JOFOC_Riddle__(SAM_gov_Redacted)_1.pdf

United States Department of the Interior

BUREAU OF LAND MANAGEMENT

https://www.blm.gov

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

This document sets forth the justification and approval in accordance with Revolutionary Federal Acquisition Regulation (FAR) Overhaul 6.103 and Department of Interior-Acquisition, Assistance, and Asset Policy (AAAP)- F0006.

1. Identification of the Agency and the Contracting Activity:

Department of the Interior (DOI) Bureau of Land Management (BLM)

DOI BLM Headquarters Operations Office of Acquisition and Property Management

2. Nature/description of the action:

This action is a non-competitive out-of-scope follow-on to Task Order (TO) 140L0125F0048 under Indefinite

Delivery Indefinite Quantity (IDIQ) contract 140L0120D0008 for the Wild Horse and Burro Program (WHBP)

Off-Range Pastures (ORP) support services. The current TO expires June 30, 2026. The Government requires continued performance; therefore, this modification will extend the period of performance for six months

(184 days), from July 1, 2026, through December 31, 2026, and add the necessary funding.

The original competitive full and open Request for Proposal (RFP) No. 140L0119R0002 and IDIQ award did not include a contract ceiling. A ceiling of $ was later established by bilateral modification. Total obligations recorded in Financial and Business Management System (FBMS) for all task orders, excluding this one, are $ , exceeding the established ceiling.

As a result, this extension represents a new, sole-source requirement outside the original scope and must be justified as an exception to full and open competition.

3. A description of the supplies or services, including the estimated value:

Excess wild horses are removed from the public lands and made available to the public to be placed into private care through adoptions and sales programs. Wild horses that have not been adopted or purchased are cared for in corrals and ORP. ORP contractors for which the requirements of the National

Environmental Policy Act (NEPA) have been met are eligible to provide ORP services. The NEPA process takes a minimum of six months for new contractors. The above contractor has completed NEPA compliance and provides off-range pasture services for up to 785 wild horses. Given that the current contract is expiring, this 6-month extension is necessary to continue providing care for these horses until additional pasture space becomes available through anticipated contract awards from RFP No.

140L0125R0010.

The total estimated value of the extension is $ for 184 days

4. Statutory authority permitting other than full and open competition:

41 U.S.C. 3304(a)(1), FAR 6.103-1 Only one responsible source and no other supplies or services will satisfy agency requirements

5. A demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited:

The proposed contractor possesses unique qualifications that necessitate use of cited authority. The incumbent, Sharon Riddle, has successfully provided off‑range pasture care for BLM horses for approximately fifteen years, and currently maintains approved facilities and pastures supported by existing NEPA compliance. Establishing a new facility requires a comprehensive approval process that typically takes six months or longer, making prompt transition to a new contractor infeasible.

Extending the current order is necessary to ensure uninterrupted care while additional capacity is obtained through a new procurement. Riddle’s approved facilities, available pasture space, and established operations provide the only viable near‑term solution, as alternative facilities lack sufficient space to accept these animals. Relocating the horses at this time would create substantial change, including elevated stress, increased risk of injury or fatality, heightened disease‑transmission risk, and an estimated relocation cost of approximately $ . Feeding day costs would continue to accrue regardless of location.

Riddle’s long‑standing performance under the contract also allows BLM WHBP personnel to maintain consistent access for inspections and operational oversight. Transitioning the animals to another provider would pose mission risk, including possible service interruption, schedule delays, duplicative costs, and potential harm to the animals.

Accordingly, the incumbent contractor is the only source capable of meeting the agency’s needs within the designated period, and extending the contract is fully justified to ensure continuity of operations and protection of animal welfare.

6. A 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 FAR Subpart 5.2 and, if not, which exception under FAR 5.202 applies:

Potential ORP contractors were not solicited due to the limited duration of this requirement and the duration of time required to obtain DNA. A public notice will be posted to SAM.gov.

7. Determination of fair and reasonable cost:

The price for the extension is the same unit rate as current TO. The contracting officer determined that the anticipated cost to the government was fair and reasonable.

8. Description of market research conducted:

New Market Research was not conducted for this effort. Any findings would not result in a new award due to the extraordinarily long approval process for potential awardees. The NEPA compliance process for new contractors takes a minimum of six to twenty-four months and as such no one can meet the continuity requirement without delay.

9. Any other supporting facts:

• There are no other existing efforts to meet this need, nor are there any existing pasture or corral facilities that can promptly care for this inventory of horses.

• The new RFP is being prepared, and BLM anticipates awards later this year.

10. Listing of interested sources:

• Sources listed at time of RFP posting.

• None for this immediate TO effort.

• Any new sources for off-range pasture services would be eligible to submit a proposal in response to pending RFP No. 140L0125R0010.

11. Actions taken to remove barriers to competition:

The Government will:

• Refine future requirements and continue funding forecasts

• Ensure future solicitations/contracts include sufficient ceiling and/or options

• Ensure RFP No. 140L0125R0010 allows qualified vendors to submit proposals, following the requirements outlined in the RFP.

This request is specifically to extend the current period of performance until the award of new ORP services can be made.

12. Certification and Signatures:

I certify that any supporting data is the responsibility of technical or requirements personnel (i.e. verifying the Government’s minimum needs or schedule requirements or other rationale for other than full and open competition) and which form a basis for the justification have been certified as complete and accurate:

Approvals and Signatures on file