Justification_IAW_FAR6.302-5_VAAR_819.7008-7009.pdf

VHAPG Part 819.7008/7009 Sole Source Awards to SDVOSB/VOSB Page 1 of 3 Revision: 05 Effective Date: 12/15/2025

DEPARTMENT OF VETERANS AFFAIRS

Justification and Approval (J&A) For

Other Than Full and Open Competition

Acquisition Plan Action ID: 36C262-26-AP-3813

1. Contracting Activity: Department of Veterans Affairs, VISN 22, VA Greater Los Angeles Health Care

System (VAGLAHS), NCO 22.

2237: 691-26-2-5220-0063

2. Nature and/or Description of the Action Being Approved:

This is a one-year requirement for Post Closure Landfill Use Plan (PCLUP) Phase 1 Report that will be awarded as a new Firm-Fixed Price contract to support VAGLAHS.

3. Description of Supplies/Services Required to Meet the Agency’s Needs:

The VAGLAHS has a requirement for providing Phase I Report – Office Level Investigation (Report) editing, review and packaging services. The work to be provided continues work performed for PCLUP investigation and review services on Contract 36C26224P1828, awarded to Pacific Coast Contracting Group, Inc. Work included drafting the Phase I Office Investigation Report (Phase I Report), with VA revisions, then incorporated. VA revisions resulted in changes and needs that necessitate additional report work, prior to its finalization and regulatory submission. Following contract award, the VA will provide the contractor with a current working version of the report (with comments and or markups, as required) for the performance of the work.

The Period of Performance (PoP) for this effort is one year, with an anticipated start date of 05/01/2026. The estimated dollar value of this requirement is $30,700.00

4. Statutory Authority Permitting Other than Full and Open Competition: 41 USC §3304(a)(5), 38 U.S.

Code § 8127(c), as implemented by RFO 6.103-5 (Authorized or Required by Statute). COs may use the non-competitive (sole source) procedures authorized in VAAR 819.7008 (DEVIATION) or VAAR

819.7009 (DEVIATION)- up to $5,000,000. Check the specific VAAR clause used below:

( X ) 819.7008 Sole source awards to a certified service-disabled veteran-owned small business;

or ( ) 819.7009 Sole source awards to a certified veteran-owned small business

5. Demonstration that the Contractor’s Unique Qualifications and/or Nature of the Acquisition Requires the Use of the Authority Cited Above (applicability of authority):

VAAR 819.7008 allows sole source awards to SDVOSB/VOSB based on 38 U.S.C. 8127(c). Pacific Coast Contracting Group, Inc. has been determined to be a responsible source with respect to performance. Pacific Coast Contracting Group meets eligibility requirements per 819.7003 and is listed as an SBA-certified Service Disabled Veteran-Owned Small Business in the SBA Small Business Search database.

https://www.va.gov/oal/library/vaar/vaar819.asp#8197008 https://www.va.gov/oal/library/vaar/vaar819.asp#8197009 https://www.va.gov/oal/library/vaar/vaar819.asp#8197009 https://www.va.gov/oal/docs/business/pps/deviationVaar20230216.pdf

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6. Description of Efforts Made to ensure that offers are solicited from as many potential sources as deemed practicable, including whether a notice was or will be publicized as required by RFO 6.301 and, if not, which exemption under RFO 5.101(b)(1) applies:

As stated above, this procurement is a continuation of the reporting work already provided by Pacific Coast Contracting Group on the previous contract, making it virtually impossible for another vendor to step in and perform. The contractor will literally be revising the document created previously. Due to this restriction, quotes will not be solicited from potential sources.

The exception at RFO 5.101(b)(2) applies. The justification will be publicized on sam.gov.

7. Determination by the CO that the Anticipated Cost to the Government will be Fair and Reasonable:

Price reasonableness for this procurement will be based on a comparison with Contract 36C26224P1828, priced at $59,500.00, which is much higher than the estimated price for this effort, priced at $30,700.00. Price analysis will be a straightforward comparison of fixed pricing between the two contracts. Certified cost or pricing data is not required; and a technical evaluation will not be performed.

8. Description of the Market Research Conducted and the Results, or a Statement of the Reasons

Market Research Was Not Conducted:

Market research for this requirement for Contract 36C26224P1828 was previously conducted on 07/17/2024. This research found that firms offering full environmental compliance services either directly or through competent subcontractors was scarce. Firms with specific CA compliance experience appeared limited. SDVOSB companies providing the required services were even more limited. The full text of this research can be found in the eCMS Briefcase for Contract 36C26224P1828.

A search within the SBA Small Business Search database for SDVOSB vendors under NAICS 541620 was conducted on 03/11/2026. Twenty-five SDVOSBs were identified. This search did not identify Pacific Coast Contracting Group, Inc.; however, a specific search of this vendor did reveal it is also an SDVOSB under NAICS 541620. Of all 26 vendors, only 2, to include Pacific Coast Contracting Group, are in California.

As stated previously, this requirement was previously procured under Contract 36C26224P1828, awarded to Pacific Coast Contracting Group, Inc. Again, the work for this procurement is a continuation of the reporting work already provided by this contractor.

9. Any Other Facts Supporting the Use of Other than Full and Open Competition: None

This action is being procured under the authority of 38 USC 8127(c).

10. Listing of Sources that Expressed, in Writing, an Interest in the Acquisition:

No sources were sought.

https://www.acquisition.gov/far-overhaul/far-part-deviation-guide/far-overhaul-part-6#FAR_6_301 https://www.acquisition.gov/far-overhaul/far-part-deviation-guide/far-overhaul-part-5#FAR_5_101

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Effective Date: 12/15/2025

11. A Statement of the Actions, if any, the Agency May Take to Remove or Overcome any Barriers to Competition before Making subsequent acquisitions for the supplies or services required:

At present, no actions will be taken to foster competition for future acquisitions of these services.

The scope of this procurement with VAGLAHS is highly specialized and limited to the very specific requirement of revising a report previously provided by the vendor on a previous contract. Due to the specific nature of these services at VAGLAHS, another acquisition is not currently planned.

12. Requirements Certification: I certify that the requirement outlined in this justification is a Bona Fide Need of the Department of Veterans Affairs and that the supporting data under my cognizance, which are included in the justification, are accurate and complete to the best of my knowledge and belief.

Chelsea M. Black Deputy Chief, Strategic, Facility and Master Planning VA Greater Los Angeles Healthcare System

13. Approvals in accordance with the VHAPM Part 806.3 OFOC SOP:

a. Contracting Officer or Designee’s Certification (required): I certify that the foregoing justification is accurate and complete to the best of my knowledge and belief.

William T. Cook Contracting Officer

NCO 22

https://dvagov.sharepoint.com/sites/vhapromanual/SitePages/VHAPM-Part-806.3.aspx