Limited Sources JA GBFMD Redacted.pdf

4. AUTHORITY AND SUPPORTING RATIONALE AND A DEMONSTRATION OF THE PROPOSED

CONTRACTOR’S UNIQUE QUALIFICATIONS TO PROVIDE THE REQUIRED SUPPLY OR

SERVICE.

This Limited Source Justification is prepared under the authority of FAR 6.302-1(a)(2) and FAR 6.302-3, which allows for an exception to fair opportunity to maintain a facility, producer, manufacturer, or other supplier available for furnishing supplies or services in case of a national emergency or to achieve industrial mobilization. The USTRANSCOM Strategic Plans, Policy & Logistics Directorate (USTRANSCOM-TCJ5/J4) and GBFMD operations division require specialized data analysis services to support the GPIC and ensure uninterrupted fuel support to military operations worldwide. These services, as detailed in the Performance Work Statement (PWS), necessitate expertise and capabilities that are uniquely held by commercial fuel producers, specifically U.S.

petroleum companies with global capabilities to operate one or more domestic refineries with a minimum total production capacity of 200,000 Barrels Per Day (BPD) and an OCONUS distribution network including transportation, storage, and logistics management for petroleum products.

General consulting services and other potential vendors lack the critical, in-depth, understanding of refining processes, product specifications, logistics networks, knowledge of the fuel supply chain when it is being used in the interest of national defense, and real-time market dynamics essential for providing actionable recommendations to the DoD. While non-industry consultants may possess analytical skills, they lack the direct operational experience, infrastructure control, and access to the real-time, data necessary to effectively analyze DoD's fuel logistics capacity, identify challenges to capacity acquisition and sustainment, and provide recommendations that are both data-driven and operationally tested and applied. In essence, general consulting and other potential vendor capabilities are no different than those currently possessed by GBFMD GPIC.

Only U.S. petroleum companies can provide the required level of expertise because they:

Possess Knowledge of Fuel Logistics: As direct participants in the fuel supply chain, these companies possess intimate knowledge of fuel movement, storage capacity, and network capabilities. This includes knowledge of the fuel supply chain when it is being used in the interest of national defense. This knowledge is not readily available to outside consultants or analysts.

Control Critical Infrastructure: U.S. petroleum refineries own and operate the infrastructure necessary to produce, store, and distribute fuel. This direct control provides them with a unique perspective on the challenges and opportunities associated with meeting DoD's fuel requirements. They possess detailed knowledge of their own capabilities and limitations, which is critical for accurate analysis. This also means that they are crucial in the event of industrial mobilization, and they provide critical capacity. U.S.

petroleum companies will be needed to obtain fuel in the interest of the national defense.

Offer Real-Time Market Insights: These companies have access to real-time market data and insights into fuel availability, pricing, and potential disruptions. This information is crucial for developing proactive, data-informed strategies for ensuring uninterrupted fuel support to military operations worldwide. Their understanding of market dynamics is based on direct participation in the market, not on theoretical models, and impacts on the market when the fuel supply chain is used in the interest of national defense.

Operate Under Stringent Regulations: U.S. petroleum companies operate under stringent environmental and safety regulations, providing a level of assurance and reliability that may not be present with other potential vendors.

Attempting to utilize other sources, such as general consulting firms or companies without the requisite infrastructure, industrial expertise, knowledge of the fuel supply chain when it is being used in the interest of national defense and operational experience, would result in analyses lacking the necessary depth, accuracy, and practical applicability. This would ultimately hinder DoD's ability to effectively manage and posture bulk fuel globally, jeopardizing critical military operations and impacting national defense and strategic readiness. The inherent and irreplaceable knowledge residing within these companies makes them the only viable source for this requirement.

5. DESCRIPTION OF THE MARKET RESEARCH CONDUCTED AMONG POTENTIAL

CONTRACTOR’S AND THE RESULTS

In accordance with FAR Part 10, comprehensive market research was conducted to determine the availability of qualified sources capable of providing specialized data analysis services to support USTRANSCOM's GBFMD operations. This market research effort was documented in the Market Research Report (MRR) dated 15 July 2025 and included the following key activities:

- Market Survey: A broad market survey was conducted to identify potential vendors offering data analysis, logistics support, and energy consulting services. This survey encompassed:

o GSA Schedules Review: An extensive search of GSA Schedules was conducted to identify vendors offering relevant services.

o Industry Database Searches: Industry databases and online resources were searched to identify companies with expertise in the petroleum refining industry, data analytics, and logistics.

o Review of Government Contract Vehicles: An assessment was made of existing Government-wide acquisition contracts (GWACs) and Indefinite Delivery/Indefinite Quantity (IDIQ) contracts that could potentially support this requirement, including but not limited to GSA Multiple Award Schedule (MAS), ITES-3S, OASIS Plus Small Business, SeaPort NxG, VETS 2 GWAC, and Information Analysis Center Multiple Award Contract (IAC MAC). (See MRR Section 2.1.7)

- Request for Information (RFI): To gather more specific information about potential vendor capabilities and commercial availability, a Request for Information (RFI) was released on SAM.gov on 17 June 2025 (TRANSCOM25W002). The RFI was strategically designed to solicit detailed information on potential sources' capabilities, experience, security clearances, and proposed approaches for meeting the requirements outlined in the draft Performance Work Statement (PWS). The RFI specifically requested information on:

o Company information, business size, and socioeconomic status (RFI Sections 3.1 & 3.2).

o Experience in performing data analysis at the classified level, including analyzing fuel logistics capacity, identifying challenges to capacity acquisition, and developing actionable recommendations (RFI Section 3.4).

o Past performance on similar projects or contracts (RFI Section 3.4).

o Commercial availability of the required services and potential commercial solutions (RFI Section 3.5).

o Potential organizational conflicts of interest (RFI Section 3.5).

o Suggestions for improving the procurement and innovative solutions to be considered (RFI Section 4).

- Analysis of RFI Responses: The RFI closed on 24 June 2025, resulting in the receipt of nine (9) responses from a diverse pool of vendors, including both large and small businesses (MRR Section 6.1). The RFI responses were carefully analyzed and assessed against the requirements outlined in the draft PWS. The key findings from this analysis are summarized below:

o Market research reveals a substantial disconnect between respondents' capabilities and mission partner requirements. Although several consulting firms expressed interest, the Government determined they lacked the essential technical knowledge needed to properly understand the classified data specifications of this procurement. The mission partner requires data analysis involving bulk fuel supply chain networking information that exists exclusively within U.S.

Petroleum companies. While data analysis represents the core acquisition function, the specific data elements are highly detailed and unique to the U.S. Petroleum sector. The Government requires industry expertise on fuel supply chain networks, fuel capacity logistics, and real-time market analysis within the U.S. Petroleum industry across both peacetime and wartime scenarios.

Following evaluation of RFI responses, only one organization demonstrated the specialized expertise and experience outlined in section 4 of this J&A. The other eight respondents identified themselves as general consulting companies that currently do not possess any operational experience in the U.S. Petroleum industry. Consequently, USTRANSCOM J 5/4 and TCAQ have determined that limiting sources to U.S. Petroleum companies is necessary to achieve its intended objective.

o According to section 3.B of the PWS, contractors may need to engage in relevant planning and operational activities, including classified briefings and deliverables. Given the classified nature of this requirement, multiple contractors claimed Top-Secret Facility Clearances (FCLs). However, in order for these firms to share/discuss our requirements with the U.S. Petroleum companies possessing the specialized industry knowledge USTRANSCOM requires, these companies would also require FCLs. TCAQ has not identified any U.S. Petroleum refinery with a Secret FCL.

Therefore, these interested general consulting firms cannot subcontract or access the industry-specific expertise this acquisition demands, furthering the need to limit sources to U.S. Petroleum companies only. Note: In order for the Defense Counterintelligence and Security Agency (DCSA) to process an FCL application for a contractor, a contractor must possess a classified contract requirement. Contracting directly with Petroleum companies will fulfill this DCSA requirement for those companies that respond to the requirement and receive an award. Relevant experience in bulk fuel matters as described are expected to outweigh the delay associated with obtaining and FCL, which would be required of any vendor in the class of U.S. Petroleum companies.

o No Organizational Conflicts of Interest: Based on the RFI responses, no potential organizational conflicts of interest (OCI) were identified (MRR Section 9.5).

6. ANY OTHER FACTS SUPPORTING THE JUSTIFICATION.

The nature of the GBFMD mission requires a high degree of reliability and accuracy. Flawed data analysis could have significant negative consequences for military operations. The decision to limit the source to U.S. petroleum companies is based on a careful assessment of the risks and benefits associated with different potential outcomes.

Technical data packages, specifications, and engineering descriptions suitable for Full and Open Competition have not been developed because the core requirement is for consulting based on specialized operational expertise and cannot be codified or replicated in a standard solicitation package. The value lies in the companies understanding of the fuel market and their ability to apply that knowledge to DoD's specific plans and needs.

7. 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 SERVCIES IS MADE.

It is unlikely that the barriers to limited competition can be eliminated, since the DoD’s specific requirement for operational experience to set the theater to achieve “Readiness” can only be achieved from firms with Secret clearances from the Petroleum industry sector. However, it should be noted that competition exists within this industry sector and all responsive firms that satisfy the evaluation criteria will receive an award with an unrestricted capability to compete at the task order level to provide operational planning (OPLAN), reviews, validations, and recommendation opportunities and deliverables specific to AORs of need.