LSJ 89233118FNA400044 - COOG and COOP Support - FINAL.pdf

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U.S. DEPARTMENT OF ENERGY (DOE)

NATIONAL NUCLEAR SECURITY ADMINISTRATION (NNSA)

OFFICE OF EMERGENCY OPERATIONS (NA-40)

LIMITED SOURCES JUSTIFICATION

Contract: GS-00F430GA/ 89233118FNA400044

I. AGENCY IDENTITY AND CONTRACTING OFFICE

The services required are in support of the National Nuclear Security Administration (NNSA), Office of Emergency Operations (NA-40). The contracting activity is the NNSA Office of Acquisition and Project Management, Non-M&O Contracting Division, Services Acquisition Branch (NA-APM-124-1).

II. NATURE AND/OR DESCRIPTION OF THE ACTION BEING APPROVED

The purpose of this modification is to add additional support within the scope of work under Task 3.2 Continuity of Operations (COOP) Support and to add a new Task 3.4 COVID-19 Surge Support under contract 89233118FNA400044 issued against GSA Schedule contract GS-00F430GA, held by Covenant Park Integrated Initiatives, Inc.

(“Covenant Park”), located at 3493 Barristers Keepe Circle, Fairfax, VA 22031, to provide continuity program office support to NA-40. Contract 89233118FNA400044 was awarded on April 4, 2018, as a Firm-Fixed-Price (FFP) contract with a three-year period of performance (a one-year base period with two, one-year option periods) ending on April 3, 2021. In response to the COVID-19 events affecting the country, NA-40 identified that it required additional support under the contract. This additional support would result in:

an increase to the amount of support required under Task 3.2 and the creation of Task

3.4 for support directly related to COVID-19 efforts. The additional support includes:

conducting Business Impact Analysis/Business Process Analysis as directed by Federal Continuity Directive 2; and Classified and Unclassified Communications Support as established by the White House Office of Science Policy which includes testing, response readiness, policy, and operational manual writing.

III. DESCRIPTION OF SUPPLIES AND/OR SERVICES

One of NNSA’s core missions is leveraging its unmatched expertise in nuclear security to provide the nation the capability to respond to any nuclear or radiological incident in the U.S. or abroad. This contract provides technical, operational, analytical, and programmatic support to assist the Office of Emergency Operations: Continuity Program Office (CPO), to ensure that the Department of Energy (DOE) is capable of carrying out its Priority Mission Essential Functions (PMEFs) and Mission Essential Functions (MEFs), as well as provide plans, operational support, test, training and exercises along with mandated assessments in support of the Department’s Continuity of Government (COG) activities. This scope not only includes support in the event of natural or man-made disasters but also sustaining our nation’s eight National Essential Functions (NEFs).

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As part of it’s responsibility to support the Continuity Program, NA-40 requires COVID-19 surge support capabilities such as reconstitution plan, developing and revising Continuity Status Reporting Methodology processes, and products to include development of a reporting tool/chart, and developing Continuity Plans and analyzing COVID-19 response to determine changes to existing processes/products used by the DOE Continuity Program.

The value of the additional work is 1,330,248.00which increases the total contract value to $4,811,726.22 .

IV. LIMITED SOURCES AUTHORITY

The authority permitting limited sources as implemented by Federal Acquisition Regulation (FAR) 8.405-6(a)(1)(i)((B) – only one source is capable of providing the services required at the level of quality required because the services are unique and highly specialized.

V. JUSTIFICATION FOR USING LIMITED SOURCES OF AUTHORITY

The required additional support is an expansion of the services already being provided by Covenant Park under Task 3.2 of the contract. The newly created Task 3.4 will provide NNSA necessary support to respond to COVID-19 National Emergency response and recovery effort.

Under Task 3.2 COOP Support, Covenant Park shall continue to support COG and COOP planning initiatives to include Devolution and Concept of Operations (CONOP) Planning, monthly tracking of FEMA Readiness/ Continuity Status Reporting, assist in the review, completion, and distribution of the Department’s Continuity and Devolution plans, developing and executing the Continuity Strategy and Plan to advance and integrate continuity communication capabilities.

Covenant Park shall provide additional deliverables under Task 3.2 to support OSTP D- 16-1 Task Force working groups toward development of new continuity communications requirements. Develop implementation plans to address any new requirements for the Department. Develop an annual report to analyze the state of continuity communications capabilities, needs, and priorities. Develop a training program and roll out a national “train the trainer” and formal assistance program for all DOE/NNSA field elements to conduct their own Business Process Analysis (BPA). Integrate the field element BPA into the enterprise-wide BPA. Following the BPA, commence a formal Business Impact Analysis (BIA) to integrate into a comprehensive risk portfolio and implementation of a documented baseline for implementing resiliency actions across the enterprise. Develop a training program and roll out a national “train the trainer” and formal assistance program for all DOE/NNSA field elements to conduct their own BIAs, in addition to integrate the field element BIAs into the enterprise BIA.

Under Task 3.4 COVID-19 Surge Support, Covenant Park shall provide surge support capabilities to any task force, working group, or special project related to the COVID-19

P a g e 3 | 5 pandemic response and recovery effort as well as revise the DOE/NNSA Reconstitution Plan based on COVID-19 Lessons Learned. Also, Covenant Park will develop and revise the Continuity Status Reporting Methodology, process, and products, to include development of a reporting tool/chart based on COVID-19 Lessons Learned. In addition, Covenant Park will analyze COVID-19 response to determine changes to existing process/products used by the DOE Continuity Program, to include an implementation plan for implementing the lessons learned.

Covenant Park possess the expertise in supporting COG and COOP activities as well as knowledge on specialized and unique relevant standards such as Presidential Policy Directive 40, Federal Continuity Directive 1, Federal Continuity Directive 2, DOE Order 140.1A, Office of Science and Technology Policy/Office of Management and Budget Circular D-16-1, and the National Continuity Policy Implementation Plan. Also, Covenant Park possess a Top Secret facility clearance, employees with Q and/or TS/SCI clearances, and is able to quickly provide staff in the National Capital Region.

Established expertise in supporting COG and COOP activities is vital due to the urgency of the requirement. Moreover, Covenant Park is currently coordinating on behalf of the Federal executive agencies associated with COG and Enduring Constitutional Form of Government (ECG) programs. As such, Covenant Park remains as the only company capable of performing NA-40’s need to provide the technical, operational, analytical, and programmatic support associated with the stated requirements. In addition, Covenant Park is a small business and possesses the following: Top Secret FCL, DOE Continuity Experience, Current Continuity Plans, Executive Branch Continuity Policy Development, Continuity Planning Experience, Enduring Constitutional Government Experience, Continuity Program Development, Management, and Assessments, General DOE Headquarters and Complex Experience, Federal Business Process Analysis Experience, Federal Business Impact Experience, and DOE Order Knowledge. Covenant Park is the only vendor that can meet NNSA’s requirements for the immediate and urgent need in response the COVID-19 national emergency declaration of March 13, 2020. Given Covenant Park’s specialized experience and expertise on COOP and Continuation of Government (COG), changing or competing this work in the midst of this national emergency can be counterproductive to the ongoing effort during the national emergency response. Expanding the current support under Task 3.2 COOP Support and adding Task 3.4 COVID-19 Surge Support is necessary to support the Government’s immediate and critical need.

VI. CONTRACTING OFFICER DETERMINATION OF BEST VALUE

The Contracting Officer has determined after considering the level of effort and the mix of labor proposed to perform the tasks that the price is fair and reasonable and represents the best value for the Department consistent with FAR 8.404(d). The Contracting Officer made this determination based on price analysis techniques utilized under FAR 15.404- 1(b)(2)(iv) (Covenant Park utilized previously negotiated and approved GSA schedules) and (v) (a comparison to an IGCE).

Other vendors were not solicited for this effort, given the specialized, immediate needs identified in § III and V.

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VII. MARKET RESEARCH

NNSA did not conduct market research for this effort. While more than one potential vendor may possess experience on COOP and other national emergency response support related activities, due to the urgent, critical, and immediate need, and time constraints to award this national emergency action related to COVID-19, competing this effort among potential sources is not feasible.

VIII. OTHER FACTS

NA

IX. INTERESTED SOURCES

NA

X. STEPS TO FOSTER COMPETITION

Should the need to support these additional efforts continue beyond the existing period of performance, NNSA will consider the ability of other vendors to support these efforts through future market research.

CERTIFICATIONS

Acquisition Initiator/Technical Representative:

I certify that the facts and representations under my cognizance, which are included in this justification and which form a basis for this justification, are complete and accurate.

Signature Date

Contracting Officer:

I certify that this justification is accurate and complete to the best of my knowledge and belief.

Competition Advocate:

I have reviewed this justification and find it to be accurate and complete to the best of my knowledge and belief. Since this JOFOC does not exceed $13.5M, this review serves as approval.

5/12/2020

05/12/2020

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