Justification Approval CMa 2026 01 14.pdf

GENERAL SERVICES ADMINISTRATION

NATIONAL CAPITAL REGION

Office of Planning and Project Management DIVISION (OPPM)

LIMITED SOURCE JUSTIFICATION

1. Identification and Description of Action being Approved:

Project Title: CMa Services for Nuclear Regulation Commission at One White Flint North 2nd and 3rd floor renovations.

This procurement request is for CMa services for the Nuclear Regulatory Commission (NRC) 2nd and 3rd floor renovations at One White Flint North (OWFN) Building (MD0199ZZ), 11555 Rockville Pike, Rockville, MD which is currently underway.

2. Description of Services Requested:

This SOW is for the continued provision of Construction Manager as Advisor (CMa) services.

The CMa assumes the position of professional advisor or extension of staff to the agency. The base award included Program and Design Phase review services, constructability review services, A/E Contract Management and General Contractor Procurement Phase Services.

Construction Phase Services, Post Construction/Closeout Phase Services and Commissioning Services; plus, Supplementing, Miscellaneous Claims, and Testing Services were included as options.

The CMa assists in collaborating on design, constructability issues, schedule, cost, and a value engineering process. The immediate goal of this requirement is to establish a final Estimated Cost of Work that is within the original “not-to-exceed” target set by GSA and NRC. The CMa's involvement during the project design phase offers GSA the ability to identify current market conditions concerning labor and material availability, constructability issues, and any phasing and sequencing impacts.

3. Identification of Statutory Authority:

The authority permitting a BPA Call modification to a single source under GSA BPA Contract 47PD0319A0028 is GSAR 538.7104-3(b)(i).

4. Authority and Rationale:

In accordance with GSAR 538.7104-3(b)(i), "The need is of such unusual urgency that following the procedures would result in unacceptable delays in fulfilling that need”. Due to the government shutdown, PBS did not timely exercise Option 2 of the existing BPA Call for continued CMa services on the construction project. This resulted in the expiration of the BPA

Call on December 4, 2025. The PBS Contracting Officer directed the CMa to stop providing services until proper documentation to support an urgent bilateral modification to the existing BPA Call could be executed. This requirement is urgent because any further delay in award of the modification for CMa support services would result in overall delay to the agency’s project schedule, increase cost to the government and negative impacts to NRC. Only the continuation of current services can address the required timeframe. Due to the urgent nature of this required service; to ensure that the necessary CMa services are provided with an established urgent and short duration schedule, it is imperative that AFG Group provide continuous CMa service for this project.

The project is currently preparing to move to the 95% Design Phase and Construction RFP phase. Awarding these services to any other source would result in substantial duplication of costs that cannot be recovered through competition and would cause unacceptable delays in fulfilling NRC’s critical operations mission requirements. AFG provides critical analytical and integration expertise, as well as real property business acumen and private sector best practices that are essential for the continued execution of the Real Property Strategy and maximizing lease cost avoidance.

5. Demonstration of the Contractors Unique Qualifications

It is in the government’s best interest to enter a sole source modification with AFG, who has demonstrated successful ongoing performance with this project. AFG employees have completed all required background investigations and hold the proper credentials to work in the building. Hiring another contractor would cause delay in the project due to credentialing requirements, vetting timeline required, etc. The project is currently under an urgent, time sensitive construction schedule, to complete specialized spaces for public safety, to meet NRC mission critical operations and avoid lease costs penalties of $27M if NRC does not timely move out of their existing space. It is urgently necessary to immediately complete structural construction, preventing delays to the data center and special ops command center facility, ensuring critical public safety functions remain operational without delay and interruptions to continuity of operations. Any further delay due to not having a CMa on board to assist with the project will have a damaging and irreversible impact on the operations of the NRC’s mission critical operations.

6. Demonstration that Anticipated Cost will be Fair and Reasonable:

An Independent Government Estimate (IGE) was prepared that reflects prices found reasonable on similar projects and current market prices and similar work of a like nature.

The Contracting Officer will use the IGE in the amount of $565,658.40 which was prepared by the COR and Subject Matter Expert who have historical knowledge of pricing for such services, and in comparison, of prices found reasonable on similar projects against the Contractor’s proposed price to determine a fair and reasonable price in award/modification.

7. Description of Market Survey

Due to the urgent nature of the requirement, GSA only reached out to AFG. AFG has a strong history with both the NRC and GSA and has already performed preparatory work for the release of the Construction RFP.

Source:

AFG Group, Inc.

950 Herndon Parkway, Suite 200 Herndon, VA 20170 Telephone: (571) 839-0925

GSA BPA 47PD0319A0028

www.afgcm.com Contract Administrator: Guy “Kai” Goodrich Email: kgoodrich@afgcm.com

8. Any Other Facts Supporting this Justification:

Due to the subject matter expertise provided by AFG on the NRC project, it is imperative that AFG continue services without further interruption to help deliver the necessary services and to position the upcoming workload for a successful end-state outcome, without incurring a significant delay of project knowledge transfer and provide expedited design service to meet FY25 budget requirements.

Maintaining the current CMa under consistent PM leadership will allow this procurement to adhere to the communicated schedule, avoid delays, damage to mission operational performance and prevent irreversible financial loss to the NRC.

APPROVAL:

Certification

Technical Certification:

I certify that the facts and representations under my cognizance, which are included in this justification, and which form a basis for this justification, are complete and accurate.

_Isoken Ihama_________________________________________________ Isoken Ihama, GSA, PM/COR Date 01/13/2025 http://www.afgcm.com/

Contracting Officer Representative (COR) Certification:

I certify that this justification is accurate and complete to the best of my knowledge and belief.

_Isoken Ihama_________________________________________________ Isoken Ihama, GSA, PM/COR Date 01/13/2025

Contracting Officer’s Certification:

- I certify that the justification is accurate and complete to the best of my knowledge and belief.

- I have determined that the order represents the best value (as defined in RFO 2.101) and results in the lowest overall cost alternative (considering price, special features, administrative costs, etc.) to meet the Government’s needs.

Christina Williams Date 01/14/2025 GSA, Contracting Officer https://www.acquisition.gov/far-overhaul/far-part-deviation-guide/far-overhaul-part-2