Justification and Approval Redacted.pdf

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PL 84-99 GGS Mitigation Credits
Solicitation number
W9123826Q1By7
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JUSTIFICATION AND APPROVAL FOR OTHER THAN FULL AND OPEN COMPETITION

This document is a Justification Review Document and Contracting Officer approval for a single-source procurement by the U.S. Army Corps of Engineers (USACE), Sacramento District. The contracting action procures 16.08 Giant Garter Snake (GGS) habitat mitigation credits from a USFWS-approved mitigation bank to support the 2017 Public Law 84-99 Rehabilitation Inspection Program (RIP) mitigation projects. The procurement is a new firm-fixed price contract, with an estimated value that is redacted. The authority for other than full and open competition is 10 U.S.C. § 3204(a)(1), implemented by RFO 6.103-1(b), citing that only one responsible source can satisfy agency requirements. The contracting activity is USACE, Sacramento District, Contracting Division, Service and Supply Section, located at 1325 J Street, Room 1420, Sacramento, California 95814-2928.

The single-source justification is based on strict regulatory requirements mandating that GGS mitigation credits must be purchased from a USFWS-approved mitigation bank located within the Sacramento Basin service area. Market research identified only Resource Environmental Solutions (RES) as having currently available USFWS-approved GGS credits within the mandated service area at a competitive price lower than the published rate. Westervelt Ecological Services offered credits pending final Bank Enabling Instrument (BEI) signature anticipated in early 2027, making it a high-risk option. The Independent Government Estimate (IGE) was generated using quoted market cost from RES, confirming pricing is grounded in current market realities. The contractor must submit a price/cost proposal per IAW RFO Part 15; Certified Cost or Pricing Data will not be required. The document was prepared and approved by the Contracting Officer on 29 June 2026.

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