PIADC - JA FY25-00171.pdf

JUSTIFICATION AND APPROVAL FOR OTHER THAN FULL AND OPEN

COMPETITION

41 U.S.C. 3304(a)(1))

J&A No.: FY25-00171

Pursuant to the requirements of the Competition in Contracting Act (CICA) as implemented by the Federal Acquisition Regulation (FAR) Subpart 6.3 and in accordance with the requirements of FAR 6.303-1, the justification for the use of the statutory authority under FAR Subpart 6.3 is justified by the following facts and rationale required under FAR 6.303-2 as follows:

1. Agency and Contracting Activity.

The Department of Homeland Security (DHS), Office of Procurement Operations (OPO), Federal Protective Service (FPS), Acquisition Division (AD) proposes to extend the ordering period of Contract 70RFP119DE2000002, with Alutiiq Advanced Security Solutions (Alutiiq) for Armed Protective Security Officer (PSO) and related services at Plum Island Animal Disease Center (PAIDC) on the basis of other than full and open competition.

2. Nature and/or Description of the Action being Approved.

(a) Nature of action: FPS AD intends to procure protective security officer services on a noncompetitive basis for up to six (6) months, July 1, 2025 – December 31, 2025, to allow time to finalize award of the competitive follow-on contract and provide adequate time for transition. This action will result in a modification to extend the ordering period of the current contract to allow placement of a task order to continue critical PSO and related services at Plum Island Animal Disease Center. The task order will only be issued under this contract for the necessary length of time required, but not to exceed six (6) months.

The current contract is set to expire on June 30, 2025. The follow-on procurement is currently in the pre-award phase. This follow-on effort will require a transition period of 120 days from the date of award to the performance start date. As such, this extension will allow time to complete the award documentation reviews and provide an adequate transition period to the new effort for this requirement.

(b) Name and address of the contractor:

Alutiiq Advanced Security Solutions 3909Arctic Blvd Ste 500 Anchorage, AK 99503-5769

(c) Contract type: Indefinite Delivery Indefinite Quantity, Firm Fixed Price

(d) Estimated total value: Six months -

3. Description of Services.

The purpose of this extension is to provide Armed PSO and related services at Plum Island Animal Disease Center. Alutiiq Advanced Security Solutions is currently performing under a six (6) month extension pursuant to Justification and Approval No. FY25-034 for the period January 1, 2025 – June 30, 2025 under the competitively awarded contract 70RFP119DE2000002. To complete the competitive procurement process and provide a transition period for the new follow-on contract, FPS AD finds it necessary to request approval for up to an additional six (6) months of service under the authority for other than full and open competition cited herein. This will extend the ordering period under Contract 70RFP119DE2000002 from July 1, 2025, through December 31, 2025 in the event all six months are needed.

The instant action is requested to allow FPS AD to continue procuring PSO services from Alutiiq under Contract No. 70RFP119DE2000002 while awarding the competitive follow-on contract and providing a 120-day transition period to the successful offeror. This will ensure uninterrupted security and related services at federal facilities at Plum Island Animal Disease Center between the expiration of the existing contract and the start of full performance by the successful vendor under the follow-on effort. The proposed sole source extension will ensure services are provided while the award is being finalized and will also cover the 120-day transition for the new vendor to train and meet all requirements of the new contract prior to standing post. The requirement fulfills an existing government need and the extension of the existing contract is the most advantageous and only practical method of fulfilling the government's need, price, and other factors considered.

This contract extension also takes into account the government's need for continuity of operations and potential costs of disrupting operations. The period of performance for this extension is for up to six (6) months of additional PSO services from July 1, 2025, through December 31, 2025, at an approximate value of .

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

The statutory authority permitting other than full and open competition is 41 U.S.C.

3304(a)(1) implemented by the FAR Subpart 6.302-1 entitled “Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.”

5. Identification of Exception to the Buy American Statute

Not Applicable

6. Demonstration that the proposed contractor’s unique qualifications or The nature of the acquisition requires use of the authority cited.

Alutiiq Advanced Security Solutions is currently satisfactorily performing PSO services under Contract 70RFP119DE2000002 at the PIADC. The contract is set to expire on June 30, 2025.

FPS AD is in the process of awarding a follow-on contract which was solicited as a 100% small business set-aside for Protective Security Officer and related services.

However, due to unexpected delays and circumstances beyond the control of the contracting office, the Government requires additional time to award the follow-on contract and allow for a 120-day transition. The unexpected delays were attributable to FPS incurring unexpected delays over the past several months due a variety of policy updates that led to procedural changes, thus requiring additional documentation which increased reviews and processing timelines for procurement actions. Therefore, the circumstances listed above necessitate an extension of the incumbent contract to allow for the additional time to finalize the award documentation and allow for the required transition period.

The follow-on requirement under this contract is estimated to be awarded on or before September 1, 2025, with an anticipated performance start date on or before January 1, 2026. The follow-on contract will have a transition period of 120 days from the date of award to the performance start date. This transition period enables the follow-on contractor to obtain all necessary equipment, licenses, training, and other certifications/ suitability requirements for its employees to be able to begin standing post at the start of performance. Due to extensive screening, training, licensing, and transition requirements for PSOs under the FPS program, another PSO firm cannot immediately replace the existing contractor without a severe and unacceptable degradation in overall security jeopardizing federal government personnel, visitors, and assets.

For these reasons, it is also not feasible for any portion of the work to be segregated to allow for competition. The incumbent contractor, Alutiiq, is familiar with the instant requirement, facility locations, and has a fully qualified staff in place and is the only contractor at this time that can immediately fulfill the requirement without delay or interruption of services. As a result, a short-term extension of services under the current contract is necessary to ensure a seamless transition takes place from the existing requirement to the follow-on effort.

Title 40 United States Code (U.S.C) §1315 gives DHS the responsibility to protect federal facilities and the people therein. Presidential Policy Directive 21 (PPD-21), and the National Infrastructure Protection Plan (NIPP) further refine DHS’s responsibility to protect buildings, grounds, and property that are owned, occupied, or secured by the Federal Government. These documents also establish U.S. policy for the protection and resilience of the Nation’s critical infrastructure and provide a framework for integrating efforts designed to enhance the safety of critical infrastructure. Given the reality of terrorist threats, it is in the best interests of DHS and the public to continue to allow the incumbent contractor to provide services until the follow-on contract is appropriately transitioned. Effective PSO services are integral to the FPS mission to respond to terrorist attacks, domestic workplace violence, trespassing, disorderly conduct, and emergency medical situations. PSO services also mitigate threats by detecting firearms, hazardous materials, and suspicious packages at these locations. Due to these critical roles, a modification to extend the ordering period under the current contract 70RFP119DE2000002 with Alutiiq is required to allow placement of a new competitive contract to provide continued services to ensure

The agency has conducted Market Research for the new requirement and is familiar with the other potential sources and their qualifications. Based on our market research, other firms could provide PSO services at Plum Island Animal Disease Center, however they could not do so by July 1, 2025, causing unacceptable delays or potentially jeopardizing the safety of government employees or visitors.

Accordingly, no other contractor can provide the services without an unacceptable interruption in service at this time.

10. Any Other Facts Supporting the Use of Other Than Full and Open Competition.

Since it is essential that service continue without interruption for the security of the facilities, its tenants, its visitors, and the fact that Alutiiq is performing satisfactorily as documented under the Contractor Performance Evaluation Assessment Report System (CPARS), it is in the best interest of the government to extend contract 70RFP119DE2000002 for up to six months with the current contractor.

11. A Listing of Sources, if Any That Expressed, in Writing, an Interest in the Acquisition.

Not Applicable.

12. A Statement of the Actions, if Any, the Agency May Take to Remove or Overcome Any Barriers to Competition Before Any Subsequent Acquisition for Supplies or Service Required.

This requirement is for the sole purpose of issuing a modification to continue PSO services under Contract 70RFP119DE2000002 until the competitive follow-on contract is awarded and transitioned to start. The agency is currently processing a follow-on requirement which is taking longer than originally projected due to unanticipated issues and delays. The agency plans to make award no later than September 1, 2025, with the new award to start no later than January 1, 2026. It is essential that services continue without interruption for the security of federal facilities at Plum Island Animal Disease Center to include government personnel and visitors at these locations.

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