Justification and Approval - six-month extension 20250415 draft_Redacted.pdf

Justification and Approval (J&A) for Other Than Full and Open Competition

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Was a J&A approved for the preceding acquisition where that acquisition required a J&A? Yes No

Is this a new or amended J&A Document? New Amended ( Prior to Award Only! )

Is this a Bridge Action as defined at DAFFARS 5302.101? Yes No

Dollar Value of this Acquisition: < $750K > $750K and < $15M > $15M and < $100M > $100M

Contracting Activity: 911 AW/MSG/PK

Purchase Request (if available) / Local ID Number: FA671223C0004

Program / Project (and PE, if applicable): Base Operations Support (BOS) Services for Pittsburgh ARS, PA

Program Type (PEO, Enterprise, of Operational): Operational

Authority:

6.302-1 – 10 USC 3204(a)(1), Only One Responsible Source - No Other Supplies or Services Will Satisfy Agency Requirements Estimated Contract Cost (including options): J&A Type: Class Individual

COORDINATION ( DAFFARS 5306.304(a))

Date

07 Apr 2025

Program Manager Signature

Date

08 Apr 2025

Contracting Officer Signature

Date

11 Apr 2025

Legal Reviewer Signature

Date

14 Apr 2025

Chief of the Contracting Office (COCO) Signature

APPROVAL ( DAFFARS 5306.304(a))

Date Department of the Air Force Program Executive Officer - Services, (Acting)

Signature

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I. Agency and Contracting Activity.

911 AW/MSG/PK

2375 Defense Ave., B210 Coraopolis, PA 15108

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

Pittsburgh Air Reserve Station, PA (PARS) proposes to award an extension to the existing Base Operations Support (BOS) bridge contract with Firm-Fixed-Price (FFP), Labor Hour (LH) and Cost Reimbursement (CR) Contract Line Item Numbers (CLINs) for work that cannot be accurately predicted, to the incumbent BOS services contractor, Criterion Corporation (CAGE 0KJM5), a Service-Disabled Veteran Owned (SDVOSB) and Woman Owned Small Business (WOSB).

The previous long-term contract, FA671217C0002, was competed with a Period of Performance (PoP) of 1 September 2017 to 28 February 2023, and contained FFP, LH and CR CLINs. These services are currently being performed under the existing bridge contract, FA671223C0004, with a PoP of a six (6) month base (1 March 2023 to 31 August 2023), a six (6) month extension option (1 September 2023 to 29 February 2024), followed by a secondary extension adding a nine (9) month extension (1 March 2024 to 30 November 2024) with a final five (5) month extension (1 December 2024 to 30 April 2025).

A new long-term competitive effort has been in the works since early May 2023 and the Request for Proposal (RFP) was anticipated to be posted mid-October 2023. However, the acquisition was halted prior to the release of the RFP when PARS was directed to change the course of the Source Selection Plan (SSP) by the Headquarters (HQ) Air Force Reserve Command (AFRC) A4 - Director of Logistics, Engineering and Force Protection. As a result, the new long-term competitive effort SSP has been in the process of being re-evaluated and a long-term contract will not be awarded prior to the end of the current bridge contract's PoP of 30 April 2025.

However, business clearance was received on the new acquisition strategy and the long-term RFP was officially solicited in Contract Opportunities on 19 March 2025.

This bridge contract extension is being conducted under FAR 6.302-1, Only one responsible source and no other supplies or services will satisfy agency requirements. The PoP of this bridge contract will have a six (6) month extension option (1 May 2025 to 31 October 2025). The CLIN structure for this bridge contract will mirror the CLIN structure of the current contract.

III. Description of supplies/services required to meet agency needs.

The BOS Services are Mission Essential Services to support Pittsburgh ARS, PA and its DoD mission to provide strategic airlift of airborne forces, equipment and supplies. More specifically, the BOS Services include all personnel, supervision, equipment, tools, materials, test equipment, supplies, and services necessary to accomplish the following functions:

(1) Materiel Management which is defined as the continuous actions that plan, organize, direct, coordinate, control and evaluate the application of resources to ensure the effective and economical support of the military base within the 911th Logistics Readiness Squadron (LRS).

(2) Ground Transportation and Vehicle Management which provide accountability management, and maintenance services for the base vehicle fleet, selected registered and non-registered equipment, and transient vehicles.

(3) Traffic Management Operations which provide a full range of traffic management services for base organizations, to include day-to-day, exercise and contingency operations.

(4) Real Property Maintenance which provides preventive maintenance (PM) and corrective maintenance (CM) service calls for facility maintenance for all real property, and Real Property Installed Equipment (RPIE).

(5) Fuels Management which provides fuels management services to wing, tenant, and transient organizations, as defined by the Performance Work Statement (PWS).

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Appropriated funding for the extension CLINs are FY2025 Air Force Reserve Command Operations & Maintenance (3740).

Six (6) Month Extension Period of Performance and CLIN Breakout: (1 May 2025 to 31 October 2025) CLIN 4002: Base Supply; FFP;

CLIN 4003: Vehicle Operations and Maintenance; FFP;

CLIN 4004: Traffic Management Operations; FFP;

CLIN 4006: RPM PM - General; FFP;

CLIN 4007: RPM PM - Pavement Clearance; FFP;

CLIN 4008: RPM PM - Pest Control; FFP;

CLIN 4009: RPS PM - Facilities Management; FFP;

CLIN 4010: RPS PM - Grounds Maintenance; FFP;

CLIN 4011: Fuels Management; FFP;

CLIN 4014: RPM CM/O&A - LH;

CLIN 4015: RPS CM/O&A - LH;

CLIN 4016: RPS CM/O&A - Pest Control; LH;

CLIN 4017: RPS CM/O&A - Facility Management; LH;

CLIN 4018: RPS CM/O&A - Grounds Maintenance; LH;

CLIN 4019: RPM DBA; LH;

CLIN 4020: RPM Reimbursable; CNF;

CLIN 4021: RPS Reimbursable; CNF;

CLIN 4022: RPS Pest Control Reimbursable; CNF;

CLIN 4023: RPS Facility Management Reimbursable; CNF;

CLIN 4024: RPS Grounds Maintenance Reimbursable; CNF;

CLIN 4025: Base Supply SCA/O&A; LH;

CLIN 4026: Vehicle Operations and Maintenance SCA/O&A; LH;

CLIN 4027: Traffic Management Operations SCA/O&A; LH;

CLIN 4029: Fuels Management SCA/O&A; LH;

CLIN 4032: Vehicle Operations Reimbursable; CNF;

CLIN 4033: Natural Disaster/Crisis/Terrorist Act; CNF;

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CLIN 4034: Travel; CNF;

CLIN 4035: Data; FFP; NSP

Total Estimated Value (Option Period):

The methodology used to calculate the total estimated value was based on current BOS contract expenses with % inflation adjustment rate added to the previous PoP CLINs. Reimbursable/labor hour CLINs will be adjusted based on available funding.

IV. Demonstration that the contractor's unique qualifications or the nature of the acquisition requires use of the authority cited above.

IAW 6.302-1 (a)(2)(iii), the services provided by the current contractor, Criterion Corporation, are highly specialized services based on the nature of BOS services. The PARS BOS services have been designated as mission-essential functions IAW DFARS 252.237-7023, Continuation of Essential Contractor Services (DFARS clause 252.237-7023 is cited in the current contract FA671223C0004) as well as identified in paragraph A6.3 of the Performance Work Statement. BOS services are of such a critical nature that these services must be performed 7 days a week/24 hours a day, under all circumstances so that Pittsburgh ARS is able to function, perform its DoD mission and responsibilities. Failure to perform/sustain BOS services would significantly affect the DoD's/PARS's ability to provide vital services, exercise authority, direction and control. Because of the limited performance periods, retaining the existing contractor is in the best interest of the Government. Continued timely performance is required to prevent an unacceptable delay in fulfilling the agency's BOS services requirements. An unacceptable delay is defined as a break in mission critical/essential services if the current contract does not continue performance.

The current PARS BOS services contractor, Criterion Corporation, has performed the PARS BOS services for the past seven (7) years, and has over sixteen (16) years of experience performing similar BOS services at various U.S. Air Force locations such as Pittsburgh ARS, Youngstown ARS, March ARB, as well as multiple U.S. Army locations. As the incumbent contractor, Criterion has the unique operational knowledge of the services and challenges required to ensure no break in the provision of essential contractor services while PARS finishes the competitive procurement for the follow-on BOS contract. These mission-essential services are of such a critical nature that any delay in the award of this extension would result in an immediate and serious impact to PARS's ability to function and perform its primary DoD mission and responsibilities.

To illustrate the serious mission impact that would occur at PARS if BOS services stopped, beginning 1 May 2025, the 911th Airlift Wing, 32d Aerial Port Squadron and the 758th Airlift Squadron would cease operations, resulting from the loss of Fuels Management support, Materiel Management support, and Traffic Management operations. Furthermore, all other tenant organizations located at Pittsburgh ARS would be immediately and negatively impacted with the loss of vital services such as Vehicle Operations and Maintenance support and Real Property Maintenance support.

This serious mission impact would also negatively affect environmental management activities, pavement clearance activities, pest control activities, facilities maintenance, facilities repairs, and HVAC sustainment activities, which are critical to military operations. Additionally, a work stoppage of PARS BOS services would result in grossly neglected installation and critical flight-line conditions.

PARS does not have the government-owned equipment, tools, or personnel to perform the services provided under this contract. Therefore, it is imperative that PARS retains the performance of these BOS services. A loss/gap in BOS services provided under this effort would not only result in the shutdown of Pittsburgh's mission-essential functions, it would also drastically affect its ability to exercise vital services, authority, direction, control, and support to its tenant organizations such as Headquarters, 4th Air Force and the Naval Operational Support Center.

The current PARS BOS services contractor, Criterion Corporation, is the only source that can provide the immediate capabilities necessary to meet the total BOS service requirements. Criterion Corporation has the financial stability and resources in place (e.g., all personnel, supervision, equipment, tools, materials, test equipment, and supplies) to continue performance of all BOS mission-essential services without a costly and unacceptable delay.

V. 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 subpart 5.2 and, if not, which exception under

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FAR 5.202 applies.

It would have been impracticable to solicit offers from sources other than the current contractor, to include a limited competition, due to the short time remaining until the expiration of the current PoP on 30 April 2025. With the numerous requirements included in the BOS contract, the vast amount of initial award contract deliverables, along with need for site-visits, question-and-answer period, negotiations, mobilization/de-mobilization period, if applicable, and the time frame required for solicitation posting, there is not enough time between the current contract PoP end date and the ability for a new contractor to take over all aspects of the BOS contract without creating an undue delay to the mission. The exorbitant start-up/mobilization costs for any new contractor to try and take over all BOS requirements, hire and transition all personnel, purchase all required materials, vehicles, equipment, submit all Contract Data Requirement List (CDRL) deliverables/reports, and have any new personnel trained and ready to go by 1 May 2025 is impractical from an initial start-up cost perspective. Especially if there is no guarantee the new contractor will be awarded the long-term contract after this short-term effort expires in order to recuperate all of their initial start-up/upfront mobilization costs.

A notice of this bridge action will be publicized IAW FAR 5.2, Synopsis of Proposed Contract Actions in Contract Opportunities no later than 15 April 2025.

VI. Determination by the Contracting Officer that the anticipated cost to the Government will be fair and reasonable.

The cost/price of this bridge effort will be determined fair and reasonable to the Government based upon comparison of the existing BOS contract costs and any cost/price analysis of other than certified cost or pricing data if needed.

VII. Description of the market research conducted and the results, or a statement of the reasons market research was not conducted.

Market research has been conducted for the long-term, follow-up requirement which will provide for full competition.

While market research has shown that there are multiple sources currently available to provide BOS services, no one source can take over all BOS services beginning 1 May 2025 without unacceptable delays and exorbitant costs to account for the initial mobilization costs and risks associated with a short-term contract.

VIII. Any other facts supporting the use of Other Than Full and Open Competition.

FAR 6.302-1, Only on responsible source and no other supplies or services will satisfy agency requirements, is appropriate as any lapse in the award of a contract for BOS services which provides mission-essential services could result in the shut down of operations at PARS. The bridge contract will provide the minimum time necessary to finalize any current issues on the long-term effort to allow for adequate competition of the new contract.

Several Air Force Reserve Command (AFRC) locations anticipated an award of a FFP competitive contract prior to the expiration of the previous long-term PARS BOS Services contract. The below timeline is relevant to the PARS BOS requirement because the Logistics, Engineering, and Security Forces Directorate (HQ AFRC/A4) BOS Performance Work Statement is used across AFRC bases with minor changes for unique base requirements.

On 25 June 2021, an interested party on the Westover Air Reserve Base (ARB), MA, BOS Request for Proposal (RFP) FA660621R0001 under notice FA660621RWESTOVERBOS, filed a pre-award protest with the Government Accountability Office (GAO) challenging the terms of the solicitation which differ from the terms of the current Westover ARB BOS contract, to include the category of services (currently non-commercial/now considered commercial); and type of contract (currently cost reimbursement/now entirely firm-fixed price). The protest focused on the impact of these changes primarily related to the corrective maintenance CLINs as industry typically performs corrective maintenance on some type of "reimbursable" basis. The Air Force decided to take corrective action consisting of revising the minimum requirements and making any other corrective actions deemed necessary. On 20 July 2021, GAO dismissed the protest stating that the Air Force has committed itself to revising the solicitation and to provide offerors with the opportunity to respond to the revised solicitation. The Air Force deemed it in everyone's interest (Air Force and offerors) to cancel the current RFP, modify/extend the existing contract, and release a new RFP.

Dobbins ARB, GA then posted a separate BOS RFP FA670322R001 under a notice titled Dobbins BOS Services, through

August 2023 Page 6 of 7August 2023 Page 6 of 7 https://www.sam.gov (SAM) on 24 December 2021. On 10 February 2022, another pre-award protest was filed by an interested party with the GAO. The protest sited multiple reasons, but mainly focused "on the feasibility of commerciality" and the FFP CLIN structure, inclusive of the corrective maintenance. On 22 February 2022, GAO dismissed the protest based on AFs decision to take corrective actions.

Prior to the protest received for the Dobbins ARB, GA BOS RFP, Homestead ARB, FL posted their own BOS RFP on 14 January 2022 in SAM under RFP FA664322R0003 with notice Homestead ARB BOS Services Limited Competition. On 25 January 2022, another pre-award protest was filed by an interested party with the GAO. The protest sited multiple reasons, but was consistent with the Dobbins ARB, GA protest.

After the multiple protests, the Air Force made the decision to withdraw any AFRC BOS RFPs until the necessary corrections have been made to both the solicitations and Performance Work Statements (PWS) for AFRC BOS efforts.

The new PARS BOS long-term competitive effort had been in the works since May 2023 and the Request for Proposal was anticipated to be posted mid-October 2023. However, the acquisition was halted prior to the release of the RFP when PARS was directed to change the course of the Source Selection Plan (SSP) by the Headquarters (HQ) Air Force Reserve Command (AFRC) A4 - Director of Logistics, Engineering and Force Protection. As a result, the new PARS long-term competitive effort SSP has been revamped and recently re-evaluated. After extensive reviews between the 911th Air Wing Program Manager, 911th Mission Support Group Contracting Officer, HQ AFRC Contracting and HQ AFRC Legal personnel, Business Clearance approval by the Senior Contracting Official was finally received 19 March 2025.

The new RFP was officially synopsized in Contract Opportunities on 19 March 2025.

Award of a competitive long-term contract is estimated to be between September and October 2025. However, award date for the long-term contract may be further impacted by pre/post award protests or further mandated acquisition strategy changes.

Plan of Action & Milestones (POA&M): Estimated (2025): Actuals (2025):

Business Clearance Review Briefed and Approved: ------------------------------- ------------------------------

Post Request for Proposal Solicitation: ---------------------------------------------- ------------------------------

Pre-Proposal Conference/Site Visit: -------------------------------------------------- ------------------------------

RFP/Solicitation Questions Due: ------------------------------------------------------ ------------------------------

Solicited Contractor Proposals Due: ------------------------------------------------- ------------------------------

Conduct Initial Source Selection Evaluation Board: ------------------------------- ------------------------------

Complete Initial Source Selection Evaluation Board: ----------------------------- -----------------------------

Conduct Discussions: ------------------------------------------------------------------ -----------------------------

Request Contract Clearance Step 1 - FPR: ---------------------------------------- ------------------------------

Close Discussions/Draft Pre-Award/Award Documents:-------------------------- -----------------------------

Staff Judge Advocate Review/Approval: -------------------------------------------- ------------------------------

Route Contract Clearance Step 2 - SSDD: ------------------------------------------ -----------------------------

Source Selection Authority Brief/Approval: ----------------------------------------- ------------------------------

Contract Clearance - SSDD Brief/Approval: ---------------------------------------- -----------------------------

Send Congressional Notification (DD1279): ---------------------------------------- ------------------------------

Unsuccessful Notice of Award/Debriefs: -------------------------------------------- ------------------------------

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Potential Protest Initiated: ------------------------------------------------------------ -------------------------------

Successful Notice of Award Posting: ------------------------------------------------ -------------------------------

Target Award Release Date: --------------------------------------------------------- -------------------------------

Post-Award Conference/Kick-off Meeting: ----------------------------------------- ------------------------------

Mobilization Period 60 days (if needed) -------------------------- ------------

Follow-on Contract Start: ------------------------------------------------------------- ------------------------------

IX. List of any sources that expressed, in writing, an interest in the acquisition.

See Section V above.

X. A statement of the actions, if any, the agency may take to remove or overcome any barriers to competition before any subsequent acquisitions for the supplies or services required.

The new procurement has been synopsized in Contract Opportunities as of 19 March 2025. There are no competitive barriers on the long-term effort. Multiple companies have already shown interest in the synopsized effort.

XI. Certification by the Contracting Officer.

As evidenced by my signature above, I certify that this justification is accurate and complete to the best of my knowledge and belief.

XII. Certification by the technical/requirements personnel.

As evidenced by my (our) signature(s) above, I (we) certify that any supporting data contained herein, which is my (our) responsibility, is both accurate and complete.