JOFOC_EP09H001115.doc

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

OFFICE OF

ADMINISTRATION

AND RESOURCES

MANAGEMENT

LIMITED SOURCES JUSTIFICATION

1. Identification of the agency and the contracting activity.

U.S. Environmental Protection Agency (EPA), Headquarters Procurement Operations Division, Administrative Contract Service Center.

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

The action being approved is the award of a bridge contract for the GSA task order EP09H001115 with one (1) six month Base Period and six (6) one-month Option Periods. This bridge contract will serve as an interim contract, providing reasonable time for EPA to solicit a consolidated contract on a competitive basis in 2016.

The consolidated contract will combine and integrate the requirements of this GSA task order EP09H001115, as well as eight other task orders different divisions and offices within EPA. Combining the requirements of these task orders into a consolidated contract will result in internal efficiency, operational effectiveness and a reduction of costs. A bridge contract is necessary to allow additional time to properly align the period of performance and the start dates of the various task orders that will be consolidated.

3. A description of the supplies or services required to meet the agency’s needs:

The Environmental Protection Agency (EPA) is striving to manage its facilities consistent with requirements and intent of statutory and regulatory mandates for pollution prevention, affirmative procurement, energy efficiency, and greening of federal facilities. The Facilities Management and Services Division (FMSD) is responsible for implementing these mandates in EPA facilities through a number of initiatives. A 5-year GSA task order EP09H001115 was awarded on 05/12/2009 to Eastern Research Group, Inc. (ERG) to provide assistance to EPA with implementing the aforementioned mandates. ERG assists FMSD with promoting and accomplishing EPA’s use of energy conservation, reduction of Greenhouse Gas (GHG) emissions, green building standards, green and renewable power, water conservation practices, adoption of innovative technology, recycling and pollution prevention programs. These efforts also substantially reduce agency operating costs. The task order awarded to ERG has four major support areas to assist FMSD with meeting EPA’s required statutory and regulatory mandates:

1.

Technical support, including a.

Research and analysis related to resource conservation and new technologies b.

Professional technical services, such as engineering and architectural support, and general program and project implementation

2.

Program/pilot development and support

3.

Outreach and training, including:

a.

Preparing training modules for internal and external use b.

Identifying and documenting best practices c.

Providing support for outreach events such as Earth Day and conferences

4.

Regular reporting and program assessments/evaluation

On May 12, 2009, the 5-year task order was awarded to ERG in the total amount of $12,007,663.40. The total estimated value of the interim bridge task order is $2,002,127 if all of the option periods are exercised. The period of performance is for one (1) six-month Base Period (March 16, 2015 – September 15, 2015) estimated at $986,269.57 and six (6) one-month Option Periods (from September 16, 2015 – March 15, 2016) estimated at $1,015,857.65.

4. Identification of the justification rationale.

The authority for this procurement is FAR 8.4 and the Multiple Award Schedule program and subsequently 8.405-6(a)(1)(i)(C) “In the interest of economy and efficiency, the new work is a logical follow-on to an original Federal Supply Schedule order.” The rationale that supports this authority is set forth below:

This is an interim bridge contract for professional services supporting FMSD to allow for the continuity of services while a long-term consolidated contract is placed for these services, estimated to be awarded in Spring 2016. Due to the nature of the competition and evaluation for the upcoming consolidated contract, it has been determined that an additional interim performance period is required until the consolidated contract is in place. The new contract will be a consolidation of this task order and eight other task orders from different offices and divisions within EPA. This requires complex joint meetings and intricate partnership between all the offices and divisions involved, not to mention, senior management’s approval for each decision made. As previously mentioned, additional time through an interim bridge contract is absolutely necessary to properly align the periods of performance and the start dates of the various task orders that will be consolidated.

In addition, ERG has provided support to EPA with the four major categories referenced above in Section #3. In providing this support, ERG has developed the specialized knowledge required to assist EPA in complying with all required statutes and regulations because of ERG’s detailed knowledge of EPA’s real estate portfolio, its ownership status, reporting status, and individual facility “optional or required” performance classifications under numerous Executive Orders and Energy Conservation legislation that impact federal green buildings Also, ERG has developed an intimate knowledge of EPA’s water conservation program and water conservation approaches specific to laboratories, and the outliers and individual water issues at each EPA facility. Therefore, ERG’s continued involvement is necessary and constitutes as a natural follow on to the work that has already been performed. While other contractors could in the long-term develop that specialized knowledge, in the short-term, it is not feasible for the planned and on-going projects, such as developing climate resiliency risk assessment procedures and EPA facility guidelines for improved climate resiliency. Over the last 18 months, ERG has developed and provided climate resiliency expertise apropos to EPA’s inventory that would take a new vendor considerable time to develop. EPA is under a tight deadline to meet the milestones in its Climate Resiliency Implementation Program, which would be in jeopardy if support by ERG is stopped midstream. Additionally, because the tasks under the current task order have begun and are in-progress, the interim bridge contract is a natural outgrowth and vital product of these existing tasks.

5. Determination that the order represents the best value to the Government.

This interim bridge contract cannot be competed or awarded to another contractor because ERG is most familiar with a large amount of varied complex components in the overall FMSD Infrastructure as outlined above in Section #3. Therefore, ERG will not be burdened with start-up cost that another vendor would encounter, nor would ERG incur the initial learning curve that would be detrimental to this current and time sensitive need.

GSA has already determined the prices to be fair and reasonable. Furthermore, the Contracting Officer will request discounts from ERG’s current GSA schedule prices. Lastly, the undersigned Contracting Officer has determined that the overall price of this acquisition was the best value for the government at the time of award.

6. Description of the market research conducted.

No new market research was conducted for this bridge contract. However, thorough market research was conducted prior to the release of the solicitation for this task order. Since the market research was last conducted, the nature of the services and the marketplace have not changed significantly, therefore, the original market research is applicable to this interim effort. In addition, the Government will once again conduct a thorough review of the vendor’s GSA schedule and its price list for pricing of all proposed labor categories, and the number of hours per labor category.

Lastly, thorough market research will be conducted prior to the release of the solicitation for the consolidated contract in order to refine our requirements in a way that will promote robust competition.

7. Any other facts supporting the justification:

N/A

8. A statement of the actions, if any, the agency may take to remove or overcome any barriers that led to the restricted consideration before any subsequent acquisition for the supplies or services is made.

EPA plans to award a consolidated contract before this interim bridge contract expires in 2016. The consolidated contract will be awarded by full and open competition, which will ensure robust competition for this consolidated contract. Several offices and divisions are currently actively pursuing this high visibility initiative and are collaborating to award a strategic sourcing contract in a timely manner.

9. Evidence that any supporting data that is the responsibility of technical or requirements personnel (e.g. verifying the Government’s minimum needs or requirements or other rationale for limited sources) and which form a basis for the justification have been certified as complete and accurate by the technical or requirements personnel.

_//signed// Peter K. Stinger_______ _________________

Project Officer

Date

10. Contracting officer certification that the justification is accurate and complete to the best of the contracting officer’s knowledge and belief.

//signed Benita Jackson ________ _________________

Contracting Officer

11. ACSC Service Center Manager certifies that the justification is accurate and complete to the best of the SCM’s knowledge and belief.

//signed// Mi Suk Cox__________ _________________

Service Center Manager

12. Competition advocate certifies that the justification is accurate and complete to the best of the competition advocate’s knowledge and belief.

//signed// Susan Moroni_______ _________________ Competition Advocate

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