us.navy.mil.

CERTIFICATIONS AND APPROVAL

TECHNICAL/REQUIREMENTS CERTIFICATION

I certify that the facts and representations under my cognizance which are included in this Justification and its supporting acquisition planning documents, except as noted herein, are complete and accurate to the best of my knowledge and belief.

Technical and Requirements Cognizance:

Signature Name (Printed) Phone No. Date

LEGAL SUFFICIENCY REVIEW

I have determined this Justification is legally sufficient.

CONTRACTING OFFICER CERTIFICATION

I certify that this Justification is accurate and complete to the best of my knowledge and belief. To the extent that the J&A value is between $250K and $750K, the Contracting Officer’s signature below also represents approval of th

CONTRACTING ACTIVITY COMPETITION ADVOCATE REVIEW

To the extent that the J&A value is between $750K and $15M, the Competition Advocate’s signature below also represents approval of the J&A.