JA to Extend and Increase Capacity NAD AOR A-E SATOCs_SAM_Redacted.pdf

Control Number: NAD-25-005818

Justification Review Document for Other than Full and Open Competition

FAR Part 6.302-1

1. Contracting Activity: Department of the Army, United States Army Corps of Engineers (USACE), Baltimore District (CENAB).

2. Description of Action: This Justification supports a modification to six (6) Single Award Task Order Contracts (SATOC) for Architect-Engineer (A/E) Services, contract numbers W912DR20D0001 thru 0006, in order to extend the ordering period and increase the capacity. The additional ordering period and capacity will serve as a bridge until the replacement contracts are awarded, which is projected to be in the second quarter of fiscal year (FY) 2026. Task orders are anticipated to be funded with Army Operation and Maintenance (O&M) as well as Military Construction (MILCON) Planning and Design funds.

3. Description of Supplies/Services: The services covered under the contracts include preparation of full plans and specifications, preparation of design-build requests for proposal, construction cost estimating, site investigations, analysis, planning, master planning, National Environmental Policy Act (NEPA) documentation, programming (1391), topographic and utility surveys, geotechnical investigations, storm water management design, sediment and erosion control plans, National Pollutant Discharge Elimination System (NPDES) permitting (including obtaining all necessary state permits), charrettes, hazardous material investigations, Building Information Modeling (BIM), energy modeling, and the preparation of reports, studies, design criteria/ design analysis documents, Leadership in Energy and Environmental Design (LEED) documentation, value engineering, presentations, coordination with various government agencies and commissions, and other general A/E services. The Indefinite-Delivery, Indefinite-Quantity (IDIQs) are used to support Military Construction (MILCON), Sustainment, Restoration, and Maintenance (SRM), Interagency and International Support (IIS), and Civil Works projects in accordance with Defense Federal Acquisition Regulation Supplement (DFARS) 219.502-1 and DFARS 219.502-2 for military and other non-military government agencies. The geographic area of performance was the CENAB area of responsibility (AoR) within the continental United States, with incidental support to other Districts within the North Atlantic Division (CENAD) AoR (support does not include CENAD Europe District). The six (6) SATOC holders have successfully performed all awarded task orders.

Contracts W912DR20D0001 through 0006 were competitively awarded on 31 January 2020 to six

(6) firms with an individual capacity of $40M per contract, for a total capacity of $240M across all six (6) SATOCs. At that time, the common practice was to award overlapping A/E SATOCs with individual capacity and then consider each SATOC in the placement of task orders. In accordance with USACE memorandum, Subject: Updated Procedures for the Selection of Task Orders on Architect-Engineer Indefinite Delivery Contracts, first issued in April 2021 and further updated in April 2025, A/E SATOCs shall not be awarded with overlapping scopes. Rather, Multiple Award Task Order Contracts (MATOCs) are now awarded to a minimum of three (3) A/E firms and the Government applies qualification-based procedures, consistent with A/E statute, in the selection of task order awards. The follow-on procurement that will replace the current six (6) SATOCs will be

(SOURCE SELECTION INFORMATION SEE FAR 2.101 AND 3.104-4)

b. Justification. The services provided by the six (6) existing SATOC holders are specialized in nature, as they provide A/E design services for complex facilities requirements within the CENAB AoR and CENAD. Specialized experience includes, but it not limited to, experience with USACE, DoD, and other federal design criteria and policy, such as, adopted industry codes as indicated in the Unified Design Criteria (UFCs), Anti-Terrorism Force Protection and Cybersecurity requirements, and legislative requirements, such as the Energy Policy Act of 2005 (EPACT), Energy Independence and Security Act (EISA07), National Environmental Policy Act (NEPA), Section 106 of the National Historic Preservation Act of 1996 (NHPA), Executive Orders, and National Defense Authorization Act (NDAA) Directives. These contracts were awarded according to the procedures of the Selection of Architects and Engineers statute with selection based on qualifications. The selected A/E firms were the most highly qualified and the price schedules were determined to be fair and reasonably priced. Increasing the capacity of the IDIQ contracts will enable CENAB to continue issuing competitive task orders for known mission critical requirements that cannot wait for award of the replacement MATOC, and also to continue executing unexercised options and necessary modifications to ongoing task orders without untenable delays.

SATOCs for the A/E Services requirements detailed in Tables 2-4, as their award is expected before the replacement MATOCs are available. As detailed in Table 5, the known forecasted capacity requirements are . To accommodate potential changes, economic uncertainties, and unknown future requirements within CENAB, an additional contingency is necessary to ensure timely award of task orders and modifications without unacceptable delays.

Over the last five (5) years of ordering, the total orders per year has ranged from to which necessitates a high level of flexibility for contingencies. Therefore, the capacity increase of $90M is required to meet project needs without untenable delays.

Due to the unique demands of its stakeholders, CENAB requires A/E firms with specialized experience, particularly in the unique environment of the National Capital Region (NCR). This includes a proven track record in expeditious delivery, deep familiarity with FAR requirements for construction procurement, and expertise in building quality through Unified Guide Specifications (UFGS). Crucially, firms must demonstrate cost estimating consistency capabilities, including experience with DoD Construction Agent (DCA) cost assessments and Cost Schedule Risk Analysis (CSRAs). This expertise is vital for establishing design maturity, cost estimate classification, and the accurate completion of DoD ENG FORM 6196 and validation of DoD programming documentation (DD FORM 1391), which are necessary for project appropriation and authorization.

Our existing A/E firms were among the first for NAB to implement these newer DoD requirements related to DCA cost assessments, CSRAs, and ENG FORM 6196 completion early in their contract delivery periods. This specific experience has been invaluable for navigating the NCR's stringent regulatory environment, which involves the Commission of Fine Arts (CFA) and the National Capital Planning Commission (NCPC). Successfully managing projects within this complex landscape a critical consideration for our Mid-Atlantic and NCR stakeholders requires an exceptional understanding of state and local codes, procedures, and stakeholder engagement.

While other contractors may possess some of these capabilities, the current firms have demonstrated their specialized knowledge and ability to navigate complex approvals and collaborate effectively with advisory agencies. Extending their services under the existing contracts is essential to avoid unacceptable delays in critical projects over the next year. Such delays would not only jeopardize the timely execution of vital infrastructure and mission support initiatives but also risk significant cost overruns due to prolonged project timelines, increased administrative burden, and potential re-scoping requirements. Furthermore, any substantial disruption in design and planning could impact stakeholder confidence, delay critical appropriations, and potentially lead to disruptions in essential services. This continuity with firms already proficient in these unique demands and regulatory processes minimizes the risk of project setbacks and ensures timely delivery during this transition period.

Due to the unique requirements associated with ongoing task orders, the continuation of A/E services under the expiring SATOC is necessary to support USACE project delivery. The incumbent Contract Holders currently serve as the Designer of Record (DOR) on multiple projects that are either in late design stages or under active construction. In accordance with FAR 6.302- 1(a)(2)(iii), "when the supplies or services required by the agency are available from only one responsible source," these services are not practicably available from any other source without unacceptable delays or substantial duplication of cost.

Changing the DOR at this stage of the project life cycle presents unacceptable technical and contractual risks. Design continuity is essential to maintain design intent, ensure timely responses during construction, and avoid rework or misinterpretation. Transitioning to a new A/E firm would also incur significant costs associated with revalidation, re-design, and onboarding. These costs would not provide added value and would delay delivery of mission-critical projects. The current DORs are actively engaged in construction administration activities, including responding to requests for information, reviewing submittals, and addressing unforeseen site conditions. Their effectively. The incumbent firms possess deep institutional and project-specific knowledge that would be lost if a new firm were engaged. Their familiarity with site conditions, stakeholder requirements, and project history provides significant benefit to program continuity and efficiency.

The decision to continue using the incumbent A/E Contract Holders under the expiring SATOC is based on their unique position as DOR for active projects and their irreplaceable role in ensuring continuity and construction support. As such, any deviation from this approach would result in undue cost, delay, and technical risk, inconsistent with USACE mission requirements and sound acquisition practices.

While the preceding discussion primarily addresses the necessity of continuing services for existing task orders nearing completion or requiring modifications, this Justification also supports the need to issue new task orders under the proposed SATOC modification during the extension period. To illustrate the urgency and infeasibility of alternative procurement methods for these new requirements, the following paragraphs outline the justifications for a representative sample of planned projects identified in Table 4 above. These justifications, while specific to the projects highlighted, are indicative of the overall need to leverage the existing SATOC to ensure timely and efficient project delivery in alignment with USACE mission requirements due to the time-critical nature of these projects.

Specifically, Items 4 & 5 on Table 4 above are MILCON projects to design and construct

Additionally, multiple Sustainment, Restoration, and Modernization (SRM) and International and Interagency Support (IIS) projects listed in Table 4 are similarly time-sensitive and crucial for maintaining operational readiness and safety across various installations within CENAB's AOR.

These projects, while generally smaller in scale than MILCON, collectively represent a significant portion of annual programmed funding and address immediate infrastructure deficiencies. The following examples highlight the urgency and necessity of utilizing the SATOC for smaller, yet equally critical, SRM projects.

. Failure to upgrade these systems increases the risk of uncontrolled fires, potentially leading to significant property damage, personnel injuries, and even loss of life. The storage and handling of munitions inherently involves a heightened risk of fire, making reliable fire suppression systems absolutely essential.

Lastly, in addition to maintaining infrastructure through SRM projects, CENAB plays a vital role in supporting international and interagency partners through dedicated IIS projects. These collaborative efforts, while distinct in their scope and objectives, share the same imperative for timely execution to ensure mission success and maintain strong partnerships. The following examples will demonstrate the time and mission criticality of representative IIS projects.

In summary, the projects identified in Table 4, and their respective programs, are in direct alignment with enterprise mission priorities and national defense imperatives. Delays in planned and programmed awards would result in unacceptable setbacks to national readiness, innovation, and quality of life initiatives impacting service members and their families. This acquisition action is mission-critical across multiple defense objectives to include Readiness and Modernization, Industrial Base Revitalization, Talent Retention and Quality of Life, and Strategic Unity and National Security. Senior defense leadership has emphasized the urgent requirement to ensure troops have the necessary training, equipment, and leadership to succeed. The Secretary of the Defense has prioritized reform of the defense acquisition process and revitalization of the industrial base. This effort requires the acceleration of innovation, production, and fielding timelines from years to weeks or months. Addressing recruitment and retention challenges requires decisive investment in support systems for Soldiers, Sailors, and Airmen. Approval enables progress in improvements in pay, housing, and childcare that directly affect force stability and family well-being. The strength of our military lies in unity and shared purpose. Planned execution of identified projects supports a capable, lethal force and aligns with national priorities to safeguard homeland security and global stability. Any delay beyond the most efficient acquisition process may impose operational, industrial, and human capital costs inconsistent with senior military leadership priorities and strategic guidance. Prompt execution is essential to fulfill our commitment to deliver and support the Warfighter and Nation.

c. Alternatives. Alternative options to the existing A/E SATOCs were evaluated for suitability.

The request for increased capacity is limited to the amount reasonably calculated to support the program requirements until the replacement MATOC is in place. There were no acceptable or viable alternatives available that can be utilized on a timeline that will support the specialized nature of the work and execution of key SRM, MILCON and IIS requirements discussed in this J&A.

i) Standalone Contracts. Awarding a standalone contract is not feasible due to the significant time and cost involved. The procurement process alone typically takes business days, and when the acquisition requirements planning phase is included, the average lead time is approximately business days. In contrast, task orders under an IDIQ for projects valued between and have a procurement lead time of just business days, with a total average acquisition lead time of business days. Utilizing an IDIQ for task order execution offers a time savings of roughly calendar weeks per typical project a critical advantage for design project timelines. projects identified in Table 2 require award timelines shorter than the time needed to establish a new standalone A/E services contract.

ii) Replacement MATOC. Planning for a $500M replacement A/E services MATOC for a five (5)-year period began in within the CENAB. Despite planning for the replacement MATOC beginning in with an initial target award of January 2025, the projected award date has shifted to the second quarter of FY 2026.

Consequently, the new MATOC will not be available to support critical project needs arising in fourth quarter FY 2025 into first and second quarter of FY 2026.

iii) Borrowing IDIQ Capacity from other Organizations. To cover larger project requirements while this J&A is under review, CENAB is leveraging other A/E Service contracts that have geographic scope coverage within CENAD with highly qualified firms for requirements covered by the current suite of SATOC contracts. Most of the other Districts within CENAD do not have available capacity to transfer to CENAB. The capacity obtained from Norfolk District (CENAO) has helped to bridge the gap in needed capacity for larger projects. This borrowed capacity is expected to cover more than four (4) actions, not included in Tables 2 and 3, totaling $15M.

CENAB searched for available capacity under existing A/E Services contracts within USACE and those with other services and agencies. There is not additional capacity available to borrow from another District.

d. Impact. It is essential that CENAB obtain approval for a capacity increase of $90M for Contract Nos. W912DR20D0001 thru missions. Without this capacity increase as well as a 12-month extension to the ordering period, there will be unacceptable delays because procuring services through task orders is the only procurement method that can be executed within the required timeframe. The projects identified in Table 2 above are required to be awarded before the replacement contract can be in place. The specified requirements identified in paragraph 3 are mission, representing vital components of our infrastructure and operational readiness. Even a slight delay in obligating funds for these projects would have a cascading and potentially severe impact, leading to an entire fiscal year delay for elements within the MILCON program.

Furthermore, it would directly hinder our SRM and IIS partners who have already secured FY programmed funding based on expected timelines. Such delays don't just push schedules; they can result in lapsed funding, increased project costs due to inflation or re-scoping, and a loss of stakeholder confidence. This requested action isn't just about maintaining momentum; it's about providing CENAB with the essential capacity to execute these key mission requirements without interruption while we finalize the replacement MATOC procurement. This continuity is vital as we adapt to the new and higher levels of A/E Services requirements necessary for our evolving portfolio.

If the extension and capacity increase is not approved, CENA MILCON, IIS, and SRM programs will be negatively affected. The projects identified in Table 4 serve to sustain military installations and provide new buildings for the warfighter. The delay of these A/E Service requirements would be unacceptable and negatively impact military installation operations, life safety, and critical infrastructure. The funding for the programming and subsequent design and their resultant construction projects with a combined Programmed Amount greater than would be unacceptably delayed, pushed to out years, or cancelled.

6. Efforts to Obtain Competition: As discussed above, the replacement A/E Services contract will be competed under full and open competition with a Small Business Reserve, but award cannot be made in time to satisfy the execution of the identified urgent requirements. When considering the significant potential for negative outcomes and consequences, particularly degraded military deployment readiness, the ability to have strictly vetted contractors meeting stringent qualifications is critical, and the current A/E SATOCs are the only option available to accomplish this function without creating unacceptable delays. Contracts Nos. W912DR20D0001 thru 0006 were competed under Full and Open Competition and all future task order actions will be competed among the six (6) SATOC holders upon approval of this Justification. With the $90M in capacity shared by the Contract holders, the source selection will be more competitive since there is no risk of exceeding the capacity of a single contract causing that Contractor to be removed from the competition.

a. Effective competition. A notice of intent to increase capacity and extend the SATOCs was posted to SAM.gov on 15 April 2025 and revised on 30 April 2025 for the $90M capacity increase to be shared by the Contract Holders instead of divided between Contractors. As of 5 May 2025, CENAB received one (1) capability statement in response to the notice that was determined to be not capable.

. The replacement MATOC, anticipated for award in Q2FY26, will be solicited via Full and Open Competition.

b. Subcontracting competition. All Contract Holders on Contract Nos. W912DR20D0001 thru 0006 have individual subcontracting plans IAW FAR 52.219-9 Small Business Subcontracting Plan. As of the last reports, over half of the goals were exceeded. IAW FAR 19.705-2(e), the not envisioned at the time of contract award.

Table 6: SATOC Subcontracting Goals services covering the same geographic area in FY19. The FY19 procurement resulted in the award of two (2) Unrestricted SATOCs in the amount of $24.5M each, for a total of $49M, Contract Nos.

W912DR19D0012 and W912DR19D0013. These SATOCs were awarded to Dewberry-Mason & Hanger JV and AECOM. For the existing suite of SATOCs, contracts were awarded using full and the Selection of Architects and Engineers statute. The ordering capacity was set to $40M each for a total capacity of $240M with an ordering period of five years.

b. Other facts. In FY19, four (4) Small Business SATOCs were awarded in the amount of $10M each for a total of $40M, Contract Nos. W912DR19D0014 thru 17 which have expired and will be replaced as part of the pending MATOC as a Small Business Reserve. The Small Business SATOCs were awarded to Dhillon Engineering, Summer Consultants, EBL Engineers, and BKM.

Projects that are suitable for a Small Business set aside must be satisfied by borrowing capacity or establishing standalone contracts until the MATOC is awarded.

There have not been other Justifications for and of the A/E SATOCs.

The current projected capacity shortfall for known requirements and, with a contingency for capacity, a total increase of $90M is required. The CENAB MDB IDIQ Project Delivery Team has confirmed that all the SATOC Holders remain qualified. The current Contractors have all competed for and been awarded task orders under this suite of SATOCs. They have demonstrated their technical expertise and are performing satisfactorily for the Baltimore District.

These Contractors are familiar with the CENAB mission, local codes, laws and regulations, and there will not be any delays using these Contractors to continue to perform the work identified within this Justification.