Justification and Approval POF Fuels Redacted_Rev 1_Redacted 09.16._Redacted.pdf

Control Number:

A break in PM services could result in required inspections and preventive maintenance activities not being performed when scheduled, increasing the likelihood of equipment deterioration, system failures, deferred maintenance, and safety or environmental risks.

A break in CM and emergency maintenance capability would leave the Government without the established contractual mechanism and immediately available contractor capability necessary to respond to unplanned petroleum-system failures and emergency conditions. Depending upon the system affected, such failures could restrict or interrupt fueling capability at installations supporting tactical aircraft, ground forces, and other mission requirements.

These petroleum facilities directly support ability to accomplish critical joint and bilateral defense missions, maintain tactical operational readiness, and preserve strategic fueling capability across the . An interruption in maintenance support therefore presents operational consequences substantially greater than the ordinary administrative inconvenience associated with a change in contractors.

Attempting to compete and transition a different contractor solely for the interim period would also delay restoration of continuous coverage and result in duplicative transition and mobilization costs, followed shortly thereafter by another transition to the competitively selected follow-on contractor.

For these reasons, disapproval would expose the Government to unacceptable operational delay and mission risk and could result in unnecessary duplicative costs.

7. Efforts to Obtain Competition: The Government has made substantial efforts to obtain competition for the underlying long-term requirement. Market research identified five technically capable firms, and CEHNC issued the competitive follow-on solicitation on 18 March 2026. Proposals were received on 13 April 2026 and are currently being evaluated through the competitive source-selection process.

A separate interim acquisition was not initiated earlier because the Government reasonably anticipated completing the competitive follow-on before expiration of the current contract. Only as the source-selection process progressed did it become apparent that the remaining evaluation, discussions, review, approval, and award activities would extend beyond 27 August 2026.

Additionally, once the need for an interim action became apparent, in accordance with DFARS PGI 206.302-1(d), CEHNC posted a Sources Sought Notice on 05 August 2026.

Three sources responded:

In FY2024, changes to GSA processes resulted in discontinuation of the catalog method previously used by CEHNC. GSA proposed using CTAs as an alternative.

CEHNC determined that the contemplated CTA approach did not adequately support the HNC Fuels Program's requirement for immediate emergency service orders because necessary items would need to be available through participating CTA members' existing MAS offerings.

CEHNC consequently began development of a standalone follow-on contract capable of supporting recurring PM, FFP CM service orders, and emergency service orders under a single program structure.

, is currently performing these services under GSA Task

Order , which expires on 27 August 2026.

The competitive successor requirement was issued under Solicitation No. W912DY-26- R-A005 on 18 March 2026. Proposals were received on 13 April 2026, and source selection remains in progress.

b. Other facts. The Government's determination is based on the distinction between a contractor's general technical capability to perform the requirement and its ability to satisfy the Government's immediate need within the available interim period.

The Government recognizes that other firms are capable of competing for the long-term requirement. The basis for this J&A is that transitioning to another contractor before completion of the competitive follow-on would require additional acquisition and transition time, result in an unacceptable interruption or delay in critical fuels maintenance capability and impose duplicative transition costs for what is intended to be only a temporary period of performance.

This approach is consistent with Government Accountability Office decisions recognizing that RFO 6.103-1 may support an interim award to an incumbent where other firms could ultimately perform the underlying services but could not be competed, transitioned, and placed into full performance within the available interim period without unacceptable delay.

The Government has also considered RFO 6.103(b)(1), which prohibits justification of other than full and open competition based upon a lack of advance planning. The acquisition history described above demonstrates that CEHNC began planning for the follow-on requirement well before expiration of the current contract and has continuously pursued a competitive replacement. The need for this limited interim action resulted from the amount of time required to complete a complex competitive source selection, rather than an absence of procurement planning.

The proposed contract is therefore limited to the minimum period reasonably necessary to maintain continuity of critical services while completing the competitive follow-on acquisition.