23F0013 P00003_LSJ_Redacted.pdf

CUI//SP-PROCURE//DL ONLY

V 1.4 (29 Nov 2023)

MEMORANDUM TO THE FILE

Subj: FAR SUBPART 8.4 LIMITED SOURCES JUSTIFICATION

I. BACKGROUND:

A. FAR 8.405-6 states that orders placed or BPAs established under Federal Supply Schedules are exempt from the requirements in FAR Part 6. However, an ordering activity must justify its action when restricting consideration. This memorandum documents the justification for limiting sources, in accordance with FAR 8.405-6(c).

B. This acquisition is conducted under the authority of the Multiple-Award Schedule Program (see

FAR 8.401).

C. For a proposed order or BPA exceeding the simplified acquisition threshold (SAT), the requiring activity shall assist the ordering activity contracting officer in preparation of the justification, in accordance with FAR 8.405-6(c)(1).

II. IDENTIFICATION OF THE AGENCY AND CONTRACTING ACTIVITY:

This acquisition is being conducted by the Department of the Navy, under the Headquarters Marine Corps, Installation and Logistics (HQMC, I&L) Head of the Contracting Activity (HCA). The executing contracting office is Marine Corps Installation Command (MCICOM), Headquarters (HQ) Contracting, in Arlington, VA.

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

The action being approved is the award of a sole source modification to Concurrent Technologies Corporation (CTC) to provide Public Works (GF-PW) with continued energy support services. This acquisition will utilize CTC's existing General Service Administration (GSA) OASIS contract GS00Q14OADU112 and Task Order M95494-23-F-0013. This is a firm-fixed-price (FFP) Task Order with cost-reimbursement line items for contract access fees and travel expenses.

IV. DESCRIPTION OF THE

NEEDS (INCLUDING THE ESTIMATED VALUE):

The contract provides the MCICOM Facilities Directorate Public Works (GF-PW) with energy security support services, including modernizing infrastructure, reducing dependence on external suppliers, minimizing energy and water consumption, generating facility energy data, and fostering long-term alignment with Congressional legislation, DoD strategic direction, and Fleet Marine Force requirements targeting climate, energy resilience, and Force Design. Contractor services are required to support different sections (i.e., Headquarters, Regions, and Installations) of the USMC, which possess their own

Controlled by: DON, USMC, I&L HCA Controlled by: MCICOM HQ Contracts CUI Category(ies): PROCURE Limited Dissemination Control: DL ONLY POC: MCICOM HQ Contracts

FAR Subpart 8.4 Limited Sources Justification

The support under this contract includes:

HQ Support: Sets overarching policy and Program direction. Provides technical expertise for energy planning and management and utility systems, policy recommendations for energy and utility requirements, project implementation guidance and strategies, centralized energy information data management, transportation operations, communications, and outreach.

Region Support: Oversees installation progress and coordinates reach back support. Provides energy program technical expertise, surge support, project development guidance, best practices and lessons learned, coordination between installations for sharing resources.

Installation Support: Carries out day to day activities to meet Program objectives. Provides core energy program support services, energy project development, designs, reviews, lifecycle cost analysis, feasibility studies, reporting functions, data gathering, utility bill tracking and analysis, energy and water audits, performance assurance, and commissioning.

There are currently six (6) tasks under this contract:

Task 1: HQMC / MCICOM GF-PW Task 2: Marine Corps Installation East (MCI-East) Task 3: Marine Corps Installation West (MCI-West) Task 4: Marine Corps Installation Pacific (MCI-PAC) Task 5: National Capital Region (NCR) Task 6: G-4 Non-Tactical Vehicle Fleet

Within Task 1, the contractor is required to perform various tasks including the review of current USMC policy, instructions and guidance and identify updates and revisions necessary to comply with applicable Congressional Legislation, Presidential Directive, DoD, and Department of Navy (DoN) Instructions;

provide technical and analytical support to respond to inquiries from Congress, Government Accountability Office, and Naval Audit Services; provide technical, analytical, and administrative support to pla Investment Program (ERCIP) and provide technical and analytical support to develop and execute the USMC Energy Resilience Readiness Exercises (ERRE) Program.

requirements with Congressional statutes (i.e., 10 U.S. Code § 2911 and 10 U.S. Code § 2920) and Office of the Secretary of Defense (OSD), DoN, and USMC policies regarding energy security. Specifically, under Task 1, GF-PW requires added support including additional technical, analytical, and

Resilience and Conservation Investment Program (ERCIP); provide oversight of Energy Savings Performance Contracts (ESPC) and Utility Energy Service Contracts (UESC); and review and provide recommendations to update USMC Energy Projects Development Guidance to incorporate revised policy, new legislation, and Executive Orders and to clarify content and update supporting documents (e.g., Life Cycle Cost Analyses (LCCA)) with revised reference data.

As specified in Technical Exhibit A of the Performance Work Statement (PWS), the Marine Corps provided the labor categories and hours necessary to perform the required tasks. The contract includes twelve (12) different labor categories under Task 1 including one (1) Senior Energy Consultant. To support the added abovementioned taskings and new priorities, the Marine Corps has determined that an requirements of MCICOM as they currently serve in that capacity and have provided such support for over five (5) years of exceptional service.

CTC has performed the required tasks under this existing contract since 30 September 2023.

However, MCICOM has received similar support from CTC under a different contract with Naval Facilities Command (NAVFAC) for Energy Resilience to develop Installation Resilience Roadmaps (IRR). This contract was awarded to Risk Management Consulting (RMC). RMC subcontracted the project development work to CTC. MCICOM GF-PW is realigning resources from NAVFAC to the new priorities addressed by the subject increased scope through CTC with Marine Corps. The realignment of initiatives and projects through one Energy Support contract with CTC is the only way to achieve the required support without substantial duplication of cost to the Government which is not expected to be recovered through competition .

The previous referenced NAVFAC cost MCICOM approximately per option year and the estimated cost of this modification is only starting in option year three. These savings are achieved by reduction of unnecessary subcontracting, overhead fees, and unnecessary management fees when this work is executed as a modification with CTC under the current contract. By issuance of this contract modification, MCICOM will meet the contract requirements and save approximately per option year. Additionally, as discussed below, market research indicates that award to any other source will result in cost duplication.

Due to the exceptional capability, inherent cost savings, and immediate need to resource these requirements, MCICOM requires this sole source modification to CTC.

The additional FTEs will support the following new emergent needs, objectives, and priorities:

Japan ESPC: The regional Energy Service Performance Contract (ESPC) in Japan, valued at , with potential to be a project (largest ever ESPC in DoN), is nearing award. Per the Fiscal Year (FY) 2021 National Defense Authorization Act (NDAA), this project is the first to be executed in accordance with 10 U.S. Code § 2914(d) authority (military construction projects for energy resilience, energy security, and energy conservation). This project combines Energy Resilience and Conservation Investment Program (ERCIP) funds with ESPCs. The project is at a critical juncture with many issues to resolve, including incorporation of Planning and Design (P&D) funds into ESPC; securing Army Corps of Engineers involvement as the DoD executive agent of construction in Japan; conducting electrical modeling; reviewing technical documents;

assessing utility budgets; writing draft task order language, etc. This project is extremely important to the UMSC as it is in the Pacific Theater and the highest priority for the USMC and any potential failures or delays could result in cancelled projects and additional support is needed to ensure the project stays on timeline and is executed successfully.

ERCIP: GF-PW received roughly of new ERCIP P&D funds. This amounts to a nearly 20% increase compared to previous FYs. For program years FY25-30, MCICOM anticipates potentially receiving up to in ECRIP, which will necessitate significant management support. Additional Senior Energy Consultants are needed in order to ensure that GF-PW adequately plans and interfaces with NAVFAC regions. The additional contractor personnel will support preliminary design authority, final design authority, and ensure that progress aligns with MCICOM Energy Program overall objectives.

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Nuclear: GF-PW launched a new effort to implement small modular reactors at one or more installations. GF-PW is actively participating in Office of Secretary of Defense for Energy working group that is assisting with the initial project initiatives and plans. The project will result in meeting energy resilience and carbon free electricity requirements, as well as additional investments in the form of in-kind consideration. However, based on data from DoD agencies, the process from initial concept to operations can take between five-to-ten years to accomplish. GF-PW requires additional Senior Energy Consultants to assist with developing of the requirements, providing in-depth technology assessments, and coordinating with stakeholders to ensure long-term success.

Hydrogen: GF-PW recently launched a new effort to explore the use of hydrogen at one or more installations. Hydrogen will be used to generate stationary power in order to support energy resilience and carbon free electricity requirements. As part of this overall effort, GF-PW is currently involved with various federal agencies to help further the hydrogen program. For example, GF-PW has initiated a study with Marine Innovation Unit and is currently participating in the DoN Hydrogen Technical Planning Team. GF-

Technologies Office and is exploring grant opportunities as well as partnering with the DoE-funded Regional Hydrogen Hubs. Lastly, GF-PW recently engaged with an architect and engineering company to provide a detailed feasibility analysis through DoD Environmental Security Technology Certification Program (ESTCP). GF-PW requires additional Senior Energy Consultants to provide guidance and in-depth technology assessments, and coordinate stakeholders to ensure long-term success.

Offshore Wind: Off-shore wind leasing activities on the East Coast have opened up the potential for installations to secure funding in exchange for underutilized land to support deal with Naval Air Station Oceana for in-kind consideration in excess of .

Additional opportunities exist for some of Marine Corps installations. GF-PW requires additional Senior Energy Consultants to provide guidance and in-depth technology assessments, and coordinate stakeholders to ensure long-term success.

Advanced Battery Technologies: In order to support intermittent renewable energy technologies and improve energy resilience at Marine Corps installations, there have been major advancements in battery energy technologies. GF-PW is currently engaged in planning efforts for two non-Lithium-Ion battery technology solutions, leveraging investments of for a Vanadium Flow Battery and for a Zinc Halide Battery.

In addition, GF-PW is working on a ERCIP project at an installation to implement significant battery storage capabilities. GF-PW requires additional Senior Energy Consultants to provide guidance and in-depth technology assessments, and coordinate stakeholders to ensure long-term success.

Risk to Mission if not approved: Without additional support, USMC is at risk of not being able to execute and support the related projects mentioned above including ESPCs valued at , UESCs valued at , ERCIP valued at , and ERCIP P&D valued at . These funds and projects are intended to develop energy security capabilities and meet energy security requirements within DoD. In other words, OSD may cancel projects if DON and USMC are unable to properly execute these projects. This modification will bring the support to these projects to ensure they are executed on schedule and effectively to achieve the capabilities we

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(b) (1) (A) (b) (1) (A) (b) (1) (A) need. One example includes the P-143 project at MCAS Pendleton which was cancelled by OSD because USMC did not perform the proper coordination efforts. This cancelled project caused the USMC to lose $8M in opportunity investment in energy and utilities.

Additionally, in accordance with FAR 8.405-6(a)(2), the redacted justification will be posted to SAM.gov within 14 days after award.

C. ___ IN THE INTEREST OF ECONOMY AND EFFICIENCY, THE NEW WORK IS A

LOGICAL FOLLOW-ON TO AN ORIGINAL FEDERAL SUPPLY SCHEDULE ORDER

(FAR 8.405-6(a)(1)(i)(C)):

D. ___ ITEMS PECULIAR TO ONE MANUFACTURER (FAR 8.405-6(b)):

VI. DETERMINATION THAT THE ORDER OR BPA REPRESENTS THE BEST VALUE:

The Contracting Officer has determined that the order or BPA covered by this justification will represent the best value to the Government. Fair and reasonable pricing will be determined in accordance with DoD Class Deviation 2014-O0011 using the proposal analysis techniques at FAR 15.404-1.

VII. DESCRIPTION OF THE MARKET RESEARCH CONDUCTED AMONG SCHEDULE

HOLDERS:

Market Research: Synopsis Notice ID M95494-23-F-0013-P00003 was posted to SAM.gov on and included a statement that all responsible sources were permitted to submit a capability statement and that this notice of intent was not a request for competitive quotes.

One capability statement was received from a company who self-identified as a service-disabled veteran-company was not registered as a SDVOSB under the applicable NAICS code.

capabilities statement was reviewed by MCICOM, who determined that the respondent was not capable of performing the requirement in its entirety.

VIII. ACTIONS TAKEN TO REMOVE OR OVERCOME BARRIERS:

MCICOM will include the requirement for increased energy support in the future competition of the follow-on contract.

Distribution List for DL ONLY Limited Dissemination Control

MCFCS Personnel

LB Personnel

Procurement Team Personnel (to include but not limited to: Legal, Customers/Requirements Owners, Source Selection Personnel, Small Business Representatives)

Any other individual designated by the KO