JA Modular Dorms Redacted.pdf

Justification and Approval (J&A) for Other Than Full and Open Competition

CONTROLLED UNCLASSIFIED INFORMATION

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I. Agency and Contracting Activity.

Requirement owner: 17 Civil Engineer Squadron, Bldg 3511, 460 E. Kearney Blvd., Goodfellow AFB, TX, 76908-4104

Contracting Activity: 17 Contracting Squadron, Bldg. 707, 210 Scherz Bldv., Goodfellow AFB, TX, 76908-4104

II. Nature and/or description of the action being approved.

Goodfellow AFB currently has temporary modular dorms to house approximately 384 technical training (pipeline) students while a new 400-person dorm will start its construction in 2026 under the approved MILCON project. The previous contracts provided means to hold the 17th Training Wing's training students, providing sufficient housing to further the Wing's mission while waiting for the new pipeline dorm. This J&A will support a new firm-fixed-price follow-on contract to renew the lease of the current temporary dorms with the same Contractor. The lease duration will consist of one base year and one additional option year. The lease agreement is projected to begin in June 2026 and will continue until June 2028 or construction completion of the new 400-person dorm, whichever comes first. This new lease is a follow-on requirement to a previous lease contracts that have been in place for the last 5 years.

III. Description of supplies/services required to meet agency needs.

This J&A will cover the lease for one base year and one option year from 1 July 2026 to 30 June 2028. The previous lease was previously considered a service, however DoDI 4165.56-1.2.d-e states relocatable facilities should be considered an equipment item, driving the commodity determination. Despite this determination, the new contract includes incidental services including: furnishing all necessary parts, labor, tools, supplies, supervision, equipment and materials; the contractor will maintain utilities and maintenance for the facility. The Current permanent housing is insufficient for the students occupying the temporary dorms. The temporary dorms will be required until the new 400-person pipeline student dorm is constructed. The new dorm construction is planned to be awarded by 30 March 2026 with construction to be completed in

June 2029. Approval of this J&A will provide time for construction completion should delays occur and will prevent the displacement of students causing interruptions in the 17th Training Wing's mission.

IV. Demonstration that the contractor's unique qualifications or the nature of the acquisition requires use of the authority cited above.

Contractor's Unique Qualifications:

Intimate knowledge of the existing modular housing infrastructure, established maintenance protocols and operational procedures tailored to the current facilities, existing trained personnel familiar with the specific systems and student housing requirements, demonstrated performance history managing housing for 384 pipeline students without service interruptions.

Nature of the Acquisition:

The requirement involves continuation of a lease using existing contractor-owned modular units already installed and

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Goodfellow AFB to accommodate 384 students during any transition period, and displacing students for 2 months would disrupt training, resulting in a 1.22% reduction in training capacity for the affected period. This would create a backlog delaying their entry into critical Air Force roles and potentially impacting operational readiness. The temporary nature of the requirement (2026-2028) makes the existing solution uniquely suited, as it bridges the gap until permanent facilities are completed. Changing contractors would result in significant additional costs for demobilization/remobilization and potential mission impact due to student displacement. The estimated cost of this disruption, including lost productivity, increased training costs (due to rescheduling and overtime), and the potential for delayed deployments, is conservatively estimated at

$47,900 per-week. This estimate is based on the average cost of training an intelligence analyst, which is $5,208 per week according to Air Force training records.

The current contractor's specialized knowledge, and trained staff directly support the 17th Training Wing's ability to produce highly skilled, Department of War wide intelligence professionals and Fire Academy trainees which is critical to national security. Therefore, this justification is essential to maintaining operations and ensuring the Air Force can meet its intelligence analysis requirements without interruption.

V. Description of efforts made to ensure that offers are solicited from as many potential sources as practicable, including whether a notice was or will be publicized as required by subpart 5.2 and, if not, which exception under FAR 5.202 applies.

Market research was conducted to identify potential sources capable of providing a temporary modular housing lease for 384 pipeline students at Goodfellow AFB. However, due to the unique circumstances of this requirement, specifically the need to maintain operational continuity with existing modular infrastructure and avoid student displacement, full and open or set aside market solicitation are not practicable.

For contracts anticipated to be awarded using authority FAR 6.302-1 require pre-solicitation notice posted via GPE in accordance with FAR 5.201. The notice of the intent to award sole source will be posted on SAM.gov along with this J&A and remain posted for 15 days. The notice will provide consideration for capability statements to be used for market research purposes, however, due to the unique nature of this procurement sole source award with the incumbent contractor will be pursued.

The current proposed action extends these same general requirements: maintaining the existing modular housing units and contractor-provided facility management/maintenance services for a base year with one option year until permanent housing construction is completed. Since the fundamental scope of work remains unchanged from the previously synopsized contract, and given the operational necessity to avoid any housing service interruption, publication of a new synopsis would not yield additional qualified sources capable of seamlessly continuing operations with the existing infrastructure.

This acquisition is integral to the Mission in providing our joint training forces with suitable housing.

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VI. Determination by the Contracting Officer that the anticipated cost to the Government will be fair and reasonable.

The Contracting Officer will determine that the anticipated cost to the Government for this sole-source follow-on contract will be fair and reasonable. The determination will be based on a price analysis, comparing the proposed price to the prices paid under the existing contracts FA303021C0010 and FA303020F0075. Market research indicates no significant changes in leasing pricing for comparable leases since the previous contract award. The proposed price is expected to be comparable to the previous contract price, with any minor variances fully justified. An IGE will be prepared and validated, and the proposed price will be compared to the IGE to ensure alignment. The proposed profit/fee is anticipated to be consistent with historical profit margins for similar services and will be considered reasonable.

VII. Description of the market research conducted and the results, or a statement of the reasons market research was not conducted.

Market research indicated the incumbent, Modular Management Group, INC., is uniquely positioned to fulfill this need due to their existing on-site infrastructure, specialized knowledge, and proven performance in managing these facilities. This acquisition is a follow-on to previous contracts (FA303021C0010 and FA303020F0075) with the same contractor, aimed at avoiding unacceptable disruptions to student training and significant demobilization/remobilization costs. The temporary nature of the requirement, bridging the gap until permanent facilities are completed in 2029 with potential delays, further reinforces the rationale for leveraging the incumbent's existing capabilities.

VIII. Any other facts supporting the use of Other Than Full and Open Competition.

Any interruption to the training pipeline would negatively impact the Air Force's ability to meet its critical intelligence analysis requirements, potentially impacting national security. The combination of the incumbent's existing infrastructure, specialized knowledge, demonstrated performance, and the unacceptable disruptions and costs associated with a new contractor necessitate a sole source award to ensure the uninterrupted and cost-effective housing and training of critical Air

Force personnel under FAR 6.302-1.

IX. List of any sources that expressed, in writing, an interest in the acquisition.

Given the unique nature of this procurement, the Government has determined that full and open competition is not feasible for the follow-on lease. Therefore, a broad market survey to identify all potential contractors was not conducted. The current contractor Modular Management Group, INC who manages both incumbent contract leases (Modular Concepts, INC (CAGE

6RBD6) under contract FA303021C0010 for 84 personnel, and Modular Management Group, INC (CAGE 46Y71) under contract FA303020F0075 for 300 personnel) has expressed their willingness to support the follow-on lease under CAGE Code

46Y71, offering potential efficiencies in transition and execution.

X. A statement of the actions, if any, the agency may take to remove or overcome any barriers to competition before any subsequent acquisitions for the supplies or services required.

To increase future competition, the agency will explore alternative housing solutions, develop a transition plan for future acquisitions, and re-evaluate requirements to broaden the pool of potential contractors. Regular market research will identify new entrants and emerging technologies. Further, the agency will ensure MILCON projects remain on-time to avoid any future gaps in housing. These efforts are aimed at reducing reliance on the incumbent and fostering a more competitive environment for subsequent acquisitions. The ultimate goals is to eliminate sole source requirements unless absolutely

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XI. Certification by the Contracting Officer.

As evidenced by my signature above, I certify that this justification is accurate and complete to the best of my knowledge and belief.

XII. Certification by the technical/requirements personnel.

As evidenced by my (our) signature(s) above, I (we) certify that any supporting data contained herein, which is my (our) responsibility, is both accurate and complete.