Justification_PAN409-25-P-0000 025310_redacted copy_081525_Redacted II.pdf

CUI//SP-SSEL

Control Number: T-25-0017

JUNE 2025

JUSTIFICATION REVIEW DOCUMENT

FAR Part 13 Justification and Approval

Simplified Procedures for Certain Commercial Items

Program/Equipment: Local Drayage Services Italy

Authority: Title 41 United States Code (U.S.C.) §1901(e)(2) as implemented in Federal Acquisition Regulation (FAR) 13.501(a)(1)(ii), sole source (including brand name) under the authority of the simplified procedures for certain commercial items.

Amount: 124,016.19 134,086.05)

Prepared by:

Contracting Officer:

Technical:

Requirements:

Controlled by: Army Controlled by: ACC/409th CSB/TCC CUI Category: CUI/SP-SSEL Limited Dissemination Control: FED Only POC: Israel Gutierrez, 314-542-6813

Reviews: I have reviewed this justification and find it adequate to support other than full and open competition.

Program Manager:

Signature: Date: See Digital Signature

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impact the ability of the United States European Command (EUCOM) to complete Permanent Change of Station (PCS) for individuals and families in and out of the European Area of Responsibility (AOR).

The Army will be unable to house inbound customers until Household Goods (HHG) shipments arrive and are delivered to the dwelling unit. This lack of support would cause a dramatic increase in costs to the Government due to the increased costs with extended stays in temporary lodging.

Costs to stay in Temporary Lodging Allowance (TLA) will experience at least 50% cost increase due to being forced to say in lodging without the drayage and furnishings support that is normally afforded to both Inbound and Outbound personnel. This increase in costs could be in the millions of dollars being that ALL inbound and outbound personnel will be affected.

Customers who require furnishings items exchanged, such as, inoperable appliances, could require relocation to Temporary Lodging due to the basic necessities authorized according to Army Regulation (AR) 420-1 and

CTA 50-909.

PCS of service members may be impacted by delaying reporting dates due to the lack of furnishings support available in Europe.

Construction and renovation projects will be delayed and experience increased costs associated with not being able to provide furnishings to the buildings. Construction projects and major renovations that have been authorized furnishings within the project may be delayed due to lack of furnishings.

Local Housing Offices will not be able to assign housing due to the lack of permanent issue items such as refrigerators, ranges, washers, etc. Inbound and Outbound customers are authorized temporary loaner furniture as they arrive in country and are assigned housing as well as upon departure prior to vacating their dwelling unit.

AMC furnishings projects out of U.S. Army Corps of Engineers Support Center Huntsville (CEHNC) will not be completed. CEHNC is to provide furnishings directly from Huntsville which arrive in containers and are usually offloaded at the FMO location or arrive at GSE in Sembach. Services are then requested from the Drayage Contractor for transport from the FMO to the units where they are delivered, assembled, and/or installed. New residents will not be able to occupy these units until permanent issue/duration of tour items are available. Costs for the supply items are covered in the DD 1391 as part of each individual project.

FMOs at each garrison will no longer be able to provide services to their contracted service provider to perform these essential services. This includes the lack of augmented labor, cleaning of furnishings, and any additional needed processing. Issues, Pick-ups, exchanges, installs, and un-installs will

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stop until a proper contract vehicle is in place in order to provide these critical services.

Under Contract award W564KV25P2001, the Contractor is responsible for coordinating transportation of furniture and appliances across the entirety of Italy to military and civilian personnel. The Contractor coordinates the transportation and delivery from a total of two (02) FMO warehouses located throughout Italy. In addition, the Contractor is required to provide augmentation in Government warehouses necessary to receive, clean, inventory, and prepare Government-owned furniture and domestic appliances for re-issue. The Contractor performs the services in accordance with the responsibilities outlined in the Performance Work Statement (PWS) while adhering to Italian transportation regulations.

The Government awarded Contract W564KV25CA013, on 25 June 2025, which included a 30-day phase-in period, to contractor, Ecolog Deutschland GmbH (Ecolog). Full performance under this new contract award is scheduled to begin on 25 July 2025, however, the awardee will not be ready to begin full performance under Contract W564KV25CA013 (see paragraph 5 for details). As a result, issuing this bridge requirement is the only procurement vehicle available to support IMCOM deliveries and pick-ups from across the two (02) FMO warehouses based on weekly schedules issued at each location, which is also susceptible to changes, including volume increases, address revisions and date/time rescheduling. As part of the contract requirements the Contractor is responsible for supplying all the vehicles necessary for the transportation of all the Gover

5. Authority Cited: Title 41 U.S.C. §1901(e)(2) as implemented in FAR

13.501(a)(1)(ii), sole source (including brand name) under the authority of the simplified procedures for certain commercial items.

6. Reason for Authority Cited: Local drayage services provide distribution, installation, and uninstallation of IMCOM E managed furniture and appliances as well as warehouse staff augmentation throughout the European theatre of operations, specifically Contract award W564KV25P2001 covers the services provided in Italy and is supposed to cover the services until 23 July 2025, when the award expires and full performance is scheduled to begin under the new contract, W564KV25CA013. Local drayage services are supported in regulation and policy by AR 420-1, Army in Europe Supplement to AR 420-1, the Defense Joint Travel Regulations as well as other associated DOD/Army policy and regulations. Delivered furniture includes both temporary issued and permanent issued items required for households as they are inbound/outbound and throughout their assignment.

Services are funded/appropriated through the Army Family Housing and Unaccompanied Personnel Housing (MDEPs E33H, E35H, and QHFM). These services are determined to be mission essential.

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As previously stated, the Government award Contract W564KV25CA013 on 25 July 2025, at which point the period of performance commenced with a 30-day phase-in period. During this period the new contractor, Ecolog, would complete all the necessary tasks and responsibilities, including securing installation access for all required personnel, to take over performance of the local drayage services and warehouse augmentation from contractor, Roiatti, S.R.L., as their contract, W564KV25P2001, will expire on 23 July 2025. As soon as the new award, W564KV25CA013, was received, Ecolog began to diligently work through the list of required tasks and responsibilities; however, as they work with the on-location Contracting Officer Representative (COR) in Italy to secure installation access passes for their personnel it became apparent that the process was more complex and involved two (02) background checks. The reason for this is installations the U.S. Government operates from in Italy are Italian Government military bases, thus for personnel to gain installation access the request first goes through U.S.

Government systems followed by another review of the request by the Italian Government. The Italian review process for installation requirements includes a background check and will generally be about 30 days. Altogether the request for installation access for contractors in Italy will normally require 45 to 60 days for processing when the individual requesting access is a resident of Italy, if all the information submitted is correct and proper. The entire process is lengthier when the applicant is not an Italian citizen. Additionally, the applicant may need to apply separately and on their own for a Soggiorno Working Visa, allowing them to work in Italy for the duration of the contract. This is regardless of them being part of the EU.

Being part of the EU only allows individuals to remain in Italy for up to 90 days and is totally separate from gaining Garrison access.

It is anticipated that the Government will be delayed three (03) months in processing installation access for the personnel needed to carry out the required services under Contract W564KV25CA013. Providing a list of names of individuals requiring access is only the first step. The process commences once the list and all other required documentation from the contractor, constituting the installation access request package, is received and verified by the Requiring Activity personnel. The documentation required for the first step is a passport, an identification from the current area of residence and a copy of the contract. Once this first step is complete, the period starts with the submittal of the access request to the installation access control office which will review the request again and validate it. From there it goes to the Carabinieri, Italian law enforcement entity, who conducts the background check. Once background check is complete, the request goes to the Italian Base Commander (IBC) for approval. Once the IBC approves, the request goes back to the installation access office who will inform us the request is approved. At that point, the contractor can pick up the base pass and begin full performance.

Additional time is factored into the processing time required to obtain installation access to account for the possibility that the initial request is rejected, or the information needs to be revised. When issues arrive with the information in the request package is not accepted, the process usually must start again. The amount

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of time required to process the installation access can be hard to predict because it dependent on the results of the security background checks and the decision made by the Italian Base Commander. Furthermore, the process followed in Vincenza differs from that followed in Livorno as each location has a different Italian Base Commander and different applicable regulations.

ROIATTI S.R.L., the current Contractor, has the base and facility access for their entire staff of personnel. The skilled workforce understands and meets performance and training requirements to address the logistics and repair requirements. To satisfy full performance for this requirement, a contractor would not only require about 90 days to prepare their personnel to be fully capable of meeting contract requirements but also require an additional 90 days to be granted base access.

Given the current situation Ecolog is facing with installation access, issuing an interim award to another contractor unfamiliar with requirement and likely requiring installation access as well, would duplicate the situation and the efforts to correct it.

As discussed below, ROIATTI S.R.L. is uniquely qualified to provide these services to IMCOM E and award of the interim requirement is appropriate in the interest of economy and efficiency.

Uninterrupted performance of services by skilled and certified technicians of various appliance Original Equipment Manufacturers.

Logisticians knowledgeable of the government infrastructure; government data tracking software/systems, performance criteria and regulations governing the PCS support authorized for military and civilians in the European theater.

Base access for contractor personnel.

The mobilization period new contractor to begin on site full performance to include badging for base and facility access, processing/approval of various technician certifications, as well as clearances for access to software/systems.

ROIATTI S.R.L. is currently providing services under Contract W564KV-25-P- 2001 and has unique knowledge of the current Government infrastructure, distribution requirements, inventory capabilities and transportation methods that position itself to effectively meet mission needs.

ROIATTI S.R.L. possesses the qualifications and personnel required to fulfil this requirement and can continue performance without interruption if a bridge contract is approved and executed. No other Contractor can meet a similar timeline. ROIATTI S.R.L. is currently providing the services for all FMO Warehouses and modifying this award would allow those services to continue uninterrupted.

ROIATTI S.R.L., as the incumbent, will not need to expend resources to continue performing the required services considering its performance under the current Contract. Attempting to award to another Contractor other than the incumbent prior to the current uly 2025, would result in a break in service and would lead to mission failure.

Moreover, this extension would provide the necessary time for the Government to work with Ecolog to complete the installation access process and begin full performance of the services under Contract W564KV25CA013. This mitigates the possibility of performance issues. The incumbent contractor, ROAITTI S.R.L., has proven they can provide reliable services to support IMCOM E. ROAITTI S.R.L holds significant knowledge and experience with this requirement. ROAITTI S.R.L. is performing satisfactorily, continuity will remain intact through the three (03) month bridge contract, and there is no risk of a break in service. For these reasons, a bridge requirement is justified, and documentation will be included in the contract file.

Impact to Mission: A break in service would present unacceptable complications and expenses to the drayage requirements currently handled by IMCOM E. A break in services would prevent IMCOM E from performing its mission of ensuring no interruption in transportation, delivery and pick-up of furniture and appliances within the German AOR for all DoD military and civilian personnel. A gap in these critical services will have severe and immediate consequences:

The Army will be unable to house In-bound customers until Household Goods (HHG) shipments arrive and are delivered to the dwelling unit. This lack of support would cause a dramatic increase in costs for the Government due to the increased costs with extended stays in temporary lodging.

Significant Deterioration of Housing Support: The housing office will be unable to effectively manage and distribute furniture and appliances, directly impacting the quality of life for service members and their families.

Delayed PCS Out-processing and In-processing: Central Furnishings Management Office (CFMO) cannot clear Service Members (SMs) set to PCS out because furniture and appliances can't be returned to the warehouse.

This could delay their out-processing from the current base, which in turn delays their in-processing at their new duty station. Furthermore, for SMs residing in private leases, once a private lease is terminated, landlords can take ownership of all items left behind, therefore, the government could lose a significant amount of CFMO assets due to a gap in service.

Inability to Receive Critical Household Items: Customers will be unable to receive essential items for their homes when In-processing, including emergency replacements for unrepairable appliances, leaving families without vital necessities.

Extended Temporary Lodging Acceptance (TLA) and Temporary Quarters Subsistence Allowance (TQSA) for In-bound personnel: TLA costs will increase by at least 50%. In-bound customers will be forced to remain in hotels for extended periods due to their inability to have necessary furnishings delivered to their newly assigned residences, resulting in a waste of government funding.

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Delayed Occupancy for Renovated Barracks: Soldiers in renovated barracks will not receive the necessary items from the warehouse for their rooms, which will delay the occupancy of these facilities.

No Repairs or Cleaning of Damaged Furnishings: The absence of contract services means there will be no repairs or cleaning of broken furnishings, leading to a rapid decline in the quality and availability of usable items.

No Short-Notice or Emergency Services: Critical short-notice or emergency services, often required due to adverse weather or flooding, will not be provided, leaving personnel vulnerable during unforeseen circumstances.

Warehouse Overwhelm and Operational Stagnation: Without the critical warehouse augmentation, Government warehouses will quickly become overwhelmed with unmanaged inventory, halting the process of receiving, cleaning, and preparing items for re-issue.

Customers who require furnishings items exchanged, such as inoperable appliances, could require relocation to Temporary Lodging due to the basic necessities authorized according to Army Regulation (AR) 420-1 and

CTA 50-909.

Increased Costs and Resource Strain: Delays and inefficiencies will inevitably lead to increased costs related to extended TLA and TQSA, potential damage to unmanaged inventory, and the need for emergency, high-cost solutions to mitigate the imminent crisis.

Damage to Morale and Readiness: The inability to provide basic housing support directly impacts the morale of service members and their families, potentially affecting overall readiness.

FMOs at each garrison will no longer be able to provide services to their contracted service provider to perform these essential services. This includes the lack of augmented labor, cleaning of furnishings, and any additional needed processing. Issues, Pick-ups, exchanges, installs, and un-installs will stop until a proper contract vehicle is in place in order to provide these critical services.

7. Efforts to Obtain Competition:

a. Effective competition: The Government awarded Contract W564KV25CA013 on a competitive basis. This bridge action is meant to afford the awardee additional time to complete all phase-in tasks and begin full performance of the service requirements.

b. Subcontracting competition: The incumbent contractor operates a network of sub-contractors they can rely upon to perform the services in those locations where the source may not have an enduring presence. In accordance with FAR Part 44.204(c)(1), FAR Clause 52.244-5, Competition in Sub-Contracting, is not

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pertinent since Contract award W564KV25PA018 is a firm fixed-price contract, which was awarded on the basis of adequate price competition.

8. Actions to Increase Competition:

9. Market Research: Market research has been an ongoing team effort between the Requiring Activity and Contracting Office, with data collection beginning during performance of Contract W564KV22C0058 and continuing on to the award of the new contract, W564KV25CA013.

Comparison to an independent government estimate (FAR 13.106-3(a)(2)(vi) was conducted and also to pricing on Contract no. W564KV25CA013 and it was determined that the submitted pricing (same pricing) is considered fair and reasonable. Please see spreadsheet in folder IGCE for direct comparison.

10. Interested Sources: No potential sources have expressed any interest in supporting the continuation of services. This justification will be posted in accordance with the requirements of FAR Part 5.201 and 6.305.

11. Other Facts:

a. Procurement history.

The Current Contract W564KV-25-P-2001, awarded 23 January 2025 with a six (06) month period of performance (24 January 2025 to 23 July 2025),including all option years. The total contract amount is

Previous Contract W564KV-22-C-0058, awarded 23 August 2022 with a 18-month period of performance (23 August 2022 to 23 January 2025), ($208,533.06). Full and open competitive solicitation.

Previous Contract W564KV-17-D-2001, awarded 01 February 2017 with a five (05) year ordering period (01 February 2017 to 30 June 2022). The contract included FAR Clause 52.217-8, thus allowing an extension of the ordering period to 30 June 2022. The total contract amount was

b. Other facts.