JA_NAVFAC SW NR MASC_FINAL with signature page_Redacted.pdf

DEPARTMENT OF THE NAVY

NAVAL FACILITIES ENGINEERING SYSTEMS COMMAND SOUTHWEST

750 PACIFIC HIGHWAY

SAN DIEGO CA 92132-5190

IN REPLY REFER TO

J&A No. 26-16-2

February 19, 2026

JUSTIFICATION AND APPROVAL

FOR USE OF OTHER THAN FULL AND OPEN COMPETITION

1. Contracting Activity.

Department of the Navy, Naval Facilities Engineering Systems Command Southwest (NAVFAC SW), San Diego, California.

2. Description of the Action Being Approved.

This justification and approval (J&A) authorizes and approves a 12-month extension to the period of performance, using other than full and open competition, for the Natural Resources (NR) Multiple Award Service Contract (MASC) (overall referred to as the “NR MASC”) N62473-20-D-0021, N62473-20-D- 0022, and N62473-20-D-0023.

3. Description of Supplies/Services.

The NR MASC is used to award task orders for services for botanical, ornithological, mammal, amphibian, reptile and invertebrate surveys; wetland delineations; biological monitoring; soil sampling and analysis; natural resources management plans, native plant community planning and restoration, wildland erosion control plans, fire management plans; analysis of the effect of military training or similar extensive land uses on natural resources at the species, community and landscape scale; and use of this information to predict ecological trends; natural resources and land use model development (including both conceptual and mathematical modeling); aerial photos interpretation of land use and natural resources in non-urban areas; geographic information systems (GIS); research on natural resource related optics; and preparation of interpretive materials on natural resources topics at various military installations located in the NAVFAC SW area of responsibility to include, but not limited to: Arizona, California, Colorado, Nevada, New Mexico, Utah, Oregon and Washington.

The Contracts were competitively awarded, pursuant to 10 U.S.C. Section 3203 as implemented by Federal Acquisition Regulation (FAR) 6.203, among small businesses, to four (4) contractors on March 2, 2020, as follows: N62473-20-D-0021 to Vernadero Group, Inc, N62473-20-D-0022 to Gulf South Research Corporation (GSRC), N62473-20-D-0023 to BioResource Consultants Inc., and N62473-20-D- 0024 to Hercules Joint Venture. The proposed action will extend the existing contract for twelve (12) months to March 1, 2027. The contract had a two (2) year base period, one (1) three (3) year option period, and one (1) one (1) year bridge period approved January 15, 2025. The maximum capacity for all four (4) contractors is $60,000,000.00. The total awarded amount to date is approximately

. No additional capacity is being added. Three (3) of the four (4) contractors agreed to keep year five (5) pricing and will have their respective contracts extended (N62473-20-D-0021 to Vernadero Group, Inc, N62473-20-D-0022 to Gulf South Research Corporation (GSRC), and N62473- 20-D-0023 to BioResource Consultants Inc.).

4. Statutory Authority Permitting Other Than Full and Open Competition.

The statutory authority permitting other than full and open competition is 10 U.S.C. Section 3204(a)(1), as implemented by FAR 6.302-1, Only one responsible source and no other supplies or services will satisfy agency requirements.

5. Rationale Justifying Use of Cited Statutory Authority.

This action is justified under the authority of FAR 6.302-1, Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements. According to FAR 6.302-1(a)(2), this authority is applicable when the supplies or services required by Department of Defense (DoD) are available from only one or a limited number of responsible sources, and no other type of supplies or services will satisfy agency requirements.

Additionally, FAR 6.302-1(a)(2)(iii) states that for DoD, National Aeronautics and Space Administration (NASA), and the Coast Guard, services may be deemed available from only the original source for follow-on contracts for highly specialized services, particularly when award to another source would likely result in:

(A) Substantial duplication of cost to the Government that is not expected to be recovered through competition: or

(B) Unacceptable delays in fulfilling the agency’s requirements (see 10 U.S.C. Section 3204(b)(B)).

As detailed below, at the present time, only the current NR MASC can meet the agency’s needs.

Proceeding with full and open competition for this requirement at this time would result in both of these adverse outcomes.

Background:

The existing NR MASC provides NAVFAC SW with a critical rapid-execution capability. Currently, task orders with pre-priced Exhibit Line Item Numbers (ELINs) are awarded within three weeks of receiving a work package. A unique feature of this MASC is the ability to award some task orders in as little as a few days.

This capability is essential for responding to emergent requirements and critical events, allowing supported projects to proceed without significant delays. Furthermore, the use of pre-priced ELINs enables NAVFAC SW to award task orders late in the fourth quarter, ensuring critical requirements are met before the fiscal year ends—a significant benefit to NAVFAC SW and its supported commands.

Impact of Non-Approval: Delays and Increased Costs:

If an extension to the period of performance is not granted, NAVFAC SW will lose this rapid procurement capability and face the following consequences:

A. Unacceptable Delays in Fulfilling Agency Requirements Without the NR MASC, natural resources task orders would have to be procured on an individual, full and open basis. At a minimum, each new procurement would require a 30-day posting and take approximately six months (26+ weeks) to award. This represents a turnaround time nearly nine times longer than the current NR MASC process (3 weeks), severely limiting NAVFAC SW’s ability to support the warfighter.

B. Substantial Duplication of Cost to the Government In addition to unacceptable delays, procuring each requirement individually creates a significant increase in contracting labor costs. An analysis of U.S. General Services Administration (GSA), Defense Acquisition University (DAU), and U.S. Small Business Administration (SBA) data reveals a substantial difference in the hours required:

Pre-priced Task Order:

Standalone C-Type Contract:

Using median hours the labor cost difference is per project, as detailed in the tables below.

Projecting this cost difference over the projects anticipated for FY26, the U.S. Navy would incur an additional in contracting labor costs alone.

Market research and impact on Industrial Base:

Since 2014, the available pool of contractors with experience, permits, expertise, and familiarity has remained relatively constant at three (3) to four (4). Without a contract vehicle with pre-priced ELINs, NAVFAC SW would not be able to respond effectively to its supported commands, which compromises their mission readiness and support for the warfighter. Denying this NR MASC bridge contract would disproportionately harm these few contractors, as the prohibitive cost of open competitions would likely reduce the number of bidders. In the end, one of the current NR MASC contractors would likely win the individual contracts, but at a substantially higher cost to the Government and with significantly less competition.

Conclusion:

For the reasons stated above—namely, the prevention of unacceptable delays and substantial duplication of costs—this action should be approved in accordance with FAR 6.302-1, Only one responsible source and no other supplies or services will satisfy agency requirements.

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

A follow-on contract is being competitively sourced. A sources sought notice was posted to the Government Point of Entry (GPE) at sam.gov on April 9, 2025, per Defense Federal Acquisition Regulation Supplement (DFARS) Procedures, Guidance, and Information (PGI) 206.302-1(d). In response to the sources sought notice, a total of responses were received, and respondents were found to be capable. This finding is consistent with the available pool of contractors identified under “Market research and impact on Industrial Base” in section 5 above. The planned action covered by this J&A meets an exception to the synopsis requirements per FAR 5.202(a)(11). The approved J&A will be released in accordance with FAR 6.305(a).

7. Determination of Fair and Reasonable Cost.

The Contracting Officer has determined the anticipated cost to the Government of the supplies/services covered by this J&A will be fair and reasonable.

8. Actions to Remove Barriers to Future Competition.

The follow-on contract is currently being procured competitively and is anticipated to be awarded no later than . Award of this vehicle will eliminate the need for future bridge contract requests.

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.

Navy Region Southwest, N45 Environmental Division Director NAVFAC Southwest

Phone Date

LEGAL SUFFICIENCY REVIEW

I have determined this Justification is legally sufficient.

Associate Counsel

NAVFAC SW

Phone Date

CONTRACTING OFFICER CERTIFICATION

I certify that this Justification is accurate and complete to the best of my knowledge and belief.

Contracting Officer

Phone Date

NAVFAC SW ECHELON IV CCO APPROVAL

Upon the basis of the above justification, I hereby approve the proposed contract modifications described herein using other than full and open competition, pursuant to the authority of 10 U.S.C. Section 3204(a)(1).

Chief of Contracting Office

Phone Date

Digitally signed by

Date: 2026.02.05 10:56:29 -08'00'

Date: 2026.02.05 13:46:51 -08'00'

Date: 2026.02.17 08:58:00 -08'00'

Date: 2026.02.18 09:31:54 -08'00'