Justification_W564KV-25-P-2001_drayage services italy_012925_Redacted.pdf

Control No: T-25-0011

Version – February 2017

Memorandum for Record – Limiting Competition at or below the Simplified Acquisition Threshold

1- Contracting Activity: 409th Contract Support Brigade (CSB) – Theater Contracting Command

(TCC), Kaiserslautern, Germany

2- Description of Action:

Nature: New Requirement Follow-On Requirement (Bridge Requirement) Mod to Existing Purchase Order/Contract Number

Installation Management Command – Europe (IMCOM – E) G4/GSE Furnishings Management Office (FMO) requests approval for a bridge requirement to extend the period of performance of Contract award W564KV-22-C-0058 a further six (06) months (3-month-base, 3-month option) to continue drayage services, including transportation, delivery and pick-up of furniture and appliances, in Italy.

The current contract, W564KV-22-C-0058, is a Firm Fixed Price (FFP) Contract type with a period of performance presently ending on 23 January 2025. The anticipated bridge contract will remain FFP on the contract. Fiscal Year 2025 Operation and Maintenance (O&M) funding will be used for this bridge contract.

Contract Vehicle:

Purchase Order (PO) #: To be Determined Blanket Purchase Agreement (BPA) #: _______________ Order/BPA #: , against FSS Contract #:

Order #: , against Multiple Award IDIQ Contract #:

Order #: , against Single Award IDIQ Contract #:

Modification #: to existing award #:

Pricing: Firm-Fixed Price Time and Materials

Cost Reimbursable Hybrid, insert percentage of each contract type

Funds: OMA Other Funds: insert funding type _________ Fiscal Year: 2025

Name of Proposed Contractor(s) and Address:

Roiatti S.R.L.

Via L. Savio 14 Pordenone, PCN Italy 33170 CAGE Code: A(527

Brand Name Buy: Yes No

1. Description of Services or Supplies: The Government award contract W564KV-22-C-0058, awarded on 23 August 2022, to ROAITTI S.R.L. This procurement requires a contractor to perform delivery/pick-up of temporary and permanently issued furniture and appliances on loan to authorized military and civilian personnel stationed on and around US Army Garrisons in Italy. Drayage distribution services include installation and removal of domestic appliances for the Army in Europe Army Family Housing (AFH) and Unaccompanied Personnel Housing (UPH). The procurement also requires a contractor to augment the Government workforce in performing warehouse tasks at the local FMO warehouses to include cleaning of furniture and appliances, minor repair of furniture, Stoppage” would be realized due to the lack of a 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.

Under Contract award W564KV-22-C-0058, 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.

Presently, this is the only procurement vehicle available to support IMCOM – E’s mission. The Government relies on the Contractor to plan and coordinate 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 Government’s furnishings and appliances.

Contract W564KV-22-C-0058, was awarded with the following 36-month period of performance:

Base Year – 24 August 2022 to 23 July 2023 Option Period I – 24 July 2023 to 23 July 2024 Option Period II – 24 July 2024 to 23 October 2024 52.217-8 – 24 October 2024 to 23 January 2025

Concerns rising from unknown variables associated with the effects the CoVID-19 pandemic was creating on commodity prices and labor costs across many global markets as well as the uncertainty that one (01) Contractor would be able to provide services to all US Army Garrisons in Italy ultimately led to the decision to shorten the requirement’s period of performance. Given the instability of the economic environment at the time, the period of performance was shortened to alleviate the high risk created by the precarious global conditions, while also allowing for data collection concerning resourcing/staffing and pricing to navigate market conditions as we reprocure future drayage services in Italy.

Since the award of Contract W564KV-22-C-008, the economies worldwide have stabilized and data collected through market research for the follow-on procurement has confirmed market sources are not only capable of providing support with one (01) Contractor for all US Army Garrisons in Italy, but believe economies of scale can be leveraged with a single contractor providing support to the

IMCOM – E AOR.

3- Authority:

FAR 13.106-1(b)(1): For purchases not exceeding the simplified acquisition threshold (SAT), only one source reasonably available, urgency, exclusive licensing agreements, brand name, or industrial mobilization.

2. Reasons 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 W564KV- 22-C-0058 covers the services provided in Italy. 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 mission essential.

It is anticipated that the Government will be delayed six months in award of the competitive follow-on contract. PCF Cabinet W564KVRA0002 was created by the then Contracting Officer’s Representative (COR) on 20 March 2023.

In addition, the delay derived from reasons that were realized from the current contract performance issues. As identified in the Market Research Report for the follow-on procurement, detailed in the excerpt below, there are unknown components that have led to extensive discussion on the most appropriate course of action for the procurement and necessitate major revisions to the Acquisition Strategy and rewrites to the Solicitation, in particular to the Evaluation Criteria.

“Pricing is generally based on weight and destination of the items being moved. Since most services are based on need, a contractor would not be able to set a price for each item as all items vary in size, shape, and weight. Normally, a seller, before making an offer, would do a site survey of the household goods that need to be moved and then quote its price based on the particulars for that household. Some of the forces that may drive price are fuel and labor. The potential for price increases in a primary input cost for the drayage contractor would need to be factored into any firm-fixed-price offer from potential drayage contractors. However, fluctuating prices for fuel are an inherent risk for any entity engaging in delivery or drayage services and would not be unique to the current situation. The best way for the Government to combat high prices is to reduce the unknown factor. The unknown factor is a risk factor for most contractors. The Government can provide enough historical information for weight and destination/pick-up this could reduce the price premium on unknowns by the vendor and thus would give the Government a more efficient price."

The Acquisition Strategy and Source Selection method for the follow-on procurement have been the subject of debate throughout the processing for the requirement through the various contracting phase before the issuance of the Solicitation. Presently, new revisions to the Acquisition Strategy and Solicitation are currently under review. The time it would take to finish a follow-on procurement and the lead-time to bring another contractor on board would result in a break in services.

The traditional procurement lead time was initially anticipated for this contract award and the customer did plan for this time. However, through the requirement’s development and analysis of the current contract design and performance, it is noted that the follow-on contract would require a revision to the planned strategy, scope and solicitation structure to reduce risk of claims by a future contractor. This work in the pre-award phase of the follow-on contract is in effort to mitigate contract performance issues and/or claims on the on the follow-on contract.

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 require 60 days to prepare their personnel to be fully capable of meeting contract requirements. Therefore, it is not feasible that should a new contractor be awarded the follow-on requirement, that a new contractor would be postured to fulfill the contract requirements by the end of the current contract (23 January 2025.) Furthermore, there are several reasons supporting a bridge contract, to allow for an additional six (06) months of performance (3-month base, 3-month option), if needed. As discussed below, the Contractor is uniquely qualified to provide these services to IMCOM

– E and award of the interim requirements discussed below 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-22-C-0058 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 perform 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 Contract’s expiration on 23 January 2025, would result in a break in service and would lead to mission failure.

A new Contract would necessitate the awardee have time and financial resources to get their employees in place to provide the services under the terms and conditions of the Contract.

Significant delay would occur if the subject, interim requirement is competed via full and open competition, resulting from resourcing the contract, obtaining base and facility access, workforce orientation/training for performance compliance and meeting logistics requirements with an authorized vehicle fleet. All this would be necessary for compliance with regulations associated with supporting the military and civilian PCSs within the European AOR.

IMCOM – E submitted a timely acquisition package to the Contracting Office for the follow-on competitive action for these services. As previously indicated due to changes in the scope, the solicitation and specifically a change in strategy of contract type, the ability to provide a new competitively awarded contract prior to expiration of this contract is not feasible. To preserve the long-term support to our military and civilians within the European theater a bridge extending Contract award W564KV-22-C-0058 is logical, economical, and efficient.

Significant delay would occur if the subject, interim requirement is competed via full and open competition prior to implementing the changes to the scope, solicitation and contract type.

It is anticipated that it will take until 23 April 2025 to award the Contract. Additionally, the new Contract will require a 60-day phase-in period to allow the new Contractor sufficient time to bring new employees on board, meaning full performance likely will not be possible under the new Contract until about 23 June 2025 at the earliest. During this time IMCOM – E still requires full performance of services to ensure their mission is successful. This bridge contract will ensure continued services to the Government while the completion of this follow-on contract occurs.

Moreover, this extension would provide the necessary time to complete the procurement process for the follow-on Contract award via full and open competition and mitigate the possibility for performance issues under the new procurement. 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 possible three (03) month option should it be exercised, and there is no risk for a break in service. For these reasons, a bridge requirement is justified, and documentation will be included in the contract file.

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. As previously stated, readjustments to the Acquisition Strategy and the Source Selection method, as well as re-writes to the Solicitation led to a delay in procuring follow-on services was unavoidable due to the time it took to develop this requirement, based on current market conditions and practices.

ROIATTI S.R.L. have provided drayage services under W564KV-22-C-0058 since the award of the contract on 23 August 2022. ROAITTI S.R.L. has assets readily positioned to support the IMCOM – E mission, including resource and logistics network, to provide local drayage distribution services for Government-owned furniture and domestic appliances. ROAITTI S.R.L. possesses the specialized and technical expertise for drayage services and is already positioned in Europe to support IMCOM – E’s mission to manage, provide, distribute and maintain all furniture and appliances that are owned by the U.S. Government that are used by U.S. Government personnel that are stated within Europe.

4- Publicizing Contract Actions:

For FAR Part 13 actions, the public display and synopsis requirements of FAR 5.101 and FAR 5.203—

Do not apply due to the $ threshold, Apply and will be followed, or Do not apply due to an exception at 5.202(a)(12).

Requirement to post justification in accordance with FAR 8.405-6(b)(3), FAR 13.105(c), or

FAR 16.505(a)(4)(iii)(A)— Action is NOT a brand name restriction and is under $150K, no posting required.

Action is a brand name restriction, under $25K, no posting required.

Action is a brand name restriction, over $25K. It will be redacted and posted with the solicitation.

Action is a brand name restriction over $25K but will not be posted due to exception:

FAR 6.305(f) FAR 8.405-6(b)(3)(iii)(A) FAR 8.405-6(b)(3)(iii)(B) FAR 8.405-6(b)(3)(iii)(C) FAR 16.505(a)(4)(iii)(C)