LSJ_Logical Follow-On_68HERH21A0018.pdf

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

1300 Pennsylvania Ave, NW

Washington, DC 20460

LIMITED-SOURCES JUSTIFICATION

in accordance with FAR 8.405-6(c)(2) conducted under the authority of the Multiple-Award Schedule Program

1. FAR 8.405-6(c)(2)(i), Identification of the agency and contracting activity:

Agency: Environmental Protection Agency

Contracting Activity: Office of Finance and Administration (OFA)

Office of Chief Procurement Officer (OCPO)

Land, Enforcement, and Air Division (LEAD)

Program Office: Office of Superfund and Emergency Management (OSEM)

Program POC: Nadya Rose, OSEM

Project Identification: Superfund Redevelopment Initiative (SRI) and Technical Assistance

Services Contract (SR-TASC)

Proposed Source(s): SKEO SOLUTIONS, INC.

GSA Contract No. 47QRAA20D0027, EPA BPA No. 68HERH21A0018

2. FAR 8.405-6(c)(2)(ii), Nature and description of action being approved:

The purpose of this limited source justification is for a logical follow-on to increase the capacity (i.e.

ceiling) of EPA’s Blanket Purchase Agreement (BPA) no. 68HERH21A0018 under GSA Schedule

Contract no. 47QRAA20D0027, with SKEO SOLUTIONS, INC. (“SKEO”) by $800,000.00 (or 2%) to ensure continued support for the evaluation of Superfund cleanup activities, including examining remediation progress, modeling and analyzing remediation data and supporting the redevelopment of cleaned up sites services in support of OSEM, specifically for the Superfund Redevelopment Program

(SRP) Support provided under Call Order No. 68HERH22F0027. The logical follow-on is intended for

SKEO to provide the same scope of work but at a expanded level of support under Tasks 2, 3, 5 and 8 under the aforementioned call order for the duration of the remaining performance period through July 31, 2026.

The BPA was originally competed as a small business set-aside under GSA Multiple Award Schedule

(MAS) 541620 for Environmental Consulting Services in accordance with applicable Federal Supply

Schedule and set-aside ordering procedures, resulting in an award to SKEO on July 29, 2021, with total ceiling of $52,000,000.00, inclusive of all labor and ODCs for a 12 month Base Period and four (4) 12 month option periods beginning on August 1, 2021. This ceiling was sufficient at the time of award for providing the full scope of Superfund Redevelopment Initiative (SRI) and Technical Assistance Services.

During the last option period of the BPA, call orders that required continued support were extended to

July 31, 2026, the maximum allowable date under the BPA while the program office undertook timely efforts to submit follow-on call order packages for continued support under the Agency’s OLEM Large multiple-award suite of BPAs. Due to the Executive Orders issued in January – February 2025, several of the packages had to be revised to be in compliance with the orders, requiring support to continue under existing, active call orders more than had been anticipated at the beginning of the last BPA option period

(August 1, 2025 – July 31, 2026). Accordingly, it was determined that the current ceiling for SRP

Support provided under Call Order No. 68HERH22F0027 was insufficient to sustain support for the duration of the call order period of performance through July 31, 2026, warranting an estimated increase to the call order ceiling in the amount of $1,050,000. With only $269,726.57 remaining in BPA capacity, the increase to the call order further requires an increase to the BPA ceiling in the amount of $780,273.43, herein rounded to $800,000.00.

3. FAR 8.405-6(c)(2)(iii), A description of the supplies or services required to meet the agency's needs (including the estimated value):

The services to be provided under the logical follow-on to the BPA are as follows:

• BPA Task 1. TECHNICAL AND ANALYTICAL SUPPORT. There are no changes to the

BPA SOW for the logical follow-on work from the work already being performed.

• BPA Task 2. MEETING AND CONFERENCE SUPPORT. There are no changes to the BPA

SOW for the logical follow-on work from the work already being performed.

• BPA Task 3. TRAINING SUPPORT. There are no changes to the BPA SOW for the logical follow-on work from the work already being performed.

• BPA Task 4. TECHNICAL INFORAMTION ASSISTANCE SUPPORT. There are no changes to the BPA SOW for the logical follow-on work from the work already being performed.

• BPA Task 5. COMMUNICATIONS AND OUTREACH SUPPORT. There are no changes to the BPA SOW for the logical follow-on work from the work already being performed.

• BPA Task 6. PROGRAM EVALUATION, PLANNING AND IMPLEMENTATION

SUPPORT. There are no changes to the BPA SOW for the logical follow-on work from the work already being performed.

For Call Order No. 68HERH22F0027, the services to be provided under the ceiling increase are as follows:

• Task 1. Performance Measure Support and Communications (SWRAU). This task falls under BPA SOW Tasks 1 and 5. There are no changes to the Call Order SOW for the logical follow-on work from the work already being performed.

• Task 2. Website Support. This task falls under BPA SOW Task 5. There are no changes to the

Call Order SOW for the logical follow-on work from the work already being performed with the exception of requiring an additional 2,000 hours of the same support for an expanded section of the website on key Agency priorities and web content.

• Task 3. SRP Program and Technical Support. This task falls under BPA SOW Task 6. There are no changes to the Call Order SOW for the logical follow-on work from the work already being performed with the exception of requiring an additional: 4,500 hours of the same support for application of reuse in the site assessment program and provide potential reuse technical assistance to EPA SAMs and state/tribal partners; and 14,000 hours of the same support for reuse trends and supportive actions.

• Task 4. Economic Analysis and Regional Reuse Economic Reports. This task falls under BPA

SOW Tasks 1 and 5. There are no changes to the Call Order SOW for the logical follow-on work from the work already being performed.

• Task 5. Geospatial Resource Development for Superfund Sites. This task falls under BPA

SOW Tasks 1 and 5. There are no changes to the Call Order SOW for the logical follow-on work from the work already being performed with the exception of requiring an additional 6,000 hours of support for additional activities, such as (but not limited to): conducting spatial analyses;

creating, maintaining, and updating applications; using and developing Superfund GIS data, spatial analyses and tools to address new administration and program priorities; and develop (as needed) interactive tools to support Superfund site redevelopment efforts.

• Task 6. SRP Information Management. This task falls under BPA SOW Tasks 1 and 6. There are no changes to the Call Order SOW for the logical follow-on work from the work already being performed.

• Task 7. SRP / HUD Federal Partnership Support. This task falls under BPA SOW Tasks 1, 2, 3, and 5. There are no changes to the Call Order SOW for the logical follow-on work from the work already being performed.

• Task 8. External Communications and Outreach. This task falls under BPA SOW Tasks 5 and

6. There are no changes to the Call Order SOW for the logical follow-on work from the work already being performed with the exception of requiring an additional 4,000 hours of the same support EPA in drafting public-facing materials.

• Task 9. Superfund Reuse Training. This task falls under BPA SOW Task 3. There are no changes to the Call Order SOW for the logical follow-on work from the work already being performed.

• Task 10. Convert Quickscore to Web Application. This task falls under BPA SOW Task 1.

There are no changes to the Call Order SOW for the logical follow-on work from the work already being performed.

The total estimated value for the logical follow-on is $800,000.00, inclusive of labor and ODCs).

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

In accordance with FAR 8.405-6(a)(1)(i)(C), this justification is for a logical follow-on to a BPA awarded against an original Federal Supply Schedule contract, 47QRAA20D0027, that was awarded competitively under GSA MAS 541620 for Environmental Consulting Services in accordance with applicable Federal

Supply Schedule and set-aside ordering procedures. In the interest of economy and efficiency, the expanded support is a logical follow-on to the current BPA, 68HERH21A0018, that was entered into with

SKEO on July 29, 2021. There are no revisions to the BPA SOW, and the revisions to the SOW for Call

Order No. 68HERH22F0027 are only limited to the additional hours of support required for which this increase is requested.

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

The current BPA was issued against GSA MAS 541620 for Environmental Consulting Services. Services offered on the schedule are priced either at hourly rates, or at a fixed price for performance of a specific task (e.g., installation, maintenance, and repair). Although GSA has already determined the prices of supplies and fixed-price services, and rates for services offered at hourly rates, under schedule contracts to be fair and reasonable, the Contracting Officer conducted a separate price evaluation in accordance with FAR 8.405-2(d), considering the level of effort and the mix of labor proposed to perform the requirements to make an affirmative determination that the total proposed price was reasonable on the basis of adequate price competition prior to issuance of the BPA, which was placed utilizing the competitive procedures of FAR 8.405-2, indicated the Contracting Officer’s determination that the BPA represented the best value in meeting the Government’s needs for Superfund Redevelopment Initiative

(SRI) and Technical Assistance Services.

Because the logical follow-on will be a continuance of the same scope as currently provided under the

BPA, with an expanded level of the same support as currently provided under Call Order No.

68HERH22F0027, which has already been determined to represent the best value in meeting the

Government’s needs as stated above, at existing BPA pricing which was based on the same pricing originally offered under the same GSA Schedule Contract, 47QRAA20D0027, the Contracting Officer has determined that the logical follow-on represents the best value in meeting the Government’s needs for

Superfund Redevelopment Initiative (SRI) and Technical Assistance Services and specifically (SRP)

Support provided under Call Order No. 68HERH22F0027 consistent with FAR 8.404(d).

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

There was no market research conducted for this requirement since the authority of FAR 8.405-

6(a)(1)(i)(C) allows for a logical follow-on, which has been determined to be in the best interest of the

Agency for obtaining expanded Superfund Redevelopment Initiative (SRI) and Technical Assistance

Services and specifically (SRP) Support provided under Call Order No. 68HERH22F0027 within the existing BPA periods of performance.

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

None

8. FAR 8.405-6(c)(2)(viii), 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:

Since this Limited Source Justification is for a logical follow-on, offers will not be solicited from any additional sources beyond SKEO for an expanded level of SRP support currently provided under

68HERH21A0018 per the authority in FAR 8.405-6(a)(1)(i)(C). However, in accordance with FAR

8.405-6(a)(2)(ii), within 14 days after issuing the modification to increase the capacity of the BPA, a notice of this Limited Sources Justification will be published in accordance with FAR 5.301 and the justification will be posted at the Government Point of Entry (GPE) (https://www.SAM.gov) and on

FedConnect (https://www.fedconnect.net), which will provide access to the justification by linking to the

GPE, for a minimum of 30 days. Any responses received to the notice or justification will be recorded and retained as a listing of interested and/or prospective sources to be included in EPA’s market research for the future recompete.

9. FAR 8.405-6(c)(2)(ix), The ordering activity contracting officer's certification that the justification is accurate and complete to the best of the contracting officer's knowledge and belief:

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

Whitney Coleman-Clark Date [if not electronically signed]

Contracting Officer

Office of Finance and Administration (OFA)

Office of Chief Procurement Officer (OCPO)

OLEM & OECA Procurement Branch (OOPB)

10. FAR 8.405-6(c)(2)(x), Evidence that any supporting data that is the responsibility of technical or requirements personnel (e.g., verifying the Government's minimum needs or requirements or other rationale for limited sources) and which form a basis for the justification have been certified as complete and accurate by the technical or requirements personnel:

The undersigned hereby certify that all supporting data that is the responsibility of technical or requirements personnel (e.g. verifying the Government’s minimum needs or requirements or other rationale for limited sources) and which form a basis for this justification is complete and accurate.

Nadya Rose Date [if not electronically signed]

Contracting Officer Representative (COR)

Office of Superfund and Emergency Management (OSEM)

APPROVAL:

Heather M. Adams Date [if not electronically signed]

Section Supervisor

Office of Finance and Administration (OFA)

Office of Chief Procurement Officer (OCPO)

OLEM & OECA Procurement Branch (OOPB)