Limited_Sources_Justification.pdf

FWS Form 3-0058 (Rev. 5/2024) U.S. Fish and Wildlife Service

Limited Sources Justification

JOINT ADMINISTRATIVE OPERATIONS

Acquisition Operations

In accordance with FAR 8.405-6, the Contracting Officer may restrict consideration of sources for orders placed or BPAs established under Federal Supply Schedules (FSS) under the condition that the restricted consideration be justified in writing.

Instructions: The information in the text boxes are provided as sample language or to indicate a needed fill-in. Sample language shall be removed from the final document. All text boxes require information and shall not be left blank.

1. Agency and Contracting Activity:

Department of the Interior, U.S. Fish and Wildlife Service (FWS), Joint Administrative Operations, Acquisition and Property Operations.

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

The Gulf Restoration Office requests approval for an End Product contract to fund procurement of fixed services and data for the North Breton Island Restoration Project in FY 2025. The contract will provide essential image analysis services from Colibri Ecological Consulting, LLC (Colibri). These services are crucial for meeting restoration monitoring requirements, maintaining regional consistency in monitoring methodologies, and creating a uniform dataset to help us evaluate restoration. Because of Colibri’s long-term involvement in aerial bird monitoring, their unique and effective methodologies, and work on other avian monitoring efforts in the Gulf of Mexico, their services are necessary for the success of our future monitoring work. This document provides supplementary documentation to demonstrate that

Colibri is the only service provider capable of fulfilling our service requirements.

3. Description of the Supplies or Services Required to Meet the Agency’s Needs (including estimated value):

North Breton Island is a 426-acre barrier island, located approximately 13 miles off Louisiana’s coast. It is part of Breton National Wildlife Refuge. The North Breton Island Restoration Project began in 2020 and used dredge fill and plantings to restore form and function to the beach, dune, and back-barrier marsh components of the barrier island ecosystem. An important function of these habitats is breeding, foraging, and loafing habitat for bird species that were injured during the Deepwater Horizon oil spill and response that began in 2010. The monitoring phase of the project began in 2022 and is ongoing. It includes an aerial survey component to monitor use of the restored habitat for nesting by wading birds and nearshore seabirds, including brown pelicans, terns, skimmers, and gulls. Counts of breeding birds will be derived from aerial imagery captured during the nesting season (May-July 2024). There is a need for manual marking, or “dotting,” of these images to collect data within them—counts of birds and nests on the island in each image. Necessary deliverables include counts of birds and nests, a database containing the count information, and a final report describing the image processing methodology and summary counts. The period of performance for this procurement contract is four months. Procurement of data deliverables and image processing services is estimated to value at $115,500.

4. a. Authority Cited (Select One):

☐ FAR 8.405-6(a)(1)(A) – “An urgent and compelling need exists, and following the procedures would result in unacceptable delays.”

☐ FAR 8.405-6(a)(1)(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.”

☐ FAR 8.405-6(a)(1)(C) – “In the interest of economy and efficiency, the new work is a logical follow-on to an original Federal Supply Schedule (FSS) order provided that the original order was placed in accordance with the applicable FSS ordering procedures. The original order or BPA must not have been previously issued under sole-source or limited-sources procedures.”

☒ FAR 8.405-6(b)(1) – Items Peculiar to One Manufacturer. “The particular brand name, product, or feature is essential to the Government’s requirements, and market research indicates other companies’ similar products, or products lacking the particular feature, do not meet, or cannot be modified to meet, the agency’s needs.”

b. Supporting Rationale:

The North Breton Island Restoration Project restored 426 acres of barrier island habitat with dredge fill and plantings to restore breeding, foraging, and loafing habitat for bird species that were injured during the Deepwater Horizon oil spill and response. The construction phase of the project was completed in 2022, and the monitoring phase of the project is ongoing. An important part of the monitoring plan is measuring counts of nests, breeding adult birds, juveniles, fledglings, and hatchlings. Aerial images were acquired with drones during the nesting season (May-July) in 2024 through a previous contract to document breeding on the restored island area. It is now necessary to analyze these images to derive monitoring data from them—counts nests, breeding adults, juveniles, fledglings, and hatchlings for various species. The Service does not currently have the personnel capacity to perform this analysis to an acceptable standard.

An important requirement for the image processing is that the methodology is consistent with other aerial monitoring efforts that have been funded across Louisiana through other restoration projects, including Louisiana Colonial Waterbird Monitoring, RW TIG—Colonial Waterbird Monitoring, and

Coastwide Colonial Waterbird Aerial Photographic Nest Surveys and Nest Dotting Analyses, Louisiana. This will allow our data to be comparable to these efforts, and increase the quality, utility, and interoperability of the data. It will satisfy our monitoring requirements and evaluate the effects of island restoration on breeding waterbirds and nearshore seabirds. Additionally, this approach to monitoring nests and birds is likely to be more cost-effective than alternative methods of aerial surveys using fixed-wing aircraft. Colibri’s image processing methodology involves a technique called “dotting.” In this process, personnel carefully evaluate aerial images containing breeding birds to identify those that most accurately reflect the nesting season for each species. They then manually count the bird nests, breeding adults, and fledglings within these selected images. Each image contains many different species and hundreds of birds and nests in diverse stages and conditions. Because of this, this task requires extensive knowledge of the physical characteristics and breeding behaviors of various species, including terns, skimmers, and gulls, as well as an understanding of their nesting phenologies. It is also necessary to have a deep working knowledge of the Louisiana coastal environment and breeding bird habitat.

This contract would procure the image analysis services to derive monitoring data that is necessary for the project’s success. Deliverables include counts of nests, breeding adult birds, juveniles, fledglings, and hatchlings, a Microsoft Access database containing the count information, and a final report summarizing the data and the methodology for image processing. Its in the best interest of the government to award to Colibri to prevent us from having to convert any images that aren’t consistent with our current reporting.

5. Best Value Determination:

This order represents the best value and results in the lowest over cost alternative to meet the

Government’s need given the Gulf Restoration Program requirements. Although GSA has already negotiated and determined fair and reasonable prices, additional discounts will be sought prior to placing the order.

6. Market Research:

Market research was conducted by the Gulf Restoration Office in August 2024 to compare competitive options and costs for image processing services. Conducting this research helped investigate whether a single source award would be the best choice for services. Awarding this requirement to a separate contactor may result in a different Market information was collected from past image processing contracts written and solicited by Louisiana state wildlife management agencies. Results confirmed that a single source award would best satisfy our image processing and data standards, and that this option is a cost-effective choice for the government. The attached email correspondence documents the market research that was conducted.

7. Any Other Facts Supporting the Justification:

NA

8. Statement of Actions to Remove Barriers:

No competition is sought for this award because of the need to create data that is consistent with existing datasets collected through other aerial bird survey efforts. We have determined through market research and discussions with project partners that only one source, Colibri Ecological Consulting, LLC, is capable of providing the needed services to meet our project’s standards.

9. Technical/Requirements Personnel Certification I hereby acknowledge that the supporting data that forms justification is my responsibility and certify that the basis for this justification is complete and accurate.

Program Partner Signature

10. Contracting Officer Certification I hereby certify that this justification is accurate and complete to the best of my knowledge and belief and approve the use of limited sources procedures pursuant to FAR 8.405-6.

Contracting Officer Signature

11. Approval by the Chief of the Contracting Office (>SAT) Based on the foregoing justification, I hereby approve this procurement.

Chief of the Contracting Office Signature

12. Approval by Senior Chief of Contracting Office (>$750k)

Senior Chief of the Contracting Office Signature

13. Approval by Head of Contracting Activity (>$750k)

Head of the Contracting Activity Signature