Justification_and_Approval_for_Other_than_Full_and_Open_Competition_Redacted_1.pdf

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WBR 1406.303-1 Template 1 eFile - B02

(04/2021)

JUSTIFICATION AND APPROVAL FOR OTHER THAN FULL AND OPEN

COMPETITION

In accordance with FAR 6.302 or FAR 13.501(a), the proposed contractual action is pursuant to the statutory authority identified in paragraph 4. This template is required for actions over the Simplified Acquisition Threshold (unless the procurement is acquired as a limited source IAW FAR 8.405-6 or is an Exception to Fair Opportunity IAW FAR 16.505(b)(2)).

1. Agency and Contracting Activity (FAR 6.303-2(b)(1)). U.S. Department of the Interior, Bureau of Reclamation, Lower Colorado Basin.

2. Nature/Description of Action (FAR 6.303-2(b)(2)). Approval is being requested for other than full and open competition for a firm-fixed price contract for parking and ticketing services at Hoover Dam.

3. Description of Supplies/Services (FAR 6.303-2(b)(3)). This is a service requirement for parking and ticketing services at Hoover Dam which includes all personnel, equipment, materials, supervision, and other items and services necessary to implement, manage, and operate an integrated on-site Ticket Sales and Reservations System for the Visitor Center admission, tour tickets and special events at Hoover Dam, as well as, for the Hoover Dam Parking Garage (HDPG), Fee Collection Point (FCP) and Parking Lot Number 9. The period of performance for this requirement is 6 months with an option in accordance with FAR 52.217-8, using FY 2026 funding. The estimated value of this procurement is

4. Statutory Authority Permitting Other than Full and Open Competition (FAR 6.303- 2(b)(4)).

Authority FAR Coverage Application 41 U.S.C. 3304(a)(2) FAR 6.302-2 Unusual and compelling urgency

5. Demonstration of Contractor’s Unique Qualifications (FAR 6.303-2(b)(5)).

This requirement is being solicited on a sole source basis in accordance with FAR 6.302- 2, Unusual and Compelling Urgency. The current performance period for these services will end on December 31, 2025, and the contract has already utilized the maximum six-month extension allowed under FAR 52.217-8. The requirement is to provide operations and management services to run the parking lot and tour ticketing at Hoover Dam. This project has been in the planning stages for the past year; however, unforeseen delays have significantly impacted the acquisition timeline. These delays include a late and incomplete requisition package from the customer, a Government shutdown, and staffing

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(04/2021) losses within both the program and contracting offices. The Delayed Resignation Program (DRP) further exacerbated the situation by causing unexpected staff departures and prohibiting rehiring, leaving both offices short-staffed and unable to maintain the acquisition schedule. Notably, the contracting office lost a Contracting Officer (CO) due to DRP, which increased the workload for the remaining CO and contributed to the delay in completing the competitive acquisition.

The solicitation for the new competitive contract has been written and is currently undergoing acquisition review. However, considering the remaining acquisition steps — including required legal and policy reviews, corrections to solicitation documents, System for Award Management (SAM) posting, a site visit, vendor questions, solicitation amendments, source selection, negotiations, and pre-award reviews — it is not reasonable to expect that a new competitive contract will be in place by December 31, 2025.

A lapse in service would result in the closure of the Hoover Dam parking garage, parking lots, and Visitor Center, including ceasing all public tours. This disruption would cause a significant financial loss to the Government and negatively impact public access, visitor experience, and operational continuity. Hoover Dam receives approximately 1 million visitors annually, averaging 2,700 to 3,000 visitors per day, depending on the season.

Based on the mix of ticket types for the Dam, Powerplant, and Visitor Center tours, the estimated daily revenue from ticket sales is approximately . If services were interrupted during the anticipated six-month period required to complete the competitive acquisition, the estimated revenue loss would total approximately per month.

To avoid this insurmountable financial loss and ensure uninterrupted public access and operations, the Government must pursue a short-term sole source bridge contract. Ticket sales at Hoover Dam contribute significantly to covering the operational and maintenance costs of the facility. Any disruption in these services would result in a loss of revenue, which would have a ripple effect on the overall operations and sustainability of Hoover Dam. The inability to collect fees and manage visitor access effectively is unacceptable and would not only negatively impact financial stability but also diminish the visitor experience and public trust.

The proposed sole source contractor is Laz Parking LTD, LLC., located at 1 Financial PLZ, Hartford, CT 06103. Laz Parking has been the incumbent contractor for these services at Hoover Dam for five and a half years, with a record of satisfactory performance. During this contract period, Laz Parking has consistently demonstrated the unique capabilities, experience, and expertise required to perform the specialized services at the Hoover Dam Fee Collection Point, Visitor Center, and parking garage. Their familiarity with the operational environment, security protocols, and customer service

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(04/2021) expectations has ensured uninterrupted and high-quality service delivery. Laz Parking’s personnel are already trained and embedded in the operational structure of Hoover Dam, and their continued presence is critical to maintaining continuity of service.

Transitioning to a new contractor at this time would require onboarding and training of new personnel, which would introduce significant risk of service disruption. Given the critical nature of these services and the high volume of public visitation at Hoover Dam, any delay or interruption would result in substantial financial loss and operational impact on the Government. Laz Parking’s proven ability to perform these services without interruption, combined with their institutional knowledge and operational readiness, makes them uniquely qualified to continue providing services under a short-term bridge contract.

This bridge contract will allow sufficient time for the Government to complete the solicitation, evaluation, and award of the new five-year competitive contract. It is a temporary, risk-mitigation measure that ensures continuity of services while the Government completes the in-progress, competitive acquisition for a long-term solution.

6. Description of efforts made to maximize competition (FAR 6.303-2(b)(6)).

Although this action is being conducted under the authority of FAR 6.302-2 due to unusual and compelling urgency, the Government remains committed to promoting competition to the maximum extent practicable. In this case, the urgent need to avoid a lapse in critical services precludes the ability to conduct full and open competition for the bridge contract.

However, the Government is actively developing a competitive solicitation for a new five-year contract. Market research is underway to identify qualified sources, and the upcoming solicitation will be posted on SAM.gov to ensure broad visibility and access to all interested vendors. The bridge contract is a temporary measure to maintain continuity of operations while the competitive process is completed.

The Government will not extend the bridge contract beyond the minimum time necessary to complete the competitive acquisition to demonstrate its intent to restore full and open competition as soon as practicable.

7. Determination of Fair and Reasonable Cost (FAR 6.303-2(b)(7)).

The Contracting Officer anticipates the cost for this sole source bridge contract will be fair and reasonable. This determination will be based on a comparison with historical pricing from the incumbent’s current and previous contracts for the same or similar services at the Hoover Dam Visitor Center.

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The incumbent, Laz Parking LTD, LLC, has been providing these services for the past five and a half years, . There will be no significant changes in the level of effort, service requirements, or performance locations during the bridge period.

Given the short-term nature of the bridge contract and the urgent need to avoid a lapse in critical services, the Government will use FAR 15.404-1(b)(2)(ii) historical pricing as a comparison of the proposed prices in making a price reasonableness determination.

8. Description of Market Research Conducted (FAR 6.303-2(b)(8)).

Due to the urgent nature of this requirement and the limited time available before the current contract expires on December 31, 2025, the scope of market research was necessarily constrained. However, the Government leveraged existing knowledge of the market gained through the administration of the current contract and prior procurements for similar services.

The incumbent, Laz Parking LTD, LLC, has been performing these services for over five years with satisfactory results. Their continued performance has provided the Government with insight into the technical and operational requirements of the Hoover Dam site, including visitor flow management and revenue collection systems.

While no formal Request for Information (RFI) or sources sought notice was issued for this bridge action, the Government is actively conducting market research in preparation for the upcoming full and open competition for the long-term requirement. This includes reviewing vendor capabilities, industry practices, and pricing data through platforms such as SAM.gov, GSA eLibrary, and FPDS.

The bridge contract is a one-time, short-term solution to prevent a lapse in critical services. The Government remains committed to maximizing competition for the follow-on contract and will continue to engage with industry to identify qualified sources.

9. Any Other Supporting Facts (FAR 6.303-2(b)(9)).

The Hoover Dam Visitor Center is a high-profile federal facility that serves thousands of visitors each week and generates significant revenue through parking and ticketing operations. The services provided under this contract are essential to maintaining public access, ensuring visitor safety, and supporting the operational integrity of the site. In addition, the statute that established the construction and management of Hoover Dam required allowing visitation after construction.

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A lapse in these services would not only result in the closure of the Visitor Center and parking facilities but would also lead to substantial financial losses for the Government and negatively impact the public’s experience at a nationally significant landmark.

Additionally, the unique security and logistical requirements of the Hoover Dam site make it impractical to onboard a new contractor under urgent conditions without risking operational disruption.

The use of FAR 6.302-2 is appropriate and justified given the compelling urgency and the potential consequences of service interruption.

10. Listing of Interested Sources (FAR 6.303-2(b)(10)).

Laz Parking LTD, LLC., located at 1 Financial PLZ, Hartford, CT 06103

11. Actions Taken to Remove Barriers to Competition (FAR 6.303-2(b)(11)).

The Government is committed to promoting full and open competition and has taken steps to remove barriers that may have previously limited vendor participation. Although this bridge contract is being awarded under the authority of FAR 6.302-2 due to unusual and compelling urgency, it is a temporary measure to prevent a lapse in critical services.

To support future competition, the Government is:

Developing a new competitive solicitation for a five-year contract that will be posted on SAM.gov to ensure broad visibility and access to all interested vendors.

Conducting market research to identify additional qualified sources capable of performing the required services.

Reviewing and updating the performance work statement (PWS) to ensure it is clear, current, and does not contain unnecessarily restrictive requirements.

Engaging with industry through informal outreach and planning for potential pre-solicitation notices to encourage vendor interest and feedback.

These actions are intended to ensure that the follow-on contract is awarded through full and open competition, consistent with the Competition in Contracting Act (CICA) and the Government’s acquisition objectives.

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SIGNATURES

REQUESTING OFFICE REPRESENTATIVE CERTIFICATION:

PREPARED BY:

CONTRACTING OFFICER (CO) (FAR 6.304(a)(1) or FAR 13.501(a)(2)(i)): (All Values)

CIDEF OF THE CONTRACTING OFFICE (CCO) (DOI-AAAP-0024): (> $250K)

BUREAU COMPETITION ADVOCATE (FAR 6.304(a)(2) or FAR 13.501(a)(2)(ii)):

(>$750K)

WBR 1406.303-1 Template 1 eFile -B02

(04/2021)