SIGNED - CUI_Cavazos JA 2025_29_Redacted.pdf

Control No: MICC 2025-29

JUSTIFICATION REVIEW DOCUMENT

FAR 6 JUSTIFICATION AND APPROVAL FOR OTHER THAN

FULL AND OPEN COMPETITION

Program/Equipment: United States Army Test and Evaluation Command (ATEC) White Sands Test Center requires Test Engineering and Analysis Support (TEAS) services to support testing for Department of Defense (DoD) program offices at White Sands Missile Range (WSMR).

Authority: 10 U.S.C. 3204(a)(1) as implemented by FAR Part 6.302-1 - Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.

Amount:

Prepared by:

Contracting Officer:

Technical:

Requirements:

Reviews: I have reviewed this justification and find it adequate to support other than full and open competition.

FAR Part 6 Justification and Approval for Other than Full and Open Competition

1. Contracting Activity: United States Army Mission and Installation Contracting Command - Fort Cavazos (MICC-CV), White Sands Missile Range (WSMR) Branch, 143 Crozier Street, White Sands, NM 88002.

2. Description of Action: The United States Army Test and Evaluation Command (ATEC) at White Sands Test Center (WSTC), New Mexico requests a Cost-Plus-Fixed- Fee modification for approval of a four-month extension to the Test Engineering and Analysis Support (TEAS) 5-year Cost-Plus-Fixed-Fee contract (W91151-18-C-0013) with TNT Premier Partnership, LLC, 9180 Socorro Rd, El Paso TX, 79907-6645. This is an interim action to allow continued performance with the incumbent contractor. The current contract period of performance will end on 28 February 2025. The follow-on requirement is in the process of an 8(a) procurement and an extension to the contract is needed until the competitive follow-on 8(a) requirement can be awarded which is currently projected for 27 May 2025. The Government projects award of this extension to start on 1 March 2025. There is no change in scope to the work to be performed. The extension will be incrementally funded through modifications using appropriate Fiscal Year (FY) Research, Development, Test & Evaluation (RDT&E) funds.

This document is requesting continuation of TEAS services as performance will end under contract W91151-18-C-0013 on 28 February 2025. The FAR Clause 52.217-8 has been exercised on this contract. A J&A was subsequently signed by the MICC DCG approving performance through 28 February 2025. At that time this J&A was signed, this requirement had been transferred from MICC-Fort Carson, who was initially assigned the procurement, to MICC-Fort Cavazos in May 2023. Due to a diminished staff at MICC-Fort Cavazos, the requirement was once again transferred to the newly created MICC-Theater Support Center (MICC-TSC) contracting office in May 2024.

Since that transfer, the MICC-TSC finalized the performance work statement, completed and obtained the approval of the acquisition strategy, released the solicitation, and completed the initial evaluation of proposals.

The four-month extension is needed to prevent a break-in-service and provide the follow-on procurement sufficient time to conduct discussions, award the follow-on contract, and allow a 30-day transition between incoming and outgoing contractors.

Therefore, an extension of the existing contract with the current incumbent is necessary.

3. Description of Supplies/Services: The TEAS contract supports WSTC by providing the short-staffed Government workforce with contractor support personnel and by providing a means of acquiring short-term specialty skills. The TEAS contract provides non-personal services for test engineering, analysis, and support of the WSMR mission, its tenants, and the ATEC Organizations. The services include test planning consisting of: coordination, execution, and reporting of test results; data collection, entry and analysis; engineering and technical support; software analysis; software development;

1) Suspension of Contract Support. The TEAS requirement is ongoing and critical to mission accomplishment. Suspension of contract support will cause critical disruption to the ATEC-WSMR mission and would significantly impact scheduled operational tests, established program milestones, and program costs resulting in the delay or stoppage of the latest technology improvements for warfighting weapons systems for DoD. Therefore, this alternative is not viable, nor in the Government’s best interest.

2) Use of In-House Resources. ATEC-WSMR lacks sufficient manpower, technical expertise, and resources to perform the required TEAS functions. The United States Army does not contemplate acquiring adequately trained personnel within the Government in the future. Attempting to initiate actions to increase the Government workforce to accomplish this mission would take years and result in multiple mission failures during the time required to adequately recruit and staff a trained workforce.

Therefore, this alternative is not viable, nor in the Government’s best interest.

3) Conduct a competitive procurement for this interim 4-month period. There is insufficient time to competitively solicit, evaluate, and award a new contract, phase-in a new contractor, transfer and account for Government Furnished Property inventory, obtain security clearances, and allow for familiarization with tests. Additionally, there would be significant degradation in test support as contractors transition during testing.

Any contractor other than the incumbent does not have sufficient knowledge and trained manpower readily available on short notice to seamlessly assume the performance of these ongoing tests and services. An award to any other source would result in unacceptable delays ranging up to four-months in fulfilling the ATEC mission.

Furthermore, this action is a temporary solution to facilitate the transition of this requirement to the follow-on competitive 8(a) award. Therefore, this alternative is not viable, nor in the Government’s interest.

4) Issue a modification to the existing contract to extend service with the incumbent contractor. Award to any other source would result in a delay in fulfilling the agency’s requirements and would not be in the best interest of the Government.

c. Impact if justification not approved: Disapproval of the 4-month extension will result in a lapse in service and jeopardize WSMR’s mission to provide RDT&E, experimentation, assessment and training services to the Army, Navy, Air Force, other DoD and Government agencies, and industry.

6. Efforts to Obtain Competition: The Contracting Officer shall publish the notices required by FAR 5.201 and any bids or proposals received shall be considered.

a. Effective Competition: Because this is a sole source action, effective competition is not applicable.

11. Technical Certification: I certify that the supporting data under my cognizance which are included in the justification are accurate and complete to the best of my knowledge and belief.

12. Requirements Certification: I certify that the supporting data under my cognizance which are included in the justification are accurate and complete to the best of my knowledge and belief.

13. Fair and Reasonable Cost Determination: I hereby determine that the anticipated cost or price to the Government for this contract action will be fair and reasonable. This determination will be made using Cost Analysis and Certified Cost and Pricing data, IAW FAR 15.404-1(c) and FAR 15.403-4. As a part of this basis, certified cost and pricing data will be required due to this being a non-competitive, non-commercial action exceeding the threshold for obtaining certified cost and pricing data established in FAR 15.403-4(a)(1).

14. Contracting Officer Certification: I certify that this justification is accurate and complete to the best of my knowledge and belief.

Approval

Based on the foregoing justification, I hereby approve the procurement of Test Engineering and Analysis Support services on another than full and open competition basis pursuant to the authority of Title 10 United States Code Section 3204(a)(1) - Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements. The estimated value of the contract is for 4 (four) months from approximately 1 March 2025 through 30 June 2025. The approval is subject to availability of funds, and provided that the services or supplies herein described have otherwise been authorized for acquisition.

SCOTT D. KUKES

Alternate Advocate for Competition U.S. Army Mission and Installation Contracting Command, JBSA Fort Sam Houston, TX