McCrady_JA_Fort_Jackson_W9124C19C0004_Redacted.pdf

Fort Jackson JA2019-1

-1- “For Official Use Only”

JUSTIFICATION AND APPROVAL

FOR OTHER THAN FULL AND OPEN COMPETITION

1. Contracting Activity: MICC - Fort Jackson

2. Description of Action: Request for approval to award a one (1) year contract to the State of South Carolina, through their established non-profit agency, the 218th Regiment Dining Facility, for the Meal Support Service (MSS) in support of McCrady Training Center SC.

Nature: New Requirement Follow-on Requirement Mod to Existing Purchase Order/Contract Number

Pricing: Firm-Fixed Price Time & Materials Cost

Funds: OMA Other Funds:

Name of Proposed Contractor(s): 218th Regiment Dining Facility Street Address: 5411 Leesburg Rd.

City, State, Zip: Eastover, SC 29044-9184 Phone: 803-806-2241

3. Description of Services or Supplies:

The total estimated value of the proposed action is $ 458,290.00

Description of Supplies/Services: The South Carolina Army National Guard (SCARNG) operates the McCrady Training Center (McCrady), a cantonment area, which is located on the Southeastern corner of Fort Jackson, pursuant to a license granted under the authority of 32 U.S.C. § 503. Fort Jackson received a mission to train mobilized Individual Ready Reserve (IRR) soldiers in support of the Global War on Terrorism. It was determined that the best location for this training was at McCrady. The dining facilities at McCrady are operated by the Military Department of South Carolina, presently in accordance with South Carolina Appropriations Act, § 61.9. This operation is intended to be an "enterprise operation," a self-supporting organization, for the State of South Carolina. For contracting purposes the enterprise operation is doing business as", the 218th Regiment Dining Facility", hereinafter referred to as Contractor. This contract provides for Meal Support Services (MSS) from the McCrady Dining Facility (DFAC) under the Master Cooperative Agreement by the South Carolina Military Department, Deputy for State Operations. For this requirement, the contractor is required to provide all necessary resources to include labor, equipment, tools, materials, supervision, and other associated work necessary to serve IRR Soldiers meals within the State owned and operated DFAC. A Firm Fixed Price (FFP) contract is the best contract vehicle for this requirement.

4. Authority: 10 United States Code 2304(c)(1) as implemented in Federal Acquisition Regulation 6.302-1(a)(2)(iii)(B), Only one responsible source and no other supplies or services will satisfy agency requirements.

5. Reasons for Authority Cited:

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a. Reason for Authority Cited: Services are needed to satisfy requirements to feed soldiers at McCrady Training Center, SC without unacceptable delays. The current contract will expire on 31 December 2018. This requirement is not subject to the Randolph-Sheppard Act (R-SA) based on the fact that the DFAC on McCrady is completely managed and operated by the State of South Carolina.

b. The Army will provide the manpower and resources required to conduct selected combat skills training for Navy Individual Augmentees at the McCrady Training Center in order to prepare Sailors to execute mission ISO CENTCOM/AFRICOM. Due to the nature of the 218th Regiment Dining Facility operating as a non-profit entity, pricing must be based on the previous year’s contract and future year’s forecasted expenses to ensure contract pricing is as close to actual operating cost as possible. Based on this strategy, the State of South Carolina comptroller’s office mandates that pricing be established a year at a time. Therefore, the contract must be awarded on a yearly basis.

The current strategy is to implement a FFP contract for MSS operations at McCrady.

c. Alternatives:

(1) Suspension of Food Program Services: The services procured by this contract are tied directly to the mission success of the Department of Defense and cannot cease without a negative impact on the mission of the Army and Fort Jackson. The services procured support Fort Jackson's mission to train mobilized IRR soldiers and Navy Sailors in support of Overseas Contingency Operations. As a result, the suspension of FFS is not a viable option.

(2) Use of In House Resources: The L o g i s t i c s R e a d i n e s s C e n t e r ( LRC) Fort Jackson does not have the personnel or resources to continue the mission. Per AR 30-22, The Army Food Program, paragraph 3-42(c) (2), permanent party soldiers (military) are not allowed to perform dining facility attendant functions on a regular detail basis without prior approval from Headquarters, Department of the Army. McCrady Training Center has a minimal population of permanent party soldiers and therefore does not have the capability of providing food service. There are no military occupational specialty (MOS 92G10) food service specialists or noncommissioned officers (MOS 92G20-40) assigned to Fort Jackson to perform as cooks, making it impossible to provide services with internal resources.

(3) Use of Catered Meals to Feed Soldiers: AR 30-22 paragraph 3-44 authorizes commercially prepared catered meals only when food service personnel or equipment are not authorized or available, and support cannot be obtained from another Reserve Component or Active Army unit with food service capability. Request to purchase catered meals must be approved by the Deputy, Chief of Staff, G-4 for the Department of the Army. The Army G-4 is highly unlikely to approve catered meals, as using catered meals to feed the Soldiers opens the potential risk of violating the USC Title 10, Section 2533a (The Berry Amendment).

(4) Transport meals from the Ft. Jackson DFACs: It is impractical to attempt to transport meals from existing dining facilities on Fort Jackson. The drive to the location is approximately 40 minutes each way (1 Hr 20 Min round trip). The Soldiers training are on a tight schedule to ensure Soldiers are trained on required tasks prior to deployment to combat areas. The transportation time coupled with the 1 Hr 30 Minute serving time does not provide the required flexibility to the training unit to accomplish their mission without delays caused by feeding. The quality of meals provided through remote feeding is subpar compared to meals freshly prepared in a dining facility. This is not the type of meal service desired by the Commander in support of Soldiers preparing for deployment in combat areas.

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(5) Bus personnel back and forth from Ft. Jackson DFACs: It is impractical to attempt to transport Soldiers back to existing dining facilities on Fort Jackson. The drive to the location is approximately 40 minutes each way (1 Hr 20 Min round trip). The Soldiers training are on a tight schedule to ensure Soldiers are trained on required tasks prior to deployment to combat areas. The transportation time coupled with the 1 Hr 30 Minute serving time does not provide the required flexibility to the training unit to accomplish their mission without delays caused by feeding. In a day, 8.5 hours would be used just to feed Breakfast Lunch and Dinner meals.

(6) Establish a new DFAC operation for TFM Soldiers on McCrady: There are no available facilities to meet the short term (2YR) requirement to feed Soldiers at McCrady Training for Deployment as part of Task Force Marshall. The time and resources required to establish facilities is not feasible and cannot be funded with the accompanying OMA funds used to support this mission.

(7) Have another contractor operate from the current 218th Regiment Dining Facility DFAC:

The State of South Carolina will not allow for a private contractor to use its facilities.

The support provided by the State is the most cost effective and current support provider.

The DFAC is operated by the State non-profit owned entity, 218th Regiment Dining Facility.

(8) Enter into direct negotiations with the State of South Carolina, doing business as the 218th Regiment Dining Facility, a non-profit entity of the state of South Carolina. The 218th Regiment Dining Facility is currently providing FFS under ISA as the non-profit performing contractor for the State of South Carolina. They have both the manpower and the resources to adequately perform these mission critical services. This is the best value to the Government without additional administrative burden or cost. There is no other capacity available to feed an average population of over 3,000 Soldiers three meals a day.

d. Justification: It is essential that MSS operations are sustained without disruption to satisfy the requirement to feed Soldiers. Presently, there is no known source that could provide performance in the existing State run DFAC on McCrady. The State of South Carolina will not allow for a private contractor to use its facilities. Hence, to solicit from another source would cause unacceptable disruption to food service operations. A delay in services or intermediate change of contractor will disrupt critical mission operations and cause the Government to incur significant costs. It is more advantageous to the Government to continue the contract services with the 218th Regiment Dining Facility through another 12 month contract.

In accordance with FAR 6.302-1(a)(2)(iii), the 218th Regiment Dining Facility is the only logical source available that will satisfy the continued food service requirements FFS at McCrady Training Center. Awarding to other than the 218th Regiment Dining Facility would not be realistic or ·cost effective due to startup costs, manning problems including recruitment, and possible relocation fees associated with awarding to other than the incumbent.

e. Impact: The magnitude and complexity of management and operation of food services performed under this contract require a minimum of a 30 day phase-in period for a new contractor.

Furthermore, if awarded to other than the 218th Regiment Dining Facility, a new contractor would be required to recruit, mobilize and train at least 30 plus personnel to meet the current mission.

Awarding an interim to other than the 218th Regiment Dining Facility would not be realistic or cost effective due to the manning problems that may include recruitment and possible relocation fees

-4-associated with awarding to other than the incumbent. Possible start-up costs and delays include:

inventory of Government equipment in each facility; uniform costs for employees and staff; on-site and home office set-up to include operational fees; vehicle start-up costs; equipment purchase or rental fees; computer compliance costs to operate on Government provided networks; and initial sanitation training certificates. Additionally, we do not own the current facility nor can we utilize the SCNG facility that they currently have their NG Soldiers eating in without contracting with the SCNG/USPFO. There are no other facilities on the SCNG compound (McCrady) that can be provided by the SCNG to be used by a separate contractor.

6. Actions to Increase Competition: At this time no other vendors can provide MSS at the State operated facility. A sole source synopsis notice will be posted on FedBizOpps on 6 December 2018 that includes a draft performance work statement.

7. Market Research: Extensive market research has been conducted for this requirement. On 19 November 2018, a market research report was completed and signed by the Contracting Officer. The Contracting Officer determined that it is impractical to award a competitive contract due to the requirement on McCrady being a State ran dining, the ability to perform for the State.

Every effort was made in the past to obtain competition for this requirement.

8. Procurement History:

Previous Purchase Order(s) or Contract(s): Yes No

Purchase order or contract number: W9124C-18-C-0005 Was action competed? Yes No

The previous Meal Support Contract was awarded after direct negotiations with the South Carolina Adjutant General’s Office who operates the 218th Regiment Dining Facility.

The previous authority cited was 10 USC 2304 (c) (I), as implemented by FAR 6.302-1, Only One Responsible Source and No Other Supplies or Services will satisfy agency requirements.

9. Additional Information to support the justification. None

10. Technical / Requirements Certification: I certify that the supporting data under my cognizance which is included in this abbreviated J&A is accurate and complete to the best of my knowledge and belief.

11. Fair and Reasonable Price Determination: As contracting officer, I hereby determine that the anticipated cost to the Government for this contract action will be fair and reasonable based upon price analysis, comparison of proposed prices with an independent government estimate, -5-and negotiations. Certified cost and pricing data will not be obtained in accordance with FAR 15.403-1(b)(3).

12. Review: I have reviewed this justification and have no legal objection.

13. Contracting Officer’s Approval: I hereby certify that this justification is accurate and complete to the best of my knowledge and belief. Based on the foregoing, I approve this sole source justification subject to availability of funds, and provided that the services and supplies herein described have otherwise been authorized for acquisition.

Name: Kimberly C. Marsh

Contracting Officer US Army Mission and Installation Contracting Command, Fort Jackson SC