LSJ FE_Redacted.pdf

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LIMITED SOURCE FOR AN ORDER EXCEEDING

THE SIMPLIFIED ACQUISITION THRESHOLD

(AUTHORITY: FAR 8.405-6)

This acquisition is conducted under the authority of the Multiple Award Schedule Program.

1. Agency and contracting activity. Department of Commerce (DOC), National Oceanic and

Atmospheric Administration (NOAA) Acquisition and Grants Office (AGO), Western Acquisition Division and National Marine Fisheries Service (NMFS) Southeast Regional Office (SERO).

2. Nature and/or description of the action being approved.

This is a limited source justification to award a follow-on to an existing task order. A Firm-Fixed- Price (FFP) task order under the General Services Administration (GSA) Multiple Award Schedule (MAS) Special Item Number (SIN) 54151S, Information Technology (IT) Professional Services is anticipated. This FFP task order will be awarded against Technical and Engineering Support Alliance LLC (TESA)’s GSA Schedule 47QTCA19D006G for support services for the SERO’s Catch Share Online System/Individual Fishing Quota (CSOS/IFQ) system.

3. Description of the supplies or services required to meet the agency’s needs (including the estimated value).

SERO manages three (3) commercial Catch Share programs (CSOS): the Gulf of Mexico (Gulf) Red Snapper Individual Fishing Quota (IFQ) program (RS-IFQ), the Gulf Grouper-Tilefish IFQ program (GT-IFQ), and the South Atlantic Wreckfish Individual Transferable Quota (ITQ) program. Currently, the two (2) Gulf IFQ programs are housed in the CSOS. While the Wreckfish ITQ program is currently a paper-based program with shares recorded in the Permit Information Management System (PIMS). There is an active amendment to the Fishery Management Plan (FMP) for the Snapper-Grouper Fishery of the South Atlantic Region (Snapper-Grouper FMP) to move the program into the CSOS.

All three (3) programs are guided by regulations in the Magnuson-Stevens Fisheries Conservation and Management Act (MSA) and specific regional regulations for each program. Program management must meet all regulations as specified per the program. The IFQ programs were implemented with Amendments 26 and 29 to the FMP for the Reef Fish Fishery of the Gulf of Mexico (Reef Fish FMP). Fishery Management Councils (Councils) can modify the Catch Share programs through the regulatory process specified in MSA, which comes with established timelines for the completion of any requested changes. Both IFQ programs have current amendments with the Gulf of Mexico Fishery Management Council (Gulf Council) that may impact functions in the CSOS.

The Southeast region must transition the CSOS/IFQ system from one (1) Amazon Web Services (AWS) Cloud Instance to a Cloud Instance that SERO controls and operates. The services include the cloud transition and operation and maintenance. The Contractor will be responsible for transitioning the CSOS/IFQ system and for its operation and maintenance (application and back-end database), while SERO will maintain the Cloud services operations. The Contractor must work with SERO IT to plan for and complete the transition, keep the system secure, and ensure system

In 2020, TESA modernized the IFQ system into a modern programming language and has since maintained its operation and maintenance and new development through the OSF task order.

The system is custom-built and not an off the shelf product. The system contains a significant amount of validations in the behind the scene coding to ensure that the actions taken by the stakeholders conform to federal regulations regarding this program. Due to the complex nature of this system, another contractor cannot support the system without a high degree of risk of failure. There is a steep learning curve for this system (anywhere from 4 to 9 months), and this system is required to be operational 24 hours a day, 7 days a week. There is no alternative system for reporting if this system fails. The intent is for this system to be off boarded to Federal management upon hiring and training of new Federal employees.

TESA ensures no lapse in service coverage for the CSOS/IFQ system. There are no existing employees outside of TESA that can replicate the service support provided from TESA. There have been efforts to hire federal employees to serve in this support role, but unforeseen complications have delayed any hiring action and have resulted in this potential gap in support.

The CSOS/IFQ system is required by law under the Magnuson-Stevens Fisheries Conservation and Management Act. Without operations and maintenance support, SERO is at risk of noncompliance and the potential of litigation if there is an error that causes a system failure because there are no personnel authorized or qualified to resolve it outside of TESA.

5. Determination by the ordering activity contracting officer that the order represents the best value consistent with FAR 8.404(d).

GSA has already determined the prices of services fair and reasonable. Therefore, ordering activities are not required to make a separate determination of fair and reasonable pricing.

However, in accordance with FAR 8.404(d) and 8.405-2(d), the Contracting Officer will conduct a price evaluation in order to determine the pricing is reasonable and provides the best value. In addition, in accordance with FAR 8.405-4, the Contracting Officer will seek additional discounts prior to placing the task order.

6. Market research conducted among schedule holders (or reason market research was not conducted).

A Request for Information (RFI) was emailed to five (5) Women Owned Small Businesses (WOSB) on the NOAA Mission IT Services (NMITS) Blanket Purchase Agreement (BPA) holder listing on January 17, 2023 to gauge capabilities and interest of these WOSB. This RFI included Dakota Consulting, Halvik, IBSS, TESA, and Alpha Omega Integration. On January 23, 2023 one

(1) response to the RFI was received from the incumbent, TESA. A follow up email was sent on January 23, 2023 requesting feedback from the RFI and no responses were received. On January 30, 2023 an additional RFI was sent out to four (4) additional WOSB with a due date of February 3, 2023. This RFI included Innovim, Ocean Associates, Spatial Front, and Syneren. No responses were received to the second RFI. The Statement of Work (SOW) attached to the RFI only included the operation, maintenance, and design support services. The cloud transition services were later added to the SOW on February 3, 2023. For both RFI’s, the vendors that did not submit a response were emailed to determine why they did not submit a capability statement. None of the vendors responded.