Limited Source Justification Columbia 7 2021 09 02 _Redacted.pdf

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LIMITED SOURCE JUSTIFICTION

FAR 8.405-6

U.S. GENERAL SERVICES ADMINISTRATION

Public Building Service, Region 4, Carolinas Branch

Project: Columbia 7 Combined Services

1. Contracting Agency and Activity. (FAR 8.405-6(c)(2)(i))

The contracting agency and contracting activity are the U.S. General Service Administration (GSA), Public Building Service (PBS), Region 4, Carolinas Branch, located at 205 Regency Executive Park Dr., Suite 440-A, Charlotte, NC.

2. Nature of Action Being Approved. (FAR 8.405-6(c)(2)(ii))

This document provides justification for the acquisition of operations, maintenance (O&M) and janitorial services through a sole source contract to the incumbent provider, Raven Services Corporation while GSA concurrently pursues a long-term procurement using Federal Supply Schedule (FSS) procedures under FAR Part 8 for this requirement, which supports GSA’s Strategic Acquisition of Quality Services (SAQs) initiative.

The incumbent contractor, Raven Services Corporation, has provided these services via a Blanket Purchase Agreement (BPA) through the FSS.

3. Description of Supplies or Services. (FAR 8.405-6(c)(2)(iii))

GSA PBS, Region 4 has a continuing need to provide uninterrupted Operations, Maintenance, and related Janitorial services at the following locations:

Strom Thurmond USCT, Columbia, SC (SC0069AA)

Strom Thurmond FB, Columbia, SC (SC0068AA)

J.L. McMillan FBCT, Florence, SC (SC0058ZZ)

J. Bratton Davis USCT, Columbia, SC (SC0018ZZ)

Matthew Perry Parking Garage, Columbia, SC (SC0013ZZ)

Matthew Perry USCT, Columbia, SC (SC0010ZZ) and

Charles E. Simon USCT, Aiken, SC (SC0002ZZ)

4. The authority and supporting rationale and, if applicable, a demonstration of the proposed contractor’s unique qualifications to provide the required supply or service. (FAR 8.405-6(c)(2) (iv))

Orders placed under the GSA FSS are exempt from the competition requirements in FAR Part 6. However, an ordering activity must justify its actions when restricting consideration of FSS contractors to fewer than required in FAR 8.405-1 or 8.405-2. This justification is executed under the authority of the Multiple Award Schedule Program, specifically the authority of FAR 8.405-6(a)(1)(i)(B), “Only one source is capable of providing the supplies or services required at the level of quality required because the supplies or services are unique or highly specialized.”

The incumbent contractor, Raven Services Corporation is currently the only responsible source that will satisfy the agency requirements immediately, without a lapse in critical services, while GSA works toward competitively awarding a new contract for O&M and janitorial related services. Any other company would require a transition period which is not feasible at this time since the existing contract expires on August 31, 2021, and the new, competed solicitation is currently under development.

Raven Services Corporation possesses critical site knowledge and familiarity with technical systems borne from over 5 years of successful management and operations of the seven locations for the Government. The ability to successfully manage such vital program areas into an overarching O&M contract relies heavily on practical site experience and an in-depth knowledge of the intricacies of the systems, building drawings, public utility system pathways, operating manuals and historical perspective on the equipment condition, repair and replacement history, operational challenges and how the systems’ support critical tenant-owned systems.

The incumbent contractor possesses this practical institutional knowledge of these systems that cannot be garnered, replaced, or substituted through a short-term interim contract with a new contractor. The incumbent contractor retains a unique situational position that will provide the government with the greatest opportunity for a successful transition of these critical and complex service needs. A failure to use this contractor in the short term for these transition services would impose undue risk to the facility, its tenants, and the taxpayer.

No other contractor has the capability to continue to provide GSA with these critical operations, maintenance, and related janitorial services without transition time. There are no alternate contractors sufficiently knowledgeable of the site and its systems operations that is capable of immediately providing services and oversight in this arena.

In addition to the above stated capabilities and concerns are the practical risks associated with a short-term, competitively awarded contract with an alternate contractor that increases performance risk as well as costs.

5. A determination by the ordering activity contracting officer that the order represents the best value consistent with 8.404(d). (FAR 8.405-6(c)(2) (v))

The cost of the proposed sole source interim contract to the incumbent, which the Government has estimated to be $ will represent the best value to the government per FAR 8.404(d). FSS prices have already been determined to be fair and reasonable by GSA. A price evaluation will be completed pursuant to 8.405-2(d) by considering the level of effort and labor mix proposed and determining the total price is reasonable. The total price will be compared to the Independent Government Estimate, as well as current contract rates from which the Government has successfully awarded the base services to this contractor. The evaluation of proposed pricing will be performed by multiple Subject Matter Experts well versed in the performance of these contract areas, in addition to the Contracting Officer, to determine that the total proposed price is reasonable.

6. A description of the market research conducted among schedule holders and the results or a statement of the reason market research was not conducted. (FAR 8.405-6(c)(2) (vi))

Market research beyond a query of the small business schedule holders was not conducted due to the unique requirements of this acquisition which inhibits the ability of a new contractor to successfully perform and provide the best value to the government. This acquisition does not have a transition period and the base Period of Performance is less than 1 year (8 months). These limiting factors are already mitigated for the follow on to this interim solution as GSA is concurrently working on a longer term, competitive acquisition.

7. Any other facts supporting the justification. (FAR 8.405-6(c)(2) (vii))

GSA Public Buildings Service’s (PBS) Strategic Acquisition of Quality Services (SAQs) is a national initiative for the procurement of quality services related to O&M, Janitorial and like services. GSA’s Region 4 is participating in this initiative. The SAQS goal is to reduce the number of O&M contracts to streamline and provide efficiencies to the management of contracts across PBS. This reduction of contract vehicles will also reduce workload while providing better and more consistent coverage. Region 4 is striving to strategically meet the objectives of the initiative by creating Statewide or zonal Facilities Engineering Services contracts. The O&M and janitorial services for the 7 locations as listed previously will become a part of the South Carolina Statewide Facilities Engineering Services contract. It is in the best interest of Region 4, Carolinas Branch to support this initiative. The competitive Statewide contract is already underway with a tentative start date in spring/summer 2022. Therefore, this shortened base period of performance of less than 1 year (8 months) is necessary to align the proposed start date with the new statewide contract. As described above, a transition period would be required to stand up new O&M and related janitorial services contract should this requirement be awarded to a new contractor. Given the need for a potential transition period, competitively awarding this action at this time would result in unacceptable delays, and a high probability of disruption in O&M and janitorial related services at the seven locations indicated above. Additionally, the shortened period of performance (POP) would also lead to a much higher rate and overall cost for GSA as the new contractor would be taking a much higher risk in bringing personnel on board and being able to retain the personnel. The additional new contract start-up costs would also be eliminated by using the current contractor. In addition, the vital fire and life safety and Electrical Systems testing and maintenance into the overarching O&M contract, requires practical site experience and institutional knowledge, which cannot be garnered, replaced, or substituted with a short-term interim solution with a new contractor.

8. A statement of the actions, if any, the agency may take to remove or overcome any barriers that led to the restricted consideration before any subsequent acquisition for the supplies or services is made. (FAR 8.405-6(c)(2) (viii))

The Government will seek competition to the maximum extent possible for the acquisition for these services. The long-term acquisition strategy is already in process with the intent of providing fair opportunity to the FSS contractors in accordance with FAR Part 8 procedures.

9. Contracting Officer’s Certification. (FAR 8.405-6(c)(2)(ix))

Contracting Officer: I prepared this Justification and certify that this Limited Sources Justification is accurate and complete to the best of my knowledge and belief.

Signature Peyton L. Rowley

Name: _

6/16/2021

Date

Title: _C_o_n_t_r_a_c_t_i_n_g O_f_f_i_c_e_r_ _

10. Technical/Requirements Certification. (FAR 8.405-6(c)(2)(x)

Technical/Requirements Personnel: I certify the requirement meets the Government’s minimum need and that the facts, representations, and data included in this justification are complete and accurate.

6/17/2021

Signature (Project Manager) Date Demarco Calhoun

Title:

Building Management Specialist

11. Concurrence / Review

Concur: One-Above the Contracting Officer

Brenda Myers

Title: _S_u_p_e_r_v_i_s_o_r_y__C_o_n_t_r_a_c_t S_p_e_c_i_a_l_ist

6/17/2021 _

Reviewed: Office of General Counsel (if over legal review threshold, see ADM 5000.4B)

6/21/2021

Tammi Snyder Queen

Title: A_s_s_i_s_t_a_n_t R_e_g_i_o_n_a_l C_o_u_n_s_e_l_,_ LD4

Concur: Director, Acquisition Management Division

6/23/2021

Signature Date Keanna N. Houston

Title: D_i_r_e_c_t_o_r__o_f A_c_q_u_i_s_i_t_i_o_n_s

12. Determination and Approval by Approving Official. (FAR 8.405-6(c)(2)(xi)

As the approving official, I have determined that FAR 8.405-6(a)(1)(i)(B) applies and that Raven Services Inc.

is the only source capable of providing the supplies and services required.

Approved: Competition Advocate:

6/23/2021

Pamela Mitschke

Title: _C_o_m_p_e_t_i_t_i_o_n A_d_v_o_c_a_t_e